HomeMy WebLinkAbout0393.093~. . .
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July 15, 1993
THE HONORABLE CITY COUNCIL
Palo Alto, California
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Regional Water Quality Control flan~ Discharge S~~ndards
Members of the Council:
Report in Brief
This report is background information for the July 19, 1993 study
session, and it con~erns the discharge standards for the Regional
Water Quality Control Plant (RWQCP). No action is required by
Council at this time. This ~aterial will also be useful for future
discussions on potential reclaimed ....,ater programs, which will be
scheduled this October.
Backgronnd
Due to the relatively poor flushing and dilutioI", wr:ich occurs in
San Francisco Ba~ below the Durnbarton Bridge, the RWQCP is facing
increasingly st*ingent dischar3e standards_ These standards are
found in two key documents. The first is th~ San Francisco Bay
Basin Plan (Basin Plan). The second is the individual National
Pollutant Discharge Elimination System Permit (permit) issued to
the City for the RWQCP.
The Basin Plan contains the ambient standards (the standards for
the Bay itself) and the Permit contains the discharge standards
(the standards for the City's treated wastewater}. For Palo Alto r
sunnyvale and San Jose (the lower South Bay dischargers) these two
sets of standards are essentially identical, becauze dilut:ion
allowances have net been granted by the Regional Water Quality
Control Board (Regional Board). North of the Dumbarton Bridge l a
dilution allowance of ten to one is used, making those discharge
standards roughly ten times leSls stringent. thau Palo Altors.
Trte BaSin Plan was recently amended and contains standards whi=h
the RWQCP cannot meet with its current facility and process.
Components of the Basin Plan are being considered for adoption at
the State level by the State Water Resources Control Board (State
Board). ~t the appropriate point in this process, the City may
appeal elements of thE ~~sin Plan to the State judicial system.
On a parallel track, the Regional Board will, in all likelihood,
incorporate the newest standard~ into the Permit scheduled to be
issued on July 21. 1993. The City may wish to appeal the Pex~it to
the State Board~ consistent with previous Palo Alto appeals and the
appeals of Sunnyvale and San Jose. ThE'-Permit would remain in full
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force and effect during the appeal process.
term, it ~s not likely that the City would
for failure to meet standards_
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However~ in the short
be fined or penalized
The City's agreement with a coalition of environmental groups
(CLEAN' South Bay; in February 1993 dramatically reduced the
likelihood of citizen suits. The City's nationally recognized
source control program and plant opera~ion and maintenance program
greatly reduce the possibility of any punitive action by the
regulatory agencies in the short term.
While punitive action {e.g. a fine) i.s \.' ..likely in the short run,
it is probable that a Cease and De~i..=;t O~T,~r will be issued on July
21.. 1993 along with the new pelmit. This enforcement order will
C'ontain a compliance schedule for achieving the standayds and
inco.lPQrating the activities ~ontained in the February 1993
agreement with CLEAN South Bay.
Conl.:ent.ration ye. Mass Standards
Two types of standards are used to limit dischaz.-ges. Cc-ncentration
limits arE: stated as ar,lount of pollutant per unit vC':ume~ ..... hereas
mass limits are stated as total amount of pollutant over time.
Historically, concentration standards (micrograms per liter; also
called parts per billion or "ppb~) have been used to regulate toxic
constituents such as metals in treated wastewater. concentration
standards do not provide an incentive to reduce water use. If
anything, they create an incentive to increase clean .... :lter use to
dilute pollutants~ Concentration standards are also problematic,
because reducing the amount of wastewater discharged is not aD.
effective strategy for meeting the stand3r~~. Therefore, reusing
wastewater (reclamation) does not ensure compliance with
concentratioil standards.
However, regulatory agencies and e!'1vironmental groups are
incr~asingly concerned with ~he total amount (mass; typically
expressed as pounds per year (lbs/yrl] of 4 pollutant. Cities have
encouraged s~'itchin9 from concentration sta:~dards to mass standards
to increase the avajlable compli3nce strategies.
The latest amendment to the Basin Plan includes for the first time,
a copper mass allocation. Copper is the most difficult st;::.ndard to
meet and the first one for which the Regional Board has attempted
a mass allocation among the dischargers.
In adopting the new standards, the Regional Beard also adopted a
policy of allowing deletion uf concentration standards following
refinement of the mass allocations. At the Regional Board ~eeting
in June 1993, this action marked the first formal ce,:nm.itment to
switch to a more mass-based regulatory approach.
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Copper Standards
The most difficult standards to achieve ..... ill be the copper
Btc'\ndards. Following July 21, 1993. the Perr..it wlll likely contain
the following standards:
TYPE ST.I\ND1d!Il '" RKDl1CTION RF.QUIRED
Copper Concentration 4" 9 ppb 80\
(Maximum)
Copper :Mass 720 lbs/yea!' 32\1
(Average)
In addition, the South Bay dischargers (including storm water
dischargers) .."i11 be required to allocate an additional
950 Ibs/year reduction among themselves. If this allocation were
made proportional to ~urrent loading, Palo Alto's required
percentage reduction would increase from 32 percent. to
approximately 3"1 percent+ The actual allocation is not yet
determined and will be set as a result of negotiations with San
Jose, Sunny"J'ale and the SCinta. Clara Valley Water District as
required in the Tentative Permit (Attachment 2).
rh~ reductions needed for ather pollutants are much smaller and
therefore, the copper standard controls the design of moet control
strategies.
Other permit Provisions
In addition to copper, standards for the following pollutants will
be very difficult for the RWQCP to meet:
Arsenic
C".fanide
Mercury
Nickel
Selenium
Tributyl tin
Zinc
A numerical summary for these pollutants is provided in the
Treatment Standards (Attachment 1) .
Another concern is that the current detection limits available from
state of the art sampling and testing equipment are, for some of
the po] lutants (Dioxin and certain pesticides). higher than the new
standard. Thua, we cannot be sure whether the RWQCP discharge
complies or not. As laboratory techniques change and lower
detection limits become possible~ it may be that even more
pollutants are found to be above the standards.
7be "bas"!line" used is. a mult.ipl~ Y'@4r av~rage. The 15-9:2 level was
substantially J~ver but vas not used by the Regional Board due t.o the unique
rainfall and econ~c conditions.
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The permit requires Palo Alto to coordinate ...,ith San Jose,
Sunnyvale, and the county;.tide storm water pollution prevention
program (administered by the Santa Clara Valley Hater DistZ:'ict) and
to deveJ.op an allocation plan for an additional reduction in copper
discharges. Specifically, these agencies must find an additional
950 Ibs/year of copper and commit to its reduction. Discussions
with the ocher agencies; er.vironmental grcups, and R~glonal Boa~d
stdff have begun; and ar. allocation by January 30, 1994 must be
produced. This is a uni~Je new t~~~irement which delegates the
responsibility for allocating a reduction to dischargers. If it is
successful. the Regional Board can be expect.ed to use it as a model
for other pollutants.
pollutant Reduction Strategies
The following reduction strategies are being considered and
part-ially implemented as noted:
REDUC-rION STRA1EGY
SOURCE CONTROL
RECLAIMED WATER USE
El>"HANCED POLLUTANT REMOVAL AT TIlE
RWQCP
DISCHARGE POINT RELOCATION
Reclaimed Water and the Standards
STATUS
Industrial, Commercial and
Residential programs are underway
with more plarli1ed for
implementation.
CUrrently, ~-2t of treatp,d ~ater is
reused and further projects are
under consid'~ration.
Building a reverse osmosis plant
has been shelved due to its hiqh
environmental and dollar cost.-A
study is underway to determine if
part of the reduction could be
achieved by enhancements co
exis~ing processes.
,,",oving the discharge pipe no~·th cf
the Oumbarton Bridge has been
8h .. :'led d1!e to the likelihood that
limits will become more stringent
north e;£ the bridge :-=.~==== __ ='
using treated or -reclaimed-~ater removes the need to discharge it
and creates a correapond~ng mass reduction in pollutants
discharged. Thus. rel1sing 10 per-cent of thp w.;!O=~~lNate~ for
irrigation, the most via.ble reuse option, creates ?-10 percent
pollutant reduction. Studies have been underway to determine how
much reuse is feasible within the 8erv~ce area and at what cost.
That information will be forwarded to Council ~~ the near future to
prepare for decision making on reclaimed water. It is not probable
that viable opeions for reuse within 'the service area would be
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available to provide all )f the 32 -3? percent reduct ien. Source
control programs, and possibly RWQCP removal enhRncements, will be
needed also. However, it has not been possible to accurately
estimate the reduction potential of these latter strategies to
date.
ReuSlng wastewater ..-ill not contribute to meeting the concentration
standard. No estimates exist that ens~re that any combination of
control s~rategies would attain the concentrati~n standard; the
required ~eduction is Dimply too large. The alternate strategy is
that the concentrat ion standard may event'.lallj' be incJ::-eased or
removed from the permit, once the mass allocations are achieved and
documented.
Tbe forthcoming materials and presentation 0:'. water reclamatior..
program alternatives will further detail the pot~ntial for partial
.tta~nment of mass allocation standards as a re9ult.
Con,} ua;QP
This new ~r.mit will drive the Water Quality Con~rol Plant to meet
standards that are both beyond current detection ability and beyond
the current treatment system technology. Thereforel continued
progress in the following strategies must continue:
1. sour~e control and reduction;
2. investigation of increased removal at WOCP;
3. pursue investigation of reclaimed water opportunities to
red.uce mass discharges;
44 consider potential legal and legislative actions toward
continuing evolution of the sta~dards.
Respe~tfully B~.itted,
a.< .. :~i,.; ~
WILLTA."'1 MIKS
7;L1er~rOl
GLENN S. ROB TS
Di of lie Works
Treatment standards
2. Tentative NPDES Permit
3. Tentative Cease and Desi~t Order
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ATIAal!= 2 ~:~~;::. REGIONAL W1t]):R=Q=U=A=LI=TY=C=O=N=r=RCn BOAR7f:')======~";::"":W:::;"~"';:;"~;';:;::_.;;;-=
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1101 wusm !Tifft. SU~ 500 .,.....'!t
O.t.ICLAh'D. CA. '~IJ
(510) :l'U-l:}5)
Wifli.am Miks
RWaCp Manager
Pillo Alto Regional Water Quality Control Plant
2501 Embarcadero Way
Palo Alto, CA 94303
Marvin Rose
Sunnyvale Public Works Department D~rec:or
P.O. Box 3707
Sunny .... ale. CA 94086
June 23. 1993
File Nos. 2189.801 i
2189.8018
IBRLliSMMI
Subject: Revised Tentative Orders cOr'naining Dr"'lft NPDES Permirs and Aecomparl,·ing
Cease and Desist Orders
Dear Messrs. MiJ;;s, and Rose:
We ha .... e enclosed draft NPDE"S Permiu; and Cease and Desist Orders (COOs) for the
City of Palo Alto's Aegio:1at Water Quality Control PlatH and ~he Cit·, c~ Sunny .... ale·s \I\taTer
ponlltion Contror Plant, These tentative Orders are scheduied to be considered by the
Regionar Board 2111: its regular meeting on July 21, 1993.
The: draft N?DES Permits and COOs have been revfsed to include the requirements of th.e
Waste Lo~d Alloca.tion for Copper adopted by the Regional Boa,d on June 16. 1993. In
addition, the draft CDO for Sunnyvale has bee"! revised to reflect the Sen1ement Agreemen!
between the City and Clec.tn South Bay. Response to comments on the first drah of the CDOs
wilf be available by July 2, 1993.
Written comments on the draft permits and fact sheet are due at the Regional Board offices
on or before June '30.1993. The Board will also hear oral testimony at the public hearing in
July. We understand that this is a short comment period. However. we berLevs that one
week. should be sufficient because the major revisions are based on the Waste load Atlocation
which hed an extensive public comment period. If there are any questions on the drafi: NPDES
permit. please can Steve Moor!' ZIt l51 0) 286·1262. jf there are questions on the draft COO.
plea.s.e call Beth levine at (510) 286-0656.
Anachments
cc wJanacnments: Mailing list
RECEIVED
J()!i 2 ~ )993
WATER QUALITY
CONTRO(' PCANT
Sincerely,
.;kf-<4'~------" Ten~-ChuJ .;.;~, '~hjef
Surfa.ce Water
Protection Division
'L
CAUFORNlA REGIONAL WATER QUALITY CO]\;"TROL BOARD
SAN FRANCISCO BA Y REGION
ORDER NO. 93-
NPDES PERMIT NO. CAOO37834
REISSUING WASTE DISCHARGE REQUlREME."<TS FOR:
CITY OF PALO ALTO
PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT
PALO ALTO
SANTA CLARA COUNTY.
Th. California Regional Water Quality Control Board, San Francisco Bay Region
(hereinafter called the Board) lind, that:
1. The Oty of Palo Alto (hereinafter the dlscharg.r) submitted a National
Pollutant Discharge Elimination System (I\.'PDES) permit application dated July
5.1991. for reissuance and amendment of 'waste d.jscharge requirements under
]\;1'DES Permit No. CAOO37534.
2 The discharger is curren~y subject to NPDES Permit CA0037634 (Order No. SS-
175. adopted December 21, 196B, and mOOified as follows: Order 9a.034.
adopted February 21, J990; Order 9()'69 .dopted May 16, 1990; and. Order 9J-
068, .dopled April 17, J991). Order 6&'175 was app.aied to the Stale Water
Resources ContrDl Board after its adoption, and the State Board rued on th~
.ppeals in Order No. WQ 9()'S, issued October 5,1990.
3. The" discharger currer.tJy discharges an average dry weather flow of
approximately i9 million gallons per day (rngd) from its adnnced waste
treatment facility at 2501 Embarcad.ro Way, Palo Alto. The discharg.r supplies
recJajrnfd water (unrestricted use) at its tacHt)'. Treatment facilities cDnsist of
screening. primarj treatment. fi.,d-fiJrn roughing fiile ... for CBOD reduction.
activated sludge for nitrification, secondary cJarificditionl dual media filtration,
chlorination, and dechlorination. Sludge is gravity thickened, a.watered using
belt presses, and incinerated in multiple hearth fumaces. A plant expansion
"'as completed in 1988, providing ayerage dry weathe,' flow capacity of 39 mgd.
The faciUty treats wastewaler from Paio Alto, MOllnwn View, Los Altos. Los
.'>llos Hills, Stanford Uniy .... ity. and the East Palo Allo S.n;tary District
Treated wastewater effluent from the treatment plant flows into a manama de
channel (37 deg. ]J min. 11 sec. latitude -122 deg. 06 min. 36 sec longitude) to
South San Francisco Bay. wat.rs of the Uniled States.
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WAT:'::; C'lIAlIT'r
CONTNOt ;"LANT
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The Board amended its Wate, Quality Control Plan for the San Francisco Bay
Region (Basin Plan) on gP~!:'~(1~;:1.~, and the State Water Res.ources
Control Board (State Board) approved It on i!"pTI"27,C.l~,~. The Reg>onal Board
amended the Basin Plan on October 21, 1992 to adopt a site-specific objective of
4.91'gll for ropper for San Francisco Bay and the .hallow water marine
effluent limit on;e,c ·oiiiiHIiiii'd:amm<l",r:the-Basm::P.liin di\·'iilie-rrn993!ri !'!.£Pf !':~¥o~~~~~qi~J6r~'~·@~ij:mh1\~~A~l}~~~?Th~"proviS1~ns 01 0
!his permit are consistent wid, iJi"eS.sGiPlan amendmentSadepted by the
Regional Board. The 52te Board has not approved the Basin Plan amendments
of October 1992 ~Ju'!~Jm as at the date at this permit
Certain portions of the Basin Plan not yet approved by the State Board are
included in this permit. Such lirnHations, specifications, and provisLons are
based on best pro[es5iona) judgment and .staff evaluation of the presentations at
the October 1992 (1Iem 6) ,~d Jtiii·e19~3(!tefr(6) Board meetings. Th, records
from these hearings are incorporated by reference i.n this permit hearing.
5peci5cally, the site-specifi" objective for copper is included based on the
Regional Board study that emplo)'ed the '""ater effect ratio" approach
developed by the US Environmental Protection Agency (EPA). n.;s approach
provides a measure of the binding capacity of natural walers (dependent on
farticula~e matter) rel.::d:ive to the binding capacity of reference (filtered ocearuc
water) waters. ThO; ,!,ass!oading limit for.<'cippe! in thhperinit is fr"m the
regf6n:~~~~~astel~d all ?Cation fo'r cOPP~"_ developed to, implement the site
'pecific cOI\~~,~non limit by n<quiring reductions in copper mass discharged
from riverine; non-point discha:ges, and mUnicipal and L-tdustrial dischargm
~~ug~~~(~1:l~ ?3.~, F~~~~s~? .~~y~Delt~', Es~,~~··Ai1-ad\-;intige· of t11e'-sjte~
specific objective is that it is protective of the most sensitive use of San
Francisco Bay waters \'o,;th respect to ccpper: habitat for aquatic organisms.
5. The beneficial uses of San Francisco Bay, South Bay (south of the D-"mbarton
Bridge) and contiguous water bodies are:
Water contact recreation
Non-contact wa~er recreation
Wudiife habita!
Preservation of rare .and endangered species
Estuarine habitat
F:sh migration
Fish spawning (potential use)
Industrial service supply
ShtIlfish harvesting
Navigation
Commencial and sport fishing
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The existing djscharge location is contrary to Basin Plan pOlicy. The' 'Basin Plan
pro/uoits discharges receiving less than 10:1 minimum iru~a1 dilution ",a. deep
water diffuser, discharges to dead·end sloughs, and discharges south of the
Dumbarton Bridge. The exhting discharge location is also (ontrary to the State
Water Resources Control Board Bays and Estuaries policy, which prohibits
discharges south of t11e Dumbarton Bridge.
7. E"(ceptions to t.~e three Ba51n Plan prohibitions may be considered where t.J,e
discharger can .show {l) a net en ... ironmentaJ benefit as a result of the d.ischarg~.
(2) that the project is part of a reclamation project, or (3), that the discharge will
provide equj ... aJE'nt·protection~
8. The 1986 Basin PJa!1 did not induc~ v.'alE'r quality objectives for San FrancisC"o
Bay south of U,e Dumbarton Bridge. The Basin Plan found that the South Bay
had a unique hydrogeologic environment~ and tha~ site-specific ""'ater quaiiry
objectives for metals were appropriate for the ' .... at:-r body. Order 88-175
contained requirements [or studies to assess impacts from metal's on the water
body, to in\'estigate c-ontro:s on meWs 1E''''e!s discharged in effluent, and to
develop \'\'ater qu::--..!ity objectives based on cost'impact. Th£se st'"IJdies hay.: all
been received by the Regional B:J~rd. The di!.charger W!S a1ro .... ·ed to propose
\ ... ·ater quality objecti\'es bzsed on to.x.fcity testing. A conditiollal finding of net
cm.;ronmental benefit far the dlscharge was mode in ]9S9 at the time ..... ·aste
discharge requirements ",,'ere adopted. )Ji uncondHional finding of net
e.mironmentaJ benefit could nor be made because of unresolved concerns
regarding the impacts of heavy meWs on the SOUL" Bay.
9. State Board Order \""Q 90-5 found that a net en\;ronmental benefit exception
could not be mad •. Order WQ 90-5 found Liat water quality objectives were
needed for the' South BaYI and direcled the Bo.ard to adopt objecti\,fs by March,
1991, and fa amend the permi, to include wafer guality based metals limits by
April, 1991. In addition, the Board was reguired to modify the mass loading
limits for metals in the permit. On April 17, 1~91, Order 91-068 .... as adopted by
the BoardJ which included revised concentration and mass loading limits for
metals. The discharger has submitted inIonnation on t.l,e South Bay waters and
sediments that propose modest use of dilution in calculating effluent limits. No
dilution iillawance can be made for rnernuy at tl"Lis time because of concerns
regarding bioaccumulation and biomagnilication effects.
A decision regarding the dilution calculation submittea by the dls<harger will
be made by the Board in the futuT< following a demonstration that an
aggressive pre-treatment and source control program is in ;r'lace a.nd that tht:
other Basin Plan condi~ons for ar. .xception to the: era dilution requirement
have been met. The concentration limits canta,j"neU: in thls permit may be
revised upwards at atat time in conformance with the Basin Plan..
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Order WQ 90-5 found that. finding of e~uivaJent protection could be made if
water quaJity based .concentration limits for met.a.ls and revised mass Ioarung
limits for meWs were p!at:ed ln the permit Based on this requirement PaJo
Alto qualifies [or an ""ception booed on equi-.alent protection.
10. The metals Jim,jts in this permit are in some cases more stringent than previous
limits. The cUscharger is conducting a source control program aimed at
compliance with metals limits. Source: controt including waste minimization., is
a more desirable pollutant reduction technique than structural modjfication at
the discharger's planl Source control tasks are contained in the Cease and
Desist Order that a~corr.panies this Order.
11. The discharger completed th! ChIOniC toxicity tes-ring requirements of the
effluent characterization programo The Teswts of that work show ctlrof'JC
toxicity associated with the eftluent The discharger is currently implementing
a Toxkity Reduction Evaluation, including muree control and waste
minimizatiOT!, a..imed at controlling metals concentrations in effluent from the
plant The discharge .. -has conducted a Tox.i=ity Identification Evaluation to
detemUne spedfie causes of the chroruc: toxicity, \\,tJch inchJde zinc and
hardness.
12. The discharger has Coosttt.lc'ed a freshwater marsh enhancement project located
on lhe m site (in L'-,e Palo Alto B'Y'ands). near the treatment plant. Funding
for the project was acqUired from the California. Coast3..l Conse-rvancy_ The
project diverts up to 1 mgd of final effluent to create a 15 acre freshwater marsh
that \\.;1.1 drain into MEitadero Creek... The project aha includes an inlet on the
south arm of the Palo AHo Harbor to permit salt water inflow into a series of
ex.isting sloughs and development of salt marsh habitat an ihe project site.
13. The marsh ""'ill be operated to enhance benl':'fida! uses of reclaimed \"o.°ater, and
as such qualifies for Board consideration of an exception to the discharge
prohibitions stated i:1 Finding 6 abo ..... e. The diversion of 1 mgd of treatment
plant effluent to an altema!f discharge point dDes .not alio\V an increase in the
39 mgd capacity of the planl
14. The Board adopted Resolution 77·1 specifically establishing its f'olicy regarding
the "Use of wastewater to create., restore, mainta!n, arid ezmance marsh lands.
The discharger submitted a Marsh Ennancement Plan that outlines operations
of the marsh project, future enhancement of the marsh, and a program for
protection of rare and endangered species. The discharger will measure melal.
in the ,ediment o[ the marsh before operation, begin. and periodically
thereafter in waters and sediments. As ve-getation and arUmals in the marsh
ecosystem increase, additional studies to monitor the health of the marsh "';11
be considered_
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15. Department of Health Sen-ices guidelines require tha. the discharge to the
marsh should not exceed a median coliform limit of 23 MPN/l00 m.l to protect
pubUc health. The dischargo currenUy meets that requiremenl .
16. The discharger is hereby notified l".t the Board will consider amendment of
the TIT Marsh requirements as necessary to protect other beneficial uses (e.g.,
aqua!i: habitat). The consideratiD" 01 ame!1dments ,,;11 depend On
demonstrated effects of t.'"te marsh operations on other beneficial uses of the
waters of the state.
1i. The discharger has an appruved EPA Local PretTeatmenr Program [or SOUTce
control and application of pretreatment standards.
18. Federal Regulations for storm water discharges were promulgated by EPA on
November 19, 1990. The regulations [40 CFR J??, 123 and 124) require specific
categories of industria! 2cti ... ities including PubEcly O"r\·r.ed Treatment \'\forks
(POTWs) wruch disch.arge storm \',:ater associated ""-it.l" industria! acthity
QndustriaJ storm water) to obtain a I'\'FDES permit and to implement Best
Available Technology Economically Achievable (!lAT) and Best Conventional
Pollutant Conrroi Technology (BO) to control pollut~nt.s in industrial storm
",,'ate: discharges.
19. The storm \. .. ·i!tec flows from the" ",2.5Ie\· .. at~T treatment faciHty process are.as .arE
diTfcted to the \'.'a5tf'\ ... at~r treatment plant headwork.s 2nd are treated along
" .. -ith the wastewater ciJso:harged to the treatment plant These storm water
flo~~'s constitute all indu.strial storm \· .. aler al this fadlity and consequently this
penrJt reg-..z.!ates all industrial storm water cfi5charge at this facility.
21. This Order .serves as an NPDES permit, reissuance of whkh is exempt from the
provisions of Chapter 3 (commencing with Section 21100) of Division 13 of the
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, : <i:~ ~' ... -: . :> .. ;
.. _J
o
Public Resources Code (CEQ"') pursuant to Section 13389 of the Califomia
Code.
22 The" discharger and interested agencies and persons have been notified of the
Board'. In!ent to reissue the NPDES permit for th';' discharge and have been
provided an .oPportunity to submit their Written comments and appear at the
public hearing.
23. The Board,.t a properly noticed public meeting, heand 2nd considered
comments pert";ning to the discharge .
. IT 1S HEREBY ORDERED, that t."e discharger, in order to me<t the provisions
contained in Division 7 of the California Water Code and regulations adopted
thereunder and the provisions of the Oean V"ater Act as a.mended and regulations
and guidelines adopted t.ooreunder, ,haJJ comply with the following:
A. Discharge Pro~libitjons
1. Discharge of waste to waters of San frandsco Ba.)' south of the Dl.lmbarton
Bridge or tributaries is prohibited.
2. Discharge of waste not recehing injtiaJ dilution or at !~ast 10 to 1 thrO'l.'gh a
deepwater diffuser is prorubited.
3. DiSCharge of waste' to dead·end sloughs or confined water ...... ays is prorubited.
4. There ~haH be no bYFB.S5 or overflow of untreated ...... astewater to wate~ of the:
State at the treatment plant or from fr~e collection system under the control of
the discharger.
5. The average dry weather flow shalJ not exce.d 39 mgd, aetennined during an}'
fiye·weekday period during the months of June throui"h QC'~ober. nus flow
limit includes 1 mgd of groundwater dea.,·up flows and 38 mgd of industrial
and domestic flows. Groundwater clean.up flows should not occur during wet
weather periods and should be consist,nt with local pretreatment limits and
"ther requirements.
6. Discharges of warer, materials, or wastes other than storm water, whk." are not
otherwise authorized by this NPDES pennit, to a .tonn drain system or wate"
of the state are prohibited.
7. Consistent wil.o State Boand Order WQ 90-5, this Order contalns warer quality
based e/fluent !jmits and mass lo"ding limits for meWs. Therefore the
discharger is pnled an exception to discharge prohibition. 1 through 3.
6
~ ..
B. Effluenl limilotio11S
I. The disd\arge of an ellluen! containing constituents in exress of the following
limits is prohibited:
Instant-
Monthly Daily aneoU$
Qmstirurnt .i.b:ri1 Aver2g:e Maximum Maximum
a. BOD my I 10 20
b. Ammonia-N mgll 3.0 8.0
c_ Suspended Solid. m~l 10 20
d. Oil and Grease mgil 5 10
e. Settleable Matter myl-hr 0.1 0.2
f. Turbidity NTI! 10
g. Chlorine R .. id"al mgtl 0.0
2. The discharge .hall not h,,·e pH of less than 65 nor great., Ihan 85.
3. Efflyent Toxicity
3.1 brute TolCicitv
The surviva! of orgarusms in undiluted effluent shall re an ]]-sample
ntE'cllan value of not less than 90 percent survival, and 21 90 perc~ntile
value of not: less than 70 percent survival. The 1 I-sample med.i3n and
90th percenb"le effluent lintiutions are defined as foHows:
1 I-sample median: Jf five or more of the past ten or fewer samples 5hcw
less than 90 percent 5un.iva,j, then 5uni'w'aI of less
Ihan 90 percent on the "ext .ample represents a
vlo!ation of the effluent lil1'jt;
90th percentile: If one Or more of the past len or fewer samples show
Jess dlan 70 percent sur .... ival, then survival of less
than 70 percent on the next sample represents a
violation of the .ffluent limitation.
3.2 Chrank Toxicity
All permit amendme"ts contained in Regional Board Order No. 92-1O.J,
the Blanket Chronic Toxicity Order, are hereby included in this Order.
4.. Congmtratiorl Limits for Tn,ac Pollutants
7
.-',. :
.'
" .
'<-"~-... " , ,
,-_, ," _,. 'F':" "/"
r i~, .. -.~::, .~-
o
4.1 The effluent 'hall not e.CiOetl the following concentr.tion limits:
1.o.y 4-day Monthly
Canst] ttl en t A"""rage .!!!.i:Llli Average ("gll)t AVerd&e (u&'lIt
Arse,,;c 3.6 (A,F)
udmiurn 9.3 (A,C)
Chromi urn [>'I) 10 (A,F)
C,-pper 4.9 (C)
Load 5.6 (A,Cj
Memuy 2.1 (C) 0.025 (A,E)
Nickel 8.3 (A,C)
Seleruum 2.0 (A,F)
Silver 2.3 (A,q
Zinc 86 (A,C)
Cy.";de 40 (A,F)
Phenol 100 . (A,F)
PAHs 40 (A,F)
4.2 The effiu~nt shalt not exceed the follo\\ing C'oncE'ntranon lirn5ts by June.
30, 1993:
I-day 4-day Monthly
Con:'PNrnt Average Cug'f)t .... v.rag. ("~I1lt Average (lIgll1t
Aldrin 0.00014 (E)
a·SHC 0.013 (E)
p·llHC O.CI46 (E)
Chlordane" O.O().l (C) 0.000081 (E)
Chloroform -l80 (E)
Cyanide 5 (C)
DDT' 0.001 (C) 0.0006 (E)
Dieldrin 0.0019 (C) 0.00014 (E)
Endosulfan' 0.0087 (C) 2.0 (EJ
Endrin' 0.0023 (C) 0.8 (E)
>'.BHC (lindane) OJ6 (C) 0.062 (El
Halomethanes' 480 ~)
Heptad-Jar 0.0036 (C) 0.00017 (El
Her!1!~!,"JCi Epoxide ,. 0.00007 (El
Hex.ochlorobenzene ".00069 (E)
PAHs' 15 (C) 0.031 (E)
PClls' 0.03 (C) O.W.!J7 (E)
TCDD equivalents' 1.4E~ (El
Toxaphene 0.0002 (C) 0.00069 (E)
r"Dulyllin 0.005 (E)
a
,
t , ,
•
t -
A
5
C
D -
E
F -
4.3
Analytic:aJ definition of constituent (ou"d in Attachment 2 of this permil,
"Organic PrioriI)' PoIiutanls Definitions"
Compliance detenninations shaH be based on a .... ailabJe analyses [or the:
tiIl1t interval associated ¥lith Ute effluent limitation. VVher. only one
sample analysis is available in a specifie~ time interval (e.g., 30-day
average or 4-day average), that sample shall serve to characteriz~ the
discharge for th~ entire-interval. For 4-day averages, compliance with
the effluent limHation may be demonstrated by reporting concentrations
of fOllr 24-hour composite samples, as well as the average of the four.
Limit same as previous limit.
Limit same as fresh water quality Objective / aquatic jife.
limH same as marine water quality Objective I aquatic iife.
Limit same as fresh wa~fr guaJity objective / human heaJLI-t..
Limit same zs marine water quality Objective / human heaJlrL
Limit derived from 95th percentile concentration from 1989 plant
perionnance. The disch.3Tger ""ill evaluate compliance v.ith me 95th
percentile Iimlt monthly. The 95th perc~l1ble vaJue is the highest
concentration measured during a time period (two years m.!,Xjmum) after
removing the top 5% of the results for that time period. After 5% of the
measures Eor any toxin have exceeded the eEr1utmt Iimlt, each additional
e'lCceedanC'e \'\;11 constitt.!:e a \;olation for the measurement period of that
toxin (e.g., for metals measurements that are measured monthly, each
exceedance after the 5% allowed \ .. ;Il be counted as one month of
\iolation).
limit of Quantllation a.OQ) Method Detection Limit "roD Oli1d
Practical Quantification t imit {POll
AJI me~aJ effluent ri~ts are abo\'e the associated practicaJ quantification
limit (PQL) [or that metal e.':cept for mercury_ Provi~;jon E.5 contains a
task to determine the LOQ, MDL, and PQL for mercury and the
constituents 01 Section 5.4.2 measured by the RWQCP laboratory and 10
request the oUlside laboratories to identify their MDLs ."d PQLs for
specific constituents. According to the Slate" Beard's Enclosed Bays and
Estuaries Plan (91-13 WQ), the LOQ shall serve as the PQL where a
discharger develops a LOQ specific to their matrix and satisfactory to the
Regional Board.
When the effluent limitation is less than the PQL, compliance
determinations based on analysis of a single sample .hall only be
undertaken jf the concentration of the constituent of c:oncem in the
sample is grealer than or egual to the PQL When the elf1uenllimitation
9
~ "' . ~ .-_.~ ,j:J-
o
is less than the PQL~ and recurrent analytical responses between the
PQL and the effluent limitation OCClJr~ compliance r:halJ be de!emtined by
review of data and laboratory bench sheets to determine the method
de~ed:ion Iirrut, and, where appropriate, the statistical signHkance of
the5!! ';alues.
5. Mus limits for Toxic Pollutants
The-co---r","sreIoad'illocaoon Bas; "~PlanAiiiendffienn'M fed b' ill • .... ~".pl"t,"." ·""'"'.'""'w·,C"·" ". " .. ,.," .. ,. .. .. p"."". y" " l:lOeep[I} UI1.e 16, !.m; ~all$tl'r.. ille" three. Soutp. ,B._ Y.N,TIX!.tll ,:,,"~u",e
f"tB~k~~s,d"i~Sh-rgeJ .bX;".E'~l1'."111 0£25%;. T!?e~ •. lit:ni.tf,?r ""
£9f'~,J'1..§~,c:t pn ,~,;;c3 '?fithl!!,~!'1"'tr~q <.cts. thl.~.qutred "ned '1~ti on,'""
~f~!;;~!"-'~7:.!l!E""O(20J'~du~"ti~n.!n_!~'!"-E~.~dings.I"O
~i:>"""''''~A:Y~ __ ~ ,._.~""'"
!iI"~ddi~oriii)the-aDOverequii'di.duction';illepaloAltoRWQCP,th'
~th.r.tw0 South Bay ponV,;.and the SantaOara YaUey Nonpoinf
So""""Poliution Control Program ane required to :fduc. their combined
discharge of copper into South. Bay by an additional 950 pound' per
rear, to be acrompll,~ed by 1998. This required redu~ti.on is not
~.fJ!~Ot~d,in the coPpeiTllaSS ~~m,;tot Section 1l.52
5.2 The effluent mass loadings shall not e.xc-efd the Iollm'\.;ng mass Jo.ading
limits:
Annual
limit
(Ib1yr)
Constituent .£12i
JtJ'Seruc lSS
Cadmium 237
Chrorni urn (VI) 474
Copper 720
Lead 790
Mercury 16
Nickel 948 ."
Selenium 100
Silver 237
Zinc 5925
Cyanide 1659
Phenol. 3950
PAH. 1580
10
(1) Melals limits h.sed on average flow data [rom 1985-1988 2nd average
concentration data from 1989, except for copper, whkh is based on the
wasl.load allce,tion adopted by the Board on ,~'!§. 1993. Aocordjng
to the Basin Phn, .fter a wasteload allceation (lor copper) is
jrnplemented in pennits and load reductions consistent with that
allocation are occurring. the Board ",-.. m reevaluate the effluent
concentration lirru'tations for coppF.'r. Limits [or cyarude .. phenols. and
PAHs a!'e based on 1985-1988 average flow dara and 1989 performance
data.
(2) In cakulating compliance, the discharger tNill count alll1on-detect
meas'.Jres at the detection level. If a mass Emit "1olation is observed .. and
!lon-detects contribute to the violation, the discharger wiIl improve
rnorutonng capabilities for the specific ,"onstituent, and the violatio:is \ .. ;lJ
be eva1ua~ed 'kith consideration of the detectiDn limits.
Mass loading shouJd be calc-uJated for each analytical re-sLUt (e.g.~ for
' ... ·fE'lJy me2SUTes~ calculate loadings ...... eekly using ;i!\'erage h·eekIy flow
data. The discharger snaIl submit 2: .::umulative total of mass loadi::"lgs for
the pre\ious h· ... eh·e months ... ith each Self.Monitoring Reportj.
CompliancE' \.,;IJ be detennined based on the predeus tv\'el\'f' months of,..
monitoring. and ""-ill be calculated weekly for """eekIy me.asures~ and
monthly for monthly measures. MonitOring data coDE'<:ted u!".der
accelera!pd !;-Ch~=..J~;i; 5h01.J.id be time-weighted when calculating the
a\'erage a.nnual ~o.adi.ng.
For performance-based maS5 lilT'Jts: Because m.:i5$ may increase during
heavy rainfall yeaTS ,md wet year data were not considered in the
de\'~Jopment of LI,ese limits r f)(ceedances during "",'et ""eather years \'\-lli
be e\'aJu.ated sepuately.
6. The arithmetic mean of valUE'S for BOD a.nd suspended solids in effluent
samples coUected in each monthly reporting period shall not exceed J5% of the
arithmetic m~an of respective vaJ:ues for influent samples collected at
appnoximately the same times duri~g the same monthly period (i.e. 85%
removal).
7. The effluent shan not exceed a median 1t.fPN for total coliform organisms of
23{]OO ml, nor a maximum of 24CVlOO ml, 2S detemUned fnom the results of the
previous ronsecutive live (5) days for which analyses have been completed.
11
o
c. kceiving Woller Limitations:
I. The dUeharge of waste shall not cause the following conditions to exiS! in
wal ... of the stale at any place:
L Floating, suspended, or deposited maCToocopic particulate rna tter, or foam;
b. Bottom deposits or aquatic growths;
c. Alteration of temp.?rature, turbidity, or apparent color beycmd pre .. nt
natural background levels;
d. Visible, floating, suspended, or deposited oil or other products of petroleum
origin;
e. Toxic or othf:r deleterious substances to be present in (oncentrations or
quantities which Mll cause deleterious effects on .aquatic biota, MJdHfe, or
waterfowl~ or which render any of these unlit for human consumption either at
levels created in the receiving waters or as a result of bioiogical conc~ntratiop..
2. The discharge of waste shall not cause the foIlo\o\ing iimits to be exc-eeded in
waters of the state \\;thin one foot of the water surface:
Constituent
a. Dissolved Oxygen
b. Dissolved Sulfide
c. pH
S.O mgfl minimum. Medidn of any three (onserutive
months sha..il not be Ie-55 th~n 50% sah!ration. \Vhen
natural factors cause' Jesse'! concentrations than those
indicated above'~ then this discharge shall not cause
further reduction in the concentration of dJssDlved
oxygen.
0.1 mgt I maximum
Variation from natural ambient pH causing
unreasonable effects on beneflciaJ uses.
d Un-ionized Ammonia 0.025 mgtl as N, annual m,di.n. 0.4 mgtl as N,
maximum
3. Any appucable receiving water quality standard for receiving water> adopted
by the Board or the State Water Resources Control Board, as required by the
aeon Water Act or amendments thereto, including the chronic toxicity
objectin, shall De mel ,,;thin 250 feet of the point of discharge. In t .... e cas. of
12
CAUFORNiA REGIONAL WATER QUALITY CONTROL BOARD
S"A FRANCJSCO SAY REGION
SELF·MONIT0AING PROGRAM
fOR
CITY OF PALO !.i. TO
PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT
S .... \lT A CLARA COUl'l.'TY
NPDES NO. CAOO378.>4
ORDER NO. 93-
CONSISTING OF
PART A (Dated December 1956) and PART B
o o
QRGANlC PRIORllY POLLUTANTS SPECIAL DEFINITIONS
(from Appendix 1 of the Califomia Enclosed Bays and Estuaries Plan 91-13 WQ)
CHLORDANE sr .,.-~ mean the sum of chlordane-zlpha, chlordane-gamma, cNordene
alpha, chlordene-gamma, nonachlor-alpha, nonachlor-garnma, a.nd o)(ychlo:-dane.
QQI shall mean the sum of the p,p' and o,p' isomers of DDT, DDD (IDE), and DDE.
ENDQSULE.I,N shall mean the sum oi endosulfan-a1pha, endc,ulfan-beta, and
endosclfar. sulfate.
E)\''PRlN shall m.an the sum of endrin and endrin aldehyde.
HAl OMETHANES shall mean the sum of bromo(ortr'" bromomethane (rr,ethyl
bromide)~ chloromethane (methyl chioride), chlorodibromomethane, and
dichlorooromomethane .
.Ea!:U (polynuclear aromatic hydrocarbons) shall mean the ,um of "enaphthylen.,
anthracen~. l,2-benzanthracene, 3.4-benzofluoranthene, benzo[klfluoranthene, 1,12-
benzop.!)'len', benzo[a]pyren., chrysene, dibenzo[ahJanthrac,ne, fluo"ne,
indeno(l.,2p.-cd]p}Tene .. phenanthrene, and pyrenc:.
~ (polychlorinated biphenyis) shall mean the sum of chlorinated biphenyls whose
analytic:aI characteristics resemble those of Aroc!or-l016. Arodor-1Ul, Aroclcr-1232.
Arodor-1242, Arccior-1248# A.roclor·r254, and Asoclor-12bO.
TCDD EQUIVALENTS shall mean the sum of tr.. concentrations of chlorinated
dibenzodi"xins (2,3,7,S-CDDs) and chlorinated dib.nzofurans (2,3,7,S-CDFs) multiplied
by their respective to:ddty equivaJenre factors, as shown 1n the table below.
l50mer Croup
2,3,7,S-letra CDD
2,3,7,S-penta CDD
2,3,7,8-hexa COD
2.3,7 ,8-hepta COD
oct.a CDD
2,3;7 ,8-tetra CDF
1,2,3,7,8-p.nta COF
2,3,4,7,8-penta CDF
2,3,7,S-hexa CDFs
2,3,7,S-hepta CDFs
oct.a CDF.
,
Toxicity
Equivalence
Factor
1.0
05
0.1
0.01
0.001
0.1
0.05
05
0.1
0.01
0.001
marine water quality objectivE'sl the standard shaJl be met ""here the salinity is
greater than or equal to 5 parts pe; thousand..
If more stringent appli!:able water quality standard,;; are promulgated Or
approved pursuant to Section 303 01 the Oean Water Act, or amendments
there~o, the Board win revise or modi!)' this Order in accordance Mth such
more stringent standards.
D. Slud':e" Reguireme-nts
t The discharge of sewage sludge shall not cause waste material to be in a
position where it is ... or can be carried from the sludge starage site and
deposited in the waters of the State.
2. ~Iudg'e,·tieabi1ent. sl¢'fage~·-and disposal.oT~'use shill nof creafe"a riws3'n(f,
~1.!ch ,~~ o~j f'C~ti?nabI~-od:,P!:i _ C)_r_,f1~ ~.EE ,~:uI~. i_~"s::.o_ll£l~~·~! ~EEC?!:t.2 rrJnati O!1.
3. D"tYtti mltigare: The dEcharger .halltakeall ie .. enab!e stel" to p;ei'<ntar
'runi",j,. 21'1y sludge. use Or disposal which !I~_~_likel~0<J~ .of 2d"esely .
~~e~ti~nK ~U?~i ~"e~_~ ?T .. ~~ e~\~:::m!!l,:!l_~
4:. All 'sh:~dge-generated bi L~~ dischargefmust be" disposed of in. m incinerator, in
atwrdancr ,\;m 40 CFR Part 503. If the ~ischa!'ger de:slt"es to d,jsF-~se of s1ud~
by B different methodr a request for penrut modification must be subj"nltted ~D
l'1e EPA )50 days \>rlOrf .tart·up of the altFmate disposal practice. .'\11 L>,e
r~qui..reI!1e;tt:s in ~o CFR 503 are enfo~eabJe by EPA \"'heth.er or not they ue
~tate~. j~Z:,~I1. ,~£~~.S. P~!.,'?£~~~_~~ pe~~l.~~.~e: £~~~.
5. Th,; dischiirg'€r·.rcaJriubmifaii-ii~"ri-ua!report tcrtheUA-andtheRegl""a]
~oard C9ntaining-morutot1ng,~~ults as specifi~:Un S?O~.~S, postmarhd
!,eb~ .1'1.9f each yea, for th_'_~ri"~_c"!.eJi"gt,!" • .o.P.:.;~"i?~sE~eI)dar).,,ar-
6, Tne Board may amend this pennit prior to expiration if changes occur in
applicable state and federal sludge regujations_
'E.. Provisions
1. The requirements of this Order supersede the requirements of Orders 88-175,
90-034, ~9 and 91-068. Orders 88-175, 90-034, 9~69, and 91-068 are hereby
rescinded.
2. The discharger shall comply with all sections of this Order immediately upon
adoption.
J3
.
,.---,
o
Effluent Toxicity
3.1 Acute Tqxicity
CompHanr:e Yiith the acute tDxidty limitation in effluent limitation 8.3 of
this Order shall be evaluated by measuring survival or lest fishes
exposed to undiluted emuent of 96 hours. Each fish species represents a
'ingle sample. The toxicity tests will be performed .<cording to protocols
approved by 1M U.S. EPA or State Board or published by the Arnerican
Society for Testing and Materials (ASTM) or American Public Health
Association. fWD fish species will be tested concurrently. These shall be
th~ most sensitive two species determined frem concurrent screenir:g(s)
of three species: three~spjne stkkJeback, rainbow trout and fathead
minno ..... -. If concurrent screenings have been conducted prior to tNs
pemdt reissuance, tht: e::cisting data may be submitted to the Board. 1f
such information is found to me~t the reqwrements of tI>fO Basin Pian,
furthe~ sCieenings ·, .. '0 .... 110' r';ot be requI,ed.
The Regional Board may consIder allo\l\.ing compliance morutoring hith
Of'Jy one (the most sensitive, if known) fish species, it the: following
condition is met the discharger can document that the acute to)jcity
limitation, specified above, has not been exceeded during th~ pre .... i.ou5
three years, or Wt acute toxicity has been observed :n only one of t> .. ·o
fish species.
3_2 Chronic Toxicit\'
All permit amendments contained in Regiona.! Board Order No. 92~10-;,
the Blanket Chronic Toxicity Order, are hereby included in this Order.
4. The discharger shall submJt a tec-ruucal report aCCfptable to the ExeC1J~ve
Officer summarizing the results of a minimum of ten (10) effluent szmple
analyses for mercury and seJemum (five in wet season, five in dry season), and
six (6) for the constituents listed in S.ction B.4.2 (three wet, three d,y, with the
exception of TCDD equivalents [dioxin) for which three (3) analyses shall be
sufficient). The report shall include the limit of quailtitation (LOQ). method
detection limit (MDL) and practical quantification limit (PQL) achieved .t the
RWQCP laboratory and an evaluation of compliance with the effluent
limitations for each constituent. Fo~ each constituent, the LOQ, MOL, and PQL
should be less than the emu.nt limit, wh.re technically feasible. For
constituents analyzed outside of the RWQCP laboratory, MOLs and PQLs
should be provided to the RWQCP by outside laboratories, and included in tJ-Js
:echnical report. If the mDnitoring results for a constituenl in S.ction B.4.2
document that the emuent limit cannot be attained by June 30, 1993, the
14
(.
, __ .charger may petitlon lor interim limits by July 31, 1993. The techrucal report
shall cor.ta,jn recommendations for further eftluent sampling and L"1aJysis, both
"ith respect to type and frequency of analysis. This NPDES permit shalJ be
sub5equently modified to indude eHluent sampling for th~ subject constituents.
Due Date
Submit Technical Report July 31, 1993
5. !he. diSchaigef 'hhlleoiiiplY"'ith lherequlreir'enfbf1l5,1.!i-()f tl\il pefr.1it t6
!educeth.e combin~d discharge of copper Irom}he discharger, the SUMyvale
y>'Pcp, the .Sari ]ose!SaritJiOar. wpcp,."d the Sa,,!a OaraValIeyNonpoint
POUrce PoU."tionConrrolPr08Tamby950pounds per year: n,edischa:-ger ,haTI
submit a joint pl.n, acceptable to.the Executive Oificer, with the Sunnyvale
WPC?, the San]ose/Smta Clara WPCP, and the Santa Clara VoUey Nonpoinl
Source PoUution Control Program for developIng a proposaJ to achievE"
compliance with 85.1.b of this permir. The joint proposal, .,c"Ftable to me
Lecutive Officer, sh0uJd be submitte~ 5 mont!u_alter th." submittal 01 L~e plan.
Due Date
Joth! Pia" fordevelopi.~g: August 30,1993
propcs31 to .achieve: compliance
\.,1th B.5J.b
Due Date
Jo;"fproposa:! to .due".-· -January 30,1.994
cO~'plianc~ v.ith B.5 . .1.:b
6. The discharger shall compl)' with the attached Sell-Morutoring Program. }1-,e
Executive Officer may make rainor amendmenLs to jt pursuant to feder.al
regulations [40 CFR 122.63)_
7. The dischargp.T shall comply ",,;111 aU items in Lie attached hStandard Provlsiof,S,
Reporting Requirements, and Definitions" dated December 1956.
8. The discharger shall review and update its Operation and Maintenance Manual
annually, or in the event of significant lacility or process changes, shortly alter
such changes occur. Annual revisions, or leffers stating that no such changes
are needed shall be submitted to the Board by April 15 of each year.
9. The diSCharger .hail annually review and updale its Contingency Plan. The
diS(harge of pollutants in violation of this Order, where the discharger has
15
failed to devolop an<tlor implement a contingcr.cy plan will b. the basis fDr
considering such disc-harge a "Willful· and negligent violation of this Order,
pUf3uant to SectiDn-13387 of the Water Code.
10. The discharger shall implement and enforce its apprDved pretre.tment pro/;'".m
in accordance with Board Order 89-179 and its amendments thereafter. The
discharger's responsibilities include .. but are not lim5led to:
a. Enfortement of National Pretreatment Standards (e.g., prohibited
discharges, Categonoal Standards, local limits) in accordance wit;, 40 CFR
403.5 and Section 307(b) ."d (c) of the Oean Water Act.
b. ImplEmentation of the pretreatment program in £!cco"'dance with legal
aLithorities, policies; procedures, and financial provistc.:1s described in the
General Pretreatment regulations (40 CFR 403) and its approved
pretreatment pro!;'"'m.
c. SubmIssion of annual and quarterly repnrts !o EPA and the State as
descnbed in Board Order 89-]79, and its amendments theteafter.
11. Ths Otder e::::pires on July 21, 1998. Tne discharger must file a report of 'o\.·aste
discharge in accardanc€ 'nith Tille 23; Chapter 3, Subch.aplet 9 of the CaHforr-Ja
Administrative Code not lat';'t than 180 cays before thls expiration date as
application for reis5uance or wa~te discharge requirements.
i2. 'TNs Order shall serve as a 1'-!ati·:-nal Pollutant Discha.ge Elimination System
(1\:rDES) permit pursuant to Section 402 of the Oean water Act Or amendments
thereto, and shall become effective 10 days after the date of jts adoption
provided the Regional Administrator, EPA, has no objection. If the RegiDnal
Administrator objt"cts to its jssuance, the permit shaIl not become effertI\'f' until
such objection. is \'\.i!hdrawn.
16
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(\ ',-.
I, Sleven R. Ri(chie, Executive omc,r, do hereby certify that the foregoing is a full, '
true, and correct copy of an order adopted by the California Regional Water Quality
Control Soard, San Fl'1!Incisco Bay ReglOn, en __ ~
Attachmen ts;
Location Maps
STEVEN R. RITCHIE
Executive Officer
Org.rue Priority Pollutants Defirutions
Self·Monitoring Program
Standard Provisions~ Reporting ReqU£rements. and Definitions (dated D~c. 17, ]'986)
Pretreamoent Order No. 89·179
Chronic Toxicity Od« No. 92-11.'\
Fllf No. 2~S9.S011
17
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SELF-MOI\.'!TORING PROGRAM
FOR
CITY OF PALO ALTO
PARTB
I. DESCRlPTlON OF SAMPLING STATIONS
A. INFLUEIIIT AND TNTAJ..'E
Station
A-OOI
B. EFFLUENT
Station
E-ool
E-OOI-O
C. RECEIYll':G WATERS
Station
. Descri p ti on
At any point in the treatment facilities headworks at ",·h..ich
all waste tributary to the system is present
Description
At any point in tr.e outfall from the treatment facilities
between the point of discharge and the point at 'wruch all
waste tributary to that outfall is present (May be the same
.. E-ooI-O).
At any point in the disinfection facilities for waste at ..... hkh
point adequate contact \"with the disinfectant is assured.
Description
!;:!.:·~"E: ':::'~::;~;L:; LcY.~teilri"ifr_ Sand·.Point, iippiOXimaI'elY2(~Jeeteast.ot
whe"'. the. Unnamed •. lllan,made.,J ough. cOl)veying the ~~':!'!.~i~Jnl? §<i"-tl!..~·E.!~ii~~:~iy,-. ... . -
D. LAND OBSERVATIONS
Station
POl thru P-'n'
Description
Lo<.ted at the comers and midpoints of the perimeter
{enceline surrounding the treatment faclities. (A sketch of
the locations of these facilities will accompany .3ch report)
o
E. OVERFLOWS AND BY?ASSES
Station Description
OV.l thru OV·'n' Sypa.:.ses or overflows from manhole.sl p~mp stations t or
colIection systems.
F. SJ.UDCE
The discharger sha1! continue to analyze sludge pursuant to the pretreatment
requirements of Order 89:179.
IL SCHEDULE OF SAMPLING
The schedule of sampJi,'g and analysis >hall be that given in Table I, '""pt for
sludge. Sludge sampling shall follow the schedule and anzJysf's !'ped5e-d by Order
64-60. as amended.
III. lIT MARSH MONITORING
A. DESCRI1'TlON OF SAMPLING STA nONS
1. LWLUENT AND EFFLUENT
Station
E-l
Description
Located at tne marsh discharge point, and consisting
entirely of discharge from the marsh.
2. MARSH WATERS AND SEDlMENTS
Station
l-A,I-5,1-C,I-D,
l-E,t..A,2-8,2-C,
2-E,3-A
Matadero Creek
DescriptiDn
N; specified in Figure A (attached)
At the point where Matadero Creek passes ben •• th the
Eayshore Freeway
B. SCHEDULE OF SAMPLING AND ANALYSIS
The schedule of sampling and analysis shall be that given in Table 2.
2
IV. MODIFICATIONS TO PART A
Add lu Serna" G.(.e:
Include b each monthly report the following:
........... !'!'..!~ tabt.!!!ti-o!'!~ !Jf aI! d!~! -c0!!~c~e"d tf"l-_l"'Qugh the y~!r up to thp I'Ppnrt.pd
month to date fo: acute toxicity, monthly flow~ and influent and effluent metaJs
and c),anide. For metals and cyanide, include influent and effluent
concentration and mass data. On a monthly basis, report the minimum,
maximum, 95t.., pe:r:centile and average meWs and cyanide concentration vaJues
for the year, through the reported monL". Report year to date toW mass
discharged for metals "nd qanide.
I, S~eyen R. Ritchie. Executive Officer, hereby certify that the following Self
Monitoring Progr~m:
1. H~$ be~n developed in .accordance with the procedures set forth in this
Regional Board's Resolution No. 73--16 in order ~o obtain data and document
compliance \'\ith wasle ctischarge requirements established in Board Order __
2.. Has been amended and ordered by the Board on ___ .
3. May b. r"'sed Dy the Executive Officer pursuant to federal regulations (40 CFR
122.35); other revislons may be ordered by the Board.
Attachments;
Table 1
Table 2
STEVEN R. RITCHIE
Executive Offioer
figure A -m Marsh sampling site.
Part A (dated ~cember 1986)
3
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TABlEt
SCHEDULE FOR SAMPliNG, MEASUREMENTS, AND ANALYSIS (3,6)
City of Pale AIt"
ISAMPUN(;~TA1IUN A-DOl E-{)Ol E-{)oIL; I' (7) T(5) P IOV
lYPE OF SAMPLE C-24 G(2) Cont . C-2 4 G G G G 0
flow Rate (mgd) D
BOD, 5-day, 20'C W W
(mg/L&:lb/day) (1) -
Total Suspended Solids W W
(mg/L &. Ib/d,y) (!J
Chlorine Residual &. 2H or Cont.
Dosage (mg/L &: Ib/d.y)
I (4)
Oil &. Grease I M
(mgIL &. Ib/day) I
Total Coliform -----3/1'1---1 I (MPN II 00 ml)
Acute Toxicity-96 hr, W
Flow-thru (110 survival in
""diluted emuentJ
Chronic Toxicity (11) M T
I Dissolved Oxygen D
(rng/L &. % saturation)
Dissolved Sulfides 0
(mg/L if 00<5.0 mglLl
pH (units) D
Ammonia Nitrogen W
(mg/L &. Ib/eay)
Nit.-ate Nitrogen 2W .
(mg/L &db/day)
.
Nitrite Nitrogen 2W
(mglL &. lb/day)
Total Organic Nitrogen M
(mg/L &: Ib/day)
Total Phosphate M
(mg/L &. Ib/day}
Turbidi ty, N ephelometrie W
CNTUl
o
~.~ UN..,!> J A IluN A-DOl
T¥P£OFSAMPLE C-24
Aluminum (mg/kg)
!ron (mg/kg)
Manganese (mg / kg)
Arsenic M
(mg/L & Ie/day)
Cadmium 1M (mg/L & Ib/day) ,
Chromium j",j
(mg/L & Ib/day)
Copper M
(mg/t& Ib/day)
Cyanide M
(mg/L & Ib/day)
Silver r (mg/L & Ie/day)
Lead M
(mg/L &. Ib/day)
Mercury M
(mg/L &. Ib/d.y) (9)
Nickel M
(mg/L &. Ib/day)
Zinc M
(mg/L&lb/day)
Selenium M
(mgiL & Ibl day) (9)
Phenolic Compounds
(mg/L & Ib/day)
PAHs(8)
(mg/L & Ibl day)
All ap?licable Standard
Observations
B.4.2 Organic Pollutants 2/Y
(mg/L & Ib/d.y) (10)
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TABLE 1 (continued)
City of Palo Allo
£-001 L
G(2) Cont C-24 G
M
M
M
W
'W I I I
W
I 1M
M
I W
W
M
. M
Q
D
2/Y
5 (7) T15, P IVY
G G G 0
I
I
-
2/W E
TYPES OF SAMPl,ES
G =
TABLE 1 (continued)
City or Palo Alto
TIPES Of STATIONS
C-24 =
Cont.
0 =
grabsamplo
composite sa.r.1ple (24-hcu::)
continuol.ls s3..l'Ip~ng
obsen'ati'on
A = treanncnt facililj' influent station
E == waste emuenl stations
L = basin andior pond levee stations
T:; tissue sampling stations
S:: Rcciving s:d..'7lcnt sarnp:lng stations
P = treatmenl [aciHties penml:!er Statior.);
OV =. bypasses or overflows ('Urn manholes.
pump stations, or collection s)'.m:ms
FREQUENCY OF SAMPLING
E :: uch occurrence
H ::=: (mee each hour
D = once each day
\V = once each wed:
M ~ ona: e.:Jch month
Y = once each year
!\orES FOR BE! E l'
2/H =. t\I."ice per hour
2/\V -= 1 Cays per wu.k
5fW = 5 da)'s per ",eek
21M = 2 days per month
'2/Y = once in Man:h & Sept.
3/Y -= Lir:~ rim:::s per yeM
Q = QU3!"'.:rly, once each in
2H =. cvery 2 hot.lrs
2D = every 2 days
2\V::; c"/ery 2 we:ks
2M ;;; every 2 months
Cont = contint.lot.:s
Mar" )'100, Sep ... &: De:,
(1) ~trCt.u r:.mc"":!.1 (dlll:'!nt .... 5. ir.Duem) sh.!.l.t 2.lsc be n::por'.:!d.
(2) Grab sarnpl:.s s3;a!1 be clen on day(s) of compos it!: !amplLng.
(3) If any emuen! ,,,mpl: is in viobcon of IL'nil5, "c:P' L;OS: for m",,!s, cyanid!, a!'d
organics (Sectlon BA.2 of pc:.nnit), sampling sball be increased for that pa.rameter LO at kas:
dajJy d. ~a!er until compIiarlcc: is demonsuate.d in %"''0 successive samples. Recej\"U:.5
Wll!T violations shall be n::poi1ed in the montrJy ~pon; incr:.l.Sed receiving wat::r
monItoring rr:ay be: roquu-...rl. Complia.'lc! mea5u~me~ts ~pre~n[ co~p!jance s:.arws for
the. tim~ period b:t\l.'e:.n rn:'lS',.l..~!!"l.c:nts.
(4) Chlorine residual analyzer> ,hall be ealimtod against grab ,amples as freqUOl'_tly zs
necessary 10 maintai.., accurate contrOl and reliable o~ration. If an eCfluent vlolation is
detecled, grab sampks shJ.ll be taken e·w'C:ry 30 minutes uncil compliance.is achi::ve.d..
(5) TIssue sampling or MacotnIJ bal.hica 10 be done by USGS •• th: Sand Poinl Sution during
low tide, -
(6) AU now other than \0 the outfall (e,g,. sludge) shall be reponed monthly, Daily record.o
shan be kept of the quanti ry and solids conttn t of dewaterc: d s!udge dhposed of and to'"le
location of Iii sposaI,
(7) Receiving sedimen( monhoring to be done by USGS at the Sand Poirlt Station during low
tide,
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TABLE 1 (continued)
City of Palo Alto
LEGENp (cpn!in1red1
o
(8) PAH. = Polynuclear Aromatic Hydrocarbo,,_ PAHs ,hall me .. , the sum of
aeerlaphlhylem:, .anthra~ ne, 1 ,.2-bc:nzan1h.racer.e, 3,4-benzofi uoranthene,
benzo[k)fluoranthene, 1.12-ben:roperylene. be:nwfa]p),renc:, chrysene,
dibenzo[a.h]anthracene, fluorene, indeno{l ,2,3-c,d]pyrene, phenanthrene. and pyrene.
PAH analysis mu,", he done by EPA MeLood 610_ -
(SI) In addition to monthly monitoring. special s.amplmg and anaJysis studies a..'"'e fe.qu~d for
mercury and selenium p'llrS"uant to Provision £.4 of the !\PDES pennit (~n c:fr1\.,;CnI
samplts. consisting of five during weI season .a.-Iii r. ve during dry season). AnaTydcal
monitOring methods llsed (Dr the special siudy ~qllir:d by Provision E.4 must yield a
method detectil:n limil for mercu.ry that is less than or equal 10 10 ngIL. and a method
detcction limit for se!eniwn that is. less :i:.a;r! or equa.ltc 0.1 ~g.r1....
(10) Orp .• '1ic priority pollutantS and oLl,er ..:on.srin::ents lisled in S~crion B.4.1 of this NPDES
permit must be: mon:~ored on a monthly basis for six months pcrsuam 10 Provbior EA of
this permit (i.e.~ three: momhs wet .season and "lh..-ee mont.hs dry ~3son) ta c~:.!!111ine
whether any of th:-se: constl!utr.ts are ~s.enc in excess of theu-ccI"7t:spondlng dlluenl
limits. The frequency of sampling ~iU ~,"ert to 1~ice per ye3 ~2/Y), 2S i..,dlc:m:d in Tab]::
1. for constituents thaI are c:let.!.m1.ined to be :1on·d!:!::c~b!~ 0 ..... e!.! below Lir.:::.r
co~spondillg efIluenllimits. Uthe sj~ mom.~s of mon.iloring show th::.t conc::nrrations of
a specific poiluti!11! a.'"t: ne:ar or abo ... e its: efih..le:rllli ... n~L the Bo.lrd. may r:qutr: s!mpling
frtquencil.': s gn::a~r than rv. ·ice per y~aL
(11} Whi]::: L~e d.i~h:!.fger is conducting il.S TIE/iRE srud)'. ef:luer.! d-..ronic toxicit), monitoring
';I.:i11 be tv.·ice per year (2!Y). once during t.'1e wet se3.son i!Jld once dt.<Jing the dry se.:l.son.
Upon completion of th= TIE/TRE srudy, morumrmg will rev-:n 10 the fr:-quer:cy ii1d.icat.:d
in Table I. ehr ~nic toxicity moniloring is 10 be carried aul on the specits de!!rmine.d by
the TIE stud:.! as the most appropriately sensitive test org:mism. See Order 92-1~
(anached) for monitoring and r::porting n;quU-CmenIs.
Afer at leasr "[\a.·el ... e test TOl!IlCs. l.l1e discharger may r:quest tl';t Executive OrTiC1::T to
dccrt:as:: th:. requirt:d fr:qu-:nc)' of chronic toxiciTY tesnl""lg. and/or to reduce t.l-Je ntdTlber of
compliance s;x;cies to om::. SL:ch a request rna)' be made only ift-ox..iciry eKceeding the: TIle
values specified in the effiucnllimitatior.;s was nC:\'eT observed using thar test species.
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Al"1o:'1'IlC lltS1L1 (5)
Clvoml'llm (u,ILJ (5)
i'h~noJ:s (11,& IL)
~JrNum (Ug7u (5;
:' .... HI· EPA Mtlho:j' 610
i\Jg/U
Orf;.lNC.M Me-~llll: Pnor
:!'Y PeDUUil"l1S (mgfl)
7)7E5 or SAWlli
G • gr.b wmfle
C·2" • COJ'll':inuou:s umplt (201 hour)
Cor.! .• C'QntinLl~.u 50Impling
o II: Q:t~~., non
FootnOte:
I--2W
2W
2W ,W
2W
2W
2W
2W
2Vl
2W
, ....
I 1'.'
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SA!>O'UNG fKEQUENCY
D. on;t u~ d.y
W • ooC't ucn ""ft~
...,. cnoC"t' uch rnonlh
M
M
M
M
M
M
M
M
M
M
O· q\ololrtmy. 11'1 Mu .• ]UTI~. Sci'! , and ~.
lW • ~ w:ry ""0 Wftlr..s
3fW -= thtC"fwmpln por Wftk
"r' • Dr.~ r .. ~h .re' r
O} MtlSUrtSUlO1.Ild Or m"de in the 1M .(te:rnoon. WN-n pH.r.d Imrnot'lll to .. [~ry ITt.1 wir rNllmum
Q) Musumshould b( nv.de w;tNn an hour 01 dawn., ""'h-en -dl!",1~ oxytm YI1ue1I~'! Ihe-lf
Io\lltsllrvds...
01 Whth" -<SI)" ver.,te mttJils mtlS\:l re ttteed the D\l:ljmjm lnnuCTlI values to the-I"NI rsh,
~I:ori"& wiD be-incn-oIJed 10 'bi.rnonthly u1"l,,1 ~worJ ... dt'CI"U.Jt.
tot} Monlhly znttollts monitoring.m.ly be done .1 eil"~ Jtlnon :.I!I or 2· Ito fulfW !.hi, ~ulrtmC'nt
Gl Method' dtltdion rimits I~ 2f'oI,rsJ, MtnptC'S iNn bc-I'W) Sftalrr lhan thov uN'd
in Icstin& enatmml pLlni etOUe1\l.
(61 al'I.ppbablr JUndolrd obtcTvatiOtlJo, l:ncludin, r.iNan
~.,~, .::"1
1 1~"~\'\ ~
~ "l·n-~~
" ; \ .
, ' 2·C •
'. , .,
'.
, '.j.~ '·:U.I1'Y P '\"
j.~..... I:" 1-D%~ . . ~, I _~.~~--~ ...... ~-~-/ ... ~ ... _ 1/ .... __ ~-... -.. ~-.-. t·E· / ,
. -------: .,
·~-II·I'A. ''\ / f/M~/~Ct
I ;( 1·0 ·,AUH",.m X/r) /_.~ i / ,MAnS"
, •
I /' /~:/.,,,,, / 1/ --~ //.i?~Q~
I • '.D , •..... :~/ " .,z.~
, , .... -"'" ..... ;:-//.'1' ~
I ~ / •• ' 0"',1' ", ,.\! • ." .::., /.',,'1/ , 'I ". .':' //,:<~., '/ ." // /,. ... . , ,,-."'./'" .... ,{.; .... .
I . .,_ '.:/ .'" ·l,'
, " ........ ,.-",:. /1' I . . • . ,.,.., .. ; . . ,_....... ".~ ,..... ,.,' .I': ,,0 "
'''-••• , ,.:1' {/.// . ...... ~~ ~ ~ ...".... .. ' // ". / .• .,,-' .,..' /..r,,/'.. " ---...---. ,.' , ..
~f'IIt01 .. 'e&ll ,. P. 0
t::'I :
.. f1 '" tot
rlGUltE 1\ • ',IT MAltS!! SAMI'UNG SITES
(I'~r' V, Scll·Molli'Ofinr. rr"r.I~m. ITf M~"h. Q"lrr '11· )
.,' I,'
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ATrAOiIIEl'IT 3
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
TENTATIVE ORDER NO. 93·
CITY OF FALO ALTO
PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT
PALO ALTO
SANTA CLARA COUNTY
R!OCEIIIED
J If'l ~ .~ 1953
WAr::::; ')UA.liTY
·::::JNTROL ?~A.~
REOUIRING THE CITY OF PALO ALTO TO CEASE AND DESIST DISCHARGING WASTE
CONTRAlIY TO DISCHARGE PROHI81TIONS IN ORDER NO. 93-_IN?DES PERMITI
The California Regional Water Quality COr"ltrol Board, San Francis-co B2I)' Region (herei:i.:~rher
caHed t~e Board) finds. that;
1. On July 21,1993, the Board adopted Order No. 93·_ [NPDES Permit
CAOO37834l presctibing waste discharge requiremer'hs 10r 'the City of Pa.te Alto
Ihereinafter the dischargerJ.
2. The discharger opeH~es a waler pol!utiol"! controi plant located at 2501
Embarcadero\) Way. Palo Alto. In 1991. the piant discharged 20.1 mgd Id!ily
averagl;-) of treated wUlewater effluent into an unnamed channel tributary tv South
S~n Francisco Bay.
3. Frior to adoption of Order No. 93-_. the dis.charger wu sIJbjec1. to NPOES Permit
CA0037834 {Order No. 8S-175, adopted Oecember 21. 19Se, which was amended
by the fcl!owitl9 orders: -Order 90-034. 3dopteo February 2'. , 990; Order 90-0-69
ad'O,Ptec:f Moy 16, 1990; and, Order 91--068. adopted Ap,iT 17, -; 991 I.
4, Order 91..Q68~ adopfed en ApriJ 17, 1991, revised the discharg3r's NPDES permit
10 include water quality based effiuent Gmits. Between Ma)l 1991 and AU9ust
199.2. the cfoscharge!'r had significant viDlations of treir N?DES permit for e)(ceed'ing
the 1~day average e1fluen't flmits for the fol\owtng consti\'.len1S:
Constitue ni:
Copper
N'"teke!
Order 91-068
Eff!uent Umns ug/1
2.9
8.3
# Violations
701100%1
5 (7%1
5. Between May 1991 and A.ugust 1992. the discharger had minor violation~ of 'the
effluent rrmitations fer. $i1vl:!r (1 violatro"l. arsenic [3 ..... iolationst cyanide [l
violati.on) selenium t2 vioia1itmsl. and zinc (19 violations). The discharger had twC
zinc violations between January 1992 and May 1993. The remaining 17 tine
violations occlJrred between May end Deci!lmber 1991.
6. Res.ults. of ambtl!;nt monitoring conducted by "the Sooth Bay dischargers between
1989 and 1991 showed [hat both tota.r and dissolved concentrations of mercury
frequen.tly exceeded the wa.ter quality objective of 0.025 ugfl. The e~ceedances
_____________ c __ __
~ :
7.
8.
9.
/.
o o
occurred at all station.s. The Santa Clara Valle." Nonpoint Source Program has
begun investigating potential sources of mercury in I"ur.otf. Tl"le measurement of
merc-~ry concentrations in ef1luent at the levels of the efnueOlt limitations and
receiving weter obje~tjves reoquires advanced methods which are nc~ ,Qutinely used
making compliance determination difficult. However. the multiple potential SOt.lrces
of mercury in POTW waste 5tte~ms. th!! low level of the effluent [imitations. and
the high rate cf discharge by the d1sche.rgers into the South Bay, leao' to the
conclusion thi!t the discharger is likely to exceed the effluent fimitation and to
significantly contribute to exceedanees of the water Quality objective.
Order No, 93--, revised the discharger's existing effluent limits (or copper and
cyanide_ On October 21,1992, the Regional Board adopted a site-specific
objective in San Francisco Bay and a shanow water marine effluent limit for copper
of 4.9 ugll. On September 16, 1992. the Regional Soard adopted al'1 emuent limit
for cyanide of 5 ug(t.
ff the 4.9 ugn effluent limitation for copper had beer. in effect between May 1991
.and Aug\Js! 1992. 1he discharger would still have been in. violation 100% of the
tim~. Between May 1991 and August' 992, the discharger's detection ~jmh fDr
cyarlide, 10 ug/!, was greater than the new effluent limit of 5 ugll. The discharger
recorded 7 values greater tharl 10 ugJl and therefore at a minimum would have
violated the new effluent limit 7 times.
Based on the past data from May' 991 through August i 9;2, it: ;5 anticipated that
the discharger wiii immediately be out of compiiar'lce wit" Provision 8_4.1 {limits
lor Toxic PolTutantsJ of Order 93,_ fOf copper, nickei, zinc. and cyanide. It IS also
anticipated that the discharger thrutens to violate the effluent limitation tor
men;urv·
10. On Jcne i6, 1993, the Board adopted Resolution 93-6T specifying a waste load
anocation for S::lurces of copper which enter San Francisco Bay. Based on tMe
waste load allocation, Provision 8.5 of Order 93· requires. the discharger to
discharge no more than 120 Ibs/yeer of copper. ~addition. the discharger aiong
with the two other So'Jth Bay POTWs ar-,d [he Santa Clara Va!ley Non~oint Source
ponutlon Control Program are rtlquirsd to reduce [heir combined discharge of copper
into South BaV by an additional 950 pounds per )lear, to be ac:comp'ishe~ by 1998.
In 1992. the discharger discharged 755 rbs of copper. Tnetefore, it I:> amicipated
that the discharger threatens to viotale Provision B.5 (mass timita.tron fer capper) 01
Order 93,_.
11. In June 1989. EPA designated San Francisco Bay below the Dumbarton Bridge as
an \mpaired water body under Section 304(1) of the C\ean Water Ac'L There was
evidence of willer quarrty impacts in the South BaV associated with seven metals:
cadmium. copper, lead, mercury, nic);,er, selenium. and snver. The three municipar
plants and storm water discharges in the South BitV were designated 85 point
sourc.es contn'bLl1ing to this impairment. Section 30411) requires States. to adopt
Individual Controf Strategies for designated point source discharges thi!lt wit! result
in attainment of objectives for tOKtC-pollutants within three years. EKceedances of
witer qualrty objectives for COppet, mercury. and nicker still occur.
2
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12. O:-der No. 88·17&. adopted Oe~embel 2', '98B. requited the discha:ger to ider'ltrty
3" significant controllable sources 01 metals and to determine feas,ble measures to
redl.1ce t1'Ie'metefs loadings to the treatment plant. On October 1, ~ 989. the
dist:harger submitted the Meufs Source Identification Study 10r tne Palo Alto
Regional Water Quality Control Plant. On Dect!mber 1, 1989, the discharger
submine-d the Waste Minimization Study.
13, Order No. 90-069, adopted May' 6, ~ 990, r~qlJjred the discharger to make pre~
treatment program improvements, to implement a p;iot waste minimization
program. ~nd 10 require targeted Industries to submit waste minimization plans.
Tne discharger submined i! progress report for the SOL/rce reduction program orr
December 16 1990 and a Sta1us report for the Source Reduction Program on
August 1. 1991.
14. 1he pre-treatment program impro'Vemef'tts included expanding flow monitorirlg for
targeted industries. regulating auto-repair and photoproc:essii";$J firms. and
imprementing more Bg!jress1ve enforcemf"i'lt a::::tior'ls a~ajn5t violators. The
discnargf;!r S'uccessfufiv initiated Bnd continu~s to impfement t.hese pre.·trealr."lem
program improvements.
15. The dischat'ger's pilot waste minimizat~on and public education program was
targeted at reducing silver discharges 10 thE treatment plant. The pilot program
was directed towards commercial ilnd ;ndustJial photo-processcors. x-ray labs, and
other potl!'ntia:1 silver dischargers. Tl'le discharger implemented a very successful
pre>gram. The average silver influent concentration decreased 63% durin.g the
period prior to implementation of the pilot progfam 1;'1 1990 until 1992. Average
effluent concemrations of siTver have also been reduced by approximately 7&%
since the init["tion of the pnot program. Prior to 1990. the discharger rO\J1ineiy
exceeded 2.3 ugl1. the current e1fiuent limitation. In 1992. the discharger "as not
had any violations 01 the silver efiluem fimiL
16. The dischergt, initiated the "Clean Say Business" program in which vehicle service
fiteilities receive an award for successful imploementarion of Be'S! Management
Practices (BMPs) which result in zero discharge to the sanitary sewer. As of
November i 992. 13 i facilities ;"ad been designated as a "Clear. Bay Business,"
17. The disc~arge! has reC::IF,Jlred waste minimization plans from 28 industries who nave
high metal concentrations in their discharge. The plans address product
$ubstrtuticn, ptocess changes, water \Jse reduction, in-;,Iant reuse. recycling and
enhanced wastewater treatment. Implementation of the plans are vofuntary.
18. By August 31. T992, an the communities served by the dischi!l~ger had adopted
ordinances banning t"'e use of copper·based root control age ins which are typically
25 percent pure copper, by weight. The discharger estimat!!:s that copper·based
root contror agents. could contribute approximat~ry 20 pounds of copper to tneir
effluent per year.
19. Most of ~he discharger's service area receives their water supply from sources
managed bV the San Francisco Welter Department. The San FranciSCO Water
Department added approximately 62.000 pounds of copper sulfate pentahydrale 10
•
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th~ water supply reservoirs for algae contr~ in T 991 .
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20, On August 28. 1 9S12. tl'le Board issued a "Request for lnfcrmation and. a Proposed
Strategy to Reduce Copper and Selenium in South Bay Drinking Water SOutCe5~ 'to
tl'la d(schilrgers, water districutors and re-taiters in the South Bay. A steering
committee representing the affected parties was formed and a joint monitoring
proposar was submitted on November 2. 1932.
21. The discharger optlrates an approved pretreatmen1 program with local discharge
[imilS for non-domestic users of the collection system. The discharger adopted
local limits for its users in the late 19705. In 1991, the discl'larger adopted stricter
local rimfts for silver 81"1d zinc.
22. On January 19, 1993. the discharger signed' an agreement with Clean South Bay, a
coafltion of environmental groups, concerning the source control program for the
RWOCP. The discharger has submitted this agreement te the Board to achieve
compliance with their NPOES permit requirements. The agreement includes source
contror measures to reduce thp' concentration and mass of metals in their ~nfluent.
The proposal c:ddrBsse5 contributions from the industriar. resideraia!, commercial
and Water supply sources. The compliance proposal hat: been inc-orporaled into this
Order as Attachment 1. Anac!1ment 2 of this Order specifies addit;ol1al source
comror requirements.
23. Section 13301 of 1he Califot:1ia Waler Code authorizt:!S the Regionar Board to issue
a Cease Clnd Desist Order when it finds that a waste discharge is taking place or
threatening to take place in yiolation of the Board's prescribed :--eQuiremer"lts.
24. This-action is an cuder to enforce waste dischargt. .~quiremems adopted bV the
Board and is categor~8ny exemp1 from CEOA pursuant to Section 15321 of the
Resources Agency Guidelines.
25. T!'l.e Qtschar.ger and' mteresteo persons have been notified of the Board"s intent to
ad!lpt t..'"Ie enforcement order, and have been provided with the opportwnity for a
public hearing and the opportunity to submit their wri1ten views and
recommendations. The Board, in a public meeting, heard and consideted an
c.omments pe-nain.ing 'to the discharge.
IT IS HEREBY ORDERED THAT, the Discharger shan cease and de.s·ist from violating waste
dlscharge reQuuementa contained in Order No. 93-_ as follows:
1. Compliance with effluent fimftation B.4.1 of Order 93-_ for copper shan be
achit.wed y, accordance with the time schedules and interim measures described in
Anachment 1 and 2 which is incorpora1ed herein and made a part of 1his Order.
Fun Compliance with the c:opper effluent riml1 shan be achieved by July 21.
1998,lI1131
2. Compflance with mass timi1.s 8.5 of Order 93-_ 10r copyl!'r shall be achieved in
8ccordance with the time schedule below and implementation of interim measures
described fn Attachments 1 and 2. Fun compflance with the mass effluent limit for
4
copper sh~1I b~ achieved by December 31, 1994.(21[3)
Note:
(11
(21
/31
According to the Basin Plan, afrer a waste-load ailocation {for copperJ is
implememed in permits and load reductions consistent with that anocatlon
are occurring, t!"le Board will reevaluate the etfluent concentration ~mitatio~
fa( copper.
Mass loadings are to be calculated week!y using average weekly flow daIa.
The discharger shltll submit a cumulative total of mass loadings for the
preyious twelve months with each Self Monitoring Report. Compliance shall
be determined based on the previous twelve months of monitoring and shaH
be calculltted weekly.
If in the proce.s:s of 8ttaining these limits, the discharger determines that
measures lequired to attain these fimits v-.ould result ill substantIal and
wtdespread economic and social impac..t, the discharger may pe!itiOn the
Board to reevaluate these limits.
3. Compliance with effluent limitation El.4.1 of Order 93· for nickel shari be
achieved in a:::cordani:e with the time SChedules and interim measures described in
Attachment 1. Full Compliance with the nickel effluent limit shall be achievej by
Apr, 11, ~ 996.
The discharger shaM ,:omply forthWith with Ihe fotlowing interim r'mit. The irlterirr..
limit IS derived from the 95th percentile plant performance concentra:.ions dwring
the period between January 1992 and May 1993.
Con5tituen:~ Interim Limitfuglil
Nickel 8.9, 4-day average
I, Steven FL Hitchie, EXzl"'U'f:ive Officer, de hereby certify that the foregoing is a full. true,
and correct COPy of an Order adopted by the California Regional Water Quality Contro~
Board, San Francisco Bay Region. on
5
STEVEN R. RITCHIE
Exe~L1t:ve Officer
o
ATTACHMENT 1
'.
EXHIBIT B
SOURCE CONTROL PROGRAM
OF TIlE
PALO ALTO REGIONAL WAlER QUAUTY CONTROL PLANr
TABLE OF CONTEN"TS
L
II.
rntroduc:tion
Gen~ral (Non·Source Specific) Acli'titics
A
S.
e.
$Ollrce Id:ntincation
Loca! Limits
Removal Efficiency
III. fndl.lstria! Sector
A
B.
e.
V'/ii!:5tc Minimization .
Discharge InfonnalioD
lnCelllives for PCD1.Jtanl Reduction
IV. Resid:ntia1 Sector
v.
A
S.
e.
General Pubiil:: Education
'·PoinH::.f·$alc" (Retail) Program
Search for Re.s-id::ntial SOLlrce.s
Commercial Sector
A
B.
C.
D.
E.
F.
Pholo!X-ray
Vehicle Service
Laboratories
M. chin e Shops
Hospi.als
Cooling Towers
VL Water Supply
Pag~
2
2
1
3
7
8
8
8
8
9
9
9
9
10
30
10
II
II
12
12
12
Page I of ]3
Source Control Program
of the
Palo Alto Regional Water Quality Control Plant
1. Introd uction
The activities outlined in this document are being conducted by the City
of Palo Alto and its partner communiti" within the service area of the
Regional Water Quality Control Plant (RWQCP) to reduce pollutant
diScharges to the' sanitary sewer. Palo Alto has studied' Dr v.'iU study
facilities accounting for 85% of the discharges of cc'l'per and nickel and
will be able to identify appmpriate cost-effective measures for reducing
those discharges.
II. General (Non-Source Specific) Activities
A Source Jdentification
1. Refine general facility data concerning photo shops, printers,
x-ray facilities, vehicle service radii ties, machine shops and
laboratories in the Source Control Management data base:
2. Annually check City and other data bases ane! utilize mail
Paso 2 of 13
surveys to locate new industrial and commercial sources.
3. In each calendar year, issue permits to thO's. facilities found
to have a manufacturing prxess producing a waste stream
containing cepper or nickel during the preceding calendar
year.
4. Anr.ually, recalculate cepper and nickel poliutant
centnbutiens by Secter (residemial. commercial and
industrial~ This will be based, in part, en centinuing
residential and industrial sampling and will be submitted at
the same ti~e as th' february Annual Pretrea"iment ReporL
The first sudl reporl shall be due February 1994.
5. Centinue te search for previously unidentified chemical
products. practices and activities which contnbute copper,
nickel, zinc, lead, cadmium, selenium, silver, cyanide or
mer;ury to the Bay.
B. Local Limits
1. Pale Alte agrees te acquire sufficient infermation, te enable
it to adopt lawfuDy by September 30, 1994, Local Limits
which will at a minimum achieve maximum feasible
reductions for copper and nickel on an expedi:ious time
scheaule, sO as to achieve compliance with Dischilrger's
Permit, and such Local Limits shall take effe~t no later than
October 31, 1994 and shall be incorporated in10 individual
control mechanisms by January 3D, 1995. Palo Aha will
comply with aU state, local and federal requirements
inCluding but not limited to notice and hearing procedures
for the adoption and implementation of pretreatment
requirements. The Local Limits may be in the form of an
. -
amendment in the Palo Alto M unicipar Code (and
corresponding Codes of other jurisdictions in the service
area) and shall be.composed of at least three pam;
(1) Concentration limits
(2) Mass Limits
(3) Mandatory Pollution Prevention Measures which
at a minimum shall cover Metal Finishing and
Printed Circuit Board facilities.
2. For purposes of the establishment of the I..ncal Limits
referred to in the preceding paragraph:
Pase 4 of lJ
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I a. The information referred to in the preceding
paragraph shall include at II minimllm, 6Dc Pilot
PoUution Prevention Studies (Audits), which shrJI
include review of reductions in the range of 90% to
100% of the amount of copper and nickel and shall
determine which copper and nickel waste minimization
measures or group of measures, includi:\g source
reduction and enhanced treatment necessary to
facilitate in-plant recycling, are co~t effective using a
range of interest rates between %ero and nine percent
.... ith an assumed payback period of five years.
b. As used herein a "maximum feasible red1JctioD" is one
which would be cost-effecti\'e for the industrial
discharger, calculafd at the prevailing iDterest rate
and with an assllmed payback of S years, and wOllld
result in the 5Jl'Iallest pollutant discharge. However, in
the event thet either DISCHARGER or CLEAN
Page 5 of 13
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believes that a different payback period should be
used, based on information generated in the process of
. developin~ the Local Limits, the parties agree to
negotiate in good faith to determine whet!!.r theyean
agree on a different payback period, as an amendment
to this requirement
c. PalO Alto recognizes thaI the formulation and
adoption of Local Limits wiil depend, in part, upon the
results of studies not yet completed, as ... ·eil as other
'~vidence which may be presented during the process
of fonnulating local limits. Accordingly, Palo Alto
retains [he. right and obligation 10 exercise its
discretion and judgment on the basis of such
information, induding specifically the right to modify
the Local Limits to meet legal prerequisites for the
lawful adoption of such Local Limits. By Ibis
provision, Palo Alto specificalJy intends to retain
sufficient tlexibiliry in the exercise of its judgment and
discretion to meet the requirements for adoption of
I'age 6 of 13
.;.;.
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! lawful Local Limits. This provision does not alter in
any manner Palo Alto's uhligation to acquire sufficient
information to enable it to lawfully adopt Local Limits
which will at a minimum achieve maximum feasible
reductions for copper and nickel. However. this
prOvision is intended· to allow Palo Alto to avoid
prejudgment of any decision for which notice and an
opportunity to be heard is required by Jaw.
3. Palo Alto further agrees that by September 30, 1994. it "ill
consider and, as aFpropriate in its discretion, develop the
following:
a. Other methods for achieving reductions that represent
substantial opportunities for source reductions,
including financial incentives Of changes in rate
.tructures.
C. Removal Efficien cy
Continue evaluation of Regional Water Quality Control Plant
processes, identify and implement operational and minor capital
Changes which can improve the copper removal efficiency "ithout
Pase 7 of n
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adversely impacting other aspects Df plant performance. The focils
for FY 1992-93 shall be the dual media filter operatiDn.
TIl. Industrial Sector
A Waste Minimization
1. Utilize the annual inspection process at the 28 facilities
which completed Waste Minimization Studies to review
progress and negoriate further commitments.
B. Discharge Information
Continue to require upgraded ilow monitating and increased
frequency of metals monitoring and complete" current permit
reissuance cycle in FY 1992-93.
C. Incentives for Pollutam Reouc!ion
1. In FY 92-93 begin to assess sewer fees based upon the moss
of at least copper and nickel discharged to the sanitary sewer
frDm industrial facilities.
2. Continue aggressive enforcement.
3. Assist industry in recognizing cost savings of waste and water
use reductions.
~
IV. Residential Sector
A. General Public Education
Use the following mechanisms to encourage residents to red"ce
the discharge of toxics ,0 th~ sanitary sewer:
1. Fact sheets, brochures
2. U till!"1 bill inserts
3. Newspaper adds/press releases
4. RWQCP tours
5. Visits to schools
6. Doorknob hangers "
B. "Point·of-Sale" (Re!ail) Program
1. Reoistnbute photo prOcessing Iitera!llre te-chemical supply
stores and photo shops.
2. Distnbute copper-based root control literature to hardware
an d similar stores.
3. Develop delive!)" systems to retailers jointly with lhe County
and consider recognition program for cooperating retailers.
C. Search for Residential Sources
1. Track EPA-funded Centra! Contra Costa Sanita!)" Dist:ic!
,
I
"
(CCCSO) study of residential sources and similar efforts
elsewhere. Advise, assist and look for opportunities to
augment
v. Commercia! Sector
Permits and Best Management Practices issued in the commercial
sector shall assure at a minimum the maximum extent practicable
reduction of pollutant discharges, including where practical
requiring zero discharge for rhese pollutants, to the City's RegiQ!"!21
Water Quality Control Plant, based on the information available.
A· Pholo!X-ray
1. Continue to enforce the Palo Alto Municipal Code Sewer
Use Ordinance,.which prohibits the discharge of spent
photographic solutions to the sewer if the limitations in the
ordinance are exceeded.
2, Provide assistance and information [0 small businesses
L;rough brochures, workshops, mailings and newsletters.
B. Vehicle Service
1. Administ!'r a program (the "Qean Bay Business" Program)
which recognizes vehicJe service facilities which comply ";lh
Pago JO of 13
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the Palo Alto Municipal Code provision. affecting Vehicle
Service Facilities.
<" 2 ~ By July 1, 1993, issue permits tQ those Vehicle Service
"1
1
Facilities electing to maintain a discharge to the sanitary
sewer.
3. Enforce ordinance requirements.
C. Laboratories
Deyelop a wall poster, a training brOChure and a checklist
containing Bes: Management Practices for laboratory facllities .
. . .
, Distnbute tbese materials by March 1, 1993, to labOratories within
the service area of the Regionai Water Qualli)' Control Plant, and
consider other measure~ besides education.
D. Machine Shops
1. Develop Bes! Management Practices for Machine Shops by
July 1, 1993.
2 Form a new subcommiltee of the Palo Alto Metals Advisory
Group and seek input from industry and environmental
groups during the formulation of Best Management
Practices.
'~.
3. By October 1, 1993, issue permits to those machine shops
not previously permitted which elect to discha.ge a
wastestream containing pollutants of coneern to the sanitary
sewer~
E. H Dspitais
1. Develop Best Management Practices for hospitals by
September 1, 1993, based in part on a waste minimization
review of a hospital, designed to quantify all sources of
copper and nickel and based also on information obtained in
ongoing inspections by the Plant of oth~r hospitals.
2 Fonn a new subcommittee of the Palo Alto Metals Advisory
Group and seek input from hospitals and environmental
groups during the formulation of Best Management
practices.
F. Cooiing Towers
1. Develop Best Management Practices for cooling towers by
Apnl I, 1993, and distribute to businesses and institutions.
VI. Water Supply
A Palo Alto shall implement source reduction measures compatible
Page 12 ern
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with the "Request for Information and a Proposed Strategy to
Reduce Copper and Selenium in South B!y Drinking Water
Sources" issued on August 28, 1992, by the Regional Water Quality
Control Board (Att!chment 1), or with such further directives as
may be issued by th e Board.
Exhibit B (1/11/93) Pase 13 of 13
:/ ,
Anact,ment 2, Order No. 93-
Palo Alto Rwacp
'. 'l
Tne foliolNiJ1g measures al-ong with Attachment 1 are d~sig~ed to achieve compliC'nce with
the discharger's NPDES permit IEffJuent concentration and mas.s limits B.4. 1 arid B.51. All
measure~ are req~ired to be continued until the discharger full., compiies ~"'it'" those
provisions. The Board will d.ecide whicn meuures should be continued beyond t."tat date.
1. LOCAL LIMITS
A. lGCaf limits Developmeril
1. The discharger snarl submit a report, acceptable to the Execl..!tive
Officer. of the analysis of the pollutants which are of concer" to
treatment p:ant operations. The d~terminaticn Df poflutams cf
concern shall inclUde screening of in1'ueot, effluent. and sludge data
to de:ermine· poltutants revels wnich have the potential to cause
problems ca~ed on worker heafth and safely requirements. sludge
requiremems. ;r;hfbition and pit5!-tnrough. The p·:;JfJutarlts determined
to be of concern must be compared to those pollula.''lts which tne
disr.harger currently reg'UJates. The r~port shall also include a plan for
addressing the factorS invotved in the development ot the kica! limits
a:"Id shall provide de-uns of ad'ditional sampling which wi!! need to be
performed. instanc:e5 where data may b-e needed in order to provide
the technicaf basi!i for justifying localllmiis include: total vs. total
recoverabfe effluent concentration limits; 1reatmeilt plant ejllciencies;
data on commercial, industrral, residential, and water supply
contribution.
Report Due: July 30, 1993
2. The dischar9a~ shari submit a repoM:, acceptabfe to the Executive
Officer, of the maximum ponutar.t foadings to the trutment pla.1t
whic'" wilr enable tnt treatment plant to mee ... NPDES effluent
limitations. This anal",·s;s will consist of it calculation of treatment
p!ant removal efficiencies. The report will provide sufficient
documentatio;'l ot the resid'entiat contribution to justify the amou~t of
loadiog which is a .... ailable to the industriai and commerciai users. Tne
report shan also descrfbe any actions which will be taken to lower
contributions from domestic or water supply sources. The calculation
of the loading which remains 10r allocation to the non~domestic
sources shall also be included in the report.
Repon Due; October 1, 1993
3. The discharger shan submit OJ repOl1, IIcceptable to the Exec-utive
Officer, describing the method for determining Joading eJlocaticn for
each non-domestic user. The allocation Shall incfude an analysis of
methods such as indUSlital contribtJtory limits, mus-based rimits,
concentration limits, and a required percemage reduction of
., ~.
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polh.nants. Data shen be provided on the industriaf and commercia!
users to justify the methodology of required reductjo!)s.
Report Due; January 1, 1994
4. The di.icl1:arger shen submit a report, acceptable 10 the Executive
Officer, propos~ng the fioa' loc~1 limits for industrfaf and commercial
users which win enable the discharger to meet the NPDE:S effluent
nmns. The report shall also contain the results of the pilot ponution
prevention studies (auditsl.
Report Due: April 1, 1894
5. The discharger shall adopt local limits. as approved bV tht! Executi\le
Officer, which will enable the discharge to meet the NPDES effluent
rimits. At a minimum, the rim its will achieve maximum feasible
reductions' for ccpper and nicio~r on an expeditious time schedule. so
as to achieve compliance with the ois.cha:rgeI's NPDES permit. The-··
locallim[ts shalt be composed of at least three parts:
(1) Concenuation Limits
(2} Mess Limits
f3j Mandatory Pollution Plevention Measures which iIlt a
minimum shall cover Metal Finishing and Printed Circuit
Board facilities,
If any other municipal discharger within the San Francisco Bay Reaion
requires. companies within its jurisdiction to implement ill ~ost
effective measure that is appricable to iOOL'stries in the dischargeI's
area, the discharger sha~ present the measure for consideration as a
manaatory poltutton prevention measure.
Adoption Date: September 30, 1994
Effective Date of Ordinance: October 31. 1994
Maximum feasible reduction is one which would be cost·effective for the
industrial discru.rger ~ calculated at the ptevalfing interest fate and whh an
assumed payback of 5 years, and would result in the smeUest pOnUlltMt
cfJScharge. Use of I different payback period may be required, based on
information generated i.n the process of devetoping the Local limits jf agreed
upon by the Executive Officer.
2
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6. The discharger shall incorporate local limits in the individual comrol
mec~lanisms tor each industrial or commercial user. These limils shalJ
be based on the places!: approved by the Regional BDard.
Jncolporation Date: Januar-p' 30. 1995
", WATE-~ SUPPLY
A P:J(suant to the "Request tor Information ar.d a Proposed Strategy to Reduce
Copper and Selenium in South Bay Drinking Water Sources" submit a joint
report generated from the steering committee, which includes mcnil0rir1g
resurts of drinking water scurces and II proposal for immediate aC'Bons that
can be taken te reduce copper inputs to the water suppry, Tl"le proposal
shall inc!ude an e .... aluation of fe-due in; andior eliminating the ~ddition ot
copper sulfate into drinking wat~r sources as an immedia:e action.
Report Due: Janu3:ry 15.1994
B. Commence impfementation of immediate actions, as approved by the
Exe cutive 0 ffie e r .
Commef'cement Date: Apru i 5, 1994
c. Submit a proposal for apprc .... aJ by the Executive Officer tor long term actions
and ill proposed implementation schedure that can be taken to reduce copper
inputs to the water supply, Tne proposal shan fnclude an e\laluatiol1 of the
results of the Santa Ciara VatJey Water District corrosion inhibitof stud)'.
Report Due: July 1, i 994
D. Submit a status report in Pretreatment Annur:!1 Report
Status Report Due: February 28, 1994
1II, PILOT WASTE MINIMIZATION PROGRAM FOR MERCURY
L If monitorfn; results submitted pursuant to Provision E.5,1 of Ordp,r 93-
indicate that mercury effluent concentrations ltXceed the e1flLJ~nt limitation,
the discharger snair develop a piJot waste minimization program fO( mercury
for approval by the Executive Officer. The program s.houfd be done in
coordination with San Jose, SunnYV3'e, and the Bay Area Waste
Minimization Group.
Submit Proposal: OClober 1. 1993
2. Begin implementation of the pilot waste minimization program for mercury, jf
required, according to the proposal approved by the Executive Officer.
3
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Implementation Date; January 1, 1994
.-.
3. Complete pilot waste minimization program for mercur)l.
Compl!!ttion Date: January 1. i995
IV. COORDINATION WITH SAIIIT A CLARA VALLEY NON·POINT SOURCE CONTROL
PROGRAM
The discharger shan coordinate w3ste minimization/source control acti .... ities with
the Santa Clara Yaney Non Poil1t Source Pollution Control Program in order 10
increase overaJr effeGtivenes5 of con1!oriing f'leavy metal discharges to th~ So LIth
Bey. Coordination should include. bo.Jt not be limited to the toi"lowing areas: SOiJrce
identification, inicit connection elimrnation to stcimwaler drajn:s. industrial discharge
runoff identification and control programs, and public: inform .. tion and participation
programs.
V. MONITORING AND EVALUATION
1. The discharger shJri provide on~gojng traCking of influent. sludge. and
eifJuent revels to determinl!:! the reduction or polll..'tanrs and show the
effectiveness of the revised local limits and other waste minimizatiorl
activities intended 10 reduce treetmet"lt plant foadings.
The discharger shall incfude this summary of reductions to influent. and
effluent 108din95. and sludge metal concentrations end status oi compliance
with the mass and toracentration effh.!ent limits contained in This Order as
part of the Annual PreO'estment Report.
2. Annuany. re(;a!culate Gopper and nickel pollutant contributions by the
fonowing sectors: residential, commercial, industrial, water supply. tnclude
an evaluat10n of the eHectjven~ss of the waste minimization measure:; at
achievlng reductions.
Vl. REPORTING REOUIREMENTS
1. The dischar;er shall include in the pretreatment annual report, required by
Order No. 69·179 (Pretreatment Amendments}: .
o the status, progress, eVililuation, results and any written products of
all of tne ebove program areas.
o reasons for any delays or potential delays in completion of any of the
tasks. together with proposed remed;~s for the delays 5hail be
fncluded.
o tI proposal for the following year's work program to achieve the mass
.a~ concentration fimitS" including budget iH'Id staffing.
4
o
o t~e pre ... Jou$ year's budget and stsHmg to accomplish the
pretreatme.'11/wB!te-minimization program.
2. The di.schsIQe-r shal' include in the second q ... arterly report a britf Status
report on an 01 the above-program areas.
5
', .. .:"