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HomeMy WebLinkAbout2021-04-30; Carlsbad Water Recycling Facility Permit District 3); Gomez, PazTo the members of the: CITY COUNCIL Dat~~oji1 CA ✓ cc ✓ CM_ ACM ___0cM (3) ~-. April 30, 2021 CMWD Board Memorandum To: Carlsbad Municipal Water District Board of Directors From: Paz Gomez, Deputy City Manager, Public Works Vicki Quiram, General Manager ~ Via: Scott Chadwick, Executive Manager ~. Re: Carlsbad Water Recycling Facility Permit (District 3) Ccarlsbad Municipal Water District Memo ID# 2021092 This memorandum provides information regarding potential required permit coverage for the Carlsbad Water Recycling Facility (CWRF) under the National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Industrial Activities. Background During a recent inspection of the CWRF for compliance with the facility's Master Recycling Permit and Waste Discharge Requirements, the Regional Water Quality Control Board (Regional Board) requested several verification documents. These inspections are conducted every two years, and Encina Wastewater Authority (EWA) staff coordinate the onsite inspections. EWA staff sent the requested documents to the Regional Board on April 26, 2021, including the 2008 Storm Water Pollution Prevention Plan (SWPPP), Spill Prevention Plan, Spill Response Plan and the current chemical storage list. Discussion Subsequent to the onsite inspection, CMWD staff became aware that the CWRF stormwater discharges may be covered by the NPDES General Permit for Storm Water Discharges Associated with Industrial Activities, commonly referred to as the Industrial General Permit or IGP. "Sewage or wastewater treatment works" is one of the classifications of facilities covered by the IGP. Attachment A contains the list of covered facilities that includes: 9. Sewage or Wastewater Treatment Works ... "Facilities used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge, that are located within the confines of the facility, with a design flow of one million gallons per day or more, or required to have an approved pretreatment program under 40 Code of Federal Regulations part 403." While the facility does produce recycled water, the primary and secondary treatment of the domestic sewage takes place at the adjacent Encina Water ·Pollution Control Facility, which does have IGP coverage. Staff sent a letter to the Regional Board requesting clarification on whether coverage under the IGP is required for the CWRF (Attachment B). Carlsbad Municipal Water District 5950 El Camino Real I Carlsbad, CA 92008 I 760-438-2722 t Board Memo -Carlsbad Water Recycling Facility Permit (District 3) April 30, 2021 Page 2 The CWRF is included in the city's Environmental Management Department's existing development inventory under the city's municipal stormwater permit, and a third-party contractor regularly inspects the CWRF for stormwater permit compliance. The site does have a SWPPP and implements best management practices onsite consistently. The facility has not received any violations for at least the last five years and has minimal to no risk of stormwater pollution. All industrial processes are covered and contained. If CMWD does need to apply for coverage under the IGP, which appears to be likely, CMWD may qualify for certifications that are less cumbersome. In addition to sending the request for clarification letter to the Regional Board, CMWD staff are coordinating with the city's Environmental Management Department, who are required to report CMWD to the Regional Board as a potential non-filer under the NPDES Permit by May 3, 2021. Whether full coverage under the IGP or potential reduced coverage via a No-Exposure Certification is required, staff will prepare the required documentation and submit it for permit coverage. Next Steps Staff will provide an update to the CMWD Board of Directors after the Regional Board provides clarification. There could be additional permitting costs, which are expected to be minimal, and fines, which would need to be negotiated with the Regional Board. It is too early in the process to estimate what the fines would be, if any. The CWRF has not had any illegal storm drain discharges from their facility but may not have applied for coverage on the proper stormwater permit years ago. Staff is still researching the issue and will update the CMWD Board of Directors when more information is known. Attachments: A. Attachment A of the IGP B. CMWD letter dated April 29, 2021 cc: Scott Chadwick, Executive Manager Celia Brewer, General Counsel Laura Rocha, Deputy City Manager, Administrative Services · Robby Contreras, Assistant General Counsel James Wood, Environmental Manager Dave Padilla, District Engineer Tim Murphy, Senior Program Manager Keri Martinez, Senior Engineer 1. 2. 3. 4. ATTACHMENT A ATTACHMENT A FACILITIES COVERED BY NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) GENERAL PERMIT FOR STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITIES (GENERAL PERMIT) Facilities Subject To Storm Water Effluent Limitations Guidelines, New Source Performance Standards, or · Toxic Pollutant Effluent Standards Found in 40 Code of Federal Regulations, Chapter I, Subchapter N (Subchapter N): Cement Manufacturing (40 C.F.R. Part411); Feedlots (40 C.F.R. Part 412); Fertilizer Manufacturing (40 C.F.R. Part 418); Petroleum Refining (40 C.F .R. Part 419), Phosphate Manufacturing (40 C.F.R. Part 422), Steam Electric (40 C.F.R. Part 423), Coal Mining (40 C.F.R. Part 434), Mineral Mining and Processing (40 C.F.R. Part 436), Ore Mining and Dressing (40 C.F.R. Part 440), Asphalt Emulsion (40 C.F.R. Part 443), Landfills (40 C.F.R. Part 445), and Airport Deicing (40 C.F.R. Part 449). Manufacturing Facilities: Facilities with Standard Industrial Classifications (SICs) 20XX through 39XX, 4221 through 4225. (This category combines categories 2 and 10 of the previous general permit.) Oil and Gas/Mining Facilities: Facilities classified as SICs 1 0XX through 14XX, including active or inactive mining operations (except for areas of coal mining operations no longer meeting the definition of a reclamation area under 40 Code of Federal Regulations. 434.11 (1) because the performance bond issued to the facility by the appropriate Surface Mining Control and Reclamation Acts authority has been released, or except for areas of non-coal mining operations which have been released from applicable State or Federal reclamation requirements after December 17, 1990) and oil and gas exploration, production, processing, or treatment operations, or transmission facilities that discharge storm water contaminated by contact with or that has come into contact with any overburden, raw material, intermediate products, finished products, by-products, or waste products located on the site of such operations. Inactive mining operations are mining sites that are not being actively mined, but which have an identifiable owner/operator. Inactive mining sites do not include sites where mining claims are being maintained prior to disturbances associated with the extraction, beneficiation, or processing of mined material; or sites where minimal activities are undertaken for the sole purpose of maintaining a mining claim. Hazardous Waste Treatment, Storage, or Disposal Facilities: Hazardous waste treatment, storage, or disposal facilities, including any facility operating under interim Order 2014-0057-DWQ 1 status or a general permit under Subtitle C of the Federal Resource, Conservation, and Recovery Act. 5. Landfills, Land Application Sites, and Open Dumps: Landfills, land application sites, and open dumps that receive or have received industrial waste from any facility within any other category of this Attachment; including facilities subject to regulation under Subtitle D of the Federal Resource, Conservation, and Recovery Act, and facilities that have accepted wastes from construction activities ( construction activities include any clearing, grading, or excavation that results in disturbance). 6. Recycling Facilities: Facilities involved in the recycling of materials, including metal scrapyards, battery reclaimers, salvage yards, and automobile junkyards, including but limited to those classified as Standard Industrial Classification 5015 and 5093. 7. Steam Electric Power Generating Facilities: Any facility that generates steam for electric power through the combustion of coal, oil, wood, etc. 8. Transportation Facilities: Faciliti,es with SICs 40XX through 45XX (except 4221- 25) and 5171 with vehicle maintenance shops, equipment cleaning operations, or airport deicing operations. Only those portions of the facility involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication) or other operations identified under this Permit as associated with industrial activity. 9. Sewage or Wastewater Treatment Works: Facilities used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge, that are located within the confines of the facility, with a design flow of one million gallons per day or more, or required to have an approved pretreatment program under 40 Code of Federal Regulations part 403. Not included are farm lands, domestic gardens, or lands used for sludge management where sludge is beneficially reused and are not physically located in the confines of the facility, or areas that are in compliance with Section 405 of the Clean Water Act. April 29, 2021 San Diego Regional Water Quality Control Board ATTACHMENT B ~· (_carlsbad Municipal Water District Mr. Tony Felix, WRC Engineer via email to tony.felix@waterboards.ca.gov Ms. Laurie Walsh, PE, Senior Engineer via email to laurie.wa lsh@waterboards.ca.gov 2375 Northside Drive, Suite 100 San Diego, CA 92008 Re: Request for Clarification on NPDES General Permit for Storm Water Discharges Associated with Industrial General Permit (IGP) Activities for a Carlsbad Municipal Water District (CMWD) facility Dear Mr. Felix and Ms. Walsh, CMWD staff were recently made aware that the Carlsbad Water Recycling Facility (CWRF) may be subject to the IGP. While we are still evaluating the specifics, staff wanted to reach out and get your input. The CWRF takes secondary effluent from the adjacent Encina Water Pollution Control Facility (EWPCF) and incorporates water treatment technologies to produce recycled water meeting Title 22 of the California Administrative Code for "unrestricted non-potable reuse." See the attached CWRF Synopsis for more detailed information (Attachment A). Attachment A of the IGP, 9. Sewage or Wastewater Treatment Works, states that "Facilities used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge, that are located within the confines of the facility, with a design flow of one million gallons per day or more, are required to have an approved pretreatment program under 40 Code of Federal Regulations part 403." This facility does produce recycled water, but the primary and secondary treatment of the domestic sewage takes place at the adjacent EWPCF which has IGP coverage. Based on our review, CMWD is seeking clarification on whether the IGP is applicable to the CWRF and can provide additional detail as requested. Associated Permits The CWRF has coverage under Order No. R9-2016-0183 Master Recycling Permit for CMWD, CWRF, San Diego County and under Order No .. R9-2018-0059 Waste Discharge Requirements for the Encina Wastewater Authority EWPCF and Satellite Wastewater Treatment Plants ··-. Carlsbad Municipal Water District 5950 El Camino Real I Carlsbad, CA 92008 I 760-438-2722 I 760-431°1601 fax I www.carlsbadca.gov Discharge to the Pacific Ocean through the Encina Ocean Outfall. Regional Board staff conducts regular compliance evaluation inspections at this site, under these permits, and fn concert with EWPCF and has not been found in violation. The CWRF is also included on the Existing Development Inventory for the City of Carlsbad required under Order No. R9-2013-0001, as amended by Order No. R9-2015-0001 and Order No. R9-2015-0100 and is regularly inspected under that program. The facility has a Storm Water Pollution Prevention Plan (SWPPP) and implements best management practice in its daily operations. The facility has not received any violations for at least the last five years. CMWD is committed to compliance with all applicable permits, laws, and regulations and will move quickly to obtain proper coverage if it is determined necessary. You may contact me at 760-443-8879 or by email at vicki.quiram@carlsbadca.gov. Sincerely, t;;:_h-rl ti lu,'1_:~ Vicki Quiram General Manager. Attachment: A. CWRF Synopsis cc: Geoff Patnoe, Assistant Executive Manager Paz Gomez, Deputy City Manager, Public Works Robby Contreras, Assistant General Counsel Dave Padilla, District Engineer Keri Martinez, Senior Engineer, Utilities Shoshana Aguilar, Senior Management Analyst ATTACHMENT A BACKGROUND The Carlsbad Water Recycling Facility (CWRF) is owned by the Carlsbad Municipal Water District (CMWD) and operated and maintained by Encina Wastewater Authority (EWA). Located in Carlsbad, CA, the CWRF treats secondary effluent from the adjacent Encina Water Pollution Control Facility to produce up to 7.0 MGD of Title 22 recycled water. The CWRF was constructed in 2005 as part of Phase II of a comprehensive regional program to provide Carlsbad and surrounding areas with a reliable, drought-proof recycled water supply. Phase Ill Recycled Water Project included an expansion of the CWRF to 7.0 MGD capacity. the goals of the CWRF expansion were to increase filtration reliability, enhance operational flexibility, and improve stored recycled water quality. The CWRF expansion included the addition of three pressurized ultrafiltration_ (UF) skids to produce 3.4 MGD of additional filtrate flow. The UF system includes feed pumps, feed tank, booster pumps, strainers, UF membrane skids, backwash pumps, CIP tank and pumps, air compressors, blowers, and chemical transfer pumps. The startup and testing period of the new equipment began in June 2016 and the expanded facility started producing Title 22 water in September 2016. The expansion project was completed in November 2016. Performance Demonstration testing of the UF system was completed on June 17, 2017. CARLSBAD WATER RECYCLING FACILITY CWRF is a 7 million gallon per day (MGD) water reclamation facility. CWRF is located adjacent to the Encina Water Pollution Control Facility (EWPCF). The CWRF takes secondary effluent from the EWPCF and incorporates water treatment technologies to produce recycled water meeting Title 22 of the California Administrative Code for "unrestricted non-potable reuse." The CWRF takes secondary effluent from the EWPCF and treats the flow through two parallel advanced treatment processes. One treatment process utilizes granular media filtration (GMF) and the other uses ultrafiltration (UF).The product water from the two processes is blended and disinfected, using sodium hypochlorite, in the chlorine contact tank (CCT) prior to recycled water storage and distribution. The CWRF was designed to meet Title 22 requirements of the California Administrative Code for unrestricted non-potable reuse . Key Title 22 conformance features include: • Filtration -The CWRF design features two parallel processes: a granular media process and an ultrafiltration process. The processes are designed in accordance with Title 22 Section 60301.320. • Disinfection -The CWRF design features a chlorine disinfection process in accordance with Title 22 Section 60301.230. Sodium hypochlorite is diffused and mixed into the treatment processes blended effluent prior to entering the chlorine contact tanks where a 90-minute minimum modal contact time and a minimum CT of 450 mg-min/Lis provided to meet the Title 22 effluent total coliform requirement of 2.2 colonies/ 100 ml. • Reliability Requirements -Title 22 reliability is met through the "alternative discharge point" requirement. When a treatment process is placed out of service, pumping to the CWRF from the effluent pump station ceases and production flow is diverted back to EWPCF. As such, no standby basins, standby equipment, or emergency power is provided. .In the event the CWRF final effluent total coliform or turbidity requirements are not met, the noncom pliant effluent is diverted back to EWPCF. Alarm conditions, as described in Title 22 Section 60335, are included in the CWRF control system to the extent that they are applicable. CWRF is permitted to produce up to a daily average of 7 MGD, the difference in influent and product water flow is comprised of backwash/reject flows from the GMF and UF processes. These flows are returned to the EWPCF secondary treatment systems. GRANULAR MEDIA FILTRATION GMF is a continuous backwash, up-flow type of media filter manufactured by Andritz. The GMF process is comprised of an influent feed channel, two filter cells of six filter modules each, and backwash equipment. Flow ent~rs the filtration influent feed channel on the north end of the filter complex. Flow into each filter cell is through an isolation valve and pipeline that feeds each of the six modules. The inlet isolation valve allows shutdown of a filter cell for maintenance or repair. The granular media filters are designed to backwash continually with flow entering the bottom of the filter module and moving upwards through the descending media. An airlift located at the center of the module continuously lifts solids and filter media to a solids-separator box located near the filter surface. Solids are collected in the solids-separator box and flow by gravity to the EWPCF secondary treatment process. Thedeaned media moves to the top of the filter media, where it begins filtering while moving downward once again. A ded.icated air compressor and air receiver supply air for the airlifts. The GMF is designed to produce up to 3.7 MGD and a 2 NTU effluent with an influent turbidity of 6 NTU. ULTRAFILTRATION UF utilizes three parallel trains of Toray HFU-2020N modules to treat a portion of the secondary effluent from the EWPCF. Secondary effluent is pumped to a UF feed tank, which provides operational storage for the UF booster pumps. Prior to entering the UF feed tank, the secondary effluent is pretreated to achieve the following: • Chlorination to satisfy the chlorine demand of the EWPCF secondary effluent and provide a residual to inhibit biological fouling of the membranes • Prescreening and removal of large particles (greater than 300 microns). UF prescreening is designed to treat a flow up to 3. 76 MGD while removing particles greater than 300 microns. The UF process can produce 3.38 MGD of UF effluent. The difference between UF influent and effluent (product water) is due to filter designed reject rate of 10% and filter backwashing with product water. The UF System consists of 216 modules arranged in three trains with 72 modules per train. Each module contains 9,000 fibers with a nominal pore size of 0.01 microns. UF exerts a large energy demand on CWRF. As a means of reducing energy expenses at CWRF, and to provide CMWD with good financial stewardship, EWA has adopted an operating strategy of operating the UF process outside of the San Diego Gas & Electric Company's peak energy periods when utility electrical costs are at their highest. The UF process is not operated between the hours of 4pm -9pm each day unless production demands require it. The UF is used as a secondary process method of water production, with the primary process of the water produced at CWRF originating from the lower operating cost of the GMF system. Under this mode of operation, the UF process operating frequency and duration vary based on CMWD's water demand.