Clean Bay REGIONAL WATER QUALITY CONTROL PLANT 2501 EMBARCADERO WAY, PALO ALTO, CA (650)

Transcription

1 Clean Bay Pollution Prevention Plan 2009 REGIONAL WATER QUALITY CONTROL PLANT 2501 EMBARCADERO WAY, PALO ALTO, CA (650) OPERATED BY THE CITY OF PALO ALTO FOR THE EAST PALO ALTO SANITARY DISTRICT, LOS ALTO S, LOS ALTOS HILLS, MOUNTAIN VIEW, PALO ALTO & STANFORD

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3 Clean Bay Pollution Prevention Plan 2009 The Pollution Prevention Plan for the City of Palo Alto's Regional Water Quality Control Plant February 2009 For More Information Additional program information is available at the Environmental Compliance Division web site: Questions about this document should be directed to the Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto, CA 94303, (650) , Acknowledgements The Clean Bay Plan is produced by the City of Palo Alto's Environmental Compliance Division, and describes the pollution prevention activities of the Industrial Waste and Source Control programs. Key staff members in the development and implementation of this plan include Phil Bobel, Maree Doden, Brad Eggleston, Chris Fujimoto, Ryan Harrison, Brian Jones, Nina McNitzky, Karin North, Jim Stuart, Ken Torke, Julie Weiss, and Margaret Zittle. Clean Bay Pollution Prevention Plan 2008 Page i of 107

4 Executive Summary The City of Palo Alto operates the Regional Water Quality Control Plant (RWQCP), a wastewater treatment plant for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo Alto, and Stanford University. Wastewater from these communities is treated by the RWQCP prior to discharge to the Bay. Stormwater runoff in the RWQCP s service area flows untreated to the Bay. Wastewater and stormwater discharges are both regulated via National Pollutant Discharge Elimination System (NPDES) permits issued by the San Francisco Bay Regional Water Quality Control Board. Given the strict permit requirements, Palo Alto must explore all feasible methods of reducing its metals and toxic organic pollutant discharges to San Francisco Bay, including industrial pretreatment and pollution prevention. The RWQCP began the Pollution Prevention Program in This document describes the pollutant priorities, sources of those pollutants, pollution prevention progress made in 2008, and the tentative plan for the coming year. Over the past few years, the City of Palo Alto staff has created extremely effective pollution prevention programs for mercury, pesticides, copper and trash. In 2009, the pollution prevention priorities for the RWQCP will continue to include: Mercury (Section 4) Pesticides (Section 5) Copper (Section 6) Trash (Section 7) In addition, the RWQCP will continue to implement programs that address other pollutants (Section 8) and programs that address multiple pollutants (Section 9). We will continue to study the sources and prevention options for some emerging contaminants (Section 10). Table 1 presents the Pollution Prevention highlights for 2008 and the major plans for ii

5 Table Program Accomplishments and 2009 Plans (for details, see referenced section) Pollutant 2008 Accomplishments 2009 Goals Evaluation Criteria Mercury Section 4 Confirmed that 133 dental offices are maintaining amalgam separators based on annual amalgam inspection report. Continue to inspect dental offices to verify compliance with best management practices and amalgam separator maintenance. Continue to provide electronic and phone technical support to local dentists regarding maintenance of amalgam separators. Pesticides Section 5 Metals (copper, zinc, and other non-mercury metal) Sections 6 & 8 Updated Mercury Loading Estimate (previous Estimate was for 2000) to reflect new loadings after full implementation of Dental Amalgam Program. Dental office mercury loading, as a percent age of the total, decreased from 56% to 29%, and it is estimated that 11 pounds per year of mercury that would have been discharged to the sanitary sewer is now captured by amalgam separators. RWQCP laboratory switched to a mercury-free Chemical Oxygen Demand (COD) test methodology. COD vials containing significant concentrations had been used for about 350 COD tests per year. Performed annual evaluation of City s pest management and pesticide use. Reduced active ingredient use by 153 lbs (36%) and ecotoxic pesticides use by 83lbs 59% from 2007 to 2008 due to less toxic fungicide use, continued increase mulching to reduce herbicides, techniques to reduce aphids in City trees, and ongoing efforts to control ants, mice and rats using hygiene and exclusion methods, and extensive trapping for gophers and ground squirrels. Natural pest population cycles may cause increases in future years, but the successes this year are attributed in large part to staff s IPM efforts. Palo Alto s contractor updated the copper presentation and presented at the plumbers union in San Mateo to educate plumbers regarding copper pollution from pipe corrosion. After consulting with businesses regulated by the Industrial Waste Program, drafted ordinance provision restricting molybdenum use in cooling systems and developed a brochure on cooling system additive restrictions in the RWQCP service area. Continue to assist with Santa Clara County Household Hazardous Waste Program to expand light collection throughout Santa Clara County, by conducting public outreach via Santa Clara Valley Urban Runoff Program. Evaluate previous year s pesticide use and pest management strategies. Focus on perimeter trapping to reduce rodenticide use. Further research and if appropriate advocate and publicize the use of bee tunnels. Investigate possibility of having a pesticide-free park or demonstration site in the City. Continue IPM partnership for residential outreach, including point-of-sale educational materials at hardware stores and training program for store employees. Continue to facilitate outreach from member BAPPG agencies to regional unions and engineering groups. Seek partnership with Green Plumbers USA to educate plumbers on how to reduce copper pollution from entering the bay. Adopt ordinance provision restricting molybdenum use in cooling systems and conduct outreach to cooling system owners, contractors, and treatment chemical vendors. Percentage of dental offices in compliance with amalgam separator maintenance and best management requirements. Number of fluorescent lamps collected and expansion of collection sites. Produced annual IPM Program report analyzing pesticide use trends and toxicity. Expansion of trapping and reduction of rodenticide use. Research results and outreach accomplished. Success in establishing a pesticide-free park. Sales data is not available to show trends but increased shelf space and continued interest and expanding participation by large chain stores is occurring. Number of plumbers and engineers contacted at association meetings throughout the BAPPG service area. Adoption of ordinance and completion of outreach. Molybdenum concentrations in RWQCP influent and incinerator ash. Clean Bay Pollution Prevention Plan 2008 Page iii of 107

6 Table Program Accomplishments and 2009 Plans (continued) (for details, see referenced section) Pollutant 2008 Accomplishments 2009 Goals Evaluation Criteria Trash- Section 7 Participated in a tarp give-away program with the Palo Alto Landfill to encourage people to cover vehicle loads and reduce windblown trash. Adopt an ordinance restricting single-use checkout bags at large grocery stores. Compliance with ordinance requirement. Salinity Section 8 FOG- Section 8 School Outreach Section 9 Emerging Contaminants Section 10 Participated in two creek cleanup days, organizing a new cleanup site for one of the two events. On just one of these cleanup days, 300 Palo Alto volunteers cleaned more than 4.5 linear miles to remove 7,000 pounds of trash and 1,075 pounds of recyclables at 3 locations in the creeks. Conducted trash assessments at 16 local trash hot spots. Completed analysis of salinity (total dissolved solids, sodium, and chloride) in RWQCP partner trunklines, influent, and recycled water. Conducted 33 full FOG inspections and 374 stormwater inspections at Food Service Establishments, 24 notices of noncompliance were issued. In 2007/2008 school years, RWQCP school program visited 138 classrooms, which reached approximately 3,201 students at twenty-three schools. Expanded our microbes in sewage program to educate 65 seventh graders in seven schools in our service area. Since 2005, RWQCP staff collected over 2,798 lbs of pharmaceutical waste throughout our service area. In 2008, more than 70% of the collected medications were from the PAMF site. Assisted with the development of the statewide No Drugs Down the Drain event and helped organize a regional press event. Adopt an ordinance restricting the use of expanded polystyrene disposable food service containers by Food Vendors. Assist City of Mountain View as needed to obtain general permit and redirect saline groundwater discharges to tidal areas of Stevens Creek and Charleston Slough. Compare before and after salinity profile in MV1 trunkline using upstream and downstream salinity species sampling and continuous conductivity monitoring. Work with and encourage City of Mountain View to identify and repair salinity infiltration into MV1 trunkline. Adopt new Sewer Use Ordinance provisions developed in 2008 to enhance sewer and storm drain pollution prevention requirements for food service establishments. Inspect one-third of Palo Alto food service establishments (as follow up and enforcement actions allow) Continue existing successful outreach programs in elementary, middle, and high school classes. Develop a new 2 nd grade program that supports the changes in the science curriculum and still delivers our P2 messages. This might include a greater emphasis on trash and the impact of trash on the environment. In school year, goal is to present the Microbes In Sewage program to every seventh grade class in our service area. Continue to lead BAPPG to developing a long-term solution to residential disposal of pharmaceutical waste. Develop a pilot pharmaceutical collection program for residents at pharmacies. Continue to collect pharmaceuticals at the wastewater treatment plant. In March 2009, RWQCP staff will co-lead a BAPPG training to educate hospital staff regarding the information in the guidance document. Completion of outreach to food vendors preliminary to 2010 effective date of proposed restriction. Rerouting of Mountain View well discharges from the sanitary sewer Completion of analysis Reductions in Mountain View trunkline and recycled water TDS, conductivity, sodium, and chloride Adoption of new ordinance provisions Number of restaurants inspected; percent compliance with ordinance requirements. Number of students and classrooms reached. Completion of new 2 nd grade program. Number of students and classrooms reached. Progress towards developing a long-term disposal option. Amount of pharmaceuticals collected. Number of attendees; Number of hospitals receiving guidance document iv

7 Table of Contents EXECUTIVE SUMMARY...II LIST OF FIGURES...4 SECTION 1: INTRODUCTION...5 SECTION 2: BACKGROUND...9 A. THE RWQCP AND SERVICE AREA...9 B. REGULATORY CONTEXT RWQCP Discharge Permit Stormwater Discharge Permit...11 C. POLLUTANTS OF CONCERN...11 D. CITY OF PALO ALTO S SUSTAINABILITY AND CLIMATE ACTION PLAN Sustainability Climate Action Plan...13 E. TARGET AUDIENCES...14 F. PLAN MODIFICATION...15 SECTION 3: PROGRAM EVALUATION SUMMARY...16 A. RWQCP REGIONAL COMMITMENT...16 B. PROGRAM AWARDS...16 C. PROGRAM EVALUATION CRITERIA...19 SECTION 4: MERCURY PROGRAM...21 A. WASTEWATER SOURCES...22 B. STORMWATER SOURCES...23 C. RESIDENTIAL POLLUTION PREVENTION PLAN Residential Fluorescent Lamp Recycling Universal Waste and Producer Responsibility Residential Thermometer and Thermostat Drop-off Program Residential Mercury Program Evaluation...28 D. DENTAL OFFICE SOURCE CONTROL Dental Program Implementation Ongoing Dental Program Dental Program Evaluation Educating Other Bay Area Wastewater Agencies...35 E. POTW MERCURY USE INVESTIGATION...35 F. POTW MERCURY REPLACEMENT EFFECTIVENESS RWQCP mercury replacement COD laboratory procedures Identification of sources and alternatives...37 G. MERCURY PROGRAM EVALUATION...38 SECTION 5 : PESTICIDE PROGRAM...42 A. WASTEWATER SOURCES...42 B. STORMWATER SOURCES...42 C. PESTICIDE POLLUTION PREVENTION PLAN Reducing City of Palo Alto Pesticide Toxicity and Use City Pesticide Use Program Evaluation Residential Pesticide Outreach Residential Outreach Program Evaluation...50 SECTION 6: COPPER PROGRAM...52 A. WASTEWATER SOURCES...52 Clean Bay Pollution Prevention Plan 2009 Page 1 of 107

8 B. STORMWATER SOURCES...52 C. POLLUTION PREVENTION PLAN Plumbing Practices Copper Roofing Materials Metal Finishing Facilities...57 D. CONTINGENCY PLAN...58 E. PROGRAM EVALUATION Elevated Copper in Influent Elevated Copper in Incinerator Ash...64 SECTION 7 : TRASH PROGRAM...66 A. STORMWATER SOURCES...66 B. TRASH POLLUTION PREVENTION PLAN Comprehensive Reusable Bag Program Proposed Ordinance to Restrict Expanded Polystyrene Disposal Food Containers Tarp Program at the Landfill Participation in Creek Cleanups Base Programs for Trash Control...72 C. TRASH PROGRAM EVALUATION Participation in Creek Cleanups Trash Assessments...72 SECTION 8: PROGRAMS FOR OTHER POLLUTANTS...73 A. DIOXINS AND FURANS PROGRAM City Paper Purchasing Biodiesel Purchases Dioxins and Furans Program Evaluation...76 B. FATS, OILS AND GREASE Implementation of a FOG Control Program Source Control Food Service Establishment Inspections Inspection Highlights of Food Service Establishments Outreach Regional FOG Groups Goals for the FOG Control Program...81 C. SILVER HAULING PROGRAM...84 D. MOLYBDENUM Molybdenum in RWQCP Incinerator Ash Molybdenum Source Reduction Plan...85 E. SALINITY Salinity Reduction Plan...86 SECTION 9: PROGRAMS ADDRESSING MULTIPLE POLLUTANTS...90 A. SCHOOL OUTREACH PROGRAM Elementary and Middle School Program Highlights Elementary and Middle School Program Evaluation High School Program Highlights Plans for School Year...93 B. VEHICLE SERVICE RECOGNITION PROGRAM Annual tasks for Vehicle Service Facility...95 C. VEHICLE SERVICE RECOGNITION PROGRAM EVALUATION...96 D. CLEAN BAY AD CAMPAIGN...96 E. GREENLIGHT EARTH DAY FILM FESTIVAL...97 F. HOUSEHOLD HAZARDOUS WASTE...97 G. LESS TOXIC PRODUCTS IN THE WORKPLACE...99 H. LAUNCH OF GREEN PROCUREMENT PROGRAM SECTION 10: PROGRAMS FOR EMERGING POLLUTANTS Clean Bay Pollution Prevention Plan 2009 Page 2 of 107

9 A. PHARMACEUTICALLY ACTIVE COMPOUNDS Evaluation of Pharmaceutically Active Compounds in San Francisco Bay and RWQCP Influent and Effluent Hospital Disposal of Pharmaceutical Waste Residential Disposal of Pharmaceutical Waste Residential Disposal of Pharmaceutical Waste Program Evaluation B. TRICLOSAN C. ALKYLPHENOL ETHOXYLATES D. PERFLUORINATED ORGANIC COMPOUNDS E. NITRO-MUSKS F. POLYBROMINATED DIPHENYL ETHERS G. N-NITROSO DIMETHYLAMINE (NDMA) REFERENCES GLOSSARY APPENDICES APPENDIX A EFFLUENT LIMITATIONS APPENDIX B PUBLIC CONTACTS IN APPENDIX C SELECTED FACTSHEETS, NEWSLETTER ARTICLES AND UTILITY BILL INSERTS APPENDIX D FOG INSPECTION FORM List of Tables TABLE PROGRAM ACCOMPLISHMENTS AND 2008 PLANS (FOR DETAILS, SEE REFERENCED SECTION)...III TABLE 1-1. SUMMARY OF RWQCP POLLUTION PREVENTION PROGRAM...6 TABLE 2-1. POLLUTANTS OF CONCERN FOR THE RWQCP AND PALO ALTO S STORMWATER SYSTEM...12 TABLE 3-1. SUMMARY OF RWQCP REGIONAL COMMITMENTS...17 TABLE 4-1. MERCURY POLLUTION PREVENTION PLAN...24 TABLE 4-2. RESULTS FROM PRODUCT DROP-OFF PROGRAMS (THROUGH DECEMBER 31, 2008)...28 TABLE 4-3. INVENTORY RESULTS AND CURRENT PLANS...37 TABLE 4-4. SUMMARY OF THE AVERAGE MERCURY CONCENTRATION BEFORE AND AFTER THE INSTALLATION OF AMALGAM SEPARATORS FOR INFLUENT, SLUDGE CAKE AND EFFLUENT...38 TABLE 5-1. POLLUTION PREVENTION PLAN FOR PESTICIDE REDUCTION...44 TABLE 6-1. COPPER POLLUTION PREVENTION PLAN...55 TABLE 6-2. PRELIMINARY COPPER CONTINGENCY PLAN...58 TABLE 7-1. POLLUTION PREVENTION PLAN FOR TRASH REDUCTION...70 TABLE 8-1. CURRENT PALO ALTO PAPER PURCHASES...73 TABLE 8-2. ADDITIONAL POLLUTION PREVENTION PRIORITIES...74 TABLE 8-3. CITY OF PALO ALTO PURCHASES OF DIESEL AND B100 (100% BIODIESEL WHICH IS LATER BLENDED WITH TRADITIONAL DIESEL FOR A 20/80 BLEND)...77 TABLE 8-4. SUMMARY OF FOG FSE INSPECTIONS FOR & 2009 GOALS...82 TABLE 9-1. ADDITIONAL MULTIPLE POLLUTANTS PRIORITIES...91 Clean Bay Pollution Prevention Plan 2009 Page 3 of 107

10 TABLE 9-2. SUMMARY OF SCHOOL SERVICES...94 TABLE 9-3. POUNDS OF WASTE COLLECTED BY PALO ALTO HOUSEHOLD HAZARDOUS WASTE PROGRAM...99 TABLE EMERGING CONTAMINANTS POLLUTION PREVENTION PLAN List of Figures FIGURE 2-1. REGIONAL WATER QUALITY CONTROL PLANT SERVICE AREA...10 FIGURE 4-1. ESTIMATED CONTRIBUTIONS OF MERCURY TO THE SAN FRANCISCO BAY...21 FIGURE 4-2. RWQCP MERCURY LOADING ESTIMATE, FIGURE 4-3. RWQCP MERCURY LOADING ESTIMATE, FIGURE 4-4. RWQCP MERCURY LOADING ESTIMATE, FIGURE 4-5. RESULTS OF PALO ALTO DENTAL CLEANOUT AND SEWER TRUNKLINE ANALYSES...34 FIGURE 4-6. SOME OF THE MERCURY ALARM SWITCHES THAT WERE REMOVED FROM SERVICE OR PULLED FROM STORAGE AT THE RWQCP IN FIGURE 4-7. RWQCP MERCURY INFLUENT CONCENTRATIONS: FIGURE 4-8. RWQCP AVERAGE MERCURY INFLUENT CONCENTRATIONS: FIGURE 4-9. RWQCP MERCURY EFFLUENT CONCENTRATIONS: FIGURE RWQCP AVERAGE MERCURY EFFLUENT CONCENTRATIONS: FIGURE RWQCP SLUDGE CAKE MERCURY CONCENTRATION: FIGURE RWQCP AVERAGE MERCURY SLUDGE CAKE CONCENTRATIONS: FIGURE 6-1. ESTIMATED CONTRIBUTIONS OF COPPER SOURCES TO THE RWQCP, FIGURE 6-2. URBAN STORMWATER COPPER SOURCES...53 FIGURE 6-3. COPPER INFLUENT LOADING: FIGURE 6-4. COPPER EFFLUENT LOADING: FIGURE 6-5. RWQCP INFLUENT AND INDUSTRIAL COPPER MASS LOADING, AND INDUSTRIAL PROCESS FLOW: 2000, 2001, 2005, 2006, AND FIGURE 6-6. RWQCP INFLUENT COPPER AND SFPUC LANGELIER INDEX...63 FIGURE 6-7. RWQCP QUARTERLY AVERAGE TTLC AND STLC COPPER IN ASH, ANNUAL AVERAGE INFLUENT COPPER ( )...65 FIGURE 8-1. AVERAGE TOTAL DISSOLVED SOLIDS IN VARIOUS TRUNKLINES...87 FIGURE 8-2. AVERAGE FLOWRATE BY TRUNKLINE...88 FIGURE 8-3. AVERAGE TDS MASS BY TRUNKLINE...88 FIGURE SUMMARY OF PHARMACEUTICALS COLLECTED THROUGH PALO ALTO S PROGRAM Clean Bay Pollution Prevention Plan 2009 Page 4 of 107

11 Section 1: Introduction The City of Palo Alto operates the Regional Water Quality Control Plant (RWQCP), a wastewater treatment plant, for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo Alto, and Stanford University. Wastewater from these communities is treated by the RWQCP prior to discharge to the Bay. Stormwater runoff in Palo Alto washes pollutants from streets, gutters, and all other paved and covered areas to storm drains and creeks, which flow untreated to the Bay. Some stormwater flows into or infiltrates sanitary sewer lines, becoming a source of wastewater pollution. Nonrainwater discharges to streets and storm drains may be included in such stormwater inflow and infiltration (I&I), through intentional waste dumping and unintentional pollutant discharges through spills and ordinary activities. Through the RWQCP and the Santa Clara Valley Urban Runoff Pollution Prevention Program, all of the cities in the RWQCP service area cooperate to conduct stormwater protection programs to protect the Bay. The RWQCP and stormwater discharges are both regulated via National Pollutant Discharge Elimination System (NPDES) permits issued by the San Francisco Bay Regional Water Quality Control Board. Given the strict permit requirements imposed on the RWQCP, Palo Alto must explore all feasible methods of reducing its metals and toxic organic pollutant discharges to San Francisco Bay. Since 1990, the RWQCP and the City of Palo Alto have implemented an aggressive water pollution prevention program addressing wastewater and stormwater discharges to San Francisco Bay. After initially focusing on major industrial facilities, the RWQCP expanded its regulatory and informational programs to include many commercial and residential activities. Innovative strategies adopted by the RWQCP include integrating pollution prevention into permit requirements, developing incentive programs for businesses, and using creative methods to encourage pollution prevention through public outreach. Table 1-1 summarizes the Program s highlights through This document describes the RWQCP s plan to reduce the toxic pollutant levels in wastewater discharges from the six-community area. The plan focuses on pollution prevention because this approach is generally environmentally beneficial and cost effective. Section 2 provides background information, including the regulatory context and pollutant priorities for Section 3 summarizes the program evaluation techniques. Sections 4 through 10 present pollutant-specific programs, and programs that address multiple pollutants. Clean Bay Pollution Prevention Plan 2009 Page 5 of 107

12 Table 1-1. Summary of RWQCP Pollution Prevention Program Year Actions 1989 Pollution Prevention Program initiated 1990 Storm drain permit issuance--began to direct wastewater discharges to sewer Increased industrial enforcement Large dischargers required to prepare pollution prevention plans 1991 Silver reduction program initiated Community outreach on copper-based root control products 1992 Clean Bay Business Program for vehicle service facilities started Local ban on sale and use of copper-based root control products 1993 Cooling water systems program Laboratory program Education on selenium toner Clean Bay Business Program for hardware stores and plumbers initiated Sewer line through Superfund site begins to receive high levels of arsenic 1994 Regional outreach on copper-based root control products Pool, spa and fountain program started Machine shop program started Automobile parts stores Clean Bay Business Program initiated 1995 Reduced local discharge limit for nickel Expanded cooling water systems efforts Regional mobile cleaner outreach Hospital and medical facility program Sewer line through Superfund site repaired Copper dumping incident Final ban on sale of lead-containing gasoline takes effect Intensive enforcement on silver program, vehicle service facility program 1996 Regional ban on copper-based root control products Regional mobile cleaner certification Metal finishing program Vehicle Clean Bay Business program five-year anniversary; 88% participation 1997 Auto body shop BMPs distributed School program enhanced Record 92% of vehicle service facilities become Clean Bay Businesses 1998 Laboratory improves mercury analysis IPM Partnership launched Began collection of mercury thermometers and other products; collected 34 pounds mercury Printers and dentists receive BMPs 1999 Launched mercury thermostat drop-off program Began education campaign regarding residential woodsmoke pollution Expanded the IPM Partnership program 2000 City of Palo Alto adopted a Mercury and Dioxin Elimination Policy; participating in and funding ABAG dioxin group Initiated dental stakeholder group regarding amalgam management Drafted mercury product legislation Piloted a residential drop-off program for fluorescent lamps City of Palo Alto adopted fireplace ordinance Clean Bay Pollution Prevention Plan 2009 Page 6 of 107

13 Table 1-1. Summary of RWQCP Pollution Prevention Program Year Actions 2001 Initiated and drafted SB 633, the CA Mercury Reduction Act Conducted mercury audits at three local hospitals Successful expansion of pilot residential recycling of fluorescent lamps at 5 hardware stores and at RWQCP Led BAPPG in creation of an inspection checklist for dental offices and a set of PowerPoint presentations for dental community outreach Began using 20% biodiesel in City s diesel landfill and golf course equipment Began purchasing process-chlorine-free office paper and letterhead and unbleached paper towels Completed the City pesticide policy and implementation plan Assisted the Palo Alto Unified School District (PAUSD) comply with the Healthy Schools Act 2002 The Mercury Elimination Policy resulted in new City purchasing specifications to require lowmercury lamps Created first annual report of City pesticide use Initiated copper pollution prevention program, educating local plumbers and designers about copper pipe corrosion. Ordinance passed that included: Lowered the mercury limit for industrial dischargers Prohibited sewer disposal of zinc-containing floor waxes Banned new and replaced copper roofs Required covered carwash facility for new and remodeled buildings with 25 units or more Added boilers and heat exchangers to the requirement of wastewater collection and analysis if one is doing scouring and cleaning. Led Emerging Contaminants Workgroup of the Watershed Management Initiative to compile and finalize an Endocrine Disrupting Compounds Information Sheet. Distributed a drug free sewers utility bill notice to describe proper disposal of expired prescriptions 2003 Completed work plan for an advanced mercury source control study that focuses on (1) improving amalgam collection and pretreatment at dental offices and (2) continuing identification of on-site RWQCP mercury uses and alternatives. Palo Alto has developed seven IPM plans and extensive training for weeds, gophers, ground squirrels, yellow jackets, ants, rats, and mice. From inception through 2003, the fluorescent lamp program collected over 7,575 lamps at four drop off sites in our service area. In the 2002/2003 school year, RWQCP school program visited 151 classrooms which reached approximately 3,682 students. This was a 41% increase over the previous year. Palo Alto staff educated approximately 350 people regarding Endocrine Disruptor Compounds by presenting at seven different conferences/ meetings throughout California 2004 Palo Alto and Mountain View adopted dental amalgam pretreatment ordinances requiring dentists to install amalgam separators by March 31, City of Palo Alto light collection program was expanded throughout Santa Clara County and is now operated by the Santa Clara County Household Hazardous Waste Program. Implemented two new successful, non-chemical ground squirrel control strategies: the use of shade cloth along the municipal golf course fence line to deter ground squirrel population expansion, and a new trap design which captures up to four ground squirrels per trap. The traps have proven immediately successful. Published: Tracking the Fate of Polybrominated Diphenyl Ethers releases in a Wastewater Treatment Plant Effluent, Palo Alto, California, North, K.D.; Environ Sci. Technol.; 2004; 38(17); , concluding that the RWQCP discharges 2 pounds per year of PBDEs to the Bay. Clean Bay Pollution Prevention Plan 2009 Page 7 of 107

14 Table 1-1. Summary of RWQCP Pollution Prevention Program Year Actions 2005 Dentists required to install amalgam separators in service area by March 31, 2005; 98% of dentists complied. City of Palo Alto collected 8,481 pounds of fluorescent lights at the recycling center. Analyzed City pesticide use; designed a prioritization process for annual workplan; drafted IPM Scope of Services for structural pest control contract Made pesticide use reporting system for City staff available electronically and integrated database with GIS to map pesticide use Served as chair of the Emerging Contaminants Workgroup of the Santa Clara Basin Watershed Management Initiative, which in 2005 produced two white papers titled Discussion of Pharmaceutical Disposal to Sewer Systems and Environmental Emergence of Triclosan In 2004/2005 school years, RWQCP school program visited 151 classrooms, which reached approximately 4025 students City of Palo Alto led a BAPPG/CWEA Dental Amalgam Training that was attended by approximately 90 people. Inspected 113 of 300 food service facilities within the first 6 months of the program. Co-led a regional pharmaceutical disposal event at 39 locations throughout the Bay Area that diverted over 3,500 lbs of pharmaceutical waste. In Palo Alto, collected approximately 960 lbs of pharmaceuticals at pharmacies, local senior centers, and the wastewater treatment plant within the RWQCP service area. Authored a report titled Report on the San Francisco Bay Area s Safe Medicine Disposal Days 2007 In fiscal year collected 270 pounds of thermometers and thermostats and 13,498 lbs of fluorescent lights. Hired and began using and EcoWise Certified IPM contractor for City facilities to ensure reduced dependence on pesticide use and discontinued use of structural pesticides associated with water quality impacts and ecotoxicity. In 2006/2007 school years, RWQCP school program visited 163 classrooms, which reached approximately 3,961 students at twenty-six schools. Expanded our microbes in sewage program to educate all seventh graders in our service area. Clean Bay Pollution Prevention Plan 2009 Page 8 of 107

15 Section 2: Background A. The RWQCP and Service Area The RWQCP treats domestic and industrial wastewater from northern Santa Clara County and one city in San Mateo County. The service area, presented in Figure 2-1, includes the majority of East Palo Alto (the portion served by the East Palo Alto Sanitary District), Los Altos, Los Altos Hills, Mountain View, Palo Alto, and Stanford University. The treatment plant is on the shore of San Francisco Bay in Palo Alto adjacent to the Palo Alto Baylands Preserve. The RWQCP discharges treated wastewater effluent to a man-made channel, which empties into the southern reach of San Francisco Bay. Approximately 220,000 people live in the RWQCP service area. Of the wastewater flow to the RWQCP, about 60 percent is estimated to come from residences, 10 percent from industries, and 30 percent from commercial businesses and institutions. In 2008, the plant treated an average of 22.3 million gallons per day (MGD) of wastewater, well below its permitted dry-weather capacity of 39 MGD. The RWQCP uses physical, biological, and chemical treatment to remove about 99 percent of the solids and organic materials from influent wastewater. Despite the RWQCP s excellent performance in removing most pollutants from the wastewater, it has come under increasing scrutiny in regards to its discharge of metals and toxic organic pollutants. While the RWQCP s primary, secondary, and advanced treatment steps remove most of the metals found in wastewater prior to discharge, the RWQCP (like other municipal wastewater treatment plants) was not specifically designed to remove metals or toxic organic pollutants from wastewater. Stormwater runoff from the RWQCP service area, as well as runoff from the remainder of the Santa Clara Valley, flows to the southern reach of San Francisco Bay. The amount of runoff discharged to the Bay varies from year to year depending on the total rainfall. Unlike wastewater discharged to the sewer system, stormwater runoff does not receive any treatment prior to discharge to local creeks and the Bay. Runoff not absorbed through unpaved surfaces carries pollutants, including metals and toxic organic pollutants, directly into the Bay. Clean Bay Pollution Prevention Plan 2008 Page 9 of 124

16 Figure 2-1. Regional Water Quality Control Plant Service Area B. Regulatory Context In compliance with the requirements of the Federal Clean Water Act (CWA) and the California Porter-Cologne Water Quality Control Act, the San Francisco Bay Regional Water Quality Control Board (Regional Board) adopts and implements water quality criteria for San Francisco Bay. The water quality criteria are contained in the San Francisco Bay Water Quality Control Plan (Basin Plan). Additional water quality criteria applicable to San Francisco Bay and other California water bodies have been published by the U.S. Environmental Protection Agency (EPA) in the California Toxics Rule (May 18, 2000). Section 303(d) of the CWA requires states to identify those waters where water quality criteria are not attained despite the implementation of enforceable effluent limits. The states must also rank these impaired water bodies by priority, taking into account the severity of the pollution and Clean Bay Pollution Prevention Plan 2008 Page 10 of 124

17 the uses to be made of the waters. Lists of prioritized impaired water bodies are known as the 303(d) lists and must be submitted to EPA every two years. 1. RWQCP Discharge Permit In August 2003, the Regional Board issued a NPDES permit to the RWQCP. The permit became effective on November 1, The permit includes effluent limitations for conventional pollutants (e.g, biochemical oxygen demand, ammonia, suspended solids, chlorine residual, enterococci), effluent toxicity, and toxic pollutants. Similar permits were issued for Sunnyvale and San Jose. The requirements for the three Lower South Bay treatment plants were negotiated through the Santa Clara Basin Watershed Management Initiative, a stakeholder group, which includes government agencies, businesses, and environmental organizations. Three key issues were negotiated, which include: 1. Mercury Discharge Limits In an effort to control mercury releases to San Francisco Bay the Regional Board staff had proposed very stringent limits, which would not have allowed the full utilization of the design capacity of the RWQCP. An alternative approach was negotiated which calls for Palo Alto to work with dental offices to install new mercury-reducing technology. 2. Pathogens New limitations on pathogenic (disease causing) organisms were negotiated which target human pathogens more precisely, and which reduce chlorine usage by approximately one-half. 3. Cyanide Limits Compliance with the initially proposed cyanide limits would not have been possible due to complications with the analytic method for cyanide. Understanding that the test method was not really detecting toxic forms of cyanide, all parties agreed on interim limitations that are achievable. Appendix A lists the effluent limits in the permit. This permit is scheduled to be renewed in April Stormwater Discharge Permit In February 2001, the Regional Board renewed the permit for stormwater runoff discharge to the Bay. The City of Palo Alto, along with 14 other local governments in Santa Clara Valley, collaboratively operate the Santa Clara Valley Urban Runoff Pollution Prevention Program (Urban Runoff Program) to coordinate stormwater permit requirements. C. Pollutants of Concern Table 2-1 presents the pollutants of concern for wastewater and stormwater in the RWQCP service area. While the list is primarily based on the CWA 303(d) listings for South San Francisco Bay and local urban creeks, the RWQCP has identified three additional reasons for prioritizing pollutants in wastewater: Sludge Management Limits The pollutant is subject to metal concentration limits for the land disposal of incinerated sludge ash. Air Emissions The pollutant is a significant contributor to the air emissions health risk from the RWQCP or is an air pollutant recognized by the U.S. EPA as impairing a local creek or the Bay. (In 1999 and 2000 the sludge incinerator was rehabilitated to improve destruction of toxic Clean Bay Pollution Prevention Plan 2008 Page 11 of 124

18 organics and to reduce metal emissions, therefore, the magnitude of this contribution is considerably diminished for all pollutants except mercury.) Recycled Water The pollutant interferes with the use of or lowers the quality of the RWQCP s recycled water for irrigation or other uses. Table 2-1. Pollutants of Concern for the RWQCP and Palo Alto s Stormwater System Pollutant Copper Dioxins Mercury Molybdenum Pesticide toxicity PCBs Trash Salinity Reason for Selection ffluent limitation; sludge management limits U.S. EPA 303(d) listing; air emissions U.S. EPA 303(d) listing; effluent limitation; air emissions sludge management limits U.S. EPA 303(d) listing U.S. EPA 303(d) listing U.S. EPA 303(d) listing (proposed) recycled water In its role as a participant in the Urban Runoff Program, the City of Palo Alto will support work on all metals listed in the Metals Control Measures Plan, but will focus its pollution prevention efforts on the above local list of pollutants of concern. Other factors considered in setting program priorities include: Compliance with permit requirements Previous actions to reduce discharges of the pollutant The ability and authority of the RWQCP to achieve discharge reductions of the pollutant U.S. EPA and State priorities that may revise the water quality standards in the future. On the basis of such evaluations, the pollution prevention priorities for the RWQCP and the Palo Alto stormwater program are: Reducing mercury discharges (Section 4) Reducing pesticide releases (Section 5) These pollutants are the primary focus of this pollution prevention plan. In addition, the RWQCP will continue to implement programs that address copper discharges (Section 6), other pollutants of concern (Section 7), and multiple pollutants (Section 8). A new focus in 2008 will be reducing the use of molybdenum in cooling systems. The RWQCP will also continue to study the sources and prevention options for some emerging contaminants, with a focus on development of takeback programs for unwanted and expired residential pharmaceuticals (Section 9). D. City of Palo Alto s Sustainability and Climate Action Plan 1. Sustainability In April of 2001, the City of Palo Alto adopted a policy reflecting the City's commitment to sustainability. The first policy focused primarily on the environmental aspects of sustainability and was revised in June 2002 to reflect the economic and social equity components of Clean Bay Pollution Prevention Plan 2008 Page 12 of 124

19 sustainability (visit The policy resulted in a special assignment position in the City Manager's office filled half-time by two staff one from the RWQCP. This opportunity helped leverage source control project goals of dioxins reduction and less toxic product alternatives. Specific accomplishments include: Palo Alto became the first city government to achieve the Association for Bay Area Governments Green Business Certification (2002) across all City operations, in addition to independent certification that same year for the City s print shop (four of its most toxic printing chemicals were switched to less-toxic alternatives and soy inks were substituted for petroleum inks). A switch to process-chlorine-free letterhead for Citywide use and less-toxic printing chemicals Converting to unbleached or alternatively bleached bathroom papers and less-toxic custodial chemicals In 2005, Environmental Compliance adopted the Sustainable Silicon Valley Pledge to reduce the City of Palo Alto s carbon dioxide Emissions by 20% by RWQCP staff leads the City s Green Procurement Policy and program efforts and assists with Climate Protection Plan development and implementation. Additional efforts In 2006, the City adopted a Zero Waste Policy and is implementing actions per its operations plan to expand HHW collection and other waste reduction efforts In 2007, the City was recertified as a Bay Area Green Business across all operations by the Association of Bay Area Governments. 2. Climate Action Plan To address global warming the City has drafted a Climate Action Plan which was adopted by City Council in December of Goals are to work within City operations and with the community to reduce: By 2009, City operation emissions by 5% from 2005 emission levels for a total reduction of 3,200 metric tons CO2e By 2012, City and Community emissions by 5% from 2005 levels for a total reduction of 40,000 metric tons of CO2e By 2020, the City and Community emissions by 15% from 2005 levels, equal to 119,000 metric cons of CO2e and bring the community in line with State reduction goals. City of Palo Alto has already been reaching far to help accomplish these goals. In-house efforts: Between 1995 and 2000, the City of Palo Alto reduced its emissions by 15% through innovative programs in energy efficiency, green energy production, and solar programs, among other initiatives. The City has also been recognized as the 2007 EPA Landfill Methane Outreach Program (LMOP) Energy Partner of the Year, and as a Climate Action Leader with the California Climate Action Registry (which required the completion and certification of the City s baseline greenhouse gas emission data). BRAD, what about info here about Plant CO2 reductions? Clean Bay Pollution Prevention Plan 2008 Page 13 of 124

20 Residential programs: In each of the past two years, Palo Alto has achieved the highest level of customer participation of any voluntary green power program in the United States and has been recognized as a US EPA Green Power Community, City-owned Utilities department is on track to meet the Council-adopted Renewable Portfolio Standard of, 30% renewables by 2012 and 33% by In addition the City has aligned efforts with regional and national initiatives to reduce Greenhouse Gas emissions via: The adoption of the Sustainable Silicon Valley Pledge to reduce the City s CO2 emissions by 20% by The reduction will be achieved by substituting landfill gas for a large portion of the natural gas used at the RWQCP incinerator, improving ventilation and boiler efficiencies at City Hall, and purchasing higher percentages of renewable-based electricity. The Mayor s signature onto the U.S. Mayors Climate Protection Agreement E. Target Audiences Each of the pollutant-specific sections includes a table summarizing the RWQCP pollution prevention plan for that pollutant. For each pollutant of concern, the summary table has been divided into three general target audiences: Government agencies Industrial and commercial Residential The government target audience has multiple components because the RWQCP is operated by one city, Palo Alto, for a service area of multiple cities. A municipal audience may be the jurisdiction of Palo Alto, other partner cities in the service area, the RWQCP, or other agencies, such as the Santa Clara Valley Water District. When the source is identified within the City of Palo Alto or RWQCP jurisdiction, RWQCP staff collaborate with other City departments, such as Purchasing, Facilities, or Utilities, to review available alternatives and develop a plan for reducing or eliminating that pollutant source. Communication between multiple departments is enhanced by the presence of a unifying policy. Many times, pollution prevention opportunities for the City of Palo Alto are also relevant to the other service-area cities. In that case, RWQCP staff communicates the activity and its alternatives to the other cities, urging them to adopt similar practices and offering to provide technical assistance. Industrial pollution prevention programs operate in conjunction with the RWQCP Pretreatment Program, which monitors and sets requirements for wastewater discharges from major industry and large institutions. The RWQCP also permits certain non-industrial facilities, such as vehicle service facilities, machine shops, laboratories, hospitals, photo processors, and x-ray developers. The Pretreatment Program Annual Report (Palo Alto RWQCP, February 2008) provides details of industrial facility permitting, inspection, monitoring, and enforcement. At non-permitted facilities, educational materials, incentives, and site visits are used to inform facilities of ordinance requirements. Clean Bay Pollution Prevention Plan 2008 Page 14 of 124

21 RWQCP community education programs address water pollution associated with activities conducted by residents and employees. F. Plan Modification The Clean Bay Plan is intended to be flexible and subject to change based on: Annual evaluation and planning Ongoing program re-evaluation based on information obtained during the plan year New information that alters program priorities While the plan document will only be revised annually, the programs and other activities described will be adjusted as required to address new information, identified opportunities, technical requirements, and external changes. For example, if a major new source of copper (such as a commercial business category) is identified, the RWQCP will re-evaluate this plan and will consider redirecting resources toward reducing the copper discharge from the newly identified source. Clean Bay Pollution Prevention Plan 2008 Page 15 of 124

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23 Section 3: Program Evaluation Summary The RWQCP strives to create and implement an effective pollution prevention program. In 2003, the Regional Water Board requested that the RWQCP develop evaluation criteria for new and existing programs. The RWQCP has actively worked toward finding ways to quantify the program s success that are in addition to influent and effluent pollutant concentrations. RWQCP program effectiveness is difficult to quantify since RWQCP staff are active participants and leaders in many regional programs, conferences and meetings. Therefore, the overall evaluation of the program s effectiveness is based on: RWQCP regional commitment; Awards the program has received; and Program evaluation criteria. A. RWQCP Regional Commitment RWQCP staff acknowledges that collaborative working groups are often more effective at creating solutions for regional pollutants. RWQCP staff participates in the twenty-three state and regional workgroups listed in Table 3-1. B. Program Awards The RWQCP pollution prevention programs and its staff members have received recognition from several organizations in the past few years: In 2007, the Santa Clara Valley Water District presented its Sharing the Silver award to Palo Alto s Environmental Compliance Manager. In 2007, the California Regional Water Quality Control Board San Francisco Bay Region presented the Bay Area Pollution Prevention Group the Dr. Teng-chung Wu P2 Award for the Regional Dental Amalgam Training. In 2007, the United States Environmental Protection Agency presented the Bay Area Pollution Prevention Group with the 2007 Environmental Award for Outstanding Achievement for their innovative work on pharmaceutical waste disposal. In 2007, the Friends of the Estuary presented the Bay Area Pollution Prevention Group with the Outstanding CCMP Implementation Project Award for their work on pharmaceutical waste disposal. Clean Bay Pollution Prevention Plan 2008 Page 16 of 124

24 Table 3-1. Summary of RWQCP regional commitments Group Association of Metropolitan Sewerage Agencies (AMSA) Mercury Workgroup Bay Area Clean Water Agencies (BACWA) Permits Committee Bay Area Pollution Prevention Group (BAPPG) California Product Stewardship Council Copper Brake Pad Partnership Creek Connection Action Group Integrated Pest Management Partnership Committee Media Relations of the Bay Area Clean Water Agencies (BACWA) and the Bay Area Stormwater Management Agencies Association (BASMAA) Regional IPM Conference Committee Silicon Valley Anti Litter Group SCVURPPP (Santa Clara Valley Urban Runoff Pollution Prevention Program) SCVURPPP Illicit Connection/ Illegal Discharge Ad Hoc Task Group Brief Description AMSA s Mercury Workgroup was formed to ensure that AMSA members have access to the latest information on mercury issues and to provide a venue for sharing expertise and experience. Where information has not been readily available, AMSA s Mercury Workgroup has conducted its own studies and generated its own reports to provide its members with the information they need to address mercury. BACWA Committee sharing information on NPDES permitting and pollutant issues. Regional subgroup of Bay Area Clean Water Association (BACWA) where 39 municipal wastewater agencies develop pollution prevention programs Statewide group that is crafting legislation focusing on product stewardship. The Brake Pad Partnership brings together government regulators, brake pad manufacturers, stormwater management agencies, and environmentalists. This collaborative team is evaluating the potential effects of brake wear debris on water quality, using copper in South San Francisco Bay as an example. County-wide effort to coordinate two creek clean up days in conjunction with National River Day and Coastal Cleanup Day. Regional group that creates fact sheets and public displays that are used throughout the region and state. BACWA and BASMAA Media Relations Campaign was developed to 1) firmly establish the agencies as media contacts on water quality and pollution prevention issues, and 2) generate media coverage that encourages individuals to adopt behavior changes to prevent water pollution. Agency group organizing a regional IPM conference County-wide group of local agencies and politicians who work together to clean up trash in Santa Clara County. SCVURPPP is an association of 13 Santa Clara Valley cities and towns, together with Santa Clara County and the Santa Clara Valley Water District. To reduce pollution in urban runoff to the "maximum" extent practicable, the Program incorporates regulatory, monitoring and outreach measures aimed at improving the water quality of South San Francisco Bay and the streams of the Santa Clara Valley. County-wide effort to enhance anti-discharge requirement and to ensure uniform reporting throughout the County. RWQCP Role Participant Participant Chair Participant Support Financially Participant Participant, Support Financially Participant Participant, Support Financially Participant Participant Participant Clean Bay Pollution Prevention Plan 2008 Page 17 of 107

25 Table 3-1. Summary of RWQCP regional commitments (continued) Group SCVURPPP Mercury Ad Hoc Task Group SCVURPPP Pesticide Outreach Ad Hoc Task Group SCVURPPP Trash Ad Hoc Task Group Santa Clara Basin Watershed Management Initiative (SCBWMI) SCBWMI Emerging Contaminants Workgroup SCBWMI South Bay Permit Subcommittee Tri-TAC Tri-TAC Fats, Oils and Grease Committee Watershed Education and Outreach (WE & O) Committee Urban Pest Management Working Group Urban Pesticide Committee Brief Description SCVURPPP Mercury Committee is a county-wide effort to minimize the amount of mercury entering the watershed through stormwater. SCVURPPP Pesticide Outreach Committee focuses on minimizing the use of pesticides within municipal jurisdictions; outreach to residential and commercial users, pesticide retailers, municipal employees and special districts regarding less toxic pest control; and continued monitoring and regional coordination. SCVURPPP Trash Committee focuses on minimizing the amount of trash that enters streams within Santa Clara County. Representatives from regional and local public agencies; civic, environmental, resource conservation and agricultural groups; professional and trade organizations; business and industrial sectors; and the general public that coordinates existing regulatory framework on basin wide scale, ensuring that problems are addressed efficiently and cost-effectively. A workgroup which assembles and assimilates technical information into general informational pieces for other agencies and the public regarding emerging contaminants Collaborative group formed to ease South Bay Dischargers permit renewal negotiations. Tri-TAC is a technical advisory committee that works with regulatory agencies and interest groups with the goal of improving the effectiveness and accountability of environmental programs that impact California publicly owned treatment works (POTWs). Tri-TAC is a joint program of the League of California Cities, the California Association of Sanitation Agencies, and the California Water Environment Association. Statewide collaboration of wastewater agencies regarding how to manage fats, oils and grease. A public outreach effort coordinated between SCVURPPP and the SCBWMI. Palo Alto Staff served on the California Urban Pest Management Working Group, representing sewage treatment plant management agencies in California. The group formulated a series of recommendations to the Department of Pesticide Regulation (DPR) aimed at reducing pesticide contamination of surface waters and at human health protection. The recommendations were formulated in 2007 and will go to DPR in early Agency and NGO Representatives meet to discuss legislation, research of pesticide use and impacts and trends in urban pesticide use and pest management. RWQCP Role Participant Participant Participant Participant Chair Participant Participant Participant Participant Participant Participant Clean Bay Pollution Prevention Plan 2008 Page 18 of 124

26 In 2007, the Friends of the Estuary presented the City of Palo Alto with the Outstanding CCMP Implementation Project Award for innovative Clean Bay Campaign. In 2006, the California Regional Water Quality Control Board San Francisco Bay Region presented, the Palo Alto Regional Water Quality Control Plant the Water Quality Excellence Award, The World is My Oyster - Global Pollution Prevention Solutions. In 2006, the National Association of Flood and Stormwater Management Agencies presented the Santa Clara Valley Urban Runoff Pollution Prevention Program Watershed Watch Campaign the 2006 Excellence in Communication Award Improving Water Quality- Third Place. In 2006, United States Environmental Protection Agency presented the Santa Clara Valley Urban Runoff Pollution Prevention Program the National First Place Clean Water Act Recognition Award for Stormwater Management Excellence Municipal Program. In 2004, Susanne B. Wilson Environmental Achievement Award for excellence in resource conservation. C. Program Evaluation Criteria While influent and effluent pollutant concentrations and loadings are important facility metrics, a variety of factors other than pollution prevention and pretreatment program enforcement activities affect mass loads and pollutant concentrations. For example, pollutant loads could be reduced by: Economic downturns Water conservation RWQCP operational efficiency improvements Water supply corrosion control Wastewater reclamation Area trend toward less intensive industrial development. Area trend toward digital photographic processes Pollutant loads could increase as a result of: Sewer discharge of wastewater previously sent to storm drains, such as vehicle wash water, cooling tower blowdown, and cleaning wastewaters Treatment of stormwater runoff through RWQCP Infiltration and inflow from heavy rain and post-drought water table elevation Increased post-drought water use Substitution of aqueous solvents for non-aqueous solvents Regional growth and business expansion due to economic prosperity Since these factors cannot be readily quantified, it is important to recognize that they complicate the evaluation of the RWQCP s pollution prevention and pretreatment programs. Meanwhile, Clean Bay Pollution Prevention Plan 2008 Page 19 of 124

27 given the nature of the discharge sources and other factors influencing pollutant loads in the RWQCP effluent, it is generally not possible to distinguish the effects of individual pollution prevention programs on overall pollutant loadings. Therefore, pollutant-loading data is simply one of many evaluation tools. In 2003, RWQCP developed evaluation criteria for each specific project in addition to pollutant loading. Where applicable, RWQCP staff attempt to quantify the program s success from year to year. Since the program activities do not remain static, the evaluation criteria from year to year may change. The overall program effectiveness is based on evaluation criteria that are specific for each project, which include: Number and variety of outreach mechanisms to the public (see Appendix C for a tabulation of public outreach activities) Quantity and mass of material collected in product take-back programs Number of meetings with partner cities and industries regarding specific pollution prevention programs Quantifying changes in chemical or material usage by the City, or by particular dischargers (e.g., hospitals, schools) Results of surveys to targeted groups (e.g., amalgam disposal practices by dental offices, hospital mercury sources) Awards to the RWQCP or to staff members Evaluating projects before and during implementation is a valuable tool, which enables effective prioritization of staff time and resources to focus on the most effective programs. Within each section the project summaries and evaluations are provided, and evaluation criteria for each project are listed in the pollution prevention plan tables. Clean Bay Pollution Prevention Plan 2008 Page 20 of 124

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29 Section 4: Mercury Program Mercury, a 303(d)-listed pollutant for San Francisco Bay, is present in both wastewater and stormwater discharges to the Bay. Figure 4-1 presents the estimate of mercury sources to the San Francisco Bay, based on the Regional Board s September 2004 TMDL Proposed Basin Plan Amendment and Staff Report (Regional Board, 2004). Bed Erosion and the Central Valley Watershed are the two largest source of mercury to the San Francisco Bay, with the single largest contributor being the historic legacy of abandoned mercury mines. Direct Atmospheric Deposition (2%) Guadalupe River Watershed (8%) Non-urban Storm Water Runoff (2%) Wastewater (1.6%) Urban Storm Water Runoff (13%) Bed Erosion (38%) Central Valley Watershed (36%) Figure 4-1. Estimated Contributions of Mercury to the San Francisco Bay Clean Bay Pollution Prevention Plan 2008 Page 21 of 124

30 A. Wastewater Sources Sources of mercury discharge to wastewater include laboratories, hospitals, dental offices, human waste, food waste, and stormwater inflow. Since 1997, the RWQCP has quantified the relative importance of mercury sources using local sampling information in conjunction with data from other wastewater treatment plants and the scientific literature. As noted later in this chapter, the RWQCP s dental amalgam program, which required dental offices to install amalgam separator devices in 2005, has significantly reduced mercury loadings from dental offices. Figure 4-2 presents the mass loading estimates as a percent of the total influent load. The mercury loading estimate was updated in 2008 to reflect the decreased contribution from dental offices ( Mercury Headworks Analysis for 2008, Barron, February 2009). The estimate also accounts for new information about decreases in amalgam procedures at dental offices and the greater importance of mercury in human waste resulting from dental amalgam swallowed by patients during amalgam placement and removal. For comparison, the mercury loading estimates for 2000 and 2008 are both provided in the Mercury Program Evaluation section. Industrial & Commercial Dischargers, 3.8% Water Supply, 0.4% Infiltration / Inflow, 6.4% Foods & Products, 8.8% Dental Offices, 29.2% People w/ Amalgam Restorations, 51.4% Figure 4-2. RWQCP Mercury Loading Estimate, 2008 Clean Bay Pollution Prevention Plan 2008 Page 22 of 124

31 B. Stormwater Sources The largest stormwater source in the South Bay is abandoned mercury mines. Other contributors in the watershed include: Mobile combustion Stationary combustion Fluorescent lamps Construction erosion Natural erosion and reservoir spills C. Residential Pollution Prevention Plan Table 4-1 summarizes the RWQCP s current efforts and evaluation criteria used to reduce mercury discharges to both the sanitary sewer and storm sewer. Mercury program highlights are described below. 1. Residential Fluorescent Lamp Recycling The RWQCP initiated a pilot fluorescent light-recycling program at local hardware stores in In 2004, Santa Clara County adopted and expanded Palo Alto s fluorescent light recovery program county-wide using grant funding. In 2005, County-wide tipping fees increased to fund universal waste collection programs which included service to stores in most of the RWQCP service area. This funding had been authorized by the California Integrated Waste Management Board for one year, contingent on the County seeking alternative funding options in subsequent years. In 2006, the Santa Clara County HHW Program Manager approached wastewater and storm water agencies county-wide to ask for contributions to HHW funds in 2007 to help cover the cost of universal waste collection. While it has been determined that it is unlikely that local agencies will be able to contribute more to the County program, the County s funding need has galvanized an effort to support local and statewide initiatives through extended producer responsibility (EPR), as described below. Fluorescent Lamp Recycling at Palo Alto s Recycling Center In 2004, the City of Palo Alto also began collecting fluorescent lamps at its recycling center. Lamps are accepted from Palo Alto residents. Bulbs are stored using a barrel and dolly system inside a modified shed. This program has remained in continuous operation since The quantity of bulbs collected each fiscal year is tracked and reported in the Residential Mercury Program Evaluation section. RWQCP partner cities Mountain View and Stanford cannot establish fluorescent collection at their recycling centers due to either space constraints or concerns about universal waste storage at unmanned sites. Clean Bay Pollution Prevention Plan 2008 Page 23 of 124

32 Table 4-1. Mercury Pollution Prevention Plan Source Audiences Message / Program ALL AUDIENCES Air deposition of mercury Air Quality District GOVERNMENT AGENCIES Fluorescent lights Mercurycontaining thermometers, switches and manometers Purchasing and Utilities Departments Facilities, Utilities, and Wastewater Treatment Operations Reduce amount of mercury air emissions Continue recycling fluorescent lights and purchase lowmercury bulbs Identify and replace mercurycontaining switches and manometers within City operations Implementation Plan & Timeline Continue to urge the Bay Area Air Quality Management District to enact strict controls on atmospheric releases of mercury for the expressed purpose of meeting water quality objectives in the State s natural waterways. Continue to recycle spent bulbs and to purchase low mercury replacement bulbs. Collaborate with the California Product Stewardship Council to effect legislation requiring extended producer responsibility to cover universal waste disposal costs and operations. Continue to replace mercury-containing thermometers, switches, and manometers with non-mercury alternatives upon failure. Evaluation Criteria Number of correspondences with air district staff Annual confirmation that low mercury bulbs are being purchased Progress towards legislation. Number of locations or uses for which alternative switches are identified. Clean Bay Pollution Prevention Plan 2008 Page 24 of 107

33 Chapter 4-1. Mercury Pollution Prevention Plan (continued) Source Audiences Message / Program COMMERCIAL/INDUSTRIAL Mercurycontaining Building and Recycle HVAC mercury- thermostats contractors thermostats. Install nonmercury thermostats Fluorescent lights Scrap amalgam, chairside trap waste, filter waste, and amalgam sludge Facility managers Dentists, dental assistants and dental hygienists Recycle fluorescent lamps. Purchase lowmercury lamps. Reduce dental mercury discharges through amalgam separator technology and best management practices Implementation Plan & Timeline Following up on the passage of AB2347 which requires mercury-containing thermostat wholesales to provide collection effective April 1, 2009, staff will review the local status of this effort and assess next steps. Develop and implement ordinance requiring that mercury and PCBs-containing devices be inventoried, removed, and properly managed prior to demolition of commercial and industrial buildings. This ordinance is expected to be adopted in Via SCVURPPP participation, provide outreach and assistance regarding Universal Waste Rule (UWR) requirements for conditionally exempt small quantity generators. Continue implementation and institutionalization of dental amalgam program, including annual selfcertification forms and inspection of dental offices to confirm proper amalgam separator maintenance and BMP compliance. Continue to distribute BMP information to community college dental assistant classes. Once class of 60 dental assistant students were reached in Evaluation Criteria Identification of program reach in RWQCP service area: where are drop off locations, extent of coverage Implementation of ordinance Continued participation in SCVURPPP project Receipt of annual selfcertification forms, confirmation of amalgam separator maintenance and BMP compliance through inspectionscontinued tracking of trunkline and treatment plant mercury data Number of students reached Clean Bay Pollution Prevention Plan 2008 Page 25 of 124

34 Chapter 4-1. Mercury Pollution Prevention Plan (continued) Source Audiences Message / Program RESIDENTS Consumer Homeowner, Recycle products: landlords and mercurycontaining Mercurycontaining renters products thermostats, Thermometers, and other consumer products Consumer products: Fluorescent lights Homeowner, landlords and renters Recycle fluorescent lights Implementation Plan & Timeline Continue to collect and recycle thermometers and thermostats through the RWQCP dropoff program and HHW events. Continue partnership with Utilities on mercury/digital thermostat exchange program when program is offered. Partner with regional take-back efforts as they arise and CPSC on implementing manufacturer responsibility for products. Monitor and attempt to assist with any funding issues experienced by the County HHW Program to ensure that the County-wide fluorescent lamp collection program continues to serve the RWQCP s entire service area. Continue to collect and recycle fluorescent lamps accepted at the recycling center and at HHW events. Evaluation Criteria Quantity of thermometers, thermostats, and other mercury-containing products collected Number of thermostats collected Progress of CPSC and contributions of RWQCP staff time. Participation in program. Continuation of County-wide program Quantity of lamps collected at recycling center and HHW events. Clean Bay Pollution Prevention Plan 2008 Page 26 of 124

35 2. Universal Waste and Producer Responsibility One new area of focus for RWQCP staff is assisting in the steering committee and formation of the California Product Stewardship Council (CPSC) to address issues of Extended Producer Responsibility (EPR). The goal of CPSC is to work state-wide with water quality, solid waste, and hazardous waste programs to develop partnerships and/or legislation to change the current system, in which local government is tasked with the financial and operational burden of collecting electronic, pharmaceutical, and other wastes. Instead, EPR would involve manufacturers bearing the largest responsibility for reducing the public and environmental risks associated with these products at their end of life. To date, the City of Palo Alto has taken a leadership role in promoting EPR and supporting CPSC by encouraging the water quality community to participate in the EPR dialogue and to support CPSC financially, and by organizing and providing presentations to the water quality community about EPR. In addition, staff has met with Assembly member Ira Ruskin and other legislators in tandem with CPSC as local agency representatives and advocates of EPR. Palo Alto also took a leadership role in drafting next steps encouraging stormwater co-permittees to become CPSC signatories and financial contributors. In 2009, Senator Ira Ruskin successfully sponsored AB2347, which requires wholesalers of mercury-containing thermostats to set up a collection program for mercury thermostats by April 1, The RWQCP hosted a press conference organized by Senator Ruskin s staff to publicize the adoption of AB2347. The press conference was attended by Senator Ruskin and by representatives of the Sierra Club, CPSC, and the Thermostat Recycling Corporation. 3. Residential Thermometer and Thermostat Drop-off Program The RWQCP s thermometer and thermostat takeback program, which began in 1998, remains in operation. The number of thermometers collected annually has decreased significantly since the conclusion of a very successful campaign in The thermometer exchange program will continue to be offered to public groups and RWQCP partner cities that want to offer takeback programs at special events. Recent efforts to expand thermometer collection in East Palo by partnering with the Ravenswood Family Health Center yielded a low return rate. Feedback provided by the Health Center is that the population they serve often does not have mercury thermometers to begin with. Next steps Clean Bay Pollution Prevention Plan 2008 Page 27 of 124

36 are to explore assisting with their general mercury awareness campaign to clients, supplementing the Center s human health-focused mercury information with local data about fish advisories, environmental impacts of mercury on the Bay, and general mercury awareness. Digital thermometers may be distributed along with mercury avoidance and recycling information as part of the Health Center s mercury outreach packet. RWQCP has also partnered with the City of Palo Alto Utilities digital thermostat rebate program. Residents bring mercury thermostats into participating hardware stores to exchange them for a digital thermostat. The hardware stores accept the mercury thermostats for recycling. Staff followed up on the implementation of AB1415, which requires the discontinued sale of mercury containing thermostats in California. Stores were spot-checked to ensure only digital thermostats were sold, DTSC was contacted and offered assistance in any potential enforcement actions to ensure local compliance, and the Thermostat Recycling Coalition members were consulted in how they ensure the phase out of mercury thermostats in California. 4. Residential Mercury Program Evaluation About 91 pounds of mercury, including 8,501 thermometers, have been collected since the Program s inception in January The results for our collection programs are further tabulated below in Table 4-2 and in Figures 4-3 and 4-4. The mass collected varies greatly from year to year, as it is strongly influenced by individuals bringing in several pounds at one time. The mass of mercury collected can be compared to the RWQCP s annual influent loading of approximately 13 pounds. Table 4-2. Results from Product Drop-off Programs (through December 31, 2008) Mercury-Containing Items Number of units Collected at RWQCP Since Inception 1 Pounds Collected at HHW Programs 2 Program Initiation Date Thermometers 7, January 1998 Thermostats 167 NA 3 Fall 1999 Fluorescent Lamps 4 No longer accepted 19,603 4 October Number of units calculated for calendar year 2008 from RWQCP Plant HHW Waste Summary Total pounds reported for fiscal year Data from Lead Agency 303a Household Hazardous 3. Beginning in fiscal year , thermostats are recycled by the Thermostat Recycling Corporation (TRC) 4 Includes lamps collected at Palo Alto Recycling Center. Hardware store collection data tracked separately by Santa Clara County HHW Program beginning in Clean Bay Pollution Prevention Plan 2008 Page 28 of 124

37 D. Dental Office Source Control In January 2000, the RWQCP began partnering with South Bayside System Authority (SBSA) and the Mid- Peninsula Dental Society (MPDS) to educate dentists about their role in preventing mercury contamination in San Francisco Bay. The program prepared training materials, conducted training seminars, made on-site consultations, and defined voluntary best management practices (BMPs) to prevent mercury amalgam from reaching the environment. In 2003, The Regional Water Board reissued the RWQCP s NPDES permit. The permit included a provision requiring the RWQCP to achieve additional mercury reductions from dental offices by requiring the installation of amalgam separators. In 2004, the RWQCP adopted an ordinance requiring all owners and operators of dental vacuum suction systems to install an ISO certified amalgam separator device by March 31, The ISO certification process for amalgam separators includes demonstrating that the separator removes a minimum 95% of amalgam from the wastestream. In addition to the amalgam separator requirement, the following best management practices (BMPs) that directly affect sewer discharges were required by the ordinance: Do not rinse chairside traps, vacuum screens, or amalgam separator equipment in a sink or other sanitary sewer connection. Train staff in the proper handling and disposal of amalgam materials and fixer-containing solutions; training records are available for inspection. Do not use bleach or other chlorine-containing disinfectants to disinfect the vacuum line system. Do not use bulk liquid mercury; use only precapsulated dental amalgam. Store amalgam waste in accordance with recycler or hauler instructions. Other amalgam-related BMPs, though not required by the ordinance, are encouraged. 1. Dental Program Implementation Based upon the information collected by the RWQCP in 2004, it was determined that 134 of the 168 dental offices in the RWQCP s service area were required to install amalgam separators. The other 34 dental offices are exempt from the ordinance because they specialize in fields of dentistry in which amalgam removal or placement is uncommon, and the removal or placement of amalgam fillings occurs at their facility no more than 3 days per year. In July 2005, the RWQCP began inspecting the dental offices that were required to install an amalgam separator. A typical inspection lasted approximately 20 minutes, and addressed the following issues: Implementation of amalgam best management practices (BMPs); Presence of an amalgam separator; Review of separator maintenance records; and Management of amalgam wastes and x-ray processing wastes. Clean Bay Pollution Prevention Plan 2008 Page 29 of 124

38 As of December 31, 2006, 134 dental offices had been inspected at least once. Three quarters (75%) of the 134 dental offices inspected were in full compliance with all requirements. These offices had installed amalgam separators, and were using all required BMPs at the time of their initial inspection. The remaining 25 percent of the offices still needed to implement one or more of the BMPs. Follow-up inspections were conducted at many of these sites, with the result that by December 31, 2006, most of the 134 offices were in compliance with all of the required BMPs. In spring 2007, inspections confirmed that all of the 134 dental offices subject to the amalgam separator requirement had completed installation of a separator In 2007, the RWQCP developed a new database to help track dental offices and dentists within our service area. The dental database is complex because many amalgam separators are shared by multiple dental practices or managed by a landlord or property management company. The database also tracks when the separator was last maintained from the data collected on the annual amalgam separator form. The key components of the ongoing dental amalgam program are as follows: Track new dental offices through the building permit process and ensure that amalgam separators are installed Require submittal of annual report forms from all dental offices to allow self-certification of BMP compliance and amalgam separator maintenance Inspect dental offices to verify compliance and to educate dentists Maintain database using information obtained through inspections and annual report forms Maintain web site that includes electronic versions of the brochure, forms, ordinance text, list of approved separators (linked to list maintained by Bay Area Pollution Prevention Group) and answers to frequently asked questions. Starting in 2007, RWQCP staff sends an amalgam self-certification form to the dental offices, which requires each dental office to self-certify that the office is maintaining its amalgam separator and complying with the required BMPs. The dentists complete this form annually, assisting the RWQCP in tracking new business information and prioritizing inspections. 2. Ongoing Dental Program Since 100% of the dental offices subject to the ordinance have installed amalgam separators, the primary goals of the ongoing program are to verify that amalgam separators are properly maintained, maximize compliance with BMPs, and ensure that new dental offices are captured by the program. In March 2008, RWQCP staff sent amalgam self-certification forms to 133 dental offices. Based on the response, RWQCP inspected 30 dental offices to confirm that they are following the required BMPs and maintaining their amalgam separators. Staff also inspected those offices with new owners to ensure compliance with the ordinance requirements. Clean Bay Pollution Prevention Plan 2008 Page 30 of 124

39 3. Dental Program Evaluation a. Dental Facilities in Compliance with Ordinance In 2008, RWQCP staff confirmed 100% compliance with separator maintenance. In regards to the BMPs, the majority of dental offices follow the required BMPs. A few dental offices still place the chairside traps in the trash. As discussed previously, inspections conducted at 134 of the 134 dental offices subject to the ordinance indicate that all dental offices have installed an amalgam separator. Therefore, we have confirmed 100% compliance with the amalgam separator requirement. b. Decrease in estimated loading from dental facilities The RWQCP s mercury loading estimate was updated in 2008 to reflect lower contributions from dental facilities after implementation of the dental amalgam program. Figures 4-3 and 4-4 illustrate the dramatic reduction in estimated mercury loading from dental offices between 2000 and The dental office contribution is estimated to have decreased from 56 percent to 29 percent of the RWQCP s influent mercury loading. During this same period of time, the overall influent mercury loading has decreased by approximately one-third. The methodology employed to estimate the annual mass of mercury discharged to the sanitary sewer for individual dentists can also be used to estimate the mass of mercury captured (e.g. collected for appropriate disposal by amalgam separators and implementation of Best Management Practices) due to the RWQCP s dental amalgam program. The 2008 analysis estimates that the current loading to the sewer from dental offices in the Palo Alto service area is 5.1 pounds per year, with 47.4 pounds per year captured by use of best management practices and amalgam separators. It is estimated that the dental loading would be 16.3 pounds per year if the dental amalgam program had not been implemented. Therefore, the RWQCP estimates that 11.2 of the total 47.2 pounds captured or collected by dentists is attributable to the dental amalgam program. 1 The 2000 Mercury Loading Estimate displayed in Figure 4-5 differs from the 2000 Estimate provided in previous Clean Bay Plans. As the 2008 Estimate was in process, it was noted that the original 2000 Estimate used a lower number of dentists than the number now known to be practicing in the RWQCP service area. In addition, the People with Amalgam Restorations estimate had been understated because excretion of mercury swallowed during dental procedures had not been considered. For details, see Mercury Headworks Analysis for 2008, Barron, February Clean Bay Pollution Prevention Plan 2008 Page 31 of 124

40 Foods & Products, 4.9% Water Supply, 0.2% Infiltration / Inflow, 2.3% Industrial & Commercial Dischargers, 5.4% People w/ Amalgam Restorations, 30.8% Dental Offices, 56.3% Figure 4-3. RWQCP Mercury Loading Estimate, 2000 Industrial & Commercial Dischargers, 3.8% Water Supply, 0.4% Infiltration / Inflow, 6.4% Foods & Products, 8.8% Dental Offices, 29.2% People w/ Amalgam Restorations, 51.4% Figure 4-4. RWQCP Mercury Loading Estimate, 2008 Clean Bay Pollution Prevention Plan 2008 Page 32 of 124

41 c. Mercury concentration in a dental building cleanout and dental area trunk line before and after amalgam separator installations The RWQCP conducts sampling of a dental building cleanout and a sewer trunkline (in an area with numerous dental facilities and no residential inputs), in order to compare mercury concentrations before and after the installation of amalgam separators. The RWQCP selected two sites for this dental line sampling, as presented below: Sampling Locations Building cleanout on Welch Road, Palo Alto A trunkline on Welch Road, Palo Alto Site Description Large medical and dental building housing several dental offices as well as some medical clinic offices. The landlord provides shared vacuum systems for all the dental offices in the building. Manhole site is upstream from the building cleanout sampling location (due to safety concerns at the sampling location downstream of that address). This is downstream of numerous dental and medical facilities. There are no residential inputs to this sewer line. Wastewater samples were gathered at each of these locations via a standard 24-hour composite methodology the same method used throughout the city for sanitary sewer pollutant analysis. There were two baseline rounds of sampling conducted prior to the installation of amalgam separators. In order to determine the impact of amalgam separator installation, additional rounds of sampling were conducted in September 2005, November 2006, and June Figure 4-5 on the following page presents the sampling results. Note the logarithmic scale on the graph. Building Cleanout Results. The building cleanout results are represented by the open squares. There was an approximate 90% reduction in the average mercury concentration in the building cleanout after amalgam separators were installed. This reduction was calculated by comparing an average of 20 samples taken after separators were installed to an average of 24 samples taken prior to installation of separators. One would expect a very significant reduction, because the vacuum system at this building is a dry vacuum system. Wastes from dry vacuum systems do not pass through a vacuum screen before being discharged to the sanitary sewer, as is typical in a wet vacuum system. Therefore, at this monitoring site amalgam particles were directly entering the sanitary sewer prior to installation of the amalgam separator. The new separator now captures these amalgam particles. Sewer Manhole Results. Mercury concentrations in samples collected from the sewer manhole in after amalgam separators were installed indicated an approximate 50% reduction from the samples collected prior to amalgam separator installation. This reduction was calculated by comparing the average mercury concentration of 25 samples after separators were installed to the average of 25 samples before this installation. Please note that this sewer manhole is located on the same street as the above building cleanout, but upstream of that building. Clean Bay Pollution Prevention Plan 2008 Page 33 of 124

42 Palo Alto Dental Cleanout and Manhole Data: Before and After Installation of Amalgam Separators (Amalgam Separators Required March 31, 2005) 1 6/28/2003 1/14/2004 8/1/2004 2/17/2005 9/5/2005 3/24/ /10/ /28/ /14/ /1/ /18/ Dental Building Cleanout City Sewer Line [Hg], mg/l 0.01 IW discharge limit = 0.01 ppm Pre Amalgam Separators Average residential line [Hg] = ppm Sampling Date Post Amalgam Separators Figure 4-5. Results of Palo Alto Dental Cleanout and Sewer Trunkline Analyses Clean Bay Pollution Prevention Plan 2008 Page 34 of 124

43 4. Educating Other Bay Area Wastewater Agencies a. Presentations at Meetings and Conferences In 2005 and 2006, RWQCP staff presented the results of the RWQCP Dental Amalgam Program to the Bay Area Pollution Prevention Group and the Pretreatment, Pollution Prevention, and Stormwater Committee of the California Water Environment Association (P3S Committee). In April 2008, RWQCP provided information on the RWQCP Dental Amalgam Program that was presented at the State California Water Environment Association Conference. b. Dental Amalgam Program Workshop and Inspector Training In December 2006, staff from the RWQCP spearheaded and funded the organization of a oneday dental amalgam program training. The Creating a Dental Amalgam Program workshop was co-sponsored by the Bay Area Pollution Prevention Group (BAPPG) and the California Water Environment Association. The overall goal of the workshop was to provide wastewater agencies with the tools and knowledge to start their own dental amalgam programs. Attendees received a workbook, which included a CD that contained a literature review on dental programs locally and nationally. The Creating a Dental Amalgam Program CD contains the most complete reference material put together to date nationally on this subject. The CD includes examples of outreach material, ordinance language, permits and inspection information. Staff from the Regional Water Quality Control Plant organized the contents of the workbook and CD. The workbook was shared with federal, state and local agencies throughout the nation. In 2008, RWQCP staff will share the CD at the State California Water Environment Association Conference. In January 2009, RWQCP staff spearheaded a second BAPPG inspector training course. Approximately 75 inspectors attended the training provided by Tom Barron, a local dental pollution prevention expert. The training was well-received and participants now feel more knowledgeable when they inspect a dental office. E. POTW Mercury Use Investigation Pursuant to the August 2003 Discharge Order, the RWQCP was tasked with conducting a thorough investigation of the uses of mercury at the Plant. The investigation included the following: An inventory of the mercury used at the Plant, focusing on switches and reagents, but including all uses A listing of available non-mercury alternative products Recommendations and a time schedule for action by Palo Alto where appropriate In accordance with the Santa Clara County Urban Run-off Program and associated stormwater discharge permit, the City of Palo Alto was required in 2002 to prepare an initial investigation of municipal mercury uses. This analysis included mercury uses at the RWQCP. The inventory is presented in Table 4-3, organized into three separate sections: lights, switches, and lab reagents. The list includes currently inventoried mercury-containing products, as well as the plan for action, as appropriate. Clean Bay Pollution Prevention Plan 2008 Page 35 of 124

44 Figure 4-6. Some of the mercury alarm switches that were removed from service or pulled from storage at the RWQCP in (All such switches are turned in to the City s municipal hazardous waste collection for recycling.) In 2005, the RWQCP reviewed these results and found no additional mercury-containing components to add to the list. If additional sources are identified in the future, the RWQCP will review applicability of alternative products and recommend any additional actions. As for previously identified products, the schedule is presented in Table 4-3. The primary items for which alternatives have been identified are mercury switches (Figure 4-6). In those cases, because there is no immediate pathway between the switches and the environment, the schedule involves removing mercury switches upon failure. F. POTW Mercury Replacement Effectiveness Effectiveness of this program is measured by: Numbers of switches collected and replaced Adoption of a mercury-free alternative to the COD laboratory procedure Further identification of other sources and alternatives 1. RWQCP mercury replacement Since 2002, RWQCP has replaced or removed 37 mercury switches (approximately 2.3 pounds) from the plant. Many of the switches that were recycled were not in service but were inventory in the shop and warehouse contributing to the large amount of mercury recycled in a short period of time. In 2005, the RWQCP replaced six switches within the plant that contained approximately 100 grams of mercury. In 2006 no switches were replaced within the treatment plant, but in 2007, the RWQCP replaced 5 float switches which containing approximately 250 grams of mercury. 2. COD laboratory procedures In 2008, the RWQCP s laboratory switched to a mercury-free Chemical Oxygen Demand (COD) laboratory method following the method s approval by EPA. The RWQCP laboratory typically analyzes approximately 350 samples per year for COD. The actual number of COD vials used is Clean Bay Pollution Prevention Plan 2008 Page 36 of 124

45 greater than 350, as many are analyzed in duplicate and quality control samples must also be analyzed. 3. Identification of sources and alternatives City staff identified an alternative float switch, which is a non mercury bulb and is produced by the same manufacturers as the mercury switches. For other applications, such as temperature or pressure switches, there are a variety of techniques for replacement, usually by digitizing the signal and using logic to control a switch. In addition the RWQCP uses a Programmable Logic Controller (PLC) system to make contacts when necessary while monitoring a signal. These are usually a case-by-case modification rather than a universal replacement. Other situations arise where the switch is an integral part of an existing system that does not retrofit, such as the torque alarms on the clarifier sweeps. Nothing short of redesigning the sweep arms can replace the mercury switches; these will not be replaced. Table 4-3. Inventory Results and Current Plans Product Use at RWQCP? Lights Fluorescent Yes common Metal halide (high intensity discharge lamps None found w/blue-white light) High pressure sodium (yellow-white lights Yes used for street lamps, outdoor security, and common some lighting in process areas) Mercury vapor lamps Yes uncommon Plan for Seeking Alternatives Now using low mercury lights formally initiated in 2001 Evaluating potential for replacing these lamps with LED lighting No current plan use (2-3 only) Switches Silent wall switches (prior to 1991) None found Will replace any overlooked upon failure Wall-mounted office thermostat Yes 6 to 10 Will replace upon failure Airflow/fan limit controls None found Building security systems None found Pressure control None found Will replace, upon failure, any overlooked devices and replace with Hg-free Torque-arm alarm switches Yes about 12 to 16 Will not replace; integral part of existing torque arm Float control (used for sump pumps) Yes Will replace with Hg-free upon failure. Lab Reagents Pre-mixed test tubes for monitoring chemical oxygen demand (COD) Yes In 2008, the laboratory switched to a mercury free COD test procedure. Clean Bay Pollution Prevention Plan 2008 Page 37 of 124

46 G. Mercury Program Evaluation One measure of the mercury program s effectiveness is by analyzing mercury concentrations in influent, effluent and biosolids; figures 4-9 through 4-14 present RWQCP data on influent and effluent mercury concentrations and mercury concentrations in sludge cake prior to incineration. The dental amalgam program has proven very effective in reducing mercury loadings to the Plant and to the environment; the average effluent concentration for 2006 through 2008 declined 47 percent compared to the average effluent concentration for 2001 through 2004 (Table 4-4). These reductions are believed to result primarily from the dental amalgam program, not from other residential and commercial programs addressing mercury, because they occurred after the takeback programs for thermometers, thermostats, and fluorescent lamps had been in place for a number of years. Table 4-4. Summary of the average mercury concentration before and after the installation of amalgam separators for influent, sludge cake and effluent Location (pre-amalgam separators) Average Mercury Concentration (post-amalgam separators) Percent Reduction (pre- vs. postseparators Influent 0.31 µg/l 0.20 µg/l 34% Sludge Cake 397 µg/kg 264 µg/kg 34% Effluent µg/l µg/l 47% As shown in Figures 4-7 and 4-8, influent mercury concentrations have decreased significantly since Influent samples are collected on a weekly basis. Since the ordinance required installation of amalgam separators by March 31, 2005, data from 2001 through 2004 are used as the pre-separator baseline. The average influent concentration for 2006 through 2008 was 34 percent lower than the average influent concentration for 2001 through With respect to influent data gathering, there is a data gap that must be acknowledged. Mercury amalgam particles are very dense, and are more likely to travel along the bottom of sewer pipes than to be suspended throughout the water column. Due to the configuration of the RWQCP influent sampling location, it is believed that some mercury amalgam particles would not be captured in the influent samples. These amalgam particles would not enter the RWQCP s primary treatment process, but would be trapped in the grit channel at the headworks of the RWQCP. Because the grit is highly irregular, it is not feasible to conduct accurate, representative sampling. The grit is disposed of at a landfill, and its pollutant content has never been included in the various mass balances that have been conducted. Therefore, we recognize that undetected decreases in the mercury content of that material may have occurred. Figures 4-9 and 4-10 present effluent mercury concentration data. Effluent samples are collected on a monthly basis. The average effluent concentration for 2006 through 2008 declined 47 percent from the average concentration for 2001 through The 2008 average effluent concentration is the lowest annual average concentration to date for mercury. As shown in Figure 4-9, the effluent mercury concentration since early 2005 trended steadily downward through early 2006, then upward, then downward again. Since the installation of amalgam Clean Bay Pollution Prevention Plan 2008 Page 38 of 124

47 separators, the correlation between effluent suspended solids and mercury has become much stronger, and these trends track well with suspended solids removal performance. Mercury concentrations in the RWQCP s pre-incineration sludge cake are presented in Figures 4-11 and Sludge cake samples are collected monthly. Sludge cake mercury concentrations have declined substantially since The average concentration for 2006 through 2008 is 34 percent lower than the average for 2001 through sample rolling average discrete data points 0.80 Mercury (µg/l) Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Date Figure 4-7. RWQCP Mercury Influent Concentrations: Mercury (µg/l) Year Figure 4-8. RWQCP Average Mercury Influent Concentrations: Clean Bay Pollution Prevention Plan 2008 Page 39 of 124

48 sample rolling average discrete data points Mercury (µg/l) Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Date Figure 4-9. RWQCP Mercury Effluent Concentrations: Mercury (µg/l) Year Figure RWQCP Average Mercury Effluent Concentrations: Clean Bay Pollution Prevention Plan 2008 Page 40 of 124

49 sample rolling average discrete data points Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Mercury (µg/kg) Jan-09 Date Figure RWQCP Sludge Cake Mercury Concentration: Mercury (µg/kg) Year Figure RWQCP Average Mercury Sludge Cake Concentrations: Clean Bay Pollution Prevention Plan 2008 Page 41 of 124

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51 Section 5 : Pesticide Program In previous years, water quality agencies focused their efforts on the reduction of organophosphate pesticides, specifically diazinon and chlorpyrifos because of water toxicity associated with their use, primarily from the residential sector. While less toxic product use has increased in recent years due to programs such as Our Water, Our World, diazinon and chlorpyrifos product cancellations have also resulted in increased sale and use of pyrethroid products, which have emerged as the newest ubiquitous and persistent source of pesticide toxicity in local creeks. The San Francisco Bay Regional Water Board adopted a TMDL addressing diazinon and pesticide toxicity in Bay Area urban creeks in November The TMDL is focused on pesticide toxicity reduction, and aligns with City of Palo Alto goals of encouraging overall reduction and toxicity of pesticide use, instead of targeting specific active ingredients. The City is targeting opportunities to achieve these goals in the residential sector and in its own in-house pesticide use. A. Wastewater Sources Pesticides may reach the sanitary sewer through numerous routes, including stormwater inflow, indoor application, post-application clean-up, laundry graywater, human waste, food waste, hazardous waste management, and water supply. Because several of these sources are related to outdoor pesticide application, and stormwater is the release route to local creeks, the RWQCP has not determined the relative importance of sanitary sewer sources. B. Stormwater Sources Residential urban pesticide use is the primary source of pesticide toxicity in Bay Area creeks. Currently, pyrethroids are the main family of chemicals associated with local pesticide toxicity and include specific active ingredients such as permethrin, cypermethrin and bifenthrin. Pyrethroids are frequently sprayed on impermeable surfaces, most often to control ants. In addition, pyrethroids are used in granular form for control of lawn pests such as grubs and fire ants. Many granular lawn care products marketed primarily as fertilizers are also formulated to contain pyrethroid pesticides. Pyrethroids applied to impervious surfaces or landscaping can be washed by rain or irrigation into storm drains, travel to creeks, and bind to sediments, causing toxicity to freshwater amphipod crustaceans such as Hyalella azteca that represent an important intermediate link in aquatic food chains. Since the phase-out of organophosphate products in 2000, use of pyrethroids products has doubled. 2 2 Sources of Urban Pyrethroid Runoff, Kelly Moran, Clean Bay Pollution Prevention Plan 2008 Page 42 of 124

52 C. Pesticide Pollution Prevention Plan Integrated Pest Management (IPM), also referred to as reduced-risk pest management, encourages reduced-risk, long term pest prevention and suppression through a combination of techniques including: biological controls, habitat manipulation, use of resistant plant varieties, improved landscape/building hygiene, and structural repair and pest barriers. IPM sanctions synthetic chemical pesticides only as a last resort, and only with the least toxic chemicals available. IPM seeks to minimize pest concerns while minimizing human health, environmental, and financial risks. IPM is the best approach to prevent or solve pest problems with minimal pesticide use, and promoting IPM principles is therefore the focus of the pesticide pollution prevention plan. Table 5-1 summarizes the RWQCP s pesticide reduction plan for Actions to address municipal, industrial, and residential sources are similar because in each case there are do-ityourselfers and those who use pest control operators (PCOs). At this time the City of Palo Alto is focused on two programs: 1) reducing the use of pesticides by City of Palo Alto staff, and 2) expanding the regional IPM Partnership ("Our Water Our World") to reduce residential pesticide use by do-it-yourselfers. Palo Alto is also participating in two new regional programs which target structural pest control operators and landscape maintenance providers: EcoWise Certified Eco Wise Certified is an IPM certification for structural pest control operators. Palo Alto has required its new pest control contractor to be EcoWise certified. This contract commenced in In addition, Palo Alto will assist with local outreach about IPM service providers as EcoWise graduates become available. Bay Friendly Gardening The Bay Friendly Gardening program provides environmentally friendly landscape certification to landscape maintenance and design professionals and includes an IPM component. This program is a project of Alameda County s StopWaste.org program. StopWaste.org has provided grant funding for a consultant to launch Bay Friendly gardening throughout the region with the intent of seeking water quality agency input. Palo Alto and other local agencies are exploring ways to expand and strengthen the IPM component of this program. In 2009, three Bay Friendly workshops are scheduled in Santa Clara County, including one IPM workshop scheduled for June 20 titled: Gardening to Manage Pests Naturally Control pests without the use of pesticides. Clean Bay Pollution Prevention Plan 2008 Page 43 of 124

53 Table 5-1. Pollution Prevention Plan for Pesticide Reduction Source Audiences Message / Program Implementation Plan & Timeline GOVERNMENT AGENCIES Use on golf Purchasing Use IPM courses, and Parks techniques to parks, and Departments greatly municipal reduce use of facilities all pesticides Evaluate previous year s pesticide use and pest management strategies Offer IPM mini-grants to City of Palo Alto divisions responsible for pest control, prioritizing those that offer potential reductions in ecotoxicity or reduction of pesticides used in large amounts. Follow and encourage the success of perimeter trapping for gopher and ground squirrels. Go out for bid for next three-year structural pest control contract emphasizing EcoWise Certified requirements. Advocate and publicize the use of bee tunnels. Staff will also work with Pestec to share this method with other agencies and the public in order to encourage bee protection. Explore the timing for inclusion of IPM language into landscape maintenance contracts. Investigate the possibility of having a pesticide-free park or demonstration site in the City. Assist in Bay Area expansion of Bay Friendly gardening program, promote EcoWise Certified companies as they become available, continue to support Our Water, Our World program and work with subcommittee of the regional UP3 committee which expands and supports IPM efforts in public agencies. Evaluation Criteria Production of annual IPM Program report analyzing pesticide use trends and toxicity. Success in effecting new IPM projects. Success of trapping efforts and potential reduction in rodenticide use. Award of new pest control contract Completion of task to provide public and industry outreach. Inclusion of criteria into landscaping contracts. Clarity on when and if this task is possible after meeting with Parks and Open Space staff. Extent of participation in Bay Friendly expansion, number of advertisements and outreach for EcoWise Certified companies, and participation efforts in the UP3 committee. Clean Bay Pollution Prevention Plan 2008 Page 44 of 107

54 Table 5-1. Pollution Prevention Plan for Pesticide Reduction (continued) Source Audiences Message / Program Commercial / Industrial Application by hired pest control operators RESIDENTS Do-ityourselfers Facility managers at businesses, schools and other institutions Residents preparing to purchase pest control supplies Use IPM techniques to greatly reduce use of all pesticides. IPM techniques can greatly reduce use of all pesticides Implementation Plan & Timeline In 2009, pending availability of new companies certified through the EcoWise certification project, assist with local and regional outreach about certified IPM structural pest control services. Continue IPM Partnership for residential outreach, including point-of-sale educational materials at hardware stores and training program for store employees. IPM displays at farmers markets, community events, and corporate fairs. Evaluation Criteria Extent of regional and local promotion of EcoWise Certified companies (pending availability of companies). Number of stores participating in program. Number of farmers markets and events attended. Application by hired pest control operators Residents who hire PCOs Hire a contractor that is trained and/or certified in IPM techniques (as available) Assist in Bay Area wide expansion of Bay Friendly Gardening program, which provides workshops for residents. In 2008, pending availability of new companies certified through the EcoWise Certified project, assist with local and regional outreach about certified IPM structural pest control services. Assist in Bay Area wide expansion of Bay Friendly Gardening program, which seeks to provide workshops for landscape companies and certify them as Bay Friendly. Extent of participation. To be determined; dependent on presence of certified companies that can provide service to the RWQCP service area. Results of workshop(s) held by SCVURPPP co-permittees. Clean Bay Pollution Prevention Plan 2008 Page 45 of 124

55 1. Reducing City of Palo Alto Pesticide Toxicity and Use a. City Pesticide Policy and Implementation Plan In 2001, the City of Palo Alto began quantifying its staff and contractor pesticide use. In 2009, staff completed the report quantifying 2008 pesticide use which also updated the IPM workplan recommendations. Additional IPM strategies are gradually employed each year, building on efforts of preceding years. The complete report is located in Appendix E. To evaluate the chemical toxicity of chemicals used, a tier system is used (based on a City of San Francisco study) which considers: (1) acute human toxicity and chronic health risks; (2) the level of training required to use the product; (3) inclusion of Clean Water Act (303d) listed chemicals; (4) environmental toxicity; and (5) a chemical s persistence and mobility in soil. Tier 1 chemicals are of highest concern, Tier 2 are of moderate concern, Tier 3 are of lowest concern, and Tier 4 are chemicals for which there is insufficient information to analyze their toxicity. Each annual report summarizes progress made on the previous year s recommendations, quantifies pesticide use (target pests and where, when, and which pesticides were used), and identifies the IPM project goals for the coming year. This information is made available to the public on-line. Pesticide use for 2008 is summarized in the City Pesticide Use Program Evaluation section in the 2008 Pest Management and Pesticide Use Report. To date, Palo Alto has developed seven IPM plans and conducted extensive training on how to address weeds, gophers, ground squirrels, yellowjackets, ants, rats, and mice using IPM principles. In 2008, Palo Alto: Piloted the use of less toxic fungicides and provided training on effective ground squirrel and gopher control. The products traditionally used for these three pests are among the most ecotoxic and the most frequently and greatest used in the City. Palo Alto also tested the use of bee tunnels; a device designed by the City s contractor, Pestec, to divert bees located in hives situated in public areas which may be hazardous if there is interference from people. The device allows bees to stay in their hive, but diverts them via a tunnel away from people minimizing potential harm. Bee tunnels protect bee populations and remove the need for pesticides. b IPM Program Highlights It should be noted that in previous Annual Reports, Palo Alto s pesticide use information reflected actions from two years prior due to the timing that the City s annual Pest Management and Pesticide Use report was drafted. In this year s 2009 Clean Bay Plan, 2008 pesticide use and pest management updates are provided as pesticide report information was targeted for earlier completion. Decreased total pesticide use, Decreased Tier 1 Use, Decreased Ecotoxic Pesticide Use In 2008, the City decreased the total amount of active ingredient it applied by 153 pounds (36%) and decreased Tier 1 pesticide use by approximately 150 pounds (48%) from the previous year due primarily to less use of the fungicides mancozeb and thiophanate-methyl. In addition, the City used 35 pounds (41%) less ecotoxic pesticides through the reduced use of thiophanatemethyl; ecotoxic pesticide use was the lowest observed since Clean Bay Pollution Prevention Plan 2008 Page 46 of 124

56 Increased Tier 2 fungicide use in place of Tier 1 fungicide use In 2008, the City targeted the reduction of fungicide use which has historically contributed much of the Tier 1 and ecotoxic pesticides used by the City. The City of Palo Alto provided an evaluation of the least toxic fungicide options for use at the golf course which identified Medallion (fludioxonil) and ProStar (flutolanil) as being two viable alternatives. These products were tested by the Golf Course in 2007 and worked very well. As a result these products have been rotated into the menu of product options for ongoing use at the golf course. The golf course was able to operate its fungus control program in 2008 without any use of ecotoxic fungicides. Explored perimeter trapping for gophers and ground squirrels A well-received training program was held focusing on control of gophers and ground squirrels through perimeter trapping, which targets the corridors that gophers and ground squirrels travel from to minimize population expansion. Five agencies were represented and approximately 25 Palo Alto staff attended. Perimeter trapping may prove to reduce the need for rodenticides and will be reported on in the 2009 report. Bee Tunnels piloted To protect bees and humans from each other when bee hives are formed in areas where humans are more likely to come into contact with them, the City s contractor, Pestec, developed a method of directing bees that are entering and exiting their hives away from people. A PVC pipe is mounted over the hive (often located in a tree trunk) using mesh and plaster-of-paris to cover the hive opening. The pipe runs up the length of tree above where people are likely to disturb the hive. This effort will be monitored and refined as necessary. RWQCP staff will distribute a public education piece they developed about the importance of protecting bees and the use of bee tunnels as necessary. Staff will also share this method with other agencies and the public in order to encourage bee protection. 2. City Pesticide Use Program Evaluation Since the adoption of the Integrated Pest Management Policy (IPM) in 2001, the 500 City of Palo Alto has made considerable efforts to implement pest management 350 procedures that minimize the need for pesticide applications 250 and has strived to use the least toxic 200 pesticides when 150 chemical control of 100 pests and disease is needed. Figures and 5-2 present the 0 results of Palo Alto s annual quantification Amount of Active Ingredient (lbs) Figure 5-1: Total Pesticide Active Ingredient Use by Year ( ) Clean Bay Pollution Prevention Plan 2008 Page 47 of Year

57 of pesticide use through 2008 by total active ingredient and by active ingredient tier ranking, respectively. Successes to date include the reduction of the quantity and toxicity of pesticides used for weed and insect control, EcoWise Certified structural pest control contractor requirements, piloting the use of less toxic fungicides, targeting cultural practices that reduce gophers, ground squirrels, and innovating ideas that minimize bee threats to humans without harming bees or using pesticides. These practices all further protect water quality of creeks and the Bay. Figure 5-2: Tier 1, 2, and 3 Pesticide Use by Year ( ) Tier 1 Tier 2 Tier 3 Active Ingredient (lbs) Year 3. Residential Pesticide Outreach a. Regional Program The Our Water, Our World (OWOW) program developed in 1997 continues to be the integral consumer resource for the RWQCP. The program, under the leadership of the Regional IPM Partnership Committee, is a partnership among water agencies and their local nursery and hardware stores, carried out regionally and by local staff. It is designed to educate the public and the retail pesticide industry about less-toxic pest management, inform them about alternatives, and encourage responsible use and proper disposal when pesticide use is deemed necessary. In 2008, the RWQCP continued to contribute both monetary and staff support to the program. The Committee has served as the central source of information and program materials for other water quality jurisdictions preparing to participate in the OWOW program or to adapt it to other areas. Groups in many parts of the United States have shown interest in starting OWOW or similar programs. The website now makes OWOW materials immediately available to prospective new participants, and adds new updated information as needed and requested This year two additional pest fact sheets will be added to the website, Gophers, Moles and Voles and Rats and Mice, making a total of thirty-two fact sheets. Clean Bay Pollution Prevention Plan 2008 Page 48 of 124

58 Orchard Supply Hardware (OSH) now has 86 stores participating in the OWOW program. Their own Earth Friendly culture compliments the use of less toxic pesticides promoted by the OWOW campaign. Management continues to use the OWOW logo in their direct mailings, and use the logo in store ads statewide. They also ran a large Spring ad last year promoting the OWOW products. Another important part of the program is the current year s lists of less-toxic products, available both alphabetically and by pest. This list is continually reviewed, updated and available online to stores, residents and PCOs as a guide for product purchases. Products on the list are identified in the participating stores by colorful OWOW shelf talkers. b. Local participation in Regional Program Ten stores located within the RWQCP service area participate in the program. Partner stores receive free educational materials, attractive displays, assistance from local staff and Master Gardener Annie Joseph. In return the stores carry less-toxic products from the partnership s approved list, and agree to send employees to a training session. Locally, RWQCP implemented the following aspects of IPM outreach during 2008: Provided personal pest management advice by phone and by via Palo Alto s Environmental Compliance website, cleanbay.org Distributed regional and locally developed IPM materials on our website; maintained the website for the Clean Bay campaign Reviewed and copyedited regional program materials for OWOW websites Distributed the OWOW materials, including fact sheets and shelf talkers identifying less-toxic products at partner stores (with substantial staff assistance from SCVURPPP); distributed fact sheets and/or posters at city halls, a city development center, libraries, a city Clean Bay Pollution Prevention Plan 2008 Page 49 of 124

59 sewer district, and at special events, such as the Environmental Film Festival, local Earth Day events, Farmers Market and a neighborhood community Home and Garden Tour Distributed other handouts, primarily pencils, magnets and booklets at various events Sponsored an IPM workshop that qualified for continuing education credits to city staff and IPM professionals Participated in corporate sponsored Earth Day events including PARC, Acterra, Roche, Watt Stopper and Wilson, Sonsini, Goodrich and Rosatti. Attended Stanford University Student s Group Earth Day and answered questions For details on events, see our list of public contacts in Appendix B. c. Additional Local Pesticide Outreach In addition to its participation and support in regional pesticide outreach efforts, the RWQCP also initiates its own public education each year via ads in local newspapers, utility inserts, theater ads, and stories in the Palo Alto Daily, Palo Alto Weekly, and Mountain View Voice, East Palo Alto Today, and Los Altos Town Crier. In 2008, RWQCP continued to promote EcoWise Certified service providers and increased public awareness of legacy pesticides. 4. Residential Outreach Program Evaluation The Our Water, Our World program and the RWQCP residential program utilize regional surveys and joint regional evaluations to minimize the expense of duplicative local surveys. The notable surveys, white papers, and presentations are listed on the Urban Pesticide Project s website at The most current surveys include pesticide use data such as that presented in TDC Environmental s Pesticides in Urban Surface Water: Urban Pesticide Use Trends Report, 2007; Improving Urban Surface Water Pesticide Toxicity Reduction Efforts: Pesticide Use Data and Recommendations for Action, June 2005; and the most recent shelf survey, San Francisco Bay Area Regional Shelf Survey, September Generally speaking, the annual shelf surveys of registered insecticides note the continuing trend toward replacing banned organophosphorous products with pyrethroids and other pesticides with troubling water quality implications. Although no studies have been completed recently, past OWOW studies of market share in the Bay Area reflected positive trends, with consumer demand driving the introduction of less-toxic products and their purchase. The website underwent a change in servers during the fall of 2008, and is unable to give a complete year of Web Trends data. Online consumer interest continues to climb for the OWOW program. The increase in website hits has gone from 4,475 in March 2004 to 92,263 in March 2008 Clean Bay Pollution Prevention Plan 2008 Page 50 of 124

60 Community Events. Our residential outreach focus this year was on pharmaceuticals and less toxic pesticide use. Staff participated in IPM related events at fifteen outdoor, in-house or specially requested venues. Interest in disposing of expired or unwanted pharmaceuticals has great increased over the last year. Providing information and services to help residents with this concern has been appreciated. Requests for pharmaceutical take back collections at fairs and events increased, and when announced or publicized in advance, were very successful. Clean Bay Pollution Prevention Plan 2008 Page 51 of 124

61 Section 6: Copper Program The RWQCP has an effluent limitation for copper, and is also subject to copper limits for the management of ash from sludge incineration. In early 2009, EPA approved Copper Site Specific Objectives and a Copper Action Plan applicable to all of San Francisco Bay. The RWQCP s copper pollution prevention program includes the primary elements of the Copper Action Plan. A. Wastewater Sources Copper enters wastewater from many sources, including residences, commercial businesses, industrial operations, infiltration and inflow of ground and surface water into the sewer system, and corrosion of water piping in buildings. The RWQCP s most recent review and update of the technical mass loading analysis, completed in 2002, is presented in Figure 6-1. The estimates of copper sources are based on extensive local sampling and a number of technical studies conducted by the RWQCP and others since 1992 (EIP Associates, 1999). B. Stormwater Sources The Santa Clara Valley Urban Runoff Pollution Prevention Program Metals Control Measures Plan (Urban Runoff Program, February 1997) provides an estimate of copper sources in urban stormwater runoff (see Figure 6-2). Due to the small amount of available data for several sources, especially motor vehicle brake pads, the estimates should be considered rough, providing information about the relative importance of various sources. Efforts by the Urban Runoff Program and others should provide more definitive estimates of copper sources in the future. Clean Bay Pollution Prevention Plan 2008 Page 52 of 124

62 Storm Water Inflow 3% Circulating Hot Water Systems* 3% Permitted Industries 5% Cooling Tow ers 3% Septage 3% Identified Commercial Sources 2% Infiltration and permitted Groundw ater 1% Human Waste 6% Residential Waste (excluding Human Waste) 7% Corrosion 60% Water Supply 7% Figure 6-1. Estimated Contributions of Copper Sources to the RWQCP, 2002 Other 6% Industry 7% Water Supply/ Corrosion 7% Vehicle Brake Pads 80% Figure 6-2. Urban Stormwater Copper Sources Clean Bay Pollution Prevention Plan 2008 Page 53 of 124

63 C. Pollution Prevention Plan The pollution prevention plan for copper is presented in Table 6-1. For the coming year, the RWQCP will continue to focus on copper pipe corrosion and copper roofing materials, and to review the use of copper at metal finishing facilities. In addition, the RWQCP will complete its review of issues related to the use of chlorinated polyvinyl chloride (CPVC) piping for potable water supply, which was approved for California in 2007, to determine whether its use should be promoted as an alternative to copper. 1. Plumbing Practices Because proper design and maintenance can minimize corrosion of copper piping, the RWQCP has developed a set of guidelines for plumbers. The guidelines focus on the following practices: Ensuring pipe quality Limiting the use of flux and choosing less aggressive fluxes Importance of clean joints and limiting excess solder Selecting solders with widest working temperature range Limiting pipe velocities Lowering the set point of hot water temperature In 2001, Palo Alto technically reviewed and updated the guidelines. In 2002, staff gave presentations to the San Jose local pipe fitters union and the American Society of Plumbing Engineers. These audiences were receptive to the information and provided thoughtful guidance regarding how to reach their peers. In mid-2002, the City of Palo Alto initiated a BAPPG effort to create a set of fact sheets and a giveaway item to be distributed throughout the Bay Area via presentations and newsletter inserts for pipefitting unions and engineering societies. In 2003, the BAPPG copper subcommittee successfully completed two fact sheets and a Power Point presentation to be used by all Bay Area water agencies to create a set of fact sheets and a giveaway item to be distributed throughout the Bay Area via presentations and newsletter inserts for pipefitting unions and engineering societies. In 2003, the BAPPG copper subcommittee successfully completed two fact sheets and a Power Point presentation to be used by all Bay Area water agencies. The group compiled a list of unions and engineering groups, which include the following: Local 342: Alameda County and the refineries in Contra Costa County Local 343: Napa and Solano Counties Local 467: San Mateo County Local 393: Santa Clara County Local 38: San Fran, Marin, Sonoma, Lake and Mendocino Counties Local 159: Contra Costa County PHCC: Plumbing Heating and Cooling Contractors ASHRAE: American Society of Heating, Refrigerating and Air Conditioning Engineers ASPE: American Society of Plumbing Engineers NACE: National Association of Corrosion Engineers Clean Bay Pollution Prevention Plan 2008 Page 54 of 124

64 Table 6-1. Copper Pollution Prevention Plan Source Audiences Message / Program Implementation Plan & Timeline Evaluation Criteria GOVERNMENT AGENCIES Vehicle maintenance Fleet managers Use low copper brake pads when data become available on copper content Keep fleet manager apprised of new information on copper content of after-market pads (future) Evaluations on hold, pending multiyear copper brake pad study COMMERCIAL / INDUSTRIAL Corrosion in copper pipes, cooling towers and cooling water systems Plumbers, Designers, architects Facility managers Limit corrosion of copper pipes and equipment via design and maintenance In 2007 BAPPG staff presented to 1 pipe-fitter union. In 2008, continue to facilitate outreach from member BAPPG agencies to regional unions. In 2008, BAPPG will also partner with Green Plumbers USA to begin presenting at their Caring for Our Water workshops that target experienced plumbers. Estimate of the number of plumbers and engineers contacted at association meetings throughout the BAPPG service area. Review survey results. Architectural uses (roofs) Architects; designers; city planners Copper roof materials contribute to stormwater pollution In 2009, distribute newly developed brochure on cooling tower additive restrictions, including copper restrictions, to local facility managers and cooling system maintenance contractors. Ensure that development center staff continues to enforce the ordinance. Completion of outreach effort. Enforcement of the ordinance. Clean Bay Pollution Prevention Plan 2008 Page 55 of 107

65 Table 6-1. Copper Pollution Prevention Plan (continued) COMMERCIAL / INDUSTRIAL (Cont) Metal finishers and platers Business facility staff Continue to aggressively enforce copper and nickel discharge limits and ordinance requirements Semi-annual industrial inspections and appropriate enforcement actions (on-going) Industrial waste metal concentrations; change in ordinance violations. Metal part machining and fabrication Machine shop staff and metal fabricators Continue to aggressively enforce machine shop BMPs and ordinance requirements In 2008, the one remaining facility was 100% in compliance with BMPs. Annual inspections and appropriate enforcement actions (ongoing) Percent compliance with BMPs during annual inspections. Automobile brake pads RESIDENTIAL Pool maintenance Auto parts stores Vehicle service facilities Brake pad manufacturers Residents; pool maintenance workers Continue to seek reductions in copper content. Don t use copper algaecides or discharge pool water to storm drains Continue to support the Brake Pad Partnership program. Pressure manufacturers to reduce copper in brake pads and to enhance the current monitoring program. Continue to distribute SCVURPPP pool brochure to residents upon request or in response to illicit discharges. In 2009, give a presentation to a local swimming pool worker association and distribute the SCVURPPP brochure. Evaluations on hold, pending multiyear copper study Distribution of brochures Completion of presentation Clean Bay Pollution Prevention Plan 2008 Page 56 of 124

66 To address difficulties water agency staff experienced in getting responses from the union and engineering representatives, the City of Palo Alto funded a contractor to provide support for this task. In , the contractor organized BAPPG members to present to 11 different unions and engineering groups throughout the Bay area. This activity has been placed on hold, as membership in the professional associations does not change significantly from year to year. In 2005, the Apprenticeship Program at the Pipe Trades Council has taken the presentation originally developed for the BAPPG speakers presentations and has incorporated the information into their permanent curriculum that focuses on Environmental Issues relating to the Pipe Trades. The copper pollution prevention message will now become part of their annual apprenticeship training. This point is being shared with the other local unions, which are being encouraged to consider doing the same. In 2008, Palo Alto s contractor, Stephanie Hughes, updated the copper presentation and gave two presentations to the UAL 467 Plumbers Union in San Mateo County, educating approximately 35 students. San Francisco Public Utilities Commission retained Ms. Hughes to present to 120 plumbers at UAL 38 in San Francisco County. In 2009, BAPPG will contract with Ms. Hughes to organize and present the updated presentation to the plumber unions throughout the bay area. In 2007, a new organization, Green Plumbers USA, was started in California. Green Plumbers USA provides classes for experienced plumbers who would like to become green plumber certified. One of the Green Plumber s workshops is Caring for Our Water, which has a section specifically focused on stormwater pollution prevention. In 2009, BAPPG will work toward partnering with Green Plumbers to help educate experienced plumbers about minimizing copper corrosion to protect the Bay. BAPPG looks forward to this partnership opportunity, which will enable BAPPG to educate experienced plumbers. 2. Copper Roofing Materials In 2000, the RWQCP investigated the relative importance of copper used in roofing materials. Based on the analysis, the City of Palo Alto adopted an ordinance prohibiting the use of copper roofing materials that became effective in The ordinance has the following two provisions: Prohibits the use on new roofs of either copper metal roofing or asphalt shingles containing copper granules. (Exempts copper flashing, ornaments and replacement metal roofing on historic structures. Requires replacement roofing to be prepatinated.) Prohibits the use of copper gutters, but exempts replacement gutters on historic structures A fact sheet was developed regarding this ordinance and is available at the City s Development Center, where all building permits are handled. Although the architectural copper prohibition is now institutionalized, Environmental Compliance staff meets with Development Center staff on an annual basis to ensure that residents are notified early in the permit process about the prohibition. 3. Metal Finishing Facilities Most industrial copper use in the RWQCP service area is at metal finishing facilities, and the industrial portion of the copper source reduction efforts is therefore focused on metal finishing operations. In 1994, the RWQCP service area cities adopted Sewer Use Ordinance requirements specific to metal finishers and printed circuit board manufacturers. Metal finishers that use copper were required to select one of two options for compliance. The first option, known as the RCM Option, involves: Clean Bay Pollution Prevention Plan 2008 Page 57 of 124

67 Installation of the Reasonable Control Measures; Meeting an annual average copper concentration limit of 0.4 mg/l of copper in the facility wastewater discharge. The second option, called the Mass Limit Option, involves: Performing a RWQCP-conducted pollution prevention study; Using the study to set a facility-specific annual copper discharge mass limit consistent with implementing identified pollution prevention measures that have a payback period of five years or less. In recent years, the decline of the local printed circuit board industry has dramatically reduced copper loading from metal finishing facilities. Metal finishing facilities, however, continue to be a focus of the RWQCP Industrial Waste group, including minimum semiannual inspections and monthly sampling events. Compliance details for the metal finishing facilities, including comparisons of annual copper loadings and average copper concentrations with the applicable limits, are available in the RWQCP s 2008 Pretreatment Program Annual Report. D. Contingency Plan The RWQCP s Copper Contingency Plan (Table 6-2) was developed in the 1990s prior to adoption of Site Specific Objectives for copper in South San Francisco Bay. At that time, copper concentrations in the RWQCP s effluent regularly exceeded applicable water quality objectives. The Plan is retained as a list of potential future actions that could be undertaken if the RWQCP was unable to meet copper effluent limitations. Several of the contingency plan elements have been implemented by Palo Alto and other Bay Area dischargers. Table 6-2. Preliminary Copper Contingency Plan Contingency Action Discharge Reduction Add corrosion inhibitor to local drinking water Reduce copper piping corrosion by an supplies. estimated 30%, if inhibitor addition was implemented in all San Francisco Water Create financial incentives for implementation of copper pollution prevention measures at private businesses, emphasizing measures for largest copper dischargers. District supplies in the RWQCP service area Reduce copper wastewater discharge from industrial copper use, from cooling towers, and from circulating hot water systems. Some additional reductions in industrial process copper discharge (currently about 4% of RWQCP influent copper), cooling water copper corrosion discharges (currently 6% of influent copper) and circulating hot water system discharges (which may be as much of 7% of influent copper) are possible. Clean Bay Pollution Prevention Plan 2008 Page 58 of 124

68 Table 6-2. Preliminary Copper Contingency Plan (continued) Contingency Action Advocate use of CPVC piping and/or restrict use of copper piping in new construction and remodeling. Implement regional training and certification program for plumbers. Require use of recommended fluxes and solders and adherence to IAPMO best management practices during all copper plumbing installation. Adopt copper pipe flow velocity restrictions as part of city building codes. Recommend lower operating temperatures for home and business hot water systems (while maintaining user safety and sanitation). Prohibit installation of open cooling towers and prohibit towers with copper piping and parts. Expand wastewater reclamation programs. Investigate and consider implementing chemical addition to increase copper removal at the RWQCP. Expand water conservation education and incentive programs. Discharge Reduction Reduce copper discharges from corrosion of copper piping. Rate of reduction is uncertain as the current pipe replacement rate in the service area is unknown. Since replacement rate is probably slow, significant reductions would probably not be achieved for 5 to 10 years. Reduce copper discharges from corrosion of copper piping due to poor installation practices. The amount of reduction that would be achieved is unknown. Reduction would slowly increase as piping is replaced. Reduce copper discharges from corrosion and erosion of copper piping. The amount of discharge reduction is unknown, but could be measurable depending on current average flow velocities. Reduction would slowly phase in as piping is replaced. Reduce copper discharges from corrosion of hot water piping (which occurs at an accelerated rate). The amount of discharge reduction is unknown. Reduce copper discharges from cooling towers (6% of RWQCP copper influent) as the restriction phased in. Preliminary data suggest that at least half of the cooling water systems in the service area are open systems or contain copper, and that copper discharge reductions of more than 50% are possible if such systems are replaced with copper-free closed systems. Reduce the amount (but not the concentration) of copper discharged to San Francisco Bay by an amount proportional to the amount of wastewater diverted from Bay discharge. Increase copper removal efficiency at the RWQCP, decreasing copper discharge concentration. Copper discharge reduction (if any) is unknown. (Full-scale testing would be required to determine the potential reductions.) Reduce copper discharges associated with water use, primarily from water supply and corrosion. The amount of reduction would be proportional to the decrease in indoor water use achieved. Clean Bay Pollution Prevention Plan 2008 Page 59 of 124

69 E. Program Evaluation Influent and effluent loadings are tracked to evaluate overall success of the copper outreach programs. Figures 6-3 and 6-4 present the annual copper mass loadings in the RWQCP s influent and effluent from 1999 through Influent copper mass loading decreased steadily during the 1990s, but has generally been higher since During this same time period, effluent copper loading has also increased. In addition to influent and effluent mass loadings, copper concentrations in the RWQCP s incinerator ash have sometimes exceeded the soluble threshold limit concentration (STLC) hazardous waste limit for copper. (Starting in 2007, the ash is being taken to a Hazardous Waste Landfill.) Influent Copper (lbs/year) Figure 6-3. Copper Influent Loading: Year Clean Bay Pollution Prevention Plan 2008 Page 60 of 124

70 Copper Effluent (lbs/yr) Figure 6-4. Copper Effluent Loading: Year Elevated Copper in Influent Despite the RWQCP s ongoing source control programs addressing copper, the influent copper loading in recent years has been significantly higher than the lowest loading that was observed in As depicted in Figure 6-5, copper loading from industrial processes decreased by over two-thirds between 2000 and Throughout the 1990s, the RWQCP influent loading and the industrial process loading were both decreasing as programs addressing metal finishing facilities and a copper root control chemical ban were implemented. The recent increases in influent loading, which occurred as industrial process loading declined, demonstrate that industry is not the source of the additional loading. Clean Bay Pollution Prevention Plan 2008 Page 61 of 124

71 Copper Mass Loadings (pounds/year) 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 Influent Copper Loading Industrial Process Copper Loading Industrial Process Flow Year 1,800,000 1,600,000 1,400,000 1,200,000 1,000, , , , ,000 0 Industrial Process Flow (gpd) Figure 6-5. RWQCP Influent and Industrial Copper Mass Loading, and Industrial Process Flow: 2000, 2001, 2005, 2006, and 2007 As displayed previously in Figure 6-1, corrosion of copper pipes is a significant source of copper in wastewater. The 2007 Clean Bay Plan (published in February 2007) first described a correlation that was observed between RWQCP influent copper concentration and the Langelier Index of the potable water supplied to most of the RWQCP s service area by San Francisco Public Utilities Commission (SFPUC). Langelier Index, also known as Langelier Saturation Index, is a measure of a water s saturation with respect to calcium carbonate, and can be calculated using a water s ph, temperature, conductivity, alkalinity, and calcium concentration. Water with a Langelier Index greater than zero will tend to precipitate calcium carbonate, while water with a Langelier Index less than zero will tend to dissolve calcium carbonate. Maintaining water with a slightly positive Langelier Index has traditionally been believed to provide protection from corrosion. Higher influent copper loadings in 2005 and 2006 tended to occur when the potable water Langelier Index was negative. RWQCP staff met with SFPUC staff in July 2007 to discuss the possible links between increases in copper influent and SFPUC water quality parameters. SFPUC provided literature suggesting that the conditions under which their water supply has a negative Langelier Index (low dissolved inorganic carbon and ph greater than 9) should be very protective against copper corrosion. They also explained that California Department of Public Health has agreed that ph control is the optimal corrosion control treatment for their water supply, and that there is little evidence that Langelier Index correlates with leaching of copper. Figure 6-6 provides the influent concentration and SFPUC Langelier Index data through Influent and Langelier Index data from 2007 and 2008 do not show the correlation observed during previous years. Instead, Langelier Index is seen to be relatively stable at a slightly Clean Bay Pollution Prevention Plan 2008 Page 62 of 124

72 negative value during the summer, while influent copper increases dramatically. The high influent copper concentrations in mid-2007 may be at least partially attributable to the cleaning of a large sewer trunkline that conveys the majority of the RWQCP s influent flow to the plant. This cleaning took place during June and July; a full cleaning of the trunkline had not previously occurred in the RWQCP s 35 years of operation. In addition, the City of Palo Alto Utilities Department hired a contractor to clean and videotape 95 percent of the City s 200 miles of collection system in 2005 and It is possible that these activities may have contributed to the higher influent loadings observed in those years. However, these activities were completed before 2008, when the same pattern of high copper concentrations in the summer months was observed. RWQCP Influent Copper and SFPUC Langelier Index: Jan Dec Influent Copper Monthly Average Influent Copper SFPUC Langelier Index Monthly Average SFPUC Langelier Index 8 6 Influent Copper (ug/l) SFPUC Langelier Index /1/2005 7/2/2005 1/1/2006 7/2/2006 1/1/2007 7/2/2007 1/1/2008 7/1/ /31/2008 Date Figure 6-6. RWQCP Influent Copper and SFPUC Langelier Index The RWQCP will continue to track water supply data throughout The influence of higher ambient air temperatures during the summer months, when copper corrosion appears to be greatest, will also be assessed. A preliminary comparison of air temperature data for Palo Alto appears to show a strong relationship for calendar years 2005 and later. In addition, the RWQCP will conduct a trunkline copper study using historical and recent trunkline and influent monitoring data. The trunkline study will determine whether the seasonal trends are observed in all trunklines. Clean Bay Pollution Prevention Plan 2008 Page 63 of 124

73 2. Elevated Copper in Incinerator Ash As described in the 2007 Clean Bay Plan, RWQCP staff became concerned in 2006 that higher levels of copper were being measured in its incinerator ash by the total threshold limit concentration (TTLC) and soluble threshold limit concentration (STLC) tests. The copper STLC test had sometimes measured individual values greater than the California hazardous waste limit of 25 milligrams per liter. (Compliance with the hazardous waste limit is based on a long term average.). In 2006, the RWQCP investigated why TTLC copper values increased dramatically in 1999 through 2000, more than doubling the values that were measured in 1997 and 1998 (Figure 6-7). Analyses on archived ash samples from this time period, and on more recent samples, demonstrated that in the TTLC and STLC tests began measuring a greater percentage of the true total amount of copper present in the ash. Even though the TTLC test has the word total in it, the nitric acid digestion used in the TTLC test does not dissolve some forms of copper. A more complete measure of the total copper can made with a digestion that uses hydrofluoric acid. It appears that characteristics of the ash changed in the timeframe to allow more of the copper that had always been present in the ash to be solubilized by the TTLC and STLC tests. There are multiple factors that could have contributed to this change, including: Solids from the February 1998 flood working their way through the plant, Rehabilitation of the sedimentation tanks, Rehabilitation of the incinerators, and The first cleaning of the 72 influent line. We do not have a good understanding of how these events could have caused more copper to be captured by the TTLC and STLC tests. In Summer 2007, the RWQCP responded to the increased copper concentrations measured by the STLC test by diverting its incinerator ash to a hazardous waste landfill. It is hoped that shipping the ash to the hazardous waste landfill will be a temporary measure, and that it will be possible to resume beneficial use of the ash as a fertilizer for farm and pasture land application. In 2009, as described in Section 7, Programs for Other Pollutants, the RWQCP will work to reduce molybdenum concentrations in the ash to ensure that the ash meets or exceeds all California Department of Food and Agriculture requirements for registration as a Commercial Fertilizer. If molybdenum concentrations can be reduced to acceptable levels, we will consider working with an agronomist to demonstrate that the copper concentrations in the ash are safe for land application, and to work with the Department of Toxic Substances Control to obtain a waiver that would allow a resumption of land application. Clean Bay Pollution Prevention Plan 2008 Page 64 of 124

74 TTLC Copper (mg/kg) TTLC STLC Influent Copper STLC Limit = 25 mg/l STLC Copper (mg/l), Influent Copper (ug/l) Year and Quarter Figure 6-7. RWQCP Quarterly Average TTLC and STLC Copper in Ash, Annual Average Influent Copper ( ) Clean Bay Pollution Prevention Plan 2008 Page 65 of 124

75 Section 7 : Trash Program Trash has been found at high levels in some sites within San Francisco Bay Area watersheds, creeks, and the Bay. State regulators appear ready to require new trash control programs as they have done in Southern California. On February 11, 2009, the Water Board listed two of Palo Alto s creeks, San Francisquito Creek and Matadero Creek, on the 303(d) list for trash. The listing must be approved by the State Water Board and Environmental Protection Agency prior to becoming final. The new trash control programs will, in all likelihood, be triggered by a new storm water discharge permit for Palo Alto, and later made even more stringent by a new TMDL for trash. Palo Alto is proactively taking a variety of actions to address to reduce trash impacts in our local community and in the wider environment. A. Stormwater Sources Trash is not a new problem for the Bay Region, but it is a continuing problem as an aesthetic nuisance, as a serious threat to aquatic life in tributaries, and as a threat to marine life in estuaries and oceans. Data suggest that plastic from trash persists for hundreds of years in the environment and can pose a threat to wildlife through ingestion, Biodegradable 13% Large 1% Metal 7% Misc 5% Trash Characterization Santa Clara County Creeks Toxic 1% Construction 3% Glass 7% Biohazard 1% Fabric/Cloth 2% Plastic 60% Percentage of Litter Types Observed in Santa Clara County Creeks (35 sites) entrapment, and entanglement, and this plastic can leach potentially harmful chemicals to the aquatic environment. The data in Figure 1, compiled by the Santa Clara Valley Urban Runoff Pollution Prevention Program, confirms that Bay Area public agencies have a continuing problem with plastic litter in our waterways. Plastic bottles, bags and Styrofoam pellets were the single most common and abundant types of trash surveyed and removed. (SCVURPPP 2007, SFBRWQCB 2007) Proportion of Trash Pieces, by category, observed during Rapid Trash Assessments of San Francisco Bay Creeks (SCVURPPP 2007) Clean Bay Pollution Prevention Plan 2008 Page 66 of 124

76 The Cost of Plastic Litter to Wildlife Even with best efforts to control litter, a proliferation of plastic disposable items find their way into the Bay Area s diverse watershed areas. The U.S. National Park Service estimated that on land it takes 10 to 20 years for a plastic bag to break down into tiny plastic particles. 4 Definitive studies on the breakdown rate of plastic bags in the marine environment were not found; however, it is believed to take much longer than on land, as seawater slows the rate of degradation. Whether the bags degrade on land or in the ocean, the remaining plastic particles are largely indigestible. In the ocean, plastic can carry harmful bacteria and various toxic pesticides which then may be transferred to ocean life, particularly when the plastic is ingested by marine filter feeders. Toxins ingested by filter feeders can Guadalupe River, 2007 (photo courtesy of L.M. Johmann) accumulate up the food chain to reach dangerous levels. 5 According to the Marine Mammal Commission, 51 species of seabirds, 34 species of fish, 19 species of seal and sea lion, 11 whale and dolphin species and 6 species of turtle are common victims of entanglement in nylon fishing nets, plastic bags and six pack rings. 6 In Cairns, Australia, a beached whale was examined after death and 6 square meters of plastic were found in its stomach. Sea turtles, like other species such as whales, mistake plastic in the water for jelly fish or other food. The bags can choke the animal or restrict food absorption in the body leading to injury or death. Greenpeace reported that 50-80% of the endangered sea turtles found dead had ingested marine debris. Young turtles are particularly affected when plastic takes the place of necessary food. Out of those that died, 12% died from ingestion of plastic bags. Further, even with millions of dollars spent on mandated cleanup, plastic debris in the ocean is actually increasing The Marine Debris Research, Prevention and Reduction Act: A Policy Analysis, Columbia University, Summer The Marine Debris Research, Prevention and Reduction Act: A Policy Analysis, Columbia University, Summer Clean Bay Pollution Prevention Plan 2008 Page 67 of 124

77 The North Pacific Gyre harbors an enormous accumulation of plastic debris and researcher Dr. Marcus Eriksen believes the Great Pacific Garbage Patch is in fact two massive areas of swirling rubbish that are linked. Dr. Eriksen says the gyre stretches from about 500 nautical miles off the coast of California, across the Northern Pacific to near the coast of Japan. 8 The Algalita Foundation has been studying marine debris in this area for years and in 2000, Algalita found an alarming number of plastic bags in the center of the Gyre. B. Trash Pollution Prevention Plan The pollution prevention plan for Trash is presented in Table 7-1. For the coming year, the RWQCP will focus on eliminating the use of single use checkout bags at large grocery stores, eliminating the use of disposable food service containers made out of expanded polystyrene, mandating the use of tarps for covering loads delivered to the Palo Alto landfill, and participation in creek cleanup events. 1. Comprehensive Reusable Bag Program Plastic comprises approximately sixty percent of the litter found in local creeks. One way to reduce the amount of plastic in local creeks is to reduce the number of plastic bags that are used within the City. In 2006, the City adopted a Zero Waste Operational Plan which included a plan to develop a solution to problems caused by single-use plastic bags. Plastic bags were noted in the Zero Waste Plan as a problem not only because these bags were going into the landfill, but because they were a persistent and plentiful form of litter in City streets, storm drains, creeks, and the Bay. There is a high cost associated with both the cleanup and the environmental impact of littered plastic bags. Numerous studies have determined that plastic takes many years to break down and these bags have been found in the stomachs and throats of marine animals, when mistaken for food, causing injury and death. These problems are universal, not only to Palo Alto but the entire world and many of those communities have sought to eliminate these bags entirely by banning them or charging a fee. City staff is currently partnering with local retailers on a campaign to promote the use of reusable retail carryout bags. Local retailers have been very supportive of this campaign. City staff is committed to finding ways to reduce the high volume of disposable bags in the waste stream and the marine environment. Significant improvements can be made, as a 2008 survey leading up to the campaign determined that about ten percent of the carryout bags observed were reusable bags. Following a series of stakeholder meetings in the Spring and Summer of 2008, City staff prepared a Comprehensive Reusable Bag Program consisting of 1) prohibition of single use plastic checkout bags, 2) a fee on paper checkout bags, and 3) outreach and promotional programs to encourage the use of reusable bags. These three components are designed to work together to reduce the number of plastic bags entering the natural environment and to encourage a shift to reusable bags, rather than a shift to paper bags. In 2009, Palo Alto intends to adopt an ordinance that would eliminate single use plastic checkout bags at large supermarkets. Actions at 8 La Canna, Xavier (Friday, February 4), "Floating rubbish dump 'bigger than US'", News.com.au (Australia: news.com.au), < Retrieved on 26 February 2008 Clean Bay Pollution Prevention Plan 2008 Page 68 of 124

78 other stores would follow as meetings with those affected occur and as issues raised are resolved. A paper bag fee system is currently under development and will be carefully coordinated with County and State efforts to ensure either implementation of one fee system, or consistency of fee systems. 2. Proposed Ordinance to Restrict Expanded Polystyrene Disposal Food Containers In addition to the City s efforts to reduce the impacts of single-use plastic bags, City staff are working to restrict the use of expanded polystyrene food service containers in Palo Alto. Polystyrene litter is a threat to natural ecosystems due to its light weight and its tendency to break apart into very small pieces that are similar in size and appearance to the food of some wildlife species. The main chemical constituent of polystyrene is the styrene monomer which has been identified as a suspected carcinogen and neurotoxin by the United States Environmental Protection Agency. Palo Alto is currently unable to accept expanded polystyrene in its recycling program, leading to its disposal in landfills or as litter in the environment. Therefore, in 2008, City staff drafted an ordinance that would restrict the use of expanded polystyrene and other nonrecyclable plastics as disposal food service containers. In 2008, Palo Alto staff sent a letter summarizing the proposed Ordinance to 375 Palo Alto Food Vendors and coordinated with the Chamber of Commerce to hold a stakeholder meeting to discuss the Ordinance. A number of other cities have also prohibited the use of expanded polystyrene in disposable food containers. In 2009, Palo Alto intends to adopt the ordinance, which would become effective one year from the date of adoption. The primary goal of the proposed Ordinance is to restrict the use of expanded polystyrene disposable food service containers by Food Vendors, creating a shift to multi-use containers where possible. Where multi-use containers are not viable, the desired shift is to recyclable plastic or fiber (paper) containers. Although all single-use products produce negative aesthetic effects when not disposed of properly, the Ordinance addresses the unique problems presented by expanded polystyrene with respect to its impacts on the environment. Clean Bay Pollution Prevention Plan 2008 Page 69 of 124

79 Table 7-1. Pollution Prevention Plan for Trash Reduction Source Audiences Message / Program Implementation Plan & Timeline GOVERNMENT AGENCIES Trash in creeks Trash in creeks Trash in creeks Green Streets Team Public Works Operations Public Works Operations Commercial / Industrial Plastic Bags Large Grocery Stores Expanded Food Polystyrene Vendors Pick up trash in creeks by green streets team Improve the removal of trash in local creeks Improve removal of trash by stormwater pump stations Ban Singleuse checkout bags Ban Expanded Polystyrene RESIDENTS Plastic Bags Residents Bring your own bag Litter from open vehicles Residents Cover loads with tarp to prevent wind-blown trash In 2009, pilot a program to expand Palo Alto s Downtown Sreets team program to include hiring low income and homeless persons to pick up trash in local creeks. In 2009, work with Santa Clara County Water District and Public Works Operations to install and maintain a trash collection boom on Matadero Creek downstream of the Matadero pump station. Continue participation in SCVURPPP-sponsored program to assess stormwater pump stations to identify methods to improve trash retention rates over retention of current trash racks. In 2009, adopt an ordinance to restrict single-use checkout bags at large grocery stores. In 2009, adopt an ordinance to restrict the use of expanded polystyrene disposable food service containers by Food Vendors In 2009, increase awareness of the new ordinance restricting single use check-out bags and educate residents to bring their own bags when shopping. In 2009, adopt new fee and tarp give-away program for residents arriving at landfill with uncovered loads. Evaluation Criteria Quantity of trash collected and number of participants. Improvement in creek trash assessment scores. Installation of trash boom and quantity of trash collected. Implementation of any new methods to improve trash retention. Level of compliance with ordinance requirements. Completion of outreach to food vendors preliminary to 2010 effective date of restriction Increase in percentage of reusable bag use (if data is available). Adoption of proposed fee. Decreasing rate of fees assessed as program is effective in changing behavior. Clean Bay Pollution Prevention Plan 2008 Page 70 of 107

80 3. Tarp Program at the Landfill One pathway for trash to enter the environment is by blowing out of the back of pickup trucks on the way to the dump. Local statutes require that loads in trucks be covered with a tarp, but this law is difficult to enforce. In 2008, Palo Alto staff participated with the Santa Clara Valley Urban Runoff Pollution Prevention Program in a tarp giveaway program at landfills. In Santa Clara County, 1071 tarps were given to people who showed up at Santa Clara County landfills without a tarp in April and November. In 2009, Palo Alto plans to impose a new $21 fee for those vehicles arriving at the landfill that do not cover their load. Upon paying the fee, Palo Alto staff will give drivers of those vehicles a tarp. This will be a pilot program for the County to determine if charging a fee combined with a tarp give-away is effective in modifying behavior. 4. Participation in Creek Cleanups In 2008, Palo Alto staff participated in and assisted with the May 17 National Rivers Cleanup Day and the September 20 California Coastal Cleanup Day. Palo Alto staff organized a new cleanup location on San Francisquito Creek as part of the National Rivers Cleanup Day. Over 1,800 volunteers helped clean up twenty-six Santa Clara County locations totaling almost 39 linear miles of waterways, and removed 95,656 pounds of trash and 26,327 pounds of recyclables. This was a substantial gain in volunteers and trash / recyclables removed from previous Coastal Cleanup Day events. The three sites in Palo Alto addressed four specific areas on three creeks. The Palo Alto locations had 379 volunteers who cleaned more than 4.5 linear miles to remove 7,000 pounds of trash and 1,075 pounds of recyclables. The site on San Francisquito Creek had three homeless encampments, which required police presence during the cleanup. The group found a significant Clean Bay Pollution Prevention Plan 2008 Page 71 of 124

81 amount of spray cans used for graffiti, cigarette butts, and used caution regarding potential to find needles and human waste. In 2009, Palo Alto plans to coordinate and participate in the May and September cleanup events, and is considering organizing an additional event as part of the Great American Cleanup Day. 5. Base Programs for Trash Control In addition to the new programs described in 1-4 above, the City operates the following base programs for trash control: Street sweeping Enforcement of litter laws Trash collection and disposal Recycling program Trash removal and clean-up of City parking lots, parks and other City property Inspections of dumpster areas during food service establishment inspections (Note: This activity increased dramatically in 2007 and 2008 with the addition of a full-time dedicated food service establishment inspector) C. Trash Program Evaluation 1. Participation in Creek Cleanups The creek cleanup in Palo Alto was a success. Over three hundred Palo Alto volunteers cleaned more than 4.5 linear miles to remove 7,000 pounds of trash and 1,075 pounds of recyclables at 3 locations in the creeks. In 2009, Palo Alto will participate in the creek cleanup efforts again. 2. Trash Assessments Since 2005, Palo Alto staff has conducted trash assessments twice a year in certain local trash hot spots. In 2005, there were 20 trash hot spots. In 2008, there were 16 trash hot spots. The creek sites are assessed for trash using two methods: a rapid trash assessment that has a score up to 120 and a Keep America Beautiful assessment from 1 to 4. The rapid trash assessment reviews the quantity and type of trash in the creeks. The assessment also attempts to determine where the trash came from. In 2008, according to the rapid trash assessments our creeks had an average score of 90 before the creek clean up events. After the creek cleanup events the creeks scored 115 out of 120. According to the rapid trash assessments, the majority of the trash comes from homeless encampments or from illegal dumping. The other creek health score is based on keep America beautiful scoring system which is from 1 (best) to 4 (worst). The score is subjective score based on a brief scan of the creek. In 2008, the creeks had an average score of 1.5, with one location ranked a 4 due to the amount of plastic and Styrofoam in the creek. Clean Bay Pollution Prevention Plan 2008 Page 72 of 124

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83 Section 8: Programs for Other Pollutants In addition to the pollutants of primary focus mercury, pesticides, copper, and trash the RWQCP continues to implement a number of programs that focus on other pollutants. These programs are summarized in Table 8-2. The Dioxin and Furans Program; Fats, Oils, and Grease Program; and Silver Hauling Program, as well as efforts to address molybdenum levels in the RWQCP s incinerator ash and salinity species in the RWQCP s recycled water are further described below. A. Dioxins and Furans Program Polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs), referred to collectively as dioxins, are on the CWA 303(d) list as impairing San Francisco Bay. In the following pages, two programs are highlighted: 1) a chlorine-free paper product program, and 2) a biodiesel fuel evaluation program. 1. City Paper Purchasing In 2001, in response to regional concerns about dioxin and the adoption of a mercury and dioxin reduction policy, the City of Palo Alto began purchasing process-chlorine-free (PCF) paper paper that does not use chlorine-based bleaching agents during its manufacture. The paper is 100 percent post-consumer recycled content and is bleached with hydrosulfite and hydrogen peroxide instead of chlorine. The purchasing change was institutionalized by revising the City s paper purchasing specifications. In 2002, the City began purchasing unbleached paper towels and elemental-chlorine-free toilet tissue. In 2003, the purchase of PCF copy paper and letterhead was suspended due to its high cost and the City s need to reduce expenses. PCF, unbleached or alternatively bleached restroom paper is still purchased. Table 8-1 lists Palo Alto s current paper purchases. Table 8-1. Current Palo Alto paper purchases Hand towels Bay West EcoSoft 100% recycled 40% post-consumer waste, bleached using hydrogen peroxide and sodium hydrosulfite (Fort James) Toilet Paper Letterhead JC 100% recycled, unbleached, 1-ply toilet tissue. Discontinued. Current paper is Boise Aspen 20lb 30% Post consumer content.palo Alto s Purchasing department discontinued the purchase of PCF products due to cost in As part of the City s Green Procurement Program, office and printing supplies are being reevaluated in 2009 to increase recycled content. Clean Bay Pollution Prevention Plan 2008 Page 73 of 124

84 Table 8-2. Additional Pollution Prevention Priorities Pollutant and Source Audiences Message / Program Implementation Plan & Timeline Evaluation Criteria GOVERNMENT AGENCIES Dioxins, diesel exhaust Salinity, salt water infiltration City fleet manager City public works and utilities departments Keep all vehicles tuned up Consider alternatives to diesel fuel Paper purchasing Direct saline pumped groundwater discharges away from sanitary sewer Find and repair locations of salt water infiltration into sanitary sewer COMMERCIAL / INDUSTRIAL Silver from photographic and X-ray development Photoprocess ors Medical/dent al offices Meet ordinance requirements and minimize silver discharges to sewer As workload allows, will resume discussions with Fleet Maintenance staff regarding continued use and program commitment to biodiesel use. Begin tracking new technologies to determine if biodiesel remains cleanest and cheapest alternative. In 2009, City will assess opportunities to revise paper specifications to minimize dioxin emissions. Assist City of Mountain View as needed to obtain general permit and redirect saline groundwater discharges to tidal areas of Stevens Creek and Charleston Slough. Compare before and after salinity profile in MV1 trunkline using upstream and downstream salinity species sampling and continuous conductivity monitoring. Work with and encourage City of Mountain View to identify and repair salinity infiltration into MV1 trunkline. Evaluate whether salinity infiltration is responsible for relatively higher TDS concentrations in CPA2 trunkline and take any appropriate actions to correct problems. Continue annual self-certification by entities hauling waste off-site. Sampling and reporting by entities treating and discharging photographic wastewater. The ten permitted sites had no violations in Percent of biodiesel relative to total diesel over time. Cost of cleanliness of biodiesel compared to other technologies. Status of paper purchasing preferences. Rerouting of Mountain View well discharges from the sanitary sewer Reductions in MV1, CPA2, and recycled water TDS, conductivity, sodium, and chloride Percentage of participation in self-certification. Number of silver violations per permitted sites. Clean Bay Pollution Prevention Plan 2008 Page 74 of 107

85 Table 8-2. Additional Pollution Prevention Priorities (continued) Pollutant and Source Audiences Message / Program Implementation Plan & Timeline Evaluation Criteria COMMERCIAL / INDUSTRIAL (continued) Molybdenum from cooling systems Grease from food handling (FOG) RESIDENTIAL Dioxin from Fireplaces Facility Managers at Commercial and Industrial facilities, cooling system maintenance contractors Restaurant owners and staff Residents Replace molybdenumcontaining cooling system corrosion inhibitors with acceptable alternatives Sewer ordinance requires grease removal devices to be installed and maintained Participate in BAAQMD rebate programs Collect information on cooling system chemicals in use during industrial inspections. In 2009, adopt and implement ordinance prohibiting the use of molybdenum-containing cooling system chemicals In 2009, distribute newly developed brochure on cooling tower additive restrictions, including molybdenum restrictions, to local facility managers and cooling system maintenance contractors. Adopt new Sewer Use Ordinance provisions developed in 2008 to enhance sewer and storm drain pollution prevention requirements for food service establishments. Inspect one-third of Palo Alto food service establishments (as follow up and enforcement actions allow) Solicit proposals to contract with one or more grease haulers to service all Palo Alto food service establishments Continue to investigate possibilities for biodiesel production using service area FOG Publicize wood burning BMPs in November January 2010 timeframe with additional emphasis on greenhouse gas issues and new Air District wood burning restrictions Success in compiling information. Implementation of ordinance. Completion of outreach effort; molybdenum concentration in RWQCP influent and incinerator ash. Adoption of new ordinance provisions Number of restaurants inspected; percent compliance with ordinance requirements. Completion of outreach effort. Clean Bay Pollution Prevention Plan 2008 Page 75 of 124

86 2. Biodiesel Purchases Biodiesel is produced from natural renewable resources: vegetable oils, such as soy, canola, tallow, and restaurant greases. Made from cooking oils and alcohol, biodiesel is biodegradable and very safe to handle. Biodiesel reduces dioxin emissions as well as other air pollutants and reduces production of greenhouse gases. There are two general categories of biodiesel: 100 percent biodiesel ( B100 ) and a blend of 20 percent biodiesel with 80 percent petroleum diesel ( B20 ). In 2001, Palo Alto began piloting B20 in the equipment used at the City's landfill and golf course. Engines responded well to the new fuel, and the fuel switch created minimal impacts on staff time. Based on those results, the City began using biodiesel in landfill and golf course equipment. In 2005, the street sweepers switched from using biodiesel to natural gas. In 2006 and 2007 biodiesel use was intermittently suspended due to clogging fuel filters and performance issues of the landfill equipment. Issues could be stemming from the quality of biodiesel that the City is receiving (it is difficult to determine whether the fuel complies with existing ASTM standards). As of 2009, Palo Alto s fleet manager reports that due to the maintenance issues biodiesel has caused, uncertain compatibility with diesel particulate filters, and low diesel prices, he does not have plans to use it in 2009, but is open to reevaluation in late 2009 for 2010 use. 3. Dioxins and Furans Program Evaluation a. Paper Purchases Although local dioxin emission reductions cannot be adequately measured, purchasing nonchlorine bleached office and bathroom papers stimulate markets for these products and contribute to regional dioxin emission reduction efforts. In 2001, the cost was approximately 3.4 percent more for letterhead, 6-14 percent less for hand towels (from previous unbleached product), and 5 percent less for toilet paper. b. Diesel Fuel Alternatives The City s reliance on traditional diesel is among the evaluation metrics for the reduction of dioxins and other air pollutants. Table 8-3 presents the purchases of traditional diesel and biodiesel, beginning in 2000 (baseline). The biodiesel purchases began in Summer 2001 and are reported below as 100 percent biodiesel. When used, the biodiesel is blended with traditional diesel, usually to reach a final concentration of 20 percent biodiesel. The percentage of biodiesel has ranged from 4% to almost 13% throughout the years. In 2005, the use of biodiesel was the greatest at almost 13% of diesel purchases. The total amount of diesel purchased declined in 2005 when the City street sweepers converted to natural gas. In 2006, biodiesel use was suspended in June due to equipment problems, causing the biodiesel percentage to decline to 3.5%. In 2008, the Environmental Compliance Division has offered technical assistance to Fleet staff to identify solutions to biodiesel problems and is also evaluating the implications of low-sulfur diesel use to determine whether low-sulfur diesel should supersede future use of biodiesel. Clean Bay Pollution Prevention Plan 2008 Page 76 of 124

87 Table 8-3. City of Palo Alto Purchases of Diesel and B100 (100% Biodiesel which is later blended with traditional diesel for a 20/80 blend) Year Traditional Diesel (gal) B100 Blend (gal) Percent B100 to Total Diesel Purchases , ,189 5, % ,989 16, % ,366 12, % ,338 6, % ,938 13, % ,728 3, % ,673 6, % B. Fats, Oils and Grease Fats, oils, and grease, abbreviated as FOG, are an issue due to their ability to cause sanitary sewer blockages that may result in discharges of untreated wastewater in Food Service Establishments (FSEs) and to storm drains, creeks and the San Francisco Bay. FOG discharges result from improper management of food waste in residences and commercial FSEs. The RWQCP adopted ordinance language in 1992 requiring FSEs with grease generating activities to install grease removal devices. Additional ordinance requirements addressing FOG from FSEs were adopted in 2002, including a prohibition on installation of food waste disposers (garbage disposals), and a requirement that existing food waste disposers be removed by January 1, The Sewer Use Ordinance was revised in 2008 to include more requirements for FSEs to help reduce the number of FOG related Sanitary Sewer Overflows (SSOs), for purposes of FOG discharge prevention to the sanitary sewer and pollution prevention to storm drain systems. The City s goal is to have the revised ordinance adopted in Implementation of a FOG Control Program The City of Palo Alto implemented a FOG Control Program due to the significant number of FOG generating FSEs in the City and a history of FOG related SSOs. Many of the SSOs are caused wholly or in part by FOG blockages. In 2005, there were a total of 32 grease related SSOs. In 2006, there were 12; 2007, 22; and 2008, 14 FOG SSOs. The benefits of a FOG Control Program include FOG discharge prevention to the sanitary sewer and storm drain systems, storm drain pollution prevention from SSOs and FSE practices, reducing the number of FOG related SSOs, improving public health and safety, avoiding of spill related fines, minimizing property damage claims, minimizing the risk of lawsuits, improving sewer maintenance and improving FSE business environment. Since 1996, Palo Alto has maintained a food service program that included developing and implementing Sewer Use Ordinance (SUO) provisions, site inspections procedures, enforcement actions procedures, Best Management Practices (BMPs) and distribution of literature. FOG Program as it s is now began during the second half of 2006 with the addition of a full time FOG Program Investigator. In 2008, the program put into use a FOG database system on a tablet PC which is used for inspections, data formatting, generation of follow-up letters and storm drain program inspections as they relate to FSEs. Also during 2008, the FOG Program developed the Clean Bay Pollution Prevention Plan 2008 Page 77 of 124

88 criteria for a Grease Hauler Service Contract Work Plan. The Work Plan for the includes Program Objectives, Ordinance Revisions, Request for Proposal (RFP), draft Agreement, draft Council Meeting Review (CMR) and all other documents related to this project. 2. Source Control The City has several high density and high volume restaurant areas including Downtown, Midtown, and the California Avenue Business District, which are known hotspots of FOG discharge. There are also several smaller clusters of FSEs and other individual restaurants that have had overflows or compliance issues in the past. These areas and specific FSEs have been the primary targets for increased inspection, enforcement, and preventative cleaning. The Downtown, Midtown, and the California Avenue Business District areas FSEs are frequently equipped with undersize grease control devices (GCDs) because these have existing buildings that have limited space for expansion or remodeling. Therefore, it is difficult and more expensive to place larger or more efficient grease traps and interceptors in these locations. When a new restaurant is proposed, City staff reviews the FSE building plans and proposes solutions for new construction, remodels, and new restaurants in existing buildings. The Partner Cities remain responsible for their collection systems and are developing independent SSMP and FOG Control Programs. The City of Palo Alto will continue to support the satellite systems as needed with creation of outreach materials, training, and assistance with FSE inspections. The City s FOG Program staff manages plan check and specifications for newly constructed and remodeled FSEs to ensure all items required by the Palo Alto Municipal Code are completed prior to approval for building permits. All grease generating drainage fixtures shall be connected to a GCD. All non grease generating drainage fixtures including hot discharge equipment shall be connected directly to the sanitary sewer system. When drainage fixtures are properly plumbed and the GCDs are properly maintained, there should be very little to no FOG discharging to the sanitary sewer system. Improperly plumbed pipes and drainage fixtures are generally associated with FOG buildup downstream, occurrences of SSOs or backups. New buildings constructed to house food service facilities shall include a covered area for a dumpster. The area shall be designed to prevent water run-on to the area and runoff from the area. Drains that are installed within the enclosure for recycle and waste bins, dumpsters and tallow bins (used oil containers) serving food service facilities are optional. Any such drain installed shall be connected to a GCD and the sanitary sewer. If tallow is to be stored outside then an adequately sized, segregated space for a tallow bin shall be included in the covered area. 3. Food Service Establishment Inspections There are over 300 FSEs in the City of Palo Alto. The FOG program includes rigorous inspections and enforcement. Since each facility will not be visited annually it is important to prioritize the FSEs and conduct more frequent inspections and enforcement where necessary. The FSEs are categorized by their potential to contribute FOG to the collection system or cause other problems such as storm drain violations. Facilities located in hot spots or that have been problematic will be addressed first and receive more frequent inspections. FSEs are prioritized in one of the following categories. Problem FSEs in hot spots Clean Bay Pollution Prevention Plan 2008 Page 78 of 124

89 Problem FSEs FSEs in hot spots FSEs that have only had minor issues in the past. FSEs with potential to generate FOG FSEs without significant potential to generate FOG (juice bars, coffee shops, etc.) Past experience has shown that some facilities will frequently not meet all requirements and will need ongoing attention. These facilities will be re-visited as necessary. Facilities that demonstrate compliance will receive less attention. During the inspections the FSE will be ranked on a scale of 1 (worst) 5 (best) on their compliance with BMPs and ordinance requirements. FSEs that cause problems in the sanitary sewer, storm drain systems or have violations of their BMPs will be rated 1 or 2 depending on their location. The problematic facilities that rank 1 or 2 have one of more of the following issues: Experienced back-ups or overflows Contributed to FOG build up in the sanitary sewer (identified by CCTV or cleaning records) Unresolved compliance issues Failed to follow the proper BMPs Failed to keep records Had storm drain violations Failed to comply with verbal or written directives In July of 2008, the ECD received updated lists of FSEs from the County of Santa Clara, Department of Environmental Health, Consumer Protection Division. Not all of the 393 facilities on the list require an inspection by the City of Palo Alto as many are farmer s markets, gas stations and general food vendors. Some of the facilities required more than one follow-up inspection. A copy of the inspection form is in Appendix D. In 2008 there were 374 FSE storm drain system inspections which included initial and follow-up FOG inspections. 33 full FOG inspections were conducted including 13 Green Business Compliance inspections approving 9 to be in compliance for the certification. Only 4 of the 33 FSEs inspected were in compliance at the time of full inspection. Efforts were concentrated in areas of known problems and facilities with historical issues or known potential to discharge grease. Two residential inspections were conducted at apartments buildings in 2008 which were triggered by SSOs. We also conducted 5 FOG Program inspections with our jurisdiction Cities of East Palo Alto, Los Altos Hills and Stanford. Enforcement actions included 36 Compliance Directives, 58 Follow-up Letters, 1 Warning Letter, and 24 Notices of Non-compliance, 1 Compliance Agreement and 4 Administrative Citations. There were 25 more Compliance Directive type of enforcement actions as they were replaced with an automatically generating Follow-up Letter with the new FOG Program Database. Many of the FOG Program compliance issues were storm water related. During the inspection, posters on BMPs for handling FOG are distributed. The Bay Area Pollution Prevention Group (BAPPG) funded CalFOG to create a poster that is available in English, Spanish, Korean, Chinese and Vietnamese. In 2008, 49 posters were distributed (33 English, 13 Chinese and 3 Korean). In addition to the Posters, BAPPG created food scrapers with the RWQCP s insignia and local disposal contact info from Cleanbay.org and a phone number. These food scrapers are BMP tools to help scrape off any remaining food and FOG waste into the trash prior to rinsing kitchen Clean Bay Pollution Prevention Plan 2008 Page 79 of 124

90 items. The City distributed at least 2 food scrapers to each FSE during inspections and during many follow-up inspections. A total of 250 food scrapers were distributed to the City of Los Altos for their FOG outreach projects. Compliance with storm drain regulations is also assessed during the inspections. Outdoor cleaning of kitchen equipment, dumping of mop water, and poor housekeeping around trash compactors, trash bins and tallow bins is addressed. Packages provided by the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) have been distributed to 40 FSEs in 2008 during inspections and with Follow-up Letters. This package includes a letter from this group; top ten BMPs for FSEs and a poster addressing stormwater issues. The package is designed for training staff the proper procedures for cleaning FSEs inside and outside. City staff educates the FSE management and staff on ordinance requirements and BMPs to the extent practical during inspections. If a violation is observed the inspector issues a Compliance Directive or addressed in Follow-up Letters. Follow-up Letters have taken more emphasis over Compliance Directives as they can be generated with the new FOG Program database. Followup Letters are sent or issued at the time of inspection as a thank you to the contact person for their time and as a summary of the goals and observations during the inspection. The Follow-up Letter reminds the FSEs to complete tasks to achieve compliance for outstanding violations. For FSEs that do not achieve compliance, enforcement will be escalated according to the RWQCP Pretreatment Program s Enforcement Response Plan Inspection Highlights of Food Service Establishments The City of Palo Alto s highlights for the FOG inspection program are listed below: 33 full FOG inspections 374 FSE storm drain system inspections 36 Compliance Directives were issued 58 Follow-up Letters were issued 1 Warning Letters were issued 24 Notices of Noncompliance were issued 1 Compliance Agreements was issued 4 Administrative Citations including monetary penalties were issued Enforceable actions included: Excessive FOG on and around tallow bins which are a threatened discharge Storm drain discharges or threatened storm drain discharges such as washing kitchen equipment outside allowing wastewater to flow to the storm drain system, also dumping mop wastewater Failure to keep a maintenance log that depicts GCD clean out activities Failure to maintain a GCD by not cleaning the contents out frequent enough not to allow excess FOG to pass down the line Failure to have an adequate or properly functioning GCD Contributing to at least one sanitary sewer overflow (SSO) The presence of food waste grinders that were to be removed by January 1, 2007 For large cafeterias and markets to have their floor finish MSDS submitted by a given due date to ensure they use a Zinc-Free Floor Finish or the can contain its waste and treat it as hazardous waste. Clean Bay Pollution Prevention Plan 2008 Page 80 of 124

91 5. Outreach a. Residential Outreach for residents is an important component of the FOG program. The Clean Bay Campaign highlighted FOG as a pollutant of concern; a description of the Clean Bay campaign is provided in Section 9. In addition to the ads that were part of the campaign, residents received FOG BMP information in their utility bills. There were also ads in movie theater previews and in local newspapers. In 2008, the City of Palo Alto continued the collection of tallow (yellow grease or used cooking oil) at the City s recycling center. b. California Water Environment Association Presentation In April of 2008, RWQCP staff presented the City of Palo Alto s FOG Program highlights at the California Water Environment Association s (CWEA) Annual Conference in Sacramento, CA. In 2009, RWQCP staff will also present an Overview of the City s FOG Program and its Results at the CWEA Annual Pretreatment, Pollution Prevention and Stormwater Conference in Monterey, CA. 6. Regional FOG Groups a. California Fats, Oils and Grease Workgroup In 2008, RWQCP staff continued participating in the statewide California Fats, Oils and Grease (CalFOG) group, a collaboration of wastewater agencies addressing management practices for fats, oils and grease. RWQCP staff created and designed the CalFOG website (located at in 2004, and continues to maintain the site. In 2009, RWQCP staff will continue to support the efforts of CalFOG. b. Bay Area Pollution Prevention Group In 2008, RWQCP participated in Bay Area Pollution Prevention Group s (BAPPG) FOG Hauler Outreach Project. The goal of this project was to create outreach material on the proper FOG disposal and grease pumping requirements of AB 1333 for FOG haulers in the Bay Area. 7. Goals for the FOG Control Program The primary goal of the FOG program is to reduce the number, severity and frequency of SSOs linked to FOG and to reduce the environmental impact, liability and exposure to the City and the costs associated with SSO clean ups. RWQCP staff will continue to contribute to regional programs such as the statewide CalFOG, CWEA and BAPPG workgroups. a. Inspections and Compliance The 2008 Clean Bay Pollution Prevention Plan includes a long-standing goal of inspecting at least one-third of the FSEs each year. The expanded FOG program will include more rigorous inspections and enforcement but will maintain the same goal for the number of inspections (Table 8-4). Clean Bay Pollution Prevention Plan 2008 Page 81 of 124

92 Table 8-4. Summary of FOG FSE inspections for & 2009 goals Year Goal for 2009 Yearly Initial Inspections (33%) Yearly Total Inspections n/a n/a FSEs in Compliance at 20(23%) 4(12%) Initial Inspection n/a 37(32%) 40(36%) Compliance Directive * Follow-up Letter Notices of Noncompliance Warning Letter Compliance Agreement *Compliance Directives will be classified as Notices of Noncompliance Letters in 2009 We have continued to prioritize FSEs in problem areas where, according to the City s Water- Gas-Wastewater Division, major FOG build-up has been identified. These areas have been targeted first due to the need for accelerated line maintenance. When this round of inspections began in 2006 the intent was to complete the initial inspections without too much follow-up and to create a priority list for the next round. Due to the severity of the situations the procedure changed to do more follow-up and correct problems as they were discovered. Once all of the facilities have received an initial visit it should be possible to determine time demands and refine the prioritization. Setting reasonable goals for inspection frequency for each category and percentage of facilities in compliance will then be possible. Also, to reduce the number of 1 and 2 rated FSEs in the ranking system. The City will not know the percentage of all 1 and 2 rated FSEs until all FSEs have been inspected and ranked. The main goals for FSEs are to have GCDs maintained frequently enough to prevent FOG from escaping from GCDs and entering the sanitary sewer system, ensuring all drainage fixtures are correctly plumbed, keeping a maintenance log for GCDs, not to wash kitchen equipment or discharge wastewater to the storm drain system and to maintain the tallow bin and trash areas free of FOG and debris. In 2008, Palo Alto planned on creating a Clean Bay Business certification for FSEs as it applies only to the Sewer Use Ordinance of the PAMC. The City sees the FSEs are not generally in compliance and there needs to be more time to allow FSEs to become more complinant. The FOG investigator continued to inspect FSEs that applied for the County of Santa Clara s Green Business Certification Program and will continue in The initial goal of inspecting at least one-third of the total FSEs each calendar year was adjusted due to elevated levels of follow-up and enforcement actions, in addition to program development tasks. The City plans to continue thorough inspections of FSEs in In 2008 the City s FOG Program staff focused much of its time developing the Work Plan for a Grease Hauler Service Contract. b. Grease Hauler Service Contract The Program Objectives are as follows: The City is interested in receiving proposals from companies that have demonstrated experience providing grease control device (GCD) waste collection, disposal, processing, record keeping and manifesting services comparable to those described in the RFP. The City seeks one or more contractors who place a high priority on maintaining GCDs, disposing waste properly, have demonstrated significant results and Clean Bay Pollution Prevention Plan 2008 Page 82 of 124

93 innovation through its program development, implementation, customer education, and on-going operations. The City s goals and objectives for future services include: Minimize the carbon footprint and other adverse environmental impacts from the provision of service. (The Service Contractor(s) (SCs) can efficiently target sections of the City or more specifically, target streets to be serviced.) Maximize energy recovery. Ensure that GCD waste is collected and transported from customers within the City of Palo Alto to a legally-authorized disposal or treatment facility. Baseline services include disposing GCD waste contents at the RWQCP, although there is a limited amount of capacity. Facilitate efficient and economical food service GCD cleaning and disposal services that are in full compliance with environmental laws and regulations. Identify and minimize sewer blockages, sanitary sewer overflows (SSOs), and stormwater pollution sources created by FOG generated at FSEs. Maintain a high level of service (timely, courteous, and responsive) to customers. Ensure the cost effectiveness of the services provided. Maintain an effective reporting system of all collection and disposal activities which is up to date and available to City of Palo Alto staff, possibly as an electronic database. Ensure a fair Agreement for the SCs, customers, and City. Maintain positive communications with the City and the customer. Fulfill community needs by providing increased outreach and awareness on FOG control issues to the general public and FSEs. Ensure the efficient use of City resources. The SCs with input from the City s FOG Program Manager will determine the frequency at which each FSE s GCD will be cleaned out. The SCs will bill the FSEs directly similar to their current procedures. The City will conduct follow-up and enforcement for problem FSEs refusing service. The SCs will furnish and maintain all equipment to be functional, presentable and professional in appearance and service. All vehicles shall be subject to City s approval. The SCs shall employ and manage its staff. A request for proposals for the Grease Waste Hauler Contract is planned to be released and put into effect in c. FOG Acceptance at RWQCP and Maximizing Energy Recovery In 2008, City staff investigated the FOG acceptance procedures at the RWQCP. The goal was to evaluate the potential to receive all hauler loads associated with the Grease Waste Hauler Contract in the City of Palo Alto and possibly the other Cities in the RWQCP s service area, which would include non-contracted haulers. At this time there is limited capacity for accepting more than the current amount of approximately 6,000 gallons of grease waste hauler loads per day. The RWQCP s acceptance of GCD waste material can not exceed 130,000 gallons per month or 1.56 million gallons per year. The grease waste hauler loads are processed by combining the GCD waste loads with the floatables from the plant s primary sedimentation tanks. This mixture is pumped to the scum concentrator allowing the combined floatables to be bled into the incinerator where it is used as a fuel source to incinerate the biosolids from the plant. The excess water and bottom solid waste from the GCD waste loads are returned to the plant s head-works to be treated with the service Clean Bay Pollution Prevention Plan 2008 Page 83 of 124

94 area s sanitary sewer waste. The ultimate outcome of the FOG is an ash which is disposed at another location. City staff has met with several FOG to biodiesel companies to discuss the option of converting the grease hauler loads combined or separately with the floatables from the sediment tanks to biodiesel. This option is still feasible if the contract hauler becomes effective and increasing the amount accepted. The City will continue to investigate this process in d. Ordinance Revision Anticipated Sewer Use Ordinance revisions are planned for adoption in In this revision, the FOG requirements for FSEs should help reduce the amount of FOG entering into the sanitary sewer ultimately reducing SSOs and reduce stormwater issues with BMP requirements. e. FOG SSOs and Tallow Collection SSO data will be analyzed each year to help monitor the success of the FOG program. The City would like to see a reduction in the number of SSO from grease related blockages in Any FSEs identified through SSO events or sewer-cleaning data will be inspected within two days of notification. The City would like to see tallow collection from residents continue at the Palo Alto Recycling Center in C. Silver Hauling Program The RWQCP silver program has regulated the disposal of used photoprocessing chemicals containing silver since Businesses that collect their silver- bearing photoprocessing solutions for offsite disposal as hazardous waste are required to submit annual reports certifying that all such solutions were properly hauled offsite. Businesses that elect to treat their silverbearing photoprocessing solutions and discharge them to the sanitary sewer are issued discharge permits and are required to conduct sampling to verify that they meet a silver discharge standard. As in other years, the annual reports were solicited and collected from businesses with permits and those that have their silver waste hauled. Over the last few years trends have shifted to keep pace with the digital revolution. Some traditional printers have gone out of business, but every year more businesses have adapted by changing to digital processing. Changes are noticed as well in medical and dental imaging. D. Molybdenum Molybdenum is a metal frequently used as a corrosion inhibitor in cooling systems, or as a tracer in chemicals added to cooling towers. Limited data on the concentration of molybdenum in the RWQCP s influent and effluent are available, because reporting limits have typically been too high for molybdenum to be detected. However, the data that are available suggest that the RWQCP s removal efficiency for molybdenum is very low, so that most molybdenum present in the influent passes through the treatment process and is discharged in the effluent. There is no water quality objective for molybdenum applicable to San Francisco Bay. 1. Molybdenum in RWQCP Incinerator Ash The RWQCP is concerned about molybdenum because a portion of the molybdenum entering the treatment process is removed with the solids and incinerated. The incinerator ash typically has a molybdenum concentration of between 20 and 30 milligrams per kilogram (mg/kg). This Clean Bay Pollution Prevention Plan 2008 Page 84 of 124

95 concentration range is lower than EPA s molybdenum ceiling limit of 75 mg/kg for sewage sludge applied to agricultural land. However, the California Food and Agricultural Code requires that fertilizer labels include a warning that application of fertilizing materials containing molybdenum may result in forage crops containing levels of molybdenum which are toxic to ruminant animals, if the concentration of molybdenum in the fertilizer is greater than percent. The limit of percent is approximately equal to 10 mg/kg. The concentration of molybdenum in the RWQCP s ash is two to three times greater than this trigger for a fertilizer warning. As described in greater detail in Section 6, Copper Program, the RWQCP is currently shipping its ash to a hazardous waste landfill due to the ash s soluble copper concentration, but may resume application to agricultural land in the future. To maximize the ash s usefulness as a fertilizer, which is based primarily on its available phosphate concentrations, the molybdenum concentrations in the ash must be reduced. In 2007, the RWQCP began investigating sources of molybdenum, and discovered that other wastewater treatment agencies had implemented programs addressing molybdenum use in cooling systems in order to comply with the EPA ceiling limit for land application of biosolids. Source loading estimates done by Jacksonville, Florida and Phoenix, Arizona indicated that cooling systems accounted for about 60 percent of molybdenum loadings. A strong seasonal trend was also observed, with biosolids molybdenum concentrations significantly higher during the summer months when demand on cooling systems is greater. The RWQCP collected and analyzed monthly trunkline samples for molybdenum for four months, and found that trunklines with significant numbers of industrial users, including cooling towers, had much higher concentrations than trunklines serving primarily residential areas. These findings suggest that molybdenum concentrations in the RWQCP s influent and incinerator ash can be reduced by addressing molybdenum use in cooling systems. 2. Molybdenum Source Reduction Plan In 2008, the RWQCP industrial waste program collected information on cooling tower treatment chemicals from industrial facilities with cooling towers during the regular semiannual inspections. Facility representatives were educated about the negative impacts of molybdenum and informed that an ordinance modification prohibiting molybdenum additives was being developed. Several facilities that were using molybdenum additives agreed to immediately switch to non-molybdenum alternatives, while others agreed to phase them out over time. A new ordinance provision was drafted that prohibits adding any additive containing greater than 2 milligrams per liter (2 mg/l) of molybdenum to a cooling system. The limit applies to the additive prior to dilution with cooling water. RWQCP staff analyzed multiple nonmolybdenum cooling system additives for molybdenum to verify that any unintentional, trace amounts of molybdenum would not exceed the 2 mg/l limit. The molybdenum ordinance provision is expected to be adopted, along with other extensive modifications to Palo Alto s Sewer Use Ordinance, in Fall The RWQCP has also prepared a draft fact sheet addressing the applicable restrictions on cooling tower additives in its service area (e.g. copper, hexavalent chromium, tributyltin, molybdenum, and zinc) and the various classes of cooling tower additives that are commercially available. In 2009, the finalized fact sheet will be used in an outreach effort targeting industrial facilities Clean Bay Pollution Prevention Plan 2008 Page 85 of 124

96 throughout the service area, as well as cooling tower treatment vendors and contractors that may service cooling systems not inspected by the industrial waste program. Molybdenum concentrations in the influent and incinerator ash will be measured on a monthly basis to evaluate the effects of these actions. Influent samples will be analyzed using a method with a low detection limit to ensure that useful data are obtained. Monthly trunkline samples will also be analyzed for molybdenum for several months during the summer. E. Salinity Salinity is a RWQCP pollutant of concern because elevated salinity levels can negatively impact the use of the RWQCP s recycled water for landscape irrigation when species that are sensitive to salinity, such as redwood trees, are present. Successful use of recycled water decreases the loading to San Francisco Bay of all pollutants that are present in the RWQCP s effluent. Salinity is commonly assessed using total dissolved solids (TDS) or specific conductance as a surrogate measurement. While salinity, TDS, and specific conductance are measures of the total amount of ions in a solution, sodium concentrations are of particular importance with respect to sensitive landscape species. High sodium concentrations in irrigation water can cause a buildup of sodium in the soil that restricts proper drainage of water through the soil. For many years, the RWQCP has supplied modest amounts of recycled water for landscape irrigation to the Palo Alto Golf Course and to Greer Park, a Palo Alto city park. The RWQCP s recycled water program is currently being expanded with the installation of a major new pipeline to Mountain View s Golf Course and North of Bayshore business park area. Connections to the pipeline will occur throughout 2009, with recycled water demand expected to increase by as much as 3 million gallons per day (MGD). Additionally, a proposed recycled water pipeline that would serve other Palo Alto parks and the Stanford Research Park business area is under consideration. The TDS and sodium concentrations in the RWQCP s recycled water average approximately 900 mg/l and 185 mg/l, respectively. These concentrations are high enough to cause some concern that redwood trees and potentially other sensitive landscape species could be harmed when recycled water use begins. This concern is heightened by the mediocre soil conditions in much of the Mountain View area that will be receiving the recycled water. For instance, the Mountain View Golf Course is built on top of a former landfill, with an impermeable clay layer close to grade. For comparison, the recycled water provided by the South Bay Water Recycling Program has a TDS of approximately 600 mg/l. 1. Salinity Reduction Plan The RWQCP collects monthly specific conductance, TDS, sodium, and chloride data as part of its trunkline sampling program. An analysis of the data was recently conducted for the period of October 2007 through November 2008 to assess the most current conditions (TDS monitoring in the trunklines did not begin until October 2007). As illustrated in Figure 8-1, the MV1 trunkline has an average TDS value greater than 1200 mg/l, which is approximately twice as high as the trunklines with the next highest values. Clean Bay Pollution Prevention Plan 2008 Page 86 of 124

97 TDS (ppm) CPA2 CPA4 CPA5 LA (Del Medio) EPASD LA Meter Sample Location MV1 MV2 Stanford Recycled Water Figure 8-1. Average total dissolved solids in various trunklines. Figures 8-2 and 8-3 contrast the average flow and average TDS for the trunklines (LA Del Medio, MV2, and Stanford are excluded because they are an upstream tributary to other trunklines). Note that the MV1 trunkline contributes 31% of the average flow, but is responsible for 50% of the average TDS mass loading. The high TDS concentration in the MV1 trunkline is believed to be due to infiltration of saline groundwater in the portion of the trunkline east of Highway 101 that is near San Francisco Bay, and to highly saline groundwater that is currently pumped from three wells into the sanitary sewer to maintain low groundwater levels along the edge of the former Shoreline Landfill. The infiltration and well discharges into the MV1 trunkline are the focus of the RWQCP s current salinity reduction efforts. In 2008, the City of Mountain View collaborated with RWQCP staff, a geotechnical engineering firm, and Regional Water Board staff to apply for a general discharge permit that will allow the groundwater to be pumped into the tidally influenced Charleston Slough and Stevens Creek instead of the sanitary sewer. The permit is expected to be issued in early 2009, after which the City of Mountain View will reroute the discharges. Preliminary estimates indicate that this change would reduce the TDS of the RWQCP s recycled water from the current value of approximately 900 mg/l to about 775 mg/l. Clean Bay Pollution Prevention Plan 2008 Page 87 of 124

98 Average Flowrate By Trunkline (MGD, %) (Oct 2007 Nov 2008) MV1, 7.4, 31% CPA2, 6.0, 25% CPA4, 2.8, 11% LA METER, 3.6, 15% EPASD, 1.7, 7% CPA5, 2.7, 11% Figure 8-2. Average flowrate by trunkline Average TDS Mass by Trunkline (thousand lb/day, %) (Oct 2007 Nov 2008) CPA2, 30.9, 20% MV1, 76.2, 50% CPA4, 10.3, 7% CPA5, 9.7, 6% EPASD, 9.2, 6% LA METER, 17.0, 11% Figure 8-3. Average TDS Mass by Trunkline Following the rerouting of the well discharges, RWQCP will work with the City of Mountain View to identify additional locations where saline water is entering the MV1 trunkline. Tools to assist in this effort will include upstream and downstream monitoring of TDS, conductivity, Clean Bay Pollution Prevention Plan 2008 Page 88 of 124

99 sodium, and chloride; videotaping of sanitary sewer pipes to identify infiltration points; and periodic continuous monitoring of conductivity in the MV1 trunkline to identify patterns of conductivity variation, such as sudden increases resulting from pumped discharges, that may require other management actions. In 2009, the RWQCP also intends to investigate potential salt water infiltration into the CPA2 trunkline. As shown in Figures 8-2 and 8-3, the CPA2 trunkline contributes 25% of the RWQCP s average flow and has a higher TDS concentration than the other two City of Palo Alto trunklines. Clean Bay Pollution Prevention Plan 2008 Page 89 of 124

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101 Section 9: Programs Addressing Multiple Pollutants Many of the programs and activities implemented by the RWQCP address multiple pollutants, or are designed to educate the public about environmental issues and pollution prevention. These programs are summarized in Table 9-1. The School Outreach Program, Vehicle Service Facility Recognition Program, CleanBay campaign, Greenlight Earth Day Film Festival, Household Hazardous Waste Program and Less Toxic Products in the Workplace are further described below. A. School Outreach Program This year the RWQCP offered a variety of informative and interactive classroom programs for elementary, middle school and high school classes. The School Outreach Program goal for the school year remained 100 presentations at 30 schools for the service area of East Palo Alto, Los Altos, Los Altos Hills, Mountain View, Palo Alto and Stanford. Student who live in Los Altos Hills attend schools in Los Altos. The period July 1, 2007 June 30, 2008 ended with 138 programs presented in the PARWQCP service area. We exceeded our goal by 38 programs and continued a pace of delivery that averages 130 services per year. Schools visited were 23 out of 30, providing educational programs for 3,201 students. Additionally, two water training programs were delivered to Environmental Volunteers adult volunteers that deliver services to school age students. An additional 100 students received water pollution prevention messages by attending an allschool assembly at Covington School in Los Altos. The Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) provided these assemblies, performed by ZunZun. This data can be seen in Table 9-2. No RWQCP tours were conducted for school students during the year due to construction. 1. Elementary and Middle School Program Highlights We believe that by an increased awareness of sense of place within their community and the San Francisco Bay Area students are more likely to take action to reduce water pollution through stewardship for their environment. Our program theme for all grades every year continues to emphasize litter reduction as it relates to runoff and water pollution, with specific focus on fast food packaging, cigarette butts and grease. We continue to collect trash from the school parking lot and streets around the schools prior to the 3 rd grade Who Dirtied the Bay? program to emphasis how much pollution can potentially enter the Bay via the storm drains. This gives the students an opportunity to see in Clean Bay Pollution Prevention Plan 2008 Page 90 of 124

102 Table 9-1. Additional Multiple Pollutants Priorities Pollutant and Source Audiences Message / Program Implementation Plan & Timeline Evaluation Criteria GOVERNMENT AGENCIES Chemicals from cleaners and or print shops City Facility Managers COMMERCIAL / INDUSTRIAL Metals and organics from vehicle repair facilities RESIDENTIAL Pollution from general residential activities Household pesticides & hazardous waste Vehicle repair facility managers and staff Elementary and Middle School Students Residents Use less toxic products in the workplace Follow ordinance requirements and BMPs. Awareness of water quality issues; general ways to protect the Bay Ad campaign partnering with Save the Bay. Ensure on-going use of least toxic printing and custodial products. Distribute case study for janitorial and print shop products to industrial users. In 2008, 99% of eligible vehicle repair shops participated in the Clean Bay Business Program; the RWQCP recognized 17 shops that have been Clean Bay Businesses for fifteen consecutive years. Inspections; distribution of ordinance and BMPs. Continue the Clean Bay Business Program, providing recognition to facilities that follow ordinance and BMPs In the school year, visit at least 100 classrooms and continue to distribute evaluation cards. Updated curricula to increase scientific focus. In 2009, continue outreach about FOG, legacy pesticides, less toxic pest control, Green Business certification, and EcoWise structural pest control companies (as information becomes available). Help coordinate Greenlight Film Festival. Refresh and use outreach materials from 2006 Clean Bay Campaign. Verification of continued use of least toxic printing and custodial products. Outreach about city s efforts to other industrial users. Percent of vehicle repair shops that receive Clean Bay Business recognition. Number of businesses with continuous Clean Bay Business recognition for 10 and 15 years. Number of classrooms visited. Number of evaluation cards returned. Website hits Phone calls from public for more information. Press coverage of campaign kick off. Clean Bay Pollution Prevention Plan 2008 Page 91 of 107

103 real time what types of pollution are present in their environment and how picking up the pollution can make a difference to the health of the Bay. Included in these goals are providing the students with actions they can take that will impact water pollution. We review the 4 R s of Reduce, Reuse, Recycle and Respect and add the 5 th R for Rot. We talk to the students about composting and how this helps reduce garbage volume. We ask each class what they are currently doing to reduce water pollution. We request that each student take home information they learn and educate family members and friends about water pollution prevention. We encourage this by asking them to serve as a role model by their actions at home and at school. Other highlights include the following: The Microbes in Sewage Lab for 7 th grade biology classes directly supports the state science curriculum standards. This includes following laboratory procedures, the use of microscopes, observing live microorganisms, and the identification and documentation of these microorganisms. This year delivery expanded to 65 classes at seven schools. With the completion of our involvement in the educating for depth collaboration of the previous three years we have seen a dramatic decline in the number of programs delivered in East Palo Alto. The teachers and principal at the East Palo Alto Charter School where we delivered the Digging Deeper collaboration were contacted and offered free programs. Several expressed interest but have not yet followed through on scheduling. The Filtering Lab was presented to three 10 th grade classes at the request of the teacher as part of the class curriculum discussing macro and micro filtration. The Filtering Lab was also done for two 6 th grade classes as part of the Earth Science discussion. A correlation between the earth filtering water and pollution was made with the filtering process at the wastewater treatment plant. In the lab the students create simulated wastewater following the Sewer Science Laboratory guidelines. They then form and test their hypothesis as to which of six filters will best remove the waste from the water by conducting an experiment and by discussing and documenting their findings 2. Elementary and Middle School Program Evaluation A successful evaluation process of the school programs continues through the use of selfaddressed, stamped evaluation cards, which take teachers less than a minute to complete and return. Evaluation cards (SASE) were distributed to all teachers with a return rate of 77%. The ZunZun assembly teachers did not receive RWQCP evaluation cards as ZunZun provides their own. Clean Bay Pollution Prevention Plan 2008 Page 92 of 124

104 Ratings on the cards offer a scale of 1-5 with 5 being the highest rating. For the two areas surveyed, quality of program and clarity of program delivery, both averaged scores of 5 out of 5. Included on the card is an evaluation of the students understanding of the difference between the storm drain and sewer systems, and what they can do to help prevent water pollution. Teachers respond as to whether she/he noticed that the students awareness increased, was unchanged, or decreased. 98% of teachers felt that their students understanding of the difference between the storm drain and sewer system increased, and 100% of teachers felt that their students understanding of what they can do to prevent water pollution increased. 3. High School Program Highlights The Filtering Lab was presented to three 10 th grade classes at the request of the teacher as part of the class curriculum discussing macro and micro filtration. We continue to put the Sewer Science Lab revision on hold until there are sufficient resources to devote to the project. 4. Plans for School Year The following are plans for the school outreach program for school year Develop a new 2 nd grade program that supports the changes in the science curriculum and still delivers our P2 messages. This might include a greater emphasis on trash and the impact of trash on the environment. The second graders, as with all students, are more aware of trash and recycling therefore it will be important to find program content that meets their curriculum and is new and interesting. Continue to track and detail State Science Standard correlation in relation to any changes that are happening at the district level. Focus on the remaining 7 th grade classes in the East Palo Alto schools, for those schools that have science labs, for delivery of the Microbes in Sewage program. This includes one public and two private schools. Continue to be aware of the impact of trash, grease and cigarette butts as it relates to all programs and add information where appropriate. Provide a classroom give-away that supports the program message and can be taken home and shared with family members. We are currently looking at a recycled bag that the students can write/draw on with a positive message about water pollution prevention. Continue trash pick up in the school parking lot prior to the elementary school programs for an immediate emphasis on trash in their environment and what the students can do to make a difference. Continue outreach to public and private schools not yet receiving programs. Clean Bay Pollution Prevention Plan 2008 Page 93 of 124

105 Table 9-2. Summary of School Services Name of Program Down the Drain! Focus & Short Description Focus is on the difference between wastewater and storm water and how this impacts SF Bay and the environment. Pollution prevention solutions are discussed. Grade Levels 2nd and up No. of Classrooms / No. of Students East Palo Alto Los Altos Mtn. View 0 4/80 3/60 3/60 Palo Alto/ Stanford What s Bugging You? (IPM) Water-shed Warriors! Who Dirtied the Bay? Mercury ZunZun Assem-bly Microbes in Sewage Filtering Lab Students are introduced to the concepts of "Integrated Pest Management" by learning about insects, the food chain, and the impacts of pesticides on water pollution. Students learn about the watershed, common pollutants, how they travel in water and affects on our environment. Solutions for preventing H 2 O pollution are discussed with the use of the Enviroscape topo relief model. The focus is on the watershed and storm water and how this impacts SF Bay and the environment. The history of the Bay area is introduced to address these issues. Pollution prevention strategies are discussed. Students learn how mercury is transferred throughout ecosystems; how past (Gold Rush) and present mercury pollution is impacting water; and pollution prevention strategies. This musical assembly performed by ZunZun focuses on the concept of the watershed and its importance in our lives. Topics include water pollution, storm drains, habitat and water conservation. Microbes used in the wastewater treatment process are observed in a lab setting. Students are given the opportunity to enhance their microscope skills while using scientific observation skills including documentation and identification of microbes. Students filter simulated wastewater to better understand the science of filtering as it relates to the environment and in the wastewater treatment process 2nd /60 3rd and up 0 2/40 0 9/180 3rd 0 3/60 11/220 16/330 4th 0 3/90 3/90 9/186 K-6th 0 1/ th-8th 4/100 22/550 13/325 26/ /110 TOTALS FOR ALL PRESENTATIONS K-12 4/100 30/840 30/695 71/1566 Clean Bay Pollution Prevention Plan 2008 Page 94 of 124

106 B. Vehicle Service Recognition Program Vehicles are one of the most significant sources of water pollution in the San Francisco Bay area. Pollutants are released to storm drains and the sewer system when people drive, wash and maintain vehicles. Historically, vehicle service facilities, such as auto repair shops, gasoline stations, fleet maintenance facilities, commercial car washes, and autobody repair shops, have discharged pollutants to both sewers and storm drains. The RWQCP vehicle service facility program focuses on: Education Recognition of compliant facilities as an incentive for compliance Enforcement of requirements at non-compliant facilities Permitting of wastewater dischargers Specific pollution prevention practices, the most important of which are required by ordinance 1. Annual tasks for Vehicle Service Facility Since 1992, the RWQCP has conducted the vehicle service facility program, which involves approximately 240 facilities. Major tasks each year include: a. Visiting every facility at least once The primary purpose of the visit is education and interaction with facility operators to increase compliance rates. During visits, facilities are evaluated for compliance with ordinance requirements. b. Recognizing compliant facilities as Clean Bay Businesses The recognition program provides an incentive for compliance with water pollution prevention requirements of the Sewer Use Ordinance. Clean Bay Businesses receive promotional materials and are listed in full-page newspaper advertisements paid for by the RWQCP. Each year the RWQCP also recognizes those shops that have been a Clean Bay Business for five consecutive years with a plaque; in 2008, two shops met this criteria. The number of automotive facilities that are recognized each year for achieving five consecutive years as a Clean Bay Business has decreased in number as nearly all of the 250 original shops in the program have now met the 5- year criteria and are being recognized as 10-year or 15-year Clean Bay Business shops. Also, the RWQCP recognized six shops that have been Clean Bay Businesses for ten consecutive years with a special Outstanding Achievement plaque and other recognition materials. c. Enforcing requirements At first, the focus was to eliminate storm drain and sanitary sewer discharges. In 1994, the RWQCP implemented discharge-monitoring requirements at facilities with permits and stepped up enforcement efforts to increase compliance rates. d. Permitting and monitoring facilities The relatively small fraction of facilities electing to continue discharging to the sewer were issued permits. Permitted facilities must monitor wastewater quality and submit semi-annual compliance reports. Since 1994, permitted shops have reduced discharges of toxic metals (lead, Clean Bay Pollution Prevention Plan 2008 Page 95 of 124

107 copper, nickel and zinc) concentrations by 99 percent. RWQCP inspectors visit permitted vehicle service facilities at least twice a year. C. Vehicle Service Recognition Program Evaluation Since inception of the Clean Bay Business program, the portion of eligible facilities recognized as Clean Bay Businesses has increased to 99 percent of all eligible facilities. In 2008, the RWQCP honored 17 automotive shops achieving 15 consecutive years as a Clean Bay Business with an engraved wood plaque and other recognition materials. In 2008 the RWQCP recognized 6 more shops that have been Clean Bay Businesses for ten consecutive years, increasing the number of shops to 181 that have been Clean Bay Business certified for at least ten consecutive years. D. Clean Bay Ad Campaign In March 2006, RWQCP launched the Clean Bay ad campaign. The campaign targeted service area residents with the goal of increasing awareness of common pollutants, and the connection we have to the Bay through every day activities. Bus and movie ads, print ads, and fresh web presence at were featured. The campaign was very successful and resulted in coverage by six local papers, story coverage, and interviews on several local radio stations and ads that have been used throughout 2007 and Some ads have been revised to reflect more cultural diversity. RWQCP plans to continue the use of this creative as it refines its website content and continued outreach. Clean Bay Pollution Prevention Plan 2008 Page 96 of 124

108 E. Greenlight Earth Day Film Festival For the fourth consecutive year, RWQCP teamed up with City of Palo Alto Recycling Program, Palo Alto Utilities, Palo Alto Community Media Center and local sponsors to host the fourth annual Greenlight Earth Day Film Festival. The festival solicited films about environmental protection from local elementary, middle, and high school students and also included an Open Category for other community members. Held as an Earth Day event, the evening featured an Academy Awards night theme complete with a green carpet entrance for the producers. Local environmentally conscious organizations are offered the entrance area outside to host a table for theater goers to visit. Plans are to continue the festival as an annual event. Past videos can be accessed via Winners James Skinner and his son for their short film titled The Reusable Bag 2008 winners in the high school category from the Reikes Center F. Household Hazardous Waste In the RWQCP service area, a number of options are available for residents to safely dispose of household hazardous waste (HHW). County HHW Programs: Santa Clara and San Mateo Counties operate household hazardous waste drop off programs serving most residents and businesses in their respective counties. The Santa Clara County program serves RWQCP cities of Los Altos, Los Altos Hills, Mountain View and Stanford. It does not serve Palo Alto residents because the City opts to fund its own HHW program in lieu of the County s. Clean Bay Pollution Prevention Plan 2008 Page 97 of 124

109 RWQCP drop-off for mercury products, pesticides, pharmaceuticals and silver: The RWQCP operates a household hazardous waste drop off program located permanently at the treatment plant, for residents in its service area. The RWQCP s program accepts mercury-containing items such as thermometers and switches, pesticides, pharmaceuticals and photo processing solutions that may contain silver. (Pharmaceuticals are discussed in Section 10) Recycling Center Drop off for antifreeze, motor oil, used oil filters, household and automotive batteries, and fluorescent lamp tubes. The Recycling Center is open daily to Palo Alto residents. City of Palo Alto HHW Drop-off for Palo Alto residents and businesses in the RWQCP service area. The monthly drop off events accepts most household hazardous waste. New By Appointment drop off. This program was piloted successfully in 2008 and allows residents to drop off products by appointment during the week. RWQCP will look to expand this program to include its entire service area in Utility bills and ads were run promoting the new service. Palo Alto s household hazardous waste program submits an annual report to the Department of Toxic Substances Control detailing the amount of each type of waste collected and how each waste was managed. These reports cover fiscal year periods that span from July through June. Table 9-3 summarizes the amounts of the various waste types collected, in pounds, during fiscal years , , , , and Please note that the figures included in Table 9-3 include the City s landfill load checking program and small business hazardous waste program, in addition to the household hazardous waste drop off programs. These data are presented to demonstrate the very large quantity of HHW that is being managed by the City of Palo Alto, thereby avoiding improper disposal and release to the environment. In 2007, the RWQCP installed a permanent HHW drop off location at the entrance of the plant and modified the HHW permit to accept all hazardous waste; previously, waste to be accepted were limited to mercury, pesticides, and photographic solutions. In 2008, the RWQCP opened the HHW drop off site one day a week for residents of Palo Alto. In 2009, we hope to expand the program to residents of East Palo Alto, Los Altos, Los Altos Hills, and Mountain View as well. The primary goal of the permanent drop off location is to increase the use of the HHW program by making the program available more often than the one day per month to which the existing program was limited. Clean Bay Pollution Prevention Plan 2008 Page 98 of 124

110 Table 9-3. Pounds of Waste Collected by Palo Alto Household Hazardous Waste Program Waste Classification Flammable and Poison 119, , , , ,444 Acid 3,741 3,308 5,004 4,094 4,818 Base 3,418 3,705 4,414 5,407 6,234 Oxidizer 1,920 1,510 1,972 1,036 2,060 PCB-containing , ,133 Reclaimable 401, , , , ,041 Asbestos 1,051 2, , Universal Waste 1 Electronic Waste 1 Non-empty Aerosol Cans Not Applicable Not Applicable 44,058 48,641 46, ,529 64,664 94,124 88,593 7,589 12,170 13, ,562 Other 33,615 4,959 6, Total Weight (pounds) 572, , , , ,562 1 Note that Universal and Electronic Waste items, such as fluorescent lamps, household batteries, and CRTs, were included in the Reclaimable and Other categories prior to the fiscal year. G. Less Toxic Products in the Workplace Print shop and janitorial cleaning products are additional sources of water pollution. In order to reduce the amount of pollution from these sources, the City researched and found less toxic alternatives. The Print Shop and Facilities Division s switch to less toxic products helped the City meet the Santa Clara County Green Business Certification for city-wide operations, in October 2002 and again in 2008 when it was recertified. The City's Print Shop also achieved Green Business status, separately from the citywide effort, switching four of its most toxic printing chemicals to less-toxic alternatives and City of Palo Alto Printshop staff switched their printing products to less-toxic alternatives. Clean Bay Pollution Prevention Plan 2008 Page 99 of 124

111 converting to all vegetable-based inks. In 2008, the City began the effort to consolidate all custodial product contracts into one with uniform product standards. The Facilities Division and three other locations who ordered cleaning supplies separately are reevaluating all products for safest product choices. The contract will be awarded in 2009 and seeks to increase use of Green Seal Certified supplies and use lower toxicity disinfectants (disinfectants are not certified through Green Seal). Current green products include zinc-free floor wax, acid-free bathroom cleaners, low VOC products, 100% recycledcontent unbleached paper towels, and alternatively bleached toilet paper. H. Launch of Green Procurement Program In 2007, RWQCP led the City effort to implement a Green Procurement Program (a.k.a as Environmentally Preferred Purchasing, or EPP ). An EPP policy was adopted via City Council s approval of a Climate Protection Plan in December 2007 and recognizes that the consideration of the environmental attributes of goods and services that the City purchases are central to furthering water quality, climate protection, and Zero Waste goals. An interdepartmental team of staff began reviewing contracts and services to green as well as operations that support efforts to reduce the use of materials such as paper. The current workplan goals are to green the following contracts by or in 2009: Custodial products (less toxic, greater recycled content) Office supplies (increased recycled content, online ordering systems that filter products so that users are directed to green products first and other products are blocked) Fluorescent lights (newest lighting technology, low mercury) Printers and copiers (Energy Star certification, units preset to duplex) Iteratively add language requiring extended producer responsibility when relevant e.g., the purchase of fluorescent lights and electronic products Implement operational changes supporting green procurement, e.g., setting existing copiers and printers to automatically duplex when that function is available Pilot new environmentally preferred products such as light emitting diode (LED) street light technology which also reduces potential mercury pollution Clean Bay Pollution Prevention Plan 2008 Page 100 of 124

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113 Section 10: Programs for Emerging Pollutants The RWQCP strives to stay abreast of emerging contaminants that may become pollutants of concern. These programs are summarized in Table Below we describe our efforts in the areas of: A. Pharmaceutically active compounds B. Triclosan C. Alkylphenol ethoxylates D. Perfluorinated organic compounds E. Nitro-musks F. Polybrominated diphenyl ethers (PBDEs) G. N-nitroso dimethylamine (NDMA) In 2009, the RWQCP will remain engaged in emerging pollutants issues with a continuing emphasis on pharmaceutically active compounds. A new area of attention is the increasing use of nanoparticles in products, typically for antimicrobial purposes, that can impact water quality. In 2008, RWQCP staff attended a national discussion on emerging products that contain nanoparticles that potentially can impact water quality. RWQCP staff intends to track the continuing emergence of nanoparticles, helping to ensure that any products marketed locally fully comply with federal and state requirements for antimicrobial pesticides. A. Pharmaceutically Active Compounds Pharmaceutically active compounds (pharmaceuticals) are a class of chemicals that include hormones, antibiotics, and drugs. Pharmaceutical residuals from humans and animals, personal care products, and their metabolites are continually introduced to the aquatic environment as complex mixtures via a number of routes: discharge of treated domestic wastewater, treated industrial wastewater, commercial animal feeding operations, and surface application of manure (Daughton and Ternes, 1999). Potential public health and environmental effects from these compounds are being studied worldwide. There is increasing concern that the pharmaceuticals detected in surface waters could cause adverse environmental effects, including endocrine disruption in aquatic life and/ or increased antibiotic resistance. Wastewater treatment plants are designed to remove conventional pollutants such as suspended solids and biodegradable organic material, but they are not designed to remove low concentrations of synthetic pollutants such as pharmaceuticals. Limited testing suggests that certain types of treatment substantially remove some pharmaceuticals. Removal efficiencies of pharmaceuticals appear to be chemical-specific, especially since many synthetic compounds are designed to be resistant to biological degradation. There appears to be no single cost effective wastewater treatment technology that will remove all of these compounds. Clean Bay Pollution Prevention Plan 2008 Page 101 of 124

114 Table Emerging Contaminants Pollution Prevention Plan Pollutant and Source Audiences Message / Program Implementation Plan & Timeline Evaluation Criteria GOVERNMENT AGENCIES Triclosan Pharmaceutically Active Compounds Alkylphenol Ethoxylates Partner cities, Publicly owned treatment works, purchasing departments Partner cities, Publicly owned treatment works Council members, partner cities, publicly owned treatment works COMMERCIAL / INDUSTRIAL Pharmaceutically Active Compounds Hospital staff Do not use antibacterial soaps that contain triclosan Proper disposal of unused/ expired medications Describe alkylphenol ethoxylates and the environmental impacts and alternative products Proper disposal of unused/ expired medications Assist BAPPG in developing a fact sheet on triclosan for regional use. In 2008, assisted with the development of statewide No Drugs Down the Drain event. In 2009, may co-lead another regional outreach campaign and collection event with other BAPPG members. In 2009, RWQCP staff will continue to lead the SCBWMI Emerging Contaminants Workgroup in drafting a white paper on alkylphenol ethoxylates. In 2005, RWQCP spearheaded the effort to hold a regional training regarding the proper disposal of pharmaceuticals for hospital staff. In 2008, BAPPG finalized guidance document for hospital staff regarding the proper disposal of pharmaceutical waste specifically for California. In March 2009, RWQCP staff will colead a BAPPG training to educate hospital staff regarding the information in the guidance document. Wide distribution of document. Number of agencies participating in potential 2009 regional event. Progress toward developing a white paper. Number of attendees; Number of hospitals receiving guidance document Clean Bay Pollution Prevention Plan 2008 Page 102 of 107

115 Table Emerging Contaminants Pollution Prevention Plan (continued) Pollutant and Source RESIDENTIAL Triclosan Residents Do not use antibacterial soap that contains triclosan Audiences Message / Program Implementation Plan & Timeline Evaluation Criteria In 2006, RWQCP drafted a fact sheet targeting triclosan use by residents. In 2009, continue to use the fact sheet to educate Palo Alto residents about triclosan. Number of teachers who receive packet of information. Pharmaceutically Active Compounds Pharmaceutically Active Compounds Residents Residents Proper disposal of unused/ expired medications Legal disposal of controlled substances In , continue to educate teachers regarding triclosan-containing products. In 2009, continue existing onsite collection program and newly expanded partnership with Palo Alto Medical Foundation. Continue to educate residents about proper pharmaceutical disposal using newspaper advertisements, utility bill inserts, Cleanbay.org website, and RWQCP staff attendance at local business and community events. Work with Palo Alto police department to expand pharmaceutical disposal options by allowing residents to drop off controlled substances at Palo Alto s City Hall (police department). Quantity of pharmaceuticals collected. Number of disposal locations. Number of outreach pieces and events attended. Installation of secure collection container. Clean Bay Pollution Prevention Plan 2008 Page 103 of 124

116 1. Evaluation of Pharmaceutically Active Compounds in San Francisco Bay and RWQCP Influent and Effluent In the fall of 2006 as part of a pilot and special study under the Regional Monitoring Program for Water Quality in San Francisco Bay (RMP), samples were collected from the Bay and two wastewater treatment plants and analyzed for 39 pharmaceutical and personal care products. Five samples each of influent and effluent were collected from two wastewater treatment plants (City of San José and City of Palo Alto) in October At the same time, ten samples were collected from South San Francisco Bay. These samples were analyzed by AXYS Analytical Services Ltd. (AXYS). The 39 compounds were selected based on current thoughts on potential need for regulatory and risk assessment in the United States, Canada, and the European Union.Of the 39 compounds quantified, 12 were not detected in any of the effluent, influent, or Bay samples. Nine compounds were qualified as a result of poor precision, blank contamination, and/or surrogate recovery. Of the remaining 18 compounds, influent concentrations were typically higher than effluent (Harrold et al., 2008). As expected, concentrations of many of these compounds were also substantially lower in the Bay and were frequently below detection. Concentrations of compounds detected in the Bay were observed to decrease with increased distance from WWTP outfalls and frequently fell below detection levels further into the Bay. The concentrations observed in this study were typical of concentrations observed in studies of other water bodies and WWTP using similar analytical techniques In 2009, RWQCP will collect and analyze more samples within the plant for pharmaceutically active compounds as part of a pilot reverse osmosis program conducted in partnership with Stanford University. 2. Hospital Disposal of Pharmaceutical Waste Pharmaceuticals enter the sanitary sewer from two sources: (1) excretion of partially metabolized pharmaceuticals by the human body and (2) disposal of unused or expired medications down the sewer. The two largest sources of pharmaceuticals entering the sewer systems are hospitals and residents. Therefore, one way to reduce the level of pharmaceuticals in surface water is to educate hospitals and residents that unused or expired pharmaceuticals should not be disposed of down the sewer. Medical facilities are the largest bulk users of medications. These facilities include hospitals, skilled nursing facilities, and veterinary hospitals. Many hospitals currently dispose of excess material in syringes and IV bags into drains, where they pass into sewer systems. In 2003, Palo Alto staff participated with TriTAC to develop language that would assist hospitals and other POTW with the proper disposal of pharmaceuticals 9. In 2004, RWQCP staff worked with Stanford Hospital to add a pharmaceutical waste container to their nursing carts. In 2005, RWQCP staff spearheaded two workshops organized by the Bay Area Pollution Prevention Group (BAPPG) titled Navigating 9 Tri-TAC is a statewide technical advisory group which includes representatives from California Association of Sanitation Agencies, the California Water Environment Association, and the League of California Cities Clean Bay Pollution Prevention Plan 2008 Page 104 of 124

117 Pharmaceutical Waste Management in Medical Facilities held in the East Bay and on the Peninsula. Attendees of this workshop requested a guidance document specific to pharmaceutical waste in California, as the CA Medical Waste Management Act has more stringent requirements than federal law. BAPPG funded consultants to create a California-specific update to Hospitals for a Healthy Environment s Managing Pharmaceutical Waste document that was developed based on national rules and regulations on the proper disposal of pharmaceutical waste. The California-specific document was finalized in August In early 2009, RWQCP staff will assist the BAPPG in organizing workshops to train medical facility staff on how to best use the California-specific document. 3. Residential Disposal of Pharmaceutical Waste Traditionally, doctors and health care specialists recommended flushing unwanted medications down sanitary sewer drains to reduce accidental poisonings and abuse by those for whom the medications were not intended. This is still a common method for disposal of pharmaceuticals by residents, in the absence of convenient alternatives. Since 2002, RWQCP staff has educated residents on the proper disposal of unused or expired medications. In 2006 and 2008, the BAPPG group decided to pilot a regional collection event for residential pharmaceutical waste. a. National Efforts In 2008, Palo Alto staff helped fund, coordinate and attend two roundtable discussions on the proper disposal of pharmaceutical waste, which were run by the Product Stewardship Institute. These workshops were held in Sacramento and Washington, D.C. In conjunction with the roundtable discussion, Palo Alto participated in a national workgroup to craft federal legislation to improve the collection and disposal of controlled substances. b. Regional Efforts In May 2006, the Bay Area Pollution Prevention Group (BAPPG), led by staff from the RWQCP and East Bay Municipal Utility District, piloted a first-of-its-kind regional collection event for residential pharmaceutical waste. Throughout the Bay Area, more than 1,500 residents disposed of 3,634 lbs of pharmaceutical waste at 39 locations. Seventeen agencies within BAPPG Clean Bay Pollution Prevention Plan 2008 Page 105 of 124

118 managed the collection event details, which included staffing, police presence, and documentation of controlled substances. In October 2008, RWQCP staff partnered with BAPPG and other agencies during the No Drugs Down the Drain campaign. The campaign provided the public with information on alternative disposal options throughout the state. RWQCP staff helped coordinate a No Drugs Down the Drain press event, with California Senator Simitian; Alexis Strauss, Director, EPA Region Water Division; and Larry Klein, Mayor of City of Palo Alto. RWQCP staff helped coordinate the Senate Resolution designating October 4, 2008 through October 11, 2008 as No Drugs Down the Drain Week. In conjunction with the campaign, the City of Palo Alto issued its own No Drugs Down the Drain proclamation and Palo Alto continued to advertize our permanent drop-off sites for pharmaceutical waste. c. Local Efforts Since 2002, RWQCP has advertised Household Hazardous Waste programs (HHW) as a safe disposal method for pharmaceutical waste. In 2006, RWQCP expanded its program by collecting pharmaceuticals at the wastewater treatment plant five days a week. In addition to collecting at the plant, RWQCP participated in the regional collection event at four local Walgreens drug stores and at a local health clinic. This event was advertised extensively throughout the community. The advertising was extremely effective, with over 250 residents disposing of 720 lbs of pharmaceutical waste within the RWQCP service area during the event. The events were staffed by RWQCP staff and held over a 2-day period at each Walgreens location. In December 2007, RWQCP partnered with Palo Alto Medical Foundation (PAMF) to collect pharmaceuticals in a mailbox type container near their pharmacy. To date we have collected over 2,044 lbs of pharmaceuticals at PAMF. In December 2008, RWQCP expanded this program, adding another pharmaceutical collection container at the PAMF facility in Mountain View. The RWQCP also continued its onsite weekday pharmaceutical waste collection program, and RWQCP staff attended five local events to collect unwanted pharmaceuticals at local businesses Earth Day celebrations and City-sponsored events (i.e. Arbor Day). The total volume collected at these events for the year was 94.2 pounds. Clean Bay Pollution Prevention Plan 2008 Page 106 of 124

119 In 2008, RWQCP s pharmaceutical program was advertized in the newspaper in March, utility bill inserts in April and September, and through the statewide No Drugs Down the Drain Event. Palo Alto created a new poster regarding the proper disposal of pharmaceutical waste. In 2009, the RWQCP will continue discussions with the Palo Alto police department to expand pharmaceutical disposal options by allowing residents to drop off controlled substances at Palo Alto s City Hall. 4. Residential Disposal of Pharmaceutical Waste Program Evaluation Since 2002, RWQCP staff has worked locally and regionally on the proper disposal of pharmaceutical waste. Since 2005, RWQCP staff collected over 2,798 lbs of pharmaceutical waste throughout our service area during the collection event as well as at Palo Alto Medical Foundation and the wastewater treatment plant. In 2008 more than seventy percent of the collected medications were from the PAMF site (Figure 10-1). The current program has been well received; however, we are seeking a long-term solution that caters to residents. In 2009, the RWQCP will continue to work with other BAPPG leaders to develop a regional long-term solution for residential pharmaceutical waste. RWQCP staff continues to support SB26, which would help address some of the regulatory barriers to pharmacies collecting pharmaceutical waste PAMF RWQCP/ Events Amount of Medications (lbs) Year Figure Summary of pharmaceuticals collected through Palo Alto s program Clean Bay Pollution Prevention Plan 2008 Page 107 of 124

120 B. Triclosan Triclosan is registered as an antibacterial agent, bactericide, disinfectant, and fungicide. Triclosan use began in the 1970s as an antibacterial agent in soaps. Uses of triclosan have risen dramatically in the past few years. It appears this may be more of a marketing strategy than a medical necessity. Triclosan is found in a variety of products including hand soap, toothpaste, cosmetics and deodorants. Triclosan, as well as other antibacterial agents and their degradation byproducts, are now found throughout the environment, including surface waters, soil, fish tissue, and human breast milk (Adolfsson-Erici, M. Patterson et al, 2000). Despite increasing data reflecting the presence of triclosan in surface water, no data was found to support the necessity or efficacy of antibacterial agents in consumer products. Based on a comprehensive literature review, RWQCP staff as chair of the Santa Clara Basin Watershed Management Emerging Contaminants Workgroup finalized a white paper titled Environmental Emergence of Triclosan. The white paper details these issues and presents messages, identifies audiences, and suggests strategies to reduce unnecessary uses of antibacterial products. In , RWQCP schools contractor continued to educate approximately 100 teachers regarding the switch by providing the teachers with a factsheet and examples of triclosan-free soap and alcohol based hand sanitizer. Palo Alto s leadership on the issue has helped other agencies work towards becoming triclosan-free, specifically City of San Jose, East Bay Municipal Utility District and Central Contra Costa Sanitation District. In 2009, Palo Alto will continue to chair the WMI Emerging Contaminants Workgroup and will continue to educate businesses and residents regarding purchasing triclosan-free products. C. Alkylphenol Ethoxylates Alklyphenol ethoxylates are common surfactants widely used in cleaning products, most notably laundry detergent. There is a growing concern about the emergence of these chemicals in the environment since they are an endocrine disrupting compound. In 2008, the Emerging Contaminants Workgroup drafted an outline for a white paper that reviews the state of knowledge regarding alkylphenol ethoxylates and will recommend strategies to minimize the occurrence of alklyphenol ethoxylates and their degradates in surface water. In 2009, the workgroup will continue to work on the white paper. D. Perfluorinated Organic Compounds Perfluorinated organic hydrocarbons are commonly used in carpet and textile coatings (e.g. ScotchGard) and surfactants (e.g. fire fighting foams). The most common perfluorinated organic hydrocarbon is perfluorooctane sulfonate (PFOS). PFOS is used as the key ingredient in Scotchgard, the 3M-made fabric protector, and has been part of consumer culture for over 40 years, valued for its ability to protect materials from stains because it repels both water and oil. It is widely used in a variety of industrial and consumer products, ranging from fire extinguishing foams to wrapping for microwave popcorn and other food products. Despite its many uses, little is known about the environmental behavior or persistence of PFOS. In 2002, Scotchgard's manufacture, 3M, eliminated their line of PFOS-related products. Clean Bay Pollution Prevention Plan 2008 Page 108 of 124

121 In 2004, RWQCP partnered with Stanford University and Oregon State University to analyze the plant influent and effluent for PFOS. RWQCP is WWTP #5 in two scientific articles that analyze the quantity of perfluorochemicals in municipal wastewaters and sludge. (Shultz M.M, Barofsky D.F., and Field, J.A and Higgins, C.P., et al, 2005). In the Shultz et al paper, the concentration of fluorinated alkyl substances in the influent ranged between 0.7 to 12 ppt, and was between 3.7 to 15 ppt in the effluent. It appears that the fluorinated alkyl substances are created during the treatment process. In the Higgins, et al paper, the concentration of PFCs in primary sludge ranged from not detected to 38.2 ppb. This paper also researched the concentrations in sediment near the RWQCP s effluent outfall, at the Palo Alto Baylands, and in San Francisquito Creek. The sediment PFOS concentrations are greater in the RWQCP outfall channel than in the Baylands sediment. In 2009, Palo Alto will partner with Stanford University to analyze samples during a pilot reverse osmosis unit after the dual media filters. E. Nitro-musks Nitro-musks are used as fragrances in cosmetics and personal care products. Palo Alto partnered with a researcher from Stanford University who analyzed for nitro-musks. The researcher analyzed two sediments from the Palo Alto shoreline. One sediment was collected from the pool directly below the outfall pipe, the other was collected from the intertidal zone in the Baylands Nature Preserve. Preliminary analyses suggest that both musk xylene and musk ketone can be found in both sediments, at levels of a few micrograms per kilogram of sediment (ppb). The nitromusk reduction products amino musk ketone and amino musk xylene are also present in the sediment at similar concentrations. The levels of all nitromusk compounds appear to be higher at the outfall site than at the nearby baylands site. In 2005, the researcher worked on analytical methods. In 2007, the researcher hopes to analyze more samples near the outfall pipe as well as samples from the treatment plant. Palo Alto will continue to partner with Stanford University regarding the concentrations of nitro-musks. F. Polybrominated Diphenyl Ethers Polybrominated diphenyl ethers (PBDEs) are a class of compounds that bioaccumulate in the food web and are considered potential endocrine disruptors. PBDEs are fairly ubiquitous in consumer products; over time the products that contain PBDEs break down, which enables the release of brominated flame-retardants. Since levels of PBDEs have increased in seal blubber in the San Francisco Bay, Palo Alto staff collected samples to characterize the fate and transfer of PBDEs at the RWQCP and compare the results with other treatment plants throughout the world. In August 2002, samples were collected from the effluent, biosolids, and incinerator stack emissions. The results from this study were published in the journal Environmental Science and Technology - (North, 2004). Since Palo Alto published the results on PBDEs in the wastewater treatment plant, further studies regarding PBDEs in the Bay have emerged; specifically the Regional Monitoring Program is now monitoring PBDEs in ambient water samples. In 2004, the Clean Estuary Partnership has also allocated resources this year to conduct a literature search for PBDEs in the Bay. In 2008, Palo Alto staff attended some workshops regarding the alternatives to brominated flame retardants, specifically Firemaster 550. In 2008, Palo Alto provided sludge for a researcher to determine the new alternative Firemaster 550. Clean Bay Pollution Prevention Plan 2008 Page 109 of 124

122 Based no the researcher, we do see Firemaster 550 levels in our sludge. In 2009, Palo Alto staff will continue to stay up to date on PBDEs in the San Francisco Bay, the potential sources and alternative products. G. N-nitroso dimethylamine (NDMA) N-nitroso dimethylamine is a carcinogen known to be present in various foods and industrial products. NDMA has been found in the effluent of various water and wastewater plants, but its formation mechanism is not fully understood. According to the literature, NDMA appears to be a by-product of the chloramination of water and wastewater; the level of NDMA formed is related to the chloramine dose. In 2005, the disinfection process of the source water to the RWQCP changed from free chlorine to chloramine treatment. Since 2002, Palo Alto staff has researched the concentrations of NDMA in effluent, the concentrations range from non-detect to 300 ng/l in the effluent and 450 ng/l in recycled water. In 2004, Palo Alto participate din a WaterReuse study "Removal and Destruction of N-nitrosodimethylamine (NDMA) and NDMA Precursors during Wastewater Treatment" (WaterReuse Foudation, 2004). This study focused on NDMA formation within the plant and recycled water distribution system The concentration of NDMA increased from 100 ng/l to approximately 250 ng/l during the chlorination process and then decreased within the distribution system back to concentrations comparable to those detected prior to chlorination (WaterReuse, 2004). In 2007, a large discharger of NDMA closed in East Palo Alto, Palo Alto staff anticipates that the concentration of NDMA has decreased since the closure of a local household hazardous waste treatment facility. In 2009, Palo Alto will continue to look for further opportunities to study the formation of NDMA in wastewater. Clean Bay Pollution Prevention Plan 2008 Page 110 of 124

123 References Adolfsson-Erici, M. Patterson et al. Triclosan, a commonly used bactercide found in human milk and in the aquatic environment, in Abstracts of Dioxin, 2000, 20 th International Symposium on Halogenated Environmental Organic Pollutants and POP s: Monterey, Ca., Volume 48, page 83, Association of Bay Area Governments, Bay Area Dioxins Project, February Association of Metropolitan Sewerage Agencies, Evaluation of Domestic Sources of Mercury, August Bay Area Air Quality Management District (BAAQMD), Toxic Air Contaminant Control Program Annual Report 1994, Barron, Thomas S., 1999 Copper Headworks Loading, analysis prepared for the Palo Alto Regional Water Quality Control Plant, March Barron, Thomas S., Mercury Headworks Analysis for RWQCP for 2000, March 2001; revised Borgmann U., D.T. Bennie, A.L. Ball, and V. Palabrica. Effect of a mixture of seven pharmaceuticals on Hyalella azteca over multiple generations. Chemosphere. 66: Brain, R. A., D. J. Johnson, S. M. Richards, H. Sanderson, P. K. Sibley, and K. R. Solomon. Effects of 25 pharmaceutical compounds to Lemna gibba using a seven-day static-renewal test. Environmental Toxicology and Chemistry. 23: California Department of Pesticide Regulation, Diazinon and Chlorpyrifos in the CCCSD Sewer System, Summer 1996, California State Water Resources Control Board, Water Quality Control Plan for Enclosed Bays and Estuaries, Central Contra Costa Sanitary District (CCCSD) and Larry Walker Associates (LWA), Residential Metals Study, Common Ground for the Environment, Brake Pad Partnership: Phase 1 Report, October Cooper, Ashli, Palo Alto Regional Water Quality Control Plant, Diazinon in Urban Areas, August Cooper, Ashli, Larry Walker Associates, Memorandum: Low-Dioxin Impact Personal Hygiene Products, August 14, Copper and Selenium Steering Committee, Water Supply and Wastewater Treatment Agencies Providing Service to Santa Clara County, Copper and Selenium in the Water Supply of the Santa Clara Valley, Cunningham V.L., M. Buzby, T. Hutchinson, F. Mastrocco, N. Parke, and N. Roden. Effects of human pharmaceuticals on aquatic life: next steps. Environmental Science and Technology. 40(11): Daughton, C.G. and Ternes, T.A. Pharmaceuticals and Personal Care Products in the Environment: Agents of Subtle Change. Environmental Health Perspectives, Vol 107, Supplement 6: [available: Clean Bay Pollution Prevention Plan 2008 Page 111 of 124

124 EIP Associates, Dioxins Source Identification, prepared for the Palo Alto Regional Water Quality Control Plant, EIP Associates, Copper Source Identification, prepared for the Palo Alto Regional Water Quality Control Plant, EIP Associates, Products and Processes involving Chloranil, Technical Memorandum, prepared for the Palo Alto Regional Water Quality Control Plant, December 21, EIP Associates, Zinc Source Identification, prepared for the Palo Alto Regional Water Quality Control Plant, Engberg, Catherine, Palo Alto Regional Water Quality Control Plant, The Regulation and Manufacture of Brake Pads: The Feasibility of Reformulation to Reduce the Copper Load to the San Francisco Bay, July Environmental Defense Fund, White Paper No. 5 Environmental Comparison of Bleached Kraft Pulp Manufacturing Technologies, Fent K., A.A. Eston, and D. Caminada Ecotoxicology of human pharmaceuticals. Aquatic Toxicology. 76: , Ferrari, B., N. Paxeus, R. Lo Giudice, A. Pollio, and J. Garric. Ecotoxicological impact of pharmaceuticals found in treated wastewaters: study of carbamazepine, clofibric acid, and diclofenac. Ecotoxicology and Environmental Safety. 55: , Hansen, S. R., & Associates, Identification and Control of Toxicity in Storm Water Discharges to Urban Creeks, March Harrold, K.H., D. Yee, M. Sedlak, S. Klosterhaus, D. Oros, and J.A. Davis. Pharmaceutical Concentrations in Influent and Effluent from Two Wastewater Treatment Plants and in Lower South San Francisco Bay. SFEI Contribution. San Francisco Estuary Institute, Oakland, CA (currently in draft form) Higgins, C.P., Field, J.A., Criddle, C.S, and Luthy, R.G. Quantitative Determination of Perfluorochemicals in Sediments and Domestic Sludge, Environmental Science and Technology, Vol 39, No. 11, Hornberger, Michelle. "Copper concentrations in clams and sediment (1975 to 1998) at Sand Point." Excel file received January 15, United States Geological Survey, Menlo Park, CA, Hornberger, Michelle, Samuel Luoma, Daniel Cain, Francis Parchaso, Cynthia Brown, Robin Bouse, Christopher Wellise, and Janet Thompson, Bioaccumulation of metals by the bivalve Macoma balthica at a site in South San Francisco Bay between 1977 and 1997: Long-term trends and associated biological effects with changing pollutant loadings, U.S. Geological Survey Open File Report 99-55, Isidori, M., M. Lavorgna, A. Nardelli, L. Pascarella, and A. Parrella. Toxic and genotoxic evaluation of six antibiotics on non-target organisms. Science of the Total Environment. 346: Katznelson, Revital and Thomas Mumley, Diazinon in Surface Waters in the San Francisco Bay Area: Occurrence and Potential Impact, prepared by Woodward Clyde Consultants and the California Regional Water Quality Control Board, San Francisco Bay Region, Kennedy/Jenks Consultants, Copper Corrosion Reductions Associated with the Design and Construction Practices of Piping Systems, Heating Systems, Cooling Systems, and Hot Water Circulating Systems, June Clean Bay Pollution Prevention Plan 2008 Page 112 of 124

125 Kennedy/Jenks Consultants, Copper Loading from Cooling Towers and Potable Hot Water Circulation Systems, December Kennedy/Jenks Consultants, Copper Corrosion Reduction Associated with the Addition of a Chemical Corrosion Inhibitor to the City of Palo Alto s Distribution System, May Kolpin D.W., E.T. Furlong, M. T. Meyer, E.M. Thurman, S.D. Zaugg, L.B. Barber, and H.T. Pharmaceuticals, Hormones and Other Organic Wastewater Contaminants in U.S. Streams A National Reconnaissance, Environmental Science and Technology, 36: Looker, Richard, Johnson, Bill Mercury in San Francisco Bay Total Maximum Daily Load (TMDL) Proposed Basin Plan Amendment and Staff Report, Regional Water Quality Control Board, September, Luoma, Samuel N. et al., Near Field Receiving Water Monitoring of Trace Metals in Clams and Sediments near the Palo Alto and San Jose/Sunnyvale Water Quality Control Plants in South San Francisco Bay: December 1994 through December 1996, Luoma, Samuel N. et al., Near Field Receiving Water Monitoring of Trace Metals in Clams (Macoma balthica) and Sediments near the Palo Alto and San Jose/Sunnyvale Water Quality Control Plants in South San Francisco Bay, California: 1997, Mimeault C., A.J. Woodhouse, X.S. Miao, C.D. Metcalfe, T.W. Moon, and V.L. Trudeau.The human lipid regulator gemfibrozil bioconcentrates and reduces testosterone in the goldfish Carassius auratus. Aquatic Toxicology. 73: Montgomery Watson, Local Limits Development: Headworks Loadings Allocation Evaluation, prepared for the City of Palo Alto, January Montgomery Watson, Proposed Local Limits, prepared for the City of Palo Alto, April Montgomery Watson, Revised Estimate of RWQCP Influent Loadings During Calendar Year 1993 and Fiscal Year , September Montgomery Watson, Pollutants of Concern Evaluation, prepared for the Palo Alto Regional Water Quality Control Plant, July, Palo Alto Regional Water Quality Control Plant (RWQCP), Analysis of Impacts to Achieve Water Quality Based Effluent Limits for the Regional Water Quality Control Plant (report contains the Metals Reduction Study), North, K.D., Environmental Science and Technology, 2004: 38, Palo Alto Regional Water Quality Control Plant (RWQCP), Pretreatment Program Annual Report, February Regional Integrated Pest Management Committee, Regional Evaluation Report for the Our Water, Our World Promotion, June Regional Water Quality Control Board, San Francisco Bay Region, (Regional Board), Watershed Management of Mercury in the San Francisco Bay Estuary: Total Maximum Daily Load Report to U.S. EPA, June Regional Water Quality Control Board, San Francisco Bay Region, (Regional Board), San Francisco Bay Water Quality Control Plan, Regional Water Quality Control Board, San Francisco Bay Region, (Regional Board), Defining the Mercury Problem in the Northern Reaches of San Francisco Bay and Designing Appropriate Regulatory Approaches, June Clean Bay Pollution Prevention Plan 2008 Page 113 of 124

126 Regional Water Quality Control Board, San Francisco Bay Region (Regional Board), State Water Resources Control Board, and Department of Fish and Game (Regional Board, State Board, and DFG), Contaminant Levels in Fish Tissue from San Francisco Bay, June Samsøe-Petersen, L., M. Winther-Nielsen, and T. Madsen, Danish EPA, Fate and Effects of Triclosan, September San Francisco Bay Area Pollution Prevention Group, Diazinon & Chlorpyrifos Quantitative Identification for San Francisco Bay Area Wastewater Treatment Plants, December 18, Santa Clara Valley Urban Runoff Program (Urban Runoff Program), Metals Control Measures Plan and Evaluation of Nine Metals of Concern, February Santa Clara Valley Urban Runoff Program (Urban Runoff Program), Annual Report, September Santa Clara Valley Urban Runoff Program (Urban Runoff Program), Urban Runoff Management Plan, September Santa Clara Valley Water District and Kennedy/Jenks Consultants, Internal Corrosion Control Study, June Scanlin, James, and Arleen Y. Feng, Characterization of the Presence and Sources of Diazinon in the Castro Valley Creek Watershed, prepared for the Alameda County Flood Control and Water Conservation District, June Scanlin, James, and Sharon Gosselin, Strategy to Reduce Diazinon Levels in Creeks in the San Francisco Bay Area, prepared for the Alameda County Flood Control and Water Conservation District, August Schmitt-Jansen M., P. Bartels, N. Adler, and R. Altenburger. Phototoxicity assesment of diclofenac and its phototransformation products. Analytical and Bioanalytical Chemistry. 387: , Schultz, M.M., Barofsky, D.F., and Field, J.A. Quantitative Determination of Fluorinated Alkyl Substances by Large-Volume-Injection Liquid Chromatography Tandem Mass Spectrometry Characterization of Municipal Wastewaters, Environmental Science and Technology Vol. 40/ No.1, Vanderford B.J. and S.A. Snyder. Analysis of Pharmaceuticals in Water by Liquid Chromatography/Tandem Mass Spectrometry. Environmental Science and Technology. 40: , South Bay Copper Reduction Dialogue, Memorandum of Understanding, March TDC Environmental, Insecticide Market Trends and Potential Water Quality Implications, April WaterReuse Foundation "Draft Removal and Destruction of N-nitrosodimethylamine (NDMA) and NDMA Precursors during Wastewater Treatment" (WRF ) Sponsored by the WateReuse Foundation Principal Investigators - Michael C. Kavanaugh (Malcolm Pirnie) and David Sedlak (UC Berkeley), Woodward-Clyde Consultants, Source Identification and Control Report, prepared for the Santa Clara Valley Nonpoint Source Pollution Control Program, December 1992 Woodward-Clyde Consultants, Contribution of Heavy Metals to Storm Water From Automotive Disc Brake Pad Wear, prepared for the Santa Clara Valley Nonpoint Source Pollution Control Program, October Clean Bay Pollution Prevention Plan 2008 Page 114 of 124

127 Woodward-Clyde Consultants and Kinnetic Laboratories, Santa Clara Valley Nonpoint Source Study. Volume 1: Loads Assessment Report, prepared for the Santa Clara Valley Water District, July Clean Bay Pollution Prevention Plan 2008 Page 115 of 124

128 Glossary Best Management Practices Feasible actions that, if taken, will minimize pollutant discharges to the sewer and storm drains. Chlorpyrifos A commonly used organophosphate insecticide generally sold under the trade names Dursban, Lorsban, and Pyrinex. Clean Bay Business Business recognized by the RWQCP for actions taken in compliance with ordinance requirements that result in reduction of toxic discharges to sewers and storm drains. Clean Water Act Primary Federal law on water pollution. Congener A molecule that is the member of a family of substances. For example, there are 210 different dioxins, each with a unique structure; each unique structure is a congener. Corrosion The gradual deterioration of a surface (through relatively slow electrochemical reactions). Dioxins A collection of molecules with a common chemical structure based on two linked carbon rings. Technically, the group is known as polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs). PCDDs may have up to eight chlorine atoms. PCDFs may also have up to eight chlorine atoms. Because PCDFs share many structural and chemical characteristics with PCDDs, their inclusion is often implied when using the term dioxins, as it is in this report. Effluent Treated wastewater discharged from a wastewater treatment plant. Flux A liquid that is used when soldering copper piping that helps the solder to fill the gap and take hold between two copper pieces. Graywater Untreated household wastewater that has not contacted toilet waste, such as used water from bathtubs, showers, and clothes washing machines. Headworks The place where wastewater enters a wastewater treatment plant. High Uncertainty Calculation is based on very limited data and numerous assumptions. Data may be obtained from a poorly documented source. Treatment of non-detect data may contribute greatly to uncertainty. Error could be greater than ±100%. Infiltration Seepage of groundwater into sewer pipes, which are not water tight. Typically increases during the rainy season when groundwater levels rise to submerge a greater fraction of the sewer system. Inflow Flow of surface water into sewer pipes, which typically occurs during the rainy season when stormwater runoff enters the sewer system through openings such as manhole covers. Influent Wastewater that arrives at the wastewater treatment plant. Local Limit Locally-enforced discharge limit applied to permitted dischargers of wastewater to the sewer system. May be an EPA-specified limit or a lower value developed on the basis of the needs of a specific wastewater treatment plant. Metal Finisher Company that plates metals onto surfaces either for cosmetic reasons or as a step in a manufacturing process. Printed circuit board manufacturers are specialized metal finishers. Clean Bay Pollution Prevention Plan 2008 Page 116 of 124

129 Mobile Cleaner Person or business, such as a power washer, window washer, carpet cleaner, janitor, automobile detailer, or steam cleaner, that cleans facilities or other items at a client s site. Moderate Uncertainty Calculation may be based on several data points, often obtained directly by RWQCP staff, or calculation may be based on limited data from reliable sources. Calculation may rely on some reasonable assumptions, and non-detect data may contribute somewhat to uncertainty. Non-Point Source Source of water pollutant that is not associated with a distinct discharge source, including rainwater; erosion; and stormwater runoff from roads, farms and parking lots. NPDES Permit National Pollutant Discharge Elimination System permit issued by the Regional Water Quality Control Board which regulates the RWQCP discharge. Organochlorine Pesticides Chlorine-containing pesticides such as DDT, chlordane, aldrin, dieldrin, and endrin that are typically relatively persistent in the environment. Organophosphate Pesticides A heavily used class of pesticides (with more than 100,000 members) that includes diazinon, chlorpyrifos, and malathion. They generally degrade more quickly in the environment than organochlorine pesticides. Orthophosphate Substance added to drinking water for purposes of controlling corrosion of piping (sodium phosphate). Publicly Owned Treatment Works Wastewater treatment plant. Regional Board San Francisco Bay Regional Water Quality Control Board; agency responsible for surface and ground water quality in the San Francisco Bay Area. Runoff The portion of rainfall or irrigation water that moves across land as surface flow and enters storm drains, streams, or other surface receiving waters. Runoff occurs when the precipitation rate exceeds the infiltration rate. Safe Drinking Water Act Federal law that sets up requirements for drinking water, including health, safety, and corrosion control. Source Control The reduction of pollutant levels in wastewater treatment plant influent through actions that directly or indirectly control activities of dischargers. State Board California Water Resources Control Board; state agency responsible for surface and ground water quality that oversees the San Francisco Bay Regional Water Quality Control Board. Vehicle Service Facility Auto repair facility, fleet maintenance operation, commercial car wash, parts cleaning and repair facility, or auto body shop. Very High Uncertainty Calculation is based on interpretation of a poorly documented source (or a foreign source that may not be representative of conditions in the RWQCP service area) and numerous important, yet uncertain, assumptions. Error could be more than one order of magnitude. Zinc Orthophosphate A substance added to drinking water for purposes of controlling corrosion of piping (a combination of zinc oxide and sodium phosphate).abbreviations Clean Bay Pollution Prevention Plan 2008 Page 117 of 124

130 AB Assembly Bill Ag Silver AMSA Association of Metropolitan Sewerage Agencies As Arsenic BAAQMD Bay Area Air Quality Management District BAHWRC Bay Area Hazardous Waste Reduction Committee BAPPG Bay Area Pollution Prevention Group BASMAA Bay Area Stormwater Management Agencies Association BMPs Best Management Practices Cal-EPA California Environmental Protection Agency CBP Clean Bay Plan; Palo Alto's annual pollution prevention / source control report CCCSD Central Contra Costa Sanitary District Cd Cadmium CN Cyanide Cr Chromium Cu Copper CWA Clean Water Act CWEA California Water Environment Association DEA- Drug Enforcement Agency DHS- Department of Health Services DTSC Department of Toxic Substances Control ECF Elemental chlorine free EPASD East Palo Alto Sanitary District Hg Mercury I/I Infiltration and inflow IPM Integrated pest management lb Pound lb/yr Pounds per year MGD Million gallons per day µg/l micrograms per liter mg/l milligrams per liter MPDS Mid Peninsula Dental Society Ni Nickel NPDES National Pollutant Discharge Elimination System NPS Non-point source (generally stormwater runoff) PAH Polycyclic aromatic hydrocarbon Pb Lead PCB Polychlorinated biphenyl PCDD Polychlorinated dibenzo-p-dioxin PCDF Polychlorinated dibenzofuran PCF Process chlorine free PCO Pest control operator ph Measure of acidity or alkalinity of a solution POTW Publicly-Owned Treatment Works (wastewater treatment plant) ppb Parts per billion ppm Parts per million ppt Parts per trillion RCM Reasonable Control Measure (RWQCP) RWQCP Regional Water Quality Control Plant SB Senate Bill SBSA South Bayside System Authority Se Selenium SCVURPPP Santa Clara Valley Urban Runoff Pollution Prevention Program SCVWD Santa Clara Valley Water District SWRCB California State Water Resources Control Board TCF Total chlorine free TEF Toxicity Equivalency Factor TEQ Toxic Equivalent TDS Total dissolved solids TMDL Total maximum daily load TSS Total suspended solids (capable of being filtered out of solution) U. S. EPA Federal Environmental Protection Agency USGS United States Geological Survey UWR Universal Waste Rule Zn Zinc Clean Bay Pollution Prevention Plan 2008 Page 118 of 124

131 Appendices A. Effluent Limitations B. Public Contacts in 2008 C. Selected Ads, Fact sheets, Utility Bill Inserts for 2008 D. FOG Inspection Form E. City of Palo Alto 2008 IPM Report Clean Bay Pollution Prevention Plan 2008 Page 119 of 124

132 Appendix A Effluent Limitations Desire to comply with the RWQCP s toxic pollutant effluent limitations provides significant motivation for the programs described in this plan. The RWQCP s NPDES permit issued in August 2003has both concentration limits (Tables A-1 and A-2) and mass limits (Table A-3). Table A-1. Conventional Pollutant Effluent Limits Constituent Units Monthly Average Daily Maximum Instantaneous Maximum Boichemical oxygen mg/l demand Ammonia, as nitrogen mg/l Suspended Solids mg/l Oil and Grease mg/l Settleable Matter mg/l-hr Turbidity NTU Chlorine Residual mg/l Table A-2. Toxic Pollutant Effluent Limits (Concentration, µg/l) Constituent Daily Max Monthly Average Interim Daily Maximum Weekly Average Copper Mercury 0.021* Nickel Cyanide Chlorodibromomethane ,4 -DDE Dieldrin Heptachlor Epoxide Benzo(b)Fluoranthene Indeno(1,2,3-cd)Pyrene *concentration trigger Table A-3. Toxic Pollutant Effluent Mass Limits Average Annual Constituent Limit (kg/yr) Mercury 0.38 Clean Bay Pollution Prevention Plan 2008 Page 120 of 124

133 Appendix B Public Contacts in 2008 Date Item or Event Contact Type Feb 21 Outreach school program with Jan Raissle: Walter Hayes elementary school with 2-3 rd grade classes, topic: Who dirtied the bay? focusing on storm drains School classroom outreach Mar 21 Apr 7 Apr 8 Apr 11 3 rd Annual Green Business Conference at Roche Palo Alto: half day event focusing on the process of becoming certified as a green business. Participants including a number of vendors with displays Outreach class at local high school with Jan Raissle: Filtering lab with 3-10 th grade classes Green Conference in Sacramento: all day event lasting several days. Forums on green businesses, landfills, hybrid cars, etc. Environmental Leadership Forum: staff briefed Acterra s Be the Change on water resource issues and led the group on a tour of PA s RWQC plant. The all day event is part of a year-long forum series designated to train environmental leaders in the community. program Table with display School outreach Program Attended conference forums Environmental Leadership Forum series Apr 12 Apr 15 Apr 17 Apr 20 Apr 25 Apr 30 May 1 Anti-Litter Tarp Giveaway, as part of the Great America Litter Pickup campaign. 7 landfill sites will give away free tarps in SC county. Focus will be on educating pick-up trucks to use tarps Presentation on FOG & FSE storm water pollution prevention program at the CWEA Annual Conference in Sacramento, CA. The presentation consisted of the implementation of the FOG program, hotspot identification, current ordinance requirements, plan review, develop. & implementation of inspection tablet PC & database program, case studies, inspection highlights, residential outreach and the goals. Wilson, Sonsini, Goodrich & Rosati Earth Day Fair: for staff. To include a variety of vendors with tables & hands on items to try Earth Day at Westwind Barn in Los Altos Hills: yearly event focusing on animal & wildlife preservation, organic gardening & wine tasting. Event mainly for locals. Stanford University Students Group s annual Green Festival with table display giving information on green products, alternative products, and energy efficiency information. Addison Avenue Credit Union in PA. Green Day event: 1 st year for event held indoors at staff s lunchtime. Nearby SAP employees invited to attend event as well Education subgroup committee meeting in SJ for SVALC. Review on Tarp giveaway, possibility of doing a Bay Area-wide anti litter campaign Promotional giveaway at landfills Presentation at Sacramento s CWEA conference Outreach event w/table & handouts Outreach event w/table & handouts Outreach event w/table & handouts Outreach event w/table & handouts Meeting Clean Bay Pollution Prevention Plan 2008 Page 121 of 107

134 Appendix B- Public Contacts in 2008 Date Item or Event Contact Type May 2 Earth Day at PARC: One Planet, One Home. Coordinated by Outreach event PARC s green team, vendor tables set up in cafeteria area w/table & May 5 May 8 May 17 Silicon Valley Anti Litter Committee meeting in San Jose: all subgroups and cities participating in the program attended, including a volunteer with the Adopt a Highway program. The Great American Pickup event was discussed at great length. Visit to all participating OWOW hardware stores to inform them of the new utility bill insert showing their store information. As part of the National River Cleanup day, a team from the Water Quality plant took on 2 creeks to clean: Barron & Adobe Creeks. Several bags were filled with debris. Much of the debris was small pieces of Styrofoam. Creek banks were accessed by small boats. handouts Roundtable update Participating store visits Volunteer event. Coordinated Water Quality May 20 School outreach class at Huff School in Mt. View, with Jan Raissle. Topic: Mercury School Outreach class May 21 Invited to IPM training given by Annie Joseph at new Ace Hardware store in San 2253 Lincoln Avenue, same owner as PA Hardware: Larry Hassett. Both teams of employees attended training. Jun 2 School outreach 2 nd Grade class at Hoover Elementary School in Palo Alto with Jan Raissle. Topic: What s Bugging You Jun Acterra s Business Environmental Awards at Frances C. Arrillaga Alumni Center Stanford University. Event included cocktail reception, presentations, film clips by all winners (describing their business models) and awards given. Mayor of Palo Alto attended. Jun 16 SVALC Education Committee meeting to discuss goals for the 5 year plan. One objective is to expand the existing SJ anti-litter campaign to a bay area wide campaign including website. Next tarp giveaway to be in October 08. Jun 22 First Barron Park Green Event and Homes Tour: vendors invited to set up in Bol park area, while residents visit vendors and then tour 13 homes. Hours of event 1-5pm. Tour map given to residents for homes to visit. Event is FREE. No advertising done to promote except with the Barron Park residents. Aug 1 Watt Stoppers Green Fair put on by Watt Stopper/Legrand company in Santa Clara for staff and local offices. Assisted the SCVURPPP office answering questions at table. Aug 5 National Night Out : Attended on behalf of the Water Quality Plant. 4 block parties were visited in teams of 2-4 people between hours of 6:30-8:30pm. Other departments attending this event were Pesticide /OWOW Training School outreach class Awards ceremony City of PA was a sponsor Anti-Litter Committee meeting Public outreach event for Barron Park district Green Event for employees and surrounding offices Police outreach at neighborhood block parties. Clean Bay Pollution Prevention Plan 2008 Page 122 of 124

135 Appendix B- Public Contacts in 2008 Date Item or Event Contact Type the PA Police, Fire Dept, Utilities and Parks department. Residents truly enjoy this yearly event. Aug 7 Sep. 20 Sept. 25 Oct 2 Los Altos Farmers Market (every Thursday night from 4-8pm). Mostly produce & food vendors. Small contingency of non-food tables present to answer questions. Mostly attended by adults. National Coastal Cleanup Day local cleanup campaign done with the Santa Clara Valley Water District. Palo Alto participated by cleaning up several creeks on the east and west sides of Hwy 101. Largest national volunteer event of the year, with a lot of PR. Matadero, San Francisquito & Adobe Creeks had volunteer participation. Volume of trash collected and number of volunteers tripled from the previous year. Start of school season s Microbes in Sewage classes with Jan Raissle. Students and teaching staff love this class! Employee Benefits Fair new venue Mitchell Park, Employee Recognition Celebration to follow. Vendor tables set up for city staff. Community outreach Public awareness litter cleanup School outreach science program PA city employees event Oct. 15 Plant tour for 50 Motorola employees. Public (corporate) Tour Oct 23 Nov 1 Nov. 3 Presentation on Pharmaceutical Disposal in the Bay Area, at the Western Regional Sustainable Pollution Prevention Conference, Monterey, CA 2 nd Tarp Give Away at all landfills in Santa Clara county. 395 tarps distributed. Rainy weather had impact on volume of tarp giveaways. Combined with the 676 tarps handed out in April Campaign goal was met of handing out 1,000 tarps in 2008 City Council Study Session: Girl Scout Troop presented their student signed Plastic Bag Ban pledges from their school to the City Council members, along with a reusable bag. Dec. 4 Jewish Community Center in Palo Alto given workshop on water where does it go & what can we do to take better care of it? Pharmaceutical disposal discussed as well. Dec. 17 Gopher & Ground Squirrel IPM Workshop, given by gopher expert Dr. Gilbert Proulx from Canada. In field workshop provided after lecture and lunch. Continuing Education credits given for workshop. Presentation Free giveaway along with flyer City Council meeting Girls Scout Troop participation Presentation and talk with display Training for service area city staff + private sector pesticide businesses Clean Bay Pollution Prevention Plan 2008 Page 123 of 124

136 Appendix C Selected Factsheets, Newsletter Articles and Utility Bill Inserts Clean Bay Pollution Prevention Plan 2008 Page 124 of 124

137 Free Disposal of Household Hazardous Waste Bring your unwanted or unused toxic household products to the City of Palo Alto Household Hazardous Waste Event. Never dispose of toxics down the drain or in the garbage. ACCEPTING: Photo chemicals Pharmaceuticals Paints and paint products Solvents and fuels Chemical drain openers Pool chemicals Household cleaners Aerosols Pesticides and insecticides Hypodermic needles Palo Alto residents only. First Saturday each month, 9 a.m. noon December 6, 08 April 4 August 1 January 3, 09 May 2 September 5 February 7 June 6 October 3 March 7 July 4 November 7 New! Can t make our weekend events? Call (650) to schedule an appointment during the week. Location Regional Water Quality Control Plant 2501 Embarcadero Way, Palo Alto, CA For Palo Alto event details and information for Santa Clara and San Mateo County residents: (650)

138 1960s DDT causes cancer and harms bird populations. 1990s Diazinon and chlorpyrifos pose neurological health threats to children and cause toxicity in Santa Clara County creeks. 1970s & 80s Chlordane and dieldrin from run-off water still impair San Francisco Bay today. Safely dispose of pesticides & other household hazardous wastes free. Attend a Household Hazardous Waste Disposal Event at the Regional Water Quality Control Plant 2501 Embarcadero Way, Palo Alto. First Saturday of every month, 9am noon. Palo Alto residents only. Find directions and other drop-off options in Santa Clara and San Mateo Counties at our website or by calling New! By appointment! Can t attend the monthly drop-off event? Call to schedule an appointment for special drop-off.

139 Got Bugs? Get Answers Choose less toxic products for the healthy home and garden... available at: Common Ground Organic Garden Supply 559 College Avenue, Palo Alto Palo Alto Hardware 875 Alma Street, Palo Alto Peninsula Hardware 2676 Middlefield Road, Palo Alto Los Altos Garden Supply 4730 El Camino Real, Los Altos Los Altos Nursery 966 Hawthorne Avenue, Los Altos Look for these fact sheets and T he Argentine ant is a frequent invader in California homes. Although they can be pests, ants provide an ecological cleansing and fertilization service of considerable importance. For example, they kill and eat many pest insects, aerate the soil, and recycle dead animal and vegetable material. Because of these beneficial aspects, it is undesirable (and probably downright impossible) to eliminate ants from their outside habitat. The best approach to ant management is to try to keep them outdoors. LESS-TOXIC PEST MANAGEMENT ANTS CONTROLLING IN YOUR HOUSE DETECTION Look for individual scouts or long lines of ants in or around the house near food or water. Distinguish Argentine ants from Carpenter ants by size. Argentine ants are small ( 1 /8"), and their queens are slightly larger. Carpenter ants are 1 /4" or larger and require different management techniques from those listed below for Argentine ants. LESS-TOXIC CONTROLS INSIDE YOUR HOME Kill the scouts so they can t call in the hordes when they find a tasty tidbit. Use ant baits because they use a minimum of insecticide and confine it to a very small area (see Tips for Using Ant Baits on back). Use insecticidal dusts such as diatomaceous earth (DE) in wall voids and cracks before they are sealed. Use a hand duster to apply DE and wear a dust mask and goggles. DE has little toxicity to humans or pets, but kills insects by absorbing their outer waxy coating, causing dehydration and death. Choose less toxic products for your home and garden. Look for this symbol before you buy. OUTSIDE YOUR HOME Use sticky barriers around the trunk of a tree or bush to prevent ants from protecting aphids and other honeydew -producing insects. Prune any branches that touch walls, fences or the ground so ants cannot find alternate routes into the plant. Ant Baits. If you can find the spot outside where ants are entering the building (this is often difficult to do), place bait stations there; otherwise use baits only inside. Outside, rain and sprinklers can wash baits away, and you may end up attracting ants to your house. PREVENTION Store food in containers that seal tightly or in the refrigerator when you notice ant activity. Keep things clean and dry and fix leaking faucets and pipes (ants need food and water). Caulk cracks where ants are entering the house. Weather-strip doors and windows. Put pet dishes in a soapy moat. Partially fill a wide, shallow container with soapy water and place pet dishes in the water. shelf tags at participating stores Rancho Hardware 1150 Riverside Drive, Los Altos Blossom True Value Hardware 1297 W El Camino Real, Mountain View Orchard Supply Hardware 255 Charleston Road, Mountain View SummerWinds Garden Center 725 San Antonio Road, Palo Alto 805 Yuba Drive, Mountain View Learn about earth-friendly products The Regional Water Quality Control Plant is operated by the City of Palo Alto for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo Alto and Stanford.

140 Less-Toxic Pest Management keeping rats and mice away from your home Three of the most problematic rodents are the roof rat, the Norway rat, and the house mouse. Rats and mice eat and contaminate your food, damage property and household items, and carry diseases. Rats may carry tropical rat mites that can bite humans and cause severe itching. Rodents can aggravate allergies and asthma, and can even cause fires by chewing the plastic insulation off electrical wires in your walls or attic. It is important to keep rodents out of and away from your home. Detection Look for droppings, gnawed holes and other signs of gnawing, rat burrows in the ground, and nests made from shredded fibrous materials such as paper, cloth, or insulation. Rats and mice leave brown, greasy rub marks from the oil and dirt on their fur as they move along frequently traveled paths. You may see the animals themselves, smell them, or hear them gnawing and scampering at night in walls and ceilings. Prevention Eliminate Access to Structures The most important preventive measure is making it difficult for rodents to get into your home. Seal any cracks, crevices or voids that are large enough to stick a pencil through. Mice can squeeze through a hole that small, and both rats and mice can gnaw on a small hole to make it larger. Seal large holes with sheet metal flashing, 1 /4" hardware cloth, plaster, or mortar. Seal smaller holes with caulk, spackle, or cement. Use knitted copper mesh (scouring pads) to stuff into large gaps. (Steel wool will rust and eventually allow rodents access again.) Seal gaps around pipes and wires where they enter the structure or where they pierce an interior wall. Make sure that windows and doors fit properly. Use weather stripping and door sweeps if necessary, or repair thresholds and windowsills. Keep outside doors (or screen doors) closed. Keep tree and shrub branches 3' to 6' away from buildings to prevent roof rats from using them as a walkway to the upper parts of the structure. Store Food Properly Keep food in the refrigerator or pest-resistant containers made of glass, metal, or heavy plastic with tight-fitting lids. Do not leave food out overnight. Store dry pet food, birdseed, and grass seed in pest-resistant containers. Remove and clean pet dishes after pets have eaten. Do not leave pet food out over night, especially outdoors. Keep Things Clean Sweep or wipe up food spills promptly. Clean food preparation and eating areas daily. Promptly wash dishes and utensils, or store them in the dishwasher with the door closed. Empty garbage regularly. Store it outside in rodent-proof garbage containers with the lids closed tightly. Choose less toxic products for your home and garden. Look for this symbol before you buy.

141 PEST OR PAL? (First Time Offered!) (a fun and informative workshop that meets CA Science Content Standards) Have you or your students ever been bitten by a mosquito, stung by a wasp, had ants under your desk, or had weeds overtake your school garden? Learn about the wonderful world of bugs and how they can help make your classroom and/or garden a Pesticide-Free Zone! Join us for a fun day of hands-on activities, games, and experiments that can be used with your students! FREE TO MARIN TEACHERS in Grades 2 5, on Saturday, October 15, 2005 from 9 a.m. to 4 p.m.! (Location to be announced.) CE units available on request. What you'll learn: anatomy, life cycles, habitats, adaptations, and insect/plant connections the importance of insect pests AND pals in the environment how to identify good bugs, as well as pests, in classrooms, schoolyards, homes and gardens environmentally friendly ways to manage pests and protect the health of people, pets and the environment how to organize a pest patrol and involve students in science-based problem solving What you'll get: curriculum guide with hands-on activities and resources fun & informative activity booklet for each student healthy home and garden guide for each student s family miscellaneous items - e.g. bug ID guide, native plants and 2-way viewers All activities are aligned with the California Science Content Standards! For more information, contact Marin County Stormwater Pollution Prevention Program at ! Reserve Your Spot TODAY: Pest or Pal Workshop for Teachers Send to MCSTOPPP, P.O. Box 4186, San Rafael, CA Name Home Address City Zip Day-Time Phone School Grade Optional CE Credit Yes No (A $45 fee will be charged for 1 unit on day of class.)

142 prevent litter! It s the law Police are monitoring landfills and issuing fines* for untarped loads. It s safer Litter blowing out of your truck could cause an accident. It s cleaner Keep our streets and streams litter-free. AVOID A FINE OF UP TO $271 TARP YOUR LOAD! Tarps provided by the following agencies: Use a tarp to cover your load. To report a littering vehicle in Santa Clara County, call * State Vehicle Code (a) and City of San José Solid Waste Ordinance Other ordinances may apply.

143 THE SAN FRANCISCO BAY. IT S PART OF YOUR DAILY LIFE. SO DON T DUMP OLD MEDICINES IN SINKS OR TOILETS We live and work in a watershed that flows to the Bay. Medicines disposed down drains or toilets can be harmful to fish according to the U.S. Environmental Protection Agency. Even though water used in your home is treated before it s discharged to the Bay, modern water treatment facilities aren t designed to remove all medications. SAFELY DISPOSE OF OLD MEDICINES FREE Bring them to the Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto at the following times: On weekdays, M F, 8am 5pm First Saturday of every month, at the monthly household hazardous waste collection event FOR MORE INFORMATION, CALL The Regional Water Quality Control Plant is operated by the City of Palo Alto for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo Alto and Stanford. Individuals with disabilities who require accommodations to access City facilities, services or programs, or who would like information on the City's compliance with the Americans with Disabilities Act (ADA) of 1990, may contact the City s ADA Coordinator at (voice), or ada@cityofpaloalto.org Printed on recycled paper. 04/08

144 THE SAN FRANCISCO BAY. IT S PART OF YOUR DAILY LIFE. SO DON T DISPOSE OF USED COOKING OIL OR GREASE DOWN THE DRAIN. We live, work and play in a watershed that flows to the Bay. When grease is poured down sinks, it can solidify and cause sewer backups into houses or onto streets. Raw sewage can enter storm drains, creeks and the Bay, which harms wildlife. POUR COOKING GREASE OR SMALL AMOUNTS OF OIL INTO A SEALED CONTAINER (solidified with an absorbant such as used paper towels for liquid cooking oil) and place in the garbage. Deep frying a turkey? Bring your leftover frying oil to the Recycling Center, located at the east end of Embarcadero Road across from Byxbee Park. For more information, call or visit our website. The Regional Water Quality Control Plant is operated by the City of Palo Alto for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo Alto and Stanford. Individuals with disabilities who require accommodations to access City facilities, services or programs, or who would like information on the City's compliance with the Americans with Disabilities Act (ADA) of 1990, may contact the City s ADA Coordinator at (voice) or ada@cityofpaloalto.org Printed on recycled paper. 11/08

145 THE SAN FRANCISCO BAY. IT S PART OF YOUR DAILY LIFE. Medicines such as birth control pills, antidepressants, antibiotics, aspirin and veterinary medicines that are disposed down toilets and drains are being found in streams and rivers throughout the country, and in San Francisco Bay. DON T FLUSH EXPIRED OR UNUSED DRUGS DOWN TOILETS OR DRAINS! Even though wastewater is treated, many drugs cannot be removed before wastewater is discharged to the Bay. SAFELY DISPOSE OF OLD MEDICINES FREE Bring them to: Regional Water Quality Control Plant 2501 Embarcadero Way Palo Alto Monday through Friday, 8 am 5 pm or to the same location during the monthly Household Hazardous Waste Event (first Saturday of each month 9 am noon). Visit or Call The Regional Water Quality Control Plant is operated by the City of Palo Alto for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View, Palo Alto and Stanford. Individuals with disabilities who require accommodations to access City facilities, services or programs, or who would like information on the City s compliance with the Americans with Disabilities Act (ADA) of 1990, may contact the City s ADA Coordinator at (voice), or ada@cityofpaloalto.org Printed on recycled paper. 09/08

146 Appendix D FOG Inspection Form

147 Regional Water Quality Control Plant 2501 Embarcadero Way Palo Alto, CA * (650) FOOD SERVICE FACILITY INSPECTION SURVEY Record No. Business Name Ph. # Fax Business Address Business Owner Contact Person/Title Seating Capacity Meals/Peak Hour Last Inspection Inspection Date Food Service Establishment (FSE) Priority Level 1) Problem FSE in hot spot 2) Problem FSE 3) FSE in hot spot 4) FSE that has only had minor issues in the past 5) FSE with potential to generate FOG 6) FSE without significant potential to generate FOG FSE Type Service Type Single service (Disposable) Full service Sit down Take out Primary Languages English Spanish Chinese Korean Vietnamese Other: GRD(s) Maintenance Log Yes, available Yes, can not locate Offsite No, do not have Cleaning GRD(s) Last cleaning date: Frequency: Week(s) Month(s) Other: Self Contractor: Ph.#: Additives: No Yes, Lateral/Internal Cleaning No Yes, Vendor: Ph.#: Freq: Grease Removal Device(s) (GRD) None Grease trap # Grease interceptor # Mechanical # gallons lbs. Dimensions: L, W, H Opened & Appearance Equipment to GRD(s) Sink # 3 comp. sink # Mop sink # Dishwasher # Temperature Floor drain # Flow restrictor # Other: BMP Posters Displayed No Yes, # Cooking Equipment Grill # Fryer # Oven # Stove # Wok # Rotisserie # Best Management Practices (BMPs) Drain screens, frequent cleaning of screens Disposal of food waste to trash Dry wipe: pots, pans, dishes before washing Safe procedure for disposing of fats, oils & grease (FOG) Spill clean-up Employee training Grinder/Disposer No Yes, # Tallow Bin No Yes, # Vendor: Ph.#: Freq: Condition Good Oil spilled Lid not on correctly Trash/Back Area Covered/Enclosed Uncovered Dumpster(s) Container(s) Compactor(s) Shared Not shared Good condition Moderate condition Bad Leaking Floor Mat Cleaning Outside to Inside to Vendor: Ph.#: Exhaust Hood & Filter Cleaning Hoods Filters Vendor: Ph.#: Storm Drains # Zinc-Free Floor Finish No Yes, BMP Posters Given No Yes, # Language(s) Comments: Please fax, (650) , or mail (above address) by. Inspector s Signature Date Print Name Facility Contact Signature Date Print Name

148 Appendix E City of Palo Alto 2008 IPM Report

149 Background City of Palo Alto 2008 IPM Program Report February 2, 2009 In 2001, the City of Palo Alto adopted a reduced-risk pest management policy and drafted an Integrated Pest Management (IPM) plan for the use of pesticides by City staff and contractors. The goals of the IPM program are to: minimize water quality impacts from pesticide-related ecotoxicity; minimize total pesticide use; and use the least toxic pesticides when pesticides are needed. These goals are to be achieved through an annual quantification of the City's pesticide use and continual improvement of pest control strategies. Integrated pest management (IPM), also known as reduced-risk pest management, encourages longterm pest prevention and suppression through a combination of techniques. These techniques include: biological controls, habitat manipulation, use of resistant plant varieties, improved landscape and building hygiene, and structural repair and pest barriers. IPM sanctions synthetic chemical pesticides only as a last resort, and only with the least toxic chemicals available. While the City of Palo Alto has used these principles for many years, additional storm water protection regulatory requirements resulted in a more formal, structured IPM program. It should be noted that some pest controls, such as use of goats, mulching, mowing, and mechanical removal of weeds, were in place before quantification of pesticide use began in 2001, so that reductions in the use of some pesticides have been greater over the long term than the data indicates. To evaluate the chemical toxicity of chemicals used, a tiered system is used 1 (based on a City of San Francisco study) which considers (1) acute human toxicity and chronic health risks; (2) the level of training required to use the product; (3) inclusion of a chemical on the Clean Water Act 303d list for impairment of a local water body; (4) environmental toxicity; and (5) a chemical's persistence and mobility in soil. Tier 1 chemicals are of highest concern, Tier 2 are of moderate concern, and Tier 3 are of lowest concern. To be identified as a Tier 1 chemical, a product needs to be identified as high risk with regard to only one of the five criteria above. A primary focus of the City s IPM program is to identify and reduce the use of a subset of Tier 1 pesticides that exhibit ecotoxicity. Ecotoxicity, for this report, is defined as toxicity to birds, fish, bees, and aquatic indicator species, and potential secondary or non-target poisoning from consumption of rodent baits based on product MSDSs and other resources. This 2008 update summarizes the year s successes and challenges, reports on the City s 2008 pesticide use data, discusses program accomplishments and progress on the 2007 report recommendations, and makes new program improvement recommendations highlights include the following which are discussed in depth further in this report: 1 See Appendix I: Evaluation and Rating of Pesticide Toxicity Risk

150 The City s total pesticide active ingredient use, Tier 1 active ingredient use, and use of ecotoxic products decreased significantly. The primary drivers for these decreases were the golf course s overall reduction in fungicide use and its continuing use of two new Tier 2 fungicides first piloted in Staff held an excellent gopher and ground squirrel IPM training in December of 2008 which emphasized the advantages of trapping over pesticide use. This may result in increased trapping and less rodenticide use in The City s contractor, Pestec, identified a method of rerouting bees that are entering and exiting their hives away from people when human/bee interface is likely. The device protects bees and humans when a potential for interaction is likely. Summary of 2008 Program Achievements and Pesticide Use Changes Decreased Total Use, Decreased Tier 1 Use, Decreased Ecotoxic Pesticide Use In 2008, the City decreased the total amount of active ingredient it applied by 153 pounds (36%) and decreased Tier 1 pesticide use by approximately 150 pounds (48%) from the previous year due primarily to less use of the fungicides mancozeb and thiophanate-methyl. In addition, the City used 35 pounds (41%) less ecotoxic pesticides through the reduced use of thiophanate-methyl; ecotoxic pesticide use was the lowest observed since Increased Tier 2 fungicide use in place of Tier 1 fungicide use In 2008, the City targeted the reduction of fungicide use which has historically contributed much of the Tier 1 and ecotoxic pesticides used by the City. The City of Palo Alto provided an evaluation of the least toxic fungicide options for use at the golf course which identified Medallion (fludioxonil) and ProStar (flutolanil) as being two viable alternatives. These products were tested by the Golf Course in 2007 and worked very well. As a result these products have been rotated into the menu of product options for ongoing use at the golf course. The golf course was able to operate its fungus control program in 2008 without any use of ecotoxic fungicides. Explored perimeter trapping for gophers and ground squirrels A well-received training program was held focusing on control of gophers and ground squirrels through perimeter trapping, which targets the corridors that gophers and ground squirrels travel from to minimize population expansion. Five agencies were represented and approximately 25 Palo Alto staff attended. Perimeter trapping may prove to reduce the need for rodenticides and will be reported on in the 2009 report. 2

151 Bee Tunnels piloted To protect bees and humans from each other when bee hives are formed in areas where humans are more likely to come into contact with them, the City s contractor, Pestec, developed a method of directing bees that are entering and exiting their hives away from people. A PVC pipe is mounted over the hive (often located in a tree trunk) using mesh and plaster-of-paris to cover the hive opening. The pipe runs up the length of tree above where people are likely to disturb the hive. This effort will be monitored and refined as necessary. RWQCP staff will distribute a public education piece they developed about the importance of protecting bees and the use of bee tunnels as necessary. Staff will also share this method with other agencies and the public in order to encourage bee protection Pesticide Use Information 1. Total Active Ingredient Use Trends Total active ingredient use decreased by 153 pounds (36%) in 2008 due primarily to decreased fungicide applications of mancozeb and thiophanate-methyl. Smaller reductions in use of the herbicides imazypyr and oryzalin also contributed to the decrease. Figure 1: Total Pesticide Active Ingredient Use by Year ( ) Amount of Active Ingredient (lbs) Year 2. Tier 1-3 Pesticide Use The City s use of Tier 1, 2, and 3 pesticides for calendar years 2001 through 2008 is displayed in Figure 2. Figures 3 through 6 provide annual pesticide use, by tier, for controlling fungus, rodents, weeds, and insects, respectively. Tier 1 Pesticide Use In 2008, the City s total Tier 1 pesticide use decreased by 150 pounds (48%), which is attributed to: A 117 pound decrease in mancozeb (fungicide) A 31 pound decrease in thiophanate-methyl (fungicide) A combined total decrease of 12 pounds of imazapyr and oryzalin (herbicides). 3

152 Note that other individual Tier 1 product use increased. This accounts for the difference between the total of the individual product reductions listed above and the total Tier 1 reduction. Of the total amount of Tier 1 active ingredient that was used, fifty-five percent was applied at the golf course to control fungus. The remainder was applied at the golf course and open space for ground squirrel and gopher control and at various City locations for weeds, grubs, and root control in sewers. The dramatic reduction in golf course fungicide use is attributed to several factors: a cold, dry 2008 winter; a successful fall aeration; and increased cultural practices including de-thatching, topdressing, hand watering, and reel sharpening. Figure 2: Tier 1, 2, and 3 Pesticide Use by Year ( ) Tier 1 Tier 2 Tier 3 Active Ingredient (lbs) Year Tier 2 Pesticide Use Tier 2 pesticide use remained about the same in 2008 as compared to The Tier 2 fungicides Medallion (fludioxonil) and ProStar (flutolanil), and Roundup herbicide (glyphosate) comprised 98% of the Tier 2 pesticides used in The use of Roundup herbicide has decreased about 75% from the peak level of 2003 due to heavy mulching and mechanical weed removal. This reduction in Roundup use was accompanied by decreased Tier 1 herbicide use. Tier 3 Pesticide and non-chemical controls Tier 3 products, the least toxic category, remained at about the same levels as previous years. Nontoxic pest control measures, such as exclusion and non-chemical control measures, are difficult to quantify although their use has increased over time. Examples include increased trapping for gophers, the use of goats to consume weeds, and structural repairs that reduce ant and rodent infestations. Chemical controls may have been used if these non-chemical strategies were not used. It should be noted that higher Tier 3 pesticide use in some previous years was primarily due to the use of a glyphosate herbicide product that was reclassified to Tier 2 in

153 Toxicity of Pesticides Used for Key Pests A majority of the Tier 1 pesticides are used for controlling fungi, rodents and insects. Most Tier 2 pesticides are for weed control. Most Tier 3 products are for insect or weed control Figure 3: Summary of pesticides used to control fungus Tier 2 Tier Tier 2 Tier 1 Figure 4: Summary of pesticides used to control rodents Active Ingredient (lbs) Active Ingredient (lbs) Year Year 400 Figure 5: Summary of pesticides used to control weeds Tier 3 50 Figure 6: Summary of pesticides used to control insects Tier Tier 2 Tier Tier 2 Tier Active ingredient (lbs) Active Ingredient (lbs) Year Year

154 Top five active ingredients used by weight Figure 7 presents the five most-used pesticide active ingredients by weight for Mancozeb, imazapyr, and aluminum phosphide are Tier 1 pesticides. Flutolanil and glyphosate are Tier 2 pesticides. Figure 7: Top 5 Active Ingredients by Weight All Others 18% Mancozeb (Fungicide) 25% Imazapyr (Herbicide) 7% Flutolanil (Fungicide) 12% Aluminum Phosphide (gopher, rodenticide) 17% Glyphosate (Herbicide) 25% Figure 8: History of use for 2008 Top 5 Active Ingredients Total Active Ingredient (lbs) Mancozeb (Fungicide) Glyphosate (Herbicide) Aluminum Phosphide (gopher, rodenticide) Flutolanil (Fungicide) Imazapyr (Herbicide)

155 Table 1: Change in Top 5 Active ingredients Active Ingredient Trade Name Tier Amount Changed (lbs) Percent Changed Where Used Mancozeb (fungicide) Mancozeb DG % Golf Imazapyr (herbicide) Habitat % Open Space, Baylands Glyphosate (herbicide) Roundup % Aluminum Phosphide Fumitoxin (gopher, (tablets or rodenticide) pellets) % Flutolanil (fungicide) Parks, Golf Operations-Trees, Open Space, Foothills Golf, Open Space- Foothills Prostar 70 WP % Golf Ecotoxic Pesticide Use in 2008 The primary driver of the City s IPM policy and plan is the avoidance of ecotoxicity in water bodies from pesticide use. Ecotoxicity, for this report, is defined as toxicity to birds, fish, bees, and aquatic indicator species, and potential secondary or non-target poisoning from consumption of rodent baits based on product MSDSs and other resources. Ecotoxic pesticides are a subset of Tier 1 pesticides as described previously in this report. A product s potential ecotoxicity does not necessarily mean an immediate threat to the environment; how, where, and when the pesticide is applied and the product s breakdown time are all factors in its ultimate environmental impact. Factors to consider: Some product formulations use procedures that restrict product entry into the environment, such as containerized ant baits and dusts (applied in wall cracks and crevices). Conversely, even small amounts of some pesticides such as non-containerized pyrethroids (e.g., bifenthrin, cyfluthrin, delta-methrin) usually associated with sprayed ant pesticides, should be targeted because of their persistent toxicity in urban creek and Bay sediments when rain or irrigation washes them from surface areas into waterways. Pesticides not identified by the EPA as known ecotoxins are not free of risk. Proprietary inert ingredients and synergistic effects of multiple pollutants may still impact water quality and for that reason, large amounts of use of any single product are warranted for potential reduction. 7

156 Figure 9: Total Active Ingredient, Tier 1 and Ecotoxic Pesticide Use ( ) Active Ingredient (lbs) Total Pesticides Applied Tier 1 Pesticides Ecotoxic Pesticides Year Ecotoxic pesticide use trends In the first three years of Palo Alto s IPM program, use of ecotoxic and other Tier 1 active ingredients decreased. This accompanied an increase of total active ingredient use City-wide due to increased use of less toxic Tier 2 products. Factors contributing to the reported decrease included an active effort by staff to use non-chemical and less toxic chemical methods, a suspended use of some products while the goals of the City s IPM program were clarified by City staff, and the extent of information captured. In 2004 and 2005, ecotoxic pesticide use increased dramatically, more than doubling the level of approximately 100 pounds of ecotoxic active ingredient first quantified in The increase was attributed to increased golf course fungicide use in response to weather conditions. Ecotoxic pesticide use decreased in 2006 and 2007 due to golf course efforts to decrease the ecotoxicity of fungicides used, in particular use of PCNB and thiophanate-methyl. As shown in Figure 9, a total of 49 pounds of ecotoxic pesticide was applied in 2008, down from 83 pounds in 2007 and 162 pounds in A discontinuance of ecotoxic fungicide use at the golf course was partially offset by a slight increase in ecotoxic rodenticide use from gopher control at Foothills Park. Ecotoxic fungicide use phased out The two Tier 2 fungicide alternatives, fludioxonil (Medallion) and flutolanil (Pro Star), that were identified and funded for golf course pilot use by RWQCP in 2007 comprised 29% of the 2008 fungicide use a significant positive change in that it offsets Tier 1, ecotoxic fungicide use. These efforts to minimize the toxicity of fungicides, coupled with favorable weather conditions, made 2008 the first year since the City s pesticide reporting program began in which no ecotoxic fungicides were used at the golf course. Previous years included significant use of the ecotoxic fungicide active ingredients PCNB and thiophanate-methyl. To avoid fungi resistance, Medallion and Pro Star cannot be used exclusively, but must be components of a rotating suite of product options to combat turf fungi. These products are significantly more expensive than some of the other fungicide options. The effectiveness of these products prompted golf course staff to request and subsequently receive a $10,000 increase in budget to 8

157 fund continued use of these two products. Rodenticides replace fungicides as the largest contributors to ecotoxic pesticide use, but successful strides have been made to increase non-pesticide control measures. Rodenticides are used at the golf course, Foothills Park and several smaller park locations for gopher and ground squirrel control where the topography is ideal habitat for these animals. Rodenticides for rats and mice are essentially no longer in use because of structural repairs that Facilities Division has made, and because the City s structural pest control provider does not use bait for mice or rats. Golf course staff has steadily increased and plans to further expand trapping, which reduces the need for chemical control measures. Open Space and Parks staff also plan to expand trapping in These efforts cannot be easily captured numerically, but should be acknowledged because pesticide applications would likely be greater without them. Table 2: Locations of Ecotoxic Pesticide Use in 2008 and Potential for Reduction Division Golf Golf Open Space and Parks Operations- Trees Percent of the total ecotoxic pesticides used City-wide and related target pests 44% Rodents 9% Weed 30% Rodents 17% Insects (aphids) Moderate. Opportunity for Reduced Use Action. Staff will be experimenting with perimeter trapping in 2009 to reduce rodenticides. Low. Action. Weeds are difficult to control because of high standards for golf course playability and turf stress. Moderate. Action: Open Space will be experimenting with perimeter trapping in 2009 with the goal of reducing rodenticide use and more effective rodent control. Moderate. Action: Staff is experimenting with power washing and already incorporates many IPM measures into tree pest management. 9

158 Table 3: Progress on 2008 Recommendations for City of Palo Alto IPM Program Recommendation 1) Seek opportunities to minimize Tier 1 pesticide use, large amounts of Tier 2 pesticides and expand nonchemical pest control measures prioritizing those that will reduce ecotoxicity: a) Continue supporting golf course in identifying options and best practices for turf fungi and rodent control management b) Provide training on weed, gopher, and ground squirrel control. c) Explore designating certain City properties, such as a park or play area, to be pesticide free d) Track City s audit of golf services to ensure that IPM specifications are included if management of the golf course is contracted out in lieu of that service being performed by staff. e) If the golf course continues to be maintained by City staff, revisit placing golf course green reconstruction on CIP funding schedule to rebuild older golf course greens which foster conditions for turf fungus. f) Provide mini-grants for divisions who need technical or financial assistance to pilot and implement IPM projects. g) Continue to monitor and refine EcoWise Certified pest control service. 2) Continue supporting regional efforts to expand EcoWise Certified contractor use into public agencies and to the residential community: a) Encourage partner agencies to hire EcoWise Certified (or similar) contractors b) Advertise EcoWise Certified program in RWQCP service area Status a) On-going. b) Held gopher and ground squirrel training in December c) Not pursued due to other project priorities. d) On-going. Golf services is keeping RWQCP apprised of the potential to contract out golf services. e) This will be monitored. f) The gopher and ground squirrel workshop was funded by RWQCP and extended to RWQCP partners and other agency staff. g) Staff oversees the contract for the EcoWise Certified pest control company that provides structural pest control service to the City. a) This is somewhat challenging given the dearth of EcoWise Certified companies at this time. The company that Mountain View uses incorporates IPM techniques, but has not sought certification. 3) Address regional issues related to red-legged frog and local pesticide use. Using EPA data identify and execute actions needed to be in compliance with EPA s order to restrict certain pesticides from being used in red-legged frog habitat. b) On-going. Reviewed. The City of Palo Alto and the immediate surrounding areas are not listed as a critical habitat by the California Department of Fish and Wildlife Service. However, there are areas of non-critical habitat that were identified. Staff will investigate if pesticides are applied in these specific areas and if so identify any actions needed to protect these sites. 10

159 Highlights of IPM Implementation Progress Accurately assessing the success of the City s efforts to reduce pesticide use and use least toxic products is difficult when relying solely on yearly numerical fluctuations in pesticide use. Variations in weather patterns, natural pest population cycles, and challenges associated with quantifying pest control efforts that use biological or mechanical controls in lieu of pesticides are all important considerations. The following are accomplishments of the City s IPM efforts that cannot be measured quantitatively IPM policy is the first City Policy in the County to be adopted. The IPM Committee drafts the IPM Plan and Procedures. A tiered system for analyzing City pesticide use is adopted and the first annual report on the City s pesticide use is completed. IPM Committee votes to discontinue use of organophosphate pesticides due to water quality concerns associated with their use. Solarizing non-native plants at Pearson- Arastradero Preserve (weeds are covered in plastic tarps and destroyed by heat). Mechanical removal of weeds in Open Space Ponds Bermuda grass replaces bent grass at bowling green to reduce need for pesticides. A visual barrier installed at the golf course decreased ground squirrel damage by 100%. City begins mulching in lieu of glyphosate use to control weeds (both pre and post emergent). Mulching becomes a significant contributor to the reduction of herbicide use in the City. Herbicide spraying discontinued at schools due to Healthy Schools Act Completed five extensive IPM plans and related training for ants, weeds, yellowjackets gophers and ground squirrels. Identified all leased facilities and contractors for inclusion in the City s annual pesticide reports. GIS view of pesticide application next to Adobe creek 2003 City receives Department of Pesticide Regulation IPM Innovator award /03awards.htm Piloted new methods to reduce yellow jackets in Parks and Open Space. Piloted gopher reduction strategies at 11

160 Foothills Park using trapping as a primary method. In partnership with Santa Clara County Airport and Baylands and golf course Staff implemented two new measures to reduce ground squirrel populations a. The installation of a visual barrier hung along the golf course/airport fence line to decrease the ground squirrels ability to see predators and thus reduce activity. b. a trap design around Baylands buildings that can capture up to four ground squirrels at a time Created pesticide data entry system using a centralized database and simplified reporting interface. This streamlines staff reporting time and allows staff to also print mandatory monthly DPR reports. Transferred pesticide use information in database to GIS format allowing for visual assessment of pesticide applications next to creeks and the Bay. Use of goats in Open Space areas to control weeds proves successful (reintroduction of goats to this area is on hold due to mountain lion concerns in that area). Goats are used to reduce weeds at Enid Pearson Arastradero Open Space Preserve Scope of Services for City wide IPM contract drafted. RFP to go out in Less toxic, botanically-based insecticides ordered for Facility staff use and related Approved Pesticide List for Facilities and staff at the Regional Water Quality Control Plant who are responsible for their own pest control Confirmed pesticide reduction hierarchy A bee tunnel is installed over a bee hive in a public parking lot Hired EcoWise Certified structural pest control company to service all City facilities (Pestec) Identified less toxic fungicide alternatives Provided mini grants (<$5,000) to golf course and Art Center for structural pest control. Improved the City s database system Implemented EcoWise Certified contractor service into City operations and consolidated related billing and service levels. Completed 50% of recommended building repairs to reduce overall conditions that encourage pest activity. Dr. Gilbert Proulx provides information on gopher biology and trapping. 12