BACWA Bulletin - March 2017

Table of Contents


  • Recycled Water Comm., 3/1
  • BAPPG Steering Comm., 3/8
  • Lab Comm., 3/8
  • Permits Comm. joint meeting with CASA RWG, 3/9
  • Biosolids Comm. joint meeting with CASA RWG, 3/9
  • AIR Comm., 3/15
  • Executive Board, 3/17
  • Collection Systems, 3/23
  • Visit the Calendar for details.

Annual Members meeting survey results now posted 

BACWA hosted our Annual Meeting for our member agencies on January 27, 2017. Many thanks to those of you who attended the meeting and responded to the survey. Survey results are now posted.  BACWA uses the survey data to continue to improve the Annual Meeting experience for our members.

Regional Water Board posts proposed revisions to the 303(d) list

Under the Clean Water Act Section 303(d), State and Regional Water Boards assess water quality monitoring data for California’s surface waters to determine if they contain pollutants at levels that exceed protective water quality standards. Water body and pollutants that exceed protective water quality standards are placed on the State’s 303(d) List. The San Francisco Regional Water Board has posted proposed revisions to the San Francsco Bay Basin's 303(d) list, which will be the first update to the list since 2010. Some of the changes are substantial, such as the new toxicity listing for each segment of the San Francisco Bay. BACWA has submitted a request to extend the comment period, which currently has a deadline of March 13.

BACWA continues to engage BAAQMD on Regulation 11, Rule 18

BAAQMD is revising Regulation 11, Rule 18 (i.e., Rule 11-18) - Reduction of Risk from Air Toxic Emissions at Existing Facilities. The proposed revision would require health risk assessments for all facilities with a cancer risk of greater than 10 in a million, and require risk reduction/installation of Toxic Best Available Retrofit Control Technology (TBARCT) for significant sources of toxic air contaminants.  BAAQMD staff have specifically called out diesel emissions as the primary pollutant of concern for POTWs. BACWA has developed a White Paper to summarize the Rule and its impacts to our members. BACWA members will be attending a workshop with BAAQMD staff on March 9 to help educate them about the special challanges for POTWs and other public agencies to comply with the Rule.

BACWA developing costs associated with diesel emissions reductions

The AIR committee is surveying BACWA membership to identify/list the facilities (treatment plants, pump stations, wet weather facilities, etc.) and the number and size of diesel generators at those facilities that are impacted by BAAQMD's proposed Rule 11-18 (see above). Please email Courtney Mizutani your agency's BAAQMD permit to operate for facilities that include standby diesel generators to be included in this analysis. This information will serve as the basis for determining the potential economic impact Rule 11-18 may have on Bay Area POTWs. The permits should be sent in by Wednesday, March 15th or as soon as possible. BACWA is meeting with BAAQMD staff this Thursday, March 9th, to discuss the Rule’s impact and would like to quickly follow up with the estimated economic impact. If you have any questions, please email Courtney Mizutani or Sarah Deslauriers.

BACWA submits comments on State Water Board proposed mercury objectives and new beneficial uses

The State Water Board is proposing new mercury water quality objectives, as well as three new Beneficial Uses that may be protected by mercury objectives. The new Beneficial Uses are Tribal Tradition Cultural, Tribal Subsistence Fishing, and Subsistence Fishing. Designation of these Beneficial Uses in the San Francisco Bay could lead to extremely low mercury objectives that would need to be met by POTWs at the end of pipe, because dilution credit cannot be granted when the receiving water is already impaired.  

State Water Board staff held a staff workshop on January 9, 2017 to provide the public an opportunity to discuss the Provisions. No Board action was taken. Staff gave presentations on the proposed Mercury Water Quality Objectives and the proposed program of implementation, as well as the proposed Beneficial Uses. There was also a hearing on February 7 with State Water Board members present. The webcasts of both meetings are posted on the State Water Board's mercury webpage.

BACWA submitted a comment letter in support of protecting the new beneficial uses, but requesting changes in the implementation requirements, since POTW loads of mercury are de minimis. Even if BACWA members ceased their discharge altogether, there would not be an impact on mercury levels in fish in San Francisco Bay, since the major sources of mercury are tributaries and in-Bay sediments. BACWA also signed onto a Regional Association Comment letter proposing language that would assist Regional Water Boards in exempting POTWs from mercury load reductions that would be required to achieve the new beneficial uses.

BACWA submits comment letter on climate change resolution

The State Water Board has proposed an updated Climate Change Resolution. The section on Recycled Water states:

DWQ shall coordinate with the Regional Water Boards to make annual reporting of recycled water data a requirement of waste discharge permits and water reclamation requirements, and work with the Division of Information Technology to develop an online data entry system to track recycled water use. Starting with the 2017-18 annual Performance Report, DWQ shall include a summary on the volume of recycled water used, and types of use.

BACWA submitted comments recommending that DWQ coordinate with the Regional Water Boards to make the data they request consistent with data that agencies compile for other reporting requirements, to reduce the burden of generating additional data for different efforts. BACWA also volunteered to provide input during the development of the data forms.

BACWA comments on chronic toxicity in City of Pacifica Tentative Order

The City of Pacifica was recently issued a tentative order including toxicity limits of 1.0 TUc as an average monthly effluent limit (AMEL), and 1.8 TUc as a maximum daily effluent limit (MDEL). Their test species is Ceriodaphnia dubia, which has been demonstrated both by BACWA member agencies and by a SCCRWP study to exhibit high variability. Pacifica's sensitive species screening tests indicated that Selenastrum capricornutum was the most sensitive species, but their Tentative Order still retains C. dubia, citing past high toxicity results with C. dubia during regular testing.  BACWA submitted a comment letter recommending that they be allowed to choose either of the two test species, that there should not be a maximum daily limit in light of the known variability in the test, and that they should be exempt from accruing additional violations when they are investigating toxicity.

What's new in BACWA's Committees

AIR Committee

The November AIR Committee meeting was held November 30 at the San Jose/Santa Clara Regional Wastewater Facility. The committee discussed BAAQMD Rule 11-18 which proposes to tighten restrictions on toxic air emissions. Members also toured the Silicon Valley Advanced Water Purification Center. The next meeting is scheduled for March 15th at Fairfield-Suisun Sewer District. See previous AIR meeting materials.

Asset Management Infoshare

At the last meeting on February 23, Dana Lawson presented an overview of Central San's recent implementation efforts including GIS, web mapping, CMMS, CCTV, hydraulic model, renovation planning, and program management information system. The group reviewed the initial outline for asset cost and lifecycle tables and hopes to have a final product by the end of the year. The next meeting will be scheduled in mid-May at EBMUD.


The February meeting featured a presentation by Karri Ving of SFPUC on their Core Competency model for hiring and training staff. Doug Dattawalker gave an update on Union Sanitary District's P2 program. The April meeting will be focused on agencies' school outreach programs.  View notes from previous meetings.

Biosolids Committee

The January meeting featured a presentation on preliminary results of the BACWA Biosolids Survey, as well as a discussion about new regulations that will impact agencies' ability to use landfills to reuse or dispose of biosolids in the future. The next committee meeting will be held March 9 in conjunction with the CASA Regulatory Workgroup meeting in San Leandro.

Collections Systems Committee

The January meeting featured a discussion and presentation on force main repair and rehabilitation. Regional Water Board staff will attend the March 23 meeting to talk about their priorities. Based on the results of a survey of committee members, we will be switching our meeting day and time to the mornings of the fourth Thursdays of each month. For more information, see previous Collections Systems Committee Reports.

Laboratory Committee

The March meeting will feature a guest speaker from Waters to talk about LC/MS/MS technology application to environmental analysis. As SFEI moves toward more monitoring of CECs, this is a timely technology for committee members to better understand.

Permits Committee

The February meeting will focus on toxicity provisions being introduced into some members' Tentative Orders, and State Water Board's proposed Tribal and Subsistence Fishing Beneficial Uses and Mercury Provisions to amend the State Implementation Policy. The next meeting will be held March 9 in conjunction with the CASA Regulatory Workgroup meeting in San Leandro. For more information about committee activities, please see previous Permits Committee Reports.

Pretreatment Committee

The January meeting featured discussions with Amelia Whitson, Pretreatment Coordinator for EPA Region IX. The committee also debriefed PCI/PCA experiences and discussed food digesters for restaurants, documentation of alternative sampling methods for SIUs, and continuous pH monitoring results. The committee reviewed the elements of the recently adopted federal dental amalgam rule, planned logistics for a dental program/inspection training session that is budgeted for FY16-17, and finalized the committee's requested budget for FY17-18.

Operations and Maintenance Infoshare Group

The January meeting included a roundtable discussion where members shared their agency's policies, success stories and lessons learned about how to hire new staff, train in-house staff, and retain historical expertise.The next O&M Infoshare meeting will be held on April 26, location to be determined.

Recycled Water Committee

The March meeting featured updates on several statewide initiatives, such as the Recycled Water Policy update, the development of building standards for dual plumbing, and the State Plan for increasing water use efficiency. At the May meeting the committee will discuss AB 574 (Quirk Bill) which seeks to update the definition of potable reuse to four specific types and do away with “direct potable reuse” and “indirect potable reuse.” For more information about committee activities, please see Recycled Water Committee meeting notes.

Upcoming Events

US TAG Showcase Wastewater Technology Workshop, March 14, 2017, East Bay Municipal Utilities District, 375 11th St, Oakland, CA.

State of the Estuary October 10-11, 2017, Scottish Rite Center, 1547 Lakeside Dr., Oakland CA.

BACWA External Representation

Collaboration with outside groups and initiatives is an important facet of BACWA's mission. Below is a list of BACWA's representatives to these  technical, regulatory, and management groups:

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