wet weather consent decree implementation update...wet weather consent decree implementation update...
TRANSCRIPT
Wet Weather Consent Decree Implementation Update
Planning Committee
September 10, 2014
Agenda
• Background
• Regional Private Sewer Lateral Ordinance
• Regional Technical Support Program
• Related Discharge Permits
•Next Steps
2
Background Consent Decree Status
• Lodged with federal District court July 28, 2014
• Public Comment Period closed September 2, 2014 (no comments received)
• Consent Decree will become effective immediately upon being entered by the court
3
Background Key EBMUD Requirements
• Construct and operate Urban Runoff Diversion Project by 2017
• Implement capacity improvement along North Interceptor by 2020
• Conduct annual compliance monitoring and modeling
• Continue Regional Private Sewer Lateral (PSL) Ordinance
Develop and implement a Regional Technical Support Program (RTSP)
4
Regional PSL Ordinance Proposed Amendments
• Consent Decree adds new requirement for Public Entities to maintain their sewer laterals (no enforcement requirements for EBMUD)
• Allow Albany and Alameda to join program
– Proposed transition date January 1, 2015
– City of Berkeley will retain its own program
• Clarify ordinance language developed through initial years of implementation
5
Regional Technical Support Program (RTSP) - Overview
• Replaces $2M/yr PSL Incentive requirement under Stipulated Order
• Requires $2M/yr to identify and characterize sources of inflow and rapid infiltration
• Cumulative spend requirement
– i.e. $2M by Year 1, $4M by year 2, etc.
– Provides ability to front-load
• Includes staff time for analysis and investigation
6
RTSP Overview, continued
• EBMUD identifies sources of inflow and rapid infiltration (I/I)
• EBMUD defines which sources are “high priority”
• Satellite communities pursue high priority sources
– Eliminate public sources within 2 years
– Enforce removal of private sources
• Satellite communities consider non-high priority sources in CIP prioritization
7
RTSP Program Significance
• Key element in WWF discharge reduction
– Estimated 15% of excess peak flow originates from inflow (direct sources)
– Model assumes ability to find and remove 75% of inflow
• Critical to meet Consent Decree
– Year 8 “check-in”
– Year 16 “check-in”
– WWF discharge elimination deadlines (2027, 2033, 2035)
8
RTSP Implementation Approach
• Consent Decree requires an RTSP Plan describing first five years of work
– Draft to satellite communities early 2015
– Final to EPA for review/comment/approval Spring 2015
• Initial field work will occur concurrent with RTSP Plan development
– 2014-2015 wet season flow monitoring
– 2015 dry season smoke testing, CCTV, etc.
9
RTSP Work Plan Development
• Define approach to data analysis and field work
• Maintain flexibility to adapt as we learn
• Learn from others
– I/I investigative programs across the country
– Panel of national experts in sewer system management to support RTSP Plan development
10
RTSP Tools and Techniques
• Analysis of data to identify areas of high potential for inflow, for example: – Flow data from EBMUD and satellite communities
– Proximity to creeks and storm drains
– Sewer work records
• Field work to locate and characterize sources – Flow monitoring
– Smoke testing
– CCTV inspection
– Visual inspection 11
Related NPDES Discharge Permits
• Wet Weather Facilities – Scheduled adoption date November 12, 2014
– Reviewing with RWQCB staff
– No significant issues
• Main Wastewater Treatment Plant – Application due October 2014
– Proposed adoption March 2015
– Key issue: Ensure blending requirements dovetail with WWF permit and Consent Decree
12
Next Steps
• Bring proposed Regional PSL Ordinance amendments for Board consideration
• Work with RWQCB on related NPDES permits • Develop initial deliverables for stakeholder
review in early 2015 – RTSP Plan – Flow Model Calibration Plan – PSL Outreach Plan
• Implement initial stages of RTSP data analysis and field work
• Keep Board apprised of key activities 13
Wastewater Service Area and Major Facilities
14
Semi-Annual Regulatory Compliance Update
Planning Committee
September 10, 2014
Agenda
• Enforcement Actions
• Permit for Potable Water Discharges
• Cal OSHA Inspections
• Safety Culture Perception Survey
• Upcoming Activities
2
Enforcement Review
• Strategic Plan KPI = Zero NPDES and Waste Discharge Requirement (WDR) permit Notices of Violation (NOVs) received
– Four NOVs for discharges to water or land
– Two NOVs related to air quality compliance
3
Lafayette WTP NOVs
•May 8, 2012 discharge caused by failure of filter control valve
– Modified controls
•March 27, 2013 discharge to sump going to Lafayette Creek
– Added signage at drains “No Dumping – Drains to Creek”
• $6000 settlement agreement
4
Upcountry NOVs
• Failure to collect data on pH and temperature at Camanche North Shore Water Treatment Plant in June 2014
– Contesting due to lack of discharge
•Missed sample during 2014 Q2 at Clay Station Raw Water Pumping Plant
– Enhanced communication between staff
5
MWWTP NOV Settlement Agreement
NOV for unabated digester gas release on 11/9/13
• 15 minute release through pressure relief valves
• Plugged drain line in flare
• Settlement agreement with $4000 fine
6
MWWTP Air Permit NOV
Digester gas release on 11/22/2013
• Failure of flare igniter
• 830 cu. ft. vented through pressure relief valves
• Requested breakdown relief
•NOV issued 7/28/14
7
General Potable Water Discharge Permit
• Agreement with SF RWQCB & ABAG to fund person to develop permit
• $298,833 estimated total cost
• Agreement with 7 other agencies to share costs
• District share is $50K
SF Regional Permit Progress
• 11/20/13 - admin draft issued for review with water agencies
• 5/8/14 - tentative order issued for public comment
• 5/19/14 - public workshop held
• 7/1/14 – permit postponed pending statewide permit
Statewide Permit
• 6/6/14 – SWRCB issues draft permit
• 8/5/14 – public hearing
• 9/23/14 – permit scheduled for adoption at SWRCB hearing
Cal OSHA Inspections
• 6 inspections initiated based on employee complaint(s)
• 13 facilities examined and scrutinized
• 2 citations
– Fixed ladder exceeds 30 feet without ladder safety system or landing platforms
– Mid-rail is below the halfway point of the guardrail
11
Safety Perception Survey
• 621 of 809 OMD employees surveyed
• Scored in 62nd percentile
• Compared to 750 Companies
•Over 1.5 million responders
12
Survey Action Plans
• Communicating results
• Engage employees
• Identify top issues to address
•Develop specific action-oriented countermeasures
• Retake survey in 2 years
13
Upcoming Activities
•Work with SFRWQCB, ABAG, and Bay Area water utilities to finalize a permit for potable water discharges
•Work with Local Safety Committees to develop action plans based on safety perception survey
• Review fall protection compliance at water distribution reservoirs
Questions?
15
Orinda Water Treatment Plant
Washwater Tank Rehabilitation
Planning Committee Meeting
Orinda Water Treatment Plant
Washwater Tank Rehabilitation
Planning Committee Meeting
September 10, 2014
Orinda WTP Washwater Tank Rehabilitation
• Background
• Site Constraints
• Community Outreach
• Design Mitigations
• Next Steps
Background Orinda WTP circa1938: minimal site constraints
Orinda WTPElevation = 375’
Washwater TankElevation=410’
Source: Google Earth
• 200,000 gallons• At grade• 40 ft. diameter • 22 ft. tall• Bar‐stressed concrete
BackgroundOrinda WTP and washwater tank today
Orinda WTP
Source: Google Earth
Washwater Tank
Site constraints Poor access, trees, no staging area
Tank
Property Line
Slope
Community Outreach
• Approach:
• Notified the community early
• Explained clearly the need for the project
• Provided visual exhibits
• Held community meetings on-site
• Mitigated with design
50’dia
Proposed Tank:
Existing Tank:
Community Outreach
New tank alternative
New tankalternative
Aerial “footprint” vs. Ground-level visualExisting
Community OutreachOn-site meetings clarified neighbor concerns
Mailbox access
Tree removal
Architecture preservation
Curb appeal
Designed Mitigations Adjust retrofit method to site constraints
Manual wrapping minimizes equipment size and tree removal.
Sturdy base anchorages minimizes impact on tank architectural features.
New fence is set back for a “green zone”
Security fence
Low maintenance plantings for screening
Restore cobbles
Add staging area off-site
Minimize tree removal
Retrofit existing tank
Design Mitigated Site planning neighbor concerns
Next Steps
• Maintain communications with neighbors
• Schedule:
– Open Bids Sept 17, 2014
– Recommend Award Oct 14, 2014
– Construction Nov 2014 – Mar 2015
Questions?
Drought Communications with Billpayers
and with Non-billpayers EBMUD Planning Committee
September 2014
2
More than a third of EBMUD customers do not get a bill
387,000 accounts
Non-billpaying residents are ethnically diverse
Non-billpaying residents are younger
Print bill payers get information and news regularly from EBMUD
Direct mail to print bill payers:
• Top of bill message
• Prior-year water use
• Back of bill tips
• Customer Pipeline
• Supplemental inserts
5
Electronic billpayers get links to EBMUD news and information
E-bill with web links:
– Top of bill message
– Prior-year water use
– Back of bill tips
– Customer Pipeline
– Bill FAQs
6
Non-billpayers get most EBMUD news through other sources
Direct mail
• Annual Water Quality Report postcard
Other communication
• Earned media
• Ebmud.com
• Outdoor ads
• Community events
• Presentations 7
Many more non-billpayers say they can’t rate EBMUD
Q10. Thinking specifically about the East Bay Municipal Utility District, using a scale of excellent, good, only fair, or poor, please rate the overall job East Bay Municipal Utility District is doing
92%
79%
90%
83%
80%
68%
79%
71%
76%
66%
75%
67%
71%
57%
Bill Payer
Non-Payer
Bill Payer
Non-Payer
Bill Payer
Non-Payer
Bill Payer
Non-Payer
Bill Payer
Non-Payer
Bill Payer
Non-Payer
Bill Payer
Non-Payer
Total Agree
Non billpayers give EBMUD favorable--but lower--ratings
Provides safe tap water
Provides good tasting tap water
Is an agency I can trust
Cares about the environment
Is a reliable source of information
Operates in communities’ best interests
Is responsive to customer service requests
Conservation rating variance was 13 percent in early 2014
77%
65%
61%
55%
60%
47%
Bill Payer (78%)
Non-paying Renter (22%)
Bill Payer (78%)
Non-paying Renter (22%)
Bill Payer (78%)
Non-paying Renter (22%)
Ensuring the quality of the water we drink
Making sure we have the water supply we need
Encouraging customers to conserve water
TV news is the top source for conservation information
Page 11
7/08 2/08 2007
Television News* 38% 37% 35%
Newspaper 22% 23% 25%
EBMUD Bill insert/newsletter 14% 16% 6%
Radio 5% 12% 9%
Television Commercial 3% -- --
Brochure/Pamphlet 3% 7% 4%
Billboard 2% 4% 4%
EBMUD websites 1% 1% --
Other website 1% 2% --
Other 10% 11% 33%
Don’t Know 1% 5% 3% * In 2/08 and 2007 surveys, “Television” was not split between “News” and “Commercial”
** 2 responses were allowed per respondent in 2/08 and 2007 surveys *** “Other responses include “phone calls” and “letters” from previous EBMUD actions
Where did you see or hear the conservation information?
In 2014, active media relations has been a focus of outreach
•480 unique interviews with reporters
–218 on drought declaration/water supply
–152 on conservation tips, rebates, rules
•370 news reports featured EBMUD
12
Late 2014 proposed outreach intended to reach non-billpayers
• Ongoing
– Earned media, web, presentations, booths, etc.
• October+
– Social media policy
• November
– Updated outdoor media campaign
• December
– Direct mail to non-billpayers
13
Semi-Annual Water Quality Report
Planning Committee September 10, 2014
District’s Water Quality Goals
•Must meet Federal and State Drinking Water Standards
• KPI – Meet 100% of Federal and State Drinking Water Standards
• Strive to meet District’s Water Quality Goals
• KPI – Meet 100% of District’s Water Quality Goals
•Met all Federal and State Drinking Water Standards
•Met 117 of 119 (98%) District’s Water Quality Goals (WQGs)
– Exceeded the WQGs for TTHMs and NDMA
• TTHM – Exceeded WQG in 3 of 32 compliance
calculations
– Project underway to alter chemical injection points at Sobrante Water Treatment Plant
•NDMA – Exceeded WQG in 1 of 10 samples
– WateRF Projects •Natural sources of NDMA precursors
•Alternative polymer evaluation
UCMR 3
• Provide occurrence data to USEPA
• Prelude to potential regulatory action
• 30 unregulated contaminants
• Began monitoring: Fall 2013
• Detected – Chlorate
– Vanadium
– Strontium
– Hexavalent chromium
Hexavalent Chromium (Cr(VI))
• CA established MCL (10 µg/L) on July 1, 2014
•District began UCMR3 monitoring on Fall 2013
• Cr(VI) detected in UCMR3 samples based on USEPA detection limit (0.03 µg/L)
• Based on CA detection limit (1 µg/L) our UCMR3 data would be reported as nondetects.
CalEnviroScreen
•Quantitative assessment of pollution burden
– CalEPA Office of Environmental Health Hazard Assessment (OEHHA)
– Identify areas with high pollution burden
• Version 2.0
– Drinking Water
– Finer resolution
– Draft April 2014
CalEnviroScreen (cont)
• Acknowledge contaminant concentration used may represent untreated water
• Reference to consumer confidence reports
Potential Regulatory Action
• Candidate Contaminant List (CCL) 4
• Unregulated Contaminant Monitoring Rule (UCMR) 4
•Distribution System Reservoirs Rule
– Asked District staff to provide information on District maintenance practices (October 15, 2014)
• Research – District operations continues to experience
nitrification
– Beginning work to gain a better understanding of the underlying causes in an effort to improve operations
• Portland Water Bureau – Lead violation
– Boil Water Notice (TCR violation)
– Nitrification
Questions