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Home My WebLink About0274.091May lE., 1991 THE HONORABLE CITY COUNCIL Palo Alto., california . \ --------- Ney pischarge Limits for Regional Water Opality Control Plant Members of the Council: Report in Br ie f This is an informational report describinq new discharge limits which have been adopted by the San Francisco Negional Water Quality Control Soard (Reqional SOard) for the Regional water Quality Control Plant (RWQCP). No action by council is required. Bagkground The discharqa from the RWQCP to San Francisco Bay is regulated by the Regional Board via a National Pollutant Discha~qe Elimination System {NPDESJ permit~ Over the last several years the limits for the discharge of toxic contaminants (primarily metals) have been reduced several times by the Regional Board. until the latest revision., however, the RWQCP's discharqe had been within the limits, albeit just barely~ In late 1990 the state Water Resources Control Board (State Board) acted on an appeal of the RWQCP's permit initiated by Citizens for a Better Environment and other environmental groups. The environmental groups believed that the lilCits should be more stringent due, in part., to the fact that lower south San Francisco Bay had been placed on EPA's -impaired water body" (3D4(1}} list, because Bay water quality standards 'Jere exceeded. The State Board partially agleed with the envirolUllental groups and ordered the Regional Board to lower the limits~ New Limits On April 17, 1991, new limits ~ere adopted by the Regional Board in conformance with the state Board order. The new limits are much lower than the previous ones and call fo~ large percentage reductions as listed in Attachment 1. The most difficult limit to meet is copper~ The current discharge contains 4S .uch as 25 parts per billion (ppb); and the new limit is 2.9 ppb, requiring: an additional gO percent reduction. The RWQCP alleady removes about so percent of the copper, but increased -1- CMR'274:91 ' . . '0' '~ \ " . , • ---i IUk o removal by the RWQCP's current treatment units is not possible. Industry accounts for about 35 percent of the copper. Thus~ evan if industrial dischargers completely eliminated copper discharges, the Ii.its could not be met without major reductions from re8id~e., smaller businesses and institutions. The incoming 'WAter supply also is a problem, as the Hetch-Hetchy water supply has copper in it due to natural sources, corrosion and the addition of copper as an alqiciae. In 1990, the San Francisco Water Department reported that the copper in the Hetch-Hetchy 'Watp.r be'fore use was as high as lO ppb, 'With an average of .. ppb, siqnificantly above the new maximum limit of 2.9 ppb. The amount of copper witbin the Hetch-Hetchy syste1!l is. well within the allowable. limits to be considered safe for drinking~ Yet., technically, the. new limits im.posed by the Regional SOard would .ean that Palo Altn"S drinking water should not qo into the Bay~ Whi1e tnis apparent conflict is explained by the fact that aquatic organisms are .ore sensitive to copper than people, it demonstrates the dilemma in attempting to meet the new limits. Ipplications for Palo Alto studies are underway by palo Alto, Sunnyvale and San Jose, which may result in site-specific adj~stments tor the South Bay concerning .ev~ral of the most troublesome of these limits4 The studies are due in Auqust, ~ith action anticipated by the Reqional Board on any revisions in December 1991. However, there is no certainty about the outcome before the Regional Board. In the interim, the adopted li~its are in effect and enforceable, even if they were appealed to the state water Resources control Board~ Enforcement action by the Regional Soard before December is possible but unlikely,. considering the ongoing studies of the appropriate m.etals limits for the South. Bay and the increasing effectiveness of Palo Alto's source control efforts (Attachment 2}. The Clean Water Act provides for a range of enforce~ent remedies., including' civil penalties of $25,000 per day of violati.:>n., and orders to cease discharge, install treatment, or execute further source control measures. Source control is a generic term including controls on industry, waste minimization in businesses of all sizes, product substitution in residences and si~ilar ~easure9. Source control i5 the preferred option by environmental qroups and the regulatory agencies. There appears to be no enthusiasm for requiring the City to Duild a metals removal plant~ Such a plant would quadruple sewer rates, use vast quantities of energy., and produce a toxic brine waste residual which would be extremely hard to dispcse of properly. Requiring; the. City to cease discharge is not a practical or a likely outcome o~ an enforcement action. Monetary fines are -2- CHR:2U:9.1 t: f ------ ---------- poB8ible~ but are less likely than requiring the expenditure of funds on n.w source control measures~ Staff believes that Palo Alto's recent source control eftorts l whicb are as aqqressive as anr-her-e in the nation, would be important con6ideration~ for any enforcement proceedings. Source control work has been planned, and staff hopes to have the opportunity to brief the Regional Board on the City's efforts. Steff h.as advised the Reqior.al SOard and EPA that the cities cannot qo much furtber witheut the help of the requlatory agencies in conducting research on new control measures. Respectfully submitte~. PHILIP BOBEL Mg:~0J=nce DAVID G. ADAMS rector of Public Works ::.~~ t.ebments: (1) Discharge Limits Table {2J Nevs Article Related CMRS: 237:9, 196:0 -)- am'274:91 7"----------~--__ ... '_--. {. • , / / ,;."-.' J) .. i ' ,,'; APRIL 1991 LIMITS fOR THE RWaCp Proposed Actual % Strategy Llmlt/PQl' 1990 Reduction P9/1 Highest Value Needed" pg/l • 0 I Copper 2.9'/10 25 90% ? I I lead 5.15'/10 20 60% ? I Nickel 8.3' 34 65% Large Industry-:--l Sliver 2.3' 9 75% 1990 Ordinance - Zinc 86' 106 None SCVWD Reductions Noles: , One-day average 2 Where Ihe POL Is higher, ills shown with Ihe limil • Four-day average • 8ased upon the assumption thallhe 4-day average will be 0.7 (x) highest value and that Ihe limit (nol the pal) will be controlling over time. I o AttaChment (1) I [ ... > , ' I ' " . ., ( ", .,.. " I ' , :\ 1 ' ,0 \ I '. • ,I .. ~.)J:~l~ilt t~:{;e;;:;;':~4; ""~~fl_'".!?-, "\"i (:r,~<,. f,~.,. t; ~.G';;r'A:t,:;'· ',"t :;,. "\ """''''~,'', '. "",. 'r,' ' f'; ,-,I",-.',. . • ~, ,. ~! ./ ;, , ~r ... -,'"'l'· nmesfrllmtte 'ENINSULA TODAY COMMENT TELEVISION CLASSIFIED f)r 1"16) 853-5249 lhuraday, April 18. 1991 ··------B-t1 ) 'Impossible' water standards MARVHARPERI StAFF OAl\~"O The San Ftlncllco Rello"11 Wafel' Quality Conlrol Board on WedMlday ndoJlled slrlftsenl loxlf! slendsl'd. lot South Day '."888 pi"". that dump melollinto trl8 Bay. Some water quallly eXlletl.a, however, tailed Ih, n •• IllnelardJ "tmpolSlble" 10 meel. The regulaliOnJ werft aimed BI,awaRe plonllf In Pplo Allo, SUM),,,.le and San Jose IMI ore Iha prlmnry Il)urCe8 olloxlc metal dumplnllnlo Ibe Soul" Day. I:!;ven 'Nlel' quality bolIIrd oretel ... ac knowledAtd thai Ihe IleIlltlardl 8t8 unr. allttkl lor Mune melall, "Wt're oolioollln" 10 ,Ivo Ulem • bledl eYft," Mid Sitye Rllddoa, flJ:~utlye .,ftlcer' 01 the tfllonal board, lie saltl Ihe pi 'I to help lilt IMIwalle planlJl Implemtnl 11m· leflletl 10 teduce sewa.., dumping ut (Illie henvy metnls, "We feel U1ey're pullins out 8 gOOd .,f. fort "OW, etlJecially Palo 1\11"." lit'! sold. The lHHIrd allli pllln!! to let new 'ImllAln December Ibal could !I,dude loultt pen alllel. Sliver and coppel' at. Ibe (wo prime Iar~fIJ of Ihe new ",sulallons. "Compliance wllh the coppet IIBndllrd Is hupunible," aalll Phil Itobe', environ· mental manaler al the Plio Alto .ater flUBllly planl. lie IBId Ihlll eyen If local bu,lnelle. completely eliminated their cOflf'tl1" W8.le,lhelMlWlIjIfI plftnl would alill Ylolale Ihe new !!lantlarel hlqultlns a ., p8Ktm teducUnn. San Jose oWcl,,11 noled Ihat nol III lOurces ij( Ihe Rlelal aN! hown, lIuman walle, pipe corrlJ!llion and oyer·lhHounl. er IIrnln clflilnelll Sre PO!l'Jlble conttlbu. torl'l. sludlesl.Aye Indlcaled. Sliver dumped Inlo Ille Dey can be reo duetd .'.nllieantly. how,"er, offlelalt 8lreed, Palo ""110 bu a prosram which Babelaald will "Iu!otk down" lev. by 71 p.rcent. IIlarlel.GOO atn.lndlllfri .. fhll develop film and papet. wiler, .n"r 100011Ula"" bYPI'OdUctJ. city • .,ale pl ... " illlI* pennlilio In dusttla. II Is U'le pllnt'. naporudbllll, 10 make aunt permll ftoldal'lileep IOllettllet are dumped within 'ptclfled jlml", Rlt· clile IBid. EnvlroQmenlal sroup', melAwhlllr ) "ailed tbe na. ,lInderd.. ' AttaChment (2) "~~--, . ~ l I I f • , 'j . " '. "