BACWA Bulletin - January 2017

Table of Contents


  • Pretreatment Comm., 1/10
  • Permits Comm., 1/10
  • Collection Systems Comm., 1/12
  • Recycled Water Comm., 1/18
  • Biosolids Comm., 1/19
  • O&M Infoshare, 1/25
  • BACWA Annual Members Meeting, 1/27
  • Visit the Calendar for details.

Register for BACWA's Annual Members' Meeting - January 27, 2017

BACWA's Annual Members' meeting will be held on January 27 from 8:30 am to 3 pm at the Metropolitan Golf Course, 10051 Doolittle Drive, Oakland. A continental breakfast, and lunch will be provided. One of the highlights of the Annual Meeting is updates from our regulators, and we have speakers lined up from EPA Region IX, the State Water Board, the San Francisco Bay Regional Water Board, and the Bay Area Air Quality Management District. Please register by January 13. Stay tuned for the full program, which will be posted prior to the event.

BACWA joins Regional Associations and NACWA in lawsuit against EPA on TST 

The test of significant toxicity (TST) is an alternative method for evaluating whole effluent toxicity (WET) test results. Over the past few years, the EPA has required use of the TST in some California POTW NPDES permits, and encouraged its use where Regional Water Boards hold jurisdiction. The TST is not a promulgated method, but is favored by some regulators because it gives a simple "pass" or "fail" result, rather than a result that is open to interpretation. When using the TST to evaluate WET test results, many agencies see high rates of "false positives", where toxicity is identified where it is not actually present. BACWA is joining SCAP, CVCWA and NACWA in a lawsuit against EPA, alleging that they have no legal authority to mandate "rules" that have not been properly promulgated by notice and comment rulemaking. If this lawsuit is successful, then the EPA would need to go through a formal rulemaking process prior to requiring the TST to be implemented in NPDES permits.

BACWA submits comments on BAAQMD 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 TBARCT (Toxic Best Available Retrofit Control Technology) for significant sources of toxic air contaminants. The Draft Staff Report specifically calls out wastewater treatment plants (pages 29-30), identifying fugitive and stack emissions of Diesel PM, hydrogen sulfide, mercury, and cadmium as pollutants of concern. It also defines the Significant Risk Threshold, which sets the cancer and non-cancer risk action levels for individual sources of toxic emissions as follows:
  • Cancer: 1.0 in a million
  • Chronic hazard index: 0.2
  • Acute hazard index: 0.2
BACWA has developed a draft White Paper to summarize the Rule and its impacts to our members, which will be finalized in early January. BACWA provided comments on Rule 11-18 to BAAQMD in time for the December 2 deadline, and BACWA representatives gave oral comments at the December 6 BAAQMD Board Hearing.  A BAAQMD staff member gave a presentation on the Rule at BACWA's December 16 Executive Board meeting.  BACWA will continue to look for opportunities to engage BAAQMD on the possible consequences of adopting Rule 11-18. For a list of facilities identified by BAAQMD as potentially impacted by Rule 11-18, as well as their phase of implementation, please contact Lorien Fono, BACWA Regulatory Program Manager.

EPA finalizes Dental Amalgam Rule

EPA has finalized its dental amalgam rule, and a pre-publication version of the rule is now available. Although all dental offices will be required to have dental amalgam separators, POTWs will only need to collect a one-time certification report from the dental offices in their service areas, and will not be responsible for enforcing compliance. BACWA's Pretreatment Committee provides the following synopsis of the rule:
  • All POTWs, regardless of whether they have an existing pretreatment program, are required to receive the one-time certification from existing and new dental facilities. While processing of this submittal will take some resources, the rule does not obligate agencies to pursue enforcement against dentists who do not submit the required certification. Local agencies’ level of effort is to be determined but will be relatively minimal after the pretreatment standards for existing sources facilities are processed.
  • The final rule identifies the content of the certification form, but the burden to develop a compliant form can fall on individual agencies. A form template may also be developed by national, state, or regional associations/agencies. The latter strategy would be beneficial for local agencies that do not currently have an amalgam separator program. The BACWA pretreatment committee will discuss the form at future meetings.
  • Agencies with existing dental amalgam programs that require amalgam separator certification forms to be submitted may need to require resubmittal of certifications if the original forms used did not contain the elements specified in the EPA's final rule. 
  • Local agencies are not required to permit, inspect, or sample dental offices unless they choose to do so under their local programs.
  • Non-compliant dental practices will not be classified as Significant Industrial Users (SIUs), unless classified as such by their local agency.
For more information about how this Rule will impact Bay Area POTWs, please contact Tim Potter, BACWA Pretreatment Committee Cochair.

BACWA submits comments on pesticide reregistration to EPA

BACWA is engaged in an ongoing effort to engage regulators to recognize potential impacts of pesticides on municipal wastewater treatment plants and their receiving waters. EPA is currently reviewing the registration of several key pesticides, a task it conducts once about every 15 years. In December, BACWA submitted a comment letter requesting additional time to review a very lengthy risk assessment on a number of pesticides. BACWA also submitted a comment letter requesting that EPA review the route to the sanitary sewer of flumethrin as part of their work plan for the pesticide's reregistration. This pyrethroid is only used in pet flea collars, which release the flea collar pesticide on a continuous basis onto a pet’s fur. From the wastewater viewpoint, pet collars have similar exposure pathways to pet spot-on treatments like fipronil and imidacloprid, which have recently been shown to be transferred from pets to their owners hands and clothes where they are washed into the sewer. In the workplan, EPA has declared that the flumethrin cannot get from the flea collar into the sewer, so they do not intend to do a water quality risk assessment.

NPDES Compliance

Each year, BACWA provides a letter to the Regional Water Board outlining its activities on members' NPDES requirements that are most efficiently fulfilled as a group. The purpose of this letter is to report on behalf of BACWA members that those requirements are being met, including permit provisions related to: (A) Receiving Water Quality Monitoring, (B) Total Maximum Daily Load and Site Specific-Objective Support, (C) Mercury and PCBs Watershed Permit Support, and (D) Copper Action Plan. The letter also provides a list of agencies that have paid their dues to the Regional Monitoring Program, and that have opted into and paid their fees for the Alternate Monitoring Plan. The letter covering the 2016 calendar year will be distributed to member agencies for inclusion by reference in their Annual Reports by mid-January.

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 developing a comment letter on 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.


The December meeting featured an update on BACWA members' investigations into microplastics analysis methods, as well as presentations highlighting the pollution prevention programs run by West County Wastewater District and the City of Petaluma.  View notes from previous meetings.

Biosolids Committee

The BACWA Biosolids Committee  is conducting a survey to better understand how POTWs in our Region manage their biosolids, and their plans for when landfill application is phased out, which will likely occur by 2025. The committee reviewed preliminary survey results at its October 20 meeting, which was held at Fairfield-Suisun Sewer District. The next meeting will be held on January 19, 2017.

Collections Systems Committee

The November meeting featured a presentation on EBMUD's experience addressing I/I as part of its consent decree. Additionally, the committee plans to update the BACWA sewer rate survey in coming months. The January meeting will include a discussion and presentation on force main repair and rehabilitation. The committee will also decide on the location and time for future meetings. For more information, see previous Collections Systems Committee Reports.

Laboratory Committee

There will not be a January meeting, since lab staff will be busy preparing their Annual Reports. The focus of the February meeting will be on Method Update Rule - 2016, and preparing to implement changes. This is a great opportunity to get the information your agency needs in one session and to obtain clarification on the rule from experienced BACWA lab professionals.

Permits Committee

Regional Water Board staff attended the December meeting and gave an update on staffing changes in their office. January's meeting will focus on several initiatives that are upcoming in the new year from regulators, such as EPA's draft Human Health Recreational Ambient Water Quality Criteria or Swimming Advisories for Microcystins and Cylindrospermopsin, and State Water Board's proposed Tribal and Subsistence Fishing Beneficial Uses and Mercury Provisions to amend the State Implementation Policy (expected to be released on Jan 3, 2017). For more information about committee activities, please see previous Permits Committee Reports.

Pretreatment Committee

The next meeting will be held on January 10 at EBMUD, and will feature discussions with Amelia Whitson, Pretreatment Coordinator for EPA Region IX. The committee will also be discussing Food digesters for restaurants, documentation of continuous pH monitoring, planning for a dental program/inspection training session that is budgeted for FY16-17, as well as finalizing the committee's requested budget for FY17-18

Operations and Maintenance Infoshare Group

The next O&M Infoshare meeting will be held on January 25 at CCCSD. The discussion topic will be Succession Planning - how to hire new staff, train in-house staff, and retain historical expertise. Please RSVP.

Recycled Water Committee

The November meeting featured a presentation by Christopher Stevens from the Division of Financial Assistance at the State Water Board on funding opportunities for recycled water. He made the point that SRF funding has not decreased per se, but there are increased demands on this source. The committee also discussed the development of building standards for recycled water by the Department of Housing and Community Development and the State Water Board. January's meeting will be postponed from the first to the third Wednesday of the month to accommodate the winter holiday. For more information about committee activities, please see Recycled Water Committee meeting notes.

Upcoming Events

BACWA Annual Members' Meeting, January 27, 2017,  Metropolitan Golf Course 10051 Doolittle Drive, Oakland, CA.

CWEA Collection Systems Workshop, February 15, 2017,  Shannon Community Center Ambrose Room 11600 Shannon Avenue Dublin, 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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