BACWA Bulletin - July 2016

Table of Contents


  • Permits Comm, 7/12
  • Lab Comm., 7/13
  • Recycled Water Comm., 7/13
  • Collection Systems Comm., 7/14
  • Executive Board, 7/15
  • Biosolids Comm., 7/21
  • Visit the Calendar for details.

Thanks to those who attended Optimization/Upgrade studies workshop on June 27

Under the 2014 Nutrient Watershed permit, agencies are required to perform an analysis of opportunities for optimization and upgrades to remove nutrient loads from their facilities. Each agency covered by the Nutrient Watershed permit elected to participate in a regional analysis provided by BACWA and funded through the Nutrient Surcharge. BACWA worked with the Contract Management Group (CMG), made up of small and large agencies from each subembayment, to bring aboard a consultant team to perform these Regional Studies, and to oversee the studies.

From Spring through Fall of 2015 the consultant team visited each facility and met with key staff to develop recommendations. These recommendations will be presented for each agency in Facility Reports.  The Facility Reports will be delivered to the agencies in four waves between May and September 2016 (see Facility report schedule). Upon receipt of your agency’s Facility Report, you will have three weeks to review and comment. Ultimately, your agency’s designated Point of Contact will need to sign off on the Facility Report before it can be included in the Optimization and Upgrade Report that is required by the Nutrient Watershed Permit. On June 27, BACWA hosted the first of two workshops in 2016 to address these Facility Reports. The presentations from the first workshop are now posted online. A second workshop will be announced later in 2016 and will include Regional Water Board staff.

State Water Board adopts General Order for Recycled Water, with mandatory enrollment for 96-011 permittees within three years

On June 7, the State Water Board adopted the General Order specifying Water Recycling Requirements (General Order). At the adoption hearing, State Water Board staff presented three options for the General Order's Finding 34, which specifies which entities are to be covered under the new General Order.  The State Water Board selected option 2, which will require all current Regional permittees, including those currently covered by 96-011, to enroll in the General Order within the next three years. In BACWA's comment letter, and at testimony at the adoption hearing, BACWA recommended that if 96-011 permittees were required to enroll in the General Order, permittees should be deemed as enrolled at the end of the three year period to lessen the administrative burden associated with transitioning several dozen enrollees in our Region. The State Water Board did not adopt this recommendation (see State Water Board's response to comments), so Regional Water Boards will need to review Engineering Reports for existing Regional permittees to determine which ones meet the requirements described in the State General Order. BACWA plans to discuss the enrollment process with our Regional Water Board.

The State Water Board did not reduce the priority pollutant monitoring requirements in the General Order, as requested by BACWA. Their intent is to make the General Order consistent with the State Recycled Water Policy, which stipulates those monitoring requirements. However, the State Water Board plans to reopen the State Recycled Water Policy and adopt revisions in the next 12 to 18 months. Both Board members and Staff agreed that reducing priority pollutant monitoring is a goal for the revision. This effort will begin in Summer 2016, and will include outreach to Stakeholders. Their intent is to then reopen the General Order once the Policy is revised, and before the three-year deadline for enrolling Regional permittees, so that the monitoring requirements in the current General Order should not impact this group.

EPA proposes new selenium criteria for the San Francisco Bay Estuary

On June 30, the EPA proposed a federal Clean Water Act rule to reduce the selenium water quality criteria for the waters of San Francisco Bay and Delta from 5 ppb to 0.2 ppb. Most San Francisco Bay Area POTWs would not be able to meet this concentration without dilution credit (See 2012 SFEI study on selenium in SF Bay Area POTWs). Selenium discharges from North Bay POTWs are governed by the 2015 North Bay selenium TMDL, but POTWs in the South Bay could be impacted in the future by the new criteria. After the rule is published in the Federal Register in early July 2016, EPA will be accepting comments on its proposal for 60 days. They will also be holding a virtual public hearing on August 22, and two in-person public hearings on August 23. BACWA will hold discussions with SFEI and the Regional Water Board to develop a response to this proposed rule. SFEI is planning a Selenium Workshop on July 27 where a science strategy for the Bay will be developed. Details are to be announced.

BACWA submits comment letter to EPA on malathion reregistration

BACWA is a national leader in engaging regulators on the impacts of pesticides on POTWs. The pesticide malathion is of particular concern for wastewater, because it is one of the most common active ingredients in head-lice treatments on the market. It is an organophosphate pesticide that remains in the urban market, unlike its sister chemicals diazinon & chlorpyrifos that were largely phased out from urban use in the early 2000s.  Malathion is a “Tier 2” chemical on Urban Pesticides Pollution Prevention Partnership watch list because malathion continues to appear occasionally (10-20% of the time) in urban watersheds at concentrations above the EPA water quality criterion (which is not currently enforceable in California) and/or the EPA pesticides aquatic life benchmark.  These malathion detections could eventually land some urban watersheds on the 303(d) list. BACWA submitted a comment letter to EPA to object to the omission of wastewater from the entire reregistration process.

SFEI to coordinate voluntary CECs analysis for POTWs

The Regional Monitoring Program for Water Quality in San Francisco Bay (RMP) is coordinating a voluntary Bay-wide monitoring study this fall focused on pharmaceutical compounds in wastewater. Results may be of particular interest to wastewater agencies active in drug take-back efforts, or those exploring the effects of different stages of wastewater treatment on pharmaceutical levels.  Several BACWA agencies have already expressed their interest in participating in this study, and any other interested agencies should fill out this interest survey by July 8. Responding to this survey does not represent a binding commitment, but RMP staff will contact interested parties with additional study details and next steps during the second week in July. 

The RMP will coordinate sample collection and shipping, and will provide scientific guidance and assistance with data interpretation. Participating agencies will collect and ship samples for analysis, and will be individually provided results from the analytical laboratory in the fall. BACWA will be able to coordinate laboratory contracting among participants if desired. 

Wastewater samples will be analyzed by AXYS Analytical for 104 pharmaceutical analytes (Lists 1, 3, 4 and 5 of EPA method 1694, AXYS method MLA-075). AXYS can analyze samples of wastewater influent, partially-treated effluent, or final effluent. Results will be provided by AXYS in the fall. The approximate cost per sample will be $2000. 

Each agency will receive their data individually and will have full control over the reporting of their results. If desired, agencies can also allow the RMP to use their data, anonymously or not, to analyze data aggregated across agencies. Several agencies have expressed interest in contributing to such an analysis, and greater participation among BACWA agencies would support more robust regional analysis and conclusions. RMP staff will also be able to provide some assistance with internal or external reporting or public outreach that individual agencies choose to do based on the findings. 
Interested agencies should fill out this interest survey by July 8. If you have any questions about the study, please contact Jennifer Sun by email or (510) 746-7393.

Melody LaBella and Vince De Lange recognized as CWEA Emerging Leaders

Congratulations to Melody LaBella of Central Contra Costa Sanitary District, and Vince De Lange of East Bay Municipal Utilities District (EBMUD), who have both been recognized by CWEA as Emerging Leaders. Melody has long been a leader in the Region through her work with BAPPG, and has also engaged in Statewide and National pollution prevention initiatives focusing on pesticides, "flushable" wipes, pharmaceuticals, and other trash that should be kept out of the sewers. This award recognizes both Melody's work in pollution prevention, as well as her advocacy for water recycling projects. Vince's award recognizes his risk-based approach to decision making for his agency that allows his staff and management to navigate complicated planning issues. Vince has also been instrumental in developing EBMUD's pioneering waste-to-energy program.

What's new in BACWA's Committees

AIR Committee

The AIR Committee's Annual Meeting with Bay Area Air Quality Management District (BAAQMD) Staff was held on June 15. The key messages from BAAQMD were:
  • Draft Clean Air Plan control measures have been posted on BAAQMD’s Open Air Forum.  These measures are largely exploratory at this stage, but will help guide prioritization of future actions, including those related to greenhouse gas emissions.
  • Air Toxics:
    • BAAQMD is working on revisions to Regulation 2, Rule 5 – New Source Review of Air Toxic Contaminants.  Revised rule language should be available in August, for consideration by the Board in September.  At this time, BAAQMD is not proposing any changes to the current significance thresholds.
    • BAAQMD is considering a new policy or rule in 2017 to address air toxics emissions from existing facilities. 
  • BAAQMD is re-evaluating the enforcement of Regulation 9, Rule 2 on hydrogen sulfide discharges as new permit applications or permit modification requests are received for digesters. Their goal is to develop case-by-case permit conditions that allow digester gas venting up until a certain quantity of hydrogen sulfide has been released (# lbs/hour).  This limit is intended to correlate to the downwind concentration allowed by Regulation 9, Rule 2.
  • Given the forthcoming waste diversion regulations, BAAQMD’s Organic Waste Workgroup is researching both barriers and incentives for organic waste diversion projects (permitting issues, best management practices, economic incentives, etc.).  Contact Carol Allen/BAAQMD if you have any feedback to help promote these projects moving forward
View previous AIR meeting materials.


The June BAPPG meeting featured a presentation from the public relations consultant firm O'Rorke on the status of BAPPG's outreach initiatives.  Additionally, Bill Pollock from Alameda County Environmental Health gave an update on their pharmaceutical take-back program efforts.  BAPPG submitted a letter to Bay Area Senators in support of SB1229, which offers liability protections for pharmacies that have pharmaceutical take-back bins. The August meeting will feature the annual pollutant prioritization exercise. View notes from previous meetings.

Biosolids Committee

The BACWA Biosolids Committee plans to conduct a survey developed from the biennial biosolids survey conducted by Southern California Alliance of Publically Owned Treatment Works (SCAP). The purpose of the survey is to better understand how POTWs in our Region plan to manage their biosolids as landfill application is phased out. The next meeting will be held on July 21, location to be announced.

Collections Systems Committee

The May meeting featured a presentation by Lenny Rather about Oro Loma's recent collection system audit by the Regional Water Board. The July meeting will feature a presentation by Jim Fisher of the State Water Board staff on SSS WDR compliance and enforcement. For more information, see previous Collections Systems Committee Reports.

Operations and Maintenance Infoshare Group

The June meeting featured a roundtable discussion about transfer of knowledge and maintaining asset management data so that it is accessible and up-to-date.  The next meeting will be held September 28 at CCCSD. For more information on Group activities, please see O&M Infoshare Group reports.

Permits Committee

Regional Water Board staff attended the June meeting and reported that Diane Feinstein's staff have contacted Region 2 and 5 staff about ammonia discharges to Suisun Bay. SFEI staff were also in attendance to discuss their pharmaceuticals sampling and analysis initiative (see above). For more information about committee activities, please see previous Permits Committee Reports.

Pretreatment Committee

On June 22, the Pretreatment Committee cohosted a training with the firm EEC, covering the following items:
  • 40 CFR Key Provisions
  • Program Elements
  • Regulatory Climate Forecast
  • Updating Local Limits
  • Audit Preparation
  • Categorical Standards
  • Program Modification.
The next regular Pretreatment Committee meeting will be held mid-August at Union Sanitary District.

Recycled Water Committee

The July committee meeting has been pushed back one week to avoid the week of the July 4th holiday. The July meeting will feature a discussion about the recently adopted State General Order for recycled water (see above).  Additionally, the California Department of Housing and Community Development and the California Building Standards Commission are soliciting participation on a steering committee to assist state agencies in the research and development of recycled water infrastructure building standards.  The first meeting was held on June 14, 2016.  Although this one has passed they would like to have the BACWA Recycled Water community's technical expertise, experience, and perspective in this area to assist them in future meetings. For more information, please contact Beth Maynard.  For more information about committee activities, please see Recycled Water Committee meeting notes.

Upcoming Events

9th Biennial Bay-Delta Science Conference, November 15-17, 2016, Sacramento Convention Center, Sacramento. 


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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