casey claborn san jose water company -...
TRANSCRIPT
Casey Claborn
San Jose Water Company
Discharges covered by this permit Requirements of the new state permit ◦ Notification (pre- and post-discharge) ◦ BMP Implementation ◦ Monitoring ◦ Record Keeping/Reporting
SJWC’s experiences so far
State-wide permit first proposed for adoption in 1996 but was not adopted
In Region 2 (San Francisco Bay) drinking water systems have been discharging under the Municipal Regional Stormwater Permit (MRP) issued to MS4 Operators
Drinking water systems that did not operate an MS4 were not permitted but complied with the C15 Section of the MRP
State Board issued and adopted a state wide permit in November of 2014
Permit covers discharges from Drinking Water System to ◦ receiving water ◦ storm drain
Types of Discharges ◦ Planned discharges ◦ Emergency discharges
Supply well blowoff Tank or reservoir releases Trench dewatering (tie-ins) Distribution system flushing
Water treatment plant operations (excluding filter backwash discharged to receiving water)
Emergency drinking water system failures and repairs - includes transmission and distribution systems
Operation errors
Catastrophic events
Notification BMP Implementation Monitoring Record Keeping Reporting
Planned discharge ≥ 325,850 gallons (1 af) 3 days prior OR 24 hrs after Discharger informed to conduct
an urgent planned discharge Must notify ◦ Regional Board ◦ MS4 operator, if applicable
Within 24 hrs of becoming aware of adverse effect/impact on RW due to ◦ non-compliance, ◦ system failure or ◦ emergency
Must notify ◦ Regional Board ◦ MS4, if applicable
Additional written report within 5 days
At all Planned Discharges At Emergency Discharges as soon as feasible ◦ Concurrently protecting public health & safety
Maintain log of BMPs implemented for different types of discharges ◦ Field documentation ◦ Standard Operating Procedures (SOPs)
Planned discharges only Event Monitoring ◦ Superchlorinated ◦ Well Development and/or Rehab. ◦ Large Volume > 325,850 gallons
Annual Representative Monitoring ◦ All other discharges ◦ Same source, treatment, and BMPs
In State Permit, “Monitoring” means taking samples for Chlorine, Turb., and possibly pH
Chlorine Residual ◦ Effluent limit = 0.019 mg/L ◦ Out of Compliance if ≥ 0.1 mg/L Based on field monitoring equipment accuracy Reading not used for compliance if False Positive
Applies to ◦ All superchlorinated discharges ◦ Planned discharges directly into or within 300 feet
of creek
Monitoring Effluent Limit Applies
Well development/rehabilitation No, non-chlorinated discharges are not sampled for chlorine residual
Superchlorinated discharges Yes, to all discharges Large volume discharges ≥ 325,850 gallons
If direct discharge or discharge within 300 feet of a receiving water
Annual Representative Monitoring locations
If direct discharge or discharge within 300 feet of a receiving water
Sample collected at valid compliance sampling point but not required
If direct discharge or discharge within 300 feet of a receiving water
Turbidity Action Level = 100 NTU Applies to Groundwater Wells ◦ Development ◦ Rehabilitation or ◦ Operation discharges
Exceedance requires discharger to modify, change or enhance BMPs
# of direct discharges to RW >50,000 gal Volume discharged to RWs Volume directed to beneficial use Discharge monitoring data
Annual Report Due March 1st
Several distinct departments, each with multiple discharge types ◦ Operations ◦ Distribution Services ◦ Construction ◦ And others
BMPs were in place already, but needed
new/different paperwork on account of the new permit
Needed to advise each group in a way that was focused on their specific needs for discharge compliance ◦ Tailored SOP Development ◦ Employee Training ◦ Field Support ◦ Documentation
Manages facilities like tanks, booster pumps, and well sites
Two primary discharge types ◦ Well blowoff to waste ◦ Tank draining
Highest likelihood of exceeding 1 acre-foot threshold ◦ Sometimes difficult to predict total discharge
volume ◦ Ex: Returning a groundwater well to service
Responds to leaks, main breaks ◦ Classified as emergency discharges ◦ Limited data collection requirements, however:
For emergency discharges next to a creek, permit requires notification if an adverse effect or impact is observed
SJWC’s environmental team learned through this process that DS was also responsible for installing some new mains ◦ Planned discharges, which do require monitoring
SJWC’s Construction Department manages several contractors that conduct main replacements and other capital projects
Additional challenge of non-SJWC staff still
operating under SJWC’s permit
Most challenging planned discharges ◦ Tie-ins/trench dewatering (highly turbid) ◦ Flushing of new mains (superchlorinated)
Some low-impact SJWC operations don’t require much to ensure compliance ◦ Water quality sampling ◦ Meter testing ◦ Service flushing
Generally low-volume, ordinary drinking
water quality Often never reach surface waters ◦ Covered under “beneficial re-use” provisions
Still in development ◦ Additional BMP refinement ◦ Electronic data management ◦ Assessing need for additional training
Happy to collaborate further
