HomeMy WebLinkAboutStaff Report 252-10TO: HONORABLE CITY COUNCIL
FROM: CITY MANAGER DEPARTMENT: PUBLIC WORKS
DATE: JUNE 7,2010 CMR:252:10
REPORT TYPE: CONSENT
SUBJECT: Adoption of an Ordinance Repealing Chapter 1().09 of the Palo Alto
Municipal Code and Amending Title 16 to Adopt a New Chapter 16.09
(Sewer Use Ordinance) Establishing Regulations to Reduce Discharges
of Pollutants to the Sanitary Sewer and Storm Drainage Systems
RECOMMENDATIONS
Staff recommends that Council adopt the attached Ordinance (Attachment A) repealing Chapter
16.09 of the Palo Alto Municipal Code and adopting a new Chapter 16.09 (Sewer Use
Ordinance).
BACKGROUND
The City of Palo Alto operates the Regional Water Quality Control Plant, a wastewater treatment
plant, for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo
Alto, and Stanford'University. Wastewater from these jurisdictions is treated by the Regional
Water Quality Control Plant prior to discharge to the Bay. Storm water runoff in Palo Alto flows
directly to the Bay without treatment. Wastewater and storm water discharges are both regulated
by the United Stated Environmental Protection Agency via National Pollutant Discharge
Elimination System permits issued by the San Francisco Bay Regional Water Quality Control
Board. Given the strict permit requirements, Palo Alto is continually exploring methods for
reducing pollutant discharges to San Francisco Bay, including new storm water and industrial
pretreatment and pollution prevention requirements.
The attached Ordinance contains a number of amendments and additions to the current Sewer
Use Ordinance. The changes fall into the following categories:
1. Clarification and reorganization of existing language;
2. Incorporation of standard language from the United Stated Environmental Protection
Agency model Ordinance;
3. Incorporation of new language from the United Stated Environmental Protection
Agency Pretreatment Streamlining Rule;
4. Incorporation of changes required to correct deficiencies identified during Regional
Water Quality Board audits;
5. New or expanded requirements.
The majority of the changes fall into the first four categories. They are administrative in nature
and do not significantly change the policies or implementation of the program. The following
table lists some of the key proposed changes.
Key Changes Proposed Ordinance Change
Cyanide Lower discharge limit for cyanide changed from 1.0 to 0.5 mgIL
Zinc, Molybdenum Prohibits cooling tower chemicals containing zinc or molybdenum
Non-Compliance and Spill Expand this section to include storm drain violations in addition to
Reporting and Actions sanitary sewer violations.
Facility Closure Requirements for cleaning, inspection and testing of sewer system
upon closure of industrial facilities are expanded to include
commercial facilities.
Certain carwash facilities Carwash facilities to storm drain prohibited for multi family
prohibited. residential units and residential developments expanded to include
existing facilities as well as new ones.
Food Service Create the requirement to use grease control device maintenance
Establishments services provided by City permitted vendors. Expands and codifies
Best Management Practices.
General Modified language to group related topics, use consistent language
in all sections and delete past implementation dates.
Staff have conducted outreach and solicited comments regarding the proposed Ordinance
changes from permitted commercial and industrial facilities in the service area, City of Palo Alto
departments, the Palo Alto Chamber of Commerce, and other interest groups. Copies of the
proposed Ordinance were provided to each Food Service Establishment and each permitted
facility. A public meeting was held to review the proposed changes with the Regional Water
Quality Control Plant's permitted facilities and the Food Service Establishments in 2009. In
addition, staff attended a meeting of the Environmental Health and Safety Forum Group, and
held a meeting with Stanford University representatives. Comments were received from several
permitted facilities and from the Environmental Health and Safety Forum group. A small number
of changes have been incorporated into the proposed Ordinance language as a result of public
involvement in the Ordinance adoption process.
DISCUSSION
A summary of the key proposed Ordinance provisions is provided below. The key provisions are
those that are expected to have the most significant impact on the regulated community, and
which have been reviewed and discussed most extensively in our public outreach process. The
majority of the additional modifications are not substantive in nature. Due to the large scale of
the amendment to the existing Ordinance a redline version is not practical and thus not provided.
However, the attached Ordinance Change List (Attachment B) lists the key provisions as well as
all other changes that have warranted less attention and those that are mainly administrative in
nature. Finally, the attached Ordinance contains all of the provisions.
Cyanide Discharge Limit (16.09.040(q))
The proposed Ordinance section would lower the cyanide concentration limit for industrial waste
discharges from 1.0 milligrams per liter (mg/L) to 0.5 mg/L. The Regional Water Quality
Control Plant conducted a local limits evaluation in 2006. The change in the cyanide limit is
CMR:252:10 Page 2 of4
based upon the attached memorandum (Attachment C), which describes the process utilized to
derive the new limit. The new limit would apply to all industrial waste discharges to the sanitary
sewer. The Sunnyvale and San Jose treatment plants, which together with Palo Alto comprise
the three lower South San Francisco Bay dischargers, already have cyanide limits of 0.5 mg/L.
Zinc or Molybdenum Containing Cooling Tower Chemicals (16.09.205)
The proposed Ordinance provision addressing zinc and molybdenum containing cooling tower
chemicals would reduce zinc and molybdenum loading to the sanitary sewer system from
cooling tower activities. The majority of cooling towers are located in industrial and commercial
facilities that are regulated by the Public Works Department's Environmental Compliance
Division. Zinc is a pollutant of concern, due to its identification as a source of toxicity in the
Regional Water Quality Control Plant's treated effluent to the Bay. Molybdenum is a pollutant
of concern due to its presence in the Plant's incinerator ash which restricts its use for application
as a fertilizer to pasture land and ruminant feed crops. Molybdenum and zinc-free cooling tower
treatment chemicals are available.
Spill Reporting (16.06.140)
The proposed Ordinance modification would expand existing spill reporting and corrective
measures for sanitary sewer discharges to include spills that threaten the storm drain system. The
section includes requirements for notification as well as taking immediate steps to stop, contain,
and clean spills.
Closure Requirements (16.09.110)
The proposed Ordinance provision is intended to address contaminated treatment equipment,
broken sewer lines and contaminated sediments in sewer lines at industrial and commercial
facilities during the facility closure process. The provision would allow the Regional Water
Quality Control Plant to require testing of sewer lines to ensure their integrity in cases where the
facility had a history of pH violations or other discharges that could affect sewer lines. Testing
to determine the quantity and pollutant content of sediments could be required based upon the
type of operation at a facility and the historical pollutant discharges from the facility. Where
broken. sewer lines are identified, facilities would be required to repair or replace them. Where
contaminated equipment or sediments are identified, facilities would be required to remove them
in an approved manner.
Covered Vehicle Washpad Areas (16.09.106(f)
Starting in 2003 all new residential buildings with 25 or more units were required to provide a
vehicle wash pad to reduce discharges of pollutants from vehicle washing to the storm drain
system. Each new building subject to the provision is required to provide a covered vehicle wash
pad area for use by residents. The areas are designed to prevent water runon and runoff. The
drains for the areas are connected to an oil/water separator with a minimum 100 gallon capacity,
and to the sanitary sewer. This section of the Ordinance has been modified to clarify that the
requirement applies to residential development projects as well as to residential buildings with
25 or more units. This section has been modified to prohibit existing buildings or developments
from providing a vehicle wash pad that discharges to the storm drain system.
Food Service Establishment Requirements (16.09.075)
The new requirements for Food Service Establishments expand and clarify existing Food Service
Establishment regulations and codify best management practices and other measures that have
CMR:252:10 Page 3 of4
been established to protect storm water and to reduce the amount of Fats, Oils and Grease
(Grease) discharged to the collection system. Grease in the collection system can lead to
blockages and discharges of untreated wastewater. The section also requires Food Service
Establishments to use a City permitted grease hauler, if available, for cleaning and grease
removal from grease control devices. Staff is considering development of a program that would
permit one or more grease haulers. This program may be presented to Council for consideration
in the near future. The hauler program would reduce green house gasses by minimizing truck
trips, would help ensure compliance by providing standardized service, and will allow for better
tracking of the collection and ultimate disposal of grease waste.
RESOURCE IMPACT
There are no anticipated incremental resource impacts.
POLICY IMPLICATIONS
The recommended. Ordinance adoption is consistent with the goals and policies stated in the Palo
Alto Comprehensive Plan. The applicable policies are as follows:
Natural Environment Policy N-21:
Reduce non~point source pollution in urban runoff from residential, commercial, industrial,
municipal, and transportation land uses and activities.
Natural Environment Policy N-25:
Reduce pollutant levels in City wastewater disch,arges.
ENVIRONMENTAL ASSESSMENT
The adoption and implementation of this Ordinance is exempt from the California Environmental
Quality Act under Guideline 15308 (actions by regulatory agencies for the protection of the
environment).
ATTACHMENTS
Attachment A: Ordinance
Attachment B: Ordinance Change Summary
Attachment C: Limit Development Memorandum
PREPARED BY:
DEPARTMENT HEAD:
][, E]mnJlJl pro~s
GLENN S. ROBERTS
Director of Public Works
CITY MANAGER APPROVAL:
CMR:252:1O Page 4 of4
follows:
ATTACHMENT A
NOT YET APPROVED
Ordinance No. ---
Ordinance of the Council of the City of Palo Alto Repealing
Chapter 16.09 of the Palo Alto Municipal Code and Amending
Title 16 to Adopt a New Chapter 16.09 (Sewer Use
Ordinance) Establishing Regulations to Reduce Discharges of
Pollutants to the Sanitary Sewer and Storm Drainage Systems
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as
(A) In order to protect the public health and environment, including the City's
sanitary sewer collection system, the Palo Alto Regional Water Quality Control Plant, and San
Francisco Bay, the City has developed and implemented a water quality control program;
(B) Protection of the sanitary sewer collection system, the treatment plant, and
San Francisco Bay also requires strict control of industrial wastewater discharges and all types of
contaminated water which would otherwise flow to the storm drain system, creeks, and San
Francisco Bay;
(B) The adoption of this Sewer Use Ordinance is a component of the City's
water quality control program and supports the City's authority to implement state and federally
mandated storm water, pollution prevention, and industrial waste pretreatment programs;
(C) The City desires to maintain and enhance its leadership position in
reducing pollutant loadings to natural water bodies to the maximum extent practical, while still
maintaining a heathy and vibrant business community; and
(D) In order to continue to address new pollutants of concern and pollutant
sources, City staff shall inform the Council of the need for further controls on industrial,
commercial and residential wastewater and storm water discharges.
SECTION 2. Chapter 16.09 (Sewer Use Ordinance) of Title 16 (Building) of the
Palo Alto Municipal Code is hereby repealed in its entirety and restated as follows:
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100520 syn 6051181
Sections:
16.09.005
16.09.010
16.09.015
16.09.020
16.09.025
16.09.030
16.09.035
16.09.040
16.09.045
16.09.050
16.09.055
16.09.060
16.09.065
16.09.070
16.09.075
16.09.080
16.09.085
16.09.090
16.09.095
16.09.100
16.09.105
16.09.110
16.09.115
16.09.120
16.09.125
16.09.130
16.09.135
16.09.140
16.09.145
16.09.150
16.09.155
16.09.160
16.09.165
16.09.170
16.09.175
100520 syn 6051181
NOT YET APPROVED
Chapter 16.09
SEWER USE ORDINANCE
Purpose and Applicability
Definitions
Responsibility of the Superintendent
Confidentiality
Alternative Materials and Methods
Limitationws on Point of Discharge
Prohibitions
Standards
Additional Copper Limitations for Industrial Waste
Grease disposal Prohibited
Unpolluted Water
Standards for Other Industrial Wastes
Best Management Practics (BMPs)
Trucker's Discharge Permit
Food Service Establishments
Industrial Waste Discharge Permit
Industrial Wastes Discharge Permit Procedures
Requirements for Facilities Affected by National Pretreatment Standards
Modification, Suspension or Revocation of Industrial Wastes Discharge
Permit Issuance, Denial, Modification, Revocation, or Suspension Hearing
Waste Sampling Locations
Discharger Monitoring
Prohibition against Dilution
Discharger Self-Monitoring
Maintenance and Operation of Pollution Control and Monitoring
Equipment
Compliance with the Pretreatment Requirements
Reporting Requirements for all Permitted Dischargers
Requirments for Reporting Noncompliance, Increased Loading, Slug
Discharges, Accidential Discharges
Certification of Reports
Falsification of Information
Date of Receipt of Reports
Retention of Records
Storm Drain System: Prohibited Discharges
Requirements for Construction Operations
General Prohibitions and Practices
2
16.09.180
16.09.185
16.09.190
16.09.195
16.09.200
16.09.205
16.09.210
16.09.215
16.09.220
16.09.225
16.09.230
16.09.235
16.09.240
16.09.245
16.09.250
16.09.255
16.09.260
16.09.265
16.09.270
16.09.275
16.09.280
16.09.285
NOT YET APPROVED
Requirements for Newly Constructed, Remodeled or Converted Multi
Residential, Commercial and Industrial Facilities
Personnel Orientation
Accidental Discharges Prevention
Storage of Hazardous Materials Above Sinks
Zinc-Containing Floor Finishes
Requirements for Cooling Systems, Pools, Spas, Fountains, Boilers and
Heat Exchangers
Root and Pest Control Chemicals
Requirements for Photographic Materials Processing
Requirements for Dental Facilities that Remove or Place Amalgam
Fillings
Requirements for Vehicle Service Facilities
Requirements for Machine Shops
Annual Publication of Significant Noncompliant Dischargers
Enforcement: Warning
Enforcement: Notice of Noncompliance
Enforcement: Administrative Compliance Order
Enforcement: Criminal Penalties
Enforcement: Administrative Citation
Enforcement: Administrative Civil Penalties
Enforcement: Judicial Civil Penalties
Damage to Facilities
City Right to Terminate Discharge
Enforcement: Remedies Nonexclusive
16.09.005 Purpose.
The overall goal of this Chapter and the City's water quality control program is to prevent
and control pollution and protect and foster human health and the environment. The specific
purpose of this Chapter is to prevent the discharge of any pollutant into the sanitary sewer
system, the storm drain system, or surface waters, which would: 1) obstruct or damage the
sanitary sewer or storm drain system; 2) interfere with, inhibit or disrupt the Palo Alto Regional
Water Quality Control Plant (the "plant"), or its treatment processes, or operations, or its sludge
processes, use or disposal; 3) pass through the treatment system and contribute to violations of
the regulatory requirements placed upon the plant; or 4) result in or threaten harm to or
deterioration of human health or the environment. It is the intent of the City to update and
modify this Chapter as needed to continue to provide a program for protection of the storm drain
system and pretreatment of industrial wastes which is approved by federal and state regulatory
agencies. Therefore this Chapter is designed to be no less stringent than the U.S. Environmental
Protection Agency "General Pretreatment Requirements for Existing and New Sources of
Pollution" published at Title 40 of the Code of Federal Regulations (CFR), Part 403 and The
Federal Water Pollution Control Act, 33 U.S.c. section 1251, as applicable, and as such
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100520 syn 6051181
NOT YET APPROVED
requirements may be amended from time to time (hereinafter the "Pretreatment Requirements"
and "Clean Water Act").
16.09.010 Definitions.
The following words and phrases, whenever used in this Chapter, shall be as defined herein.
Words, terms and phrases used in this Chapter not otherwise defined shall be as defined or
interpreted or used in the Pretreatment Requirements. Terminology for analytical testing shall be
that contained in "Guidelines Establishing Test Procedures for the Analysis of Pollutants,"
published at Title 40 CFR, Part 136.
"Annual average concentration" means the average concentration of a substance
measured over any twelve-month period of time.
"Authorized Representative" means an authorized or duly authorized representative as
defined below:
(a) If the discharger is a corporation:
(1) The president, secretary, treasurer, or a vice-president of the
corporation in charge of a principal business function, or any other person who performs similar
policy or decision-making functions for the corporation; or
(2) The manager of one or more manufacturing, production, or
operating facilities, provided the manager is authorized to make management decisions that
govern the operation of the regulated facility including having the explicit or implicit duty of
making major capital investment recommendations, and initiate and direct other comprehensive
measures to assure long-term environmental compliance with environmental laws and
regulations; can ensure that the necessary systems are established or actions taken to gather
complete and accurate information for discharge permit requirements; and where authority to
sign documents has been assigned or delegated to the manager in accordance with corporate
procedures.
(b) If the discharger is a partnership or sole proprietorship: a general partner
or proprietor, respectively.
(c) If the discharger is a federal, state, or local governmental facility: a
director or highest official appointed or designated to oversee the operation and performance of
the activities of the government facility, or their designee.
(d) The individuals described in paragraphs (a) through (c), above, may
designate a Duly Authorized Representative if the authorization is in writing, the authorization
specifies the individual or position responsible for the overall operation of the facility from
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1005208yn 6051181
NOT YET APPROVED
which the discharge originates, or with overall responsibility for environmental matters for the
organization, and the written authorization is submitted to the Superintendent.
"Average concentration" of a substance means the total daily discharge weight of the
substance divided by the total daily wastewater volume at the point of discharge.
"Berm" means a ridge, lip or other raised barrier to the flow of liquid which is not
rendered ineffective by the liquid and is sufficiently high to contain anticipated fluid amounts, or
which causes sufficient grade to prevent migration of anticipated fluid amounts.
"Best Management Practices!! or "BMPs" means schedules of activities, prohibitions of
practices, maintenance procedures and other management practices to implement the
prohibitions in this Chapter. BMPs include treatment requirements, operating procedures and
practices to control plant site runoff, spillage or leaks, sludge or waste disposal or drainage from
materials storage.
"Biochemical Oxygen Demand" or "BOD" means the quantity of oxygen utilized in the
bio<;:hemical oxidation of organic matter under standard laboratory procedures.
"Categorical Pretreatment Standard!! means any regulation containing pollutant discharge
limits promulgated by EPA that apply to a specific category of dischargers and that appear in 40
CFR Chapter I, Subchapter N, Parts 405 -471.
"Categorical Discharger" shall mean any discharger subject to categorical Pretreatment
Standards.
"Cesspool" means a lined or partially lined underground pit into which raw sanitary sewage is
discharged.
"City" means City of Palo Alto
"Collection system" means the pipes, junction boxes, channels and other conveyance
apparatus used to move storm water or sewage.
"Cooling system blowdown" means water routinely discharged from a cooling water
system to maintain efficient operation of the system.
"Cooling water" means water which is used to cool fluids or equipment in commercial or
industrial processes or air conditioning systems.
"Cooling water system" means the pipes, heat exchangers and other appurtenances used
to convey cooling water in cooling towers, direct contact cooling systems and similar fixed
)
cooling systems. Multiple units of a cooling water system serving a building or piece of
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100520 syn 6051181
NOT YET APPROVED
equipment are considered as one system if the cooling water distribution system units are
physically connected.
"Contaminated groundwater" means water found beneath the earth's surface which does
not meet State or Federal standards for drinking water supplies or other specified beneficial uses.
"Contaminated. water" means water that does not meet State or Federal standards for
discharge to navigable waters.
"County" shall mean the County of Santa Clara.
"Cycles of concentration" means the flow rate of water added to a cooling tower water
system divided by the flow rate of water discharged from the cooling tower.
"Discharge" means the introduction of any pollutant or of any industrial, commercial or
domestic waste into the sanitary sewer system or storm drain system.
"Dischargertt means any person or entity who has the potential to or who discharges,
causes, or permits the discharge of any pollutant or of any industrial, commercial or domestic
waste into the sanitary sewer system or storm drain system.
"Domestic waste" means the liquid and waterborne wastes derived from the ordinary
living processes, free from industrial wastes and of such character as to permit satisfactory
disposal, without special treatment, into the sewer system.
"Enforcement Response Plan" or "ERP" means the document describing the guidelines
for identifying violations of and enforcing specific local limits; Pretreatment Standards and
requirements; and the requirements of this Chapter.
"EPA" means the United States Environmental Protection Agency,.
"Exceptional waste" means that subset of industrial waste specified m Section
16.09.080(c)(2) ofthis Chapter.
"Fail-safe valve" means a gravity, spring loaded or electrically driven valve that is
normally closed. The valve can be opened by continuously applying pressure or depressing a
switch mechanism that automatically closes the valve when not in use or depressed.
ttGrease" means, and includes, fats, oils, waxes or other related constituents. Grease may
be of vegetable or animal origin, including butter, lard, margarine, vegetable fats and oils, and
fats in meats, cereals, seeds, nuts and certain fruits. Grease may also be of mineral origin,
including kerosene, lubricating oil, and road oil. Grease in the sanitary sewer system is generally
present as, but need not be, a floatable solid, a liquid, a colloid, an emulsion, or in a solution.
6
100520 syn 6051181
NOT YET APPROVED
"Hazardous material" means any material so designated by Title 17 of this code.
"Hazardous waste" means a material designated as a hazardous waste by either State or
Federal regul~tions.
"Industrial waste" means the waste or wastewater from any production, manufacturing or
processing operation of whatever nature including institutional and commerciaL "Industrial
waste" shall not include domestic waste. "Industrial waste" shall include contaminated water
from construction operations, contaminated water from erosion of disturbed land, and
contaminated water from irrigation runoff.
"Interference" means a discharge that, alone or in conjunction with a discharge or
discharges from other sources, inhibits or disrupts the Plant, its treatment processes or
operations, or its sludge processes, use or disposal, or exceeds the design capacity of the sanitary
sewer system.
"Loading dock" means that area of a facility intended for the loading and unloading of
trucks, plus an additional radius of ten feet.
"Machine shop" means a fixed facility which cuts, grinds, polishes, deburrs, or machines
metal parts but does not conduct metal finishing as that term is defined by the EPA in 40 CFR
part 433.
"Metal fabrication facility" means a fixed facility that forms, welds and assembles metal
pieces, but does not conduct metal finishing as that term is defined by the EPA in 40 CFR part
433.
"New source" means a new or modified building, structure, facility or installation as
defined in EPA 40 CFR part 403.3(m) from which there is or may be a discharge subject to
proposed or existing Pretreatment Standards.
IIOil-water separator" means a receptacle designed and constructed to intercept, separate,
and prevent the passage of oils and sediments into the sanitary sewer system.
"Once-through cooling system" means a cooling system through which water passes
through only once before discharge to a drain, including laboratory bench top cooling systems.
"Organic solvent" means any solvent which contains carbon in its molecular structure.
IIPass-throughll means a discharge that exits the Plant into a water of the United States in
quantities or concentrations that, alone or in conjunction with a discharge or discharges from
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100520 syn 6051181
NOT YET APPROVED
other sources, is a cause of a violation of any requirement of the Plant's NPDES permit
(including an increase in the magnitude or duration of a violation).
"Person" means any individual, partnership, firm, association, corporation, or public
agency.
"Plant" means the Palo Alto Regional Water Quality Control Plant.
"Point of discharge" means the point or points designated as such in the permit. Where no
designation is made it shall mean the point where the private sewer joins a public sewer.
"Pretreatment Standards" means prohibited discharge standards, categorical Pretreatment
Standards and local limits.
"Pretreatment requirement" means any substantive or procedural requirement related to
pretreatment imposed on a discharger, other than a Pretreatment Standard.
"Pretreatment system" means a treatment system at an industrial or commercial facility
that is designed to reduce the amount of pollutants, eliminate pollutants, or alter the nature of the
pollutant properties in the waste water prior to discharge to the sanitary sewer system.
"Root control chemicals" means any chemical introduced into pipes in order to inhibit or
kill roots in the pipe.
"Sampling location" means an access box, valve, spigot or similar structure from which
samples representative of an industrial wastewater discharge from a particular process or
processes, piece of equipment, activity, building, or facility are collected.
"Sanitary sewage" or "sewage" means water-carried wastes from residences, business
buildings, institutions, and industrial establishments, excluding ground, surface and storm
waters, subsurface drainage and also excluding industrial waste.
"Sanitary Sewer Overflow" or "SSO" means any overflow, spill, release, discharge or
diversion of untreated or partially treated wastewater from the sanitary sewer system. SSOs
include:
(a) Overflows or releases of untreated or partially treated wastewater that
reaches waters of the United States;
(b) Overflows or releases of untreated or partially treated wastewater that do
not reach waters of the United States; and
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100520 syn 6051181
NOT YET APPROVED
(c) Wastewater backups into buildings and on private property that are caused
by blockages or flow conditions within the sanitary sewer system.
"Secondary containment" means and shall have the meaning specified by the Hazardous
Materials Storage ordinance (Title 17, Palo Alto Municipal Code).
"Seepage pitt! means a device comprised of one or more pits extending into porous strata,
lined with open-jointed masonry or similar walls, capped and provided with a means of access
such as a manhole cover and into which wastewater disposal system effluent is discharged.
"Sewage treatment plant" means any arrangement of devices and structures used for
treating sanitary sewage.
"Sewer" means a pipe or conduit for carrying sewage.
"Sewer system" or "sanitary sewer system" means the collection system, all sewers,
treatment plants and other facilities owned or operated by the City of Palo Alto for carrying,
collecting, storing, treating, reclaiming and disposing of sanitary sewage and industrial wastes.
"Significant Industrial User" (SIU) means, except as provided in (c ) and (d):
(a) A discharger subjecHo categorical Pretreatment Standards; or
(b) A discharger that:
(1) Discharges an average of twenty-five thousand (25,000) gpd or more of
process wastewater to the sanitary sewer system (excluding sanitary, noncontact cooling and
boiler blowdown wastewater);
(2) Contributes a process waste stream which makes up five (5) percent or
more of the average dry weather hydraulic or organic capacity of the sanitary sewer system; or
(3) Is designated as such by the Superintendent on the basis that it has a
reasonable potential for adversely affecting the sanitary sewer system's operation or for violating
any Pretreatment Standard or Requirement.
(c) The Superintendent may determine that a discharger subject to categorical
Pretreatment Standards is a Non-Significant Categorical Industrial User (Non-SCIU) rather than
a Significant Industrial User on a fmding that the discharger never discharges more than 100
gallons per day (gpd) of total categorical wastewater (excluding sanitary, non-contact cooling
and boiler blowdown wastewater, unless specifically included in the Pretreatment Standard)and
the following conditions are met:
(1) The discharger, prior to Superintendent's finding, has consistently
complied with all applicable categorical Pretreatment Standards and Requirements;
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NOT YET APPROVED
(2) The discharger annually submits the certification statement required in
16.09.135(a)(3), together with any additional information necessary to support the certification
statement; and
(3) The discharger never discharges any untreated concentrated wastewater.
(d) Upon a fmding that a discharger meeting the criteria in Subsection (b) of this part
has no reasonable potential for adversely affecting the sanitary sewer system's operation or for
violating any Pretreatment Standard or Requirement, the Superintendent may at any time, on its
own initiative or in response to a petition received from a discharger, determine that such
discharger should not be considered a Significant Industrial User.
"Significant noncompliance" means a violation or series of violations by a discharger of
one or more criteria set forth in 40 CFR 403.8(f)(2)(viii).
"Simple payback period" means the number of,years required to allow the dollar value of
an investment in water pollution control to be exceeded by cost savings resulting from the
investment.
"Single Toxic Organic" or "STO" shall mean the highest quantifiable value for any
individual toxic organic compound.
"Slug discharge" means any discharge of a non-routine, episodic nature, including but not
limited to an accidental spill or a non-customary batch discharge of wastewater, material or
waste of high volume or pollutant concentration which violates any of the specific prohibitions
listed in 40 CFR 403.5(b )or Sections 16.09.045 or 16.09.050 of this code or that has a reasonable
potential to cause Interference or Pass-Through or in any other way violate the Plant's
regulations, Local Limits, or Sanitary Sewer System requirements or NPDES Permit conditions ..
"Storm drains" or "storm drain system" means the system of pipes, gutters, surface
conveyance and channels used to collect and convey storm water.
"Superintendent" means the manager of the Palo Alto Regional Water Quality Control
Plant, his or her designee or such other person as may be designated by the city manager.
"Total Toxic Organics" or "TTon shall mean the sum of all quantifiable toxic organic
compound concentrations greater than 0.010 mg/liter .
. "Toxic organic compound" shall mean any organic pollutant contained in 40 CFR Part
433.11(e).
"Unpolluted water" means water to which no constituent has been added, either
intentionally or accidentally, that would render such water unacceptable for disposal to the storm
drain system or natural drainage or directly to surface waters.
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\.
NOT YET APPROVED
"Wastewater" the liquid and water-carried wastes generated by a domestic, commercial
and or industrial facility, whether treated or untreated, discharged into or permitted to enter the
sewer system.
"Wet sanding" means the use of water and sandpaper for the removal of paint.
16.09.015 Responsibility of the superintendent.
The Superintendent shall be responsible for the administration and enforcement of the
provisions of this Chapter, for conducting an industrial waste source control program, and for
promUlgating such orders, rules and requirements as are necessary to accomplish the purpose of
this article in accordance with the requirements that are or may be promulgated by the
Environmental Protection Agency, the state of California Water Resources Control Board, the
State Department of Health Services, the California Regional Water Quality Control Board for
the San Francisco Bay Region or other duly authorized boards or agencies.
16.09.020 Confidentiality .
(a) Any information submitted to the Superintendent pursuant to this Chapter may be
claimed as confidential by the submitter. Any such claim must be asserted at the time of
submission by stamping the words IIconfidential business information" on each page containing
such information. Information submitted prior to the inclusion of this section in the Chapter may
be withdrawn and replaced by submittals stamped "confidential business information. II If no such
claim is made at the time of submission the information may be made available to the public
without further notice.
Upon receipt of a request for the release of information to the public which includes
information which the discharger has notified the Superintendent is claimed to be a trade secret
or sensitive as provided herein, the Superintendent shall notify the discharger in writing of the
request by certified mail, return receipt requested. The Superintendent shall release the
information to the public, but not earlier than thirty days after the date of mailing the notice of
the request for information, unless, prior to the expiration of the thirty-day period, the discharger
files an action in an appropriate court for a declaratory judgment that the information is subject
to protection under the laws of the state of California or for an injunction prohibiting disclosure
of the information to the public and promptly notifies the Superintendent of that action. This
section does not permit a discharger to refuse to disclose the information required pursuant to
this Chapter to the Superintendent.
(b) Information and data provided to the Superintendent pursuant to this section
which constitutes effluent or flow data, as defined at 40 CFR 2.302, shall be available to the
public without restriction.
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( c) A discharger may be prohibited from discharging a substance unless its
composition is made known to the Superintendent.
16.09.025 Alternate materials and methods.
(a) Practical Difficulties. The Superintendent is authorized to modify any of the
provisions of this Chapter upon application in writing by the owner, a lessee or an authorized
representative where there are practical difficulties in the way of carrying out the provisions of
this Chapter, provided that the purpose of this Chapter, as set forth in Section 16.09.005, shall be
complied with, and substantial justice done. The particulars of such modification and the
decision of the Superintendent shall be entered upon the records of the plant and a signed copy
shall be furnished to the applicant.
(b) Alternate Materials. The Superintendent, upon application in writing by the
owner, a lessee or an authorized representative, and on notice to the chief building official, is
authorized to approve alternate materials or methods, provided that the Superintendent finds that
the proposed design, use or operation satisfactorily complies with the intent of this Chapter and
that the material, method of work performed or operation is, for the purpose intended, at least
equivalent to that prescribed in this Chapter in quality and effectiveness in meeting the purposes
of this Chapter. Approvals under the authority herein contained shall be subject to the approval.
of the chief building official whenever the alternate material or method involves matters
regulated by any code administered by the chief building official. The particulars of any approval
made by the Superintendent under this subsection shall be entered upon the records of the plant
and a signed copy shall be furnished to the applicant.
16.09.030 Limitations on point of discharge.
No person shall discharge any substances directly into a manhole or other opening in a
city sewer or storm drain system, other than through an approved building sewer, or other
location approved by the Superintendent.
16.09.035 Prohibitions.
Wastes discharged into the sewer system shall not have characteristics which by themselves or
by interaction with other wastes may:
(a) Endanger the health and safety of the public or city personnel;
(b) Cause corrosion or other damage to the sewer system;
( c) Create nuisance such as odors or coloration;
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(d) Result in extra cost of collection, treatment, or disposal;
(e) Interfere with, inhibit or disrupt any wastewater treatment process of the plant, its
treatment processes, sludge processes, or operations in such manner to cause violations of the
plant's NPDES permit, or any regulatory requirement, or result in the use of sludge in
noncompliance with any applicable requirements. This shall include instances due to flow rate
and/or pollutant concentration, including oxygen-demanding pollutants (BOD, etc.) and applies
to increases in magnitude or duration of violation by the plant;
(f) Pass through or exit the plant into waters of the United States in quantities or
concentrations which contribute to a violation of any regulatory requirement applicable to the
plant. This shall include increases in magnitude or duration of any violation or period of
noncompliance;
(g) Cause the temperature of the influent flow to the plant to exceed 40°C (l04°F);
(h) Prevent, hinder, delay, or impede compliance with effluent quality requirements
established by regulatory agencies, or exceed the same;
(i) Cause wastewater quality to fall outside reclamation feasibility limits.
G) Obstruct flows within the sewer system or otherwise cause or contribute to
sanitary sewer overflows.
16.09.040 Standards.
(a) The following standards shall apply to all discharges to the sewer at a designated
sampling location determined by the Superintendent to be consistent with the dilution prohibition
contained in Section 16.09.115.
(b) Maximum allowable limitations at the point of sampling shall be specified in each
discharge permit, based on flow and waste stream information supplied in the discharger's permit
application, applicable National Pretreatment Standards for process wastewaters, and other
pertinent information. Maximum allowable limitations may be expressed both in terms of total
mass discharged and maximum allowable limits.
(c) The National Pretreatment Standards set forth in 40 CFR Chapter I, Subchapter N,
Parts 405-471 shall apply to all applicable sources. The definitions and procedures for
establishing individual effluent limitations shall be as specified therein. Nothing in this Chapter
shall be construed as allowing less stringent limitations.
(d) Local limitations, in addition to those specified in this section, shall be developed
by the Superintendent based upon the prohibitions contained in Section 16.09.035. These
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limitations will be imposed on appropriate dischargers via industrial waste discharge permits or
modifications to existing permits.
(e) In addition to the requirements of (c) and (d) above, the following requirements
shall apply where they are more stringent:
Parameter
Dissolved sulfides
Fluoride
Mercaptans
Oil & grease**
Oil & grease (total)
Maximum Limits* mglliter
0.10
65
0.10
20
200
* Apply to both instantaneous and composite samples
** Gravity separation at a temperature of 20°C. and a pH of 4.5.
Para
meter
Minimum
limit Maximum Limit
pH*
*no units
Parameter
5.0
Suspended solids
Total dissolved solids
Maximum
Limits*
mglliter
3000
5000
* Apply to instantaneous samples only
** Apply to composite samples only
11.0
Maximum Limits**
mg/liter
6000
10000
(f) Dyes. Wastes showing excessive coloration shall not be discharged into the sewer
system. Excessive coloration shall be defined as any coloration in a waste which, for any wave
length, displays less than sixty percent of the light transmissibility of distilled water under the
following conditions:
(1) After filtration, through a 0.45 micron membrane filter;
(2) In the pH range of 5.5 to 11.0;
(3) Through a one centimeter light path;
(4) A maximum spectrum band width of 10 nanometers;
(5) Through the wave length range from 400 to 800 nanometers.
(g) Oil and/or grease shall not be discharged into the sewer system if the average
concentration of floatable oil and/or grease (defined as that which is subject to gravity separation
at a temperature of 20° C. and at a pH of 4.5) exceeds twenty mglliter; nor shall the total oil
and/or grease concentration exceed two hundred mglliter. In addition, the discharge of petroleum
oil, non-biodegradable cutting oil, or products of mineral origin in amounts that cause
interference or pass-through shall be prohibited.
(h) Hazardous, Noxious or Malodorous Substances. No industrial waste shall be
discharged which alone or in combination with other wastes may create a public nuisance or
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hazard, make human entry into the sewers unsafe, or which constitutes a discharge of hazardous
waste.
(i) Permitted dischargers shall be required to certify at least every six months in their
Periodic Report of Continued Compliance (PRCC) that their discharged waste does not
constitute a hazardous waste and that during the previous six months no discharge of hazardous
waste has occurred. Dischargers shall be required (as a condition to permission to discharge) to
file with the Palo Alto fire department a current hazardous materials business plan (HMBP)
pursuant to Title 17 of this code and to have on site copies of material safety data sheets for all
hazardous materials stored, generated, or used at the discharger's site. Should any discharge of a
hazardous waste occur, the discharger shall immediately verbally notify the Superintendent and
shall also verbally notify the EPA and the Regional Water Quality Control Board as soon as
possible, but in no event later than twenty-four hours after such discharge. The discharger shall
also notify the Superintendent, EPA and the Regional Water Quality Control Board in writing no
longer than 21 days after such discharge.
G) Records of hazardous waste disposal manifests, inventories of stored virgin and
used hazardous materials, and other documentation required by the HMBP shall be maintained
and made available for inspection as described in 16.09.160.
(k) Explosives. No solids, liquids, or gases which by themselves or by interaction
with other substances may create fire or explosion hazards, including waste streams with a
closed cup flashpoint of less than 140°F. (60°C) shall be discharged to the sewer system.
Flammable substances including, but not limited to, acetone, alcohols, benzene, gasoline, xylene,
hexane and naphtha, shall not be discharged into the sanitary sewer system except where present
in contaminated groundwater discharges being discharged under an exceptional waste permit
issued by the Superintendent. Where groundwater discharges contain such contaminants, the
discharger shall monitor the sewer atmosphere for explosivity and flammability using a properly
calibrated meter designed for this purpose. The frequency of such monitoring shall be defined in
the permit. Whenever ten percent of the lower explosive level is exceeded, the discharger shall
immediately notify the Superintendent of the potential hazard in the sewer once the
determination of threatened explosivity has been made. The discharger shall follow verbal
notification within five days with a written explanation of the cause of the explosive hazard,
corrective actions taken to alleviate the situation, and measures taken to prevent,reoccurrence.
The discharger shall not recommence discharge without prior written approval of the
Superintendent. Where flammable substances are used in processes, separate collection and
disposal outside the sanitary sewer system shall be provided.
(1) Organic Solvents. Except as permitted by other sections of this Chapter, the sewer
shall not be used as a means of disposal for organic solvents. Wastewater discharged to the
sanitary sewer system shall not contain a sum total greater than 1000 mg/liter of acetone,
ethanol, methanol, or isopropyl alcohol, in any combination. Dischargers having organic solvents
on site or using same shall provide and use a separate collection and disposal system outside the
sewer system and shall provide safeguards against their accidental discharge to the sewer. An
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approved toxic organic management plan (TOMP) that ihcludes control measures to prevent
entry of toxic organics and other solvents into the sanitary sewer system shall be filed by the
discharger as a condition of permission to discharge to the sanitary sewer. The TOMP shall be
updated whenever any significant change in the inventory, usage, or management of toxic
organic compounds occurs. The updated TOMP shall be submitted to the City for approval
within (30) days. Records documenting appropriate disposal and handling of organic solvents
shall be maintained and made available for inspection as described in 16.09.160.
Organic solvents shall include, but shall not be limited to those used in dry
cleaning establishments, and shall also include separator water generated by dry cleaning
equipment. Neither the organic solvent nor the separator water may lawfully be discharged to the
sewer or storm drain system.
(m) Toxic Organics. The prohibition against disposal of organic solvents contained in
16.09.040(1) may be replaced by a specific limitation on Single Toxic Organics (STO) and Total
Toxic Organics (TTO). Any such limitation must be contained in an industrial waste permit.
The maximum allowable limit for TTO shall be 1.0 mg/liter. The maximum
allowable limit for STO shall be 0.75 mg/liter.
Additionally, dischargers subject to a National Pretreatment Standard shall
comply with any toxic organics standard defined by the applicable National Pretreatment
Standards.
The maximum allowable limit for phenols shall be 1.0 mg/liter.
(n) Radioactivity. The discharge of radioactive wastes or isotopes into the sewer
system is prohibited except when in conformance with all applicable state and federal
regulations.
(0) Solids or Viscous Substances. No material shall be discharged to the sanitary
sewer system that will obstruct or damage the sanitary sewer system. Specific prohibitions are as
follows:
(1) Inert Solids. The discharge of inert solids including, but not limited to
sand, glass, metal chips, bone, plastics, etc., into the sanitary sewer system is prohibited. Settling
chambers or treatment works shall be installed where necessary to prevent the entry of inert
solids into the sanitary sewer system.
(2) Solid Particles. Industrial wastes shall not contain particulate matter that
will not pass through a one-half-inch screen; this subsection shall not apply to domestic sewage
from industrial establishments.
(P) Stored Liquid Wastes. Liquid aqueous-based wastes that have been collected and
held in tanks or containers shall not be discharged into the sanitary sewer system except at
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locations authorized by the Superintendent to collect such wastes. Wastes of this category
include but are not limited to:
(1) Chemical toilet wastes;
(2) Pleasure boat wastes;
(3) Septic tank pumping;
(4) Trailer, camper, house car, or other recreationru vehicle wastes;
(5) Industrial wastes collected in containers or tanks.
(q) Toxicity. The following is a nonexclusive list of toxic substances and the
maximum allowable limit for each discharge:
Toxicant
Maximum Allowable Limits
mglliter
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium, Hexavalent
Chromium total
Cobalt
Copper
Cyanide
Formaldehyde
Lead
Manganese
Mercury
Methyl Tertiary Butyl Ether (MTBE)
Nickel
Phenols
Selenium
Silver
Zinc
0.10
5.0
0.75
1.0
0.10
1.0
2.0
1.0
0.25
0.50
5.0
0.50
1.0
0.010
0.75
0.50
1.0
1.0
0.25
2.0
All limits for metallic substances are for total metal unless indicated otherwise.
For discharges with annual average flows greater than fifty thousand gallons per day
through any single sampling location, the maximum allowable limits shall be one-half the values
listed in the table, with the exception of copper, mercury, MTBE, nickel, and silver, for which
the limits shall remain 0.25 mg/liter, O.OlD mg/liter, 0.75 mg/liter, 0.50 mg/liter, and 0.25
mglliter, respectively, regardless of flow.
The maximum allowable limit for mercury set forth in this section shall not be applicable
to dental facilities using mercury-containing amalgam. Dental facility requirements are set forth
in Section 16.09.220.
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The maximum allowable limit for silver set forth in this section shall not be applicable to
photographic materials processing. Silver limitations for photoprocessors are set forth in Section
16.09.215.
The maximum allowable limit for zinc set forth in this section shall not be applicable to
vehicle service facilities. Zinc limitations for vehicle service facilities are set forth in Section
16.09.225.
The maximum allowable limit for copper set forth in this section shall apply to all
discharges except where maximum allowable limitations are specified in Section 16.09.045.
16.09.045 Additional copper limitations for industrial waste.
(a) Industrial waste discharges to the sanitary sewer system are subject to the copper
limitations contained in Section 16.09.040(q) except for industrial waste from the following
facilities, including facilities that are components of larger facilities, which are subject to specific
limitations set forth in other provisions of this Chapter.
(1) Cooling systems, pools, spas, fountains, boilers and heat exchangers as
specified in Section 16.09.205;
(2) Photo processing facilities as specified in Section 16.09.215;
(3) Dental facilities as specified in Section 16.09.220 and;
(4) Vehicle service facilities as specified in Section 16.09.225;
(6) Machine shops as specified in Section 16.09.230 and;
(5) Non-process, non-domestic waste as specified in Section 16.09.045(c).
(b) Industrial waste discharges to the sewer from metal finishing facilities, as defined
by the EPA in 40 CFR part 413 and part 433, shall meet either subdivision (1) or (2) of this
subsection. These requirements shall apply to process wastes containing copper or nickel prior to
dilution by non-metal finishing process wastes, domestic waste, and cooling water.
(1) The annual average copper limit for any twelve month period shall not
exceed 0.40 mg/liter. In addition, all reasonable control measures specified in accordance with
standards published by the Superintendent shall be installed and implemented; or
(2) The annual average mass of copper shall not exceed an amount specified
by the Superintendent in the industrial waste discharge permit, which is based upon a pollution
prevention review conducted or approved by the Superintendent. The limitation shall be based
upon those control measures having a simple payback period of five years or less. The annual
average mass per day shall be a "rolling" measurement, calculated by multiplying the flow
weighted average copper concentration for all samples taken during any twelve month period by
the total flow for that twelve month period. The annual average mass per day limit may be
increased by the Superintendent in proportion to increases in production at the discharger's
facility to the extent that such production increases are within the growth allocation specified in
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the document prepared by Montgomery Watson, and published by the City of Palo Alto, entitled
"City of Palo Alto-Local Limits Development -Proposed Local Limits -April, 1994."
(c) The maximum allowable limit for discharge of copper from non-process, non-
domestic waste discharges to the sanitary sewer other than those covered by subsections (a) or
(b) shall be 2.0 mg/liter. These waste discharge sources shall be designated by the
Superintendent upon request and typically consist of infrequent, low volume, or exceptional
wastes that are generated during maintenance, repair and cleaning activities.
16.09.050 Grease disposal prohibited.
No person shall dispose of any grease, or cause any grease to be disposed, by discharge
into any drainage piping, by discharge into any public or private sanitary sewer, by discharge
into any storm drainage system, or by discharge to any land, street, public way, river, stream or
other waterway
16.09.055 Unpolluted water.
(a) Unpolluted water shall not be discharged through direct or indirect connection to
the sanitary sewer system unless a permit is issued by the City. As used in this section,
unpolluted water shall include storm water from roofs, yards, foundation or under-drainage,
which meets all state and federal requirements for discharge to surface waters of the United
States. The Superintendent may approve the discharge of such. water to the sewer system only
when no reasonable alternative method of disposal is available. If a permit is granted for the
discharge of such water into the sewer system, the user shall pay the applicable charges and fees
and shall meet such other conditions as required by the Superintendent.
(b) Non-emergency once-through cooling water from systems using potable water as
a coolant shall not be discharged to the sanitary sewer system; provided that the Superintendent
may approve an exception in the following instances:
(1) For once-through cooling water used for bench top reflux or distillation or
other similarly sized activity; or
(2) For short term use only, upon the determination that the use is for a
research activity for which another source of cooling is not easily available.
16.09.060 Standards for other industrial wastes.
The Superintendent may establish standards for any industrial wastes not specifically
referred to in this Chapter. These standards shall be published and shall be made available to any
person requesting a copy of the standards.
16.09.065 'Best Management Practices (BMPs).
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100520 syn 6051181
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The Superintendent may require the implementation of BMPs. The Superintendent may
require submission of information to evaluate the implementation and effectiveness of BMPs.
16.09.070 Trucker's discharge permit.
(a) All persons operating vacuum or pump trucks or other liquid waste transport
trucks desiring to collect or discharge septic tank, seepage pit, chemical toilet, cesspool contents,
or other similar liquid wastes shall be permitted by the County and meet the requirements in
Santa Clara County Code, Title B Regulations, Chapter X. All such trucks discharging to the
City sanitary sewer system shall first acquire a trucker's discharge permit from the City.
Discharges in the City samtary sewer system shall be only at the locations specified by the
Superintendent.
(c) Truck transported industrial wastes discharged to the City sanitary sewer system
shall be only at the locations specified by the Superintendent for the specific waste. The City
shall require payment for treatment and disposal costs or may refuse permission to discharge
certain prohibited wastes in accordance with City of Palo Alto's utilities rules and requirements.
Denial, suspension, or revocation of such permit shall be in accordance with Sections 16.09.095
and 16.09.100 of this Chapter.
(d) Trucks transporting waste shall not combine loads from the different waste types
described in (a), (b) or (c).
(e) Records of all wastes collected or disposed pursuant to this section shall be
maintained and made available for inspection as described in Section 16.09.160.
16.09.075 Food service establishments.
(a) Definitions
"Black Grease" means any contents within or removed from a grease control device,
generally consisting of brown grease combined with wastewater from toilet plumbing associated
with the sanitary sewer.
"Brown Grease" means any contents within or removed from a grease control device,
generally FOG combined with non-restroom FSE wastewater.
"Fats, Oils and Grease (FOG)" means any substance such as a vegetable or animal
product that is used in, or is a by product of, the cooking or food preparation process, and that
turns or may turn viscous or solidifies with a change in temperature or other conditions.
"Food Service Establishment (FSE)" means a facility defined in California Uniform
Retail Food Service Establishments Law (CURFFL) Section 113785, and any commercial entity
within the boundaries of the City, operating in a permanently constructed structure such as a
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100520 syn 6051181
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room, building, or place, or portion thereof, maintained, used, or operated for the purpose of
storing, preparing, serving, or manufacturing, packaging, or otherwise handling food for sale to
other entities, or for consumption by the public, its members or employees, and which has any
process or device that uses or produces FOG, or grease vapors, steam, fumes, smoke or odors
that are required to be removed by a Type lor Type II hood, as defmed in CURFFL Section
113785.
"Grease Control Device (GCD)" means a grease interceptor, grease trap or other grease
removal device designed, constructed and intended to remove, hold or otherwise prevent the
passage of FOG to the sanitary sewer.
"Grease Waste Hauler Service Contract" means a contractual agreement between the City
and a City selected and managed GCD service provider to be used by FSEs.
"Lateral" means the drainage piping and appurtenances that constitute the building'S
connection to the City's sanitary sewer system.
"Tallow Receptacle" means a tallow bin or equivalent waste oil/grease receptacle.
"Twenty-five Percent (25%) Rule" means the requirement for grease control devices to
be maintained such that the combined FOG and solids accumulation does not exceed 25% of the
design hydraulic depth in any location of the grease control device. This is to ensure that the
minimum hydraulic retention time and required available hydraulic volume is maintained to
effectively intercept and retain FOG.
IIWaste Hauler" means any person permitted with the County of Santa Clara and meeting
County of Santa Clara Code, Title B Regulations and carrying on or engaging in vehicular
transport of waste as part of, or incidental to, any business for that purpose.
"Yellow Grease or Tallow" means any waste FOG material generally generated as a
byproduct from cooking.
(b) Prohibitions. The following prohibitions shall apply to all FSEs:
(1) No person shall dispose of any FOG, or cause any FOG to be disposed, by
discharge into any drainage piping, public or private sanitary sewer, storm drain system, or onto
any land, street, public way, river, stream or other waterway.
(A) Discharge of any GCD contents or materials released during sewer
pipe or lateral cleaning is prohibited.
(B) Disposal of waste cooking oil into drainage pipes is prohibited.
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100520 syn 6051181
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(c) FSE staff shall not remove the contents of GCDs. The contents of GCDs shall
only be removed by permitted waste haulers.
(d) No FSE shall install, have installed, or use a food waste disposer (grinder).
(e) No FSE shall connect any high temperature discharge lines or drainage fixtures
that are not a source of FOG to a GCD. Such shall include, but not be limited to,
the following:
(1) Dishwashers;
(2) Steamers;
(3) Pasta cookers;
(4) Hot discharge lines from buffet counters and kitchens;
(5) Hand washing sinks;
(6) Ice machine drip lines;
(7) Soda machine drip lines;
(8) Discharge lines in bar areas.
(f) No FSE shall operate a GCD where FOG and solids accumulation exceed 25% of
the design hydraulic depth of the GCD (25% rule).
(g) No FSE shall introduce any additives into GCDs and/or FSE wastewater systems
to biologically/chemically treat FOG, for FOG remediation, to emulsify FOG, or as a supplement
to GCD maintenance, unless the Superintendent grants prior written consent. Biological or
chemical treatment of FOG includes, but is not limited to, systems or additives, such as solvents
or enzymes that dissolve or mobilize FOG.
(h) No FSE shall discharge wastes from toilets, urinals, ash basins, and other fixtures
containing sanitary sewage materials to sewer lines draining to a GCD.
(i) No FSE shall allow soap or soapy water to flow to the storm drain system.
G) No FSE shall allow wastewater generated from cleaning of equipment or outside
surfaces containing FOG or food residue to flow to the storm drain system.
(k) Best Management Practices (BMPs). FSEs shall implement BMPs to prevent
FOG discharge to the sanitary sewer and to prevent non-storm water discharges to the storm
drain system. All FSEs shall implement and incorporate BMPs into their operations in
accordance with the Superintendent's guidelines, requirements and directives. The
Superintendent may require submission of information to evaluate the implementation of BMPs.
At a minimum the following BMPs shall be implemented by FSE's:
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100520 syn 6051181
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(1) Dishwashing. FSE's shall remove food from preparation and service items
prior to washing. Food waste shall not be disposed in sinks or drains. The FSE shall dispose of
all food waste directly into the trash or food scrap container by physically removing the food
waste with scrapers, towels, paper towels, rubber spatulas, or other effective methods prior to
using water to rinse off plates, dishes, pots, pans, containers, utensils, etc.
(2) Equipment Cleaning.
(A) Drain Screens. Screens shall be installed in all sinks, drains, floor
drains, floor sinks, dishwashers, etc. The screens shall be frequently inspected and cleaned by
disposing waste into the trash or food scrap container to prevent FOG and food buildUp.
(B) Cleaning Wastewater. Wastewater generated from cleaning FOG
contaminated items such as large kitchen equipment, floor mats, floors, exhaust hoods and
filters, grills, trash, recycling, and food scrap containers, and tallow receptacles; or from any
washing of items such as plates, dishes, pots, pans, containers or utensils that occurs other than in
an automatic dishwasher shall not be discharged to the sanitary sewer unless it flows through a
GCD.
(C) Exhaust hood and vent grease collection devices. All such
collection devices, including but not limited to grease cups on roofs, in hoods and removable
filters, shall be properly maintained at a frequency sufficient to prevent spills and overflows.
Collected waste oil/grease shall be disposed of in a tallow receptacle.
(3) Storm water pollution prevention.
(A) Routinely inspect and dry sweep as necessary outside areas such as
walkways, dining areas and waste storage areas to prevent storm water pollution.
(B) Routinely inspect waste collection containers to verify that covers
are in place and that container and surrounding areas are clean and free of FOG and food residue,
debris and leaks. Such containers include, but are not limited to, trash, recycle, food scrap and
tallow receptacles. If FOG or food residue, debris, or leaks are found the FSE shall immediately
take action to correct the noncompliance. This may include, placing cover(s) on containers and
receptacles, Cleaning up FOG or food residues or spills in the surrounding areas or contacting the
appropriate vendor for container or receptacle repair/replacement.
(C) If any outdoor surfaces with FOG or food residue require cleaning,
first sweep or physically remove excess residue, next use a mop and bucket, then discharge
waste mop water through a GCD.
(D) Any wastewater generated from outdoor cleaning of equipment
and outdoor surfaces with FOG or food residue shall be captured and disposed of into the
sanitary sewer. If the wastewater contains FOG, it shall be disposed through a GCD prior to
release to the sanitary sewer system.
(4) FOG Transporting. FSEs shall properly dispose of waste oil and grease
into a tallow receptacle. Waste FOG shall be transported in a covered container. Appropriate
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100520 syn 6051181
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measures shall be taken to prevent spills. Any spills shall be immediately cleaned using methods
described in this Section.
(5) Cleaning with Dry Methods. Dry cleaning methods shall be used inside
and outside to clean up FOG spills. Pick up liquids or FOG with rags or absorbent materiaL
Sweep up absorbent material and dispose of it in the trash. Regularly use dry methods to clean
near fryers and other locations where FOG may spill or drip. Clean up all FOG spills prior to
moppmg.
(6) Drain Fixture Identification. All non-restroom drainage fixtures shall be
labeled with their discharge location. Fixtures draining to GCDs shall be clearly labeled "drains
to grease control device" or equivalent. Fixtures draining to the sanitary sewer that do not drain
through a GCD shall be labeled "drains to sanitary sewer" or equivalent. A list of all non
restroom drainage fixtures and their discharge locations shall be maintained onsite.
(1) Training.
(1) All FSEs shall take necessary steps to inform appropriate personnel
employed by such FSEs of the provisions of this Section.
(2) Such personnel shall include workers and supervisors whose duties pertain
in any manner to the production, treatment or disposal of waste discharges regulated by this
Section.
(3) Steps to inform such personnel shall include but not be limited to:
(A) Orientation of newly employed or assigned personnel;
(B) Quarterly training of all appropriate personnel;
(C) Posting of signs or posters in work areas indicating BMPs.
(4) All training/orientation shall be documented and employee signatures
retained indicating each employee's attendance and understanding of the regulations reviewed.
These records shall be maintained and made available for inspection as described in Section
16.09.160.
(m) FOG Pretreatment Required. FSEs shall install, operate and maintain an approved
type and adequately sized GCD sufficlent to maintain compliance with the objectives of this
Section. The GCD shall be adequate to separate and remove FOG contained in wastewater from
the FSE prior to discharge into the sanitary sewer system. Fixtures, equipment, and drain lines
located in food preparation and cleanup areas of FSEs that are sources of FOG shall be
connected to GCDs. Compliance shall be established as follows:
(1) GCD Requirements.
(A) GCD shall be sized equal to or greater than the minimum size set
forth in the following table based on the number of Drain Fixture Units (DFU) draining to the
GCD.
Sizing Criteria:
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Grease Control Device (GCD) Sizing
DFUs
8
21
35
90
172
216
Drain Fixture
Pre-Rinse Sink
GCD Volume (gallons)
500
750
1,000
1,250
1,500
2,000
DFUNumber
4
3 Compartment Sink
2 Compartment Sink
Mop Basin
3
3
3
Prep Sink 3
Floor Drain 2
Floor Sink 2
(B) GCDs smaller than 500 gallons may be allowed with written
approval by the Superintendent, provided that the proposed design satisfactorily complies with
the intent of this Chapter.
(C) All in-ground GCDs greater than 750 gallons shall have a
minimum of three manholes to allow visibility over inlet piping, baffle (divider) piping and
outlet piping, and to ensure accessibility for inspection, cleaning and removal of all contents. The
Supenntendent may permit deviance from this requirement in writing prior to GCD installation,
provided that the proposed design satisfactorily complies with the intent of this Chapter.
(D) FSEs shall install GCDs in a suitable location to allow easy access
for inspection, cleaning and maintenance.
(E) Sample boxes shall be installed downstream of all gravity grease
interceptors as defined in the 2007 California Plumbing Code.
(F) Laterals installed between a FSE and GCD, and GCD and the
sanitary sewer system sewer main shall include installation of two way (double) clean outs to
allow access points for sewer line maintenance and inspection.
(2) GCD Connections
(A) All drainage fixtures where FOG may be discharged shall drain to
a GCD. Such fixtures include, but are not limited to:
(i) Pre-rinse (scullery) sinks;
(ii) Three compartment sinks (pot sinks);
(iii) Drainage fixtures in dishwashing room except for
dishwashers;
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(iv) Trough drains (small drains prior to entering a dishwasher),
small drains on busing counters adjacent to pre-rinse sinks or silverware soaking sinks;
drainS/sinks;
(v) Floor drains in dishwashing area and kitchens;
(vi) Prep sinks;
(vii) Mop Ganitor) sinks;
(viii) Drains in outside areas designated for equipment washing.
These drains must be covered;
(ix) Drains in trash/recycling enclosures;
(x) Wok stoves, rotisserie ovenslbroilers or other FOG
generating cooking equipment with drip lines;
(xi) Kettles and tilt/braising pans and associated floor
(B) FSEs shall have a sink or other area connected to a GeD for
cleaning floor mats, containers, exhaust hood filters and equipment. The sink or cleaning area
shall be large enough to clean the largest mat or piece of equipment.
(n) Grease control device maintenance requirements.
(1 ) GeD and sewer line maintenance requirements.
(A) GeDs shall be maintained in efficient operating condition by
periodic removal of the full contents of the GeD which includes wastewater, accumulated FOG,
floating materials, sludge and solids.
(B) All GeDs shall be kept in good repair, functioning properly and
maintained in continuous operation according to manufacturer's guidelines and the
Superintendent's requirements and directives.
(e) If a FSE utilizes automatic or mechanically cleaned GeDs its staff
shall perform daily cleaning and maintenance.
(D) All existing and newly installed GeDs shall be maintained in a
manner consistent with a maintenance frequency approved by the Superintendent pursuant to this
Section.
(E) Sewer lines to and from GeDs shall be kept in good repair and
clear of any FOG accumulation.
(F) No FOG that has accumulated in a GeD shall be allowed to pass
into any sewer lateral, the sanitary sewer system, storm drain system, or public right of way
during maintenance activities.
(G) All FOG discharged during GeD or FSE sewer line cleaning and
maintenance shall be captured. Any FSE that has their kitchen grease waste lines, GeD exit lines
and or laterals cleaned by jetting or hydro-flushing shall capture the contents prior to discharge.
Such contents shall be contained, removed and disposed of by a waste hauler.
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(H) All GCDs shall be completely cleaned out and left empty by a City
pennitted waste hauler prior to the closure of a FSE, the associated building or a change in
ownership. In the event the tenant cannot be located the building owner shall assume
responsibility for cleaning the GCDs.
(I) Logs shall be kept for all GCD cleaning and maintenance
activities. The required records shall be maintained and made available for inspection as
described in 16.09.160.
(2) GCD Maintenance Frequency.
(A) The GCD maintenance frequency shall be set so as to ensure that
the minimum hydraulic retention time and required available hydraulic volume is maintained to
effectively intercept and retain FOG and minimize the passage of FOG to the sanitary sewer
system. All GCDs shall be maintained to achieve compliance with this Section. When the
cleaning frequency to comply with the 25% rule has not yet been established, unless otherwise
directed by the Superintendent, the following minimum cleaning frequencies shall be
implemented:
(i) Grease interceptors (gravity grease interceptors) greater
than 100 gallons shall have all their contents removed at a minimum once every three months;
(ii) Grease traps (hydro-mechanical grease interceptors) shall
have their contents removed at a minimum once every month;
(iii) Automatic or mechanical self cleaning GCDs shall have
their contents completely removed at a minimum once every six months.
(B) The Superintendent may modifY GCD maintenance frequencies at
any time to reflect changes in operating conditions.
(i) The owner/operator of a FSE may at any time submit a
request to the Superintendent requesting a change in the maintenance frequency. The FSE has
the burden of demonstrating that the requested change in frequency reflects actual operating
conditions based on the average FOG accumulation over time and meets the requirements of this
Section. Upon determination by the Superintendent that the requested revision is justified, the
FSE shall adjust its GCD maintenance frequency accordingly.
(C) If the GCD, at any time, contains FOG and solids accumulation
that does not meet the requirements described in this Section, the FSE shall have the GCD
serviced immediately such that all wastewater, FOG, solids, and other materials are completely
removed from the GCD.
(3) Grease waste hauler.
(A) All grease waste haulers servicing GCDs in the City shall comply
with the requirements set forth in the Palo Alto Municipal Code Section 16.09.070, Trucker's
discharge permit.
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(B) If the Grease Waste Hauler Service Contract program has been
implemented, FSEs shall use the Grease Waste Hauler Service Contract service provider for
routine cleaning and maintenance of their onsite GCDs. Grease waste haulers not selected as
service providers for the contract may not provide routine cleaning and maintenance of GCDs.
(C) If the Grease Waste Hauler Service Contract program has not been
implemented, the FSE shall retain the services of a permitted grease waste hauler.
(D) Waste haulers disposing at the RWQCP shall not mix brown
grease loads with different types of wastes such as septic, yellow grease, black grease, or any
other waste. Each waste hauler vehicle shall be dedicated to each type of liquid waste. If a GCD
is found to contain black grease, the waste hauler shall immediately notify the Superintendent. Its
entire contents shall be collected and disposed of at the RWQCP, exact disposal location shall be
determined by the Superintendent.
(E) Waste haulers servicing GCDs shall remove the entire contents of
the GCD including all FOG, water, and solids. The sides and structures shall be scrapped or
otherwise cleaned sufficiently to restore capacity and allow inspection of the device.
(F) Waste haulers servicing GCDs within the R WQCP service area
shall not reinsert or discharge into a GCD, manhole, cleanout, or other sanitary sewer
appurtenance any materials that the waste hauler has removed from a GCD or cause those
materials to be so handled. The waste hauler shall obtain prior written approval from the
Superintendent to decant when using appropriate equipment for the separation of water from the
FOG waste.
(G) Waste hauler manifest shall contain at a minimum the following:
(i) Name and address of site serviced;
(ii) Service date and time;
(ii) Hauler name and truck ID;
(iv) Volume collected;
(v) GCD observations and comments;
(vi) Disposal site and date;
(vii) Driver signature.
(0) Tallow Receptacles.
(1) Collection of waste cooking oil and grease.
(A) Tallow receptacles shall be in place at the location of any FSE that
generates waste oil or grease. Waste oil or grease generation includes, but is not limited to, the
following equipment or activities:
(i) Fryers
(ii) Rotisserie ovens not connected or draining to a GCD;
(iii) Any other type of oil and grease waste created by cooking;
(iv) Cleaning of FOG contaminated equipment;
(v) Waste FOG from automatically or mechanically cleaned
GCDs which require FSE staff maintenance.
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(B) At the Superintendents request, the FSE shall relocate tallow
receptacles to an indoor or covered location to mitigate storm water pollution.
(2) Tallow hauler.
(A) Tallow haulers servicing FSEs shall immediately clean up any
spills occurring during service.
(B) Tallow receptacles delivered for service shall be free of exterior
FOG.
(P) Requirements for Recordkeeping.
Records shall be maintained and made available for inspection as described in Section 16.09.160.
Such records shall include, but not be limited to, the following:
(1) GCDs:
(A) Waste hauler manifests
(B) Logbook documenting all GCD maintenance and monitoring
a9tivities including FOG and solids accumulation measurements.
(2) Tallow Receptacles:
(A)Maintenance records indicating servIce, cleaning, repaIr, and/or
replacement.
(B) Spill log indicating date and time of any spills and cleanups.
(3) Plumbing:
(A)Any sewer line maintenance and monitoring records including cleaning
and videos of facility sewer pipes or laterals.
(B)Records of any sanitary sewer overflows, backups or spills.
(4) All training/orientation records ..
(5) Any other information deemed appropriate by the Superintendent to
ensure and document compliance with this Section
(q) Requirements for remodeled and newly constructed FSEs.
(1) Dischargers of FSE wastewater from newly constructed or converted
commercial and industrial facilities shall be in full compliance with the provisions of this Section
at the time of commencement of discharge.
(2) Buildings that house FSEs shall include a covered area for all receptacles,
dumpsters, bins, barrels, carts or containers used for the collection of trash, recycling, food
scraps and waste cooking FOG or tallow. The areas shall be designed to prevent water run-on to
the area and runoff from the area. Drains that are installed within waste storage areas are
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optional. Any drain installed shall be connected to a GCD. If tallow receptacle(s) are to be stored
outside then an adequately sized, segregated space for tallow receptacle(s) shall be included in
the covered waste storage area. These requirements shall apply to remodeled or converted
facilities to the extent that the portion of the facility being remodeled or converted is related to
the subject of the requirement.
(r) Accidental or threatened storm drain system discharges. For all unauthorized or
prohibited releases to the storm drain systems including sanitary sewer overflows and threatened
discharges to the storm drain system, the responsible party shall comply with Section 16.09.165.
(s) FSE Inspection and Monitoring. All FSEs shall be subject to the regulations
contained in Palo Alto Municipal Code Section 16.09.110.
16.09.080 Industrial waste discharge permit.
(a) It is unlawful for any person or organization to discharge or cause to be
discharged any industrial waste whatsoever directly or indirectly into the sanitary sewer system
without first obtaining a permit for industrial waste discharge pursuant to this Section.
Appropriate fees for such permits are specified in a utility rate schedule of the Palo Alto utilities
rates and regulations. Furthermore, it shall be unlawful for any person or organization to
discharge any industrial waste in excess of the quantity or quality limitations or to violate any
other requirement set forth in this Chapter or in a permit for industrial waste discharge.
(b) A discharger may submit an advance written request to discharge prohibited
wastes not in conformance with this Chapter or wastes containing concentrations of substances
or characteristics in excess of those permitted by this Chapter. Discharge of such wastes shall not
be allowed without an exceptional waste permit duly issued.
(c) The Superintendent may authorize a discharger by permit to discharge
"exceptional wastes" when the permit will neither result in a violation of any of the provisions of
this Chapter nor cause any of the effects described in Section 16.09.035 of this code nor any
violation ofthe Pretreatment Requirements. The City shall be compensated for any costs it incurs
in authorizing such discharge including any expense in determining whether such discharge is
compatible with the sanitary sewer system and is in compliance with the Pretreatment
Req uirements.
(1) Permission to discharge exceptional waste may either be given as an
addendum to a current permit or by a separate permit. In the case of third parties requesting
permission to discharge waste generated by another party, or the products of treating waste
generated by another party, the waste generator or responsible party must submit a "designation
of authorized representative" (DOAR) form to the Superintendent to authorize the third party to
conduct business and sign reports on their behalf. However, certification that the waste as
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discharged does not constitute a hazardous waste and the permit and permit application must be
signed by such waste generator or responsible party.
(2) Exceptional wastes are aqueous wastes that may include but are not
limited to:
(A) Construction site dewatering where soil or groundwater
contamination is present;
(B) Groundwater contaminated with organic solvents generated as a
result of pump tests in preparation for a groundwater cleanup or water generated during sampling
events;
(C) Aqueous wastes generated by either permanent or mobile
hazardous waste treatment units used to treat hazardous waste at the generator's site;
(D) Or aqueous wastes generated as a result of site cleanup activities.
(3) A pennit must be obtained prior to commencement of discharge, and
requests for such permits shall be submitted no later than twenty working days prior to intended
discharge. The letter of application shall include the name, address, phone number and title of the
responsible party, on-site contact person's name, address, and twenty-four-hour contact phone
number, analytical data on the contaminants and characteristics of the intended discharge, the
intended point of discharge, the duration and volume, dates of intended discharge, and a site
plan.
(4) A separate charge for processing such requests shall be established by the
Superintendent to recover the City's costs in processing and administering such permits.
(d) The permit for any industrial waste discharge may include, but is not limited to:
(1) A specific date upon which it will expire, not to exceed five years from the
effective date of the permit;
(2) Requiring installation and maintenance of pretreatment technology,
pollution control, or construction of appropriate containment devices, designed to reduce,
eliminate, or prevent the introduction of pollutants into the sanitary sewer system or storm drain
system and compliance schedules for meeting these requirements;
(3) Effluent limitations;
(4) Self monitoring, sampling, reporting, notification and record keeping
requirements;
(5) Prohibition of discharge of certain wastewater components;
(6) Installation and maintenance of inspection, sampling and flow
measurement equipment and facilities;
(7) Limits on average or maximum rate of discharges;
(8) Restriction of discharge to certain hours of the day;
(9) Requiring payment of additional charges to defray increased costs to the
City created by the wastewater discharge;
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(10) Implementation of BMPs or specific investigations or studies to determine
methods of reducing toxic constituents in the discharge;
(11) Other conditions as may be required to meet the purpose of this Chapter.
(e) No permit for industrial waste discharge is transferable without the prior written
consent of the Superintendent. A change of ownership (incfuding a transfer of the majority of
shares in a corporate discharger) of the waste generating facility requires a new permit
application.
(f) Any person or organization desiring to change the quantity or quality of waste
discharged to the sanitary sewer system or to discharge wastes or use facilities which are not in
conformance with their industrial waste permit shall apply for and obtain an amended permit
prior to any such discharge or use. An application for an amended permit must be filed sixty days
in advance of the proposed commencement of such discharge or use of such facilities.
(g) Compliance with the discharger's permit does not relieve the discharger of
responsibility for compliance with all applicable Federal and State Pretreatment Standards,
including those which become effective during the term of the discharge permit.
16.09.085 Industrial wastes discharge permit procedure.
(a) An applicant for a permit for any industrial waste discharge shall complete and
submit an application form established by the Superintendent. The Superintendent may require
information in addition to that required on the application form as deemed reasonable or
necessary to evaluate the application. Interested parties shall be notified of the filing of the
application via posting at city hall or on the city web page.
(b) All wastewater discharge permit applications, user reports and certification
statements must be signed by an authorized representative.
( c) Completed application forms shall be filed by the discharger not less than sixty
days in advance of commencing discharge. The discharger shall not commence discharge prior to
permit approval without specific, interim approval from the Superintendent to discharge during
the permitting process.
(d) Determination of National Pretreatment Category according to the Pretreatment
Requirements. Prior to approval of a discharge permit, the Superintendent shall determine
whether the discharge is subject to the National Pretreatment Standards provided in the
Pretreatment requirements. The determination will be made by the Superintendent following the
guidelines and procedures of that subpart.
(e) The Superintendent may impose terms and conditions on the permit which the
Superintendent deems reasonable or necessary to carry out the purposes ofthis Chapter.
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(f) The application shall be approved if:
(1) The applicant has complied with all requirements of this Chapter and all
applicable city ordinances, state and federal requirements;
(2) The applicant has furnished all requested information;
(3) The Superintendent determines that there are adequate devices, equipment,
chemicals, and other facilities to sample, meter where desirable, convey, treat, and dispose of the
industrial wastes; and
(4) The person(s) to be responsible for treatment and control are adequately
trained and capable of consistently meeting permit requirements.
(g) Interested parties shall be notified of the issuance of permits via posting at city
hall or on a city web page. Interested parties and other members of the public may appeal the
issuance of a permit within forty-five days of issuance and request a hearing on the matter. The
hearing procedures contained in Section 16.09.100 shall be followed. The permit effective date
shall not be postponed solely because of the filing of an appeal.
16.09.090 Requirements for facilities affected by National Pretreatment Standards.
In the event that an industrial waste discharge permit holder or applicant is determined to
be affected by a newly promulgated National Pretreatment Standard or an existing discharge
permit holder is reclassified as being subject to the National Pretreatment Standards provided in
the Pretreatment Requirements due to process changes, or an inspection reveals the presence of
regulated processes, or new information becomes available that justifies or requires a
reclassification, the discharger shall:
(a) File a Baseline Monitoring Report (BMR) per the requirements specified in 40
CFR 403.12(b) within ninety days of the effective date of a National Pretreatment Standard or
reclassification.
(b) If additional pretreatment, operational, or maintenance procedures, or installation
of facilities, equipment or improvements will be required to comply with the National
Pretreatment Standard, the discharger shall include a compliance time schedule per the
requirements specified in 40 CFR 403.12(c) which specifies the shortest feasible schedule by
which the discharger shall provide such additional pretreatment procedures or facilities,
equipment or improvements to attain compliance. For purposes of Pretreatment requirements, the
completion date in this schedule shall not be later than the established compliance date provided
by the applicable Pretreatment Requirements.
(c) File a Compliance Report per the requirements specified in 40 CFR 403.l2(d)
within ninety days of the date for final compliance with applicable National Pretreatment
Standards or in the case of a New Source within ninety days following the date commencement
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of the introduction of wastewater into the sanitary sewer system. The Compliance Report shall
state the average and maximum daily flow in gallons per day to the sanitary sewer system and
shall contain sampling results from National Pretreatment waste streams and shall contain a
certification statement prepared according to the requirements specified in 40 CFR 403 .12(b)( 6).
16.09.095 Modification, suspension or revocation of industrial wastes discharge permit.
(a) Any permit for industrial wastes discharge may be revoked, made subject to
additional terms or conditions, modified or suspended by the Superintendent in addition to other
remedies provided by law, for good cause, including, but not limited to, the following:
(1) To incorporate any new or revised federal, state, or local Pretreatment
Standards or requirements;
(2) To address significant alterations or additions to the discharger's
operation, processes, or wastewater volume or character since the time of the individual
wastewater discharge permit issuance;
(3) To address a change in the plant that requires either a temporary or
permanent reduction or elimination of the authorized discharge;
(4) To stop a discharge or a threatened discharge which presents a hazard or a
threat of hazard to the sanitary sewer system, plant, personnel, public health, safety, welfare,
natural environment, the receiving waters or which violates this Chapter;
(5) For violation of any terms or conditions of the discharge permit;
(6) For misrepresentations or failure to fully disclose all relevant facts in the
discharge permit application or in any required reporting;
(7) For revision of or a grant of variance from categorical Pretreatment
Standards;
(8) To correct typographical or other errors in the individual wastewater
discharge permit;
(9) To reflect a transfer of the facility ownership or operation to a new owner
or operator where requested in accordance with Section 16.09.080(e); or
(10) To implement programs or policies required or requested of the City by
appropriate state or federal regulatory agencies.
(b) Any discharger notified of the Superintendent's intent to revoke, make subject to
additional terms or conditions, modify, or suspend the discharger's permit shall immediately
comply with directives of the Superintendent or cease and desist the discharge of all industrial
wastes or such portion of said wastes as will eliminate the wrongful discharge to the sanitary
sewer system pending any hearing that the discharger may request as set forth in Section
16.09.100 of this Chapter.
(c) The Superintendent shall reissue or reinstate any industrial wastes permit or
modified permit upon proof of satisfactory ability to comply and/or compliance' with all
discharge requirements, and the payment of any costs, fines, or penalties which may be assessed.
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The Superintendent may require any permit holder to develop and implement a compliance
schedule for any proposed modification to permit terms and conditions.
16.09.100 Permit issuance, denial, modification, revocation, or suspension hearing.
(a) The discharger shall have at its request, a hearing before the city manager, or their
designee, before the industrial wastes permit application is issued, denied, or the permit is
revoked, made subject to additional terms or conditions, modified or suspended.
(b) The Superintendent shall give the industrial waste discharger applicant or permit
holder ten calendar days' written notice of intent to issue or deny the application or to revoke,
make subject to additional terms or conditions, modify or suspend the discharger's permit. The
Superintendent shall post a copy of such notice at city hall or on the city web site for interested
persons. The notice shall set forth specifically the grounds for the Superintendent's intention to
deny, revoke, or suspend and shall inform the applicant or permit holder or members of the
public that they have ten days from the date of receipt of the notice to file a written request for a
hearing. The application shall be issued or denied or the permit shall be revoked, modified or
suspended if a hearing request is not received within the ten day period.
(c) If the applicant or permit holder or interested party or parties file(s) a timely
hearing request, the city manager, or their designee, shall within ten calendar days from the
receipt of the request, set a time and place for the hearing. All parties involved shall have the
right to offer testimonial, documentary, and tangible evidence bearing on the issues and to be
represented by counsel. The decision of the city manager, or their designee, whether to issue or
deny the application or revoke, make subject to additional terms and conditions, modify or
suspend the permit shall be final.
16.09.105 Waste sampling locations.
When directed by the Superintendent, establishments from which industrial wastes are
discharged to the sanitary sewer system shall provide and maintain one or more sampling
locations or metering devices or volume and flow measuring methodologies or other sampling
and measuring points approved by the Superintendent which will allow the separate measuring
and sampling of industrial and domestic wastes. Unless otherwise approved by the
Superintendent, domestic and industrial waste shall be kept completely separated upstream of
such sampling locations and/or measuring points. Establishments that are billed for sewer service
on the basis of sewage effluent constituents shall provide a suitable means for sampling and/or
measurement of flow to determine billing constituents in accordance with the utilities rules and
requirements. Sampling locations shall be so located that they are safe and accessible to the
Superintendent at any reasonable time during which discharge is occurring.
16.09.110 Discharger monitoring.
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(a) The Superintendent may conduct all inspection, surveillance, and monitoring
procedures necessary to assure compliance with applicable sections of this Chapter or with
federal or state requirements.
(b) The Superintendent shall be authorized to enter, without unreasonable delay, any
premises of any discharger to carry out inspections, surveillance and monitoring to assure
compliance with this Chapter and applicable federal, state and local requirements. Records shall
be maintained and made available for inspection as described in Section 16.09.160.
(c) In addition to any other remedy available to the City, the Superintendent may
issue a Notice of Non-Compliance at the time of the inspection to require the discharger to
implement actions that will correct violations of this Chapter or the permit. Such directive shall
be considered as an additional condition on the dischargers' permit and may be reviewed as
provided in Section 16.09.100.
(d) Prior to final closure of any industrial or commercial facility, the Superintendent
may require cleaning, inspection andlor testing of the facility's sanitary sewer lines,
appurtenances and/or devices to ensure that the integrity of the sewer lines has not been
compromised and to determine the quantity and pollutant content of sediments. Inspection and/or
testing to ensure the integrity of sewer lines may be required when the facility's discharge history
includes pH fluctuations, or when past discharges may have compromised or call into question
the integrity of the sewer lines. Inspection and/or testing to determine the quantity and pollutant
content of sediments may be required when the facility's type of operations and pollutant content
of discharges make the presence of contaminated sediments likely. Inspection and testing may
include, but not be limited to, pressurized testing, smoke testing, video camera inspection, and/or
analytical testing of sediments for pollutants regulated by the facility's discharge permit. Where
contaminated sediments or compromised sewer lines are identified, responses may include, but
not be limited to, requiring replacement of compromised sewer lines and requiring removal of
contaminated sediments from sewer lines. In lieu of analytical testing, facilities may elect to
remove sediments from sewer lines in a manner approved by the Superintendent. For the
purposes of this section, "final closure" means closure of an industrial or commercial facility
when an entire builliing is being vacated by the current operator, or when the uses of an entire
building will no longer include use of hazardous materials.
16.09.115 Prohibition against dilution.
Except where expressly authorized to do so by the Superintendent or an applicable
National Pretreatment Standard provided in the Pretreatment requirements, no discharger shall
increase the use of process water, combine waste streams or in any other way, dilute a discharge.
In addition, no discharger shall dilute process waste streams as a partial or complete substitute
for adequate treatment to achieve compliance with such National Pretreatment Standard or any
other requirement of this Chapter.
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16.09.120 Discharger self-monitoring.
(a) The Superintendent may require the discharger to conduct a wastewater sampling
and analysis program of a frequency and type sufficient to demonstrate compliance with the
requirements of this Chapter. The discharge permit shall specify the minimum frequency and
type of samples, flow monitoring, measuring, and analyses to be conducted by the discharger.
Additional monitoring may be required by the Superintendent for violation follow-up or as part
of a notice of noncompliance or other enforcement response. If a discharger subject to reporting
requirements monitors any regulated pollutant at a designated sampling location more frequently
than required, the results of this monitoring shall be reported.
(b) The Superintendent may specify the type of sampling equipment and flow
monitoring equipment that must be installed and used. Flow monitoring equipment installed at a
permitted discharger's sampling locations shall be calibrated at a frequency of at least once per
year or at the frequency recommended by the manufacturer. pH monitoring equipment installed
at a permitted discharger'S sampling locations shall be calibrated at a frequency of at least once
every six months or more frequently if recommended by the manufacturer.
(c) Information submitted to satisfy reporting requirements shall be based on data
obtained through appropriate sampling and analysis performed during the period covered by the
report, based on data that is representative of conditions occUrring during the reporting period.
(d) All pollutant sampling techniques, analyses, and information to be included in
self-monitoring reporting, submitted as part of a BMR, wastewater discharge permit application,
or report, shall be performed in accordance with 40 CFR Part 136, 40 CFR 403.l2(g) and
amendments thereto, unless otherwise specified in an applicable categorical Pretreatment
Standard. If 40 CFR Part 136 does not contain sampling or analytical techniques for the pollutant
in question, or where the EPA determines that the Part 136 sampling and analytical techniques
are inappropriate for the pollutant in question, sampling and analyses shall be performed using
validated analytical methods or any other applicable sampling and analytical procedures
suggested by the Superintendent or other parties approved by the EPA. Samples shall be
analyzed at the discharger's expense, by a laboratory accredited by the State of California
Department of Public Health for such analysis.
(e) The detection limit used by the discharger for those substances reported as non-
detectable shall be no greater than one-tenth the lowest applicable effiuent limit.
(f) The discharger shall monitor for the toxic organic compounds specified in the
National Pretreatment requirements applicable to the discharger.
(g) The Superintendent may determine which additional toxic organic compounds
shall be monitored based on those toxic organics that are representative and expected to be
present. Permitted dischargers who file a toxic organic management plan, per the guidelines
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established by the Superintendent, may analyze a subset of the additional toxic organic
compounds to demonstrate compliance with the local limits for Single Toxic Organic (STO) and
Total Toxic Organics (TTO) when specified in a discharge permit issued by the Superintendent.
(h) The Superintendent may require self-monitoring for facilities for which a permit
has not been issued.
(i) All records generated pursuant to this section shall be maintained and made
available for inspection as described in Section 16.09.160.
16.09.125 Maintenance and operation of pollution control and monitoring equipment.
(a) The discharger shall, at all times, properly operate and maintain all facilities and
systems of treatment, disposal, monitoring and control (and related appurtenances) which are
installed or used by the discharger to achieve compliance with this Chapter and/or its wastewater
discharge permit. All required procedures shall be described in an Operations and Maintenance
Manual. The discharger shall keep in a state of readiness all systems necessary to achieve
compliance with the conditions of this Chapter andlor its wastewater discharge permit. All
systems, both those in service and reserve, shall be inspected and maintained on a regular basis.
(b) Inspection and maintenance records for process and pollution control and
monitoring systems shall be maintained and made available for inspection as described in
Section 16.09.160.
(c) It shall be unlawful to tamper with or render inaccurate or divert flow from any
monitoring device or equipment installed or operated to comply with the Pretreatment
requirements, this Chapter or a discharge permit. Doing so constitutes falsification of
information as described in Section 16.09.150.
16.09.130 Compliance with the Pretreatment requirements.
All industrial dischargers subject to the Pretreatment requirements shall be in
conformance with such, including but not limited to, effluent standards, monitoring
requirements, and reporting requirements. In the event of any apparent conflicts between the
requirements established in this Chapter and federal EPA requirements, the most restrictive
limitation shall apply.
16.09.135 Reporting requirements for all permitted dischargers.
(a) All permit holders shall be required to submit periodic reports to the
Superintendent. Specific reporting requirements shall be specified in the permit, in notices of
noncompliance or other directives. All industrial discharge permit holders are required to submit
at a minimum periodic reports of continued compliance (PRCC) every six months. The due dates
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for the PRCC submittals are July 15th and January 15th for the fIrst and second half of the
calendar year respectively. SpecifIc requirements for periodic reports of continued compliance
are listed below:
(1) Certification Statement. Periodic reports of continued compliance for zero
discharge permit holders shall require the permit holder to certify that no process wastewater was
discharged to the sanitary sewer system during the reporting period;
(2) CertifIcation Statement. Periodic reports of continued compliance for
BMP regulated dischargers shall require the discharger to certify that the BMPs have been
implemented during the reporting period;
(3) CertifIcation Statement. Periodic reports of continued compliance for
Non-Significant Categorical Industrial Users shall require the permit holder to certify that the
discharger has met the criteria for a Non-SCIU;
(4) Periodic reports of continued compliance for all permit holders not
covered in (1), (2) or (3) above shall include documentation indicating if applicable federal,
state, or local Pretreatment Standards, including those specifIed in the permit holder's discharge
permit, have been exceeded during the reporting period.
(b) If a discharger subject to reporting requirements monitors any regulated pollutant
at a designated sampling location more frequently than required the results of this monitoring
shall be included in the report.
(c) Failure to submit required reports by the specifIed due date shall be considered a
violation of the provisions of this Chapter.
16.09.140 Requirements for reporting noncompliance, increased loading, slug
discharges, accidental discharges.
(a) Reporting Noncompliance. Noncompliance with the provisions of this Chapter
that is known to the discharger shall be reported verbally as soon as possible but no later than
twenty-four hours of the discharger's knowledge of the noncompliance. A written report to the
Superintendent shall be submitted within fIve days of knowledge of the noncompliance
explaining the nature, volume and duration of the noncompliance, and the mitigation measures
taken to correct the noncompliance and to prevent reoccurrence.
Such notifIcations will not relieve any discharger of liability for any expense,
including but not limited to, costs for countermeasures; loss or damage to the storm drain system,
sanitary sewer system and/or treatment plant or treatment process; or liability to reimburse any
fInes imposed on the City on account thereof; or for damages incurred by any third party.
If the noncompliance is related to any violation of the discharge standards
specifIed in the Pretreatment requirements, this Chapter, or in a discharge permit the discharger
shall repeat the sampling and analysis of the violated pollutant(s) and shall submit the results to
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the Superintendent no later than thirty (30) days from the discharger's knowledge of the
noncompliance.
(b) Reporting Increased Loading. The reporting requirements of subsection (a) above
shall also apply to any short tenn, large or unusual increase in flow or concentration of waste
constituents regardless of whether noncompliance has resulted. Notices shall be posted in
process areas (or other equally effective notification procedures used) giving instruction on
reporting such increases.
(c) Reporting accidental or slug discharges and treatment system upsets, failures, or
bypasses or discharge of hazardous wastes.
The following requirements apply to all releases to the sanitary sewer system
caused by spills; slug discharges; pretreatment system upsets, failures, or bypasses; or any other
accidental discharges:
(l) The discharger shall immediately take action to stop, contain, and cleanup
unauthorized discharges or otherwise stop the noncompliance, and correct the problem.
(2) The discharger shall immediately verbally notify the Superintendent upon
becoming aware of such incidents.
(3) As soon as practicable and throughout the incident the discharger shall
collect representative samples at the point of release and at any impacted sampling location(s).
(4) The discharger shall submit a written report to the Superintendent within
five days of the discharger's knowledge of the incident explaining: the nature, volume, and
duration of the discharge; and mitigation measures taken to correct the noncompliance and
prevent recurrence.
(d) The discharger shall notify the Superintendent in advance of any significant
change in the volume or characteristics of discharge from the facility or any significant
operational, process, or pretreatment system changes.
(e) The discharger shall immediately notify the Superintendent of changes that occur
at the facility affecting the potential for a spill or slug discharge.
16.09.145 Certification of reports.
Permit applications, periodic reports of continued compliance, baseline monitoring
reports, and user reports submitted shall be certified and signed by an authorized representative
with the following statement:
I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the infonnation submitted. Based on my inquiry of the
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person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.
16.09.150 Falsification of information.
It shall be unlawful for a discharger, person or their agents to knowingly make any false
statements, representations, or certifications in any application, record, report, plan, or other
documentation filed, or required to be maintained, pursuant to this Chapter, a wastewater
discharge permit, or an order issued by the Superintendent, or to falsifY, tamper with, or
knowingly render inaccurate any monitoring device or method required under this Chapter or in
a wastewater discharge permit.
16.09.155 Date of receipt of reports.
Written reports will be deemed to have been submitted on the date postmarked. For
reports which are not mailed, postage prepaid, into a mail facility serviced by the United States
Postal Service, the date of receipt of the report by the Superintendent shall govern.
16.09.160 Retention of records.
Dischargers or persons subject to the reporting requirements of this Chapter shall retain,
and make immediately available for inspection and copying upon request, all records of
information obtained pursuant to this Chapter, including but not limited to any monitoring
activities required by this Chapter, any additional records of information obtained pursuant to
monitoring activities undertaken by the discharger independent of such requirements, and
documentation associated with Best Management Practices. These records shall remain available
for a period of at least three (3) years. This period shall be automatically extended for the
duration of any litigation concerning the discharger or the City, or where the discharger has been
specifically notified of a longer retention period by the Superintendent.
16.09.165 Storm drain system: prohibited discharges.
(a) It shall be unlawful to discharge any domestic waste or industrial waste into the
storm drain system, creeks, surface waters or San Francisco Bay. Unlawful discharges shall
include, but not be limited to, discharges from toilets; sinks; industrial processes; cooling
systems; boilers; fabric cleaning; equipment cleaning; vehicle cleaning; construction activities,
including, but not limited to, painting, paving, concrete placement, saw cutting and grading;
swimming pools; spas; and fountains, or substances added to the storm drain to control root
growth, unless specifically permitted by a discharge permit or unless exempted pursuant to
guidelines published by the Superintendent.
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(b) It shall be unlawful to cause hazardous materials, domestic waste or industrial
waste to be deposited in such a manner or location as to constitute a threatened discharge into the
storm drain system, creeks, surface waters or San Francisco Bay. Domestic or industrial wastes
that are not contained in a pipe, tank or other container are considered to be threatened
discharges unless the discharge has been controlled, the flow has been blocked and the material
is actively being cleaned up.
(c) For all unauthorized or prohibited releases to the storm drain system including
sanitary sewer overflows and threatened discharges to the storm drain system, the responsible
person shall:
(1) Immediately take action to stop, contain, and cleanup unauthorized or
threatened discharges or otherwise stop the noncompliance, and correct the problem;
(2) Immediately notify 'the Superintendent upon becoming aware of releases
that result in discharge into the storm drain system, creeks, surface waters or San Francisco Bay.
(d) Interior floor drains shall not be connected to the storm drain system.
(e) Exterior drains located in the following areas shall not be connected to the storm
drain system:
(1)
(2)
(3)
materials that are
contained;
Equipment or vehicle washing areas;
Areas where equipment fluids are routinely changed;
Areas where hazardous materials, chemicals or other uncontained
easily transported by wind or water are stored and are not secondarily
(4) Loading docks: See 16.09.175(k)
(f) Multi-family residential units and residential developments shall be prohibited
from providing a designated vehicle washing area that would cause wash water to be deposited
in such a manner or location as to constitute a threatened discharge into the storm drain system.
(g) Secondary containment shall be provided for any rooftop equipment, tanks or
pipes containing other than potable water, cooling water, heating system hot water, steam, water
condensate or equivalent substances, which the Superintendent determines will otherwise cause a
probable discharge to the storm drain system.
(h) Storm drain inlets shall be clearly marked with the words "No dumping -Flows to
Bay," or equivalent.
16.09.170 Requirements for construction operations.
(a) A spill response plan for hazardous waste, hazardous materials and uncontained
construction materials shall be prepared and available at the construction sites for all projects
where the proposed construction site is equal to or greater than one acre of disturbed soil and for
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any other projects for which the city engineer determines that a plan is necessary to protect
surface waters. Preparation of the plan shall be in accordance with guidelines published by the
city engineer.
(b) A storm water pollution prevention plan shall be prepared and available at the
construction sites for all projects equal to or greater than one acre of disturbed soil and for any
other projects for which the city engineer determines that a storm water management plan is
necessary to protect surface waters. Preparation of the plan shall be in accordance with Chapters
16.28 and 16.11 of this code and with guidelines published by the City engineer.
(c) Prior approval shall be obtained from the city engineer or designee to discharge
water pumped from construction sites to the storm drain system. The city engineer or designee
may require gravity settling and filtration upon a determination that either or both would improve
the water quality of the discharge. Contaminated groundwater or water that exceeds State or
Federal requirements for discharge to navigable waters may not be discharged to the storm drain
system. Such water may be discharged to the sanitary sewer system, provided that the
requirements of Section 16.09.040 are met and the approval of the Superintendent is obtained
prior to discharge. The City shall be compensated for any costs it incurs in authorizing such
discharge, at the rate set forth in the Municipal Fee Schedule.
(d) No cleanup of construction debris from the streets shall result in the discharge of
water to the storm drain system; nor shall any construction debris be deposited or allowed to be
deposited in the storm drain system.
16.09.175 General prohibitions and practices.
(a) Interior (indoor) floor drains to the sanitary sewer system may not be placed in
areas where hazardous materials, hazardous wastes, industrial wastes, industrial process water,
lubricating fluids, vehicle fluids or vehicle equipment cleaning wastewater are used or stored,
unless secondary containment is provided for all such materials and equipment. The
Superintendent may allow an exception to this requirement under the following circumstances:
(1) When the drain is 'connected to a wastewater treatment unit approved by
the Superintendent;
(2) When the drain is protected from spills by a berm system;
(3) For safety showers: When the drain is installed with a temporary plug
which remains closed except when the shower is in use, or when the drain is protected from
spills by either a covered sump or berm system. If a sump is used, the capacity shall be at least as
large as the largest chemical container in the laboratory;
(4) For industrial process equipment: If the equipment does not contain
hazardous materials or hazardous waste and if all floor drains are equipped with fail-safe valves
which shall be kept closed during periods of operation.
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(b) Exterior (outdoor) drains may be connected to the sanitary sewer system only if
the area in which the drain is located is covered or protected from rainwater run-on by berms
and/or grading, and appropriate wastewater treatment approved by the Superintendent IS
provided. For additional information regarding loading docks,see section 1 6.09.1 75(k)
(c) Interior floor drains shall not be connected to the storm drain system.
(d) Exterior drains shall be connected to the storm drain system. Such connections
shall not be permitted within the following areas:
(1) Equipment or vehicle washing areas;
(2) Areas where chemicals, hazardous materials, or other uncontained
materials are stored unless secondary containment is provided;
(3) Equipment or vehicle fluid changing areas;
(4) Loading docks: See l6.09.175(k)
(e) Roof drains may discharge to the storm drain system, provided that all roof
equipment, tanks, and pipes containing other than potable water, cooling system water, or
heating system hot water have secondary containment.
(f) Boiler drain lines shall be connected to the sanitary sewer system and may not be
connected or allowed to drain to the storm drain system.
(g) Secondary containment shall be provided for exterior work areas where motor oil,
brake fluid, gasoline, diesel fuel, radiator fluid or other hazardous materials or hazardous wastes
are used or stored. Drains shall not be installed within the secondary containment areas. The
Superintendent may allow a drain for work areas (but not for hazardous storage areas) if the
secondary containment area is covered and if the drain is connected to a wastewater treatment
facility approved by the Superintendent.
(h) Aspirators connected to laboratory sink faucets are prohibited. Aspirators
designed and used for transferring acids and bases from stationary, permanent laboratory sinks to
treatment facilities shall be allowed.
(i) Laboratory countertops and laboratory sinks shall be separated by a berm which
prevents hazardous materials spilled on the countertop from draining to the sink.
G) Sewer traps below laboratory sinks shall be made of glass or other approved
transparent materials to allow inspection and to determine frequency of cleaning. Alternatively, a
removable plug for cleaning the trap may be provided, in which case a cleaning frequency shall
be established by the Superintendent. In establishing the cleaning frequency, the Superintendent
shall consider the recommendations of the facility. The Superintendent will grant an exception to
this requirement for areas where mercury will not be used; provided, that in the event such an
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exception is granted and mercury is subsequently used in the area, the sink trap shall be
retrofitted to meet this requirement prior to use of the mercury.
i
(k) Loading docks.
(1) This paragraph covers loading docks constructed prior to August 8, 1994.
In cases where chemicals, hazardous materials, grease, oil, or waste products are handled or used
within the loading dock area, a drain to the sanitary sewer system or storm drain system may be
allowed only if equipped with a fail-safe valve or equivalent device that is kept closed during the
non-rainy season and during periods of loading dock operation. For drains connected to the
sanitary sewer system the area in which the drain is located shall be covered or protected from
rainwater run-on by berms and/or grading. Appropriate wastewater treatment approved by the
Superintendent shall be provided for all rainwater contacting the loading dock site.
(2) For loading docks constructed after August 8, 1994:
(i) Loading dock drains to the storm drain system may be allowed if
equipped with a fail-safe valve or equivalent device that is kept closed during the non-rainy
season and during periods of loading dock operation.
(ii) Where chemicals, hazardous materials, grease, oil, or waste
products are handled or used within the loading dock area, a drain to the storm drain system shall
not be allowed. A drain to the sanitary sewer system may be allowed if equipped with a fail-safe
valve or equivalent device that is kept closed during the non-rainy season and during periods of
loading dock operation. The area in which the drain is located shall be covered or protected from
rainwater run-on by berms and/or grading. Appropriate wastewater treatment approved by the
Superintendent shall be provided for all rainwater contacting the loading dock site.
16.09.180 Requirements for newly constructed, remodeled or converted multi
residential, commercial and industrial facilities.
(a) Dischargers of industrial waste from newly constructed, remodeled or converted
commercial and industrial facilities shall be in full compliance with the provisions of this
Chapter at the time of commencement of discharge. Dischargers from newly constructed,
remodeled, or converted commercial and industrial facilities, upon request of the Superintendent,
shall complete a waste minimization study in accordance with guidelines published by the
Superintendent, and shall certify that measures have been taken to minimize toxic constituents in
the discharge.
(b) The owner of every newly constructed, remodeled, or converted commercial or
industrial facility shall comply with the following requirements. These requirements shall apply
to remodeled or converted facilities to the extent that the portion of the facility being remodeled
or converted is related to the subject of the requirement:
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(1) Segregated Industrial Waste Plumbing. The owner of every new
commercial and industrial building or portion thereof shall cause the building to be constructed
so that industrial waste is segregated, by means of separate plumbing, from domestic waste prior
to converging with other waste streams in the sanitary sewer system. For the purposes of this
section only, the term "new" shall also include change to a use that requires plumbing for
industrial waste;
(2)
(3)
Exterior drains shall be connected to the storm drain system;
Loading docks: See I6.09.I75(k).
(4) Fueling areas shall have impermeable floors and rain covers that extend a
minimum of ten feet in each direction from each pump. Fueling areas shall be designed to
prevent water run-on to the covered area;
(5) Condensate lines shall not be connected or allowed to drain to the storm
drain system;
(6) Copper, copper alloys, lead and lead alloys, including brass, shall not be
used in sewer lines, connectors, or seals coming in contact with sewage except for domestic
waste sink traps and short lengths of associated connecting pipes where alternate materials are
not practical;
(7) Sacrificial zinc anodes are not permitted to be in contact with the water
supply in a water distribution system;
(8) Discharge drains for swimming pools, spas and fountains shall not be
connected directly to the storm drain system or to the sanitary sewer system. When draining is
necessary the discharge will be allowed by way of either:
(A) A hose or other temporary system shall be directed into a sanitary
sewer (not storm drain system) clean out. A sewer clean out shall be installed in a readily
accessible area;
(B) A fixed pipe with an air gap and receiving sink directed to the
sanitary sewer.
(9) If installed, parking garage floor drains on interior levels shall be
connected to an oil/water separator prior to discharging to the sanitary sewer system. The
oil/water separator shall be cleaned at a frequency of at least once every twelve months or more
frequently if recommended by the manufacturer or the Superintendent. Oil/water separators shall
have a minimum capacity of 100 gallons;
(10) New buildings and residential developments providing centralized solid
waste collection, except for single-family and duplex residences, shall provide a covered area for
a dumpster. The area shall be adequately sized for all waste streams and designed with grading
or a berm system to prevent water run-on and runoff from the area;
(11) New Multi-family residential units and residential development projects
with 25 or more units shall provide a covered area for occupants to wash their vehicles. A drain
shall be installed to capture all vehicle wash waters and shall be connected to an oil/water
separator prior to discharge to the sanitary sewer system. The oil/water separator shall be cleaned
at a frequency of at least once every six months or more frequently if recommended by the
manufacturer or the Superintendent. Oil/water separators shall have a minimum capacity of 100
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gallons. The area shall be graded or bermed in such a manner as to prevent the discharge of
storm water to the sanitary sewer system;
(12) Mercury switches shall not be installed in sewer or storm drain sumps;
(13) Fire sprinkler system flush, test or drain water shall not be discharged to
the storm drain system. Discharges to the sanitary sewer system shall not exceed 30 gallons per
minute (GPM). Higher discharge rates shall be diverted to a detention tank to achieve the 30
GPMflow;
(14) Copper Roofing Materials. On and after January 1, 2003, copper metal
roofing, copper metal gutters, copper metal down spouts, and copper granule containing asphalt
shingles shall not be permitted for use on any residential, commercial or industrial building for
which a building permit is required. Copper flashing for use under tiles or slates and small
copper ornaments are exempt from this prohibition. Replacement roofing, gutters and
downspouts on historic structures are exempt, provided that the roofmg material used shall be
prepatinated at the factory. For the purposes of this exemption, the definition of "historic" shall
be limited to structures designated as Category 1 or Category 2 buildings in the current edition of
the Palo Alto Historical and Architectural Resources Report and Inventory.
16.09.185 Personnel orientation.
(a) Holders of industrial waste discharge permits shall take necessary steps 'to inform
appropriate personnel employed by such permit holders of the provisions of this Chapter.
(b) Such personnel shall include workers, contractors, and supervisors whose duties
pertain in any manner to the production, treatment or disposal of waste discharges regulated by
this Chapter.
(c) Steps to inform such personnel shall include but not be limited to:
(1) Orientation of newly employed or assigned personnel prior to
commencement of work and at least annually thereafter;
(2) Posting of signs at 'work areas indicating approved methods for disposition
of wastes and reporting requirements and instructions for accidental spills and increased
loadings; and
(3) Posting of signs visible from each drainage area (sink, cup sink, floor
drain) not connected to appropriate treatment indicating "NOTICE do not dispose of chemicals
in this drain" or equivalent.
( d) All signs shall be translated into the appropriate language unless the primary
language of all personnel is English.
16.09.190 Accidental discharge prevention.
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(a) Each discharger shall provide adequate protection to prevent accidental discharge
of hazardous or prohibited materials, slugs, or other wastes regulated by this Chapter. Where
directed by the Superintendent the discharger shall install retention basins, dikes, storage tanks,
or other facilities in conformance with Chapter 17.12 designed to eliminate, neutralize, offset or
otherwise negate the effects of prohibited materials or wastes which may be accidentally
discharged in violation of this Chapter.
(b) When directed by the Superintendent, the discharger shall complete and
implement a slug control plan per the guidelines issued by the Superintendent in accordance with
the requirements contained in 40 CFR. 403.8(f)(2)(vi). The discharger shall notify the City of
any changes to facilities, plans or operations that would necessitate a change in the slug control
plan.
16.09.195 Storage of hazardous materials above sinks.
No person shall store hazardous materials above a sink that is connected to the sanitary
sewer system in a commercial or industrial facility.
16.09.200 Zinc-containing floor finishes.
No person shall discharge or dispose to the sanitary sewer system any zinc-containing
floor finish or a stripper solution that has been used for the stripping of a zinc-containing floor
finish, except when the solutions have been treated in a wastewater treatment unit approved by
the Superintendent for removal of zinc. For the purposes of this section, zinc-containing floor
finishes shall be defined as floor finish solutions containing greater than 0.01 % zinc by weight.
16.09.205 Requirements for cooling systems, pools, spas, fountains, boilers and heat
exchangers.
(a) It shall be unlawful to discharge water from cooling systems, pools, spas,
fountains boilers and heat exchangers to the storm drain system.
(b) No person shall discharge or add to the sanitary sewer system or storm drain
system, or add to a cooling system, pool, spa, fountain, boiler or heat exchanger, any substance
that contains any of the following:
(1) Copper in excess of2.0 mg/liter;
(2) Any tri-butyl tin compound in excess of 0.10 mglliter; or
(3) Chromium in excess of2.0 mg/liter.
(4) Zinc in excess of2.0 mg/liter.
(5) Molybdenum in excess of2.0 mg/liter
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The above limits shall apply to any of the above-listed substances prior to dilution with the
cooling system, pool, spa or fountain water.
( c) Cooling System Discharges.
(1) For the purposes of this section the average daily flow shall be determined
by dividing the total cooling system blowdown volume from April through October by the
number of days of operation for the same period.
(2) The maximum allowable limit for discharge of copper for cooling systems
discharging an average daily flow ofless than 2000 gallons per day shall be 2.0 mglliter.
(3) The maximum allowable limit for discharge of copper for cooling systems
discharging an average daily flow of greater than 2000 gallons per day shall be 0.25 mg/liter.
The Superintendent may impose a higher alternative maximum allowable copper limit when the
cycles of concentrations routinely exceed ten. The alternative requirement may consist of an
alternative limit, a mass limit or a specified maintenance program, or a combination of these.
(4) New cooling systems commencing discharge with an estimated average
daily flow greater than 2000 gallons per day shall comply with the maximum allowable copper
limit of 2.0 mg/liter and shall not be required to comply with the 0.25 mg/liter maximum
allowable copper discharge limit specified in subsection (c)(3), until one year after the date of
such commencement.
(d) Cooling System Cleaning. Wastewater from cleaning of cooling systems, boilers,
heat exchangers and associated piping where a chemical cleaner or physical scouring is used in
the cleaning process shall be sampled prior to discharge to the sewer. The maximum allowable
limits for discharge of copper shall be 2.0 mg/liter. For purposes of this section, "physical
scouring" does not include the use of water at typical water supply pressure; and "associated
piping" shall mean piping associated with a heating or cooling system through which water or
another heat transfer fluid passes during operation of the system. The wastewater shall be
analyzed for copper and any other constituents specified by the Superintendent. The results of
such analysis shall be reviewed by the cooling system operator prior to discharge.
(e)Devices using electricity to dissolve copper or silver into water distribution systems,
cooling systems, pools, spas or fountains are prohibited.
16.09.210 Root and pest control chemicals.
(a) No person shall discharge, dispose of or add to the sanitary sewer system any
substance intended to control roots, pests, or for any other purpose without first acquiring a root
control application permit.
(1) Applicants for a permit shall complete and submit an application form.
The Superintendent shall establish the contents of said form and may require additional
information on the characteristics of the root control chemical and application methods beyond
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that required on the application form. Completed application forms shall be filed by the root or
pest control applicator not less than sixty days in advance of commencing discharge. The
discharger shall not commence discharge prior to permit approval.
(2) The Superintendent may impose terms and conditions on the permit which
the Superintendent deems reasonable or necessary to carry out the purposes of this Chapter.
(b) No person shall discharge, dispose of or add to the sanitary sewer system any
substance containing greater than five percent copper by weight, to control roots or for any other
purpose.
(c) No person shall discharge, dispose or add to the storm drain system any substance
to control roots or pests.
16.09.215 Requirements for photographic materials processing.
(a) All photoprocessors shall comply with either subdivision (2) or subdivision (3) of
this subsection (a). Persons who fully comply with subdivision (3) shall not be required to obtain
an industrial waste discharge permit pursuant to Section 16.09.080, unless required to do so
pursuant to other sections of this Chapter, but shall be required to meet applicable maximum
allowable limits for wastewater discharge and other requirements.
(1) Definitions. For the purposes of this section the following words and
phrases shall be as defined herein.
(A) "Photographic materials processing" means developing silver-
bearing film, including x-ray film, or photographic paper.
(B) "Photoprocessor" means any person who owns a photographic
materials processing system including a business that does photographic materials processing or
any person who engages in photographic materials processing.
(C) "Spent solutions" means spent fixer, bleach fix, stabilizer from
washless systems, silver-bearing cleaning solutions and functionally similar solutions other than
washwater.
(D) "Regeneration" means the treatment of washwater, fix, or bleach
fix for re-use.
(E) "Washwater" means water that has been used to rinse fix or bleach
fix from photographic film or paper.
(2) Silver Removal System. Persons who comply with this subdivision (2)
shall install and operate in their facilities a silver removal system, in a manner which shall insure
consistent compliance with the following effluent standards:
(A) The maximum allowable limit for silver shall be 1.0 mg/liter. The
maximum allowable limit for copper shall be 2.0 mglliter.
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(B) All spent solutions and wash water that are not sent off site shall be
treated to insure consistent compliance with the effluent standards set forth in this subsection
(a)(2). Silver removal from wash water shall be conducted in a manner that does not reduce the
effectiveness of the treatment of spent solutions.
(C) The photoprocessor shall sample the discharge at a frequency
determined by the Superintendent based upon the flow rate from the facility. However, in no
event shall sampling be done less frequently than once a month. A duplicate of each sample
collected shall be kept until the next sampling event. The duplicate sample shall be immediately
relinquished to the Superintendent upon request. A sampling port shall be installed in accordance
with specifications set forth in the wastewater discharge permit.
(D) Every person owning or operating a silver removal system shall
cause such system to be serviced at least once per year by the manufacturer, equipment
distributor, or qualified consultant who shall certify that all equipment in the system is
functioning in accordance with the manufacturer's standards for such equipment. Records of
system service shall be maintained and made available for inspection as described in Section
16.09.160.
(E) Every person intending to comply with the provisions of this
subsection (a)(2), shall submit a completed permit application to the Superintendent, per Section
16.09.085 of this Chapter, at least forty-five days prior to commencing operation of such system.
Every person intending to comply with the provisions of this subsection (a)(2) shall
submit an annual report to the Superintendent on or before February 1 of each calendar year. The
annual report shall contain the following information for the preceding calendar year:
(i)
regeneration systems employed;
(ii)
(iii)
(iv)
operation; and
Type and description of silver removal processes and any
Amount of spent solutions generated;
Dates of equipment servicing;
Description of any major changes in equipment or
(v) All wastewater sampling data.
(3) Off-Site Disposal. Persons who comply with this subsection shall ship or
cause to be shipped off site, for recovery or appropriate disposal, all spent solutions or shall
regenerate all spent solutions on site.
Storage, shipment and disposal of spent solutions shall be in accordance with all state,
federal and local requirements.
(A) Every person who complies with this subsection (a)(3) shall
maintain, or cause to be maintained, records that detail the purchase date and quantity of all new
fixer, bleach-fix, stabilizer and functionally similar solutions kept or used by such person. Such
person shall also maintain, or cause to be maintained, detailed disposal records that include the
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date, type and amount of waste solution disposed of; the name, address and identification number
of the shipper; and the ultimate destination of each batch of waste solution shipped off site. Such
person shall also. maintain, or cause to be maintained, a record of the amount of spent solutions
regenerated on site.
(B) Every photoprocessor intending to comply with the provisions of
this subsection (a)(2) shall submit an annual report to the Superintendent on or before February 1
of each calendar year. The annual report shall contain for the preceding calendar year a summary
of the required records maintained by such person relating to purchase and disposition of
photographic solutions. The summary shall be on a form provided by the Superintendent. Along
with the summary, the photoprocessor shall submit a statement certifying that it is in compliance
with this subsection and that the required records shall be maintained and made available for
inspection as described in 16.09.160.
(C) Photoprocessors that comply with this subsection need not meet
the silver discharge limitations set forth in subsection (a)(2)(A) of this section, nor the silver
discharge limitations set forth in 16.09.040(q) with respect to the photographic materials
processing portion of their operations; provided, however, that those photoprocessors generating
a total of one hundred gallons or more per month of spent solutions shall be required to meet the
silver limitations of subsection (a)(2) of this section with respect to washwater, even if all spent
solutions are shipped off site.
(b) The maximum allowable limit for copper for photographic materials processing
shall be 2.0 mg/liter.
16.09.220 Requirements for dental facilities that remove or place amalgam Idlings.
(a) Definitions. For the purposes of this section the following words and phrases shall
be as defined herein:
(1) "Amalgam separator" is a device that employs filtration, settlement,
centrifugation, or ion exchange to remove amalgam and its metal constituents from a dental
office vacuum system before it discharges to the sanitary sewer system.
(2) "Amalgam waste" means and includes non-contact amalgam (amalgam
scrap that has not been in contact with the patient); contact amalgam (including, but not limited
to, extracted teeth containing amalgam); amalgam sludge captured by chair-side traps, vacuum
pump filters, screens, and other amalgam trapping devices; used amalgam capsules; and leaking
or unusable amalgam capsules.
(3) "ISO 11143" is the International Organization for Standardization's
standard for amalgam separators.
(b) All owners and operators of dental facilities that remove or place amalgam fillings
shall comply with the following waste management practices:
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(1) No person shall rinse chair-side traps, vacuum screens, or amalgam
separators equipment in a sink or other connection to the sanitary sewer system.
(2) Owners and operators of dental facilities shall ensure that all staff
members who handle amalgam waste are trained in the proper handling, management and
disposal of mercury-containing material and fixer-containing solutions. Training records shall be
maintained and made available for inspection as described in Section 16.09.160.
(3) Amalgam waste shall be stored and managed in accordance with the
instructions of the recycler or hauler of such materials.
(4) Bleach and other chlorine-containing disinfectants shall not be used to
disinfect the vacuum line system.
(5) The use of bulk mercury is prohibited. Only pre-capsulated dental
amalgam is permitted.
(c) All owners and operators of dental vacuum suction systems, except as set forth in
subsection (d) of this section, shall comply with the following:
(1) An ISO 11143 certified amalgam separator device shall be installed for
each dental vacuum suction system. The installed device must be ISO 11143 certified as capable
of removing a minimum of 95 percent of amalgam. The amalgam separator system shall be
certified at flow rates comparable to the flow rate of the actual vacuum suction system operation.
Neither the separator device nor the related plumbing shall include an automatic flow bypass.
For facilities that require an amalgam separator that exceeds the practical capacity of ISO 11143
test methodology, a non-certified separator will be accepted, provided that smaller units from the
same manufacturer and of the same technology are ISO-certified.
(2) Amalgam separators shall be maintained in accordance with manufacturer
recommendations. Installation, certification, and maintenance records shall be maintained and
made available for inspection as described in Section 16.09.160.
(d) The following types of dental practice are exempt from Section 16.09.220,
provided that removal or placement of amalgam fillings occurs at the facility no more than 3
days per year:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
Orthodontics;
Periodontics;
Oral and maxillofacial surgery;
Radiology;
Oral pathology or oral medicine;
Endodontistry;
Prosthodontistry.
(e) All owners and operators of dental facilities shall submit an annual report for each
facility to the Superintendent on or before February 1 of each calendar year. The annual report
shall contain information on the dental facility's amalgam separator and its maintenance, and
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shall require the dental facility to certify that it is in full compliance with this section. The annual
report shall be on a form provided by the Superintendent.
(f) The maximum allowable limit for copper for dental facilities shall be 2.0 mg/liter.
16.09.225 Requirements for vehicle service facilities.
(a) Definitions. For the purposes of this section the following words and phrases shall
be as defined herein:
(1) "Commercial vehicle washing facility" means a commercial facility where
vehicle washing is a primary business activity. Commercial vehicle washing facilities include,
but are not limited to, mobile washing rigs.
(2) "Fleet washing facility" means a facility for washing vehicles, at a location
where a business maintains six or more vehicles.
(3) "Ground surfaces" means and includes dirt, gravel, or other unpaved
surfaces.
(4) "Vehicle" means a mode of transporting people or things. Vehicles
include, but are not limited to, automobiles, trucks, recreational vehicles, tractors, airplanes and
boats.
(5) "Vehicle fluid!1 means a liquid used in or drained from a motor vehicle.
Vehicle fluids include, but are not limited to, gasoline, diesel fuel, motor oil, brake fluid, radiator
fluid, hydraulic fluid, transmission fluid, and coolant.
(6) "Vehicle service facility" means a commercial or industrial facility that
conducts one or more of the following operations with respect to vehicles or components of
vehicles: vehicle repair, fuel dispensing, vehicle fluid replacement, engine and parts cleaning,
body repair, vehicle salvage and wrecking, or vehicle washing.
(b) All vehicle service facilities shall be operated in accordance with the following
standards:
(1) No person shall dispose of, nor permit the disposal, directly or indirectly,
of vehicle fluids, hazardous materials, or rinse water from parts cleaning operations into storm
drains;
(2) All owners and operators of vehicle service facilities shall ensure that any
vehicle fluid, hazardous material, or rinse water from parts cleaning operations that comes into
contact with any floor, pavement or ground surface is cleaned up immediately from such surface;
(3) No person shall dispose of vehicle fluids or rinse water from parts
cleaning operations into the sanitary sewer system except pursuant to an industrial waste
discharge permit obtained in accordance with this Chapter;
(4) No vehicle service facilities shall contain floor drains, excepting only such
floor drains as are connected to wastewater pretreatment systems for which an industrial waste
discharge permit has been obtained in accordance with this Chapter;
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(5) No tanks, containers or sinks used for parts cleaning or rinsing shall be
connected to the storm drain system, or to the sanitary sewer system except pursuant to an
industrial waste discharge permit obtained in accordance with this Chapter;
(6) No person shall perform vehicle fluid removal outside a building, nor on
asphalt or ground surfaces, whether inside or outside a building, except in such a manner as to
ensure that any spilled fluid will be in an area of secondary containment;
(7) Leaking vehicle fluids shall be contained or drained immediately;
(8) No person shall leave unattended drip parts or other open containers
containing vehicle fluid, unless such containers are in use or in an area of secondary
containment;
(9) No person shall discharge wastewater from vehicle washing operations or
wash racks to the storm drain system or onto the ground. Discharge to the sanitary sewer system
may be allowed pursuant to an industrial waste discharge permit obtained in accordance with this
Chapter. Nothing in this subsection shall be construed to prohibit the proper reuse of wastewater;
(10) No person shall discharge into the storm drains water from vehicle
washing operations, except from rinsing of vehicle exterior surfaces, with water only, to remove
atmospheric dust that deposited on a vehicle when not in use. This exception does not apply to
commercial vehicle washing facilities or fleet washing;
(11) Vehicle service facilities shall be cleaned using only those methods of
cleaning that ensure that no materials are discharged to the storm drain system or to the sanitary
sewer system, except for wastewater which is discharged to the sanitary sewer system pursuant
to an industrial waste discharge permit obtained in accordance with this Chapter; provided,
however, that a permit shall not be required for facilities that use the following three-step
sequence for cleaning floors:
(A) Clean up spills with rags or other absorbent materials;
(B) Sweep floor using dry absorbent material;
(C) Mop floor. Mop water must be discharged to the sanitary sewer via
a toilet or sink.
(12) All owners and operators of vehicle service facilities shall ensure that spill
prevention and clean-up equipment and absorbent materials are kept in stock at all times and are
readily available for use;
(13) No acid-containing batteries shall be stored except within secondary
containment;
(14) All owners and operators of vehicle service facilities shall ensure that all
employees of such facilities are trained, upon hiring and annually thereafter, regarding best
management practices in accordance with guidelines issued and published by the Superintendent.
(15) All owners and operators of vehicle service facilities shall post or cause to
be posted signs on all storm drain inlets located on the property of the facility with the words
"No dumping Flows to Bay" or equivalent;
(16) No person shall discharge to the sanitary sewer system solid materials
from wet sanding. Vehicle service facilities using wet sanding processes shall have one or more
containers to accumulate wet sanding wastewater and mop water from wet sanding areas. A
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minimum of 48 hours shall be provided for the settling of solid materials from the water prior to
the water's discharge to the sanitary sewer system. An alternative solids removal method may be
utilized provided that the method has been demonstrated to be equally effective, and approved by
the Superintendent. Settled solid materials shall be managed in accordance with all state, federal
and local requirements.
(c) The maximum allowable limit for zinc for vehicle service facility discharge shall
be 4.0 mglliter. The maximum allowable limit for copper for vehicle service facility discharge
shall be 2.0 mglliter
(d) All records required to be kept pursuant to this subsection shall be maintained and
made available for inspection as described in Section 16.09.160.
16.09.230 Requirements for machine shops.
(a) All machine shops shall be operated in accordance with the following standards:
(1) No person shall dispose of, nor permit the disposal, directly or indirectly,
of machine shop fluids, hazardous materials, mop water, or rinse water from parts cleaning or
deburringltumbling operations into storm drains;
(2) No person shall dispose of machine shop fluids or rinse water from parts
cleaning or deburringltumbling operations into the sanitary sewer system except pursuant to an
industrial waste discharge permit obtained in accordance with this Chapter;
(3) No machine shop shall contain floor drains, excepting only such floor
drains as are connected to wastewater pretreatment systems for which an industrial waste
discharge permit has been obtained in accordance with this Chapter;
(4) Machine shops shall be cleaned using only those methods of cleaning
which ensure that no materials are discharged to the storm drain system or to the sanitary sewer
system, except for wastewater that is discharged to the sanitary sewer system pursuant to an
industrial waste discharge permit obtained in accordance with this Chapter; provided, however,
that a permit shall not be required for facilities that use the following three-step sequence for
cleaning floors, or an approved equivalent:
(A) Clean up spills with rags or other absorbent materials;
(B) Sweep floor using dry absorbent material; and
(C) Mop floor. Mop water shall be discharged to the sanitary sewer via
a toilet or sink.
(5) All owners and operators or machine shops shall ensure that spill
prevention, clean-up equipment and absorbent materials are kept in stock at all times and are
readily available for use.
(6) All owners and operators of machine shops shall post or cause to be
posted signs on all storm drain inlets located on the property of the facility with the words "No
Dumping -Flows to Bay" or equivalent. .
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(7) All owners and operators of machine shops shall ensure that all employees
who work directly on machine operations or clean up of such facilities are trained, upon hiring
and annually thereafter, regarding best management practices for machine shops in accordance
with guidelines issued and published by the Superintendent.
(b)
mg/liter.
16.09.235
The maximum allowable limit for copper for machine shop discharge shall be 2.0
Annual publication of significant noncompliant dischargers.
At least annually, notice shall be provided in the largest local daily newspaper listing
those dischargers that were found to have been in significant noncompliance, as defined in this
Chapter, during the previous twelve months.
16.09.240 Enforcement: Warning.
The Superintendent may issue verbal or written warnings in response to minor violations
or the potential for a discharger to cause violations of this Chapter. Compliance with warnings
does not limit further enforcement action by the City.
16.09.245 Enforcement: Notice of non-compliance.
(a) Unless the Superintendent fmds that the severity of the violation warrants
immediate action under Sections 16.09.255, 16.09.265 or 16.09.270 or permit revocation or
suspension, he or she shall issue a notice of noncompliance which:
(1 ) Enumerates the violations found; and
(2) Orders compliance by a certain date.
If the violations are not abated in the time period identified further action may be taken
by the Superintendent, including, but not limited to, suspension, revocation or modification of
the discharger's permit pursuant to Section 16.09.095.
(b) Subject to the following limitations, and in addition to the provIsIons of
subsection (a), the Superintendent may require a discharger that has violated any discharge limits
contained in this Chapter to install a temporary system for the capture, testing and release of
wastewater:
(1) The requirement will apply to facilities that have produced multiple
violations for the same parameter at the same sampling point, when the Superintendent
determines that appropriate corrective measures have proved difficult to identify or implement.
(2) The requirement will apply only to those specific areas of a facility from
which the Superintendent determines that the discharge may be originating, rather than to the
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entire flow from the facility, unless there is no reasonable way to determine where the discharge
may be originating.
(3) The requirement will not be applied when the Superintendent determines
that a capture system is impracticaL If the Superintendent determines that a capture system is
impractical, the Superintendent may require an alterpative compliance measure of equivalent
effectiveness.
(4) The requirement will be terminated following a demonstration of
compliance as determined by the Superintendent. The sampling required to demonstrate
compliance for violations of discharge limits shall be set by the Superintendent and may be up to
twenty-one consecutive, violation-free calendar days of sampling by the discharger followed by
up to four days of violation-free sampling by the Superintendent.
16.09.250 Enforcement: Administrative compliance order.
Any person who violates any provision of this Chapter or any provision of any permit
issued pursuant to this Chapter shall be subject to the administrative compliance order provisions
contained in Chapter 1.16 of this code.
16.09.255 Enforcement: Criminal penalties.
As provided in 1.08 of Title 1 of this code, violations of the provisions of this title shall
be subject to criminal penalties. The following designated employee positions may enforce the
provisions of this Chapter by the issuance of citations. Persons employed in such positions are
authorized to exercise the authority provided in Penal Code Section 836.5 and are authorized to
issue citations for violations of this Chapter. The designated employee positions are: industrial
waste inspector; industrial waste investigator; associate engineer; manager, environmental
control programs; supervisor, industrial waste; and manager, environmental compliance division.
16.09.260 Enforcement: Administrative citation.
Any person who violates any provision of this Chapter or any provision of any permit
issued pursuant to this Chapter shall be subject to the administrative citation provisions
contained in Chapter 1.12 of this code.
16.09.265 Enforcement: Administrative civil penalties.
(a) Complaint. The Superintendent may serve an administrative complaint on any
person who has violated any provision of this Chapter. The complaint shall state:
(1) The act or failure that constitutes the violation;
(2) The provisions of law authorizing the civil liability to be imposed; and
(3) The proposed civil penalty.
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The complaint shall be served by personal delivery or certified mail on the person subject
to requirements that the Superintendent alleges were violated, and shall inform the person served
that a hearing on the complaint shall be conducted within sixty days after service, unless the
person charged with the violation waives his or her right to a hearing.
(b) Hearing. Unless the person charged with the violation(s) waives his or her right to
a hearing, the city manager or designee of the city manager shall conduct a hearing within sixty
days. If the hearing officer finds that the person has caused a violation, he or she may assess
administrative penalties against the person. In determining the amount of the civil penalty, the
hearing officer may take into consideration all relevant circumstances, including, but not limited
to, the extent of harm caused by the violation, the economic benefit derived through any
noncompliance, the nature and persistence of the violation, the length of time over which the
violation occurs and corrective action, if any, attempted or taken by the discharger. Civil
penalties that may be imposed are as follows:
(1) An amount not to exceed two thousand dollars per day for failing or
refusing to furnish technical or monitoring reports;
(2) An amount not to exceed three thousand dollars per day for failing or
refusing to comply in a timely fashion with any compliance schedule established by the City;
(3) An amount not to exceed five thousand dollars per day of violation for
discharges in violation of any waste discharge limitation, permit condition or requirement issued
by the City; and
(4) An amount not to exceed ten dollars per gallon for discharges in violation
of any suspension, cease and desist order or other orders, or prohibition issued, reissued or
adopted by the City.
(c) Appeal. Any person against whom penalties are assessed by the hearing officer
may appeal the decision of the hearing officer within thirty days of notice of the decision. The
city council may hear the appeal or deny review of the case. If the city council decides to hear
the appeal, it shall conduct the appeal in accordance with procedures established by the council.
The decision of the city council shall be in writing and shall be final. All civil penalties imposed
in accordance with this section shall be payable within thirty days of the decision of the hearing
officer; provided, that if the decision is appealed, all penalties shall be payable within thirty days
after the city council decision on the appeal.
(d) Lien. The amount of any civil penalties imposed under this section which have
remained delinquent for a period of sixty days shall constitute a lien against the real property of
the discharger from which the violation occurred resulting in imposition of the penalty. The
Superintendent shall cause the amount of uncollected penalty to be recorded with the county
recorder, in accordance with Section 54740.5 of the California Government Code, as the same
from time to time may be amended.
16.09.270 Enforcement: Judicial civil penalties.
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Any person who intentionally or negligently violates any provision of this Chapter or any
provision of any permit issued pursuant to this Chapter shall be civilly liable to the City in a sum
of not to exceed twenty-five thousand dollars per day for each day in which such violation
occurs. The City may petition the Superior Court pursuant to Government Code Section 54740 to
impose, assess, and recover such sums. The remedy provided in this section is cumulative and
not exclusive, and shall be in addition to the penalty provisions of Chapter 1.08 of this code and
all other remedies available to the City under state and federal law.
16.09.275 Damage to facilities.
When a discharge causes an obstruction, damage, or any other impairment to City
facilities, the City may assess a charge against the discharger to reimburse the City for costs
incurred to clean or repair said facility.
16.09.280 City right to terminate discharge.
The City reserves the right to terminate sewer service for noncompliance with the
provisions of this Chapter which reasonably appear to present an imminent endangerment to the
health, safety, and welfare of persons. The discharger shall immediately cease discharge of any
waste presenting such a hazard, upon verbal and/or written notice of the Superintendent. Such
termination shall be effective immediately, but shall be reviewable pursuant to the hearing
process provided in Section 16.09.100.
16.09.285 Enforcement: Remedies Nonexclusive.
The remedies provided for in this ordinance are not exclusive. The Superintendent may
take any, all, or any combination of these actions against a noncompliant discharger.
Enforcement of Pretreatment violations will generally be in accordance with the City's
enforcement response plan. However, the Superintendent may take other action against any
discharger when the circumstances warrant. Further, the Superintendent is empowered to take
more than one enforcement action against any noncompliant discharger.
SECTION 3. The adoption and implementation of this Ordinance is categorically
exempt from the California Environmental Quality Act pursuant to CEQA Guideline Section
15308 (actions by regulatory agencies for the protection of the environment).
II
II
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SECTION 4. This ordinance shall be effective on the thirty-first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk
APPROVED AS TO FORM:
Deputy City Attorney
100520 syn 6051181
61
Mayor
APPROVED:
City Manager
Director of Public Works
Director of Administrative
Services
ATTACHMENTB
Palo Alto list of2010 Sewer Use Ordinance Changes
1. General changes
a. Pretreatment Regulations are now called Pretreatment Requirements.
b. Deleted passed implementation dates where unnecessary.
c. Used Superintendent to mean superintendent or designee throughout.
d. Used Discharger throughout for both wastewater and storm water.
e. Used Storm Drain System throughout.
f. Used Sanitary Sewer System throughout.
g. Referred to retention and inspection of records section instead of repeating.
h. Added "or city web site" for required po stings where allowed.
2. Purpose 005 (005)
a. Modified to include Clean Water Act.
3. Definitions 010 (010)
a. Defined Authorized Representative.
b. Defined Berm to include lips, ridges or other raised barriers.
c. Defined Best Management Practices.
d. Defmed Biochemical Oxygen Demand (BOD).
e. Defined Categorical .
f. Defmed City to mean City of Palo Alto.
g. Defined Discharge.
h. Defined Discharger to include industrial OR domestic waste into the sanitary
sewer system or storm drain system. Added "potential" to include haulers and
zero dischargers.
1. Defined Enforcement Response Plan.
J. Defined Fail Safe Valve to include gravity or spring loaded in addition to
electrically operated valves.
k. Definitions of Grease Control Device and Food Service Establishment moved to
Fat, Oil, and Grease (FOG) Rules and Regulations.
1. Defined Hazardous Waste to include both State and Federal requirements.
m. Defmed Interference to include exceedance of capacity of sanitary sewer system
n. Deleted Industrial User, Instantaneous Maximum and Instantaneous Minimum.
These terms are not used.
o. Defmed Pretreatment Standard.
p. Defined Root Control Chemical.
q. Defined Sanitary Sewer Overflows.
r. Defined Significant Industrial User.
s. Defined Single Toxic Organic (STO).
t. Defined Storm Drain System to include gutter or surface conveyance.
u. Defined Slug Discharge to clarify sources and circumstances.
v. Defmed Total Toxic Organics (TTO).
w. Defined Toxic Organic.
4. Prohibitions 035 (100)
a. Modified pollutant prohibition to specifically include Biological Oxygen Demand
(BOD).
b. Prohibited discharges that obstruct flows or contribute to a sanitary sewer
overflows.
c. Removed prohibition against discharges greater than 120°F.
5. Standards 040 (110)
a. Removed time limits for pH excursions 16.09.110(c).
b. Removed limits on temperature. General prohibition against raising the
temperature of the treatment plant influent remains.
c. Required verbal and written reporting for discharge of hazardous waste
16.09.11O(g).
d. Must keep hazardous waste manifests available for inspection 16.09.110(g).
e. Must notify and update Toxic Organic Management Plan (TOMP) when changes
occur 16.09.110(h).
f. May allow a subset of toxic organics to be analyzed based on Toxic Organic
Management Plan (TOMP) 16.09.110(i).
g. Modified solids discharge prohibition to include viscous materials.
h. Changed instantaneous limits to maximum allowable concentrations.
16.09.110(m).
1. Changed maximum allowable cyanide concentration from 1.0 to 0.5 mg/L
16.09.110(m).
J. Clarified that metals limits are for total metals.
6. Best Management Practices 065 (new)
a. May require submission of documentation demonstrating implementation.
7. Food Service Establishments 075 (103)
a. Expanded requirements and codified best management practices.
8. Industrial waste discharge permit 080 (020)
a. Compliance with permit doesn't ensure compliance with State and Federal
requirements. "
9. Permit Procedure 085 (030)
a. Changed "categorical" to "national pretreatment standards."
b. All permits, reports and certifications must be signed by authorized
representative.
c. Notification may be posted on a City web page.
10. Requirements for facilities subject to
national pretreatment standards 090 (031)
a. Reporting requirements for new facilities amended to include critical Federal
requirements and reference to the Federal requirements.
11. Modification of permit 095 (040)
a. Clarification of circumstances leading to permit modifications.
12. Discharger Monitoring 110 (061)
a. Required cleaning, inspection and testing of sewer and appurtenances for closing
industrial and commercial facilities.
13. Dilution 115 (121)
a. Expressly prohibited dilution without stipulation that the intent be to meet limits.
14. Discharger Self Monitoring 120 (095)
a. Reorganized to group appropriate topics.
b. Samples must be representative of conditions during reporting period.
c. Analyses and sampling conducted using 40 CFR Part 136.
d. Superintendent may specify subset of toxic organics appropriate for Single Toxic
Organic (STO) and Total Toxic Organics (TTO) monitoring.
15. Maintenance and operation of pollution control equipment 125 (new)
a. Equipment shall be maintained.
b. Records of maintenance shall be kept for 3 years and available to inspectors.
c. Unlawful to tamper with controls, monitoring equipment, or to divert flows.
16. Reporting 130 (150)
a. Added reporting of any changes to process, discharge, treatment.
b. Added reporting of any changes for potential for spills or slug loads.
17. Reporting Requirements 135 (033)
a. Added semi-annual due dates.
b. Added zero discharge certification.
c. Added compliance certification.
d. Added Best Management Practices (BMP) certification.
e. Added that any additional monitoring must be reported.
18. Reporting Non-compliance 140 (155)
a. Expanded to include storm drain system, not just sanitary discharges.
b. Expanded to include/clarify increased loading, slug discharges, accidental
discharges, treatment system failures, and hazardous waste discharges in addition
to noncompliance with discharge limits.
c. Added follow-up sampling required within 30 days.
d. Added must take immediate steps to stop, contain and clean-up discharge.
e. Added shall take samples representative of discharge or release.
19. Certification of reports 145 (new)
a. All submissions accompanied by signed certification of accuracy.
20. Falsification of information 150 (new)
a. Submission of false or misleading information is a violation.
21. Receipt of report 155 (new)
a. Receipt date is postmark.
22. Retention of records 160 (new)
a. Records retained for three years and available to inspectors.
23. Storm drain prohibited discharges 165 (106)
a. Removed that a threatened discharge must demonstrate a "probability of harm" to
be prohibited.
b. Must take steps for containment and clean-up of a storm drain spill.
c. Added reporting requirements for storm drain spills.
d. Modified "threatened discharges" to exclude spills where discharge has been
controlled and the flow has been blocked in addition to the material is actively
being cleaned up.
e. Carwash to storm drain prohibited for Multi-family residential units and
residential development projects.
f. Carwash provided for new multi-residential moved to 16.09.032
g. Carwash provided changed to more specifically include multi-single family home
community projects. This will specifically now cover home development projects
with more than 25 detached or shared wall units.
h. Covered dumpster area provided for new multi-residential moved to 16.09.032.
24. General Prohibitions and Practices 175 (092, 032)
a. No Interior (indoor) floor drains unless secondary containment is provided for
chemicals, hazardous materials or waste. Exceptions:
1. Connected to a wastewater treatment;
n. Protected from spills;
111. Safety showers with a temporary plug or protected from spills;
iv. Industrial ifno hazardous waste and failsafe valve.
b. Exterior (outdoor) drains if covered or protected. Reference to single Loading
Dock section.Interior floor drains shall not be connected to the storm drain.
c. Exterior drains to the storm drain. Except:
i. Equipment or vehicle washing areas;
n. Areas with chemicals unless secondary containment is provided;
iii. Equipment or vehicle fluid changing areas;
iv. Loading docks with chemicals (reference to single Loading Dock section).
d. Roof drains may discharge to the storm drain if roof equipment, tanks, and pipes
containing other than potable water, cooling system water, or heating system hot
water have secondary containment.
e. Boiler drain lines may not be discharged to the storm drain system.
f. Condensate lines may not drain to the storm drain system.
g. Secondary containment shall be provided for exterior work areas where hazardous
materials or hazardous wastes are used or stored.
h. Aspirators connected to laboratory sink faucets are prohibited.
1. Laboratory countertops and laboratory sinks shall be separated by a lip.
J. Sewer traps below laboratory sinks shall be made of glass when there is use of
elemental mercury.
25. New Construction 180 (032, 160)
a. Floor drains allowed when equipped with berms.
b. Copper drain line prohibition modified to allow copper traps and short length
connection pipes only for domestic waste and where alternatives are not practical.
16.09.032(b )(9).
c. Swimming pool discharge modified to allow fixed discharge point with air gap.
16.09.032(b )(15).
d. Covered dumpster requirement clarified to cover residential developments
providing centralized collection and requiring sizing adequate for all solids waste
streams. Clarified use of berm system or grading to prevent runon and runoff.
16.09.032(b)(17)
e. No mercury switches in sewer or storm drain sumps.
f. Moved a number of items to 16.06.092 Prohibited Materials and Practices. These
items are now standard in most industrial facilities. This was not the case at the
time of the original ordinance.
g. Clarified prohibition on copper roofmg and gutters to include downspouts.
16.09. 160(b)
26. Personnel Orientation 185 (035)
a. Clarification of work area and sink signage requirements.
27. Accidental discharge prevention 190 (090)
a. Preparation of Slug Control Plans may be required.
28. Fountains, pools, spas and cooling towers 205 (114)
a. Added boilers and cooling systems.
b. Prohibited discharge to storm drains.
c. Prohibited addition of chemicals to fountains, pools, spas, cooling towers, storm
drains or the sanitary sewer that contain greater than 2 ppm of Molybdenum or
Zinc.
d. Removed passed cooling tower compliance deadline for meeting 0.25 ppm Cu
limit and replaced with one year compliance schedule for new cooling towers.
29. Root Control Chemicals 210 (101)
a. Prohibition against use without permit.
30. Photographic Processing 215 (111)
a. Records shall be maintained for three years and made available for inspection.
b. Removed separate limit for photo processors with reduced water use.
c. Removed passed compliance dates and compliance schedules.
31. Dental Requirements 220 (112)
a.Removed past dental requirement implementation dates.
b. Added record retention and availability requirements.
c. Remove exemptions.
d. Added annual reporting requirements.
32. Automotive 225 (113)
a. Removed past automotive requirement implementation dates.
b. Requirement to handle solids in accordance with State and Local regulations.
c. Required labeling of storm drains.
33. Enforcement Remedies
a. Rearranged in order of severity and consolidated all enforcement.
b. Moved Damage to facilities 275 (130).
c. Moved termination of discharge 280 (152).
d. Added not exclusive to those listed in ordinance 280 (new).
e. Added Warning 240 (new).
34. End
Memorandum
DATE: October 27, 2006
TO:
SUBJECT:
cc:
Brad Eggleston, City of Palo Alto
City of Palo Alto Local Limits
Evaluation
Betsy Elzufon, LWA
Eric Zeigler, L WA
INTRODUCTION
ATTACHMENT C
L A R R Y
WALKER
IA
ASSOCIATES
Gorman Lau, P.E.
250 Lafayette Circle, Suite 200
Lafayette, CA 94549
925.962.9700 (phone)
925.962.9701 (fax)
gormanl@lwa.com
The purpose of this technical memorandum is to evaluate recent monitoring data for the
period 2004 through 2005 to determine if the City of Palo Alto's (City's) current local
limits are adequate to protect the Palo Alto Regional Water Quality Control Plant
(RWQCP) from upset, protect biosolids quality, meet current National Pollutant
Discharge Elimination System (NPDES) effluent limitations, and protect worker health
and safety.
The major elements of this technical memorandum include the following:
•
•
•
•
•
Background;
Local limits evaluation;
Local limits update strategy;
Pretreatment Streamlining Rule; and
Recommendations.
City of Palo Alto 1
Palo Alto Regional Water Quality Control Plant
October 2006
Local Limits Evaluation
::::. .
BACKGROUND
Regional Water Quality Control Plant Treatment Process Description
The City owns and operates the RWQCP, which provides treatment of domestic,
commercial, and industrial wastewater from the cities of Los Altos Hills, Los Altos, Palo
Alto, Mountain View, the service area of East Palo Alto Sanitary District, and Stanford
University. The RWQCP is a tertiary wastewater treatment facility with a dry weather
design capacity of 39 million gallons per day (MGD) and can treat up to 80 MGD during
wet weather conditions. Wastewater treatment consists of screening, primary
sedimentation, fixed film roughing filters, activated sludge, nitrification, secondary
clarification, filtration, disinfection, and dechlorination.
Approximately 95% of the treated effluent is discharged into a man-made channel
(Latitude 3r27'30", Longitude 122°06'45"), which is tributary to Lower South San
Francisco Bay. Approximately 5% of the treated effluent is discharged into the Renzel
Marsh Pond, which is a reclamation project. A small percentage of the treated effluent
is reused for irrigation and construction dust suppression.
Biosolids are currently thickened, dewatered using belt presses, and incinerated. Ash is
hauled offsite and used for soil augmentation on farm and ranch lands in the Central
Valley.
Development of Local Limits
The development and implementation of local limits is a requirement of the National
Pretreatment Program and the City's NPDES permit. As such, local limits are designed
to protect the RWQCP against industrial discharges that may cause treatment process
upset, cause violation of NPDES permit requirements, or create potential health and
safety concerns for facility operators and the public.
The City's existing local limits were generally derived according to the procedures and
recommendations presented in the USEPA Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the Pretreatment Program (1987).
Since the development of City's local limits, USEPA developed its Local Limits
Development Guidance (Local Limits Guidance) in July 2004, which updates the 1987
guidance. The evaluation of the City's local limits presented in this memorandum
follows the guidance and recommendations of the Local Limits Guidance.
Pollutants of Concern (POCs)
The 1987 local limits guidance specified ten national POCs: arsenic, cadmium,
chromium, copper, cyanide, lead, mercury, nickel, silver, and zinc. The 2004 Local
Limits Guidance recommends that the initial ten national POCs be evaluated, as well as
five new POCs: molybdenum, selenium, ammonia, 5-day biochemical oxygen demand
(BOD), and total suspended solids (TSS).
City of Palo Alto 2 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
The City currently has local limits for each of the 2004 national POCs except ammonia,
BOD, and molybdenum. Additionally, the City has local limits for other constituents for
which there are no local limits derivation driving factors or for which adequate data were
not available to evaluate the need for a local limit. These constituents were not
evaluated as part of this effort.
For this local limits evaluation, updated maximum allowable headworks loadings
(MAHLs) were calculated for each of the national POCs (including ammonia and BOD).
Adequate data were not available to calculate an MAHL for molybdenum. The purpose
of recalculating MAHLs for each POC is to account for updated information including the
City's current NPOES permit, recent removal efficiency data, and other changes to
RWQCP operations.
City of Palo Alto 3 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
LOCAL LIMITS EVALUATION
This local limits evaluation is divided into two tasks:
• Compare current influent loadings with MAHLs for each POC; and
• Review of compliance history.
This local limits evaluation utilizes data collected between January 2004 and December
2005 for influent effluent, and biosolids. Biosolids data from 2004 and 2005 are
evaluated to determine compliance with California Code of Regulations (CCR) and air
emission standards.
Comparison of Current Influent Loadings with MAHLs
Evaluation Criteria
Local Limits Guidance recommends that an MAHL be calculated for each POCo Afte r
MAHLs are calculated for each POC, the MAHLs are compared to existing influent
loadings. Local Limits Guidance suggests that local limits are necessary if any of the
following criteria are satisfied:
• Average influent loading of a toxic pollutant exceeds 60 percent of the MAHL, or
• Maximum daily influent loading of a toxic pollutant exceeds 80 percent of the
MAHL any time in the 12-month period preceding the analysis, or
• Monthly average influent loading reaches 80 percent of the average design
capacity for BOD, TSS, and ammonia during anyone month in the 12-month
period preceding the analysis.
Because the City's current local limits were derived according to the 1987 local limits
guidance, the above criteria were not used to determine POCs for which local limits are
necessary. As a result, there are existing local limits for POCs that do not meet the
above-listed criteria. These constituents (listed below) are not included in the following
local limits evaluation.
• Barium;
• Beryllium;
• Boron;
• Cobalt;
• Fluoride;
• Formaldehyde;
• Manganese;
• Phenols;
• Single toxic organics (STOs);
City of Palo Alto 4 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
• Total dissolved solids; and
• Total toxic organics.
For POCs that do not currently have an MAHL or local limit, the 2004 criteria listed
above were used to evaluate the need for local limits or other actions for these POCs by
the City. Local Limits Guidance recommends the following steps be taken to evaluate
POCs for which local limits are not currently established:
• If the current influent pollutant loading exceeds the MAHL, USEPA recommends
that a local limit is established for the pollutant. The source of the elevated
loading should be investigated, monitoring should be increased, and pollution
prevention efforts should be considered.
• If the current influent pollutant loading exceeds the established threshold value
(criteria listed previously) for the first time, USEPA recommends increased
monitoring for the pollutant.
• If the current influent pollutant loading exceeds the established threshold value
for the second time, USEPA recommends establishing a local limit and
increasing pollutant monitoring.
• If the current influent pollutant loading is below the established threshold, USE PA
recommends reviewing the pollutant periodically.
For pollutants that currently have local limits, USEPA recommends the following steps
for evaluating each POC:
• If the current influent POC loading exceeds the MAHL, USEPA recommends
revising the local limit (unless an investigation reveals that the elevated loading is
due to an unusual, one-time event), investigating the cause of the high loading,
identifying any non-complying industries, increasing monitoring of industrial
users, and considering adopting pollution prevention efforts.
• If the current influent POC loading has increased significantly from the previous
year (e.g. from 55% to 75% of the MAHL), USEPA recommends that the cause
of the increased loading be investigated, monitoring for the POC be increased, or
the local limit be revised.
• If the current influent POC loading is below the established threshold, USEPA
recommends reviewing the pollutant periodically.
MAHL Calculations
MAH Ls that were used to derive the City's existing local limits have changed over time
due to changes to the RWQCP treatment process, changes to the City's NPDES permit
upon renewal, and updates to effluent limitations. Six major factors serve as the basis
for MAHL development. These include NPDES permit effluent limitations, California
Toxics Rule and San Francisco Bay Region Basin Plan water quality criteria/objectives,
biosolids disposal restrictions, air emission standards, treatment process inhibition
levels, and treatment plant design capacity.
City of Palo Alto 5 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
In this evaluation, MAHLs for each POC were recalculated based on the equations and
derivation procedures outlined in the Local Limits Guidance. To calculate MAHLs
based on water quality criteria/objectives, it is assumed that the receiving water
hardness is 100 mg/L as CaC03 (as has been assumed in the existing NPDES permit)
and that the receiving water is effluent-dominated. This leads to the direct application of
water quality criteria/objectives as effluent limits using the pass-through MAHL
derivation equations.
Current treatment plant removal efficiencies have been calculated using influent and
final effluent data collected between January 2004 and December 2005. Domestic
collection system data are not available for ammonia, BOD, and TSS. Typical domestic
collection system data from other municipalities are used for these three cons tituents.
In this evaluation, the cyanide MAHL was calculated differently 'from Local Limits
Guidance. Additionally, the cyanide MAHL calculation also used the proposed cyanide
saltwater site-specific objective (SSO) for San Francisco Bay (draft August 18,2006),
which increases the criterion maximum concentration (acute) from 1 ).!g/L to 9.4 ).!g/L
and the criterion continuous concentration (chronic) from 1 ).!g/L to 2.9 ).!g/L. Under the
proposed SSO, the City will also be granted an aUenuationfactorof2.25 in the
derivation of effluent limits which accounts for dilution and degradation of cyanide in the
receiving water. The projected NPDES permit effluent limitation calculation for cyanide
is provided in Attachment A.
Instead of using removal efficiencies to calculate the MAH L as described in the Local
Limits Guidance, an average cyanide formation load is used to assume that cyanide is
always formed during treatment. The average formation load is calculated according to
the following equation:
Where:
LF = Average formation load [Ibs/day];
QIN = Influent flow rate [MGD];
CEFF = Average effluent pollutant concentration [mg/L]; and
CIN = Average influent pollutant conGentration [mg/L].
(1 )
It is necessary to calculate allowable headworks loadings (AHLs), which are estimated
loadings of a pollutant that can be received at the RWQCP headworks without causing
the RWQCP to violate a particular operational restriction or environmental criterion.
AHLs are calculated for each type of restriction (NPDES permit effluent limitations,
RWQCP design capacity, treatment process inhibition levels, and biosolids disposal
restrictions), and the most limiting (lowest) AHL is the MAHL. The cyanide MAHL is
revised to account for the formation load according to the following equation:
City of Palo Alto 6 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
MAHL AHL'vfIN -LF
Where:
MAHL = Maximum allowable headworks loading [Ibs/day];
AHLMIN = Minimum allowable headworks loading [Ibs/day]; and
LF = Average formation load [Ibs/day].
The subsequent maximum allowable industrial loading (MAIL) and uniform
concentration local limit are calculated according to Local Limits Guidance. The
resulting MAHLs for each poe are presented in Table 1. MAHL calculations are
presented in further detail in Attachment B.
Table 1. Revised Maximum Allowable Headworks Loadings
Ammonia 109,000
Arsenic 2.19
Biochemical Oxygen Demand (BOD) 69,100
Cadmium 1.43
Chromium 5.42
Copper 14.8
Cyanide with proposed SSO 1.04
Lead 9.38
Mercury 0.19
Molybdenuma
Nickel 11.4
Selenium 1.44
Silver 5.04
Total Suspended Solids (TSS) 62,400
Zinc 72.3
aNo influent data available -no MAHL could be calculated.
Influent Loading Analysis and MAHL Comparison
(2)
Influent loadings were calculated as the product of the measured pollutant concentration
and influent flow on the day the pollutant sample was taken. Pollutant loadings for each
year were statistically analyzed using regression on order statistics (ROS), which is a
method that estimates summary statistics for data sets that have norKietect data. The
ROS method develops probability plotting positions for each data point (detect and non
detect values) based on an ordering of the data. The log-transformation of the
City of Palo Alto 7 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
concentrations is regressed and fit with a least squares line to probability plotting
positions. Non-detect data points are assigned concentrations for calculation of
summary statistics based on their probability plotting positions and regression line
equation. Summary statistics are calculated based on detected data pOints and "filled
in" non--detect values. Variance summary statistics are calculated using a Tukey
Jackknife algorithm, which sequentially removes one point from the dataset, runs the
analysis, and calculates the variance estimators as the average of each of the lin" runs
of data.
The ROS method cannot be used ifthere are insufficient detected data to perform the
analysis «20% detected data), but yet is found to provide only small errors for important
summary statistics parameters (mean, median, standard deviation, and interquartile
range) when less than 100% of the data are detected. It should also be noted that
unless 100% of the data set is detected, the ROS method is only an estimation of the
data.
In cases where the ROS method could not be used due to insufficient detected data, a
surrogate was used to substitute for non--detect results. The three surrogates
commonly used (per Local Limits Guidance) are the reporting limit, zero, and one-half
the reporting limit. The most conservative approach is to select a surrogate equal to the
reporting limit, which assumes that the pollutant concentration is the maximum possible
value. On the other hand, if the surrogate is equal to zero, it assumes that the pollutant
concentration is the lowest possible value. Using one-half the reporting limit as the
surrogate attempts to compromise between the two extremes. For this local limits
evaluation, one-half the reporting limit is used for non-detect data when there were
insufficient detected data (e.g. cyanide) to use the ROS method. A summary of the
statistical analyses used in calculating influent loadings is presented in Table 2.
City of Palo Alto 8 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
Table 2. Summary of Statistical Methods Used for Calculating Influent Loadings
Arsenic 100 OS 100 ROS
Biochemical Oxygen Demand 100 ROS 100 ROS
Cadmium 100 ROS 98 ROS
Chromium 100 ROS 100 ROS
Copper 100 ROS 100 ROS
%MDL
100 ROS
ROS
ROS
Selenium 100 ROS
Silver 100 ROS
Total Suspended Solids 100 ROS 100 ROS
Zinc 100 ROS 100 ROS
b No influent data available.,
Daily maximum and annual average influent pollutant loadings are summarized in Table
3. A comparison of annual average and daily maximum influent pollutant loadings with
the MAHLs are summarized in Table 4.
City of Palo Alto 9 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
Table 3. Annual Average and Daily Maximum Influent Pollutant Loadings for 2004 and 2005
Cadmium 0.13 0.17
Chromium 1.52 1.91
Copper 17.9 22.9
Cyanide 0.20 0.21
Lead 0.93 1.12 1.97 1.92
Mercury 0.067 0.050 0.094
Molybdenum a
Nickel 1.12 1.59 2.25 2.87
Selenium 0.15 0.18 0.26 0.24
Silver 0.42 0.39 0.93 1.06
Zinc 28.8 30.1 54.9 53.5
aNa influent data available.
City of Palo Alto 10 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
Table 4. Comparison of Influent Pollutant Loadings to MAHLs
Arsenic 9.6% 10.5% 19.~1o 21.0010
Cadmium 4.2% 4.9% 9.1% 11.9%
Chromium 13.7% 18.5% 28.0% 35.2%
r 77.7% 95.9% 121% 155%
Cyanide with proposed SSO 15.4% 16.3% 19.2% 20.2%
Lead 9.9% 11.9% 21.0% 20.5%
Mercury 35.3% 26.3% 69.5% 49.5%
Molybdenum b
Nickel 9.8% 13.9% 19.7% 25.2%
Selenium 10.4% 12.5%
Silver 8.3% 7.7%
Zinc 8% 41.6%
8Constituents in bold exceed the average 60% of MAHL influent loading and/or the maximum 80%
of MAHL influent loading.
bNo influent data available.
Local Limits Guidance recommends using a monthly average comparison of influent
loading to the MAHL because POTWs are expected to have capacity to consistently
treat a specified amount of conventional constituent load to acceptable leve Is for
discharge. Maximum monthly average influent loads for ammonia, BOD, and TSS and
percentages of respective MAHLs are provided in Table 5.
Table 5. Maximum Annual Monthly Average Influent Loads for Ammonia, BOD, and TSS
Ammonia 5,704 5.2% 5,847 5.4%
Biochemical Oxygen Demand (BOb) 41,375 59.9% 50,634 73.3%
Total Suspended Solids (TSS) 48,574 77.8% 51,831 83.1%
aConstituents in bold exceed the maximum 80% of MAHL influent loading.
City of Palo Alto 11 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
MAHL Evaluation
Based on the evaluation of influent pollutant loadings, local limits should only be
considered for several constituents according to Local Limits Guidance criteria
previously listed. These constituents include the following:
• Copper; and
• Total suspended solids (TSS).
These constituents trigger additional consideration for local limit development because
average and/or maximum daily influent loadings exceed recommended threshold levels
outlined in the Local Limits Guidance. The copper local limit needs to be examined
further because there is a high influent loading to MAHL ratio. Additionally, it appears
that the maximum monthly average influent loading incident for TSS was a one-time
event and not consistent with typical conditions. Therefore, local limits for TSS is not
necessary at this time according to Local Limits Guidance. The City will continue to
monitor influent loadings for these constituents.
Review of Compliance History
Local Limits Guidance recommends that compliance records should also be examined
to determine if existing local limits are providing sufficient protection from pass-through
and treatment plant/process inhibition and/or upset. The following areas were reviewed
to determine the City's compliance history:
• RWQCP inhibition and/or upset;
• NPDES permit effluent limitations;
• Biosolids regulations/air emission standards; and
• Pretreatment program standards.
RWQCP Inhibition and/or Upset
In 2002 and 2003, the RWQCP's nitrification process showed intermittent signs of
inhibition. During these episodes, nitrification was not complete and ammonia in the
RWQCP's effluent was at higher levels than usual. However, there were no discharge
violations. In 2004, sLCh events were relatively minor and no events met the EPA
definitions of upset or interference and no effluent limits were violated. In 2005, no
periods of nitrification inhibition were noted and only a few minor indications of stress
were found during close examination of operational data. The City is currently working
with Stanford University, UC Irvine, and a consultant to develop gene-based nitrification
testing protocols: The testing protocols will be used to evaluate ammonia oxidizing
related genes involved in nitrification in order to prevent nitrification inhibition. For now,
there is no evidence that RWQCP inhibition or upset should trigger changes to existing
local limits. .
City of Palo Alto 12 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
NPDES Permit Effluent Limitations
The City has effluent limitations in its current NPDES permit (CA0037834, adopted
September 2003) for copper, mercury, nickel, cyanide, chlorodibromomethane, 4,4'
DDE, dieldrin, heptachlor epoxide, benzo(b)fluoranthene, and indeno(1,2,3-cd)pyrene.
The City has been in compliance with its NPDES permit effluent limitations in 2004 and
2005. While daily copper sample results have exceeded the monthly average limitation
for single samples, the City has not exceeded the average monthly effluent limitation
between January 2004 and December 2005.
Bioso/ids Regulations/Air Emission Standards
With the exception of copper, a review of 2004 and 2005 biosolids and ash monitoring
data shows that the City is in compliance with all applicable biosolids regulations and air
emission standards.
Influent copper mass loadings, and subsequent effluent mass loadings, have increased
in recent years. In addition to increases in influent and effluent mass loadings, copper
concentrations in the RWQCP's incinerator ash have occasionally exceeded the soluble
threshold limit concentration (STLC) hazardous waste limit for copper. Ash is currently
applied to pasture and feed crop land as a soil amendment and copper is desirable as a
micronutrient for this use. The City has initiated the following steps to verify the
apparent increased copper load and to identify causes:
• Evaluate possible changes in industrial copper loading;
• Determine effects of chloramine disinfection on copper corrosion in drinking
water piping;
• Investigate possible contamination in fluoride added to drinking water;
• Explore impacts of additions of copper sulfate to drinking water reservoirs;
• Examine effects of collection system line cleaning activities on copper influent;
• Determine relationships between copper concentrations in collection system
trunk lines and RWQCP influent; and
• Identify factors influencing copper concentration variability in RWQCP incinerator
ash.
Following the completion of these activities, the City will be able to evaluate and
implement source control measures to reduce copper in its biosolids.
Pretreatment Program Standards
The City has 20 categorical significant industrial users (SIUs), 48 non-categorical SIUs,
and 35 other industrial users. The City conducts sampling of categorical industrial users
twice per year, and the industries are required to conduct semi-annual sampling of their
discharge as well. Water quality samples are collected and analyzed for compliance
City of Palo Alto 13 October 2006
Palo Alto Regional Water Quality Control Plartt
Local Limits Evaluation
with existing local limits and categorical limits. Inspection frequencies for industrial and
commercial users are summarized in Table 6.
Table 6. Pretreatment Program Inspection Frequency
Categorical/SIUs Active 2 per year
Categorical/SIUs Zero 1 per year
Non-Categorical (potential toxic) Active 2 per year
Non-Categorical (minor) Active 1 per year
BMP Active 1 per year
Non-permitted Acti..e 1 per year
Groundwater Active Up
Machine shops Active 1 per year
Active 1 per year
e facilities Active 2 per year
Active As needed
The City has observed inconsistent compliance with several industrial users with
arsenic, chromium, copper, lead, nickel, silver, and zinc. The City enforces its local
limits and categorical limits by requiring additional sampling and issuing notices of non
compliance. If these requirements are not met, then the City follows its Enforcement
Response Plan and escalates penalties.
City of Palo Alto 14 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
LOCAL LIMITS UPDATE STRATEGY
The City currently does not have local limits for ammonia, BOD and molybdenum and
the development of these local limits is discussed in this section. Additionally, local
limits and strategies to manage copper, as well as cyanide and other POCs, are also
discussed in this section.
Ammonia, BOD, and Molybdenum
Local limits for ammonia and BOD are not triggered based on the previously discussed
influent loading analysis. However, ammonia and BOD are national POCs. Therefore,
the City may consider adopting a uniform local limit for these constituents as a way to
regulate industrial discharges and to prevent overloading of the RWQCP. Proposed
MAILs and associated uniform concentration local limits for ammonia and BOD are
presented in Table 7. Detailed MAIL calculations for these constituents are presented
in Attachment B.
Table 7. Maximum Allocation Industrial Loading and Uniform Local Limits
Ammonia 92,500 9,700
Biochemical Oxygen Demand 21,500 2,300
aExpressed as a daily maximum concentration.
The City currently does not have sufficient molybdenum data to calculate an MAHL or
associated MAIL. It is recommended that the data necessary to develop a local limit be
collected.
Copper
The City currently has a tiered approach for allocating copper local limits to its industrial
users, which is presented in Table 8.
Table 8. Current Copper Allocations
Individual mass limit or Average Maximum Concentration Limit = Maximum Concentration Limit =
Concentration Limit = 0.4 mg/L 0.25 mg/L 2.0 mg/L
AND
Maximum Concentration Limit
>50,000 gpd = 1.0 mg/L
<50,000 gpd = 2.0 mg/L
City of Palo Alto 15
Palo Alto Regional Water Quality Control Plant
October 2006
Local Limits Evaluation
The City's current.copper allocation has proven to be sufficient for protecting the
RWQCP from treatment process inhibition/upset a nd meeting the City's NPDES permit
final effluent limitation for copper. Although influent copper loadings are high compared
to the MAHL, the City has completed mass balance studies of copper sources and
determined that industrial users contribute only 2% of the total influent copper loadings,
as presented in Table 9. Corrosion of piping contributes approximately 58% of the total
influent copper loading. The City intends to maintain its current copper local limit
allocation and focus on reducing copper loadings from corrosion sources.
Table 9. 2005 Industrial Copper Loadings
Metal Finishers 0.05
Hospitals 0.08
Laboratories 0.02
Other 0.04
Stanford 0.09
Total Industrial Process Load 0.29
Total Influent Load 14.2
Cyanide
The City changed its influent sampling location in January 2006 because the previous
influent sampling location included some amount of RWQCP process return flows,
including incinerator scrubber return water, which is known to have high cyanide
concentrations. Data collected prior to January 2006 showed periodically high influent
cyanide concentrations. In comparison, typical raw influent wastewater contains little to
no cyanide. For the influent loading analysis, it was assumed that the influent cyanide
concentration was non-detect at a reporting limit of 1.6 J.!g/L, which were the results
from influent monitoring data obtained after changing the influent sampling location in
January 2006.
Cyanide is generated through the chlorine disinfection process. As such, the cyanide
MAHL was calculated using an average formation loading and completing a mass
balance through the treatment process. This calculation method deviates from Local
Limits Guidance. Additionally, the proposed cyanide sse is used in calculating
projected NPDES permit effluent limitations that can be expected in the City's next
NPDES permit. These assumptions result in a cyanide MAHL of 1.04Ibs/day, which
may be uniformly distributed to all industrial users as a maximum daily concentration of
55 J.!g/L. The City's existing cyanide local limit is 1,000 J.!g/L. While the City currently
does not have compliance issues with its interim cyanide effluent limitation, the City may
consider adopting the more stringent cyanide local limit in anticipation of effluent
limitations in its next NPDES permit.
City of Palo Alto 16 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
Other poes
This evaluation determined that existing local limits are sufficiently protective for
arsenic, cadmium, chromium, lead, mercury, nickel, selenium, silver, zinc and total
suspended solids according to Local Limits Guidance. To protect the RWQCP, the City
intends to maintain the existing local limits for these constituents.
City of Palo Alto 17 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
PRETREATMENT SlREAMLINING RULE
In February 2006, USEPA adopted the Pretreatment Streamlining Rule (Streamlining
Rule), which requires a publicly-owned treatment work (POTW) to modify certain
provisions of its pretreatment program and provides the option to modify other aspects
of its pretreatment program. The following changes are required by the Pretreatment
Streamlining Rule:
• Slug control requirements must be included in SIU control mechanisms
[§403.8(f)(1 )(iii)(B)(6)] -POTWs must incorporate slug control requirements into
their SIU control mechanism and must revise their approved program, if
necessary, to ensure that they have the legal authority and procedures to modify
control mechanisms as needed.
• SIUs must be evaluated for the need for a plan or other action to control slug
discharges within a year from the final rule's effective date or from becoming an
SIU [§403.8(f)(2)(vi)] -The Streamlining Rule specifies that POTWs must
evaluate all of their SIUs for the need for a slug control plan or other actions at
least one time. If the POTW has not yet done so, it must complete evaluations
before October 14, 2006 or within a year of the I U being designated as
significant.
• SIUs are required to notify the POTW immediately of any changes at its facility
affecting the potential for a slug discharge [§403.8(f)(2)(vi)] -The Streamlining
Rule requires SIUs to notify the POTW immediately of changes that occur at the
facility affecting the potential for a slug discharge, thereby allowing the POTW to
reevaluate the need for a slug control plan or other actions to prevent such
discharges.
• Significant noncompliance (SNC) definition is expanded to include additional
types of Pretreatment Standards and Requirements [§403.8(f)(2)(viii)(A-C)] -The
Streamlining Rule made several wording changes that expand the types of
Standards and Requirements that are to be considered when determining
whether an SIU's violations constitute SNC. These changes affect what USEPA
considers "chronic violations" [§403.8(f)(2)(viii)(A)], ''Technical Review Criteria
violations" [§403.8(f)(2)(viii)(B)], and "other" violations [§403.8(f)(2)(viii)(C)].
• SIU reports must include Best Management Practice (BMP) compliance
information [§403.12(b),(e),(h)] -The Streamlining Rule requires SIUs to submit
documentation as required by the Regional Water Board or applicable
Pretreatment Standards and Requirements to determine compliance with BMP
based standards or local limits.
• SIU control mechanisms must contain any BMPs required by a Pretreatment
Standard, local limits, state, or locallaw[§403.8(f)(1 )(iii)(B)(3)] -The
Streamlining Rule clari'fled that among effluent limits that mus t be contained in all
SIU control mechanisms are BMPs that are required by a categorical
Pretreatment standard, local limit, state or local law.
City of Palo Alto 18 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
• Documentation of compliance with BMP requirements must be maintained as
part of the SIU's and POTW's record-keeping requirements [§403.12(o}] -The
Streamlining Rule clarified that the POTW and the SIU must maintain records of
BMP compliance in the same way other records are maintained as part of
§403.12(o}.
• Control Authorities which perform sampling for SIUs must perform any required
repeat sampling and analysis within 30 days of becoming aware of a violation
[§403.12(g)(2)] -The Streamlining Rule provides that where a Control Authority
has assumed responsibility for sampling in lieu of the SIU, it is the Control
Authority which must repeat sampling and analysis within 30 days of becoming
aware of an exceedance. The only exception to this requirement is if the Control
Authority specifically requires the Industrial User to perform the repeat analysis.
• Require periodic compliance reports to comply with sampling requirements,
require Control Authority to specify the number of grab samples necessary in
periodic and non-categorical SIU reports, and require non-categorical SIUs to
report all monitoring results [§403.12(g}(3),(4),(6}] -SIUs are now required to
follow sampling requirements in §403.12 for periodic compliance report
[§403.12(e) and (h)], whereas they were previously only explicitly applicable to
baseline monitoring reports and gO-day compliance reports. In addition, for the
reports required in §403.12(e) and (h), the Streamlining Rule requires the Control
Authority to indicate the number of grab samples necessary to assess and
assure compliance by industrial users with applicable categorical Pretreatment
Standards and Requirements. Also, non-categorical SIUs are required to report
all monitoring results, whereas the previous regulations only made this
requirement explicit for categorical SIUs.
• Non-categorical SIUs are required to provide representative samples in their
periodic monitoring report [§403.12(g)(3)] -The Streamlining Rule extends to the
§403.12(b), (d), and (h) monitoring requirements that SIUs provide data which
are representative of conditions during the reporting period.
Prior to the adoption of the Streamlining Rule, there were no rules regarding whether a
POTW could use BMPs in lieu of numeric local limits and industrial users were not
explicitly required to report compliance data from BMPs. With regards to
implementation of BMPs in the Pretreatment Program, the Streamlining Rule specifies:
• BMPs developed by POTWs may serve as local limits;
• Full categorical industrial user reporting is required where BMPs are required for
categorical standards;
• The necessity for POTWs to document the rationa Ie for specific BMPs;
• The definitions of BMPs; and
• What USEPA considers as the minimum elements that make BMPs enforceable.
City of Palo Alto 19 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
RECOMMENDATIONS
Local Limits Update
It is recommended that the City adopt and implement the local limits presented in Table
10.
Table 10. Proposed Local Limits for the City of Palo Alto
Ammonia 92,500 9,700
Biochemical Oxygen Demand 21,500 2,300
aExpressed as a daily maximum concentration.
The City intends to maintain its existing copper local limit and focus on reducing influent
copper loadings to the RWQCP from other sources, particularly corrosion of piping.
Because adequate RWQCP data are not a vailable for several constituents with existing
local limits, and there are no driving factors for the development of local limits for many
of these existing local limits constituents, only the 15 USEPA pollutants of concern
(POCs) were considered in this evaluation. It is also recommended that the City collect
molybdenum data so that a local limit can be developed.
Pretreatment Streamlining Rule
It is recommended that the City implement modi'fications to its pretreatment program as
required by the Streamli ning Rule. The City may also want to consider optional aspects
ofthe Streamlining Rule such as developing BMPs in lieu of local limits in the future.
Ongoing Evaluation
The local limits that were developed as part of this effort are part of a dynamic process
that includes periodic review and update as necessary. The City currently has an
effective ongoing monitoring program that collects data that are necessary for local
limits evaluations and tracks trends in POC loadings. It is recommended that the City
collect molybdenum data during its residential monitoring events as well as at the
RWQCP influent so that a local limit for molybdenum can be developed. Additionally, it
is recommended that the City periodically collect priority pollutant organics data at its
residential monitoring locations.
Future circumstances may again create a need to update the City's MAILs to allow for
the compliance with environmental and operational restrictions. Such circumstances
may include the following:
• Significant changes in the City's industrial base;
City of Palo Alto 20 October 2006
Palo Alto Regional Water Quality Control Plant
Local Limits Evaluation
Significant changes in discharge characteristics of existing industries;
• Significant changes in environmental and/or NPDES permit regulations
applicable to City;
• Future facility operational difficulties, discharge compliance difficulties, or
biosolids disposal compliance difficulties from any constituents known or
suspected to be significantly contributed from industrial sources;
• Future facility infrastructure upgrades that can affect wastewater and/or biosolids
treatment processes and quality; and
• Difficulties in meeting local limits without any corresponding facility operational
challenges, discharge compliance challenges, or biosolids disposal compliance
challenges.
City of Palo Alto 21 October 2006
Palo Alto Regional Water Quality Control Plant
Attachment A
Projected NPDES Permit Effluent Limitation
Calculation for Cyanide
Water Quality-Based Effluent Limitations Calculation
"Calculations based on data collected from August 2003-August 2006.
City of Palo Alto
Palo Alto Regional Water Quality Control Plant A-1 October 2006
Attachment B
Local Limits Derivation Worksheets
Local Limits -Conventional
H+= B I C I 0 I E
, Ammonia
Units Calculations Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration mg/L 24.3 January 2004-0ecember 2005 Data
7 Maximum Influent Concentration mg/L 34 January 2004-December 2005 Data
8 Average Primary Effluent Concentration mg/L 23.2 January 2004-December 2005 Data
9 Average Effluent Concentration mg/L 0.1 January 2004-0ecember 2005 Oata
10 Maximum Effluent Concentration mg/L 0.52 January 2004-0ecember 2005 Oata
11 Average Oomestic Concentration mg/L 25.3 Reference Data
12 Existing Loading
13 Average Influent Loading Ibs/day 5,249 8.34*04*06
14 Maximum Influent Loading Ibs/day 7,344 8.34*04*07
15 Average Oomestic Loading Ibslday 5,108 8.34*(D4-05)*D11
16 Removal Efficiency
17 In-Plant Removal, Typical % 99.6% (06-09)/D6
18 In-Plant Removal, Worst % 97.9% (06-010)/06
19 In-Plant Primary Removal % 4.5% (06-08)/06
20 Treatment/Discharge Lim its
21 Discharge Limit (Daily) mg/L 8 NPDES Permit
22 Discharge Limit (Monthly) mg/L 3 NPOES Permit
23 ·t mg/L 480 EPA Local Limits Guidance Manual
mg/L --
~y 419,916 8.34*04*021/(1-017)
it Ibs/day 157,468 8.34*04*022/(1-D17)
Ibslday 108,599 8.34*D4*D23/(1-D19)
Ibs/day --
ng (MAHL)
31 Headworks Limit Ilbs/day I 108,599 I MIN{D26:D29)
32 Driving Factor Activated Sludge Inhibition Loading Limit
33 Maximum Allowable Industrial Loading (MAIL)
34 Safety Factor 10% 10,860 C34*D31
35 Industrial Allocation Ibs/day 92,631 D31-D 15-D34
36 Equivalent Across-the-Board Limit mg/L 6,572 D35/D5/8.34
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-1 October 2006
Local Limits -Conventional
FI G H I J
1 Biochemical Oxygen Demand (BOD)
2 Units Calculations Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration mg/L 204 January 2004-December 2005 Data
7 Maximum Influent Concentration mg/L 290 January 2004-December 2005 Data
8 Average Primary Effluent Concentration mg/L --
9 Average Effluent Concentration mg/L 1.5 January 2004-December 2005 Data
10 Maximum Effluent Concentration mg/L 3.7 January 2004-December 2005 Data
11 Average Domestic Concentration mg/L 197 Reference Data
12 Existing Loading
13 Average Influent Loading Ibs/day 44,065 8.34*14*16
14 Maximum Influent Loading Ibs/day 62,642 8.34*14*17
15 Average Domestic Loading Ibs/day 39,777 8.34*(14-15)*111
16 Removal Efficiency
17 In-Plant Removal, Typical % 99.3% (16-19)116
18 In-Plant Removal, Worst % 98.2% (16-110)/16
19 In-Plant Primary Removal % --
20 Treatment/Discharge Limits
21 Discharge Limit (Daily) mg/L 20 NPDES Permit
22 Discharge Limit (Monthly) mg/L 10 NPDES Permit
23 Activated Sludge Inhibition Limit mg/L --
24 Plant Capacity mg/L 320 Design Capacity
25 Headworks Loading Limits
26 Daily Discharge Loading Limit Ibs/day 587,536 8.34*14*121/(1-117)
27 Monthly Discharge Loading Limit Ibs/day 293,768 8.34*14*122/(1-117)
28 Activated Sludge Inhibition Loading Limit Ibs/day --
29 Plant Capacity Loading Limit Ibs/day 69,122 8.34*14*124
30 Maximum Allowable Headworks Loading (MAHL)
31 Headworks Limit Ibs/day 69,122 MIN(126:129)
32 Driving Factor I IPlant Capacity Loading Limit
33 Maximum Allowable Industrial Loading (MAIL)
34 Safety Factor 10% 6,912 H34*131
35 Industrial Allocation Ibs/day 22,433 131-115-134
36 Equivalent Across-the-Board Limit mg/L 1,592 135115/8.34
City of Palo Alto
Palo Alto Regional Water Quality Control Plant 8-2 October 2006
Local Limits -Conventional
KI L I M N 0
1 Total Suspended Solids (TSS)
2 Units Calculations Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration mg/L 209 January 2004-December 2005 Data
7 Maximum Influent Concentration mg/L 330 January 2004-December 2005 Data
8 Average Primary Effluent Concentration mg/L 57 January 2004-December 2005 Data
9 Average Effluent Concentration mg/L 1.3 January 2004-December 2005 Data
10 Maximum Effluent Concentration mg/L 5.7 January 2004-December 2005 Data
11 Average Domestic Concentration mg/L 158 Reference Data
12 Existing Loading
13 Average Influent Loading Ibs/day 45,145 8.34*N4*N6
14 Maximum Influent Loading Ibs/day 71,282 8.34*N4*N7
15 Average Domestic Loading Ibs/day 31,902 8.34*(N4-N5)*N11
16 Removal Efficiency
17 In-Plant Removal, Typical % 99.4% (N6-N9)/N6
18 In-Plant Removal, Worst % 97.3% (N6-N10)/N6
19 In-Plant Primary Removal % --
20 Treatment/Discharge Limits
21 Discharge Limit (Daily) mg/L 20 NPDES Permit
22 Discharge Limit (Monthly) mg/L 10 NPDES Permit
23 Activated Sludge Inhibition Limit mg/L --
24 Plant Capacity mg/L 289 Design Capacity
25 Headworks Loading Limits
26 Daily Discharge Loading Limit Ibs/day 694,542 8.34*N4*N21/(1-N17)
27 Monthly Discharge Loading Limit Ibs/day 347,271 8.34*N4*N22/(1-N17)
28 Activated Sludge Inhibition Loading Limit Ibs/day --
29 Plant Capacity Loading Limit Ibs/day 62,426 8.34*N4*N24
30 Maximum Allowable Headworks Loading (MAHL)
31 Headworks Limit Ibs/day 62,426 MIN(N26:N29)
32 Drivi ng Factor I Plant Capacity Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-3 October 2006
Local Limits -Priority Pollutant Metals
AI B C I D E
1 Arsenic
2 Units I Calculations Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 1.1 January 2004-December 2005 Data
7 Maximum Influent Concentration ug/L 2.2 January 2004-December 2005 Data
8 Average Primary Effluent Concentration ug/L 0.9 January 2004-December 2005 Data
9 Average Effluent Concentration ug/L 0.8 January 2004-December 2005 Data
10 Maximum Effluent Concentration ug/L 1 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 0.94 March 2000-September 2005 Data
12 Existing Loadings
13 Average Influent Loading Ibs/day I 0.24 0.00834"D4"D6
14 Maximum Influent Loading Ibs/day I 0.48 0.00834*D4*D7
15 Average Domestic Loading Ibs/day I 0.19 0.00834"(D4-D5)*D11
16 Removal Efficiency
17 In-Plant Removal, Typical % I 27.3% (D6-D9)/D6
18 In-Plant Removal, Worst % I --
19 In-Plant Primary Removal % I 18.2% (D6-D8)1D6
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 3.14 January 2004-December 2005 Data
28 Treatment/Discharge/Disposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L 36 California Toxics Rule/Basin Plan
30 Discharge Limit (Daily) ug/L --
31 Discharge Limit (Monthly) ug/L --
32 Activated Sludge Inhibition Limit ug/L 100 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L 1,500 EPA Local Limits Guidance
35 Incinerator Biosolids Feed Limit, Dry mg/kg 10 40 CFR 503.43
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg 500 CCR 22-66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 10.7 0.00834 *D4 *D29/(1-D 17)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day --
42 Activated Sludge Inhibition Loading Limit Ibs/day 26.4 0.00834*D4*D32/(1-D19)
43 Trickling Filter Inhibition Loading Limit Ibs/day --
44 Nitrification Inhibition Loading Limit Ibs/day 396 0.00834*D4*D34/(1-D19)
45 Incinerator Biosolids Feed Loading Limit Ibs/day 2.19 8.34 *D21*D23*D25*D35/D17
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibs/day 17.5 8.34*D22*D26*D37/D17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/day 2.19 I MIN(D39:D47)
50 Driving Factor I Incinerator Biosolids Feed Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-4 October 2006
Local Limits -Priority Pollutant Metals
FI G H I I J
1 Cadmium
2 Units I Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Infiuent Flow mgd 25.9 2005 Average Infiuent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Infiuent Concentration ug/L 0.3 January 2004-December 2005 Data
7 Maximum Infiuent Concentration ug/L 0.7 January 2004-December 2005 Data
8 Average Primary Effluent Concentration ug/L 0.4 January 2004-December 2005 Data
9 Average Effluent Concentration ug/L 0.1 January 2004-December 2005 Data
10 Maximum Effluent Concentration ug/L 0.3 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 0.4 March 2000-September 2005 Data
12 Existing Loadings
13 Average Infiuent Loading I Ibs/day I 0.06 I 0.00834'14'16
14 Maximum Infiuent Loading I Ibs/day I 0.15 0.00834'14'17
15 Average Domestic Loading Ilbs/day I 0.08 0.00834'(14-15)*111
16 Removal Efficiency
17 In-Plant Removal, Typical I % I 66.7% (16-19)116
18 In-Plant Removal, Worst I % I --
19 In-Plant Primary Removal I % I -33.3% (16-18)/16
20 Existing Conditions (8iosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to LandfiJI mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 1.17 January 2004-December 2005 Data
28 Treatment/Discharge/Disposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L 2.4 California Toxies Rule/Basin Plan
30 Discharge Limit (Daily) ug/L --
31 Discharge Limit (Monthly) ug/L --
32 Activated Sludge Inhibition Limit ug/L 1,000 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L 5,200 EPA Local Limits Guidance
35 Incinerator Biosolids Feed Limit, Dry mg/kg 59 40 CFR 503.43
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg 100 CCR 22-66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 1.57 0.00834"14"129/(1-117)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day --
42 Activated Sludge Inhibition Loading Limit Ibs/day 162 0.00834"14"132/(1-119)
43 Trickling Filter Inhibition Loading Limit Ibs/day --
44 Nitrification Inhibition Loading Limit Ibs/day 842 0.00834"14"134/(1-119)
45 Incinerator Biosolids Feed Loading Limit Ibs/day 5.29 8.34"121"123"125'135/1 17
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibs/day 1.43 8.34'122'126'1371117
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ibs/day 1.43 I MIN(139:147)
50 Driving Factor Biosolids CCR Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant 8-5 October 2006
Local Limits -Priority Pollutant Metals
KI L I M I N I 0
1 Chromium (Total)
2 I Units I Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow I mgd I 25,9 I 2005A~ 5 Average Industrial Flow
R
2005 Pretreatment
Influent Concentration January 2004-
Maximum Influent Concentration January 2004-December
8 Average Primary Effluent Concentration January 2004-December 2005 Data
9 Average Effluent Concentration January 2004-December 2005 Data
10 Maximum Effluent Concentration 1,1 I January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 3,97 March 2000-September 2005 Data
12 Existing Loadings
13 Average Influent Loading Ibs/day I 0,91 0,00834*N4*N6
14 Maximum Influent Loading Ibslday I 1.73 0,00834*N4*N7
15 Average Domestic Loading Ibs/day I 0,80 0,00834*(N4-N5tN11
16 Removal Efficiency
17 In-Plant Removal, Typical % I 88,1% (NS-N9)/N6
18 In-Plant Removal, Worst % I --
19 In-Plant Primary Removal % I 73,8% (NS-N8}/N6
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator I mgd 0,027 Average Flow to Incinerator
22 Biosolids Flow to Landfill I mgd 0,0013 A._'~ lltr-I % 26,9% January 2004-D
sto Landfill m 58,3% January 2004-[
sity to Incinerator 1,00 Local Limits Guidance
sity to Landfill 0,88 Metcalf & Eddy I
27 Average Ash Concentration, Wet January 2004-December
28 TreatmentlDischargelDisposal Limits
29 _~ Qool'" C"""""""""'" (lowml~ rnia Toxics Rule/Basin Plan
30 Discharge Limit (Daily) -
~ Discharge Limit (Monthly) -
Activated Sludge Inhibition Limit uglL EPA Local Limits Guidance
Trickling Filter Inhibition Limit ug/L EPA Local Limits Guidance
34 Nitrification Inhibition Limit ug/L 250 EPA Local Limits Guidance
35 Incinerator Biosolids Feed Limit, Dry mg/kg 230 40 CFR 503,43
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg 500 CCR 22-66261,24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 20,7 0,00834*N4*N29/(1-N17)
40 Daily Discharge Loading Limit Ibs/day -
41 Monthly Discharge Loading Limit Ibs/day -
42 Activated Sludge Inhibition Loading Limit Ibs/day 825 0,00834*N4*N32/(1-N19)
43 Trickling Filter Inhibition Loading Limit Ibs/day 2,887 0,00834 *N4*N33/(1-N 19)
44 Nitrification Inhibition Loading Limit Ibs/day 206 0,00834*N4*N34/(1-N19)
45 Incinerator Biosolids Feed Loading Limit Ibs/day 15.6 8,34*N21*N23*N25*N35/N17
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibslday 5,42 8,34*N22*N26*N37/N 17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/dayl 5.42 I MIN{N39:N47}
50 Driving Factor I Biosolids CCR Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-6 October 2006
Local Limits Priority Pollutant Metals
PI Q I R I s I T
1 Copper
2 I Units I Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 62.8 January 2004·December 2005 Data
7 Maximum Influent Concentration ug/L 110 January 2004·December 2005 Data
8 Average Primary Effluent Concentration ug/L 38.8 January 2004·December 2005 Data
9 Average Effluent Concentration ugiL 9 January 2004·December 2005 Data
10 um Effluent Concentration ug/L 16 January 2004·December 2005 Data
11 Average Domestic Concentration ugIL 78.2 March 2000·September 2005 Data fii'-13 e Influent Loading I~ 0.00834*S4*S6
14 um Influent Loading II 0.00834*S4*S7
15 Domestic Loading Ilbs/dayl 15.8 0.00834*(S4-85)*811
16 Removal Efficiency
17 In·Plant Removal, Typical I % I 85.7% (86·S9)/86
18 In·Plant Removal, Worst I % I 74.5% (86-810)/S6
19 In·Plant Primary Removal I % 38.2% (S8-S8)/S6
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Row to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004·December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004·December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 780 January 2004·December 2005 Data
28 TreatmentlDischargelDisposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L · ·
30 Discharge Limit (Daily) ug/L 17.4 NPDES Permit
31 Discharge Limit (Monthly) ug/L 11.8 NPDES Permit
32 Activated Sludge Inhibition Limit ug/L 1,000 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L · ·
34 Nitrification Inhibition Limit ug/L 50 EPA Local Limits Guidance
35 Incinerator Biosolids Feed Limit, Dry mglkg · ·
36 Biosolids 40 CFR 503 Limit, Dry mg/kg · ·
37 Biosolids CCR Limit, Wet mg/kg 2,500 CCR 22·66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit lbs/day · ·
40 Daily Discharge Loading Limit Ibs/day 14.8 0.00834*$4*S30/(1·S18)
41 Monthly Discharge Loading Limit Ibs/day 17.8 0.00834*$4*S31/(1·S17)
42 Activated 81udge Inhibition Loading Limit Ibs/day 350 0.00834*$4*S32/(1·S19)
43 Trickling Filter Inhibition Loading Limit Ibs/day · ·
44 Nitrification Inhibition Loading Limit Ibs/day 17.5 0.00834*$4*S34/( 1·S19)
45 Incinerator Biosolids Feed Loading Limit Ibs/day · ·
46 Biosolids 40 CFR 503 Loading Limit Ibs/day · -
47 Biosolids CCR Loading Limit Ibs/day 27.8 8.34 *S22*826*S37/S 17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/day I 14.8 I MIN(S39:847)
50 Driving Factor I IDaily Discharge Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B·7 October 2006
Local Limits -Priority Pollutant Metals
UI V I W X I y
1 Lead
2 I Units Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 5 January 2004-December 2005 Data
7 Maximum Influent Concentration ug/L 9 January 2004·December 2005 Data
8 Average Primary Effluent Concentration ug/L 4.4 January 2004·December 2005 Data
9 Average Effluent Concentration ug/L 0.3 January 2004·December 2005 Data
10 Maximum Effluent Concentration ugfL 2.7 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 7.6 March 2000·September 2005 Data
12 Existing Loadings
13 IlbS/day I 1.08 I 0.OO834*X4*X6
14 Maximum Influent Loading Ilbs/dayl 1.94 I 0.00834*X4*X7
15 Average Domestic Loading Ilbs/dayl 1.53 I 0.00834*CX4·X5)*X11
16 Removal Efficiency
17 In-Plant Removal, Typical I % I 94.0% I (X6·X9)1X6
18 In-Plant Removal, Worst I % I -I .
19 In-Plant Primary Removal I % I 12.0% I (X6-X8)fX6
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004·December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004·December 2005 Data
25 Biosolids Density to Incinerator kglL 1.00 Locel Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 62.9 January 2004·December 2005 Data
28 TreatmentfDischargelDisposal Limits
29 Water Quality CriteriafOb'ective (Lowest) ug/L 2.6 California Toxics Rule/Basin Plan
30 Discharge Limit (Daily) ug/L · -
31 Discharge Limit (Monthly) ug/L --
32 Activated Sludge Inhibition Limit ug/L 1,000 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L 500 EPA Local Limits Guidance
35 Incinerator Biosolids Feed Limit, Dry mg/kg 540 40 CFR 503.43
36 BiosoJids 40 CFR 503 Limit, Dry mg/kg · -
37 Biosolids CCR Limit, Wet mg/kg 1,000 CCR 22·66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 9.38 O. 00834*X4 'X29/( 1-X 17)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day --
42 Activated Sludge Inhibition Loading Limit Ibs/day 245 0.00834·X4*X32/(1-X191
43 Trickling Filter Inhibition Loading Limit Ibs/day · .
44 Nitrificetion Inhibition Loading Limit Ibs/day 123 0.00834*X4*X34/(1-X19)
45 Incinerator Biosclids Feed Loading Limit Ibs/day 34.3 8.34*X21*X23*X25*X351X 17
46 Biosolids 40 CFR 503 Loading Limit Jbs/day --
47 Biosclids CCR Loading Limit Jbs/day 10.1 8.34*X22*X26*X371X 17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/dayl 9.38 I
50 Driving Factor I IWater Quality Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant 8-8 October 2006
Local Limits -Priority Pollutant Metals
21 AA I AB I AC AD
1 Mercury
2 I Units I Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 0.269 January 2004-December 2005 Data
7 Maximum Influent Concentration ug/L 0.7 January 2004-December 2005 Data
8 Average Primary Effluent Concentration ug/L --
9 Average Effluent Concentration ug/L 0.005 January 2004-December 2005 Data
10 Maximum Effluent Concentration ug/L 0.012 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 0.19 Manch 2000-September 2005 Data
12 Existing Loadings
13 Average Influent Loading Ilbs/day 0.06 I 0.00834*AC4*AC6
14 Maximum Influent Loading Ilbs/day 0.15 I 0.00834*AC4*AC7
15 Average Domestic Loading Ilbs/day 0.04 I 0.00834*(AC4-AC5)*AC11
16 Removal Efficiency
17 In-Plant Removal, Typical I % 98.1% I (AC6-AC9)/AC6
18 In-Plant Removal, Worst I % -I -
19 In-Plant Primary Removal I % 10.0% I EPA Local Limits Guidance
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 0.011 January 2004-December 2005 Data
28 Treatment/Discharge/Disposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L 0.025 California Toxics RUle/Basin Plan
30 Discharge Limit (Daily) ug/L --
31 Discharge Limit (Monthly) ug/L 0.023 NPDES Permit
32 Activated Sludge Inhibition Limit ug/L 100 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L --
35 Incinerator Biosolids Feed Limit, Dry mg/kg 112 40 CFR 61.52
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg 20 CCR 22-66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 0.29 0.00834*AC4*AC29/(1-AC17)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day 0.27 0.00834*AC4*AC31/(1-AC17)
42 Activated Sludge Inhibition Loading Limit Ibs/day 24.0 0.00834*AC4*AC32/(1-AC19)
43 Trickling Filter Inhibition Loading Limit Ibs/day --
44 Nitrification Inhibition Loading Limit Ibs/day --
45 Incinerator Biosolids Feed Loading Limit Ibs/day 6.82 8.34*AC21 *AC23*AC25*AC35/AC17
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibs/day 0.19 8.34*AC22*AC26*AC37/AC17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/day I 0.19 I MIN(AC39:AC47)
50 Driving Factor I I Biosolids CCR Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-9 October 2006
Local Limits· Priority Pollutant Metals
AEI AF AG AH I AI
1 Nickel
2 Units Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 2S.9 200S Average Influent Flow
S Average Industrial Flow mgd 1.69 200S Pretreatment Annual Report
6 Average Influent Concentration ug/L 6.6 January 2004·December 200S Data
7 Maximum Influent Concentration ug/L 12 January 2004-December 200S Data
8 Average Primary Effluent Con ~"'~ 2004-0,~mbec 2005 """
9 Average Effluent Concentration uary 2004-December 200S Data
10 Maximum Effluent Concentration 200S Data
11 Average Domestic Concentration ug/L S,2S I March 2000-September 200S Data
12 Existing Loadings
~ 13 Average Influent Loading 0,00834*AH4*AH6
14 Maximum Influent Loading 0.00834*AH4*AH7
lS Average Domestic Loading 0.00834*(AH4·AHS)*AH11
16 Removal Efficiency
17 In-Plant Removal, Typical I (AH6-AH9)/AH6
18 In-Plant Removal Worst I (AH6-AH 1 0)/AH6
19 In-Plant Primary Removal I (AH6·AH8)/AH6
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0,0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-December 200S Data
24 Percent Solids to Landfill % S8.3% January 2004-December 200S Data
2S Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0,88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 36,1 January 2004-December 200S Data
28 TreatmentlDischargelDisposal Limits
29 Water Quality Criteria/Obiective (Lowest) ug/L --
30 Discharge Limit (Daily) ug/L 32.2 NPDES Permit
31 Discharge Limit (Monthly) ug/L 2S.6 NPDES Permit
32 Activated Sludge Inhibition Limit ug/L 1,000 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L -.
34 Nitrification Inhibition Limit ug/L 2S0 EPA Local Limits Guidance
3S Incinerator Biosolids Feed Limit, Dry mg/kg 48,000 40 CFR S03.43
36 Biosolids 40 CFR S03 Limit, Dry mglkg --
37 Biosolids CCR Limit, Wet mg/kg 2,000 CCR 22-66261.24
38 Headworks Loading Limits
39 water Quality Loading Limit Ibs/day --
40 Daily Discharge Loading Limit Ibs/day 11.S 0,00834*AH4*AH30/(1-AH18)
41 Monthly Discharge Loading Limit Ibs/day 11.4 0.00834*AH4*AH31/(1·AHl7)
42 Activated Sludge Inhibition Loading Limit Ibs/day 324 0.00834*AH4*AH32/(1·AH19)
43 Trickling Filter Inhibition Loading Limit Ibs/day . .
44 Nitrification Inhibition Loading Limit Ibs/day 81.0 0.00834*AH4*AH34/(1-AH 19)
4S Incinerator Biosolids Feed Loading Limit Ibs/day 5,569 8.34*AH21*AH23*AH2S*AH3S/AH17
46 Biosolids 40 CFR S03 Loading Limit lbs/day . -
47 Biosolids CCR Loading limit Ibs/day 37.0 8.34*AH22*AH26*AH37/AH17
48 Maximum Allowab
49 Limiting MAHL Ilbs/da I MIN(AH39:AH47)
SO Driving Factor I IMonthly Discharge Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant 8-10 October 2006
Local Limits -Priority Pollutant Metals
AJI AK AL I AM I AN
1 Selenium
2 Units I Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 0.8 January 2004-December 2005 Data
7 Maximum Influent Concentration ug/L 1.3 January 2004-December 2005 Data
8 Average Primary Effluent Concentration ug/L 1.2 January 2004-December 2005 Data
9 Average Effluent Concentration ug/L 0.6 January 2004-December 2005 Data
10 Maximum Effluent Concentration ug/L 0.8 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 0.52 March 2000-September 2005 Data
12 Existing Loadings
13 Average Influent Loading Ibs/day I 0.17 0.00834*AM4*AM6
14 Maximum Influent Loading Ibs/day I 0.28 0.00834*AM4*AM7
15 Average Domestic Loading Ibs/day I 0.10 0.00834*(AM4-AM5)*AM11
16 Removal Efficiency
17 In-Plant Removal, Typical % I 25.0% (AM6-AM9)/AM6
18 In-Plant Removal, Worst % I --
19 In-Plant Primary Removal % I --
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-Decem ber 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 3.41 January 2004-December 2005 Data
28 Treatment/Discharge/Disposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L 5 California Toxics Rule/Basin Plan
30 Discharge Limit (Daily) ug/L --
31 Discharge Limit (Monthly) ug/L --
32 Activated Sludge Inhibition Limit ug/L --
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L --
35 Incinerator Biosolids Feed Limit, Dry mg/kg --
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg 500 CCR 22-66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 1.44 0.00834*AM4*AM29/(1-AM17)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day --
42 Activated Sludge Inhibition Loading Limit Ibs/day --
43 Trickling Filter Inhibition Loading Limit Ibs/day --
44 Nitrification Inhibition Loading Limit Ibs/day --
45 Incinerator Biosolids Feed Loading Limit Ibs/day --
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibs/day 19.1 8.34*AM22*AM26*AM37/AM 17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/day I 1.44 I MIN(AM39:AM47)
50 Driving Factor I IWater Quality Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-11 October 2006
Local Limits -Priority Pollutant Metals
Aq AP I AQ AR AS
1 Silver
2 I Units I Calculations Formula/Source
3 EXisting Conditions (Wastewater)
4 Average Influent Flow mgd 25,9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1,69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 1.9 January 2004-December 2005 Data
7 Maximum Influent Concentration ug/L 5 J,"",~200~ 8 Average Primary Effluent Concentration ug/L 1,1 January 2004-De
9 Average Effluent Concentration
I JTL I
<0.2 January 2004-De
10 Maximum Effluent Concentration <0.2 January 2004-De
11 Average Domestic Concentration 0.87 March 2000
12 Existing Loadings
~ 13 Average Influent Loading 0.00834*AR4'AR6
14 Maximum Influent Loading 0.00834*AR4·AR7
15 Average Domestic Loading 0.00834*(AR4-AR5)*AR11
16 Removal Efficiency
17 In-Plant Removal, Typical I % (AR6-AR9)/AR6
18 In-Plant Removal. Worst I % I -I -
19 In-Plant Primary Removal I % I -I -
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0,027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26,9% January 2004-December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 30,6 January 2004-December 2005 Data
28 Treatment/Discharge/Disposal Limits
29 Water Quality Criteria/Ob:e 2.2 California Toxics Rule/Basin Plan
30 . Discharge Limit (Daily) --
I 31 I Discharge Limit (Monthly) -
32 Activated Sludge Inhibition Limit --
33 Trickling Filter Inhibition Limit -
34 Nitrification Inhibition Limit I --
35 Incinerator Biosolids Feed Limit, Dry -
36 Biosolids 40 CFR 503 Limit Dry --
37 Biosolids CCR Limit, Wet CCR 22-66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit 0.00834·AR4*AR29/(1-AR17)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day --
42 Activated Sludge Inhibition Loading Limit Ibslday --
43 Trickling Filter Inhibition Loading Limit IbsJday -
44 Nitrification Inhibition Loading Limit IbsJday -
45 Incinerator Biosolids Feed Loading Limit IbsJday -
46 Biosolids 40 CFR 503 Loading Limit Ibslday -
47 Biosolids CCR Loading Limit Ibs/day 5.04 8.34 *AR22* AR26*AR37/AR 17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/day 5.04 MIN(AR39:AR47)
50 Driving Factor Biosolids CCR Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant 8-12 October 2006
Local Limits -Priority Pollutant Metals
AT! AU I AV I AW AX
1 Zinc
2 I Units I Calculations Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L 141 January 2004-December 2005 Data
7 Maximum Influent Concentration ug/L 280 January 2004-December 2005 Data
8 Average Primary Effluent Concentration ug/L 79 January 2004-December 2005 Data
9 Average Effluent Concentration ug/L 48 January 2004-December 2005 Data
10 Maximum Effluent Concentration ug/L 68 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L 161 March 2000-September 2005 Data
12 Existing Loadings
13 Average Influent Loading Ilbs/day I 30 0.00834*AW4*AW6
14 Maximum Influent Loading Ilbs/day I 60 0.00834*AW4*AW7
15 Average Domestic Loading Ilbs/day I 33 0.00834*(AW4-AW5)*AW11
16 Removal Efficiency
17 In-Plant Removal, Typical I % I 66.0% I (AW6-AW9)/AW6
18 In-Plant Removal, Worst I % I -I -
19 In-Plant Primary Removal % I 44.0% I (AW6-AW8)/AW6
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 992 January 2004-December 2005 Data
28 Treatment/Discharge/Disposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L 120 California Toxics Rule/Basin Plan
30 Discharge Limit (Daily) ug/L --
31 Discharge Limit (Monthly) ug/L --
32 Activated Sludge Inhibition Limit ug/L 300 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L 290 EPA Local Limits Guidance
35 Incinerator Biosolids Feed Limit, Dry mg/kg --
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg 5,000 CCR 22-66261.24
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day 76.1 0.00834*AW4*AW29/(1-AW17)
40 Daily Discharge Loading Limit Ibs/day --
41 Monthly Discharge Loading Limit Ibs/day --
42 Activated Sludge Inhibition Loading Limit Ibs/day 116 0.00834 *AW4 *AW32/(1-AW19)
43 Trickling Filter Inhibition Loading Limit Ibs/day --
44 Nitrification Inhibition Loading Limit Ibs/day 112 0.00834*AW4*AW34/(1-AW19)
45 Incinerator Biosolids Feed Loading Limit Ibs/day --
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibs/day 72.3 8.34 *AW22*AW26*AW37/AW17
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ilbs/day 72.3 I MIN(AW39:AW47)
50 Driving Factor I Biosolids CCR Loading Limit
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-13 October 2006
Local Limits -Other Toxics
AI B I C D E
1 Cyanide with Proposed ssa (August 2006 Draft)
2 I Units Calculations I Formula/Source
3 Existing Conditions (Wastewater)
4 Average Influent Flow mgd 25.9 2005 Average Influent Flow
5 Average Industrial Flow mgd 1.69 2005 Pretreatment Annual Report
6 Average Influent Concentration ug/L <1.6 Post December 2006 Data*
7 Maximum Influent Concentration ug/L <1.6 Post December 2006 Data*
8 Average Primary Effluent Concentration ug/L --
9 Average Effluent Concentration ug/L 3.1 January 2004-December 2005 Data
10 Maximum Effluent Concentration ug/L 7.3 January 2004-December 2005 Data
11 Average Domestic Concentration ug/L <1.6 March 2000-September 2005 Data
12 Existing Loadings
13 Average Influent Loading Ibs/day 0.17 0.00834 *D4 *D6
14 Maximum Influent Loading Ibs/day 0.17 0.00834*D4*D7
15 Average Domestic Loading Ibs/day 0.16 0.00834*(D4-D5)*D11
16 Average Effluent Loading Ibs/day 0.67 0.00834*D4*D9
17 Average Formation Loading Ibs/day 0.50 D16-D13
18 Removal Efficiency
19 In-Plant Primary Removal % I 0.0% Assumed Zero Removal
20 Existing Conditions (Biosolids)
21 Biosolids Flow to Incinerator mgd 0.027 Average Flow to Incinerator
22 Biosolids Flow to Landfill mgd 0.0013 Average Flow to Landfill
23 Percent Solids to Incinerator % 26.9% January 2004-December 2005 Data
24 Percent Solids to Landfill % 58.3% January 2004-December 2005 Data
25 Biosolids Density to Incinerator kg/L 1.00 Local Limits Guidance
26 Biosolids Density to Landfill kg/L 0.88 Metcalf & Eddy
27 Average Ash Concentration, Wet mg/kg 3.18 January 2004-December 2005 Data
28 TreatmentJDischarge/Disposal Limits
29 Water Quality Criteria/Objective (Lowest) ug/L --
30 Discharge Limit (Daily) ug/L 14 Projected NPDES Permit Limits
31 Discharge Limit (Monthly) ug/L 7.1 Projected NPDES Permit Limits
32 Activated Sludge Inhibition Limit ug/L 100 EPA Local Limits Guidance
33 Trickling Filter Inhibition Limit ug/L --
34 Nitrification Inhibition Limit ug/L 340 EPA Local Limits Guidance
35 Incinerator Air Emission Limit, Dry mg/kg --
36 Biosolids 40 CFR 503 Limit, Dry mg/kg --
37 Biosolids CCR Limit, Wet mg/kg --
38 Headworks Loading Limits
39 Water Quality Loading Limit Ibs/day --
40 Daily Discharge Loading Limit Ibs/day 2.46 0.00834 *D4*D30-D17
41 Monthly Discharge Loading Limit Ibs/day 1.04 0.00834*D4*D31-D17
42 Activated Sludge Inhibition Loading Limit Ibs/day 21.1 0.00834*D4*D32/(1-D19)-D17
43 Trickling Filter Inhibition Loading Limit Ibs/day --
44 Nitrification Inhibition Loading Limit Ibs/day 72.9 0.00834*D4*D34/(1-D19)-D17
45 Incinerator Air Emission Loading Limit Ibs/day --
46 Biosolids 40 CFR 503 Loading Limit Ibs/day --
47 Biosolids CCR Loading Limit Ibs/day --
48 Maximum Allowable Headworks Loading (MAHL)
49 Limiting MAHL Ibs/day 1.04 I MIN(D39:D47)
50 Driving Factor Monthly Discharge Loading Limit
51 Maximum Allowable Industrial Loading (MAIL)
52 Safety Factor 10% 0.10 C52*D49
53 Industrial Allocation Ibs/day 0.77 D49-D15-D52
54 Equivalent Across-the-Board Limit ug/L 55 D53/D5/0.00834
*Prior to January 2006, the influent sampling location was not representative of raw influent and included some process
55 retum flow. MAHL was calculated assuming non-detect cyanide results «1.6 ~g/L) at the influent.
City of Palo Alto
Palo Alto Regional Water Quality Control Plant B-14 October 2006
Attachment C
Air Emission Standards Calculations
Local Limits Evaluation
This attachment provides documentation of sources of data used to calculate air
emission standards that a re applicable to the Palo Alto Regional Water Quality Control
Plant biosolids incinerator. Air emission standards calculations are based on equations
provided in the 40 Code of Regulations §503.43 and Local Limits Guidance. Variations
from these data sources are noted on a pollutant-by-pollutant basis.
For All Pollutants
• The maximum sludge cake feed rate is 28.8 dry metric tons per day (mton/day).
• The incinerator control efficiencies are from the City's 1994 permit application.
• The dispersion factor is 41.7 llg/m 3 /g/s.
Lead
The following equation is used to calculate the average daily concentration criterion for
lead in sludge cake fed into the biosolids incinerator:
Where:
C = NAAQS· 8,640
DF .{I CE).SF
C = Average daily concentration in sewage sludge [mg/kg];
NAAQS = National Ambient Air Quality Standard lllg/m3];
OF = Dispersion factor lllg/m3 /g/s];
CE = Incinerator control efficiency [in hundredths]; and
SF = Sludge cake feed rate [dry mton/day].
The National Ambient Air Quality Standard for lead is 1.5 llg/m3 for a maximum
arithmetic mean over a calendar quarter (40 CFR 50.12).
Arsenic, Cadmium, Chromium, Nickel
The following equation is used to calculate the average daily concentration criterion for
arsenic, cadmium, chromium, and nickel in sludge cake fed into the biosolids
incinerator:
Where:
C = 86,400· RSC
DF ·{I-CE).SF
C = Average daily concentration in sewage sludge [mg/kg];
RSC = Risk specific concentration [llg/m 3];
City of Palo Alto C-1
Palo Alto Regional Water Quality Control Plant
October 2006
Local Limits Evaluation
DF = Dispersion factor fJ.t.g/m 3 /g/s];
CE = Incinerator control efficiency [in hundredths]; and
SF = Sludge cake feed rate [dry mton/day].
The risk specific concentration (RSC) for arsenic, cadmium, and nickel are 0.023,0.057,
and 2.0 l-t9/m3, respectively (40 CFR 503.43 Table 1). The City's biosolids incinerator is
a multiple hearth furnace with a wet scrubber. As such, the chromium RSC is 0.064
l-t9/m3 (40 CFR 503.43 Table 2).
Mercury
The following equation is used to calculate the average daily concentration criterion for
mercury in sludge cake fed into the biosolids incinerator:
Where:
c= NESHAP
(l-CE).SF
C = Average daily concentration in sewage sludge [mg/kg];
NESHAP = National Emission Standard for mercury [g/day];
CE = Incinerator control efficiency [in hundredths]; and
SF::: Sludge cake feed rate [dry mton/day].
The National Emission Standard for Hazardous Air Pollutants (NESHAP) for mercury is
3,200 g/d, respectively (40 CFR 61.52). The mercury incinerator control efficiency was
calculated to be 0.005 based on January 2004-December 2005 sludge cake and ash
data.
City of Palo Alto C-2 October 2006
Palo Alto Regional Water Quality Control Plant
Attachment D
/
San Francisco Bay Area Publicly-Owned Treatment
Works Local Limits
Local Limits for San Francisco Bay POTWs
aDependent on type and amount of discharge.