Table of Contents

Nutrients

Overview

Nutrients (generally nitrogen and phosphorous) in combination with other natural environmental factors can lead to eutrophication and increased algal growth in certain types of water bodies. Wastewater entities are regulated as a point source of nutrients, though a significant amount of nutrient contributions to water bodies come from non-point sources such as agricultural runoff. The State Water Resources Control Board is developing a statewide nutrient control program focusing on wadeable streams. Efforts are also underway to address nutrients in California’s bays and estuaries.

CASA has developed a holistic, watershed-based alternative to addressing nutrient issues that is more suited to address the unique problems they present, and continues to be involved as a primary wastewater stakeholder in nutrient policy development efforts.

Comment Letters

Links

Toxicity

Overview

Toxicity, often referred to as Whole Effluent Toxicity (WET), is a term used to describe the aggregate toxic effect of a particular discharge as measured by an organism’s response to samples of that water. Wastewater discharge permits generally require wastewater plants to engage in toxicity testing as part of their water quality compliance. The State Water Resources Control Board is developing a statewide policy for toxicity assessment and control, which may alter monitoring frequencies, specify test methods and establish effluent limitations.

Despite the pending state policy, individual regional water boards have begun to issue more stringent permits including numeric effluent limitations. CASA has objected to these permitting practices as premature and inconsistent with federal regulations, and has supported its members by filing several petitions for review with the State Water Resources Control Board.

Comment Letters

Petitions for Review

Links

Resource Alignment/Cost of Compliance

Overview

The State Water Resources Control Board resource alignment/cost of compliance effort began in 2011 as a way to assess and align State Water Board priorities, resources, and performance targets. The process has evolved since that time and now serves as a forum to consider proposals developed by CASA and other regulated stakeholders to reduce the costs of compliance for dischargers while maintaining water quality protections.

Links

OVERVIEW: The State Water Board recently affirmed a checklist and supporting documents (attached) as part of the resource alignment / cost of compliance initiative that could prove valuable for wastewater agencies. Regional Water Board permit writers should already have these documents in their possession and will use them as part of current and future permit renewals. This checklist and continued support for the cost of compliance initiative should indicate the support of the State Water Board to find ways to reduce the cost of compliance for permittees while maintaining water quality protections. 

 

BACKGROUND: The State Water Resources Control Board resource alignment/cost of compliance effort began in 2011 as a way to assess and align State Water Board priorities, resources, and performance targets. The process has evolved since that time and now serves as a forum to consider proposals developed by CASA and other regulated stakeholders to reduce the costs of compliance for dischargers while maintaining water quality protections.

 

DISCUSSION: If you believe that your agency’s permit contains duplicative or unnecessary monitoring and reporting requirements, or if your agency could benefit from a regional monitoring program or the use of surrogate sampling in some circumstances, we encourage you to review this checklist closely and bring these issues up with your Regional Board permit writer at permit renewal. This is an opportunity for your agency to raise cost of compliance concerns with your Regional Board and permit writing staff and potentially get these issues addressed. 

Environmental Lab Accreditation Program

Overview

The Environmental Laboratory Accreditation Program (ELAP) provides evaluation and accreditation of environmental testing laboratories in the state, including those utilized by wastewater agencies. The ELAP program is in the process of undergoing significant changes in the wake of its transition to the State Water Resources Control Board. CASA representatives participate as part of the stakeholder group providing input related to ongoing changes to ELAP.

Comment Letters

Links

Flushables

Overview

Wastewater agencies frequently deal with problems caused by wipes and other products that do not break down quickly in the sewer system. These items cost utilities millions of dollars as agencies are required to respond to overflows and clean these products out of their systems.

CASA member agencies are very involved with efforts to raise public awareness about these products and work to ensure that they are kept out of sewer systems. These efforts are also part of broader initiative to promote source control of products that should not end up in the wastewater system, including pharmaceuticals, plastics, and fats, oils, and grease (FOG).

Comment Letters

Links

Pharmaceuticals & Personal Care Products

Overview

Pharmaceuticals can end up in the wastewater system when products are improperly flushed down the drain and through elimination. Pharmaceuticals are part of a larger suite of emerging contaminants now being detected in the environment, the impacts of which are not yet entirely clear.

CASA is encouraging the development of local and state solutions to address pharmaceuticals in the environment, including expanded drug takeback programs and education campaigns. These pharmaceutical efforts are also part of broader initiative to promote source control of other products that should not end up in the wastewater system.

Comment Letters

Federal Regulatory Issues

Overview

The United States Environmental Protection Agency (USEPA) is develops regulations to implement the major federal environmental laws—including the Clean Water Act and Clean Air Act. CASA frequently comments on and engages in advocacy related to those rulemakings that have the potential to impact the wastewater industry, including regulations addressing water quality standards, methods, and processes.

Comment Letters

Links