Table of Contents
- Resource Alignment/Cost of Compliance
- Environmental Lab Accreditation Program
- Pharmaceuticals and Personal Care Products
- Federal Regulatory Issues
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.
- SWRCB Nutrient Policy-Stakeholder Comments – June 11, 2015
- Nutrient Science Plan Comments – December 19, 2014
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.
- Toxicity – Las Galinas Permit Comments – March 9, 2015
- Toxicity – ATP Withdrawal Letter -March 3, 2015
- Toxicity – San Jose Creek Permit Comments – January 16, 2015
Petitions for Review
- CASA/SCAP Camarillo Sanitary District NPDES Permit – TST Petition – August 2015
- CASA/SCAP City of Simi Valley NPDES Permit – TST Petition August 2015
- CASA/SCAP City of Thousand Oaks NPDES Permit – TST Petition August 2015
- CASA/SCAP/NACWA LACSD San Jose Creek NPDES Permit – TST Petition May 2015
- CASA/SCAP/BACWA LACSD Whittier and Pomona NPDES Permit – TST Petition December 2014
Mercury is a pollutant that, if present in sufficient quantities, can result in water quality impairments. The primary sources of mercury in the environment include legacy mining and atmospheric deposition, with contributions from industrial source and urban run-off as well.
The State Water Resources Control Board is developing several approaches to addressing mercury that have the potential to impacts wastewater agencies. These include a statewide mercury control program for reservoirs, statewide mercury water quality objectives, and establishment of total maximum daily loads for mercury in impaired waters.
Many CASA agencies are engaged in proactive efforts to control mercury in areas where it can present an issue, including the implementation of programs to address dental amalgam and other industrial sources of mercury. CASA tracks all developments at the state and federal level related to mercury controls, and CASA staff and member agencies participate in multiple workgroups to address mercury issues.
Resource Alignment/Cost of Compliance
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.
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.
Following the Ebola epidemic in West Africa in 2014 and the subsequent presence of a few cases in the United States, the wastewater sector was concerned about the management of wastewater generated by hospital patients infected with Ebola.
There were conflicting messages from the Center for Disease Control (CDC), The World Health Organization, and others, and questions surfaced over the science upon which recommendations were based.
Immediately following the issuance of a guidance from the CDC in late 2014, CASA issued recommendations for dialogue between wastewater treatment agencies and local hospitals and public health officials regarding the management of wastewater produced by patients infected with the Ebola virus. The recommendations are updated in the 3rd edition of the guidance dated June 2, 2016, and based upon new research. The updated guidance was again developed in close coordination with several preeminent microbiologists and concurred with by the California Department of Public Health and NACWA, and are intended to offer an additional layer of protection for workers who may come into contact with wastewater prior to its treatment.
- Study done by Dr. Gerba (University of Arizona) on the survivability of Ebola surrogates in wastewater using different disinfectants.
- Study done by Dr. Pepper (University of Arizona) on the survivability of Ebola surrogates in biosolids via mesophilic and thermophilic anaerobic digestion.
- June 2016 3rd and current version of consensus recommendation for management of wastewater from patients infected with Ebola and communication between the wastewater sector and hospitals treating such patients.
- Summary of research at the University of Arizona
- Standard Operating Procedures
- CDC’s Interim Guidance for Managers and Workers Handling Untreated Sewage from Individuals with Ebola in the United States
Environmental Lab Accreditation Program
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.
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).
Pharmaceuticals & Personal Care Products
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.
- LA County EPR Ordinance Comments – November 23, 2015
- LA County EPR Ordinance Comments – September 23, 2015
Federal Regulatory Issues
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.
- CASA Selenium Criteria Comments – September 24, 2015
- Final Dental Amalgam Rule Comments – February 20, 2015
- Final E-reporting Rule Comments – January 30, 2015