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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 image00S.png image006.pnq imaqe007.png Outlook-k15d0kas.png Outlook-thzzqutf.png Outlook-pxlpiav2.png 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. .. .. .... ~GOV ~oS~,;~~~ r---. .:. 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 CAUTION. Do not o en attachments or click on links unless sender and know the content is safe. CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe.