Wet Weather Consent Decree Implementation Update

Planning Committee

September 10, 2014

Agenda

• Background

• Regional Private Sewer Lateral Ordinance

• Regional Technical Support Program

• Related Discharge Permits

•Next Steps

2

Background Consent Decree Status

• Lodged with federal District court July 28, 2014

• Public Comment Period closed September 2, 2014 (no comments received)

• Consent Decree will become effective immediately upon being entered by the court

3

Background Key EBMUD Requirements

• Construct and operate Urban Runoff Diversion Project by 2017

• Implement capacity improvement along North Interceptor by 2020

• Conduct annual compliance monitoring and modeling

• Continue Regional Private Sewer Lateral (PSL) Ordinance

Develop and implement a Regional Technical Support Program (RTSP)

4

Regional PSL Ordinance Proposed Amendments

• Consent Decree adds new requirement for Public Entities to maintain their sewer laterals (no enforcement requirements for EBMUD)

• Allow Albany and Alameda to join program

– Proposed transition date January 1, 2015

– City of Berkeley will retain its own program

• Clarify ordinance language developed through initial years of implementation

5

Regional Technical Support Program (RTSP) - Overview

• Replaces $2M/yr PSL Incentive requirement under Stipulated Order

• Requires $2M/yr to identify and characterize sources of inflow and rapid infiltration

• Cumulative spend requirement

– i.e. $2M by Year 1, $4M by year 2, etc.

– Provides ability to front-load

• Includes staff time for analysis and investigation

6

RTSP Overview, continued

• EBMUD identifies sources of inflow and rapid infiltration (I/I)

• EBMUD defines which sources are “high priority”

• Satellite communities pursue high priority sources

– Eliminate public sources within 2 years

– Enforce removal of private sources

• Satellite communities consider non-high priority sources in CIP prioritization

7

RTSP Program Significance

• Key element in WWF discharge reduction

– Estimated 15% of excess peak flow originates from inflow (direct sources)

– Model assumes ability to find and remove 75% of inflow

• Critical to meet Consent Decree

– Year 8 “check-in”

– Year 16 “check-in”

– WWF discharge elimination deadlines (2027, 2033, 2035)

8

RTSP Implementation Approach

• Consent Decree requires an RTSP Plan describing first five years of work

– Draft to satellite communities early 2015

– Final to EPA for review/comment/approval Spring 2015

• Initial field work will occur concurrent with RTSP Plan development

– 2014-2015 wet season flow monitoring

– 2015 dry season smoke testing, CCTV, etc.

9

RTSP Work Plan Development

• Define approach to data analysis and field work

• Maintain flexibility to adapt as we learn

• Learn from others

– I/I investigative programs across the country

– Panel of national experts in sewer system management to support RTSP Plan development

10

RTSP Tools and Techniques

• Analysis of data to identify areas of high potential for inflow, for example: – Flow data from EBMUD and satellite communities

– Proximity to creeks and storm drains

– Sewer work records

• Field work to locate and characterize sources – Flow monitoring

– Smoke testing

– CCTV inspection

– Visual inspection 11

Related NPDES Discharge Permits

• Wet Weather Facilities – Scheduled adoption date November 12, 2014

– Reviewing with RWQCB staff

– No significant issues

• Main Wastewater Treatment Plant – Application due October 2014

– Proposed adoption March 2015

– Key issue: Ensure blending requirements dovetail with WWF permit and Consent Decree

12

Next Steps

• Bring proposed Regional PSL Ordinance amendments for Board consideration

• Work with RWQCB on related NPDES permits • Develop initial deliverables for stakeholder

review in early 2015 – RTSP Plan – Flow Model Calibration Plan – PSL Outreach Plan

• Implement initial stages of RTSP data analysis and field work

• Keep Board apprised of key activities 13

Wastewater Service Area and Major Facilities

14

Semi-Annual Regulatory Compliance Update

Planning Committee

September 10, 2014

Agenda

• Enforcement Actions

• Permit for Potable Water Discharges

• Cal OSHA Inspections

• Safety Culture Perception Survey

• Upcoming Activities

2

Enforcement Review

• Strategic Plan KPI = Zero NPDES and Waste Discharge Requirement (WDR) permit Notices of Violation (NOVs) received

– Four NOVs for discharges to water or land

– Two NOVs related to air quality compliance

3

Lafayette WTP NOVs

•May 8, 2012 discharge caused by failure of filter control valve

– Modified controls

•March 27, 2013 discharge to sump going to Lafayette Creek

– Added signage at drains “No Dumping – Drains to Creek”

• $6000 settlement agreement

4

Upcountry NOVs

• Failure to collect data on pH and temperature at Camanche North Shore Water Treatment Plant in June 2014

– Contesting due to lack of discharge

•Missed sample during 2014 Q2 at Clay Station Raw Water Pumping Plant

– Enhanced communication between staff

5

MWWTP NOV Settlement Agreement

NOV for unabated digester gas release on 11/9/13

• 15 minute release through pressure relief valves

• Plugged drain line in flare

• Settlement agreement with $4000 fine

6

MWWTP Air Permit NOV

Digester gas release on 11/22/2013

• Failure of flare igniter

• 830 cu. ft. vented through pressure relief valves

• Requested breakdown relief

•NOV issued 7/28/14

7

General Potable Water Discharge Permit

• Agreement with SF RWQCB & ABAG to fund person to develop permit

• $298,833 estimated total cost

• Agreement with 7 other agencies to share costs

• District share is $50K

SF Regional Permit Progress

• 11/20/13 - admin draft issued for review with water agencies

• 5/8/14 - tentative order issued for public comment

• 5/19/14 - public workshop held

• 7/1/14 – permit postponed pending statewide permit

Statewide Permit

• 6/6/14 – SWRCB issues draft permit

• 8/5/14 – public hearing

• 9/23/14 – permit scheduled for adoption at SWRCB hearing

Cal OSHA Inspections

• 6 inspections initiated based on employee complaint(s)

• 13 facilities examined and scrutinized

• 2 citations

– Fixed ladder exceeds 30 feet without ladder safety system or landing platforms

– Mid-rail is below the halfway point of the guardrail

11

Safety Perception Survey

• 621 of 809 OMD employees surveyed

• Scored in 62nd percentile

• Compared to 750 Companies

•Over 1.5 million responders

12

Survey Action Plans

• Communicating results

• Engage employees

• Identify top issues to address

•Develop specific action-oriented countermeasures

• Retake survey in 2 years

13

Upcoming Activities

•Work with SFRWQCB, ABAG, and Bay Area water utilities to finalize a permit for potable water discharges

•Work with Local Safety Committees to develop action plans based on safety perception survey

• Review fall protection compliance at water distribution reservoirs

Questions?

15

Orinda Water Treatment Plant

Washwater Tank Rehabilitation

Planning Committee Meeting

Orinda Water Treatment Plant

Washwater Tank Rehabilitation

Planning Committee Meeting

September 10, 2014

Orinda WTP Washwater Tank Rehabilitation

• Background

• Site Constraints

• Community Outreach

• Design Mitigations

• Next Steps

Background Orinda WTP circa1938: minimal site constraints

Orinda WTPElevation  = 375’

Washwater TankElevation=410’

Source: Google Earth

• 200,000 gallons• At grade• 40 ft. diameter • 22 ft. tall• Bar‐stressed concrete 

BackgroundOrinda WTP and washwater tank today

Orinda WTP

Source: Google Earth

Washwater Tank

Site constraints Poor access, trees, no staging area

Tank

Property Line

Slope

Community Outreach

• Approach:

• Notified the community early

• Explained clearly the need for the project

• Provided visual exhibits

• Held community meetings on-site

• Mitigated with design

50’dia

Proposed Tank:

Existing Tank:

Community Outreach

New tank alternative

New tankalternative

Aerial “footprint” vs. Ground-level visualExisting

Community OutreachOn-site meetings clarified neighbor concerns

Mailbox access

Tree removal

Architecture preservation

Curb appeal

Designed Mitigations Adjust retrofit method to site constraints

Manual wrapping minimizes equipment size and tree removal.

Sturdy base anchorages minimizes impact on tank architectural features.

New fence is set back for a “green zone”

Security fence

Low maintenance plantings for screening

Restore cobbles

Add staging area off-site

Minimize tree removal

Retrofit existing tank

Design Mitigated Site planning neighbor concerns

Next Steps

• Maintain communications with neighbors

• Schedule:

– Open Bids Sept 17, 2014

– Recommend Award Oct 14, 2014

– Construction Nov 2014 – Mar 2015

Questions?

Drought Communications with Billpayers

and with Non-billpayers EBMUD Planning Committee

September 2014

2

More than a third of EBMUD customers do not get a bill

387,000 accounts

Non-billpaying residents are ethnically diverse

Non-billpaying residents are younger

Print bill payers get information and news regularly from EBMUD

Direct mail to print bill payers:

• Top of bill message

• Prior-year water use

• Back of bill tips

• Customer Pipeline

• Supplemental inserts

5

Electronic billpayers get links to EBMUD news and information

E-bill with web links:

– Top of bill message

– Prior-year water use

– Back of bill tips

– Customer Pipeline

– Bill FAQs

6

Non-billpayers get most EBMUD news through other sources

Direct mail

• Annual Water Quality Report postcard

Other communication

• Earned media

• Ebmud.com

• Outdoor ads

• Community events

• Presentations 7

Many more non-billpayers say they can’t rate EBMUD

Q10. Thinking specifically about the East Bay Municipal Utility District, using a scale of excellent, good, only fair, or poor, please rate the overall job East Bay Municipal Utility District is doing

92%

79%

90%

83%

80%

68%

79%

71%

76%

66%

75%

67%

71%

57%

Bill Payer

Non-Payer

Bill Payer

Non-Payer

Bill Payer

Non-Payer

Bill Payer

Non-Payer

Bill Payer

Non-Payer

Bill Payer

Non-Payer

Bill Payer

Non-Payer

Total Agree

Non billpayers give EBMUD favorable--but lower--ratings

Provides safe tap water

Provides good tasting tap water

Is an agency I can trust

Cares about the environment

Is a reliable source of information

Operates in communities’ best interests

Is responsive to customer service requests

Conservation rating variance was 13 percent in early 2014

77%

65%

61%

55%

60%

47%

Bill Payer (78%)

Non-paying Renter (22%)

Bill Payer (78%)

Non-paying Renter (22%)

Bill Payer (78%)

Non-paying Renter (22%)

Ensuring the quality of the water we drink

Making sure we have the water supply we need

Encouraging customers to conserve water

TV news is the top source for conservation information

Page 11

7/08 2/08 2007

Television News* 38% 37% 35%

Newspaper 22% 23% 25%

EBMUD Bill insert/newsletter 14% 16% 6%

Radio 5% 12% 9%

Television Commercial 3% -- --

Brochure/Pamphlet 3% 7% 4%

Billboard 2% 4% 4%

EBMUD websites 1% 1% --

Other website 1% 2% --

Other 10% 11% 33%

Don’t Know 1% 5% 3% * In 2/08 and 2007 surveys, “Television” was not split between “News” and “Commercial”

** 2 responses were allowed per respondent in 2/08 and 2007 surveys *** “Other responses include “phone calls” and “letters” from previous EBMUD actions

Where did you see or hear the conservation information?

In 2014, active media relations has been a focus of outreach

•480 unique interviews with reporters

–218 on drought declaration/water supply

–152 on conservation tips, rebates, rules

•370 news reports featured EBMUD

12

Late 2014 proposed outreach intended to reach non-billpayers

• Ongoing

– Earned media, web, presentations, booths, etc.

• October+

– Social media policy

• November

– Updated outdoor media campaign

• December

– Direct mail to non-billpayers

13

Semi-Annual Water Quality Report

Planning Committee September 10, 2014

District’s Water Quality Goals

•Must meet Federal and State Drinking Water Standards

• KPI – Meet 100% of Federal and State Drinking Water Standards

• Strive to meet District’s Water Quality Goals

• KPI – Meet 100% of District’s Water Quality Goals

•Met all Federal and State Drinking Water Standards

•Met 117 of 119 (98%) District’s Water Quality Goals (WQGs)

– Exceeded the WQGs for TTHMs and NDMA

• TTHM – Exceeded WQG in 3 of 32 compliance

calculations

– Project underway to alter chemical injection points at Sobrante Water Treatment Plant

•NDMA – Exceeded WQG in 1 of 10 samples

– WateRF Projects •Natural sources of NDMA precursors

•Alternative polymer evaluation

UCMR 3

• Provide occurrence data to USEPA

• Prelude to potential regulatory action

• 30 unregulated contaminants

• Began monitoring: Fall 2013

• Detected – Chlorate

– Vanadium

– Strontium

– Hexavalent chromium

Hexavalent Chromium (Cr(VI))

• CA established MCL (10 µg/L) on July 1, 2014

•District began UCMR3 monitoring on Fall 2013

• Cr(VI) detected in UCMR3 samples based on USEPA detection limit (0.03 µg/L)

• Based on CA detection limit (1 µg/L) our UCMR3 data would be reported as nondetects.

CalEnviroScreen

•Quantitative assessment of pollution burden

– CalEPA Office of Environmental Health Hazard Assessment (OEHHA)

– Identify areas with high pollution burden

• Version 2.0

– Drinking Water

– Finer resolution

– Draft April 2014

CalEnviroScreen (cont)

• Acknowledge contaminant concentration used may represent untreated water

• Reference to consumer confidence reports

Potential Regulatory Action

• Candidate Contaminant List (CCL) 4

• Unregulated Contaminant Monitoring Rule (UCMR) 4

•Distribution System Reservoirs Rule

– Asked District staff to provide information on District maintenance practices (October 15, 2014)

• Research – District operations continues to experience

nitrification

– Beginning work to gain a better understanding of the underlying causes in an effort to improve operations

• Portland Water Bureau – Lead violation

– Boil Water Notice (TCR violation)

– Nitrification

Questions