FROM: James D. Herberg, General Manager
Originator: Lan C. Wiborg, Director of Environmental Services
SUBJECT:
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ENVIRONMENTAL REGULATORY REPORTS
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GENERAL MANAGER'S RECOMMENDATION
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RECOMMENDATION: Recommend to the Board of Directors to:
Receive and file environmental regulatory reports: Biosolids Management Compliance Report 2020, Annual Pretreatment Program Report Fiscal Year 2019-2020, Semi-Annual Pretreatment Program Report Fiscal Year 2020-2021 (July-December), Annual Greenhouse Gas Emissions Report 2020, Annual Emission Report 2020, Marine Monitoring Annual Report 2019/2020, and Biennial Wastewater Discharge Requirements Sewer System Management Plan Audit Report 2021.
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BACKGROUND
The Orange County Sanitation District (OC San) is subject to environmental regulatory oversight by the U.S. Environmental Protection Agency (EPA), Regional Water Quality Control Board (Santa Ana Region), California Air Resources Board, and South Coast Air Quality Management District (SCAQMD). These regulatory bodies require routine reporting, which is prepared by OC San’s Environmental Services Department. These reports include:
1. Annual Biosolids Report (40 CFR Part 503) required by OC San’s NPDES permit for ocean discharge. Due February 19th of every year.
2. Annual and Semi-Annual Pretreatment Program Reports required by OC San’s National Pollutant Discharge Elimination System (NPDES) permit. Due October 31st and March 31st, respectively, of every year.
3. Annual Mandatory Reporting of Greenhouse Gas Emissions required by California Air Resources Board (CARB). This report uses an online portal for report preparation and submission. Due April 10th of every year.
4. Annual Emission Report required by SCAQMD. Due early/mid March of every year.
5. Annual Marine Monitoring Report required by OC San’s NPDES ocean discharge permit. Due March 15th of every year.
6. Biennial Wastewater Discharge Requirements Sewer System Management Plan Audit Report 2021.
RELEVANT STANDARDS
• Comply with environmental permit requirements
• Safe, beneficial reuse of Biosolids
• Comply with transparency and communication requirements, including the Brown Act
ADDITIONAL INFORMATION
Environmental regulatory reporting is required by local, state, and federal regulatory bodies to ensure protection of water, air, and land resources. Some of the routine reporting is completed using online reporting portals, which may perform calculations based on user input of operational data. The following key regulatory reports were filed recently.
The Biosolids Annual Report contains details about the management of OC San’s biosolids, including volume, quality, and locations. In 2020, OC San produced approximately 567 tons of biosolids per day. The biosolids are anaerobically digested and dried to about 24-27% solids. The biosolids are managed via composting and land application. The Biosolids Annual Report was submitted electronically as required by the EPA’s Electronic Reporting Rule.
Under its NPDES permit, OC San is required to establish and implement an approved pretreatment program to control the level of pollutants discharged into the sewer system. OC San is also required to submit Pretreatment Program Annual and Semi-Annual Reports detailing the status of the approved program. The reports identified herein contain information about all industrial dischargers permitted by both OC San and the Santa Ana Watershed Project Authority (SAWPA). The Annual and Semi-Annual reports were successfully completed and submitted prior to the October 31, 2020 and March 31, 2021 deadlines, respectively.
The SCAQMD’s Annual Emissions Report (AER) represents a facility's annual inventory of criteria pollutants (VOC, NOx, SOx, CO, PM) and toxic air emissions. The emissions are calculated based on throughput volume and emissions measured at applicable process areas and emission units. The report assesses fees based on a facility's emissions of air contaminants for the reportable year, as specified in SCAQMD Rule 301. The AER reports for Plant Nos.1 and 2 are prepared and submitted using SCAQMD's web-based emission reporting tool. For calendar year 2020, Plant No. 1 emitted approximately 26.91 tons of criteria pollutants and OC San paid total fees in the amount of $18,535.59. For the same reporting period, Plant No. 2 emitted approximately 32.9 tons of criteria pollutants and OC San paid total fees in the amount of $22,217.53. The reports were electronically submitted on March 16, 2021.
In accordance with the California Global Warming Solutions Act (Assembly Bill 32, 2006), CARB requires all major sources that directly emit Greenhouse Gases (GHG) to report their GHG emissions resulting from their combustion of fuel and importation of electrical power for each calendar year. The GHG inventory report focuses primarily on the emissions of carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). Similar to SCAQMD's AER reporting portal, the GHG report is electronically submitted via CARB's Cal e-GGRT reporting system. For calendar year 2020, Plant No. 1 reported roughly 21,677 metric tons of CO2 emissions, while Plant No. 2 reported approximately 36,709 metric tons of CO2 emissions. The reports were electronically submitted on April 9, 2021.
OC San has completed its annual report for the marine monitoring program as required by its NPDES permit which evaluates and measures potential impacts of the final effluent (comprising treated wastewater and water reclamation flows) to water quality, sediment chemistry, fish and invertebrate communities, fish health, and sediment toxicity. OC San’s ocean monitoring program has three required components: Core Monitoring, Regional Monitoring, and Strategic Process Studies. This comprehensive program is implemented through rigorous monitoring of benthic sediments for chemical deposition, changes in biological communities, and the health of fish living near OC San’s ocean outfall. Additionally, the program is tasked with profiling plume dynamics from the effluent discharge and with monitoring water chemistry, oxygen availability, and physical conditions throughout the water column to ensure regulatory compliance. This report summarizes data collected from July 2019 through June 2020 and was electronically submitted by the March 15, 2021 deadline.
OC San’s marine monitoring program continues to show the discharge of final effluent neither affects the receiving environment nor poses a risk to human health. Water quality measurements demonstrate no negative environmental impacts from OC San’s discharge. Sediment concentrations of metals and organic contaminants were well below the protective thresholds. The composition of marine invertebrates and fish communities is comparable near outfall and non-outfall stations alike. Concentrations of trace metals and chlorinated pesticides in fish tissue (muscle and/or liver) were comparable across outfall and non-outfall stations. Furthermore, concentrations of contaminants measured in sport fish samples did not exceed California’s “Do not consume” Advisory Tissue Level.
OC San completed its Wastewater Discharge Requirements Sewer System Management Plan Audit as required by the Statewide General Waste Discharge Requirements for Sanitary Sewer Systems as incorporated by reference in OC San NPDES permit. The audit, completed in March 2021, consisted of a desktop review of OC San’s Sewer System Management Plan (SSMP), and supporting documentation, staff interviews, and development of recommendations for corrective actions and program enhancements. OC San’s sewer system management operations are consistent with the SSMP and are effective in limiting sanitary sewer overflows (SSOs) in OC San’s service area. The results of the 2021 audit identified no major nonconformances, three minor nonconformances, three recommended corrective actions, and 12 recommended enhancements.
CEQA
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FINANCIAL CONSIDERATIONS
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ATTACHMENT
The following attachment(s) may be viewed on-line at the OC San website (www.ocsan.gov) with the complete agenda package:
• 2020 Biosolids Management Compliance Report
• 2019-2020 Annual Pretreatment Program Report Fiscal Year
• July-December 2020 Semi-Annual Pretreatment Program Report Fiscal Year 2020-21
• Annual Greenhouse Gas Emissions Report 2020
• Annual Emission Report 2020
• 2019-2020 Marine Monitoring Annual Report
• 2021 Wastewater Discharge Requirements Sewer System Management Plan Audit Report