HomeMy WebLinkAbout2022-01-20; Carlsbad Water Recycling Facility Industrial Stormwater Permit Update (District 3); Gomez, PazTo the members of the:
CITY COUNCIL
Date 1/zol:z:z.,c:A ✓ cc ~
CM . V ACM .:!.._DCM(3)~ ··
Jan. 20, 2022
CMWD Board Memorandum
To: Carlsbad Municipal er District Board of Directors
From: Paz Gomez, Deputy City r, Public Works
Vicki Quiram, General a
Via: Scott Chadwick, Executi e er
Ccarlsbad
Municipal Water District
Memo ID #2022014
Re: Carlsbad Water Recycling acility Industrial Stormwater Permit Update {District 3)
This memorandum provides an update to the previous CMWD Board Memorandum dated
April 30, 2021, provided as Attachment A, regarding the required permit coverage for the
Carlsbad Water Recycling Facility, or CWRF, under the National Pollutant Discharge Elimination
System, or NPDES, General Permit for Storm Water Discharges Associated with Industrial
Activities, or Industrial General Permit.
Background
The CWRF is included in the City of Carlsbad Environmental Management Department's existing
municipal stormwater permit inventory and is regularly inspected for stormwater compliance.
The CWRF has a Stormwater Pollution Prevention Plan, implements best management practices,
and has not received any violations for at least the last five years.
Following a routine inspection by the San Diego Regional Water Quality Control Board, or
Regional Board, for an existing facility operating permit last year, the Carlsbad Municipal Water
District, or CMWD, was informed that the CWRF may require coverage under the State Industrial
General Permit for stormwater. On April 29, 2021, CMWD sent a letter to the Regional Board
requesting clarification whether the facility should remain in the city's municipal stormwater
inventory or also obtain coverage under the Industrial General Permit.
On April 30, 2021, Environmental Management Department staff sent a required notice
identifying the CMWD as a potential non-filer, provided as Attachment B. CWMD staff received
the Regional Board's response on May 10, 2021, confirming that Industrial General Permit
coverage was required for the CWRF, provided as Attachment C.
Discussion
Subsequently, CMWD staff contracted with the consultant Mikhail Ogawa Engineering to assist
with preparation of the permit application and supporting documents. Following site visits, a
review of facility plans and processes and a meeting with the Regional Board, the Regional Board
recommended that the CMWD pursue a Notice of Non-Applicability, or NONA, instead. This
NONA application requires a comprehensive No Discharg~ Technical Report prepared by a
licensed engineer detailing the site layout, facility enclosures, collection and drainage system,
Carlsbad Municipal Water District
5950 El Camino Real I Carlsbad, CA 92008 I 760-438-2722 t
Board Memo -Carlsbad Water Recycling Facility Industrial Stormwater Permit Update (District 3)
Jan.20,2022
Page 2
drainage patterns, retention volume calculations, operational activities and procedures to justify
no anticipated stormwater discharge or pollution potential. If approved by the Regional Board,
the NONA excludes the CWRF from extensive monthly and quarterly stormwater runoff
monitoring, sampling, testing and reporting requirements. Additionally, this excludes the CWRF
from payment of annual fees to the Regional Board.
As required, the CMWD registered the CWRF on the State Water Resources Control Board's
stormwater tracking database and identified the appropriate site and administrative contacts.
The NONA was officially submitted on Oct. 20, 2021, and a NONA ID was assigned, provided as
Attachment D.
On Dec. 3, 2021, the CWMD received email notification from Regional Board staff stating the
NONA was approved. No violations or fines for prior noncompliance were suggested or imposed
from the Regional Board staff. The CMWD received further notice on Jan. 6, 2022, that no
reporting is required, and the staff email serves as official approval of the NONA, provided as
Attachment E.
Next Steps
Encina Wastewater Authority and CMWD staff will continue to maintain and operate the CWRF
to ensure no industrial stormwater discharges are generated. The CWRF will remain in the city's
municipal stormwater inventory and continue to be inspected annually as part of the city's
Municipal Storm Water Inspection Program.
The site 2008 Stormwater Pollution Prevention Plan is now appended with the October 2021 No
Discharge Technical Report. Regional Board staff have indicated that any future site or
operational modifications that could potentially impact stormwater will need to be evaluated,
and future additional Industrial General Permit coverage may be required if changes warrant it.
Attachments: A. CMWD Board Memorandum dated April 30, 2021
B. City of Carlsbad Notice of Potential Non-Filer email dated April 30, 2021
C. Regional Board email dated May 10, 2021
D. NONA Registration dated Dec. 21, 2021
E. Regional Board approval emails dated Dec. 3, 2021, and Jan. 6, 2022
cc: Geoff Patnoe, Assistant Executive Manager
Celia Brewer, General Counsel
Laura Rocha, Deputy City Manager, Administrative Services
Robby Contreras, Assistant General Counsel
James Wood, Environmental Management Director
Tim Murphy, Senior Program Manager
Dave Padilla, District Engineer
Eric Sanders, Utilities Manager
Keri Martinez, Utilities Senior Engineer
To the members of the:
CITY COUNCIL
Dat~1>Df2.rcA / CC ✓
CM_ ACM __k"OCM (3) J.tC .....
CMWD Board Memorandum
April 30, 2021
To:
From:
Via:
Re:
Carlsbad Municipal W_ater Di.strict Board of Directors
Pa? Gomez, Deputy City Manager, Public Works
Vicki Quiram, General Manager ~
Scott Chadwick, E~ecutive Manager~-
Carlsbad Water Recycling Facility Permit fDistrict 3)
Ccarlsbad
Municipal Water District
Memo ID# 2021092
ATTACHMENT A
This memorandum provides information regarding potential required permit coverage for the
Carlsbad Water Recycling Facility (CWRF) under the National Pollutant Discharge Elimination
Sy.stem (NPDESl 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 Oiscnarge Requirements, the Regional Water Quality Control Board (Regional Board)
requested several verification documents. These inspections are conducted eve:ry 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 avvare thatthe CWRF stormwater
discharges n,ay 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 · bythe 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 underthe (:ity's municipal stormwater permit, and a third-party
contractor regularly inspects the CWRF for stormwaterpermit 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 sendingthe 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-Exp_osure
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 Servlces
· Robby Contreras, Assistant General Counsel
James Wood, Environmental Manager
Dave Padilla, District Engineer
Tim Murphy, Senior Program Manager
Keri Martinez, Senior Engineer
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)
1. 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-NJ~
Cement Manufacturing (40 C.F.R. Part 411); 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).
2. 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.)
3. Oil and Gas/Mining Facilities:
Facilities classified as SICs 10XX 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 disch1:;1rge
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.
4. 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 cat~gory 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 (Gonstruction 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, includin·g 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:
Facilities 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 orWastewa1er Treatment Works:
Facilities used in the-storage, treatment, recycling, and
reclamation of municipal or domestic &ewage, including
land dedicated to the disposal of sewage sludge, that
are loca.ted 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
under40 Code of Federal Regulations part 403. Not
included are farm lands, domestic ga~dens, 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
witli Section 405 of the Clean Water Act.
ATTACHMENT B
~-
{__Carlsbad
Municipal Water Distritt
April 29, 202-1
San Diego Regio_nal Water Quality Control Boc1rd
Mr. Tony Felix, WRC Engineer Via email to tony.fel~x@waterhoards.ca.gov
Ms. Lau.rie Walsn,. PE, Senior Engineer via email to la:urie.walsh@waterboards.ca.gov
2375 Northside Drive, Suite iOO
San Diego, CA 92008
Re: Request for Ciarifkation on NPDES Ge1,1eral Permit for Storm Wate{Discharges Associated
with Industrial General Permit (IGP) Activities for a Carlsbad Municipal Water District
(CIYIWD) fc1cility
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 i1Jp1.1t. The CWRF takes secondary effluent from the adjacent Encina Water Pollution
Control Facility fEWPCF) and incorporates water treatment tec.hnologies to produc;e recycled
water meetingTitle 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,, arid reclamation of munlcipal or domestic sewage,
including land dedieated to the disposal of sewage sludge, that c1re located within the confines
of the facility, with a design flow of one m,illion gallons per day or more, are required to have an
approved pretreatmentprogram under40 Code of Federc1l Regulatiqns part 403." This facility
does produce recycled water, but the, prtmary and secondary treatment of the domestic
sewage takes place at the adjacent EWPCF wbith has IGP coverage.
Based on our review, CIVIWD is seeking clarification on whether the IGP ls applicable to the ·
CWRF and can provide additfonal cletail as requested.
Associated Permits
The CWRF has coverage under Order No. R9-2016-018~ Master Recycling Permit for CMWD,
CWRF, San Diego County and under Order No .. R9-2018-0059 Waste Discharge R_equirements
f~r the Encina Wastewater Authority EWPGF and Satellite Wastewater Tre~tment Plants
Carlsbad Munidpai Water District
5950 El Camino Real I Carlsbad, CA 92008 I 760-438~2722 I 760-431~1601 fax I VvWW.carlsbadca.gov
Discharge to the Pacific Ocean through the Encina Ocec;1n Outfall. Regional Board staffco_nducts
regular compliance evaluation i_nspectidns at this site, under these permits, and in concert with
EWPCF and ha~ not been found in violati'on.
The CWRF is also included on the Existing Development Inventory for the City of Carlsbad
required under Order No. R9~2Q13,..Q001, 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 re~eived any violations for at least the last flve 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,
/~.
tl /(!;,./Cl--
Vicki Quiram
General Manager
Attachment: A, CWRF Synopsis
cc: Geoff Patnoe, Assistant Executive Ma·nager ·
Paz Gomez, D·eputy City Mantfger, Public Works
Robby Contreras, Assista'ht General Counsel
Dave Padilla, District Engin~er
l<eri Martinez; Senior Engineer; Utflities
Shoshana Aguilar, Senior Management Analyst
i
!.
ATTACHMENT A
BACKGROUND
The Carlsbad Water Recycling Faeility (CWRF) is. owned by the Carlsbad !VIUnicipal Water District
(CMWD) and operated and maintained by Encina Wastewater Authority (EWA}. Located in
Carlsbad, CA, the CWRF treats secondary efffuentfrom the adjacent Encina Wpter Pollution Control
Facility'to produce up to 7.0 MGD ofTitle 22 recycled water. The GWRF was constructed in 2005 as part
of Phase II of a comprehensive regional program to proyicfe Ca.rlsbad and surrouri.ding areas With a
reliable, drought-proof recycled water supply. Phase II' Recycled Wate( Project included an expansion of
theCWRF to 7.0 MGD capacity. the goals of the CWRF expa_nsion were to in"trease filtration reliability;
enhance operational flexibility, c1nd improve stored recycled water quality.
The GWRF expansion included the addition of three pressurized 1,1ltrafiltration (U F} skids to produce ~:4
MG_D ofadditional filtrate flow. The UF system includes feed pumps, feed tank, booster pumps;
stn~ioers, UFmembrane skids, backwash pumps, CIP tank and pumps, air compressors, blowers, ?ind
chemical transfer pumps. The startup and testing period of the new equipment began in June 2016 and
the expanded facility started p,roducing Title 22 water in September 2016. The expansion project was
completed in November 2016. Performance Demonstration testing of the UF system was completed on
Jun_e 17, 2017.
CARLSBAD WATER RECYCLING FACILITY
CWRF is. a 7 million gallon per day (MGD} water reclamation facility. CWRF is located adjacent to tlie
Encina Water Pollution Control Facility (~WPCF). The CWRF takes secondary effluent from the E\ll/PCF
and incorporates water treatmenttechnologies to produce recycled water meeting Title 22 of the
California Admini~trative·code for"unrestri~ted non-potable reuse.!' The CWRF takes s_econdi!ry
efflqent from the-EWPCF"and treats the flow through two parallel advanced treatment grbcesses; One.
trec;1tment proc~ss utilizes granular media filtration (GMF) and the other uses ultrafiltration (UF).The
productwater from the two processes i.s l:ill:!n_ded c;1nd disinfected, using sodium hypochlorite, in the
chlorine contact tank (CCT) ptiqr to recyded water storage a11d distribution. ·
The CWRF was designed to meet Title 22 reguirements of tne 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 desigried in a_ccordance with Title 22Section
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 p·rovided 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 disch.arge
point" requirement. When a treatment process is placed out of service, pumping to the (:WRF
from the effluent pump station ceases and production flow is giverted b«;1ck to EWPCF; As such,
no sts1ndby basins, standby equipment, or emergency power is provided.
.In the event th_e CWRF final effluent total coliform or turbic;lity requirements are not met; the
noncom pliant effluent is diverted back to EWPCF. Alarm conditions, as described in Title22 Section
60335, are included in the CWRF control system to the extent t·hat they are applicable.
CWRF is permitted to prod1.1ce 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 FILTRATlON
GMF is a c.ontihuous backwas~hr up-flow type of media filter ma11ufactured by Andritz. The GMF process
is comprised of an influenHeed channel, two filter cells ofsix filter modules each, and backwash
equipment. Flow enters the filtratioh influent feed channel Q_n the north end of the filter complex. Flow
into each filter cell is through an is9Jatiofl 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 potfori1, of the filter module and moving
upwards through the descending media. Ali airlift located atthe center of the module continuously lifts
splids and filter media to a solids-separator box located near the filter surface. Solids are collected in
the soUds-separator box and flow by gravity to the EWPCF secondary treatment process. The.deaned
me<:lia 'moves to the top of the fjlter"media1 where it begins filterinitwhile moving downward once again.
A dedkated air compressor and air receiver supply air for the airlifts. TheGMF is designed to produce
up to 3] MGD and a 2 NTU efflqent with an infhJent turbidity of 6 NTU. ·
l!LTRAFILTRATION
Ui= utilizes three paraflel, trains ofToray HFl)-2020N modules to treat a portion of the secondary effl.uent
from the EWPCF. Secondary effluentis pumped to a UF feed tank; which provides operational storage
forthe UF booster pumps. Prior to entering the UF feed tank; the secondary effluent is pretreated tci
achieve the following: .
• Chloriiiatiooto satisfy the chlorine demancj of the EWPCF secondary effluent.and provide'a
resid1,.1al to inhibit biological fouling of the membranes
• Prescreening and removal of large particles (greater than 300 microns).
UF prescreenihg is designed to treat a flow up to 3.76 MGD while removing particles great~r t_han 300
microns. T~e UF process can produce 3.38 MGD of UF effluent. The c!ifference beJween UF influent and
effluent (product water) is due to filter desighed reject rate of 10% and filter bacl<Washing with product
water. The UF System co11sists of 216 modules arranged in three trains with 72 modules per train. Each
module contains 9,000 fibers with a nomi,nal pore size of Q.Qlr:nicroris.
Uf exerts a large energy demjlnd on CWRF .. As a me~_hs_ of reducing energy expenses at CWRF; and to
provide CMWD with good financial stewardship, EWA has adopted an operating strategy·ofoperating
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 hburs of 4pm-9p111
each day unless production demands require lt. The UF is used as a secondary process method of water
production, with the primary process of the water produced at CWRF orjginating 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.
From:
To:
Cc:
Subject:
Date:
Attachments:
stormwater
RB9 Nonfilers@waterboards.ca.gov
Storm water
Potential facilities subject to !GP
· Friday, April 30, 2021 9:59:27 AM
pastedlmagebase640.png
Dear San Diego Water Board industrial storm water staff,
ATTACHMENT B
As required under Order No. R9-2013-0001, and following an inspection and/or evaluation by City of Carlsbad staff,
the following facility may be subject to the Industrial General Permit:
--------' ---. ---- ----- ----.. ~ ~
~:~!TY ADDRESS ~::::f:TA]]\lE PHONE EMAIL -SIC CODE -
---------- ---------~ ---------~ -------------~----
CARLSBAD 6220 AVENI DA
RECYCLED ENCINAS
WATER CARLSBAD, CA
FACILITY 92011
ERIC SANDERS,
CARLSBAD
MUNICIPAL
WATER DISTRICT
760-438-
2722 eric.sanders@carlsbadca.gov 4952
Please be advised, Carlsbad Municipal Water District staff indicated they would be sending a letter seeking clarification
on the applicability of the Industrial General Permit for the Facility.
Please let us know if you have any questions. Thank you.
{City of
Carlsbad
City of Carlsbad
Environmental Management
Watershed Protection
1635 Faraday Ave
Carlsbad, CA 92008
[www.carlsbadca.gov]www.carlsbadca.gov
760-602-2799 Hotline
From:
To:
Cc:
Subject:
Date:
Attachments:
Ms. Quiram,
Walsh. Laurie@Waterboards
Vicki Quiram
Keri Martinez; Jeanette Brown; Felix. Tony@Waterboards
RE: Carlsbad Municipal Water District -Request for Clarification
Monday, May 10, 20214:17:43 PM
image00l.png
imaqe003.png
image004.pnq
imaqe00S.png
2021-04-29 Clarification Request CWRF RWOCB.pdf
ATTACHMENT C
The San Diego Water Board has reviewed your attached request for clarification about the
Carlsbad Water Reclamation Facility (CWRF) industrial activities needing to apply for coverage
under the Statewide General Industrial Stormwater Permit (IGP).
The CWRF treats secondary effluent from the adjacent Encina Water Pollution Control Facility.
The design capacity of the CWRF is 7.0 MGD. Since the CWRF is primarily engaged in the
industrial activity to further treat wastewater effluent received from Encina for the purposes
of recycling and reclamation of municipal or domestic sewage, it is our determination that
CWRF qualifies as a Sewage or Wastewater Treatment Works under Item 9 in Attachment A to
the IGP. CWRF must therefore apply for coverage under the IGP.
Should you or your staff need assistance applying for IGP coverage, please contact my staff
engineer Tony Felix. Tony can assist you with the application process.
Laurie Walsh, PE
Senior Water Resource Control Engineer I Storm Water Management
San Diego Water Board I 2375 Northside Drive, Suite 100 I San Diego, CA 92108
P: ( 619) 521-33 73 Our Office has transitioned to virtual operations. The best way to reach me is via email.
From: Jeanette Brown <Jeanette.Brown@carlsbadca.gov>
Sent: Thursday, April 29, 2021 4:13 PM
To: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>; Walsh, Laurie@Waterboards
<Laurie.Walsh@waterboards.ca.gov>
Cc: Vicki Quiram <Vicki .Quiram@carlsbadca.gov>; Keri Martinez <Keri.Martinez@carlsbadca.gov>
Subject: Carlsbad Municipal Water District -Request for Clarification
)
EXTERNAL:
Mr. Felix and Ms. Walsh,
I have attached an important letter regarding the Carlsbad Water Recycling Facility for your review.
I know how busy you both are, but would appreciate a response or a call as soon as possible.
My cell phone number is 760-443-8879 and my email is vicki.quiram@carlsbadca.gov.
Thank you very much for your time and assistance,
Vicki Quiram
General Manager
Carlsbad Municipal Water District
760-443-8879 -cell
Sent by/ for Vicki Quiram
\lcai♦isbad
Municipal Wat~r ,D1siricl
Jeanette Brown
Administrative Secretary
to Vicki Quiram/General Manager
5950 El Camino Real
Carlsbad, CA 92008
760-603-7306 Direct Line
760-802-8099 Cell
760-438-2722 Main Line
CAUTION: Do not open attachments or click on links unless you recognize the sender and
know the content is safe.
F
CALI FOl'INtA
Water Boards
December 21, 2021
Vicki Quiram
Carlsbad Municipal Water District
5950 El Camino Real
Carlsbad, CA 92008
NONA ID:
Date Processed:
~ GAVIN NEWSOM ~iil!Jj G<'.WETil~O;t
ATTACHMENT D
Facility Info: Carlsbad WRF
6220 Avenida Encinas 5950 El Camino
Carlsbad, CA 92008
SIC Code(s): 4952
9 37NNA001974
October 20, 2021
RECEIPT OF YOUR NOTICE OF NON-APPLICABILITY (NONA) FOR THE GENERAL PERMIT
FOR STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY (INDUSTRIAL
GENERAL PERMIT) ORDER NO 2014-0057-DWQ, NPDES NO. CAS000001
The State Water Resources Control Board (State Water Board) received and processed your
NONA. The NONA ID assigned to the facility is referenced above.
Please use this number in any future communication regarding the IGP.
Should site conditions change such that coverage under the Industrial General Permit is
necessary, submittal of Permit Registration Documents (PRDs) is required to obtain a Waste
Discharger Identification number.
If you have any further questions regarding permit requirements, please contact your
local Regional Water Board at 619-516-1990.
Please visit the storm water web page at
www.waterboards.ca.gov/water_issues/programs/stormwater/industrial.shtml
for storm water related information.
Sincerely,
Storm Water Program
Division of Water Quality
JOAQUIN ESQUIVEL, CHAIR I EILEEN SOBECK, EXECUTIVE OFFICER
10011 Street, PO Box 1977, Sacramento, California, 95812 I I www.waterboards.ca.gov, ph:1-866-563-3107, fax:(916) 341-5543
C.J Rl:CYOLEO PAr'Ll4
From:
To:
Cc:
Subject:
Date:
Attachments:
Felix. Tony@Waterboards
Keri Martinez
Jeff Warner
Re: Carlsbad Water Recycling Facility -NONA
Thursday, January 6, 2022 8:04:25 AM
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order.pdf
Hello Keri and Jeff,
ATTACHMENT E
We have reviewed your No Discharge Technical Report and agreed (via email) that you have
satisfied the requirements prescribed in section XX.C.
There are no reporting requirements in SMARTS. However, should any operational changes
occur at the facility that would potentially violate the no discharge requirements, you are
required to notify the water board for reevaluation of the requirements.
Respectfully,
A. Tony fell,u
Water Resource Control Engineer
Stormwater Management Unit
San Diego Water Resources Control Board
2375 Northside Drive, Suite 100
San Diego, California 92108
P: (619) 521-5921
h ov sandie o
From: Keri Martinez <Keri.Martinez@carlsbadca.gov>
Sent: Wednesday, January 5, 2022 8:07 AM
To: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>
Subject: RE: Carlsbad Water Recycling Facility -NONA
EXTERNAL:
Good morning Mr. Felix and Happy New Year,
I am following up on this email. Thank you again for your assistance in getting our facility in
compliance. We will continue to operate as planned and of course notify/reassess should any
future changes occur.
I think our consultant Jeff Warner of MOE has previously reached out, but I was also checking in with
you as my supervisor is inquiring. I am unfamiliar with the next administrative steps and was hoping
you could advise. Will we receive further approval notice from SWRCB or will there be something
posted on the SMARTS database? Are there additional fees we can expect?
Thank you in advance for your assistance.
Respectfu I ly,
Keri Martinez
Keri L. Martinez, P.E.
Senior Utilities Engineer
Public Works
5950 El Camino Real
Carlsbad, CA 92008-8802
o: 760-603-73541 m: 442-200-7376 I keri.martinez@carlsbadca.gov
From: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>
Sent: Friday, December 3, 202110:45 AM
To: Jeff Warner <jeff@mogawaeng.com>
Cc: Mikhail Ogawa <mikhail@mogawaeng.com>; Keri Martinez <Keri.Martinez@carlsbadca.gov>;
Walsh, Laurie@Waterboards <Laurie.Walsh@waterboards.ca.gov>; Ryan, Erica@Waterboards
<Erica.Ryan@Waterboards.ca.gov>
Subject: Re: Carlsbad Water Recycling Facility -NONA
Hello Jeff,
I have reviewed the No Discharge Technical Report (NDTR) dated October 2021 for
the Carlsbad Water Recycling Facility (CWRF), submitted on behalf of the Carlsbad
Municipal Water District. Section XX.C Special Conditions of the statewide Industrial
General Permit (IGP), describes the requirements for dischargers claiming 'No
Discharge' through the Notice of Non-Applicability (NONA, section 13399.30 of the
Water Code).
The NDTR documented that the Carlsbad Water Reclamation Facility is engineered
and constructed to contain the maximum historic precipitation event (more than a
seven-inch rain event) and ensure no discharge of industrial stormwater to waters of
the Unites States. The NDTR documented that most industrial activities occur within a
closed system (Appendix A, Record Drawings); the Facility uses storm-resistant
shelters to protect industrial activities and materials from exposure to precipitation;
industrial activity areas that are not within closed-systems have sufficient freeboard
and storage capacity to contain the maximum storm event; the three trench drains
and the backwash equalization basin within the Western Influent Treatment Zone
(WITZ) do not discharge runoff to the stormwater conveyance system, but rather
stormwater runoff is pumped to the Encina Water Pollution Control Facility for
treatment; and lastly, the stormwater runoff not captured by the three trench drains
and backwash equalization basin only comes into contact with sealed systems and
discharges to the area drains within the WITZ Open Space Area .
The No Discharge requirements of the IGP have been met. The Carlsbad Municipal
Water District must continue to operate the CWRF in this manner to maintain its
NONA. Should any site reconfiguration or operation change occur at the CWRF,
please notify the water board for reevaluation of the IGP requirements.
Please contact me if you have any questions.
Respectfully,
A. T~ fill,u
Water Resource Control Engineer
Stormwater Management Unit
San Diego Water Resources Control Board
2375 Northside Drive, Suite 100
San Diego, California 92108
P: (619) 521-5921
htt ov sandie o
From: Jeff Warner <jeff@mogawaeng.com>
Sent: Monday, November 8, 2021 2:23 PM
To: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>
Cc: Mikhail Ogawa <mikhail@mogawaeng.com>; Keri Martinez <Keri.Martinez@carlsbadca.gov>
Subject: RE: Carlsbad Water Recycling Facility -NONA
EXTERNAL:
Hello Tony,
I hope all is well and things are not too crazy at work. Last month we uploaded the Carlsbad Water
Recycling Facility (CWRF) No Discharge Technical Report onto SMARTS and wanted to check in and
see if you had any questions.
Thank you,
Jeff
Jeff Warner, QSP, QISP I Senior Scientist
MOE I c. 619.929.5302
iwa rner@mogawaeng.com
From: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>
Sent: Friday, September 24, 20219:17 AM
To: Jeff Warner <ieff@mogawaeng.com>; Walsh, Laurie@Waterboards
<Laurie.Walsh@waterboards.ca.gov>
Cc: Vicki.Ouiram@carlsbadca.gov; Keri Martinez <Keri.Martinez@carlsbadca.gov>; Eric Sanders
<Eric.Sanders@carlsbadca.gov>; Mikhail Ogawa <mikhail@mogawaeng.com>
Subject: Re: Carlsbad Water Recycling Facility -NONA
Hello Jeff,
Thanks for the update and let me know when the technical report is ready for the water board
review.
A. to-vt:YF~
Water Resource Control Engineer
Stormwater Management Unit
San Diego Water Resources Control Board
2375 Northside Drive, Suite 100
San Diego, California 92108
P: (619) 521-5921
htt s: www.waterboa1-ds.ca. .. .. ....
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From: Jeff Warner <ieff@mogawaeng.com>
Sent: Thursday, September 23, 2021 6:51 AM
To: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>; Walsh, Laurie@Waterboards
<Laurie. Wa lsh@waterboards.ca .gov>
Cc: Vicki.Ouiram@carlsbadca.gov <Vicki.Ouiram@carlsbadca.gov>; Keri Martinez
<Keri.Martinez@carlsbadca.gov>; Eric Sanders <Eric.Sanders@carlsbadca.gov>; Mikhail Ogawa
<mikhail@mogawaeng.com>
Subject: RE: Carlsbad Water Recycling Facility -NONA
EXTERNAL:
Hello Laurie and Tony,
I wanted to check in and let you know the status of the Carlsbad Water Recycling Facility (CWRF) No
Discharge Technical Report. We are near completion with edits and QC and expect to have
everything onto SMARTS by early October.
Thank you, and let me know if you have any questions at this time.
Jeff
Jeff Warner, QSP, QISP I Senior Scientist
MOE I c. 619.929.5302
jwa rner@mogawaeng.com
From: Jeff Warner
Sent: Friday, July 2, 202110:47 AM
To: Felix, Tony@Waterboards <Tony.Felix@waterboards.ca.gov>; Walsh, Laurie@Waterboards
<Laurie.Walsh@waterboards.ca.gov>
Cc: Vicki.Ouiram@carlsbadca.gov; Keri Martinez <Keri.Martinez@carlsbadca.gov>; Eric Sanders
<Eric.Sanders@carlsbadca.gov>; Mikhail Ogawa <mikhail@mogawaeng.com>
Subject: Carlsbad Water Recycling Facility-NONA
Hi Laurie and Tony,
Thank you for taking the time to meet and discuss the IGP coverage options for the Carlsbad Water
Recycling Facility {CWRF). I met and discussed our conversation with City Staff and they agree with
your suggestion of obtaining coverage through the Notice of Non-Applicability {NONA) process. We
are commencing with the collection and review of data to develop a No Discharge Technical Report
and initiating the SMARTS LRP requirements. The plan is to have everything uploaded onto SMARTS
by mid-August. By having everything within SMARTS in such a short timeframe, we feel there is no
need to develop a No Exposure Certification {NEC) while developing the NONA.
Thank you, have a great 4th of July, and let me know if you have any questions at this time.
Jeff
Jeff Warner, QSP, QISP I Senior Scientist
MOE I c. 619.929.5302
jwa rner@mogawaeng.com
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