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Home My WebLink About2003-04-14 City Council (8)City of Palo Alto C ty Manager’s Repert TO: FROM: DATE: SUBJECT: HONORABLE CITY COUNCIL CITY MANAGER APRIL 14, 2003 ANNUAL UPDATE DEPARTMENT: PUBLIC WORKS CMR:223:03 REGARDING THE REGIONAL WATER QUALITY CONTROL PLANT’S INDUSTRIAL PRETREATMENT AND SOURCE CONTROL PROGRAMS This is an informational report and no Council action is required. BACKGROUND The Palo Alto Regional Water Quality Control Plant (RWQCP) treats domestic, commercial and industrial wastewater from the cities of East Palo Alto, Los Altos, Los Altos Hills, Mountain View, Palo Alto, and Stanford University. The service area covers approximately 37,800 acres and includes a residential population of approximately 202,000 people. The RWQCP Pretreatment and Source Control Prouams operate under the Environmental Compliance Division of the City of Palo Alto Public Works Depamnent. The Environmental Protection Agency (EPA) approved this multi-jurisdictional Progam on July 23, 1981. Since its inception, the Prod’am has been implemented in accordance with Federal and State regulations as well as local ordinances. Given the strict permit requirements, the RWQCP must explore all feasible methods of reducing its metals and toxic organic pollutant discharges to San Francisco Bay, including industrial pretreatment and pollution prevention. Each year, the City is required to submit two reports to the San Francisco Bay Regional Water Quality Control Board: 1.Animal Pretreatment Report - Report of Industria! / Commercial Pretreatment Progam; and 2. Clean Bay Plan - Report of Pollution Prevention / Source Control Activities Both of these documents were submitted on February 28, 2003 to the Regional Board. The highlights of each report are included below. CMR:223:03 Page 1 of 6 DISCUSSION Although many factors have contributed to the success of the City’s Environmental Compliance programs, the following elements have played important roles in reducing pollutant loadings to the Plant and the Bay’: Commercial business permit progams: photoprocessors, vehicle ser~;ice facilities, and machine shops "Clean Bay Business" progams Cooperation between industrial and commercial dischargers and RWQCP staff Development and implementation of Best Management Practices (BMPs) for various activities, such as photoprocessing, machine shop operations, vehicle service facilities, hospitals, dental offices, pottery studios, and cooling water system operations Enhancement of the RWQCP operations to increase metals-removal efficiency Continued operation of a consistent and ag~essive enforcement pro~am Below are the 2002 highlights from the Pretreatment and Source Control Pro~ams, as well as the plans for 2003. INDUSTRIAL PRETREATMENT PROGRAM The RWQCP’s Pretreatment Pro~am regulates permitted facilities and attempts to identify; and reduce pollutant sources to both sanitary sev,’er and storm water collection systems from industrial facilities, commercial establishments, and residential activities. Palo Alto administers the Pretreatment Pro~am in all RWQCP service areas except for the City of Mountain View, which administers most of the progam elements for the of Mountain View. Exceptions to this general rule are delineated in ageements with each city. While the RWQCP Pretreatment Pro~aln is a multi-jurisdictional pro~am responsible for monitoring wastewater discharge activities in six communities, most industrial and commercial dischargers are in the cities of Palo Alto and Mountain View, or within the East Palo Alto Sanitary District service area. a. Pollutants Loading In 2002, the lnass loading of 10 heavy rnetals in the Plant’s influent decreased by 8% from the previous year’s loadings. The Plant received a total of 15,970 pounds of heavy metals, and discharged 4.420 pounds to the Bay. Influent and effluent metal loadings in 2002 represented decreases of 44% and 50%, respectively from the 1989 baseline values. In 2002, mercury influent loading increased by 13%. The source of the increase is not known. However, mercury in the collection system moves very slowly and a single year’s increase or decrease in Plant loading may not be indicative of a true change in mass discharge to the collection system. The RWQCP is continuing to work with CMR:223:03 Page 2 of 6 dentists in its service area to minimize mercury amalgam discharges; and a new, more stringent mercury limit for industrial dischargers was adopted in 2002. b. Monitoring Activities During 2002, the Pretreatment Pro~am monitored the industrial waste discharge activity of 97 industrial facilities. The permitted industries included 83 significant industrial users (SIUs), and 14 non-SIUs. The non-SIU dischargers include facilities whose only process-related discharge is cooling tower blow-down water. During the year, 7 permitted facilities closed their operations, 9 new facilities opened, and one facility changed its name. The Pro~am also continued monitorin~ and inspection of small commercial dischargers such as restaurants, photoprocessors, automotive setwice facilities, and machine shops. Inspections, with concurrent wastewater sample collection, were conducted at over 14 photoprocessors, 61 automotive se~wice facilities, and 5 machine shops. In addition, inspections occurred at 270 automotive facilities without industrial wastewater discharge. In addition to regular sampling and inspection of industrial facilities, pretreatment staff responded to over 304 storm water-related incidents. Investigation of these incidents resulted in the issuance of 39 compliance directives and 14 notices of non-compliance. In addition, 3 administrative citations were issued, resulting in a total of $5,250 in monetary penalties. c. Discharge Permits The RWQCP issues permits to dischargers located in Palo Alto, the East Palo Alto Sanitary District service area, Los Altos, and the town of Los Altos Hills. The City of Mountain View issues permits to dischargers located in Mountain View. Table 1 (Attachment A) lists the types of wastewater discharge permits issued by the RWQCP and its partner agencies. Permit applications are on the Internet at: vvavw.citv.palo- alto.ca.us/cleanbav/iwforms.html. During 2002, ten industrial permits were issued to new dischargers in the RWQCP service area. Five permits were issued to pharmaceutical research industrial users, four permits were issued to non EPA-categorical significant industrial user facilities, and one permit was issued to an electronic crystal facility. In Palo Alto and the East Palo Alto Sanitary District, six industrial waste permits were renewed. Permits in Palo Alto and the East Palo Alto Sanitary District service area are issued for a period of three years, and each discharger is required to pay a $750 permit fee. In addition, permits were renewed for three photoprocessing facilities, ten automotive service facilities, and three ~oundwater dischargers. CMR:223:03 Page 3 of 6 d. Enforcement During the reporting period, 31 notices of non-compliance were issued to 18 industrial facilities, while such notices were issued to non-industrial facilities such as automotive shops, restaurants, and storm water violators. Enforcement actions in 2002 that included monetary penalties are summarized in Table 2 (Attachment B). A total of $40,592 in monetary penalties was collected for sanitary or storm water discharge violations. e. Contaminated Groundwater During 2002, 13 of the 17 permitted ~oundwater sites discharged ~oundwater to the sanitary sewer. Groundwater discharges accounted for 2% of the Plant’s inftuent flow. Prior t~) issuance of each Groundwater Discharge Permit, the applicant must submit a Water Reuse Study to the RWQCP. The Plan rnust demonstrate that practicable reuse alternatives, such as irrigation and reuse in industrial processes, have been explored and that the discharge of ~-oundwater to the sewer is the only feasible option. Groundwater discharge permits include inonitoring requirements for metals, total toxic organics, and total extractable and purgable petrolemn hydrocarbons. Monitoring is also required for total dissolved solids and chloride, due to their impact on the RWQCP’s wastewater reclamation pro~am. f. Ordinance In August 2002, a number of revisions to Palo Alto’s Sewer Use Ordinance were adopted. The revisions included new requirements pertaining to both the sanitary sewer and storm drainage systelns. The City of Mountain View also adopted similar ordinance changes in 2002. The RWQCP intends to work with its other partner agencies in 2003 to ensure that their ordinance requirements are in a~eement with Palo Alto’s. SOURCE CONTROL / POLLUTION PREVENTION PROGRAMS Since 1990, the City of Pato Alto’s Environmental Compliance Division (ECD) has implemented an ag~essive water pollution prevention pro~am addressing wastewater and stormwater discharges to San Francisco Bay The progam focuses on pollution prevention because this approach is generally environmentally beneficial and cost- effective. After initially focusing on major industrial facilities, ECD expanded its regulatory and informational proN’ams to include many commercial and residential activities. h-movative strategies adopted by the RWQCP include inte~ating pollution prevention into permit requirements, developing incentive progams for businesses, and using creative methods to encourage pollution prevention through public outreach. Table 3 (Attachment C) summarizes the pro~’am highlights through 2001. Table 4 (At-tachment D) presents the prouam highlights for 2002 as well as the major plans for 2003. Pase 4 of 6 CMR:223:03 ~ In 2003. the pollution prevention priorities for the RWQCP include: Metals (primarily mercury, copper, nickel, silver and zinc) Dioxins Organophosphates and other pesticides Endocrine disruptors and pharmaceutically active compounds The City’s pretreatment and source control pro~ams are recognized as among the finest in the nation. In 2002, the Environmental Compliance Division and staff members received reco~aition from severa! organizations: o In 2002, US EPA presented its National Second Place Award to the RWQCP for an ;;Outstanding Pretreatment Progam." In 2002, the Palo Alto RWQCP ",,,’as awarded the "Plant of the Year (Large)" a’~ ard by the California Water Environment Association, Santa Clara Valley Section. This award application included pretreatment efforts, in addition to outstanding operations and maintenance pro~ams. In 2002, the City of Palo Alto became the first city in this Bay Area pro~am to be certified as a ~;Santa Clara County Green Business" (part of the Association for Bay Area Governments Green Business Pro~am). Environmental Compliance staff coordinated the city wide effort. In 2002, the Water Environment Federation presented its "Public Education Award" to the City’s high school laboratory prod’am called "Sewer Science, .... for promoting awareness and understanding of water quality issues." Sewer Science was developed by the Environmental Compliance Division and is now being used by several public agencies in California. In 2002, the Association of Metropolitan Sewerage Agencies (AMSA) presented the ~’sewer science" high school proN’am with a national ;~Public Information and Education Award" for an outstanding educational prop’am. In 2002, a city Industrial Waste Investigator, James Stuart, was named "Industrial and Hazardous Waste Person of the Year" by CWEA, Santa Clara Valley Section. o In 2002. a city Environmental Specialist, Julie Weiss, was awarded the annual ~’Sustainability Award" from the Peninsula Industry and Business Association (PIBA). The Environmental Compliance Division staff members are committed to continued excellence in pretreatment and source control. For additional information about the pro~ams and evaluations of pro~ams to date, see the annual report, "Clean Bay Plan 2003," available at http ://xv~’,¥.citvofpaloalto.or~/cleanbav/cbp.html. CMR:223:03 Page 5 of 6 ATTACHMENTS Attachment A:Table 1. Types of Wastewater Discharge Permits Attachment B:Table 2. Monetary Penalties in 2002 Attachment C:Table 3. Summary of RWQCP Pollution Prevention Pro~am Attachment D"Table 4. 2002 Highlight and 2003 p!ans PREPARED BY: DEPARTMENT HEAD: Mgnager, PW/Source Control Programs ~ " :~ if ,4, GLE~ S. ROBERTS Director of Public Works CITY 1VL~kNAGER APPROVAL: KARRISON Assistant City Manager CMR:223:03 Page 6 of 6 ATTACHMENT A Table 1. Types of Wastewater Discharge Permits Permit Types Duration*Category Industrial 3 years All Significant m~d EPA-categorical facilities Ground Water 3 years Fuel, solvents, or heavy metal contaminated sites Automotive 3 years All vetScle service facilities with waste water generating Facilities activities Machine Shops 3 years Conm~ercial machine shops engaged in grinding, machining, and fabricating metal parts Photo Processing 3 years Any photo processing site treating fixer solution. All other photo processing sites must submit an annual hauling certification Exceptional Short Temporary discharge of waste water, i.e. contaminated Discharge duration groundwater, construction de-watering activities, or one- time discharge * The Ci~~" of Mountain View renews discharge permits annually. ATTACHMENT B Table 2. Monetary Penalties in 2002 Company’s Name Devcon Construction Benco Management Devcon Construction CV Therapeutics Caliper Technologies DSM Catalytica Hitachi Chemical Diagnostics ?alo Alto Medical Foundation America Online E1 Camino Hospital Devcon Construction Palo Alto Hills CountU Club Hammon Plating Dpix, LLC CV Therapeutics Palo Alto Medical Foundation Violation Storm Drain Discharge i Storm Drain Discharge Storm Drain Discharge pH violations [:ailure to sample Failure to sample Failure to sample Failure to report copper violation Failure to sample Failure to sample iAppeal Hearing Fee Sewer Overflow Failure to report violation Copper violation pH violations Silver violations Date Issued 12/!3/01 1/10/02 1/3/02 1/2/02 1/31/02 2/7/02 2/12/02 3/26/02 4/9/02 4/30/02 Date I Received 1/14/02 1/22/02 1/31/02 2/20/02 1/31/02 2/7/02 ~I~I0_ 3/14/02 3/6/02! 3/26/02 4/15/02 5/16/02 6/10/02 7/12/02 7/30/02 9/4/02 10/3/02 11/7/02 11/25/02 Total Amount Received 2002... PenalU" Amount $ 750 $3,000 $750 $5,250 $2,000 $500~ $ 500 $ 1,500 1.000 500 254 14,088 3,000 $ 750 $4,500 $ 2.250 $ 40,592 ATTACHMENT C Year 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 Table 3. Summary of RWQCP Pollution Prevention Program Actions Pollution Prevention Pro~am initiated Storm drain permit issuance--began to direct wastewater discharges to sewer Increased industrial enforcement Large dischargers required to prepare pollution prevention plans Silver reduction progrmn initiated Convrmnity outreach on copper-based root control products Clean Bay Business Program for vehicle service facilities started Local ban on sale and use of copper-based root control products Cooling water systems program Laboratory program Education on selenium toner Clean Bay Business Program for hardware stores and plumbers started Sewer line through Superfund site begins to receive high levels of arsenic Regional outreach on copper-based root control products Pool, spa and fountain program started Machine shop program started Automobile parts stores Clean Bay Business Program initiated Reduced local discharge limit for nickel Expanded cooling water systems efforts Regional mobile cleaner outreach Hospital and medical facility program Sewer line through Superfund site repaired Copper dumping incident Final ban on sale of lead-containing gasoline takes effect Intensive enforcement on silver program, vehicle se~wice facility program Regional ban on copper-based root control products Regiona! mobile cleaner certification Metal finishing program Vehicle Clean Bay Business program five-year anniversary; 88% participation Auto body shop BMPs distributed School program enhanced Record 92% of vehicle service facilities become Clean Bay Businesses Laboratory improves mercury analysis IPM Partnership launched Began collection of mercury thermometers and other products; collected 34 pounds mercury Printers and dentists receive BMPs Launched mercury thermostat drop-off program Began education campaign regarding residential woodslnoke pollution Ext~anded the IPM Partnership program 2000 2001 Actions City of Palo Alto adopted a Mercury and Dioxin Elimination Policy,; participating in and funding ABAG dioxin goup Initiated dental stakeholder goup regarding amalgam management Drafted mercury product legislation Piloted a residential drop-offprogam for fluorescent lamps City of Palo Alto adopted fireplace ordinance Conducted mercury audits at three local hospitals Successful expansion of pilot residential recycling of fluorescent lamps at 5 hardware stores and at RWQCP Led BAPPG in creation of an inspection checklist for dental offices and a set of Pov,erPoint presentations for dental community outreach Began using 20% biodiesel in City’s diesel landfill and golf course equipment Began purchasing process-chlorine-free office paper and letterhead and unbleached paper towels Completed the City pesticide policy and implementation plan Assisted the Palo Alto Unified School District (PAUSD) become in compliance with the "Healthy Schools Act" Table 4. 2002 Highlig.hts and 2003 Plans Pollutant ’~ 2002 Program Highlights Mercury Continued educational campaig~a to dental staff on amalgam BMPs; conducted 68 office inspections The Mercury Elimination Policy resulted in new City purchasing specifications to require low-mercury lamps Final ordinance passed with lower mercury limit for industrial dischargers ATTACHMENT D Conducted mercury audits at local hospitals Surveyed use of mercury switches at RWQCP; selected alternative switches for future replacements 2003 Plans Dioxins and :. o Furans Pesticides City began purchasing elemental chlorine free toilet paper and unbleached hand towels In 2002, the City ofPa!o Alto’s use of biodiesel increased from 3.8 % to 11.4 % of total diesel purchases Continue office inspections that began in August, 2002. Begin developing a multi-year plan with the N~DS regarding how and when to require specific BMPs and advanced separator technology Evaluate residential fluorescent lamp recycling pro~am; review options for expanding this point-of-sale pro~am Continue to select alternative switches for future replacements at the RWQCP Educate industrial dischargers regarding the new lower mercury limit in the ordinance Encourage partner cities and selected businesses to purchase process- chlorine-free and!or unbleached paper products Evaluation Criteria .Project to be evaluated based on (1) percent improvement in BMP usage at sites that receive follow-up visits, and (2) the existence of a~eed-upon multiyear a~eement between RWQCP and MPDS ~Number of fluorescent lamps collected and expansion of collection sites o Number of locations or uses for which alternative switches are identified o Compliance with new ordinance Number of meetings/contacts with partner city/businesses regarding purchasing process-chlorine-flee and unbleached paper products Reviewed hospital uses of PVC; determined current level of effort at local hospitals; developed a web page listing alternatives Assisted hardware stores and nurseries with identifying and removing chlorpyrifos products Created f’Lrst annual report of City pesticide use; evaluated and prioritized City pesticide uses and alternatives Conducted periodic trainings for City staff, partner city staff and school district staff regarding specific pest control issues (e.g., ants, rodents); developed contract language for City pest control contracts Conducted four residential IPM workshops Create second annual report of City pesticide use; continue to evaluate and prioritize City pesticide uses and alternatives Continue to assist hardware stores and nurseries with the "Our Water Our World" campaign Conduct periodic trainings for City staff, partner staff and school e ~, rodents);district staff regarding specific pest control issues ( .~.., ants, distribute contract language for City pest control contracts Conduct at least four residential IPM workshops and staff training sessions Number of new IPM plans generated Request sales data from one hardware store to identify changes in sales of pesticides and less-toxic alternatives ¯Number of staff (city/parmer staff/school) trained at IPM events. Workshop evaluations ’Table continued on next page) Metals (copper, zinc, and other non-mercury metal) Table 4. 2002 Highlights and 2003 Plans (continued) *Via lectures and newsletter inserts, educated plumbing engineers and plumbers about copper pollution from pipe corrosion; developed individual messages for targeted ~oups Emer~ng Contaminants School Outreach -Section 7 Final ordinance revisions passed: o eliminate sewer disposal of zinc-containing floor waxes o ban new and replaced copper roofs o require covered carwash facility for new or remodeled buildings with 25 units or more o add boilers and heat exchangers to the requirement of wastewater collection and analysis if one is doing " scouring and cleaning Conducted a focus g-roup with property managers and custodial contractors regarding ordinance revisions, focusing on zinc floor wax issue Reviewed janitorial and print shop products; developed list of preferred products Assisted City print shop to use safer products and achieve Green Business status As Chair of Endocrine Disruptor Compound (EDC) Committee for the Watershed Management Initiative, compiled and finalized an EDC Information Sheet Distributed a "drug free sewers" Utility bill notice to describe proper disposal of expired prescriptions; reviewed feasibility of take-back pro~ams at local pharmacies Sampled for polybrominated diphenyl ethers (PBDEs) in influent, effluent, and sludge In 2002, we exceeded our goal of reaching at least 100 classrooms per school year by visiting a total of 148 classrooms Expanded the middle school pro~am ’2viicrobes in Sewage" into service areas that have not previously had the pro~am, with several schools making the pro~am a regular part of their curriculum In October 2002, RWQCP was invited to the Water Environment Federation’s annual conference to market Sewer Science as an outreach tool for other agencies. The RWQCP co!laborated with Central Contra Costa Sanitary District and South Bayside System Authority to develop the conference materials. This was our second such appearance at WEF. Lead Bay Area Pollution Prevention Group (BAPPG) in effort to develop regional fact sheets for plumbing engineers and plumbers regarding copper pollution from pipe corrosion Assist the industrial waste ~oup to educate industry regarding the new ordinance requirements, specilically zinc-containing floor waxes Distribute preferred products list for janitorial and print shop products to industrial users and pa~nner cities Distribute the Endocrine Disruptor Compound Information Sheet to Council members, partner cities, and other publicly owned treatment works. Develop an outreach campaig-n regarding emerging contaminants Analyze the results from the polybrominated diphenyl ethers (PBDEs) in effluent and sludge. Work on identifying sources of PBDEs; determine the potential for a ma=-~nified problem in service area Re-monitor for N-nitroso dimethylamine (NDMA) in our effluent; determine the potential source and precursors In 2003, RWQCP plans to participate in WEFTEACH, which is a teacher education progran3 that coincides with the WEF conference Continue parmering with a g-roup of teachers at a single school in which we visit the 2nd, 3rd, 4th and 5th ~ade classes Number of plumbers and engineers contacted at association meetings throughout the BAPPG service area Conduct phone surveys of school district and selected retail stores to determine level of compliance with the new sewer ordinance Number of meetings/contacts ~vith partner city and businesses regarding using less-to~c janitorial and print-shop products o Progess towards an outreach campaign No evaluation criteria, conducting preliminary research Concentration of N~MA in our effluent Number of teachers who attend sewer science training pro~am Pro~ess towards a plan to evaluate knowledge gained from one year to the next