The New NPDES Permit for the Sacramento Regional Wastewater Treatment Plant. Presentation to SCAP October 27, 2011

Transcription

1 The New NPDES Permit for the Sacramento Regional Wastewater Treatment Plant Presentation to SCAP October 27, 2011

2 Presentation Overview SRCSD Background NPDES Permit Renewal Leading Up to the Permit Hearing Permit Outcomes and Costs Actions in Progress Permit Issues with Statewide Ramifications Basis for Filtration Requirements? Concluding Thoughts

3 Who is SRCSD? SRCSD provides wastewater conveyance and treatment services Wastewater treatment service began in 1982 SRCSD serve area: Cities of Elk Grove, Citrus Heights, Folsom, Rancho Cordova, Sacramento, West Sacramento; Unincorporated Sacramento County; Delta communities of Walnut Grove and Courtland

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5 Sacramento Regional Wastewater Treatment Plant (SRWTP) Serves about 1.3 million residents Pure oxygen activated sludge with chlorine disinfection Permitted Capacity: MGD (ADWF)

6 SRWTP Photos Process Areas

7 SRWTP Activities Environmental Lab & River Monitoring Treatment Plant and Pumping Systems Control Center

8 SRWTP Discharge Discharges to Sacramento River Wet weather flows over 300 MGD Current discharge - approx 140 MGD Diffuser location Approximately 400 feet south of Freeport Bridge, south Sacramento County

9 SRWTP Diffuser River Bed Elevation 85. River Flow Manhole From Backflow Control Structure Thrust Block 120 Outfall Line 6 Sediment Blow-off Open Port Nozzles

10 Distance from West Bank (ft) Depth (ft) Most studied outfall in CA, probably US SACRAMENTO RIVER DOWNSTREAM OF FREEPORT BRIDGE TEMPERATURE EFFECTS - 50:1 FLOW RATIO (ROUGH BOTTOM) East River Bank Downstream (ft) Temperature above River Ambient (degrees F) DIFFUSER FLOWRATE = 181 MGD RIVER FLOWRATE = 14,000 CFS

11 Depth (ft) Depth (ft) West Bank West Bank Most studied outfall in CA, probably US SACRAMENTO RIVER DOWNSTREAM OF FREEPORT BRIDGE TEMPERATURE EFFECTS - 50:1 FLOW RATIO (ROUGH BOTTOM) Cross-Section 30 ft Downstream of Diffuser Cross-Section 60 ft Downstream of Diffuser Temperature above River Ambient (degrees F) DIFFUSER FLOWRATE = 181 MGD RIVER FLOWRATE = 14,000 CFS

12 Depth (ft) Depth (ft) West Bank West Bank 34 0 Most studied outfall in CA, probably US SACRAMENTO RIVER DOWNSTREAM OF FREEPORT BRIDGE TEMPERATURE EFFECTS - 50:1 FLOW RATIO (ROUGH BOTTOM) Cross-Section 350 ft Downstream of Diffuser Cross-Section 700 ft Downstream of Diffuser Temperature above River Ambient (degrees F) DIFFUSER FLOWRATE = 181 MGD RIVER FLOWRATE = 14,000 CFS

13 Leading Up to the Permit Last permit issued in 2000 ROWD submitted in permit administratively extended RWQCB efforts to reduce NPDES permit renewal backlog RWQCB saved the biggest permit for last.right in the heat of the Delta debate

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16 Permit Outcomes and Costs Hearing conducted in December 2010 Media circus Numerous commenters (both for and against permit) Hearing lasted 11 hours RWQCB Members deliberated approx 11 minutes New advanced treatment processes Estimated $2 Billion project costs Additional $77 Million in annual O&M costs

17 What it Could Take to Comply New Advanced Treatment Processes: Nitrification = $ 582 million Denitrification = $ 200 million Microfiltration = $1,160 million UV Disinfection = $ 116 million

18 Examples of Future Rates/Fees Total Project Costs Annual Operating Cost Monthly Residential Charge for Wastewater Treatment Impact Fees per household (or equivalent) Infill New Current Future Current Future Current Future $2.06 billion $77 million $20.00* $61.50* $ 2,800 $13,000 $7,450 $35,000 This does NOT include a separate monthly charge for local sewer collection services.

19 Is There a Cost/Benefit Analysis to Fix the Delta? Project X $1 Billion 2% Improvement Project Y $500 Million 4% Improvement

20 Actions in Progress Rate increase approved in 2011 $80 million over the next three years Require special studies and pollution prevention plans Pilot studies Design of advanced treatment processes

21 Proposed 3-Year Rate Plan SRCSD Monthly Rate Plan (Per Single Family Dwelling Unit) October 1, 2011 July 1, 2012 July 1, 2013 $22.00* $24.00* $26.00* * This does NOT include a separate monthly charge for local sewer collection services.

22 Actions in Progress Design of Advanced Treatment Process Completed technology screening Initiating pilot studies Selecting program manager

23 Actions in Progress SRCSD and CSPA Appeals Appeals consolidated in March 2011 Ruling was expected in December 2011 SWRCB adopted Order on Sept 19, 2011 Review the permit On Its Own Motion Ruling expected????

24 Major Permit Concerns with Statewide Ramifications

25 Major Permit Concerns with Statewide Ramifications Nutrient limits (ammonia and nitrate) without water quality objectives Misapplied antidegradation and Title 22 policies Application of BPTC analysis Permit s new filtration requirements

26 Nutrient Limits without Water Quality Objectives Permit describes many concerns for nitrogen levels Permit notes nitrogen issues are being vetted Permit lacks any clear statement on what is the right level of nutrients for the health of the Delta Permit jumps to end of pipe limits of 1.8 mg/l for ammonia and 10 mg/l for nitrate Permit denies both acute and human health dilution credits (Average dilution is about 50:1) What is the right amount of nutrients and the form of nitrogen for a healthy Delta?

27 Misapplied Antidegradation Policy Traditionally, antidegradation analysis required for new or expanded discharges Permit has no new point of discharge or any increase in discharge capacity Antidegradation applied because Conditions in the receiving water changed

28 Misapplied Title 22 Policy Title 22 is not directly applicable to surface waters; however, the Central Valley Water Board finds that it is appropriate to apply reclamation criteria because the receiving water is used for irrigation of agricultural land and for contact recreation purposes. The stringent disinfection criteria of Title 22 are appropriate since the partially diluted effluent may be used for the irrigation of food crops and/or for body-contact water recreation. - Fact Sheet page F-73 If a waterway is used for agriculture or contact recreation, those discharging to it must meet Title 22 standards.

29 Application of BPTC Analysis BPTC for this facility includes implementation of nitrification, denitrification, and the equivalent of Title 22 filtration with ultraviolet light, ozone, or chlorine disinfection treatment. - Fact Sheet page F-94 No rigorous analysis under Porter-Cologne and No balancing of socioeconomic impacts and water quality benefits

30 Concerns with Permit s Filtration Requirements

31 Permit s Filtration Requirements What s the Water Quality Objective? Disregarded Use of CDPH Guidelines Ignored Risk Assessment

32 What s the Water Quality Objective? Basin Plan Water Quality Objective Fecal coliform 200MPN/100 ml 30 day GM <10% of the samples over 400MPN/100 ml fecal coliform No finding that total coliform 2.2 MPN/100ml is the water quality objective Total coliform 2.2 MPN/100ml required for food crops or unrestricted recreation SRCSD Analysis No direct impact to agricultural intakes

33 Disregarded Use of CDPH Guidelines RWQCB routinely used CDPH 20:1 dilution ratio guidance in permitting (Wastewater Disinfection for Health Protection, Sanitary Engineering Branch California Department of Health Services, February 1987) 56 Central Valley permits reviewed: 33 facilities with less than 20:1, 2.2 MPN/100 ml required 16 of 18 facilities with greater than 20:1, 23 MPN/100 ml required 2 facilities with greater than 20:1 and 2.2 MPN/100 ml were special cases 5 other facilities, land application WDRs

34 Disregarded Use of CDPH Guidelines RWQCB selectively identified POTWs with considerable more dilution and excluded facilities with much lower dilution where 20:1 guidance was applied Facility Fact Sheet page F-74 Permitted Flow (mgd) Mt. Shasta WWTP, El Dorado ID, Chester Public Utility District, Tehama County Sanitation No. 1,Tuolumne Utilities District, San Andreas District WWTP Average Dilution SRCSD :1 City of Redding Stillwater Plant :1 City of Redding Clear Creek :1 City of Corning WWTP :1 City of Anderson WWTP :1 City of Rio Vista Beach :1 City of Chico WWTP :1 City of Red Bluff WWTP :1 >20:1

35 Ignored Risk Assessment RWQCB requested CDPH input on: SRWTP disinfection process Cryptospordium and giardia levels in the River CDPH concerned with contact recreation No CDPH concerns for raw water intakes RWQCB and CDPH endorsed performing risk assessment SRCSD contracted with Dr. Charles Gerba University of Arizona

36 Ignored Risk Assessment Conservative assumptions: Infection vs. Illness (increases risk by factor of 2) Volume of water ingested (100 ml vs. 6 to 37 ml) Number of recreational events (10 vs. 1 swimming event) Efficiency of analytical method, dilution of effluent, combined risk

37 Ignored Risk Assessment What is the acceptable level of risk? USEPA risk standard - 8 illnesses per 1,000 bathers/swimmers SRCSD Analysis Infection was an order of magnitude below the USEPA acceptable risk level

38 Ignored Risk Assessment CDPH does not consider USEPA criteria to provide adequate protection, because: Human origin of pathogens more hazardous to swimmers Discharge is controllable CDPH questions whether this represents a level of risk that is currently acceptable to public (June 15, 2010 CDPH Letter to RWQCB) Result : CDPH considers 1 infection per 10,000 risk acceptable for contact recreation

39 Ignored Risk Assessment SRCSD re-evaluated Risk Assessment More realistic assumptions used Included the impact of the current disinfection process on giardia inactivation Essentially the only risk of infection is associated with cryptospordium

40 Cryptosporidium Risk of Illness From One Swimming Event (Data from Table 4 of February 2010 Report) Veterans Bridge : 100,000 Freeport Marina : 100,000 Cliff s Marina River Mile : 100,000 Cliff s Marina : 100,000

41 Ignored Risk Assessment 1.00E E-01 Is there actually a problem with recreational use downstream of the SRWTP Outfall? 1.00E-02 USEPA 8:1000 Risk for Contact Recreation 1.00E-03 CDPH 1:10,000 Risk for Contact Recreation 1.00E-04 Same as USEPA Risk for Tap Water 1.00E-05 Freeport (Upstream) 1.04:100,000 Cliff s Marina (Downstream) 1.09:100,000

42 Permit s Filtration Requirements What s the water quality objective? Basin Plan WQO 200 Fecal Coliform MPN/100ml Disregarded, required 2.2 Total Coliform MPN/100ml Ignored Use of CDPH guidelines Historically used CDPH 20:1 dilution ratio guidance Disregarded, required end of pipe effluent limits Ignored risk assessment Set new risk threshold of 1 in 10,000 Disregarded assessment that achieved CDPH risk level Result - Title 22 or Equivalent Disinfection Requirements

43 Concluding Thoughts What are we to tell our ratepayers? SRCSD s position - absence of any discernable environmental benefits, permit requirements unreasonable Watch out!!! This can come to you