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January 2015 Executive Summary City of San Diego NPDES Permit and Public Utilities Department EX - 3 301(h) Application. Commitment to Pure Water San Diego Program. In requesting renewal of 301(h) modified discharge limits for TSS and BOD, this NPDES application does not propose any
Application for Renewal of NPDES CA0107409, 301 h Modified Secondary Treatment Requirements for. Biochemical Oxygen Demand and Total Suspended Solids. POINT LOMA OCEAN OUTFALL,POINT LOMA WASTEWATER TREATMENT PLANT. Submitted pursuant to,Sections 301 h and 301 j 5 of the Clean Water Act. City of San Diego,Public Utilities Department,9192 Topaz Way. San Diego CA 92123,858 292 6401,January 2015,APPLICATION FOR RENEWAL OF NPDES CA0107409. 301 h MODIFIED SECONDARY TREATMENT REQUIREMENTS,Point Loma Ocean Outfall. Point Loma Wastewater Treatment Plant,EXECUTIVE SUMMARY. January 2015, Volume I Summary Volume I is the first of a ten volume submittal by the. City of San Diego in application for renewal of NPDES CA0107409 and. 301 h modified secondary treatment requirements for the Point Loma. Ocean Outfall wastewater discharge The City requests renewal of existing. modified secondary treatment requirements for total suspended solids and. biochemical oxygen demand Volume I presents an executive summary of. the findings of the ten volume 301 h application As documented within. the application the Point Loma Ocean Outfall discharge complies with all. applicable regulations and requirements established pursuant to Sections. 301 h and 301 j 5 of the Clean Water Act,LIST OF VOLUMES. Volume I Executive Summary,Volume II Part 1 Basis of Application. Part 2 NPDES Application Forms,Part 3 Antidegradation Analysis. Volume III Large Applicant Questionnaire, Volume IV Appendix A Existing Metro System Facilities and Operations. Appendix B Future Metro System Facilities,B 1 Planned Metro System Facilities Improvements. B 2 2012 Recycled Water Study, B 3 Water Purification Demonstration Project Report. Volume V Appendix C Ocean Benthic Conditions,C 1 Benthic Sediments Invertebrates and Fishes. C 2 San Diego Benthic Tolerance Intervals, C 3 San Diego Regional Sediment Quality Contour Plots. C 4 San Diego Sediment Mapping Study,C 5 Deep Benthic Habitat Assessment Study. Appendix D Bioaccumulation Assessment,Volume VI Appendix E Sources of PCB Contamination. Appendix F Point Loma Ocean Outfall Plume Behavior Study. Appendix G Kelp Forest Ecosystem Monitoring Report. Appendix H Coastal Remote Sensing Annual Reports,Volume VII Appendix I Beneficial Use Assessment. I 1 Beneficial Use Evaluation, I 2 Compliance with Recreational Body Contact Standards. Appendix J Endangered Species,Appendix K Essential Fish Habitat Assessment. Appendix L Proposed Monitoring Program, Volume VIII Appendix M 2013 Annual Biosolids Report. Volume IX Appendix N Source Control Program,Appendix O 2013 Annual Pretreatment Report. Volume X Appendix P Oceanography,Appendix Q Initial Dilution Simulation Models. Appendix R Re entrainment,Appendix S Dissolved Oxygen Demand. Appendix T Analysis of Ammonia,Appendix U 2012 California Ocean Plan. Appendix V Correspondence,EXECUTIVE SUMMARY,Renewal of NPDES CA0107409. EXECUTIVE SUMMARY,Request for Renewal of,NPDES CA0107409 and. Clean Water Act Section 301 h 301 j 5,Modified Discharge Requirements for the. Point Loma Wastewater Treatment Plant,January 2015. Table of Contents,PURPOSE OF SUBMITTAL EX 1,BASIS OF SUBMITTAL EX 2. Renewal of Current NPDES Requirements EX 2,Requested TSS and BOD Limits EX 2. Commitment to Pure Water San Diego Program EX 3,Long Term Pure Water San Diego Goal EX 4. Secondary Equivalency Concept EX 7,METRO SYSTEM OVERVIEW EX 8. Treatment and Conveyance EX 8,Source Control EX 12. Monitoring EX 13,ORGANIZATION OF APPLICATION EX 13. PROTECTION OF THE OCEAN ENVIRONMENT EX 14, Compliance with State and Federal Standards and Criteria EX 14. TSS Mass Emissions EX 15, Clean Water Act Section 301 j 5 Requirements EX 16. Physical Oceanography EX 17,Fate of Discharged Solids EX 17. Dissolved Oxygen EX 18,Beneficial Uses EX 19,Sediments EX 19. Benthic Infauna EX 19,Demersal Fish and Megabenthic Invertebrates EX 20. Balanced Indigenous Population BIP EX 21,Endangered Threatened Species EX 22. CONSISTENCY WITH STATE POLICIES EX 22,Recycled Water Policy EX 22. San Diego Water Board Practical Vision EX 22,CONCLUSIONS EX 23. REFERENCES EX 26,City of San Diego NPDES Permit and. Public Utilities Department EX i 301 h Application. List of Figures,Figure EX 1 Secondary Equivalency Approach. for Protecting Receiving Water Quality EX 8, Figure EX 2 Metro System Facilities and Participating Agency Service Areas EX 10. Figure EX 3 Schematic of Existing Metro System Operations EX 11. Figure EX 4 Point Loma WWTP Effluent TSS Mass Emissions. Five Year Running Average 1995 2013 EX 15, Figure EX 5 Reduction in Point Loma WWTP Effluent TSS Mass Emissions. During the Period of 301 h Modifications EX 16,City of San Diego NPDES Permit and. Public Utilities Department EX ii 301 h Application. List of Tables, Table EX 1 Pure Water San Diego Potable Reuse Tasks 2015 2020 EX 5. Table EX 2 Proposed Permitted Point Loma WWTP TSS Mass Emissions EX 6. Table EX 3 Potable Reuse Implementation Goals EX 7. Table EX 4 System Wide BOD and TSS Removal 2010 2013 EX 16. Table EX 5 Summary of Compliance with 301 h Criteria EX 25. City of San Diego NPDES Permit and, Public Utilities Department EX iii 301 h Application. List of Abbreviations,BIP balanced indigenous population. BOD biochemical oxygen demand,CWA Clean Water Act, DDW State Water Resources Control Board Division of Drinking Water. EIR Environmental Impact Report,EPA United States Environmental Protection Agency. JPA Joint Powers Authority,MER mass emissions rate. MBC Metro Biosolids Center, Metro System San Diego Metropolitan Sewerage System. mgd million gallons per day,mg l milligrams per liter. North City WRP North City Water Reclamation Plant, NPDES National Pollutant Discharge Elimination System. PLOO Point Loma Ocean Outfall, Point Loma WWTP Point Loma Wastewater Treatment Plant. Regional Board California Regional Water Quality Control Board San Diego Region. ROV remotely operated submersible vehicle,SBOO South Bay Ocean Outfall. South Bay WRP South Bay Water Reclamation Plant,TSS total suspended solids. ZID zone of initial dilution,City of San Diego NPDES Permit and. Public Utilities Department EX iv 301 h Application. EXECUTIVE SUMMARY,PURPOSE OF SUBMITTAL, The San Diego Metropolitan Sewerage System Metro System provides wastewater service for. the City of San Diego and 12 participating agencies The E W Blom Point Loma Wastewater. Treatment Plant Point Loma WWTP serves as the terminal Metro System treatment facility. The discharge of treated wastewater from the Point Loma WWTP to the Pacific Ocean via the. Point Loma Ocean Outfall PLOO is currently regulated by a joint permit issued by the. California Regional Water Quality Control Board San Diego Region Regional Board and the. U S Environmental Protection Agency EPA Regional Board Order No R9 2009 0001 EPA. NPDES CA0107409 establishes modified secondary treatment requirements for the PLOO. discharge in accordance with Sections 301 h and 301 j 5 of the Clean Water Act. Order No R9 2009 0001 was originally adopted by the Regional Board on June 10 2009 EPA. issued final approval of the joint NPDES permit on June 16 2010 and the permit became. effective on August 1 2010 Order No R9 2009 0001 expires on July 31 2015 and the City is. required to file a Report of,Waste Discharge requesting. renewal of the NPDES,permit 180 days in advance,of this expiration date. February 1 2015,The City of San Diego as,the operating agency of the. Metro System requests,renewal of NPDES,CA0107409 and renewal of. modified secondary treat, ment standards for total The Point Loma Wastewater Treatment Plant is the terminal treatment. suspended solids TSS and facility serving a Metro System population of approximately 2 2 million. biochemical oxygen demand BOD established under section 301 h and 301 j 5 of the Clean. Water Act CWA,City of San Diego NPDES Permit and, Public Utilities Department EX 1 301 h Application. January 2015 Executive Summary,BASIS OF SUBMITTAL, Renewal of Current NPDES Requirements The City of San Diego s comprehensive. effluent and receiving water monitoring program 1 has documented that the combination of. enhanced source control flow diversion to recycled water use chemically enhanced primary. treatment at the Point Loma WWTP,and a deep and efficient ocean outfall. ensures that the PLOO discharge,complies with all NPDES permit. limits and all applicable state and,federal water quality based standards 2. In addition to implementing water,quality based standards to protect. receiving waters the Clean Water Act,establishes a technology based. standard that requires secondary The City s comprehensive effluent and receiving water monitoring. treatment for all municipal wastewater program demonstrates consistent compliance of the Point Loma. discharge with all discharge permit limits and requirements. discharges to inland estuarine or, marine receiving waters Sections 301 h and 301 j 5 of the Clean Water Act however. acknowledge that technology based secondary treatment requirements may not be appropriate. for all discharges and all receiving waters and allow EPA to issue modified secondary treatment. requirements for dischargers that 1 comply with applicable receiving water standards 2 do. not unreasonably impact beneficial uses and 3 result in the maintenance of healthy balanced. indigenous populations of fish and benthic bottom dwelling species outside the designated. zone of initial dilution After review of the City s three prior NPDES applications 1995 2002. and 2007 for modified secondary treatment requirements EPA determined in each instance that. the PLOO discharge qualified for modified TSS and BOD requirements under Sections 301 h. and 301 j 5 of the Clean Water Act, Requested TSS and BOD Limits This permit application requests renewal and. continuation of the following TSS and BOD percent removal requirements established in Order. No R9 2009 0001 pursuant to requirements of Clean Water Act Sections 301 h and 301 j 5. monthly average system wide removal of TSS of 80 percent and. annual average system wide removal of BOD of 58 percent. Results from the City s comprehensive effluent monitoring program for the current NPDES permit period are summarized in City of San Diego. 2011a 2014a Results from the City s comprehensive ocean monitoring program are summarized in City of San Diego 2011b 2014b. A water quality based standard is a standard that is implemented to protect receiving water quality and ensure protection of beneficial uses. including human health and aquatic habitat, A technology based standard mandates implementation of a certain treatment technology regardless of the conditions or quality of a given. receiving water,City of San Diego NPDES Permit and. Public Utilities Department EX 2 301 h Application. January 2015 Executive Summary, Commitment to Pure Water San Diego Program In requesting renewal of 301 h. modified discharge limits for TSS and BOD this NPDES application does not propose any. increase e g relaxation of the NPDES effluent flow rate concentration limits performance. goals or mass emission limits established in Order No R9 2009 0001. To the contrary this application is,based on a new direction in water. and wastewater facilities planning,for the City of San Diego that. proposes to systematically reduce,future PLOO discharge flows and. solids mass emissions through,implementation the Pure Water. San Diego program Pure Water,San Diego is a long term approxi. mately 20 year program that,would provide a safe reliable and. cost effective drinking water, The Pure Water San Diego program has a goal of producing up to 83 supply for San Diego through the. million gallons per day of purified water by December 31 2035 which application of advanced treatment. would significantly reduce the City s dependence on imported water. technology to purify recycled, water The Pure Water San Diego program is a joint water and wastewater facilities plan that. envisions a significant investment in potable water reuse and ancillary facilities that will. eventually produce up to 83 million gallons per day mgd of potable supply an amount that. equates to approximately one third of the total City of San Diego potable water demand. The Pure Water San Diego program is the result of collaboration between the City of San Diego. Metro Wastewater Joint Powers Authority JPA and a diverse array of regional stakeholders. The City Metro Wastewater JPA and regional stakeholders have agreed to cooperate to. implement a comprehensive potable reuse program using state of the art advanced. treatment technology to achieve an ultimate goal of 83 mgd of potable reuse by. December 31 2035, sufficiently reduce influent flows and solids loads to the Point Loma WWTP so that. ultimate PLOO TSS mass emissions are reduced to levels that would have occurred if the. 240 mgd Point Loma WWTP were to achieve secondary treatment TSS concentration. support the City s application for renewed 301 h modified TSS and BOD limits for the. Point Loma WWTP and,City of San Diego NPDES Permit and. Public Utilities Department EX 3 301 h Application. January 2015 Executive Summary, support the City s pursuit of administrative or legislative efforts to codify that as a result. of implementing the comprehensive Pure Water San Diego program the PLOO. discharge is recognized as equivalent to secondary treatment for purposes of compliance. with the CWA secondary treatment equivalency, To demonstrate the City s commitment to regulators and stakeholders for moving forward with. Pure Water San Diego plans this NPDES application proposes that the following enforceable. provisions be incorporated into the renewed Point Loma WWTP 301 h permit. Reduction in PLOO Mass Emissions The current Order No R9 2009 0001 establishes. requirements that limit PLOO TSS mass emissions to 13 598 metric tons per year in the final. year of the five year permit As part of the proposed renewed 301 h NPDES permit it is. proposed that allowable PLOO TSS mass emissions be reduced to 12 000 metric tons per. year for years 1 through 4 of the renewed permit and to 11 999 metric tons per year during. year 5 of the renewed NPDES permit, Enforceable Time Schedule Milestones To further demonstrate the City s commitment to. regulators and regional stakeholders to implement the Pure Water San Diego program and. offload Point Loma WWTP inflows and solids loads the City proposes that the renewed. 301 h NPDES permit incorporate an enforceable time schedule governing implementation. of Pure Water San Diego environmental review and facilities design tasks Table EX 1 page. EX 5 presents the enforceable time schedule tasks proposed for inclusion within the. renewed five year NPDES permit, Long Term Pure Water San Diego Goal The long term Pure Water San Diego goal. of the City and its regional partners is to achieve a targeted potable reuse production capacity of. 83 mgd by December 31 2035,This 83 mgd potable reuse. production capacity represents the,current maximum potable reuse. capacity that is consistent with,initial planning studies stake. holder input cost and benefit,analyses regional water demand. analyses and regulatory direction,provided by the State Water. Resources Control Board Division, of Drinking Water DDW Advanced treatment technology redundant treatment processes and. real time monitoring will be employed to ensure that purified water. produced as part of the Pure Water San Diego program will comply with. all applicable potable water standards and will be equal to or superior in. quality to the City s current imported water supply. City of San Diego NPDES Permit and, Public Utilities Department EX 4 301 h Application. January 2015 Executive Summary,Table EX 1, Pure Water San Diego Potable Reuse Tasks 2015 20201. Implementation,Category Task1, Issue Notice of Preparation for Program Environmental Impact Report EIR January 31 2015. Pure Water, Environmental Publish Draft Program EIR for Public Review January 31 2017. Certify Final Program EIR January 31 2018, Notice to Proceed Final Design of 15 mgd purified water conveyance pipeline from. January 31 2017, the North City Water Reclamation Plant North City WRP. Issue Notice to Proceed on final design of a 15 mgd Potable Reuse Purification. May 31 2017, Facility advanced water treatment facility for the North City WRP site. North City, Complete design of the 15 mgd purified water conveyance pipeline from the North. October 31 2019, Complete design of 15 mgd Potable Reuse Purification Facility advanced water. January 31 2020,treatment facility, 1 Implementation tasks proposed for inclusion as an enforceable provision of NPDES CA0109409 to demonstrate the City s. commitment to offloading Point Loma WWTP wastewater flows increasing reuse of the City s wastewater and reducing Point. Loma WWTP flows and mass emissions discharged to the Pacific Ocean. 2 Task to be completed no later than the listed implementation dates. Flows and loads to the Point Loma WWTP would be, offloaded as each new purified water treatment plant and. associated facilities become operational Table EX 2 page. EX 6 summarizes projected step wise reductions in PLOO. TSS mass emissions that are targeted within the next 20. years As shown in Table EX 2 the program goal is to cap. PLOO mass emissions at 9 942 metric tons per year by year. 2028 and beyond This 9 942 metric tons per year TSS. MER would be achieved with a combination of,Point Loma WWTP solids offloading resulting from. upstream potable reuse and treatment facilities and. maintaining chemically enhanced primary treatment,at the Point Loma WWTP no conversion of the. Point Loma WWTP to traditional secondary,A 15 million gallon day purification facility. treatment would be constructed at the City s North City. Water Reclamation Plant as part of the first,phase of the Pure Water San Diego program. City of San Diego NPDES Permit and, Public Utilities Department EX 5 301 h Application.