2009-10 Annual Report Source Control

OCSD Orange County Sanitation District ANNUAL REPORT 2010

SOURCE CONTROL PROGRAM

Orange County Sanitation District 10844 Ellis Avenue Fountain Valley, CA 92708-7018 (714) 962-2411

TABLE OF CONTENTS

Page

SOURCE CONTROL PROGRAM

Letter of Transmittal

Affirmation

Table of Contents ...... i

List of Tables ...... xi

List of Figures ...... xvi

List of Appendices ...... xix

EXECUTIVE SUMMARY

E.1 BACKGROUND ...... E.1

E.2 INTRODUCTION ...... E.1

E.2.1 Pretreatment Program Summary ...... E.2

E.2.2 Pretreatment Program Elements ...... E.3

E.2.3 Compliance with NPDES Discharge Requirements ...... E.5 chapter 1 NPDES REQUIREMENTS - PRETREATMENT

1.1 PRETREATMENT REQUIREMENTS – COMPLIANCE WITH NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT REQUIREMENTS ...... 1.1 chapter 2 OCSD’S FACILITIES AND COMPLIANCE WITH DISCHARGE REQUIREMENTS

2.1 INTRODUCTION ...... 2.1

2.2 EXISTING OCSD FACILITIES ...... 2.2

2.2.1 Description of Treatment Plants ...... 2.2

i TABLE OF CONTENTS

(continued) Page

2.2.1.1 Reclamation Plant No. 1 ...... 2.4

2.2.1.2 Treatment Plant No. 2 ...... 2.6

2.2.1.3 Joint Works Facilities ...... 2.6

2.3 COMPLIANCE WITH NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) REQUIREMENTS ...... 2.6

2.4 EFFLUENT CHARACTERISTICS ...... 2.8

2.4.1 General ...... 2.8

2.4.2 Suspended Solids ...... 2.8

2.4.3 Biochemical Oxygen Demand (BOD) ...... 2.8

2.4.4 Oil and Grease ...... 2.8

2.4.5 Settleable Solids ...... 2.10

2.4.6 Turbidity ...... 2.10

2.4.7 pH ...... 2.10

2.4.8 Toxicity ...... 2.11

2.4.9 Outfall Disinfection ...... 2.12

2.5 METALS ...... 2.12

2.6 MASS EMISSION BENCHMARKS ...... 2.13 chapter 3 PERMITS

3.1 INTRODUCTION ...... 3.1

3.2 PERMIT CLASSIFICATIONS ...... 3.1

3.3 PERMIT ISSUANCE ...... 3.2

3.3.1 Identification of New Permittees ...... 3.4

3.4 DISCHARGE LIMITS ...... 3.4

ii TABLE OF CONTENTS

(continued) Page

3.4.1 Industrial ...... 3.4

3.4.2 Wastehaulers ...... 3.4

3.5 ESTABLISHING MASS EMISSION RATES (MER) ...... 3.5 chapter 4 INSPECTION, SAMPLING, COMPLIANCE, ENFORCEMENT

4.1 INTRODUCTION ...... 4.1

4.2 ROUTINE SAMPLING AND INSPECTION ...... 4.1

4.3 NON-ROUTINE SAMPLING AND INSPECTION ...... 4.2

4.3.1 Downstream Sampling ...... 4.2

4.4 ORANGE COUNTY HAZARDOUS MATERIALS STRIKE FORCE (STRIKE FORCE) ...... 4.3

4.5 INDUSTRIAL COMPLIANCE STATUS WITH DISCHARGE LIMITS ...... 4.3

4.5.1 Industries Consistently Achieving Compliance (CAC) ...... 4.3

4.5.2 Industries Inconsistently Achieving Compliance (IAC)...... 4.3

4.5.3 Industries in Significant Noncompliance (SNC) ...... 4.3

4.6 ENFORCEMENT ACTIVITIES ...... 4.5

4.6.1 Compliance Inspections ...... 4.6

4.6.2 Compliance Meetings ...... 4.6

4.6.3 Notices of Violation – Noncompliance Fees, Penalties ...... 4.6

4.6.4 Probation Orders ...... 4.7

4.6.5 Enforcement Compliance Schedule Agreement ...... 4.7

4.6.6 Administrative Penalties ...... 4.7

4.6.7 Permit Suspensions ...... 4.7

iii TABLE OF CONTENTS

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4.6.8 Permit Revocations ...... 4.8

4.6.9 Emergency Suspension Order ...... 4.8

4.6.10 Civil/Criminal Complaints ...... 4.8

4.7 ENFORCEMENT SUMMARY ...... 4.8

4.8 JOINT AGENCY INSPECTIONS ...... 4.33 chapter 5 NON-COMPATIBLE POLLUTANTS DISCHARGED BY INDUSTRY

5.1 INTRODUCTION ...... 5.1

5.2 INDUSTRIAL DISCHARGE OF METALS ...... 5.1

5.2.1 Cadmium ...... 5.2

5.2.2 Chromium ...... 5.3

5.2.3 Copper ...... 5.3

5.2.4 Lead ...... 5.4

5.2.5 Nickel ...... 5.4

5.2.6 Silver ...... 5.4

5.2.7 Zinc ...... 5.5

5.3 ARSENIC ...... 5.5

5.4 MERCURY ...... 5.5

5.5 CYANIDE ...... 5.6

5.6 ORGANIC PRIORITY POLLUTANTS ...... 5.6

5.6.1 Influent/Effluent Organic Priority Pollutants ...... 5.6

5.6.2 Polychlorinated Biphenyls (PCB) ...... 5.6

5.6.3 Pesticides ...... 5.6

iv TABLE OF CONTENTS

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5.6.4 Phenolic Compounds ...... 5.7

5.7 RADIOACTIVITY ...... 5.7

5.8 OVERALL TRENDS ...... 5.7 chapter 6 SOURCE CONTROL PROGRAM STAFFING, COSTS, AND FIELD EQUIPMENT

6.1 INTRODUCTION ...... 6.1

6.2 STAFFING, REVENUES, AND COSTS ...... 6.1

6.2.1 Staffing ...... 6.1

6.2.2 Revenues ...... 6.1

6.2.3 Program Costs ...... 6.1

6.3 FIELD EQUIPMENT ...... 6.2

6.3.1 Equipment Inventory ...... 6.2 chapter 7 SOURCE CONTROL PROGRAM STATUS

7.1 INTRODUCTION ...... 7.1

7.2 PUBLIC PARTICIPATION ...... 7.1

7.3 WASTEHAULER PROGRAM ...... 7.1

7.3.1 Wastehauler Permitting ...... 7.1

7.3.2 Wastehauler Discharges ...... 7.1

7.3.3 Wastehauler Monitoring ...... 7.3

7.4 SOURCE CONTROL INSPECTION AND SAMPLING ...... 7.3

7.5 QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC) ACTIVITIES ...... 7.5

v TABLE OF CONTENTS

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7.5.1 QA/QC Program Tasks ...... 7.5

7.5.2 QA/QC Sampling Results ...... 7.6

7.5.3 Conclusions ...... 7.8

7.6 TOTAL TOXIC ORGANICS WAIVER PROGRAM ...... 7.9

7.7 SPECIAL PURPOSE DISCHARGE PERMIT PROGRAM ...... 7.13

7.7.1 Metrics and Trends ...... 7.13

7.7.2 SPDP Program Response ...... 7.14

7.7.3 SPDP Program Enforcement ...... 7.15

7.7.4 SPDP Regulatory Program ...... 7.15

7.8 INDUSTRIAL SELF-MONITORING PROGRAM ...... 7.15

7.9 INDUSTRIAL OPERATIONS AND MAINTENANCE IMPROVEMENT PROGRAM ...... 7.16

7.10 SIGNIFICANT CHANGES IN OPERATING THE PRETREATMENT PROGRAM ...... 7.17 chapter 8 INTERACTION WITH OTHER AGENCIES

8.1 INTRODUCTION ...... 8.1

8.2 REVENUE ZONE NO. 14 (IRVINE RANCH WATER DISTRICT) ...... 8.1

8.3 OPERATING PERMIT, REGIONAL BOARD ORDER 07-03 ...... 8.2

8.4 REPORTING REQUIREMENTS ...... 8.2

8.4.1 Analytical Reporting ...... 8.2

8.4.2 Inorganic Pollutants ...... 8.3

8.4.3 Organic Pollutants ...... 8.6

8.4.4 Report of Upset, Pass-Through and Interference Events ...... 8.6

vi TABLE OF CONTENTS

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8.4.5 Discussion of the List of Industrial Users ...... 8.6

8.4.6 Discussion of Industrial User Compliance Status ...... 8.8

8.4.7 Summary of SIU Compliance ...... 8.8

8.4.8 Discussion of Significant Changes in the Pretreatment Program ...... 8.8

8.4.9 Pretreatment Program Costs ...... 8.8

8.4.10 Equipment Purchases for FY 2009/10 ...... 8.9

8.4.11 Discussion of Public Participation Activities ...... 8.9

8.4.12 Discussion of Sludge Disposal Activities ...... 8.9

8.5 ADDITIONAL INFORMATION ...... 8.9

8.6 SANTA ANA WATERSHED PROJECT AUTHORITY (SAWPA) ...... 8.12

8.6.1 SARI System Pretreatment Program Overview ...... 8.12

8.6.2 Equipment Inventory ...... 8.14

8.7 SAWPA DIRECT CONNECTIONS ...... 8.14

8.7.1 New Permits ...... 8.17

8.7.2 Pending Permits ...... 8.17

8.7.3 Closed Permits ...... 8.18

8.7.4 Direct Connections to the SARI ...... 8.18

8.7.4.1 Aqua Mansa Power Plant ...... 8.18

8.7.4.2 Arlington Basin Desalter Facility ...... 8.18

8.7.4.3 California Institution for Women ...... 8.19

8.7.4.4 California Rehabilitation Center ...... 8.19

8.7.4.5 Chino Desalter Facility ...... 8.21

8.7.4.6 Chino II Desalter Facility ...... 8.21

vii TABLE OF CONTENTS

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8.7.4.7 City of Corona – Temescal Desalter ...... 8.22

8.7.4.8 Corona Energy Partners ...... 8.22

8.7.4.9 Dairy Farmers of America (DFA) ...... 8.22

8.7.4.10 Eastern Municipal Water District, Master Meter ...... 8.22

8.7.4.11 EMWD Menifee Valley Trucked Waste Disposal Facility ...... 8.23

8.7.4.12 EnerTech Rialto Regional Biosolids Processing Facility ...... 8.23

8.7.4.13 Green River Golf Club ...... 8.25

8.7.4.14 Inland Empire Utilities Agency ...... 8.25

8.7.4.15 Inland Empire Utilities Agency Trucked Wastewater Disposal Facility ...... 8.26

8.7.4.16 Jurupa Community Services District, Celebration Dr. Metering Station ...... 8.26

8.7.4.17 Jurupa Community Services District, Etiwanda Connection ...... 8.27

8.7.4.18 Jurupa Community Services District, Hamner Connection ...... 8.27

8.7.4.19 Jurupa Community Services District, Wineville Connection ...... 8.28

8.7.4.20 Mountainview Power Company, LLC ...... 8.28

8.7.4.21 Rubidoux Community Services District ...... 8.28

8.7.4.22 San Bernardino Valley Municipal Water District Water Reclamation Plant SARI Truck Disposal Station ...... 8.28

8.7.4.23 San Bernardino Valley Municipal Water District Water Reclamation Plant SARI Connection ...... 8.28

8.7.4.24 SAWPA Truck Disposal Stations ...... 8.29

8.7.4.25 Stringfellow Pretreatment Facility – Cleanup and Abatement Monitoring ...... 8.29

viii TABLE OF CONTENTS

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8.7.4.26 WMWD’s SAWPA Approved Truck Disposal Station ...... 8.31

8.8 DIRECT SARI CONNECTIONS - TEMPORARY/EMERGENCY ...... 8.31

8.8.1 EMWD Temporary/Emergency Permits ...... 8.31

8.8.2 IEUA Temporary/Emergency Permits ...... 8.31

8.8.3 WMWD Temporary/Emergency Permits ...... 8.31

8.9 INDIRECT PERMITS (HAULED WASTE) ...... 8.31

8.9.1 EMWD Menifee Valley Trucked Waste Disposal Facility ...... 8.33

8.9.2 IEUA Trucked Waste Disposal Facility ...... 8.34

8.9.3 SBVMWD (Valley) Reclamation Plant SARI Truck Disposal Station ...... 8.35

8.9.4 WMWD SAWPA Approved Truck Disposal Facility ...... 8.40

8.10 SAWPA SAMPLING AND SELF-MONITORING SAMPLING RESULTS ...... 8.43

8.11 FUTURE PROJECTS AFFECTING DISCHARGE QUANTITY TO SARI SYSTEM ...... 8.43

8.12 INTERACTION WITH SAWPA ...... 8.44

8.13 NATIONAL ASSOCIATION OF CLEAN WATER AGENCIES (NACWA) ...... 8.44

8.14 WATER ENVIRONMENT FEDERATION ...... 8.45 chapter 9 SOLIDS MANAGEMENT PROGRAM

9.1 INTRODUCTION ...... 9.1

9.2 BIOSOLIDS QUALITY ...... 9.1

ix TABLE OF CONTENTS

(continued) Page chapter 10 NON-INDUSTRIAL (NISC) SOURCE CONTROL PROGRAM STATUS

10.1 INTRODUCTION ...... 10.1

10.2 REGULATORY OBLIGATIONS AND LEGAL AUTHORITY ...... 10.1

10.3 FATS, OILS, AND GREASE (FOG) CONTROL ...... 10.2

10.3.1 FOG Control Commercial ...... 10.2

10.3.2 FOG Residential ...... 10.4

10.4 RADIATOR SHOPS ...... 10.6

10.5 DRY CLEANERS ...... 10.6

10.6 URBAN RUNOFF ...... 10.7

10.7 CONSTITUENTS OF EMERGING CONCERN ...... 10.12

10.7.1 Countywide Pollution Prevention Partnership Program (C4P) ...... 10.13

10.7.2 Pharmaceuticals ...... 10.14

10.7.2.1 Residential “No Drugs Down the Drain” ...... 10.15

10.7.2.2 Pharmaceuticals – Industrial Manufacturers ...... 10.15

10.7.2.3 Pharmaceuticals – Commercial Health Service Facilities ...... 10.15

10.7.3 Pollutant Prioritization ...... 10.16

x LIST OF TABLES

Page

EXECUTIVE SUMMARY chapter 1 NPDES REQUIREMENTS – PRETREATMENT chapter 2 OCSD’S FACILITIES AND COMPLIANCE WITH DISCHARGE REQUIREMENTS

Table 2.1 Average Daily Influent and Effluent Flow in Million Gallons Per Day (MGD), Fiscal Years 1991-2010 ...... 2.2

Table 2.2 NPDES Permit Discharge Requirements and OCSD’s Annual Average Influent and Final Effluent Discharge Values for Fiscal Year 2009-10 ...... 2.7

Table 2.3 Suspended Solids and BOD Annual Average Daily Influent and Final Effluent for Fiscal Years 2006-2010 ...... 2.8

Table 2.4 Oil and Grease Average Influent and Final Effluent for Fiscal Years 2006-2010 ...... 2.10

Table 2.5 Settleable Solids, Turbidity, and pH, Average Final Effluent for Fiscal Years 2006-2010 ...... 2.10

Table 2.6 Final Effluent Yearly Average Toxicity Values for Fiscal Years 2006-2010 ...... 2.11

Table 2.7 Average Metal Concentrations and Mass in the Influent and Effluent for Fiscal Years 2006-2010 ...... 2.13

Table 2.8 Mass Emissions for All Benchmark Constituents, Fiscal Year 2009-10 ...... 2.15 chapter 3 PERMITS

Table 3.1 Number of Permits Administered for Fiscal Years 2006-2010 ...... 3.2

xi LIST OF TABLES

(continued) Page

Table 3.2 Number of Permits Subject to Federal Categorical Pretreatment Standards for Fiscal Year 2009-10 ...... 3.3

Table 3.3 OCSD’s Maximum Allowable Discharge Limits in Milligrams Per Liter (mg/L) ...... 3.5 chapter 4 INSPECTION, SAMPLING, COMPLIANCE, ENFORCEMENT

Table 4.1 Summary of Inspections, Sampling and Laboratory Analyses, Fiscal Years 2006-2010 ...... 4.2

Table 4.2 Summary of Companies in Significant Noncompliance (SNC), Fiscal Year 2009-10 ...... 4.5

Table 4.3 Summary of Noncompliance Fees and Penalties for Fiscal Years 2006-2010 ...... 4.6

Table 4.4 Probation Orders Issued Fiscal Year 2009-10 ...... 4.7

Table 4.5 Administrative Penalties, Fiscal Year 2009-10 ...... 4.7 chapter 5 NON-COMPATIBLE POLLUTANTS DISCHARGED BY INDUSTRY

Table 5.1 Heavy Metal Mass Balance in Wastewater Tributary to OCSD’s Treatment Facilities (lb/day), Fiscal Year 2009-10 ...... 5.2 chapter 6 SOURCE CONTROL PROGRAM STAFFING, COSTS, AND FIELD EQUIPMENT

Table 6.1 Summary of Total Costs and Total Labor Hours for the Source Control Program, Fiscal Years 2006-2010 ...... 6.1

Table 6.2 Current Inventory of Major Equipment for the Source Control Division for Fiscal Year 2009-10 ...... 6.2

xii LIST OF TABLES

(continued) Page chapter 7 SOURCE CONTROL PROGRAM STATUS

Table 7.1 Summary of Wastehauler Loads and Gallons Discharged into Plant No. 1 Disposal Station, Fiscal Years 2006-2010 ...... 7.2

Table 7.2 Summary of Wastehauler Load Types Discharged into Plant No. 1 Disposal Station, Fiscal Year 2009-10 ...... 7.2

Table 7.3 Summary of Wastehauler Grease Wastewater Loads into Plant No. 1 Disposal Station, Fiscal Years 2006-2010 ...... 7.3

Table 7.4 Class 1 Inspection and Sampling Summary July 1, 2009 – June 30, 2010 ...... 7.3

Table 7.5 Equipment Blank Sampling Results, Fiscal Year 2009-10 ...... 7.6

Table 7.6 QA/QC Evaluation of Archived Samples, Fiscal Year 2009-10 ...... 7.7

Table 7.7 QA/QC Sample Collection Checks, Fiscal Year 2009-10 ...... 7.8

Table 7.8 Permittees with TTO Waivers, July 1, 2009 – June 30, 2010 ...... 7.10 chapter 8 INTERACTION WITH OTHER AGENCIES

Table 8.1 Class I Industries within IRWD Revenue Zones 7 and 14 ...... 8.6

Table 8.2 Summary of Irvine Ranch Water District Pretreatment Program Costs, 2008-09 and 2009-10...... 8.8

Table 8.3 Summary of Irvine Ranch Water District Pretreatment Equipment, Fiscal Year 2009-10 ...... 8.9

Table 8.4 Average Effluent Characteristics at the Green River Flow Meter for Fiscal Year 2009-10 ...... 8.13

Table 8.5 Santa Ana Watershed Project Authority – Summary of Pretreatment Equipment for Fiscal Year 2009-10 ...... 8.14

xiii LIST OF TABLES

(continued) Page

Table 8.6 Santa Ana Regional Interceptor (SARI), Permitted Direct Connected Facilities, Fiscal Year 2009-10 ...... 8.15

Table 8.7 Average Heavy Metal Discharge Concentrations and Treated Monthly Flows at the Stringfellow Cleanup Site, as Reported by the Santa Ana Watershed Project Authority (SAWPA), Fiscal Year 2009-10 ...... 8.30 chapter 9 SOLIDS MANAGEMENT PROGRAM

Table 9.1 Trends in Trace Metal Content of Biosolids, Fiscal Years 2000–2010 ...... 9.1 chapter 10 NON-INDUSTRIAL SOURCE CONTROL (NISC) PROGRAM STATUS

Table 10.1 NISC Programs, Fiscal Year 2009-10 ...... 10.1

Table 10.2 NISC Program Regulatory Objectives and Legal Authority by Program, Fiscal Year 2009-10 ...... 10.1

Table 10.3 FSEs by Category, Fiscal Year 2009-10 ...... 10.2

Table 10.4 Status of FSEs with GIs, Fiscal Year 2009-10 ...... 10.3

Table 10.5 FSE Monitoring Reports and NOVs, Fiscal Year 2009-10 ...... 10.3

Table 10.6 FSE Inspection Activities, Fiscal Year 2009-10 ...... 10.3

Table 10.7 FOG Control Program Effectiveness, Fiscal Year 2009-10 ...... 10.4

Table 10.8 FOG Residential Outreach Materials, Fiscal Year 2009-10 ...... 10.5

Table 10.9 FOG Residential Proactive Outreach, Fiscal Year 2009-10 ...... 10.5

Table 10.10 FOG-Related SSO Responses, Fiscal Year 2009-10 ...... 10.6

Table 10.11 Radiator Shops Program, Fiscal Year 2009-10 ...... 10.6

Table 10.12 Dry Cleaner Inventory, Fiscal Year 2009-10 ...... 10.7

xiv LIST OF TABLES

(continued) Page

Table 10.13 Dry Cleaner Program, Fiscal Year 2009-10 ...... 10.7

Table 10.14 Average Urban Runoff Discharge Volume by Diversion July 2009 – June 2010 ...... 10.8

Table 10.15 Urban Runoff Program, Fiscal Year 2009-10 ...... 10.9

Table 10.16 Urban Runoff Compliance, Fiscal Year 2009-10 ...... 10.12

Table 10.17 C4P Materials Distributed, Fiscal Year 2009-10 ...... 10.13

Table 10.18 C4P Outreach Events, Fiscal Year 2009-10 ...... 10.14

Table 10.19 NISC Presentations, Fiscal Year 2009-10 ...... 10.14

Table 10.20 Priority Pollutants, Fiscal Year 2009-10 ...... 10.16

xv LIST OF FIGURES

Page

EXECUTIVE SUMMARY

Figure E-S-1 Average Effluent Total Heavy Metals and Flow for Past Fiscal Years ...... E.2 chapter 1 NPDES REQUIREMENTS – PRETREATMENT chapter 2 OCSD’S FACILITIES AND COMPLIANCE WITH DISCHARGE REQUIREMENTS

Figure 2-1 Process Flow Diagram of Reclamation Plant No. 1 and Treatment Plant No. 2 ...... 2.3

Figure 2-2 Map of Orange County Sanitation District’s Service Area...... 2.5

Figure 2-3 Annual Average of BOD and TSS Contribution from Plant Nos. 1 and 2 Process for Fiscal Year 2009-10 ...... 2.9 chapter 3 PERMITS chapter4 INSPECTION, SAMPLING, ENFORCEMENT chapter 5 NON-COMPATIBLE POLLUTANTS DISCHARGED BY INDUSTRY

Figure 5-1 Average Yearly Influent and Effluent Cadmium ...... 5.2

Figure 5-2 Average Yearly Influent and Effluent Chromium...... 5.3

Figure 5-3 Average Yearly Influent and Effluent Copper ...... 5.3

Figure 5-4 Average Yearly Influent and Effluent Lead ...... 5.4

xvi LIST OF FIGURES

(continued) Page

Figure 5-5 Average Yearly Influent and Effluent Nickel ...... 5.4

Figure 5-6 Average Yearly Influent and Effluent Silver ...... 5.4

Figure 5-7 Average Yearly Influent and Effluent Zinc ...... 5.5

Figure 5-8 Average Yearly Influent and Effluent Arsenic ...... 5.5

Figure 5-9 Average Yearly Influent and Effluent Organic Priority Pollutants ...... 5.6 chapter 6 SOURCE CONTROL PROGRAM STAFFING, COSTS, AND FIELD EQUIPMENT chapter 7 SOURCE CONTROL PROGRAM STATUS chapter 8 INTERACTION WITH OTHER AGENCIES

Figure 8-1 Michelson Water Reclamation Plant, Effluent TDS ...... 8.3

Figure 8-2 Michelson Water Reclamation Plant, Influent and Effluent Heavy Metals ...... 8.4

Figure 8-3 Michelson Water Reclamation Plant, Influent

and Effluent Copper ...... 8.5

Figure 8-4 Michelson Water Reclamation Plant Influent and Efluent Lead ...... 8.5

Figure 8-5 Michelson Water Reclamation Plant Influent and Efluent Zinc ...... 8.5

Figure 8-6 Michelson Water Reclamation Plant Influent and Efluent Total Toxic Organics ...... 8.6

Figure 8-7 Michelson Water Reclamation Plant Influent Flow...... 8.10

Figure 8-8 Michelson Water Reclamation Plant Influent Selenium ...... 8.11

xvii LIST OF FIGURES

(continued) Page chapter 9 SOLIDS MANAGEMENT PROGRAM

Figure 9-1 Trends in Concentrations of Arsenic in Biosolids, Fiscal Years 1990–2010 ...... 9.5

Figure 9-2 Trends in Concentrations of Cadmium in Biosolids, Fiscal Years 1990–2010 ...... 9.5

Figure 9-3 Trends in Concentrations of Chromium in Biosolids, Fiscal Years 1990–2010 ...... 9.6

Figure 9-4 Trends in Concentrations of Copper in Biosolids, Fiscal Years 1990–2010 ...... 9.6

Figure 9-5 Trends in Concentrations of Lead in Biosolids, Fiscal Years 1990–2010 ...... 9.7

Figure 9-6 Trends in Concentrations of Mercury in Biosolids, Fiscal Years 1990–2010 ...... 9.7

Figure 9-7 Trends in Concentrations of Molybdenum in Biosolids, Fiscal Years 1990–2010 ...... 9.8

Figure 9-8 Trends in Concentrations of Nickel in Biosolids, Fiscal Years 1990–2010 ...... 9.8

Figure 9-9 Trends in Concentrations of Selenium in Biosolids, Fiscal Years 1990–2010 ...... 9.9

Figure 9-10 Trends in Concentrations of Zinc in Biosolids, Fiscal Years 1990–2010 ...... 9.9 chapter 10 NON-INDUSTRIAL SOURCE CONTROL (NISC) PROGRAM STATUS

Figure 10-1 Dry Weather Urban Runoff Diversion System Locations in Orange County ...... 10.10

Figure 10-2 Average Gallons per Day of Dry Weather Urban Runoff Diverted into the OCSD Sewer System for Treatment ...... 10.11

xviii LIST OF APPENDICES

appendix a MONITORING AND COMPLIANCE STATUS REPORT appendix b SUMMARY OF PRIORITY POLLUTANTS AND TRACE CONSTITUENTS ANALYSES appendix c PRIORITY POLLUTANTS appendix d (RESERVED) appendix e FEES/PENALTIES FOR NONCOMPLIANT DISCHARGERS appendix f PUBLIC NOTICE OF INDUSTRIES SIGNIFICANTLY VIOLATING COMPLIANCE appendix g CLASS I PERMIT SAMPLE DATA AND DISCHARGE VIOLATIONS appendix h ACKNOWLEDGEMENTS appendix i IRWD SAMPLING appendix j SANTA ANA WATERSHED PROJECT AUTHORITY MONITORING/COMPLIANCE STATUS REPORT

xix LIST OF APPENDICES

(continued) appendix k QA/QC ANALYSIS RESULTS FOR JULY 2009 – JUNE 2010 appendix l COMPANIES WITH PRETREATMENT EQUIPMENT

xx

EXECUTIVE SUMMARY

Background Introduction

EXECUTIVE SUMMARY

E.1 BACKGROUND

Recognizing the need to control the quality and quantity of wastewaters discharged to the sewerage system, OCSD’s Boards of Directors adopted in February 1954 the first Ordinance regulating the use of the sewerage system. This Ordinance was subsequently revised and amended in February 1958, April 1970, July 1976, July 1983, September 1989, February 7, 1992, and July 1998. The 1970 revision formally established OCSD’s Industrial Waste Division to issue permits, set flow and quality limits, and monitor and inspect industrial discharges to the sewerage system. Substances monitored and regulated included: oil and grease (O&G) of mineral and petroleum origin, organic materials, dissolved solids, suspended solids, phenolic compounds, radioactive wastes, combustible materials, and any other contaminants that had the potential to degrade wastewater treatment processes or cause problems in the sewerage facilities. In July 1976, the Ordinance was revised to include heavy metal limits.

In July 1983, the Ordinance was further amended to include enforcement of the EPA's Federal categorical limits and to modify OCSD’s local discharge limits for cadmium, copper, polychlorinated biphenyls (PCB), pesticides, and total toxic organics (TTOs). OCSD’s pretreatment program was approved by the EPA in January 1984. In September 1989, the Ordinance was revised to streamline administrative and enforcement procedures, to incorporate EPA regulations adopted since 1983, and to clarify the intent of the program through added definitions and procedures. In February 1992, the Ordinance was amended to revise defined terms, initiate noncompliance sampling fees, and include language giving OCSD authority to levy administrative penalties according to changes to state law enacted in January 1992. In July 1998, revisions were made primarily for the deletion of Class III permits which were issued for the collection of user charges for the discharge of domestic waste. In July 2008, a revision was made in regards to how tax credits are applied for user charges. The most recent revision in October 2009 provided clarification regarding transfer of permit ownership.

E.2 INTRODUCTION

The fiscal year (FY) 2009/10 OCSD Annual Report provides the following:

Information about the industrial source control program for the fiscal year (July 1, 2009, through June 30, 2010) as required by OCSD’s National Pollutant Discharge Elimination System (NPDES) permit issued by the California Regional Water Quality Control Board, Santa Ana Region (CRWQCB) and the Environmental Protection Agency (EPA); and

Information on how OCSD’s source control program is administered; how well industrial permittees achieve compliance at the source; what effect their discharge has had on OCSD’s influent, effluent, and biosolids; what labor, equipment, and capital resources were used for industrial source control during the fiscal year; and to document how well the program is achieving its goals.

E.1 E.2.1 Pretreatment Program Summary

Control of Pollutants

Since FY 1976/77, while Orange County experienced tremendous growth, the source control program has been successful in reducing the average daily pounds of metals entering OCSD’s system by 85% and metals discharged to the marine environment by 95%. Over this time, individual effluent metals such as cadmium have been reduced by over 99%, chromium by 97%, copper by 95%, lead by 98%, nickel by 91%, and zinc by 79%. Long-term trends of effluent heavy metals show a steady decline since FY 1977 (see Figure E-S-1).

OCSD’s source control program not only has been effective in reducing the toxic priority pollutants discharged to the sewerage system, but has also been effective in protecting the collection, treatment, and disposal facilities from incidents of pass-through or interference, and in enabling OCSD to meet its NPDES ocean discharge limits. The quality of OCSD’s influent, effluent, and biosolids are testimony to how well the program has progressed. Its future challenges will be to continue improving and meeting the program goals through the promotion of pollution prevention, education, communication, and industrial and regulatory controls. It is the policy of the Source Control Division to have consistent enforcement of OCSD’s Wastewater Discharge Regulations (Ordinance).

Total Effluent Heavy Metals Influent Flow

2500 500

l 2000 400 b 1500 300 M s G / 1000 200 D d a 500 100 y 0 0 77 81 85 89 93 97 01 05 09

Figure E-S-1 Average Effluent Total Heavy Metals and Flows for Past Fiscal Years Orange County Sanitation District

Permits

At the end of FY 2009/10, OCSD was administering 714 active permits, of which 332 were Class I permits, 46 Class II permits, 43 Wastehauler permits, 92 Special Purpose permits, 18 Urban Runoff permits, and 183 FOG (Fat, Oil, and Grease) permits. This permit inventory represents a decrease of 2% from the permits administered during the previous fiscal year. Of the 332 Class I users, 213 were subject to Federal Categorical Pretreatment Standards.

E.2 Program Costs

The pretreatment program is funded by industrial permit fees, noncompliance sampling fees, and collection of use charges. The Source Control Division operating expenditures for the fiscal year, including laboratory analyses were $6,392,989. More than $16,096,968 in sewer use charge payments were invoiced through the industrial Source Control Program.

Inspection, Sampling, and Enforcement

OCSD performed 1,492 industrial inspections during the fiscal year, with the collection of 3,679 samples resulting in 18,791 laboratory analyses. Seventy compliance inspections or meetings were held with dischargers in order to identify and assess noncompliance problems, and propose long-term solutions. OCSD conducted four covert downstream sampling projects. Approximately $42,389 in noncompliance sampling fees and penalties were invoiced through the source control program. Twenty-two (one out of business) companies (7%) of the 332 active permittees listed in the Monitoring and Compliance Status report were determined to be in Significant Noncompliance (SNC) and their names were published in the newspaper.

Significant Changes in Operating the Pretreatment Program

There were no significant changes in operating the Pretreatment Program during the reporting period. Changes in the administration of the Pretreatment Program occurred on August 23, 2010. The changes will be documented in the subsequent report.

E.2.2 Pretreatment Program Elements

OCSD administers several different program elements designed to meet the goal of controlling discharges from industrial sources. These have a direct influence on OCSD's ability to meet federal, ocean discharge, biosolids reuse and disposal, and water reclamation requirements.

Public Participation

OCSD published those industries that were in significant non-compliance in the local newspaper.

Wastehauler Program

Currently 38 wastehauler companies are under permit with OCSD, which have a total of 118 trucks. During the past fiscal year, 17 million gallons of waste were discharged by permitted wastehaulers at the Plant No. 1 Wastehauler Station.

Total Toxics Organics Waiver Program

Permittees who have not shown detectable levels of Total Toxic Organics (TTOs) based on their wastewater discharge analytical data for at least one year are eligible to waive the self-monitoring requirement if they can certify that TTOs are not used or present at their facility. For FY 2009/10 OCSD granted 149 TTO waivers.

Industrial Operations and Maintenance Improvement Program

Technical Assistance Center - In 1999/2000, OCSD evaluated the needs of an industrial operations and maintenance program and developed a plan that included outreach and operator training, and enforcement of requirements for operator and operations and maintenance practices. Following EPA’s recommendation, OCSD determined that the majority of violations by industries were due to inadequate operation and maintenance practices of their pretreatment facilities. In response, OCSD developed and implemented the Industrial Operator training

E.3 courses and industrial pretreatment operations and maintenance guidelines that cover practices and recordkeeping for industrial operators.

In August and September 2009, the course trainer completed wastewater audits at 28 industrial facilities with 42 wastewater operators who took the Advance Training Course III in April/May 2009. In October 2009 OCSD received wastewater audit reports from the trainer. The audit reports described each facility’s wastewater pretreatment system/management to evaluate proper implementation of operation and maintenance practices.

In November 2009, OCSD finalized the Advance Training Course III by issuing a Certification of Completion to 33 wastewater operators who passed both the class requirements and facility audit. Nine operators did not pass this course.

In April 2010, OCSD started a Comprehensive Training Course X by sending registration confirmation letters to 32 wastewater operators from 23 industrial facilities. This course consisted of five classes starting from April 13 through May 11, 2010. The course includes wastewater audits at each operator’s facility, which account for 60% of the total score.

The wastewater audits are scheduled to be completed in July 2010.

Non-Industrial Source Control Program

The purpose of OCSD's Non-Industrial Source Control (NISC) Program (Expanded Pretreatment Program) is to promote and implement the application of waste management strategies and practices that will reduce or eliminate the generation of waste at the source, thereby reducing the volume and toxicity of waste streams entering OCSD’s sewerage system. The Expanded Pretreatment Program also addresses non-industrial pollution sources in our light industrial, commercial and residential discharger community, as shown in detail in Chapter 10. Some of the programs included in the Expanded Pretreatment Program are shown below.

Dry Cleaners – OCSD’s Source Control Division determined that dry cleaning operations that had eliminated the usage of PERC from their facilities could forego field inspection if they continued to demonstrate compliance, i.e. zero discharge, by returning their annual certification form. At the end of the certification/inspection cycle on June 4, 2010, 366 of 368 (99.5%) dry cleaners completed their certifications. Hand delivery of a new certification form was given to the 2 outstanding dry cleaners with inspection/enforcement pending.

Radiator Shops - the Radiator Shop Certification Program aims to prevent sewer discharge of heavy metals, oil & grease, and other solvent-containing wastes generated during the draining, cleaning and rebuilding of radiators. If discharged to the sewer, this wastewater has the potential to violate numerous OCSD discharge limits.

The program consists of a biennial certification that the facility does not discharge industrial waste to the sewer. Inspections are conducted to verify information. Radiator shops must achieve zero discharge by close-looping wet process operations and hauling all non-reusable hazardous waste offsite. All floor drains in wet process areas must be sealed, and wastehauling records must be kept on-site for review by Source Control field staff. Recycling systems must have no connection to the sewer.

There are currently 28 radiator shops operating within OCSD’s service area.

Urban Runoff - For more than seven years, OCSD has been collecting and treating urban runoff from 19 diversion systems owned and operated by local agencies within OCSD’s service area. During this fiscal year, the monthly average daily flow was 1.76 million gallons per day.

E.4 Fats, Oil, and Grease (FOG) - OCSD implemented a Fats, Oils, and Grease (FOG) Source Control Program on January 1st, 2005 in response to the California Regional Water Quality Control Board and U.S. E.P.A. Region IX’s Order R8-2004-0062 issued on September 17, 2004. On November 17, 2004 OCSD’s Board of Directors passed Ordinance OCSD-25 authorizing the FOG Program. Ordinance OCSD-25 provides for establishment of the FOG program and enforcement of program requirements by OCSD’s FOG Program Manager and General Manager. The goal of the program is to eliminate Sanitary Sewer Overflows (SSOs) which emanate from Food Service Establishments (FSEs).

During the reporting period, OCSD issued 183 FOG permits to various facilities and 163 compliance inspections were conducted.

E.2.3 Compliance with NPDES Discharge Requirements

There were no plant upsets, interference, or pass-through incidents attributable to industrial users in FY 2009/10.

E.5 chapter 1

NPDES REQUIREMENTS - PRETREATMENT

Pretreatment Requirements – Compliance with National Pollutant Discharge Elimination System (NPDES) Permit Requirements chapter 1 NPDES REQUIREMENTS - PRETREATMENT

1.1 PRETREATMENT REQUIREMENTS - COMPLIANCE WITH NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT REQUIREMENTS

This section is a summary of the pretreatment program requirements contained in OCSD’s NPDES permit jointly issued by the CRWQCB and EPA Region IX. The NPDES Permit No.CA0110604, Order No. R8-2004-0062 is in three sections: 1.) The Fact Sheet; 2.) Waste Discharge Requirements and Authorization to Discharge; and 3.) Monitoring and Reporting Program (M&RP). The requirements for the Source Control Program for FY 2009/10 are listed in the Waste Discharge Requirements and the M&RP. The requirements are shown below (in bold italics) using the appropriate numeration found in the permit. Each requirement is followed by a summary of the activity that has resulted in OCSD’s compliance with the permit requirements, or a reference may be given where additional information can be found in this annual report.

NPDES Waste Discharge Requirements Section E. Pretreatment Requirements

2. The discharger shall enforce the requirements promulgated under Sections 307 (b), 307 (c), 307 (d), and 402(b) of the Clean Water Act (CWA) with timely, appropriate and effective enforcement actions. The discharger shall require all non-domestic users to comply with Federal Categorical Standards and shall take enforcement actions against those users who do not comply with the standards….

OCSD has an ongoing commitment to meeting the provisions of this requirement, and all pretreatment requirements are rigorously enforced as discussed in Chapter 4 of this report. The Wastewater Discharge Regulations (Ordinance) contains specific provisions for new dischargers that are more stringent than those required by 40 CFR 403.

The ongoing quarterly inspection, sampling, and monitoring program for each Class I industry (Significant Industrial Users) ensures compliance with federal, state, and local regulations. The compliance status of all industries subject to federal categorical standards is shown in the Monitoring and Compliance Status Report, presented in Appendix A of this report.

3. The discharger shall perform the pretreatment functions as required in 40 CFR Part 403 including, but not limited to:

a. Implement the necessary legal authorities as provided in 40 CFR 403.8(f)(1).

The legal authorities are contained in OCSD’s July 1983 "Regulations For Use of District Sewerage Facilities" (Ordinance) which were approved by EPA in January 1984, and affirmed during the May 1986 audit. Revised Ordinances, "Wastewater Discharge Regulations", were adopted and became effective September 8, 1989, February 7, 1992, July 1, 1998, July 1, 2008 and October 1, 2009.

1.1 b. Enforce the pretreatment requirements under 40 CFR 403.5 and 403.6.

The requirements to enforce and implement National Pretreatment Standards for general prohibitions and specific industrial subcategories are contained in OCSD’s Ordinance. Chapter 4 of this report describes OCSD’s enforcement efforts for FY 2009/10.

c. Implement the programmatic functions as provided in 40 CFR 403.8(f)(2).

The required functions include the identification, quantification, permitting, and enforcement of the standards set forth in OCSD’s Ordinance. Chapters 3 and 4 of this report describe the permitting and enforcement efforts for FY 2009/10.

d. Provide the requisite funding and personnel to implement the pretreatment program as provided in 40 CFR 403.8(f)(3).

The Source Control Program is funded by industrial permit fees, noncompliance sampling fees, and sewer use charges. The Source Control Division's operating expenditures, including laboratory analyses for FY 2009/10 were $6,392,989. Chapter 6 of this report provides additional details.

4. The discharger shall submit annually to the EPA and Regional Board a report describing its pretreatment activities over the previous year. In the event the discharger is not in compliance with any conditions or requirements of this permit, then the discharger shall also include the reasons for noncompliance and state how and when the discharger shall comply with such conditions and requirements. This annual report shall cover operations from July 1 through June 30 and is due on October 31 of each year. The report shall contain, but not be limited to, the following information:

a. A summary of analytical results from representative, flow-proportioned, 24-hour composite sampling of the discharger's influent and effluent for those pollutants the EPA has identified under Section 307 (a) of the CWA which are known or suspected to be discharged by non-domestic users. This will consist of wastewater sampling and analysis in accordance with the minimum frequency of analysis stated in Monitoring and Reporting Program (M&RP) No. R8-2004-0062. The discharger is not required to sample and analyze for asbestos. The discharger shall also provide any influent or effluent monitoring data for non-priority pollutants which the discharger believes may be causing or contributing to interference or pass through. Sampling and analysis shall be performed with the techniques prescribed in 40 CFR 136.

The influent, effluent, and biosolids sampling information is provided in Chapters 2, 5, and 9 and Appendix B of this annual report.

1.2 b. A discussion of Upset, Interference or Pass Through incidents, if any, at Reclamation Plant No. 1 and/or Treatment Plant No. 2, which the discharger knows or suspects were caused by nondomestic users of the POTW system. The discussion shall include the reasons why the incidents occurred, the corrective actions taken and, if known, the name and address of the nondomestic user(s) responsible. The discussion shall also include a review of the applicable pollutant limitations to determine whether any additional limitations, or changes to existing requirements, may be necessary to prevent pass through or interference;

There were no plant upsets, interference, or pass-through incidents attributable to industrial users in FY 2009/10. c. An updated list of the discharger's Significant Industrial Users (SIUs) including their names and addresses, and a list of deletions, additions and SIU name changes keyed to the previously submitted list. The discharger shall provide a brief explanation for each change. The list shall provide a brief explanation for each change. The list shall identify the SIUs subject to federal categorical standards by specifying which set(s) of standards are applicable to each SIU. The list shall also indicate which SIUs are subject to local limits;

Appendix A of this report, the Monitoring and Compliance Status Report, is an updated list of industrial users which identifies which set of categorical standards applies. d. The discharger shall characterize the compliance status of each SIU by providing a list or table that includes the following information:

1) Name of the SIU; 2) Category, if subject to federal categorical standards; 3) The type of wastewater treatment or control processes in place; 4) The number of samples taken by the POTW during the year; 5) The number of samples taken by the SIU during the year; 6) For an SIU subject to discharge requirements for total toxic organics, whether all required certifications were provided; 7) A list of the standards violated during the year. Identify whether the violations were for categorical standards or local limits; 8) Whether the facility is in SNC as defined at 40 CFR 403.8(f)(2)(vii) at any time during the year; and 9) A summary of enforcement or other actions taken during the year to return the SIU to compliance. Describe the type of action, final compliance date, and the amount of fines and penalties collected, if any. Describe any proposed actions for bringing the SIU into compliance:

This Annual Report contains all of the items listed above in the following sections: Items 1, 2, 4, 5, 7, and 8 are shown in Appendices A and G. Item 3 is shown in Appendix l. Item 6 is shown in Chapter 7. Item 9 is shown in Chapter 4 and Appendix E. e. A brief description of any programs the discharger implements to reduce pollutants from nondomestic users that are not classified as SIUs;

The activities for OCSD's non-industrial and pollution prevention programs are discussed in Chapters 7 and 10.

1.3 f. A brief description of any significant changes in operating the pretreatment program which differ from the previous year including, but not limited to, changes concerning the program's administrative structure, local limits, monitoring program or monitoring frequencies, legal authority, enforcement policy, funding levels, or staffing levels;

The description of significant changes to the pretreatment program, if any, are discussed in Chapter 7.

g. A summary of the annual pretreatment budget, including the cost of pretreatment program functions and equipment purchases; and

For FY 2009/10, the operating expenses for the source control program were approximately $6,392,989. Additional information on the source control costs and purchases are shown in Chapter 6 of this report.

h. A summary of activities to involve and inform the public of the program including a copy of the newspaper notice, if any, required under 40 CFR 403.8(f)(2)(vii).

A copy of the significant non-compliance notice (SNC) for newspaper publication can be found in Appendix F.

I. Special Provisions

1. The discharger will continue to implement its existing nonindustrial source control program and public education program that have been in effect since 1986. The nonindustrial source control program will be supplemented with an updated survey of industrial and nonindustrial contaminant sources. These programs are described in Nonindustrial Source Control Program – Final Report (CSDOC, 1987).

The special non-industrial source control program (expanded pretreatment program) descriptions can be found in Chapter 10. The most recent local limits sampling data is contained in a separate report titled “Non-Industrial Source Control Project, Determination of Domestic Waste Characteristics, March/April 2004”.

1.4 chapter 2

OCSD’s FACILITIES AND COMPLIANCE WITH DISCHARGE REQUIREMENTS

Introduction Existing OCSD Facilities Compliance with National Pollutant Discharge Elimination System (NPDES) Requirements Effluent Characteristics OCSD’s Metal Removals Mass Emission Benchmarks

chapter 2

OCSD'S FACILITIES AND COMPLIANCE WITH DISCHARGE REQUIREMENTS

2.1 INTRODUCTION

The Operations and Maintenance Department (O&M) is responsible for collecting, transporting and treating wastewater, and reusing or disposing of the treated wastewater and the separated solids in accordance with all applicable federal, state and local laws and regulations. The following pages present a summary of the operation of the wastewater treatment and collection facilities, the historical data and the regulatory compliance record for fiscal year (FY) 2009/10 (July 1, 2009 through June 30, 2010). The Orange County Sanitation District (OCSD) is also enrolled in the statewide Waste Discharge Requirements program for sanitary sewers.

OCSD operates and maintains Reclamation Plant No. 1 and Treatment Plant No. 2, and 403 miles of collection system sewers, 176 miles of local sewers, and 15 outlying pump stations. The treatment plants and pump stations are supervised, operated and maintained by highly trained professionals with the appropriate certification from the California State Water Resources Control Board for treatment plant operators, and the appropriate voluntary certification from the California Water Environment Association. A process-flow diagram of the liquid and solids handling facilities at each treatment plant is shown in Figure 2-1. The average daily flow tributary to OCSD per year since 1991 is shown in Table 2.1.

The treated wastewater is discharged into the Pacific Ocean in strict and consistent compliance with state and federal requirements as set forth in OCSD’s NPDES permit. Approximately 81.5 million gallons per day (MGD) of treated wastewater was reclaimed at facilities operated by the Orange County Water District (OCWD) during FY 2009/10. This is higher than last fiscal year’s 68.25 MGD due to the continued ramp-up of the Groundwater Replenishment System (GWRS). The GWRS is capable of producing 70 MGD of highly purified water to replenish the Central Orange County groundwater basin and to protect near coastal groundwater from seawater intrusion. Of the 81.5 MGD of treated wastewater from OCSD, OCWD was able to produce 62 MGD of purified water.

During FY 2009/10, OCSD beneficially recycled 100% of the belt press dewatered biosolids for use as agricultural soil amendments, compost products or as renewable fuel. Total biosolids production for this fiscal year was approximately 245,713 wet tons, down from 249,139 wet tons the prior fiscal year. Solids content averaged 19% for Plant No. 1 and 23% for Plant No. 2. Three management options (land application, composting and renewable fuel) were utilized through three vendor contracts in two states and four counties. OCSD’s Biosolids Management Compliance Report describes the solids management program in more detail.

Grit and screenings are transported under contract for landfill disposal. Debris and grit removed from the sewers during cleaning is dried at Plant No. 1 and then hauled to a landfill for disposal.

In December 2007, the Board of Directors reaffirmed our commitment to recycling biosolids through the Strategic Plan adoption process. The goal is to develop a sustainable, reliable, and economical program for long-range biosolids management, while providing environmentally sound practices that meet the federal, state, and local regulatory requirements. In working towards achieving a sustainable biosolids program, OCSD continues to track innovative biosolids management technologies and remains actively aware of various political and regulatory challenges surrounding biosolids management.

2.1 Wastewater quality data collected from process evaluations, special analyses, and sampling to determine compliance with NPDES permit requirements are tabulated in Appendix B as monthly and annual averages. This tabulation presents general data for Reclamation Plant No. 1 and Treatment Plant No. 2, and the final effluent ocean discharge data.

OCSD’s primary and secondary treatment, digestion, and dewatering facilities were all operated within their respective design capacities for the entire fiscal year; however, secondary treatment facilities at both plants are undergoing significant phased rehabilitation and upgrades for consent order requirements, capacity or life extension.

2.2 EXISTING OCSD FACILITIES

OCSD’s operations start with the collection of wastewater from the residential, commercial and industrial customers in 21 cities, 3 special districts, and portions of unincorporated Orange County (Figure 2-1). The average daily flow tributary to OCSD per year since 1991 is shown in Table 2.1.

OCSD collects and treats dry weather urban runoff from 19 diversion facilities comprising both pumping and gravity systems owned and operated by local agencies in OCSD’s service area. During FY 2009/10, OCSD received cumulative flow volumes of urban runoff that ranged from 0.5 to 2.2 MGD. See Chapter 7 of this Annual Report for more details regarding OCSD’s Urban Runoff Program.

TABLE 2.1 Average Daily Influent and Effluent Flow in Million Gallons Per Day (MGD), Fiscal Years 1990–2010 Orange County Sanitation District, Source Control Division

Fiscal Influent Effluent Fiscal Influent Effluent Year MGD MGD Year MGD MGD 1991* 269 262 2001 246 244 1992* 227* 221 2002 235 231 1993 232 225 2003 239 235 1994 231 233** 2004 238 238 1995 243 244** 2005 244 247** 1996 237 232 2006 234 235** 1997 244 242 2007 229 232** 1998 255*** 255 2008 221 212 1999 241 239 2009 211 167 2000 241 236 2010 207 151**** * Decrease due to drought. ** There was more effluent than influent due to in-plant construction dewatering which was discharged downstream of influent metering. *** El Nino (wet year) **** Decrease due to diverting flow to GWRS

2.2.1 Description of Treatment Plants

Based on population served, OCSD is one of the largest wastewater facilities in the United States. The network of interceptor sewers, treatment units and disposal systems is quite complex. The following sections provide an overview of the treatment facilities.

2.2

Figure 2-1 Process Flow Diagram of Reclamation Plant No. 1 and Treatment Plant No. 2 Orange County Sanitation District

2.3 2.2.1.1 Reclamation Plant No. 1

Reclamation Plant No. 1 is located in the city of Fountain Valley adjacent to the Santa Ana River. The metering and diversion structure, constructed in 1974, allows the excess wastewater from any of six trunk sewers tributary to Plant No. 1 to be diverted to Plant No. 2 to not overload the capacity of Plant No. 1 or to provide for maintenance or construction activities. The metering and diversion structure also contains pH meters, conductivity meters and flow meters to monitor the incoming wastewater on each trunk sewer. This operational flexibility also allows Plant No. 1 to provide the highest quality of wastewater for reclamation at OCWD. Flows from the Santa Ana River Interceptor trunkline, which contains Santa Ana Watershed Project Authority brines, are diverted to Plant No. 2.

The wastewater flows through barscreens with 5/8 inch wide openings where large solids (e.g., rags, non- dispersible materials, plastics, grease chunks) are removed. Wastewater is then pumped to aerated grit chambers where the velocity of the water is slowed to allow coffee grounds, seeds, sand, gravel, and other heavy particulate debris to settle out. All the screenings and grit are hauled by a contractor to a landfill for disposal. Foul air at the treatment plants is captured from the trunk sewers at the metering and diversion structure, headworks structures and grit chambers for treatment in the odor control chemical scrubbers. Four duty and one standby main sewage pumps lift flow to the grit chambers.

For improved performance chemically enhanced primary treatment (CEPT) is done. Ferric chloride and anionic polymer are added to the primary clarifiers to enhance the settling of the organic solids. Each primary clarifier is covered to capture foul air for treatment in scrubbers. Plant No. 1 has a primary treatment capacity of 204 MGD.

During FY 2009/10, 100% of the Plant No. 1 primary effluent received secondary (biological) treatment in either conventional air activated sludge secondary treatment process or trickling filters. An average of 81.5 MGD of the secondary treated water was pumped to OCWD’s GWRS and the Green Acres Project (GAP) for advanced tertiary treatment. Advanced tertiary treatment prepares the water for injection into the groundwater as a barrier against saltwater intrusion, and for percolation to the aquifer for water reclamation and reuse. OCWD also provides GAP water for industrial uses to OCSD. The balance of the Plant No. 1 secondary effluent flows by gravity to Plant No. 2 where it is blended with treated wastewater from Plant No. 2 prior to pumping and ocean disposal. Plant No. 1 effluent is disinfected with sodium hypochlorite (bleach) prior to discharge into the interplant line on the west bank of the Santa Ana River. The treated wastewater flows via gravity to the Plant No. 2 ocean outfall booster station (OOBS) or to the Effluent Pump Station Annex (EPSA). Mixing with Plant No. 2 treated effluent occurs at this time.

Solids collected in the primary and secondary clarifiers are pumped to anaerobic digesters for organic waste stabilization and pathogen destruction at 98 degrees Fahrenheit (°F). Following digestion, the sludge is dewatered using belt filter presses. The belt press dewatered biosolids are removed by private contractors. Stabilization results in the production of digester gas, a fuel which is approximately 65% methane and 35% carbon dioxide. This fuel has a heating value of about 628 Btu/cu.ft. Secondary sludge is thickened in dissolved air floatation (DAF) units prior to digestion. Digester gas is gathered, compressed, cleaned and distributed to the Central Power Generation System (CGS) at each plant as a renewable fuel for energy generation.

At Plant No. 1, natural gas and digester gas fuel three internal combustion engines that power 2,500 kilowatt (kW) electric generators. Only two of the three engine generators operate at one time to meet air quality permit limits. Supplemental power was purchased from Southern California Edison (SCE) to provide for the remainder of the Plant No. 1 energy demand. The internal combustion engines were fueled primarily with digester gas with a small amount (5%) of purchased natural gas added to aid combustion. Excess digester gas is flared by permit to the atmosphere. The interplant gas transmission and storage line remained isolated and out of service.

2.4

Figure 2-2 Map of Orange County Sanitation District’s Service Area Orange County Sanitation District

2.5 2.2.1.2 Treatment Plant No. 2

Treatment Plant No. 2 is located in the city of Huntington Beach near the mouth of the Santa Ana River. Five trunk sewers transport wastewater into the headworks, which contain pH meters, conductivity meters, and flow meters, along with five mechanically cleaned barscreens, twelve main sewage pumps and eight aerated grit chambers. All screenings and grit are hauled by a private contractor to a landfill for disposal. The foul air from the headworks, grit chambers and primary sedimentation basins is collected for treatment in a combination of chemical scrubbers and biotowers.

Ferric chloride and anionic polymer are used to enhance the settling of solids during primary treatment. Settleable and suspended solids, and floatable particulates are removed from the wastewater in primary sedimentation basins and pumped to anaerobic digesters for stabilization.

Sludge from the primary and secondary settling basins is treated in anaerobic digesters. Secondary sludge is thickened in DAF units prior to digestion. Following digestion, the sludge is dewatered using belt filter presses. The belt press dewatered biosolids are removed by private contractors.

The Plant No. 2 CGS has five internal combustion engines that power five 3,000 kW electric generators, and a 1,000 kW steam turbine powered by engine exhaust waste heat. Only two engine generators were usually operated at any one time based on digester gas availability. Excess power was sold to SCE during periods of lower plant use and power is imported during high demand periods. The internal combustion engines were fueled primarily with digester gas with a small amount (7%) of natural gas.

2.2.1.3 Joint Works Facilities

Facilities common to both plants are designated as Joint Works Facilities. These include the bypass sewer to divert sewage from Plant No. 1 to Plant No. 2, effluent lines to convey treated wastewater from Plant No. 1 to Plant No. 2 for blending and ocean discharge, a fiber optic cable line for interplant communication, the currently out of service digester gas transmission and storage line, two outfall booster pumping stations, two ocean outfalls (designated in the NPDES permit as Discharge Serial Nos. 001 and 002), and the emergency gravity overflow flap gate valves into the Santa Ana River (Discharge Serial No. 003).

Secondary effluent from Plant Nos. 1 and 2 is combined with the remaining primary effluent for ocean disposal to OCSD’s main discharge point, the 120-inch diameter, 5-mile long ocean outfall (the last mile of which is a diffuser with 503 ports that provides a minimum of 180:1 dilution). Of the 207 MGD average influent for FY 2009/10, 174 MGD received secondary treatment. Prior to discharge, the chlorinated final effluent is dechlorinated at the outfall booster station with sodium bisulfite. The older 78-inch diameter, one-mile long ocean outfall pipe was not used during this report period.

2.3 COMPLIANCE WITH NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) REQUIREMENTS

On October 31, 2004, the U.S. Environmental Protection Agency, Region IX and CRWQCB jointly reissued Waste Discharge Requirements (WDR) and Authorization to Discharge under the National Pollutant Discharge Elimination System (NPDES No. CA0110604).

This section provides a summary of limitations contained in OCSD’s NPDES permit. Table 2.2 shows NPDES permit discharge requirements and OCSD’s annual average influent and final effluent discharge values for this reporting period.

2.6

TABLE 2.2 NPDES Permit Discharge Requirements and OCSD’s Annual Average Influent and Final Effluent Discharge Values for Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division OCSD’s NPDES Permit Discharge Requirement OCSD’s Combined Final Effluent Compliance Influent Annual 30-Day 7-Day Annual with NPDES Constituent Average Average Average Daily Maximum Average1 Permit Limits Flow, MGD 207 ------151 -- BOD, mg/L 250 100 -- -- 36 Yes BOD, MT/month -- 2,7502 -- -- 620 Yes Suspended Solids, mg/L 309 55 -- -- 30 Yes Suspended Solids, MT/month -- 1,4202 -- -- 518 Yes Grease and Oil, mg/L 59.8 25 40 75 7.4 Yes Grease and Oil, lb/day -- 57,963 92,740 173,889 9,270 Yes Settleable Solids, mL/L -- 1.0 1.5 3.0 0.3 Yes Toxicity, acute Tua ------5.7 1.40 Yes Toxicity, chronic Tuc ------181 63.0 Yes Turbidity, NTU -- 75 100 225 29 Yes pH 7.9 6.0 to 9.0 6.0 to 9.0 9.0 7.8 Yes Total Chlorine Residual, mg/L -- 0.363 -- 1.45 0.61 Yes Total Chlorine Residual, lb/day -- 8343 -- 3,361 765 Yes Benzidine, µg/L ND 0.01249 -- -- ND Yes Benzidine, lb/day -- 0.0290 ------Yes Chlordane, µg/L ND 0.00416 -- -- ND Yes Chlordane, lb/day -- 0.0097 ------Yes 3, 3-dichlorobenzidine, µg/L ND 1.4661 -- -- ND Yes 3, 3-dichlorobenzidine, lb/day -- 3.3992 ------Yes Hexachlorobenzene, µg/L ND 0.0380 -- -- ND Yes Hexachlorobenzene, lb/day -- 0.0881 ------Yes PAHs, µg/L ND 1.5928 -- -- ND Yes PAHs, lb/day -- 3.6929 ------Yes PCBs, µg/L ND 0.0034 -- -- ND Yes PCBs, lb/day -- 0.0080 ------Yes TCDD equivalents, µg/L NR 0.000000706 -- -- < 0.000000421 Yes TCDD equivalents, lb/day -- 0.000001637 -- -- < 0.000000727 Yes Toxaphene, µg/L NR 0.03801 -- -- ND Yes Toxaphene, lb/day -- 0.0881 ------Yes

Additional influent/effluent data is shown in Appendix B -- Not determined 1 Based on the average of the values reported in the monthly Discharge Monitoring Report. For values based on 30-day rolling maximum averages, refer to the Benchmark section of the Source Control and Ocean Monitoring Annual Reports 2 Metric tons/month 3 6-month median 4 Daily maximum ND Non-detectable NR Not required. NPDES Permit requires monitoring and analysis of TCDD equivalents in effluent only.

2.7 2.4 EFFLUENT CHARACTERISTICS

2.4.1 General

The OCSD National Pollutant Discharge Elimination System (NPDES) permit establishes water quality effluent constituent compliance limits for major wastewater parameters and toxic materials. The following sections represent a review of the current and historical compliance status for the major wastewater parameters. Monthly average effluent data are tabulated in Appendix B. Yearly average data for combined effluent TSS and five-day BOD are presented for FY 2009/10 in Figure 2-3. OCSD’s annual average ocean discharge parameters for the past five fiscal years are shown in Table 2.3.

2.4.2 Suspended Solids

During FY 2009/10, the suspended solids discharge was in complete compliance with our NPDES permit effluent limits. The final effluent monthly average suspended solids concentration of 30 mg/L for a monthly average discharge mass emissions rate of 520 metric tons during FY 2009/10, is 55% of the allowable 30-day average concentration limit of 55 mg/L, and 37% of the mass emissions limit of 1,420 metric tons per month. The effluent suspended solids decreased by 80 metric tons from the FY 2008/09 discharge of 600 metric tons per month. The contribution of TSS from each plant process unit is shown in Figure 2.3. The suspended solids mass emissions discharge has decreased from over 33,000 metric tons per year in 1976 to the present level of 6,240 metric tons as major plant improvements came online.

TABLE 2.3 Suspended Solids and BOD Annual Average Daily Influent and Final Effluent for Fiscal Years 2006–2010 Orange County Sanitation District, Source Control Division

SUSPENDED SOLIDS BOD Fiscal Influent Effluent Influent Effluent Year mg/L lb/day mg/L lb/day mg/L lb/day mg/L lb/day

2005-06 262 510,400 34 66,600 236 460,000 49 96,000 2006-07 271 517,900 33 63,900 254 484,800 48 92,900 2007-08 293 539,100 33 58,000 259 477,600 45 79,600 2008-09 297 522,643 31 43,176 250 439,935 40 55,711 2009-10 309 533,451 30 37,780 250 431,595 36 45,336

2.4.3 Biochemical Oxygen Demand (BOD)

The NPDES permit requires a 30-day average discharge limit of 100 mg/L. The discharge was in consistent compliance for FY 2009/10. The final effluent 30-day maximum monthly running average for FY 2009/10 was 38 mg/L, which is slightly higher than the monthly average of 36 mg/L. The contribution of BOD for each plant unit process is shown in Figure 2.3.

2.4.4 Oil and Grease

The NPDES 30-day effluent limit for oil and grease is 25 mg/L and 57,963 lbs/day. The treated effluent averaged 7.4 mg/L or 9,319 pounds per day. The mass discharge represents a decrease from the FY 2008/09 average of 9,471 pounds per day. The oil and grease data for the past five years is summarized in Table 2.4.

2.8 Orange County Water District 81.5 MGD

31 MGD Trickling TBOD 20.9 mg/L Filters TSS 21.2 mg/L

RECLAMATION PLANT NO. 1 111NO. 1

TBOD 9.2 mg/L 98 MGD Primary 75 MGD* Activated CBOD 4.8 mg/L Clarifiers Sludge Influent TBOD 121 mg/L Wastewater TSS 11.5 mg/L Ocean Discharge TSS 66 mg/L TBOD 36 mg/L <1 MGD Outfall CBOD 27 mg/L Booster Primary Effluent Station TSS 30 mg/L TREATMENT PLANT NO. 2 Flow 151 MGD

109 MGD 68 MGD Primary Activated TBOD 5.6 mg/L Clarifiers Sludge Influent Wastewater TSS 8.8 mg/L

41 MGD TBOD 105 mg/L *Does not show recycle stream contributions. Primary Effluent TSS 86 mg/L

DH/YSH

Figure 2-3 Annual Average of Biochemical Oxygen Demand and Total Suspended Solids Contribution from Plant Nos. 1 and 2 Processes for Fiscal Year 2009-10. Orange County Sanitation District, California

2.9

TABLE 2.4 Oil and Grease Average Influent and Final Effluent for Fiscal Years 2006–2010 Orange County Sanitation District, Source Control Division

Fiscal Plant No. 1 Influent Plant No. 2 Influent Combined Influent Final Effluent Year mg/L lb/day mg/L lb/day mg/L lb/day mg/L lb/day

2005-06 66.5 47,700 59.8 73,810 62.3 121,500 9.0 17,600 2006-07 60.5 45,900 62.1 71,470 61.5 117,400 9.4 18,200 2007-08 62.5 47,900 71.9 77,400 68.0 125,300 8.8 15,600 2008-09 67.3 48,270 66.3 69,118 66.7 117,375 6.8 9,471 2009-10 65.5 53,534 54.6 49,635 59.8 103,237 7.4 9,319

2.4.5 Settleable Solids

The 30-day average permit limit for settleable solids is 1.0 milliliter per liter (mL/L) with a maximum at any time of 3.0 mL/L. The FY 2009/10 average for settleable solids was 0.3 mL/L. On November 19, 2009 at 2010 hours, the final effluent settleable solids grab sample result was 12.0 mL/L. This resulted in an exceedance of the ‘maximum at any time’ permit limit of 3.0 mL/L. The cause of this operational upset was attributed to the Plant No. 1 activated sludge plant nitrification/denitrification mode verification test. The operational upset was corrected immediately by employing several of the corrective actions listed in the OCSD Process Verification Study plan. The plan was submitted to the Santa Ana Regional Water Board to satisfy the Water Code Section 13385(j)(D) and receive regulatory relief from the non-compliance incidents associated with the start-up of new or reconstructed wastewater treatment facilities. A summary of the annual average settleable solids data for the past five years is shown in Table 2.5.

2.4.6 Turbidity

Turbidity is a measurement of the microscopic suspended solids or finely divided silty particles in water discharged to the ocean. The compliance limit for turbidity is 75 nephelometric turbidity units (NTU) based on a 30-day average. The FY 2009/10 average turbidity was 29 NTU, which is 61% less than the compliance limit. The turbidity of the ocean discharge increased slightly from 25 NTU last fiscal year. A summary of the turbidity data for the past five years is shown in Table 2.5.

TABLE 2.5 Settleable Solids, Turbidity, and pH, Average Final Effluent for Fiscal Years 2006–2010 Orange County Sanitation District, Source Control Division

Fiscal Settleable Solids Turbidity Year mL/L NTU pH 2005-06 0.2 27 7.8 2006-07 0.2 25 7.8 2007-08 0.2 28 7.8 2008-09 0.2 25 7.9 2009-10 0.3 29 7.8

2.4.7 pH

According to OCSD’s NPDES permit, the pH of the ocean discharge shall neither exceed 9.0 nor be less than 6.0. The effluent was in compliance throughout FY 2009/10. The annual mean pH was 7.8,

2.10 well within the high and low pH effluent limits. The ocean discharge pH has remained relatively constant over the past five years, as summarized in Table 2.5.

2.4.8 Toxicity

The NPDES permit requires that the effluent be tested monthly for chronic toxicity, and quarterly for acute toxicity. Results of acute toxicity tests are reported in acute toxicity units (TUa), which is an expression of the effluent concentration that would cause mortality in half of the organisms tested. Chronic toxicity test results are reported in chronic toxicity units (TUc), which is an expression of the highest effluent concentration to which the organisms were exposed, without observable adverse effects.

Every two years, the effluent must be tested using the species listed in the NPDES permit to determine which species are most sensitive to the effluent. The determined most sensitive test species are used as the test organisms for the next two years. During the months of April 2009 through June 2009 acute toxicity tests were performed to determine the most sensitive of two acute test species, Atherinops affinis and Mysidopsis bahia. The most sensitive acute test species was the topsmelt, Atherinops affinis. During the months of July 2009 through September 2009 chronic toxicity tests were performed to determine the most sensitive of three chronic test species the giant kelp, Macrocystis pyrifera, the purple sea urchin, Strongylocentrotus purpuratus, and the topsmelt. No toxicity was observed utilizing all three chronic test species, for historical comparative purposes OCSD continued chronic toxicity testing using the purple urchin as the most sensitive test species. Consequently, FY 2009/2010 monthly chronic and quarterly acute testing was conducted with the purple sea urchin and the topsmelt, respectively.

Table 2.6 summarizes the toxicity testing results for fiscal years 2006 through 2010. As in previous years, the toxicity of OCSD’s effluent for FY 2009/2010 remains generally low. All chronic toxicity test TUc values were below the limit of 181. The October 2009 and March 2010 chronic toxicity tests had a TUc value of 100.00. All remaining chronic toxicity test results (n=10 tests) were 55.56 TUc, which, because of the dilutions performed on the effluent prior to testing, is the lowest possible TUc value (a TUc of 0.0 is not achievable). Acute toxicity test results with topsmelt (n=4 tests) were well below the permit limit of 5.7 TUa and ranged from <1.43 TUa in April 2010 to 1.98 TUa in October 2009. Considering the 180:1 dilution of the final effluent at the point of discharge, these levels of survival indicate minimal potential for toxicity in the environment. All data has been previously reported to the EPA.

Table 2.6 Final Effluent Yearly Average Toxicity Values for Fiscal Years 2006-2010. Orange County Sanitation District, Source Control Division

Fiscal Year Toxicity 2005-2006 Acute (A. affinis) 2.48 TUa Chronic (S. purpuratus) 55.6 TUc 2006-2007 Acute (A. affinis) 2.22 TUa Chronic (S. purpuratus) 73.3 TUc 2007-2008 Acute(1) (A. affinis) 1.54 TUa Chronic (S. purpuratus) 59.3 TUc 2008-2009 Acute (A. affinis) 2.12 TUa Chronic (S. purpuratus) 59.3 TUc 2009-2010 Acute(1) (A. affinis) 1.40 TUa Chronic (S. purpuratus) 63.0 TUc

(1) Acute test TUa values of <1.43 were converted to a zero in order to calculate the yearly average.

2.11

2.4.9 Outfall Disinfection

The disinfection program initiated in 2002 calls for use of sodium hypochlorite (bleach) for disinfection and sodium bisulfite for dechlorination. The goal of the disinfection program is to comply with the California Ocean bacteria requirements at the ocean outfall discharge, which require that total coliform levels not exceed 1,000 most probable number (MPN)/100 milliliter (mL) (30-day mean). OCSD’s outfall diffuser provides a 180 to 1 dilution of seawater and treated effluent. Based on the dilution rate, the goal is to reduce the effluent total coliform bacteria from the approximate influent concentration of 25,000,000 MPN/100 mL to less than 180,000 MPN/100 mL. The residual hydrochloric acid in the ferric chloride solution added to the CEPT lowers the wastewater pH, which enhances the efficiency of the bleach and increases the bacteria-reduction rate.

The bleach feed is controlled by selecting dosage rates needed to reduce bacteria to the required levels. The bleach-feed pumps are then automatically flow-paced according to the plant influent and activated sludge plant effluent flows. During FY 2009/10, the bleach dosage at Plant No. 2 for influent raw sewage normally ranged between 21 parts per million and 28 parts per million, based on influent sewage quality, and 3 parts per million to 9 parts per million for the secondary effluent flow. The disinfection-bleach usage in FY 2009/10 was 5,350,000 gallons, compared to 7,120,000 gallons in FY 2008/09. This 1,770,000-gallon decrease was due to optimization efforts by Operations & Maintenance staff, as well as to more flow being routed to Plant No. 1 for treatment and reclamation.

In FY 2009/10, the 30-day running-geometric mean was maintained below the operating goal of 100,000 MPN/100 mL and generally ranged between 40,000 and 60,000 MPN, accounting for a 99.8% decrease from the pre-disinfection level. OCSD also complied with the National Pollutant Discharge Elimination System (NPDES) permit effluent-chlorine-residuals limit of less than 0.36 mg/L (six-month median), with a non-detectable fiscal year average.

2.5 METALS

The concentrations of seven metals (cadmium, chromium, copper, lead, nickel, silver, and zinc) are monitored by OCSD for seven days in July, October, January, and April, and once for the remaining months of the year. The results of these analyses are used to evaluate efficiencies, trend inputs from discrete sources, and potential toxic concentrations in the secondary facilities, anaerobic digesters, and dewatered sludges.

The average metal concentrations in OCSD’s influent and effluent for the last five years are shown in Table 2.7. During this time, there has been a 7% decrease in the total influent metals loadings and a 32% decrease in the total effluent metals mass emissions. Chapter 5 presents additional information on the industrial sources of non-compatible pollutants.

2.12 TABLE 2.7 Average Metal Concentrations and Mass in the Influent and Effluent for Fiscal Years 2006–2010 Orange County Sanitation District, Source Control Division

INFLUENT EFFLUENT Constituent 05-06 06-07 07-08 08-09 09-10 05-06 06-07 07-08 08-09 09-10 Cadmium mg/L 0.00051 0.00024 0.00031 0.00022 0.00014 0.0001 0.00007 <0.00007 <0.00007 0.00007 lb/day 1 0.5 0.6 0.4 0.2 0.2 0.1 <0.1 <0.1 <0.1 Chromium mg/L 0.0076 0.0082 0.0084 0.0080 0.0074 0.00149 0.0016 0.0018 0.0017 0.00158 lb/day 15 16 15 14 13 3 3 3 2 2 Copper mg/L 0.0999 0.1043 0.0989 0.1023 0.1051 0.0243 0.0260 0.0251 0.0270 0.0222 lb/day 195 199 182 180 181 48 50 44 38 28 Lead mg/L 0.00368 0.00336 0.00302 0.00303 0.00345 0.0005 0.00047 0.00035 0.00043 0.00029 lb/day 7 6 6 5 6 1 1 0.6 0.6 0.4 Nickel mg/L 0.0180 0.0154 0.0139 0.0140 0.0133 0.0127 0.100 0.103 0.0130 0.0134 lb/day 35 29 26 25 23 25 19 18 18 17 Silver mg/L 0.0041 0.00375 0.00326 0.00280 0.00229 0.00072 0.00072 0.00046 0.00033 0.00026 lb/day 8 7 6 5 4 1 1 0.8 0.5 0.3 Zinc mg/L 0.1409 0.1481 0.1441 0.1604 0.1580 0.0316 0.0330 0.0343 0.0370 0.0374 lb/day 275 283 266 282 273 62 64 61 52 47 Total Average lb/day 536 541 502 512 500 140 139 127 111 95

2005-06 Influent mass based on 234 MGD 2005-06 Effluent mass based on 235 MGD 2006-07 Influent mass based on 229 MGD 2006-07 Effluent mass based on 232 MGD 2007-08 Influent mass based on 221 MGD 2007-08 Effluent mass based on 212 MGD 2008-09 Influent mass based on 211 MGD 2008-09 Effluent mass based on 167 MGD 2009-10 Influent mass based on 207 MGD 2009-10 Effluent mass based on 151 MGD

2.6 MASS EMISSION BENCHMARKS

OCSD’s National Pollutant Elimination Discharge System (NPDES) permit (Order R8-2004-0062, NPDES Permit No. CA0110604) contains Mass Emission Benchmarks for 72 constituents identified in Section B.4 (Table B-2) of the Monitoring and Reporting Program. These mass emission benchmarks are not water quality-based effluent limits; however, OCSD will use this information as part of its annual evaluation of local limits.

The mass emission benchmarks report is required to compare each constituent’s sample result with the minimum level (ML) for that constituent contained in the permit. According to the permit requirement, sample results that are less than the reported ML but greater than the method detection limit (MDL) are to be reported as zero prior to calculating the 12-month constituent average. Some of the values in the Mass Emission Benchmarks report differ from those found in the Priority Pollutants report since the former relies on the ML as the threshold of detection while the latter uses the MDL as the threshold for reporting.

One metal constituent, selenium, exceeded its benchmark (1.92 MT/year) by 1.24 MT/year (64.7%). OCSD is investigating sources of selenium into the treatment plant system. Trunkline sampling in 2010 indicates that the selenium mass flow rate is up by 206% in the A&B Trunk, 208% in the Interplant (SARI) Trunk, and 63% in the Coast Trunk in comparison to the 2008 mass flow rates. Mass flows in the other trunklines did not significantly change from 2008. Note that Newport Beach coastal communities are tributary to the A&B Trunk, Huntington Beach coastal communities are tributary to the Coast Trunk and SAWPA dischargers are tributary to the Interplant Trunk. Construction-related selenium discharges from capital improvement projects at both treatment facilities have significantly diminished. A source investigation of dischargers tributary to these trunklines is slated for FY 2010-11.

2.13 Most of the heavy metal results fell in the range of 10 to 50% of their respective benchmarks with the exception of selenium. Unlike many of the benchmarked organic constituents, OCSD had extensive historic heavy metals sampling frequencies and detectable levels on which to base its benchmarks. As a result, the heavy metal data has less statistical variance from the established benchmarks. With continuing improvements in the pretreatment program, the heavy metals benchmark results verify the decreasing mass emission trends since constituents are less than their historic values. Heavy metals are covered under existing local pretreatment limits. The local limits for those constituents will be evaluated during the next annual local limits review.

Most of the organic compounds with benchmarks were rarely detected in the effluent. As a result, 65 organic and metal constituents reached only a small fraction (<10%) of their respective benchmarks. More than half of the 72 constituents were not detected in OCSD’s effluent, and are listed as zero (0) metric tons/year emitted and zero (0) percent of the benchmark. Historically, these constituents were rarely detected in OCSD’s effluent, so the benchmarks could only be based on the method detection limits (MDL). As OCSD continues to increase the sensitivity of its detection limits, some constituents may be discernible in the future. As detection limits are lowered, there will likely be fewer zero-tons-emitted constituents in OCSD’s list of benchmarks.

2.14 TABLE 2.8 Mass Emissions for All Benchmark Constituents – Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

2009-10 2009-10 2009-10 2008-09 2007-08 12-Mo. Avg 12-Mo. Avg % of % of % of Min. Max. Std. Dev. No. of Freq. Avg. Max. Constituent Benchmark Actual Benchmark Benchmark Benchmark (Mass) (Mass) (Mass) Analysis Detected Avg. Flow Conc. MDL

MT/Year MT/Year Percent Percent Percent Tons/Year Tons/Year Tons/Year Count Count MGD g/L g/L 1,1,1-trichloroethane 7.13 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.30 1,1,2,2-tetrachloroethane 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.12 1,1,2-trichloroethane 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.10 1,1-dichloroethene 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.72 1,2-dichloroethane 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.06 1,3-dichloropropene 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.91 1,4-Dichlorobenzene 7.68 0.000 0.00% 0.00% 1.59% 0.000 0.000 0.0000 12 0 166.92 0.00 0.69 2,4,6-Trichlorophenol 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.86 2,4-Dinitrophenol 76.81 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.84 2,4-Dinitrotoluene 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.62 3,3'-Dichlorobenzidine 4.989 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.49 4,6-Dinitro-2-methylphenol 76.81 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.63 Acrolein 24.96 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 3.7 Acrylonitrile 18.06 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.39 Aldrin 0.08 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.005 Antimony 19.2 0.306 1.60% 2.07% 1.92% 0.136 0.305 0.0394 38 38 166.92 1.34 0.23 Arsenic 1.92 0.984 51.24% 49.72% 45.24% 0.538 1.197 0.1603 38 38 154.99 4.64 0.47 Azobenzene 15.40 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.60 Benzene 3.23 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.07 Benzidine 76.81 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 2.5 Beryllium 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 38 0 166.92 0.00 0.06 Bis(2-Chloroethoxy)methane 15.4 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.73 Bis(2-Chloroethyl)ether 15.40 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.92 Bis(2-Chloroisopropyl)ether 15.4 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.73 Bis(2-Ethylhexyl) phthalate 36.67 0.000 0.00% 0.00% 2.90% 0.000 0.000 0.0000 12 0 166.92 0.00 3.1 Cadmium 0.55 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 56 0 166.92 0.00 0.07 Carbon tetrachloride 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.28 Chlordane total 0.76 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.013 Chlorobenzene 1.91 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.11

2.15 TABLE 2.8 Mass Emissions for All Benchmark Constituents – Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

2009-10 2009-10 2009-10 2008-09 2007-08 12-Mo. Avg 12-Mo. Avg % of % of % of Min. Max. Std. Dev. No. of Freq. Avg. Max. Constituent Benchmark Actual Benchmark Benchmark Benchmark (Mass) (Mass) (Mass) Analysis Detected Avg. Flow Conc. MDL

MT/Year MT/Year Percent Percent Percent Tons/Year Tons/Year Tons/Year Count Count MGD g/L g/L Chloroform 2.74 1.903 69.44% 63.93% 63.68% 0.952 2.993 0.7080 12 12 151.26 8.71 0.1 Chromium 2.94 0.388 13.21% 18.20% 18.35% 0.150 0.508 0.0919 56 56 166.92 1.69 0.21 Copper 31.52 6.287 19.95% 23.17% 26.58% 3.200 6.302 0.7326 56 56 163.89 27.61 0.26 Cyanide 7.75 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 4.88 DDT 0.26 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.016 Dichlorobenzenes 15.4 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.52 Dieldrin 0.08 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.007 Diethyl phthalate 13.65 0.711 5.21% 5.94% 8.26% 0.000 0.818 0.2071 12 11 166.33 3.08 1.3 Dimethyl phthalate 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.54 Di-n-butyl phthalate 15.39 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.75 Endosulfan 0.23 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.012 Endrin 0.04 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.01 Ethylbenzene 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.12 Fluoranthene 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.49 Halomethanes 13.44 0.172 1.28% 1.45% 1.26% 0.000 0.545 0.2375 12 3 152.76 0.72 0.66 HCH 0.30 0.000 0.00% 0.29% 0.32% 0.000 0.000 0.0000 12 0 166.92 0.00 0.021 Heptachlor 0.08 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.009 Hexachlorobenzene 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 15 0 166.92 0.00 0.43 Hexachlorobutadiene 15.40 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.33 Hexachlorocyclopentadiene 15.40 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 1.1 Hexachloroethane 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.60 Isophorone 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.77 Lead 1.29 0.061 4.73% 6.01% 9.82% 0.000 0.313 0.0536 56 6 166.92 0.27 0.43 Mercury 0.08 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 31 0 166.92 0.00 0.006 Methylene chloride 19.20 0.246 1.28% 0.73% 0.57% 0.000 1.330 0.4017 12 3 152.44 1.10 0.61 Nickel 10.55 2.892 27.41% 29.93% 31.98% 1.842 3.505 0.3695 56 56 166.92 12.57 0.81 Nitrobenzene 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.62 N-Nitrosodimethylamine 4.61 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 2.7 N-Nitrosodiphenylamine 7.68 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.65 PAH's 99.854 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.58 PCB's 13.44 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.30 Selenium 1.92 3.162 164.68% 139.92% 110.39% 1.564 4.045 0.7050 38 38 154.99 15.05 0.32 Silver 2.67 0.073 2.75% 4.90% 8.69% 0.000 0.128 0.0324 56 39 166.92 0.32 0.05 TCDD Equivalents 19.21 4.00E-08 <0.01% <0.01% <0.01% 0.00E+00 9.32E-08 4.33E-08 4 3 155.19 1.64E-07 N/A Tetrachloroethene 1.92 0.040 2.07% 1.77% 0.00% 0.000 0.000 0.0000 12 0 157.01 0.17 0.17

2.16 TABLE 2.8 Mass Emissions for All Benchmark Constituents – Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

2009-10 2009-10 2009-10 2008-09 2007-08 12-Mo. Avg 12-Mo. Avg % of % of % of Min. Max. Std. Dev. No. of Freq. Avg. Max. Constituent Benchmark Actual Benchmark Benchmark Benchmark (Mass) (Mass) (Mass) Analysis Detected Avg. Flow Conc. MDL

MT/Year MT/Year Percent Percent Percent Tons/Year Tons/Year Tons/Year Count Count MGD g/L g/L Thallium 3.84 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 38 0 166.92 0.00 0.01 Toluene 3.98 0.074 1.86% 1.73% 2.52% 0.000 0.000 0.0000 12 0 157.01 0.32 0.07 Total Chlorinated Phenols 27.6 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.86 Total Non-Chlorinated Phenols 218 1.285 0.59% 0.77% 0.83% 0.791 1.437 0.2029 12 12 159.13 5.77 1.0 Toxaphene 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.078 Trichloroethene 1.92 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.17 Vinyl chloride 3.84 0.000 0.00% 0.00% 0.00% 0.000 0.000 0.0000 12 0 166.92 0.00 0.60 Zinc 40.70 8.596 21.12% 24.64% 26.28% 4.571 15.399 2.0097 56 56 166.92 37.27 0.76

2.17 chapter 3

PERMITS

Introduction Permit Classifications Permit Issuance Discharge Limits Establishing Mass Emission Rates (MER)

chapter 3

PERMITS

3.1 INTRODUCTION

The Orange County Sanitation District’s (OCSD) Industrial Wastewater Discharge Permit System was implemented to establish control mechanisms which contain effluent limits for all standards; statements of duration and non-transferability; self-monitoring, sampling, reporting, record keeping and notification requirements; and statements of applicable civil and criminal penalties for discharge violations. The following sections describe the different classifications of permits, how new permittees are identified, and how discharge limits are established.

3.2 PERMIT CLASSIFICATIONS

There are six permit classifications for users that discharge waste to OCSD’s sewerage system: Class I, Class II, Wastehaulers, Special Purpose, Ur ban Runoff, and FOG (Fats, Oils, and Grease).

Class I Permits

Class I dischargers are defined as Significant Industrial Users (SIUs) in accordance with federal regulations. These users include plating shops, printed circuit board shops, large food processors and textile companies with high-volume flows, and industries capable of discharging non-compatible pollutants. A listing of the Class I permittees is given in Appendix A.

A Class I Permit is issued to any user who meets any one of the following conditions:

1. Is subject to federal Categorical Pretreatment Standards; or

2. Averages 25,000 gallons per day or more of regulated process wastewater; or

3. Is determined by the General Manager to have a reasonable potential for adversely affecting OCSD’s operation or for violating any pretreatment standard, local limit, or discharge requirement; or

4. May cause, as determined by the General Manager, pass through or interference with OCSD’s sewerage facilities.

Class II Permits

Class II permittees include commercial enterprises such as restaurants, supermarkets, and coin-operated laundries.

A Class II Permit is issued to any user who meets all of the following conditions:

1. Has a charge for use greater than the ad valorem tax basic levy allocated to OCSD; and

2. Discharges waste other than sanitary; and

3. Is not otherwise required to obtain a Class I permit.

3.1

Wastehauler Permits

Wastehauler permits are issued to those users who are engaged in vehicular transport and subsequent disposal of biodegradable waste into OCSD's system. Wastehauler permittees dispose of septic tank/cesspool, restaurant grease trap and portable toilet wastes at OCSD’s dedicated disposal facility located at Reclamation Plant No. 1 in Fountain Valley. The discharge of industrial wastewater by any wastehauler is prohibited unless written permission of OCSD’s General Manager has been obtained.

Special Purpose Permits

Special Purpose permits are issued to dischargers for the purpose of discharging groundwater, surface run-off, subsurface drainage, or unpolluted water directly or indirectly to OCSD’s facilities, on a temporary basis, when no alternative method of disposal is reasonably available, or to mitigate an environmental risk or health hazard. This presently includes groundwater remediation projects.

Urban Runoff Permits

Urban Runoff is contaminated water that is the result of daily activities such as over-irrigating landscape, cleaning streets and sidewalks, and washing cars. OCSD enforces wastewater discharge limits by issuing permits to urban runoff dischargers to ensure that the quality of wastewater does not compromise OCSD’s facilities.

FOG (Fats, Oil, and Grease) Permits

OCSD is administering the local FOG Program for Food Service Establishments (FSEs) that discharge to sewer lines in the City of Tustin area which are maintained by OCSD. Ordinance OCSD-25 provides for establishment of the FOG program and enforcement of program requirements by OCSD’s FOG Program Manager and General Manager. The goal of the program is to eliminate Sanitary Sewer Overflows (SSOs) which emanate from FSEs. Additional information can be found in Chapter 7.

3.3 PERMIT ISSUANCE

At the end of FY 2009/10, the Source Control Division managed 714 active permits as summarized in Table 3.1. The reduction in the number of Class II permits during this reporting period is the result of the Source Control program no longer permitting medical centers. Forty-six (46) companies went out of business during the fiscal year: 11 Class I permits, 21 Class II permits and 14 Special Purpose permits.

TABLE 3.1 Number of Permits Administered for Fiscal Years 2006–10 Orange County Sanitation District, Source Control Division

Fiscal Special Urban Year Class I Class II Wastehauler Purpose Runoff FOG Total

2005-06 373 76 36 91 17 145 738

2006-07 351 73 43 90 17 191 765

2007-08 338 69 42 92 18 191 750

2008-09 321 69 41 92 18 190 731

2009-10 332 46 43 92 18 183 714

3.2

This level of permit activity represents a 2% decrease compared to the total number of active permits in the previous fiscal year. Of the 332 Class I permittees (significant industrial users), 213 were subject to Federal Categorical Pretreatment Standards. There are an additional 119 industrial permittees that are not categorical, but discharge 25,000 gallons per day or more of process water, or have a reasonable potential for adversely affecting OCSD’s plant operations or for violating any pretreatment standard or requirement.

TABLE 3.2 Number of Permits Subject to Federal Categorical Pretreatment Standards During Fiscal Year 2009-2010 Orange County Sanitation District, Source Control Division

Category 40CFR Reference Count

ALUMINUM FORMING 467 11

CENTRALIZED WASTE 437 1 TREATMENT-A,B,C

COIL COATING 465 2

ELECTRICAL & ELECTRONIC 469 7

ELECTROPLATING <10K 413 1

ELECTROPLATING >10K 413 4

ELECTROPLATING-PM >10K 413 2

METAL FINISHING PSES 433.15 12

METAL FINISHING PSNS 433.17 152

METAL MOLDING & CASTING 464 1

NONFERROUS METALS 471 2 FORMING

NONFERROUS METALS MFG 421 1

PHARMACEUTICAL - PART D 439 6

PULP-PAPER-PAPERBOARD 430 1

RUBBER MANUFACTURING - 428 2 PART G

SOAP-DETERGENT MFG 417 8

Total 213

3.3

3.3.1 Identification of New Permittees

Each year, OCSD has access to various listings for companies that may be subject to Federal Categorical Standards or local limits. Wastewater permits are issued to those firms as required. OCSD subscribes to an industrial listing service which provides a list of companies in Orange County. In addition to that listing service, OCSD periodically checks the following:

Internet Business Listings Telephone books Business licenses Newspaper advertisements Industry, trade or association magazines Review of the County of Orange Health Care Agency, Hazardous Waste Division list of hazardous waste generators

These sources are used primarily to identify new Class I users. Identification of new Class II users may be done by a computerized or manual search of water purveyor records or local cities' business licenses. Some city building departments also contact OCSD’s Source Control Division when they become aware a new industry has located in their city. The majority of new companies are identified by Source Control inspectors while out inspecting and sampling current permittees.

3.4 DISCHARGE LIMITS

3.4.1 Industrial

In 1976, OCSD established discharge limits for specific pollutants. These limits became increasingly restrictive over a three-phased implementation period designed to give industry adequate time to comply with the more stringent standards. All of the limiting values were adopted by OCSD’s Boards of Directors in 1976 and were published in OCSD’s Regulations for Use of District Sewerage Facilities (Discharge Ordinance). New concentration limits were adopted in the revised Discharge Ordinance, which became effective July 1, 1983.

On September 8, 1989, the Boards of Directors adopted a new ordinance entitled Wastewater Discharge Regulations (Ordinance) which contained essentially the same concentration limits as the previous Discharge Ordinance. Revisions consisted of creating a specific limit of 0.1 milligrams per liter (mg/L) for polychlorinated biphenyls (PCB), and a limit of 0.1 mg/L for pesticides, and creating specific limits for wastehaulers. It also included specific discharge limits for biochemical oxygen demand (BOD). The daily maximum BOD limit is 15,000 pounds per day (lb/day). These limits were established to prevent pass- through and interference.

The 1989 Ordinance was subsequently revised in February 1992, July 1998, July 2007, July 2008 and October 2009, but with no change to the local discharge limits (see Table 3.3). Since the implementation of the Federal Categorical Standards in April 1984, OCSD applies either the Federal Categorical Standards or OCSD’s local discharge limits, whichever are the more stringent.

3.4.2 Wastehaulers

After evaluating reference materials from the EPA and laboratory results from wastehauler samples taken by OCSD, pollutant limits were established for wastehaulers discharging domestic waste that approximate the maximum expected heavy metal concentrations from domestic wastes found in septic tank/cesspool wastes. These limits are shown in Table 3.3.

3.4

TABLE 3.3 OCSD’s Maximum Allowable Discharge Limits in Milligrams Per Liter (mg/L) Orange County Sanitation District, Source Control Division

Limit Limit Constituent (mg/L) Constituent (mg/L)

Arsenic 2.00 Cyanide (Total) 5.00 Cadmium 1.00 Cyanide (Amenable) 1.00 Chromium (Total) 2.00 Polychlorinated Biphenyls 0.01 Copper 3.00 Pesticides 0.01 Lead 2.00 Total Toxic Organics 0.58 Mercury 0.03 Sulfide (Total) 5.00 Nickel 10.00 Sulfide (Dissolved) 0.50 Silver 5.00 Oil and Grease of Mineral 100 or Petroleum Origin Zinc 10.00

Maximum Allowable Discharge Limits for Wastehaulers Discharging Domestic Septage Constituent Limit (mg/L)

Cadmium 1.0 Chromium 2.0 Copper 25.0 Lead 10.0 Nickel 10.0 Zinc 50.0

3.5 ESTABLISHING MASS EMISSION RATES (MER)

OCSD uses a dual approach to regulating wastewater constituents. In order to encourage water conservation, waste minimization, and recycling; to limit the total pounds of pollutants that enter the treatment facilities; and to deter achieving compliance through dilution; permits are issued with both concentration-based limits and mass emission limits. For concentration limits, OCSD applies either the Federal Categorical Standards or OCSD’s local discharge limits (shown in Table 2.2), whichever are the more stringent. Allowable mass emission rates are calculated using the applicable concentration limits in combination with an industry's three-year average wastewater flow (or base flow rate). The base flow rate is determined at the time a permit is initially issued or reissued.

The volume of wastewater used in establishing a permittee's limits is based on water meter information or additional substantiating reports submitted to OCSD. All new companies locating within OCSD’s service area are issued mass emission rates (MERs), usually calculated on an estimated daily city water meter use until a sufficient water usage/discharge data base can be established. This process typically takes about one year. Unless additional water losses can be substantiated, 95% of the influent city water meter reading is considered to be discharged to the sewer. The remaining 5% is a standard allowance for losses in process, evaporation, and landscaping. An allowance for domestic waste is computed based on a daily

3.5

usage rate of 25 gallons per employee per 8-hour shift. If there is documentation showing other water losses, such as product water loss or boiler loss, that are greater than the standard 5% deduction, then adjustments can be made to accommodate these losses. If water conservation beyond normal industrial practice takes place, the permitted flow may be adjusted to account for water conservation and/or water recycling.

The user's annual average industrial wastewater discharge, calculated as described above, is divided by the number of days worked per year to yield the net discharge in gallons per day. Also, because the limit in lbs/day provides a pollutant "ceiling", the user is prevented from introducing large quantities of water in an attempt to dilute concentrations to meet categorical requirements. If an industrial discharger wishes to increase production by expanding capacity or by increasing the number of hours worked, pretreatment capabilities must be increased to meet the future requirements to ensure long-term compliance with the applicable limits.

If a permittee exceeds the MER or concentration discharge limits, the violation is subject to a noncompliance sampling fee as specified in the Ordinance Establishing Source Control Fees, Admini- strative Fees, Non-Compliance Sampling Fees, and Miscellaneous Charges, and may be subject to administrative penalties as provided in the WDR Ordinance.

3.6 chapter 4

INSPECTION, SAMPLING, COMPLIANCE, ENFORCEMENT

Introduction Routine Sampling and Inspection Non-Routine Sampling and Inspection Orange County Hazardous Materials Strike Force (Strike Force) Industrial Compliance Status with Discharge Limits Enforcement Activities Enforcement Summary Joint Agency Inspections

chapter 4

INSPECTION, SAMPLING, COMPLIANCE, ENFORCEMENT

4.1 INTRODUCTION

This chapter details the inspection, sampling, and enforcement activities of the Orange County Sanitation District's (OCSD) industrial source control enforcement program for FY 2009/10.

OCSD's industrial wastewater enforcement program has the goals of bringing Significant Industrial Users (SIUs) into compliance with federal pretreatment standards, and OCSD's Wastewater Discharge Regulations (Ordinance) and discharge limits; and controlling and reducing industrial pollutants. As provided in the Ordinance, OCSD has a broad range of enforcement mechanisms available including assessing noncompliance sampling fees; administrative penalties; issuing Notices of Violation, compliance letters, Probation Orders, Enforcement Compliance Schedule Agreements (ECSA), Emergency Suspension Orders, and instituting Permit Suspension and Permit Revocation Orders.

OCSD’s enforcement program is designed to bring noncompliant industries back into conformance with federal pretreatment standards and OCSD’s local discharge limits. If permittees violate a discharge limit, enforcement action is initiated. This includes the assessment of noncompliance sampling fees and additional sampling. Subsequent noncompliance may result in issuing an order detailing corrective measures, requiring the installation of additional pretreatment equipment, requiring the implementation of pollution prevention measures, issuing Emergency Suspension Orders, or suspending or revoking the discharge permit.

An individual industrial discharge status summary of all Class I permittees is provided in the Monitoring and Compliance Status Report for FY 2009/10 (Appendix A of this report). The following sections describe OCSD’s enforcement efforts and summarize permittees' compliance with EPA Categorical Standards and OCSD’s local limits.

4.2 ROUTINE SAMPLING AND INSPECTION

OCSD’s field staff consists of 1 Source Control Supervisor, 1 Senior Environmental Specialist, 9 Source Control Inspectors, and 3 Source Control Technicians who provide a visible presence and deterrence through on-site sampling and inspections. The Source Control Division inspectors sample and inspect each Class I permittee at least once every three months for regulated constituents. Class II permittees are also inspected and monitored if their discharges are known to contribute significant amounts of biochemical oxygen demand (BOD), total suspended solids (TSS), or oil and grease (O&G).

These inspections may include evaluation of waste manifests, other waste disposal documents, manufacturing plant processes, and pretreatment equipment; measurement of industrial wastewater flows; field testing of wastewater; and a review of regulations, policies, and procedures for the implementation of the pretreatment program.

Composite samples of a permittee's discharge are collected using automatic samplers and are time- composited over a 24-hour period. EPA sampling guidelines are used by the Source Control inspectors for collecting and preserving samples. In conjunction with each inspector's on-site observations, the results of laboratory analysis are used to verify compliance status, help disclose potential operational and housekeeping problems, evaluate the adequacy of pretreatment systems, and detect new sources of regulated substances. Grab samples are collected for the determination of compliance with TTO, cyanides, and pH.

4.1 During FY 2009/10, OCSD staff conducted 1,492 inspections and collected 3,679 wastewater samples resulting in 18,791 individual laboratory analyses. The number of conducted inspections decreased this year by 5%, the number of samples collected decreased by 0.2%, and the number of analyses performed increased by 5%.

TABLE 4.1 Summary of Inspections, Sampling, and Laboratory Analyses, Fiscal Years 2006-10 Orange County Sanitation District, Source Control Division

Fiscal Years Action/Status 2005-06 2006-07 2007-08 2008-09 2009-10

Industrial Inspections* 1,801 1,694 1,577 1,571 1492 Samples Collected 4,450 4,523 3,759 3,686 3679 Laboratory Analyses 22,909 28,215 21,536 17,859 18,791

* The number of composite sample events, inspections of an industry when there was no discharge, and grab samples, when not collected within one day after a composite sample.

4.3 NON-ROUTINE SAMPLING AND INSPECTION

OCSD's inspectors perform field duties beyond routine sampling and inspection, as summarized below:

Enforcement inspections are performed in response to compliance problems, and typically involve close cooperation with the permittee to identify and correct deficiencies. Source Control inspectors resample noncompliant industries within 30 days from the date of analysis verification, and submit compliance inspection reports to document corrective measures taken and to support enforcement action.

Inspectors may participate in multi-agency operations such as warrant inspections and environ- mental audits. Cross-training with other agencies enables inspectors to recognize potential problems with other media such as air and hazardous waste.

Trunkline monitoring focuses on industrial areas, and may identify unknown sources or permittees with noncompliant discharges. If the data indicates noncompliance, and if the probable source can be isolated, then a downstream project is proposed, as described in Section 4.3.1.

Chronic violators are subject to increased monitoring and inspection activity, which may include extended periods of on-site sampling.

4.3.1 Downstream Sampling

Covert sampling is conducted downstream of an industrial discharge location to verify continued discharge compliance or to determine whether discharge violations are occurring that are not being detected by on- site sampling. Typically, downstream sample sites are located in manhole structures in the local sewer through which the industry discharges. Downstream monitoring usually continues at a particular site for several days to characterize an industry's discharge habits.

The Source Control Division conducted four downstream monitoring operations during the period from July 1, 2009 through June 30, 2010.

4.2 4.4 Orange County Hazardous Materials Strike Force (Strike Force)

OCSD joined with state, county, city and other local agencies to form a Strike Force capable of identifying, investigating, and prosecuting dischargers of hazardous materials to the environment. The initial goals of the Strike Force Steering Committee were to define the roles and responsibilities of each participating agency; establish the scope of the cases to be handled; emphasize cooperative identification, investigation and prosecution of violators; and develop protocols among all participating agencies to create a coordinated enforcement system. An overall protocol was adopted by the Orange County Board of Supervisors in June 1988, and the Strike Force investigators have conducted monthly meetings to discuss investigative strategies. OCSD’s Source Control inspectors assisted the Strike Force in FY 2008/09 by attending meetings and conducting fieldwork in support of Strike Force activities.

Source Control staff used approximately 75 hours to attend Strike Force meetings and conduct field operations. The following companies were the subjects of joint OCSD/Strike Force investigations during this period.

 OCSD assisted in a search warrant inspection at Andres Technical Plating, located in the City of Brea. The warrant was served by the California Department of Toxics (DTSC) and involved the alleged illegal disposal of solid hazardous waste.

 OCSD assisted in a regulatory inspection led by DTSC at Ride Wright Wheels, located in the City of Anaheim. OCSD provided downstream monitoring support, which showed no signs of industrial wastewater. The inspection confirmed that the company has no industrial waste sewer discharge and disposes of solid waste properly.

4.5 INDUSTRIAL COMPLIANCE STATUS WITH DISCHARGE LIMITS

OCSD monitors and evaluates the compliance status of all regulated industries to determine the applicability of additional enforcement actions. Should the inspectors identify any deficiencies in an industry's process and/or discharge system, the industry is notified of the situation and corrective measures are required. A summary of the 332 significant industrial users' yearly compliance status is shown in Appendix A.

4.5.1 Industries Consistently Achieving Compliance (CAC)

For Fiscal Year 2009/10 there were 271 industries that were consistently achieving compliance, which means they had no violations during the reporting period.

4.5.2 Industries Inconsistently Achieving Compliance (IAC)

For Fiscal Year 2009/10 there were 39 industries that were inconsistently achieving compliance, which means they had at least one violation during the reporting period. This number also includes those companies where a compliance determination could not be made; for example, a company could have been recently permitted and the inspector had not yet scheduled them for sampling.

4.5.3 Industries in Significant Noncompliance (SNC)

On July 24, 1990, the Environmental Protection Agency (EPA) supplanted the term "significant violation" with the term "significant noncompliance" as defined in 40 CFR 403.8(f)(2)(vii). At the end of each quarter, OCSD is required to evaluate their industrial user's compliance status using a six-month time frame. Under this system, each industrial user is evaluated for SNC four times during the year, and the total evaluation period covers 15 months (i.e., beginning with the last quarter of the previous pretreatment year through the end of the current year). OCSD is required to annually publish in the local newspaper all industrial users that have been identified as SNC during the past year when the SNC criteria were met

4.3 during any of the previous four quarters. If a facility has been determined to be in SNC based solely on violations which occurred in the first quarter of the 15-month evaluation (i.e., the last quarter of the previous pretreatment year) and the facility has demonstrated consistent compliance in the subsequent four quarters, then OCSD is not required to publish the Industrial User (IU) in the newspaper if the IU was published in the previous year for the same violations.

As of June 30, 2010, of the active 332 Class I permittees listed in the Monitoring and Compliance Status Report there were 22 (7%) that had been classified as SNC (one is now out of business); 14 of these were categorical industries, and 8 were noncategorical. An industry was determined to be in SNC if it incurred a violation that met one or more of the criteria listed below as provided in 40 CFR, Part 403.

Chronic violations of discharge limits are defined as those in which 66% or more of all measurements taken during a six-month period exceed (by any magnitude) the daily maximum or the average limits for the same pollutant.

Acute violations of discharge limits are defined as those in which 33% or more of all measurements taken during a six-month period constitute a major violation1 of the daily maximum or the average limits.

Any other violation of a pretreatment effluent limit that has caused, either alone or in combination with other discharges, interference or pass through.

Any discharge of a pollutant that has caused imminent endangerment to human health, welfare, or the environment; or has resulted in OCSD's exercise of its emergency authorities.

Failure to meet within 90 days after the scheduled date of a compliance schedule milestone contained in an enforcement order for starting construction, completing construction, or for attaining final compliance.

Failure to provide required reports including, but not limited to, periodic self-monitoring reports and reports with compliance schedules within 45 days of the due date.

Failure to accurately report noncompliance with discharge limits or any other requirements applicable to the user pursuant to OCSD's Ordinance.

Any other violation or group of violations that will adversely affect the operation or implementation of OCSD's pretreatment program.

A summary of the permittees in SNC is presented in Table 4.2, whether they had ceased operations or not. The SNC list was published in the October 25, 2010, issue of The Orange County Register; a copy of the announcement is presented in Appendix F.

1 As provided in Section 102.A.42 of OCSD Wastewater Discharge Regulations, a major violation is a discharge exceeding a mass emission limit by 20% or more, a discharge exceeding a concentration limit by 20% or more, or a pH discharge less than 5.0.

4.4 TABLE 4.2 Summary of Companies in Significant Noncompliance (SNC), Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Company Name Permit No. City

Industries with Discharge Violations

Astech Engineered Products, Inc. 57-1-295 Santa Ana Astech Engineered Products, Inc. #2 57-1-320 Santa Ana Auto-Chlor System of Washington, Inc. 51-1-384 Santa Ana Blue Lake Energy, LTD 52-1-785 Yorba Linda DAH Oil, LLC 58-1-173 Huntington Beach Hanson-Loran Co., Inc. 3-1-107 Buena Park IPC Cal Flex, Inc. 3-1-027 Anaheim J & R Metal Finishing 52-1-823 Anaheim Nyala Screenprinting, Inc. 14-1-024 Irvine Shepard Bros. Inc. 3-1-034 La Habra Soldermask, Inc. 3-1-341 Huntington Beach Westcoast Plating, Inc. 51-1-388 Santa Ana

Industries with Reporting Violations

Data Electronic Services, Inc. (P-1) 1-1-142 Santa Ana Data Electronic Services, Inc.(P-2) 51-1-391 Santa Ana John A. Thomas 3-1-065 Huntington Beach Nollac Oil Company 2-1-094 Placentia Performance Powder, Inc. 52-1-805 Anaheim Strip Clean Company 2-1-673 Santa Ana United Pharma, LLC 53-1-418 Fullerton

Industries with Both Discharge and Reporting Violations

Derm Cosmetics Labs, Inc. 3-1-062 Buena Park Private Label Laboratories, Inc. 52-1-755 Anaheim South Coast Oil Corporation 11-1-019 Huntington Beach

4.6 ENFORCEMENT ACTIVITIES

During FY 2009/10, OCSD initiated or continued in effect various enforcement actions to bring companies into compliance. This section describes the types of enforcement actions taken against noncompliant companies. In addition, Appendix L shows a listing of pretreatment equipment that has been installed by OCSD’s permittees.

4.5 4.6.1 Compliance Inspections

In order to identify and assess any noncompliance problems, corrective actions, and the progress of permittees operating under the terms of a Probation Order, Enforcement Compliance Schedule Agreement (ECSA), or any other enforcement action, an OCSD Source Control Division engineer and inspector conduct special compliance inspections. During FY 2009/10, 46 compliance inspections were conducted.

4.6.2 Compliance Meetings

Compliance meetings are called as a result of the permittee's inability to achieve compliance with discharge requirements or to comply with OCSD's Ordinance. The meetings are held with company representatives to discuss the discharge problems and proposed long-term solutions. During FY 2009/10, 24 compliance meetings were held for those permittees that were in major or chronic noncompliance or were identified as SNC.

4.6.3 Notices of Violation – Noncompliance Fees, Penalties

A Notice of Violation (Notice) is a written notification from OCSD that references findings from recent sampling programs and indicates that specific violations of the permittees’ discharge limits have occurred. The Notice is usually accompanied by noncompliance sampling fees. The Notice instructs the permittee to take immediate action to correct the problem. For FY 2009/10, 35 Notices regarding noncompliance sampling fees and penalties were sent to 29 Significant Industrial Users.

When a permittee violates its permit limits, noncompliance fees are assessed at rates that have been adopted by OCSD's Board of Directors. For FY 2009/10, noncompliance fees, penalties, and judgments totaling $42,389 were assessed (for details see Appendix E). As noted below in Table 4.3, which shows a summary of the noncompliance fees for the last five years, the amount of total fees and penalties varies significantly depending on the circumstances and outcomes of cases pursued.

TABLE 4.3 Summary of Noncompliance Fees and Penalties for Fiscal Years 2006-10 Orange County Sanitation District, Source Control Division

Fiscal Year 2005-06 2006-07 2007-08 2008-09 2009-10

$139,608 $155,462 $130,157 $99,379 $42,389

4.6.4 Probation Orders

Upon determination that a permittee is in non-compliance with the terms and conditions specified in its permit or any provision of OCSD’s Ordinance, OCSD may issue a Probation Order. The Probation Order contains conditions, requirements and a compliance schedule. The term of a Probation Order does not exceed 90 days. The permittee is required to comply with all directives, conditions, or requirements within the time specified, including the submittal of information pertaining to waste source characterizations, pretreatment modifications, and waste minimization alternatives; and the performance of accelerated self- monitoring.

During FY 2009/10, OCSD issued one Probation Order.

4.6 TABLE 4.4 Probation Orders Issued, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Company Permit Number Critical Constituents Compliance Date

Anodyne, Inc. 51-1-389 Cd, Cr, Cu, Ni, Pb, Zn 11/30/2009

4.6.5 Enforcement Compliance Schedule Agreement An Enforcement Compliance Schedule Agreement (ECSA) is an agreement between the permittee and OCSD specifying that permit revocation will be temporarily held in abeyance provided that pretreatment equipment is installed or pollution prevention measures are implemented by the permittee within a scheduled time period, and that the permittee remains in consistent compliance during the term of the ECSA. The ECSA contains terms and conditions by which the permittee must operate and specifies dates for construction or acquiring and installing the pretreatment equipment and/or implementing waste minimization to achieve compliance. During the ECSA, inspection and sampling of the facilities are conducted monthly by OCSD's inspectors to verify that all terms and conditions of the ECSA are met. In addition, the permittee is required to perform accelerated and extended self monitoring.

During FY 2009/10, OCSD issued no ECSAs.

4.6.6 Administrative Penalties

Pursuant to the authority of California Government Code Sections 54740.5 and 54740.6, OCSD may issue administrative complaints and penalties. During FY 2009/10, in accordance with Section 615.D of OCSD's Ordinance, OCSD imposed two administrative penalties as shown in the table below.

TABLE 4.5 Administrative Penalties, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Company Permit Number Administrative Penalties

Air Industries Corporation-Knott 53-1-404 $13,000

South Coast Oil Company 11-1-019 $14,000

4.6.7 Permit Suspensions

When OCSD believes that grounds exist for permit suspension, the permittee is notified in writing of the reasons for permit suspension and the date of the permit suspension hearing. At the hearing, OCSD staff and the permittee are provided the opportunity to present evidence to a designated hearing officer. After the conclusion of the hearing, a written determination is made by the hearing officer. Upon issuance of an order of suspension, the permittee must cease and desist all discharges to the sewer for the duration of the suspension.

During FY 2009/10, one permit suspension was issued.

4.7 4.6.8 Permit Revocations

The last recourse in the chain of administrative enforcement provisions is permit revocation. A permittee with a critical noncompliance record or who has failed to pay fees and charges is notified in writing of the reasons for permit revocation and the date of the permit revocation hearing. At the hearing, OCSD staff and the permittee are provided the opportunity to present evidence to a designated hearing officer. After the conclusion of the hearing, the hearing officer makes a determination if permit revocation is warranted, and provides a written report to the General Manager for final determination. Should the General Manager determine that the noncompliance record is substantial, revocation of the industrial waste discharge permit and loss of sewer discharge privileges may result.

During FY 2009/10 no permit revocation hearings were scheduled.

4.6.9 Emergency Suspension Order

Pursuant to Section 613 of OCSD's Wastewater Discharge Regulations, an Emergency Suspension Order may be ordered to stop an actual or impending discharge which presents or may present an imminent or substantial endangerment to the health and welfare of persons, or to the environment, or may cause interference to OCSD's sewerage facilities, or may cause OCSD to violate any state or federal law or regulation.

During FY 2009/10, no Emergency Suspension Orders were issued.

4.6.10 Civil/Criminal Complaints

When a permittee intentionally or negligently violates any provision of the Ordinance, permit conditions, or discharge limits, OCSD may petition to the Superior Court for the issuance of a preliminary or permanent restraining order. In addition, OCSD can petition the Court to impose, assess, and recover civil penalties for each day that violation occurs or seek criminal penalties for illegal disposal in accordance with OCSD's Ordinance.

No criminal complaints were filed during FY 2009/10.

4.7 ENFORCEMENT SUMMARY

This section summarizes various enforcement activities taken against permitted companies for FY 2009/10. These actions include permit revocations, permit suspension, compliance inspections, compliance meetings, probation orders, and ECSAs.

Active Plating Inc. (Permit No. 1-1-115)

Active Plating Inc. (Active) performs zinc plating and chromate conversion coating on steel and aluminum parts. Wastewater is generated by alkaline cleaning, acid activation, clear and yellow chromate conversion coating, deoxidizing, electrocleaning, and zinc plating. Active operates a continuous pretreatment system consisting of equalization, chrome reduction, precipitation, clarification, and filter press. Spent solutions are bled into the continuous pretreatment system prior to discharge to the sewer.

In April 2009, Active had a chromium violation. In June 2009, Active submitted a letter explaining that the violation was due to excessive feed rate of the wastestream into the pretreatment system, which resulted in pass-through. To correct the problem, Active replaced the manual feed valves with automatic feed pumps.

In January 2010, Active had a zinc violation.

4.8 In February 2010, OCSD conducted a compliance inspection to investigate the violation. Active informed OCSD staff that the violation was due to a malfunctioning pH probe, which was subsequently replaced.

OCSD will continue monitoring Active’s discharge on a quarterly basis.

Air Industries Company (Permit No. 3-1-013)

Air Industries Company–Chapman (AIC-Chapman) is a large machine shop located in Garden Grove, and manufactures titanium and steel fasteners (rivets, screws, bolts, and nuts) for the aviation and aerospace industries. This facility, located on Chapman Avenue, is a support facility for the main company operation located nearby on Knott Street. Centerless grinding and other intermediate machining operations are performed on fasteners sent from AIC-Knott. The wastewater generated at AIC-Chapman consists of floor mop water on a daily basis, and exhaust system backwash carried out monthly. AIC-Chapman’s pollutant of concern is hydraulic / machining oil from the various grinders and lathes. Pretreatment at AIC-Chapman consists of a 2,500 gallon oil / water separation tank, followed by a microfiltration unit, for removal of residual oil and grease before discharge into a final batch discharge tank. An average of approximately 300 gallons per day is discharged to the sewer.

In January 2010, AIC-Chapman had a self-monitoring oil and grease violation. In May 2010, AIC- Chapman had a second oil and grease violation. OCSD collected a 30-day resample and conducted a compliance inspection in June 2010. AIC-Chapman believes that the probable cause was employee error in dumping mop water directly into the batch discharge tank instead of the trench and sump that feeds the mop water into the oil / water separation tank and microfiltration system. The company also ordered new membranes for the microfiltration unit, which should be in place by the following quarter. The resample showed compliance. OCSD will continue to monitor AIC-Chapman and verify replacement of the membranes.

Air Industries Company (Permit No. 53-1-404)

Air Industries Company–Knott St. (AIC-Knott) is a large machine shop located in Garden Grove, and manufactures titanium and steel fasteners (rivets, screws, bolts, and nuts) for the aviation and aerospace industries. Metal surface finishing is also performed on the titanium and steel parts, including alkaline cleaning, etching, passivation, pickling, chemfilming, cadmium and nickel electroplating; and molten salt deoxidation for titanium parts. Fasteners are also washed in conveyorized parts washers after several steps during the manufacturing process, and this wastewater, along with floor mop water, is treated offline in oil / water separation tanks before discharge to the sewer. Rinsewater from the metal finishing area is segregated, collected, and treated in standard chrome reduction, cyanide destruction, and heavy metals pretreatment units. All treatment units have automatic pH / ORP controls with mechanical mixing. After cyanide treatment and chrome reduction, the wastestreams are commingled with general heavy metals wastewater in a precipitation / pH adjust tank. After pH adjustment, wastewater flows into a conical solids settling tank, where solids are removed and dewatered with a filter press. The decant from the settling tank overflows to a below-ground clarifier with a sample box and sewer connection. Oil skimming belts are installed in all three chambers of the clarifier for removal of residual oil and grease before discharge of the treated effluent to the sewer. AIC-Knott St. employs a batch treatment process for most of their spent process chemicals, and wastehauls the remainder as necessary.

In July 2009, AIC-Knott had an oil and grease violation. As a result of previous oil and grease violations in 2008, in March 2009 AIC-Knott submitted a proposal to OCSD which outlined upgrades to the company’s pretreatment system, including installation of new oil skimming equipment for its parts washer systems. At the time of this sampling, however, OCSD noted that the upgrades had not yet been installed. AIC-Knott’s proposal specified that the pretreatment upgrades would be installed by the end of May 2009.

In August 2009, the 30-day resample also resulted in an oil and grease violation. During this sampling, OCSD again noted that pretreatment upgrades had still not been installed. AIC-Knott stated that the delay with the equipment installation was due to a modification required to the company’s tiered permit

4.9 issued by the Department of Toxic Substances Control. Upon further inquiry, AIC-Knott was unable to state when the issue with the tiered permit would be resolved. OCSD issued an Order to Cease Noncompliant Discharges in September 2009.

In October 2009, AIC-Knott had further oil and grease violations. The pretreatment system upgrades had not been installed, and there was no further communication from AIC-Knott regarding the date of installation.

In December 2009, OCSD served AIC-Knott with an Administrative Complaint for the oil and grease violations incurred from December 2008 through October 2009. An administrative hearing was scheduled for February 2010. The hearing date was extended into late March, due to termination of the managers who were responsible for the compliance issues during 2009.

AIC-Knott elected to settle the complaint in lieu of a hearing. OCSD and AIC-Knott signed the settlement agreement in early May 2010, which included monetary penalties. The company has increased maintenance of oil and grease pretreatment equipment. OCSD will continue to monitor AIC- Knott on a quarterly basis.

Alcoa Global Fasteners, Inc. (Permit No. 2-1-081)

Alcoa Global Fasteners, Inc. (Alcoa) manufactures aluminum, titanium and steel fasteners, which undergo various surface treatment operations. Wastewater-generating processes include cadmium, copper, silver, nickel and zinc plating, potassium permanganate treatment, cyanide stripping, glycol lubricant coating, acid stripping, chromate conversion coating, deburring, quenching, miscellaneous cleaning (mop water), acid/alkaline cleaning, and air scrubbing. The facility operates a continuous treatment system consisting of pH adjustment, cyanide destruct, chromium reduction, clarification and sludge dewatering using a filter press. Separate, dedicated pretreatment systems are used including electrowinning (for silver plating) and oil / water separation. Alcoa has had intermittent cadmium, chromium, nickel, and silver violations. OCSD issued a Probation Order in January 2006, which included requirements for weekly self-monitoring, interim compliance, a certified waste treatment operator(s) and a pretreatment system modification proposal.

Alcoa maintained compliance with all permit and Probation Order requirements, particularly the provision that Alcoa continue to meet all interim compliance measures required through the use of Baker tanks to store all wastewater for analysis to verify compliance prior to discharge.

OCSD continued to monitor Alcoa’s compliance, and no violations have occurred during the interim period. In December 2007, OCSD held a compliance meeting in order to determine the status of Alcoa’s lease and progress with the pretreatment system modifications proposed earlier. Alcoa negotiated with contractors for the pretreatment system modifications, including improved clarification, cyanide treatment, modernized controls and ion exchange allowing some recycle of treated wastewater back into industrial processes. Alcoa subsequently submitted a schedule for the improvements. Interim compliance measures were still in effect and compliance was maintained.

In January 2009, OCSD conducted a compliance inspection to determine the status of pretreatment modifications and to meet new staff at Alcoa, including the chief operating officer and designated contact. During the inspection, Alcoa indicated that they were securing funding for the project and expected to begin construction this summer. In May 2009, OCSD received correspondence from Alcoa with an updated schedule detailing the pretreatment system modifications to commence during summer. Final schematics will follow when installation is completed in FY 2010/11.

In November 2009, OCSD staff conducted a compliance inspection after attending a preliminary meeting to discuss pretreatment equipment installation milestones. During the meeting, Alcoa and their consultants described revisions to the original proposal and outlined their progress to date. The subsequent inspection verified their progress, including continued presence of interim measures,

4.10 installation of sand filtration, construction of improved final clarification and sampling facilities, and revised arrangement of effluent metering equipment.

Alcoa continued to make progress completing the modifications to their pretreatment system; all sampling conducted indicates compliance with discharge limits. OCSD’s monitoring showed compliance with discharge limits. Alcoa’s progress will continue to be reviewed.

Almatron Electronics Inc. (Permit No. 1-1-133)

Almatron Electronics Inc. (Almatron) is a printed circuit board manufacturer. Wastewater-generating operations include acid catalyst, acid cleaning, acid dipping, alkaline cleaning, black oxide, catalyst pre-dip, copper plating, de-smear, cupric chloride etching, electroless copper plating, fume scrubbing, gold plating, micro-etching, nickel plating, photo-film developing, resist stripping, sulfuric dipping, tin- lead plating, tin-lead stripping, and accelerator. Almatron operates a continuous pretreatment system consisting of precipitation, coagulation / flocculation, clarification, and filter press. Almatron uses a batch pretreatment system to treat spent solutions and static rinses prior to discharge to the sewer.

In October 2008, Almatron had a copper violation. Almatron appealed the sample result. OCSD analyzed the split sample, which confirmed the original sample result. In December 2008, OCSD notified Almatron that the appeal was denied. OCSD required Almatron to implement corrective action during the following quarter. In March 2009, Almatron submitted a letter explaining that the violation was due to the resist stripper causing interference with the continuous pretreatment system operation. To correct the problem, Almatron proposed to batch-treat the resist stripper. In May 2009, Almatron had a nickel violation.

In July 2009, OCSD conducted an inspection to investigate the violation. OCSD staff noted no major deficiency. Almatron stated that they did not find the cause of the nickel violation, and had no further violations in the following three quarters. OCSD will continue monitoring Almatron’s discharge on a quarterly basis.

Aluminum Precision Products Inc. Central (Permit No. 1-1-038)

Aluminum Precision Products Inc. Central (APPI) manufactures parts for aerospace, automotive, and defense industries. The wastewater is generated by abrasive jet machining, aqueous quenching, glycol quenching, and spray rinsing. Wastewater is discharged to the sewer through a three-stage below-ground clarifier.

In October 2009, APPI had a zinc violation. In November 2009, APPI submitted a letter explaining that the violation may have been due to solids buildup in the clarifier. To correct the problem, APPI cleaned the clarifier and established a cleaning schedule. The company had no further violations for the remainder of the fiscal year. OCSD will continue monitoring APPI’s discharge on a quarterly basis.

Anaheim Plating and Polishing (Permit No. 2-1-150)

Anaheim Plating and Polishing (Anaheim Plating) is a small job shop plating company that specializes in copper, nickel, and chrome electroplating of automotive wheel rims. Standard cleaning, acid activation, and Bondal (zincate) process steps are performed on the wheels before the copper, nickel, and chromium plating is applied. Pretreatment consists of chromium reduction followed by pH adjustment / metals precipitation using a coagulant and flocculant. The chromium reduction and metals precipitation modules have automatic pH / ORP control with mechanical mixing. The treated wastewater gravity flows into an above-ground clarifier for settling of solids, which are dewatered with a filter press. Effluent from the clarifier is plumbed into a three-stage module that contains granular activated carbon to remove chloroform and other toxic organics. Anaheim Plating installed the carbon module in 2007 as a result of total toxic organics (TTO) violations which occurred during 2005 - 2007. The wastewater is subsequently discharged to an underground clarifier with a sample box.

4.11 In April 2010, Anaheim Plating had a self-monitoring TTO violation, with chloroform as the primary constituent. OCSD collected a quarterly sample and conducted a pre-permit renewal inspection in June 2010. Anaheim Plating believed that the carbon had become saturated, and therefore replaced half of the carbon in the treatment module earlier in the month. OCSD’s sample for TTO was in compliance. Anaheim Plating conducted a resample in July 2010, which also showed compliance. OCSD will continue to monitor Anaheim Plating on a quarterly basis.

Anodyne Inc. (Permit No. 1-1-055 and 51-1-389)

Anodyne Inc. (Anodyne) is a job shop that performs surface finishing and painting for aerospace, automotive, commercial, industrial, military / defense, and recreational applications. The wastewater- generating operations include acid activation, acid pickle, aluminum bright dip, aluminum cleaner, aluminum etch, black nickel plating, bright nickel plating, bright tin plating, cadmium plating, cadmium stripping, chromic anodize (type 1), chromate conversion coating, color dye (black, blue, copper, gold, grey, red, and violet), copper plating, copper strike, electroless nickel plating, electroless nickel / boron plating, gold plating, hard anodize, nickel plating, nickel strike, nickel strip, silver plating, silver strike, solvent cleaning (acetone), sulfuric anodize, sulfuric dip, tin-lead plating, tin-lead rack stripping, tin-lead reflow, ultrasonic cleaning, zincate, and zinc plating. Anodyne operates continuous and batch pretreatment systems for treatment of contaminated wastestreams prior to discharge to the sewer. The continuous pretreatment system consists of two-stage cyanide destruction, chrome reduction, hydroxide precipitation, lamella clarifier, and filter press. The batch treatment system is used for treating the static rinses and some spent solutions, and consists of multiple batch treatment tanks equipped with mechanical mixers, chemical feed pumps, and automatic pH controllers.

In August 2008, Anodyne had a cadmium violation. In October 2008, OCSD contacted Anodyne to investigate the violation. Anodyne explained that they had investigated the violation and could not identify the source of the problem. They added that further sampling of their discharge had shown compliance. In January 2009, Anodyne changed ownership. OCSD terminated permit No. 1-1-055 and issued a new permit, No. 51-1-389 under the new ownership. Subsequent sample results showed compliance with discharge limits until June 2009, when Anodyne had a cadmium violation.

In July 2009, OCSD conducted an inspection to investigate the violation. During the meeting, OCSD staff noted major deficiencies in the batch pretreatment system. In August 2009, OCSD met with Anodyne to discuss the corrective actions. OCSD determined that corrective actions would be implemented under the terms and conditions of a Probation Order. In September 2009, OCSD issued a Probation Order requiring Anodyne to conduct an evaluation of the batch pretreatment system, submit a written description of the modifications and upgrades of the batch pretreatment system, retain a qualified wastewater treatment operator, submit an operation and maintenance manual for the batch and continuous pretreatment systems, and install flow controllers on all running rinses by the end of November 2009. In December 2009, Anodyne submitted the Probation Order requirements.

In February 2010, OCSD reviewed the submittals and found Anodyne had failed to submit both an Operation and Maintenance manual and a report detailing installation of flow controllers. OCSD required Anodyne to complete the aforementioned requirements by March 2010. In March 2010, Anodyne submitted the Operation and Maintenance manual and a report summarizing the installation of flow controllers on all running rinses. OCSD will continue monitoring Anodyne’s discharge on a quarterly basis.

Aqua-Con Company (Permit No. 1-1-066)

Aqua-Con Company (Aqua-Con) regenerates ion exchange columns used by its clients to produce deionized water. Wastewater is generated by rinsing the ion exchange resins with acid and alkaline solutions. Aqua-Con neutralizes the wastestream prior to sewer discharge.

In May 2009, Aqua-Con had a zinc violation. In June 2009, OCSD contacted Aqua-Con and required the company to investigate the violation. In July 2009, Aqua-Con submitted a letter explaining that the violation

4.12 could have been due to a drainage problem that resulted in lower pH of the wastestream which caused the built-up scale in the collection tank to dissolve. Aqua-Con also generated a log sheet for resin regeneration to track the process.

In April 2010, Aqua-Con had a zinc violation. In April 2010, OCSD contacted Aqua-Con and required the company to submit a pretreatment system proposal by May 2010. In May 2010, Aqua-Con submitted a batch pretreatment system consisting of an equalization tank, two in-series ion exchange columns, a collection tank, and a pH adjustment tank equipped with mechanical mixer, chemical feed pumps, and automatic pH control system. In June 2010, OCSD sent Aqua-Con a letter accepting the pretreatment system proposal. Additionally, OCSD required Aqua-Con to maintain logs of meter calibration and transfer of columns offsite for regeneration, and show the logs to OCSD staff upon request.

Astech Engineered Products Inc. (Permit No. 57-1-295)

Astech Engineered Products Inc. (Astech) is a manufacturer of jet engine housings, exhaust nozzles, and ship doors. This permit includes only metal finishing operations at the facility. Wastewater is generated by alkaline cleaning, photo processing, sodium hydroxide cleaning, and waterjet cutting. Astech uses a microfiltration unit to remove solids from wastestream prior to discharge into the sewer system.

In May 2010, Astech had a chromium violation. In June 2010, OCSD conducted a compliance inspection to investigate the violation. Astech informed OCSD that the violation was due to bypassing of overflow water in the waterjet cutting area, resulting in carryover of metal particulates to the sample point, instead of feeding it through the microfiltration. To correct the problem, Astech re-routed this wastestream to the microfiltration unit. OCSD will continue monitoring Astech’s discharge on a quarterly basis.

Astech Engineered Products Inc. # 2 (Permit No. 57-1-320)

Astech Engineered Products Inc. (Astech #2) is a manufacturer of jet engine housings, exhaust nozzles, and ship doors. This permit includes metal forming operations at the facility. Wastewater is generated by acid pickling, alkaline cleaning, dye penetrant testing, and a fume scrubber. Astech #2 operates a batch pretreatment system consisting of two collection tanks, carbon filtration columns, and an ion exchange system for fluorides.

In January 2010, Astech #2 had chromium and copper violations. In February 2010, OCSD conducted a compliance inspection to investigate the violations. As a result, OCSD required Astech #2 to install a pretreatment system for removal of heavy metals from the wastestream. In March 2010, Astech #2 informed OCSD that they had installed ion exchange columns for the removal of heavy metals.

In April 2010, Astech #2 had ammonia and chromium violations. In June 2010, OCSD conducted a compliance inspection to investigate the violations. During the inspection, OCSD noted that Astech #2 had no pretreatment system to remove ammonia from the wastestream. To remedy the ammonia noncompliance, Astech #2 proposed to install an ion exchange column. The chromium violation was due to improper pH of the wastestream fed into the ion exchange column. To correct the problem, Astech #2 installed a system to adjust the wastestream to the proper pH range. OCSD will continue monitoring Astech #2’s discharge on a quarterly basis.

Auto-Chlor System of Washington Inc.(Permit No. 51-1-384)

Auto-Chlor System of Washington Inc. (Auto-Chlor) manufactures commercial and general cleaning products. The wastewater is generated by cleaning and rinsing of the blending tanks. The wastewater is pH adjusted prior to discharge to the sewer.

In October 2009, Auto-Chlor had a total toxic organic (TTO) violation. In November 2009, Auto-Chlor submitted a letter explaining that the violation was due to mixing of a chlorine-based product with

4.13 surfactants in another product that generated chloroform. To correct the problem, Auto-Chlor is segregating the products. OCSD will continue monitoring Auto-Chlor’s discharge on a quarterly basis.

Beo-Mag Plating (Permit No. 51-1-370)

Beo-Mag Plating (Beo-Mag) is a small job shop performing surface finishing on parts made of aluminum, mild steel, and diecast zinc. Wastewater is generated by alkaline cleaning, acid activation, fume scrubbing, copper, nickel, chrome and gold plating, chrome stripping, electrocleaning, and zincating. Beo- Mag operates a continuous pretreatment system consisting of equalization, chemical precipitation, coagulation, clarification, and filter press. Beo-Mag also operates a batch pretreatment system to treat spent solutions and dragout rinses prior to discharge to the sewer.

In April 2009, Beo-Mag had a copper violation. In May 2009, OCSD contacted Beo-Mag and required the company to investigate the violation. In July 2009, Beo-Mag submitted a letter explaining that the violation was due to buildup of sludge in the clarifier which resulted in carryover into the sample point. To correct the problem, Beo-Mag developed a routine schedule for pumping the clarifier. OCSD will continue to monitoring Beo-Mag’s discharge on a quarterly basis.

Blue Lake Energy (Permit No. 52-1-785)

Blue Lake Energy (Blue Lake) is a crude oil production site located in Yorba Linda. Groundwater mixed with crude oil from two producing wells is pumped into a 10,000 gallon steel oil / water separation tank. Crude oil is skimmed from the top of the tank and drains into an adjacent storage tank, while groundwater drains from the bottom through a two-stage above-ground clarifier followed by two 55-gallon granular activated carbon drums plumbed in series, before discharge into a standpipe and sewer connection. Groundwater treated and discharged from this site is minimal, averaging less than 200 gallons daily.

During the last two quarters of FY 2008/9, Blue Lake had three violations for total toxic organics (TTO), in which the main constituent was benzene. In June 2009, Blue Lake issued a letter to OCSD which described an investigation into the cause of the most recent violations. The company also informed OCSD that they would henceforth shut down discharge from the site until a remedy and / or pretreatment upgrade could be devised.

During the fiscal year, OCSD conducted inspections of the site to verify that the company had, in fact, ceased discharge of wastewater. In September 2009, OCSD staff discovered that groundwater accumulated in a storage tank was being discharged through a hose to the uncapped sewer connection. The grab sample collected from the discharge resulted in a TTO violation, with benzene as the primary constituent. Upon receipt of the Notice of Violation, Blue Lake immediately responded with a letter to OCSD stating that a site operator had violated company rules and regulations in allowing a release of groundwater to the sewer without prior authorization. Blue Lake also stated that they would increase site inspections to insure that there would be no further unauthorized discharges, and would notify OCSD when the pretreatment system had been upgraded before resuming discharge to the sewer.

In October 2010, OCSD acknowledged receipt of Blue Lake’s letter regarding the September TTO violation, and notified Blue Lake that further discharges of groundwater into the sewer system without advanced pretreatment would result in escalated enforcement action. OCSD will continue to randomly inspect Blue Lake.

Cartel Electronics (Permit No. 52-1-814)

Cartel Electronics (Cartel) manufactures rigid, single-sided, double-sided, and multilayer printed circuit boards. Wastewater generating operations include accelerator, acid cleaning, acid pre-dip, activator pre- dip, alkaline cleaning, ammonium etching, aqueous fume scrubbing, automatic scrubbing, Cobra Bond, conditioner, copper plating, DP activator, Hyoki aluminum oxide scrubbing, manual scrubbing, microetch, neutralizer, permanganate, photo-film developer, photo-film fixer, photoresist developing, resist stripping,

4.14 rinsing (countercurrent, running, spray, & static), screen developing, screen washing, sensitizer, sulfuric dip, and tin stripping. Cartel operates both continuous and batch pretreatment systems, with ion exchange, pH adjustment, and solids dewatering in a filter press.

In December 2009, Cartel Electronics had a copper violation. In February 2010, OCSD staff inspected Cartel’s pretreatment system operations and collected a 30-day resample. The pretreatment system was found to be operating properly. A printed circuit board sanding operation was noted to be near the sample point, from which copper particles could have contributed to the violation. Cartel proposed to move this operation to another location. The resample resulted in compliance.

In June 2010, a routine quarterly sampling again showed compliance. The sanding operation has been moved to another location, well away from the sample point. No further enforcement is under consideration.

Cheek Engineering & Stamping (Permit No. 7-1-141)

Cheek Engineering & Stamping (Cheek) is a medium-sized machine shop located in the city of Tustin. Various parts made of aluminum, brass, copper, steel, and stainless steels are manufactured to customer specifications using punch presses, lathes, milling, and drilling equipment. Cheek employs three tumbling machines filled with a soap solution that contains ceramic media to smooth machined edges and corners on selected orders. After tumbling, the soap solution is drained into a covered trench which is connected to a three-stage underground clarifier with a sample box.

In April 2010, Cheek had a copper violation, the first in over ten years. OCSD was unable to collect a resample before the end of the quarter due to low/intermittent flows at Cheek, as business had been very slow due to the ongoing economic downturn. Cheek informed OCSD that they were unsure of the cause of the violation, but suspected that a batch of copper or brass parts may have been tumbled by mistake immediately before the April sample. OCSD will again attempt to obtain a resample in July 2010.

DAH Oil LLC (Permit No. 58-1-173)

DAH Oil produces crude oil from two wells located in Huntington Beach. Crude oil is separated from brine via gravity in a large wash tank, with the brine directed to the sewer. Pretreatment at the facility includes bulk oil / water separation followed by a two-stage clarifier.

OCSD sampling conducted on two occasions during FY 2008/9 resulted in violations of total toxic organics (TTO) discharge limits. OCSD conducted a compliance inspection of the facility in November 2008, during which it was found that the sampling facilities available at DAH Oil were inadequate and may be contributing to the noncompliance by allowing the accumulation of hydrocarbons in the sample retrieval container.

During routine monitoring and inspection of the facility conducted in March 2009, OCSD staff found that the sampling point had been significantly improved since the last inspection. Sampling conducted shortly after this modification showed compliance.

In August 2009, DAH had a TTO violation. OCSD’s monitoring conducted in June 2010 was again in violation of TTO discharge limits. A compliance inspection of the facility will be conducted in the following quarter.

Derm Cosmetics Labs Inc. (Permit No. 3-1-062)

Derm Cosmetics Labs, Inc. (Derm) manufactures shampoos, creams, lotions, household cleaners, drain openers, and gels. Wastewater is generated from washing the blending tanks and floor. Pretreatment consists of pH adjustment followed by membrane filtration.

4.15 In August 2009, Derm had an instantaneous oil and grease violation. Since no further violations were noted after the first quarter, no further action is warranted.

Dunham Metal Processing (Permit No. 2-1-325)

Dunham Metal Processing (DMP) is a small metal finishing job shop specializing in clear, color, and multicolor anodizing on aluminum parts for the aerospace, automotive, electronics, medical, and sporting goods industries. On a smaller scale, DMP also performs nitric passivation on stainless steel parts. Other services include laser marking, silk screen printing, and spray painting. Wastewater-generating operations include alkaline cleaning, anodizing (hard and regular), dyeing (black, blue, bronze, gray, gold, green, red, purple, copper and turquoise), caustic etching, deoxidizing, hot water sealing, nitric passivation, and associated rinsing. Pretreatment includes chromium reduction, continuous chemical precipitation, coagulant / flocculant addition, clarification, and solids dewatering in a filter press.

In November 2009, DMP had a nickel violation. Since no further violations were noted after the second quarter, no further action is warranted at this time.

Electro Metal Finishing Corporation (Permit No. 2-1-158)

Electro Metal Finishing Corporation (EMF) is a powdercoating job shop. Parts are placed in large baskets and with the use of a hoist are immersed in a heated iron phosphate solution. The parts are rinsed in a static city water rinse. The parts are subsequently racked, dried, powder applied in one of four booths, and then baked in an oven. Wastewater is generated by the iron phosphate rinse, and periodic disposal of the iron phosphate solution. EMF operates a batch treatment system for the static rinse; the iron phosphate solution is wastehauled when spent.

In May 2010, EMF had a zinc violation. In June 2010, EMF appealed the violation and requested that the split samples be analyzed to confirm the original results. Although two of the four samples resulted in a compliant concentration, a comparison of the four samples analyzed to determine the validity of the sample resulted in an average percent deviation of 2%. Results with an average percent deviation of less than 10% are valid. Thus, the original result constitutes a violation, and will be investigated in the following quarter.

Electrolurgy Inc. (Permit No. 7-1-162)

Electrolurgy Inc. (Electrolurgy) is a large job shop specializing in finishing services for aerospace, electronics, and military applications. Wastewater is generated by alkaline cleaning, aluminum etching, anodizing, nickel plating, cadmium plating, chemfilm, chromate conversion coating, dyeing, electrocleaning, copper plating, electroless nickel plating, gold plating, acid etching, nickel stripping, passivating, silver plating, ultrasonic cleaning, and zincating. Electrolurgy operates a continuous pretreatment system which consists of equalization, chromium reduction, two-stage cyanide destruction, flocculation / coagulation, clarification, Memtek system, and filter press. Electrolurgy uses a batch treatment system for treating spent dragout and spent solutions prior to discharge to the sewer. The batch pretreatment system consists of a batch treatment tank and electrowinning unit.

In February 2010, Electrolurgy had a nickel violation. In March 2010, OCSD contacted Electrolurgy to investigate the violation. Electrolurgy informed OCSD that the violation may have been caused by improper maintenance of the Memtek system. To correct the problem, Electrolurgy developed a schedule to increase the frequency of cleaning. OCSD will continue to monitoring Electrolurgy’s discharge on a quarterly basis.

Electron Plating III Inc. (Permit No. 2-1-336)

Electron Plating III Inc. (Electron Plating) is a medium-sized metal finishing job shop located in Garden Grove. Wet processing includes hard anodizing, chemfilm, electroless nickel, and zinc plating. Rinsewaters and spent process chemicals are collected in equalization tanks inside the wet process area

4.16 for transfer to an outdoor pretreatment area. The wastewaters are segregated into chrome reduction and general metals treatment streams. Pretreatment consists of chrome reduction and heavy metals precipitation modules equipped with automated pH and ORP controls and mechanical mixing. Treated effluent from the precipitation tank is pumped to a flocculant mixing tank before overflow into a large lamella-type clarifier. Solids are removed from the bottom of the clarifier and pumped into a settling tank, then extracted with a sludge pump for dewatering with a filter press. Wastewater from the settling tank is directed back to the metals precipitation unit, while overflow from the clarifier is plumbed to a dual chamber collection/pump-out box. Electron Plating recycles a portion of treated effluent from the clarifier for use as rinsewater after the alkaline cleaning and caustic etch tanks in the anodizing line. The other chamber of the pump-out box is used to transfer treated effluent from the lamella clarifier to a below-ground clarifier located inside the building, from which it discharges to a sampling vault with a sewer connection in front of the building.

In August 2009, Electron Plating had a cadmium violation. The company eliminated cadmium plating from their wet process area over ten years ago, but residual amounts of cadmium periodically appear in Electron Plating’s treated effluent. OCSD followed up with a multi-day resampling of the company’s wastewater discharge from the beginning through the end of September 2009. Upon OCSD’s initial set up of the sampling equipment, Electron Plating decided to pump out the sampling vault to remove any built-up solids in the bottom.

In September 2009, the first day of the resample, Electron Plating had another cadmium violation. The cause for this violation is believed to be pumping of the sample vault during the time the sampling was conducted, since the last two days of the multi-day sampling were in compliance for cadmium and other heavy metals. Electron Plating submitted a letter to OCSD which stated that they would discontinue onsite treatment of nitric acid-based metal stripping solution and rinse, which from previous sampling by OCSD in 2008 had shown high levels of cadmium. The company stated that spent stripper solution and rinse would now be collected in drums for wastehauling offsite. Electron Plating had been bleeding in small amounts of spent stripping solution and rinsewater to the continuous pretreatment system over the past few years in an effort to save on wastehauling costs.

In October 2009, the 30-day resample of Electron Plating resulted in a cadmium violation. OCSD staff noted no abnormalities with the company’s pretreatment system parameters at the time of the sampling, and Electron Plating reaffirmed that no nitric strip solution or rinse had been added to the pretreatment system since September.

In November 2009, OCSD conducted a compliance inspection and resampling at Electron Plating, with the intent of collecting individual process tank samples to determine if another source of cadmium existed within the company’s wet process area. Grab samples were collected from Electron Plating’s zinc chloride and nickel strike plating tanks and analyzed for cadmium and other heavy metals.

Electron Plating’s heavy metal pretreatment system is optimized for chromium and zinc removal, the company’s primary constituents of concern. During the November inspection and resampling, OCSD recommended that Electron Plating investigate modification of their pretreatment system operational parameters, and possibly add a coagulant to their pretreatment process. Due to the recent violations, Electron Plating agreed to explore all options to upgrade their pretreatment system.

The November resample was in compliance for cadmium and other heavy metals, with cadmium at non-detectable levels. The process tank sampling showed minimal heavy metals, besides zinc, in the chloride zinc plating tank. However, the nickel strike tank showed very high levels of metals, including a cadmium concentration of over 400 mg/L. Electron Plating responded that the nickel strike was infrequently used and that the bath had not been changed out in many years. The company also informed OCSD that they had contracted with a chemical supplier in late November to add a coagulant to their wastewater pretreatment. OCSD will continue to monitor Electron Plating on a quarterly basis.

4.17 Excello Circuits Manufacturing Corporation (Permit No. 52-1-815)

Excello Circuits Manufacturing Corporation (Excello) manufactures rigid multi-layer printed circuit boards. Wastewater-generating operations include accelerator, acid copper plating, alkaline cleaning, ammonia etching, anti-oxidant, board scrubbing, catalyst, cobra etch, cobra bond, desmear, electroless copper, heated soap cleaning, hydrochloric acid pre-dip, micro etch, neutralizer, permanganate, hot air levelling, resist strip, sulfuric acid dip, tin plating, tin strip, and associated rinses. Excello operates a manual batch treatment system.

In February 2010, OCSD collected a routine quarterly sample which resulted in a copper violation.

Excello changed ownership in 2008. The new owner removed the ion exchange system and attempted to maintain compliance solely through using batch treatment. In February 2010, OCSD staff conducted a routine pre-permit renewal inspection of Excello's facility. Staff observed that several running rinses were flowing at an extremely high rate although there was no work being processed. Subsequent comparison with other facilities with similar processing capabilities and employment levels confirm that Excello is using a disproportionately high volume of water. There is no end-of-pipe pretreatment for any of the running rinses, which are both acidic and metal-bearing. This is significantly below the Best Available Technology (BAT) standard required by federal categorical regulations. For this reason, the initial permit issued to Excello’s current ownership included a Special Condition that required re- activation of the ion exchange system if a discharge violation occurred.

In April 2010, OCSD held a compliance meeting with Excello. OCSD required Excello to either install a BAT-level end-of-pipe pretreatment system; optimize processing and minimize water usage to be able to treat all wastewater in an upgraded batch treatment system; or discontinue electroless and acid copper plating.

In May 2010, Excello and their consultant met with Elizabeth Clatfelter (Water Use Efficiency Programs Specialist, Municipal Water District of Orange County) and a consulting engineer to review Excello's processes. Excello has also arranged for an engineer to analyze the facility and ion exchange system to determine if it can be returned to service. In the following quarter, OCSD will monitor Excello’s progress and develop an implementation schedule.

FMH Investor Group (Permit No. 57-1-294)

FMH Investor Group (FMH) manufactures metal bellows and flexible metal hose from aluminum, Inconel, Monel, and stainless steel. Wastewater is generated by surface cleaning, hydrofluoric pickling, Inconel etching, passivation, nitric/hydrofluoric etching, penetrant inspection pressure testing, developing, and degreasing. FMH uses a silver recovery system for removal of silver from the wastestream.

In September 2007, FMH had a silver violation. In December 2007, OCSD contacted FMH to investigate the violation. FMH explained that the violation was due to malfunction of the silver recovery unit. The unit was repaired and worked properly. In December 2008, FMH had another silver violation. In March 2009, OCSD met with FMH to discuss the violation. FMH attributed the violation to inadequate maintenance of the silver recovery units. To correct the problem, FMH proposed to install two collection tanks following the silver recovery units to collect the treated fixer solutions. The treated wastestreams would be tested for silver concentration and discharged only if the sample results showed compliance with the discharge limits. In April 2009, FMH submitted a letter proposing the corrective actions. In May 2009, OCSD responded with a letter accepting the corrective action proposal. In June 2009, FMH had a silver violation. However, the violation was prior to installation of the collection tanks. OCSD required FMH to install the collection tanks immediately.

In July 2009, FMH informed OCSD that the company had completed installation of the collection tanks. OCSD will continue to monitoring FMH’s discharge on a quarterly basis.

4.18 Graphic Packaging International (Permit No. 57-1-314)

Graphic Packaging International (GPI) manufactures boxes by lithographic printing, cutting, folding, and gluing of paperboard. Wastewater is generated by rinsing baking compounds from lithiographic plates, washing glue pots with citrus cleaners, and rinsing the printing press.

In December 2009, GPI had a copper violation. In January 2010, GPI submitted a letter explaining that the violation was due to use of an ink product that contained copper. To correct the problem, GPI discontinued the use of that ink. OCSD will continue to monitoring GPI’s discharge on a quarterly basis.

Hanson-Loran Co., Inc. (Permit No. 3-1-107)

Hanson-Loran produces water-based floor finishers and specialty water-based multi-purpose cleaners for various independent contractors. Manufacturing consists of dry-blending and wet-blending raw chemicals to produce floor sealers, floor finishers, non-ammoniated wax strippers, floor cleaners, heavy duty cleaners and degreasers, sanitizers and disinfectants, and dish and hand soaps. Wastewater is generated from the washing of the mixing / blending tanks. Wastewater discharges to the sewer through a four-stage below- ground clarifier.

In December 2009, Hanson-Loran had an instantaneous oil and grease violation. Resampling in January 2010 showed compliance. Since no further violations were noted, no further action is warranted at this time.

IPC Cal-Flex Inc. (Permit No. 3-1-027)

IPC Cal-Flex (IPC) manufactures flexible printed circuit boards. Wastewater-generating operations include accelerator, acid cleaning, acid setter, activator, anti-ox, chemical cleaning, conditioning, acid copper plating, cupric chloride etching, developing, direct metalization, microetch, nitric rack stripping, peroxide etching, pre dip, resist stripping, screen washing, sulfuric acid dip, and associated rinses. IPC operates a continuous anionic / cationic ion exchange system. Regenerant from the system and concentrated spent solutions are treated in a batch treatment system.

In May 2010, IPC Cal-Flex had a copper violation. OCSD staff will conduct a compliance inspection in the following quarter.

J & R Metal Finishing (Permit No. 52-1-823)

J & R Metal Finishing (J & R) finishes metal parts by degreasing, tumble deburring, hand deburring, ball burnishing, and vibratory deburring. Solutions used in the processes contain borax, sodium tripolyphosphate, sodium nitrite, and sodium bisulfate. The pretreatment system consists of a pH adjustment tank followed by a lamella clarifier. Solids are dewatered in two filter presses.

In October 2009, J & R Metal Finishing had a self-monitoring zinc violation. J & R Metal Finishing submitted a permit application and pretreatment system drawings for the former J & H Deburring facility, and the company’s initial permit was issued effective July 1, 2009. J & R began production but did not operate the pretreatment system. During a followup inspection and sampling, OCSD staff instructed J & R to begin operating the pretreatment system immediately, which they failed to do. As a result, OCSD held a compliance meeting with J & R in February 2010. J & R hired JE Compliance Services to assist them with re-activation of the pretreatment system. J & R and JEC were instructed to first do what is necessary to bring the pretreatment system online as quickly as possible. Secondly, JEC was to submit proposed dates for achieving full compliance. In March 2010, J & R / JEC informed OCSD that they contracted with a third party to perform a comprehensive pretreatment system review. The review recommended that J & R install new pH controllers and chemical feed pumps, and also included jar testing to optimize treatment chemistry. J & R /JEC proposed to complete system modifications in March 2010.

4.19 In March 2010, J & R reported that the modifications to the pretreatment system were completed on schedule. OCSD staff collected a sample that same day, which resulted in compliance with all discharge limits. The quarterly sample collected in May 2010, resulted in compliance. No further enforcement is under consideration.

KCA Electronics (Permit No. 3-1-026)

KCA Electronics Inc. (KCA) is a large printed circuit board shop that manufactures double-sided and multi-layer printed circuit boards. The wet processes include mechanical/chemical cleaning (acidic, alkaline, and aluminum oxide); screening; UV and IR curing; solder masking; DES (develop-etch-strip); drilling; press punching; flux application; plating (electrolytic and electroless copper, tin-lead, and gold/nickel tip); black oxide; pumice scrubbing; deburring; bonding; vacuum lamination; resist coating and stripping; board fabrication; etching (microetch and cupric etch); desmearing; permanganate dip; catalytic conversion; acceleration; anti-tarnish dipping (organic coating); and associated rinsing for the various processes. KCA operates an extensive pretreatment system with multiple trains of ion exchange columns, automated pH adjustment, electrowinning, and batch treatment.

In January 2010, KCA had a copper mass emission rate violation. KCA conducts monthly self-monitoring for copper. Since no further violations were noted after the third quarter violation, no further action is warranted at this time.

Linco Industries, Inc. (Permit No. 2-1-253)

Linco Industries, Inc. (Linco) strips paint and powdercoating from metal parts using a high temperature molten salt process. Industrial processes conducted at the facility include racking, paint stripping in the molten salt bath, a hot water static rinse, and a cold water running rinse. The wastewater sources are the rinses and the fume scrubber blowdown. Due to multiple discharge violations, OCSD issued an Administrative Complaint against Linco and required installation of a pretreatment system. A settlement agreement resolved the complaint, and Linco installed a pretreatment system in April 2008. Linco reuses a portion of the treated water in the stripping process. Followup inspections by OCSD staff found the pretreatment system operating normally. On June 29, 2009, Linco had a chromium violation.

In July 2009, OCSD staff inspected Linco’s facility and pretreatment system. Linco personnel were performing maintenance on the pretreatment system. The company does not strip chromium, and Linco’s owner had no explanation for the chromium violation. Subsequent samples were in compliance. OCSD will continue to monitor Linco on a quarterly basis.

M C P Foods, Inc. (Permit No. 2-1-029)

MCP Foods, Inc. (MCP) manufactures food flavors from oils, starch, and sugars. The source of wastewater is washdown water from the tanks, equipment, and floors, discharge from a wet scrubber used in the spray drying process, and blowdown from a cooling tower. Pretreatment consists of automated pH adjustment. MCP has experienced periodic difficulty with BOD limits. Due to the high BOD loadings, MCP is required to perform daily self-monitoring.

MCP reported a total of fourteen violations of the 15,000 lb/day BOD limit from August through November 2009. OCSD held a compliance meeting with MCP in February 2010. MCP staff explained that wastewater is generated during “changeovers”, by cleaning the equipment in preparation for manufacturing a different flavoring. The flavorings are extremely high in BOD; on violation days, MCP had seven or more changeovers. In early 2009, the plant cut production and depleted inventory, and MCP also had a layoff. As inventory fell, production again ramped up, reaching a maximum in October 2009 that resulted in many changeovers and six violations. Twenty temporary workers were hired in October, which may have contributed to the violations since they were not fully trained. To mitigate the violations, MCP has implemented the following: in the continuous line, the first and last part of a flavor production do not meet specifications, and the discarded portion is therefore being wastehauled; “knockers” (which slow the rate of buildup by dislodging the material with vibration), many of which had been inoperable, have now been

4.20 repaired; the spray dryer, which produces 20% of the BOD loading, is being moved to a plant in New Jersey; the emulsion line will be moved to a plant in Mexico; and MCP projects that they will be up-to-date on current orders by July 1, 2010. By that date, production will decrease and processes will have been moved, and therefore MCP expects to be in achieve consistent compliance with the BOD limit.

MCP subsequently reported four violations of the BOD limit in May 2010. OCSD will continue to evaluate the effectiveness of MCP’s 15,000 lb/day BOD mitigation efforts.

Magnetic Metals Corporation (Permit No. 53-1-391)

Magnetic Metals manufactures toroid and cut tape-wound current transformer cores. The cores are employed in telecommunications, computer and business machines, electric motors, industrial controls, housing, aerospace and national defense equipment. Prior to painting and packaging, the cores are etched in phosphoric acid or ferric chloride. Dragouts follow both process solutions, with a static final rinse that is discarded to a holding tank when it becomes too contaminated to function effectively. No process solution or wastewater from the ferric chloride process is discharged to the sewer. The phosphoric etch and wastewater is transferred to a single holding/batch treatment tank. The pH is adjusted with sodium hydroxide using an automated controller and chemical feed pump. A mechanical mixer provides agitation, and the treated wastewater is discharged through a bag filter to the sewer. Solids are transferred to a drum and wastehauled.

In November and December 2009, Magnetic Metals had chromium violations. OCSD staff inspected Magnetic Metals’ facility and collected a 30-day resample in January 2010. Suspecting it to be the source of chromium, Magnetic Metals replaced a corroded stainless steel heater with a PVF version. OCSD also directed Magnetic Metals to sample the process tanks to discover if they are a source of chromium. The pretreatment system in place is adequate if well-operated. Both the January and March 2010 quarterly samples were in compliance.

In April 2010, Magnetic Metals' reported a concentration of 15.1 mg/l chromium in the phosphoric tank, and 511 mg/l chromium in the ferric chloride tank. With a chromium limit of 2.0 mg/l, Magnetic Metals must treat wastewater from both processes. Since all wastewater from the ferric chloride process is wastehauled, OCSD staff suggested that Magnetic Metals avoid commingling the two wastestreams by not pumping them through the same lines. This avoids having to treat remnants of the highly concentrated solution.

In June 2010, Magnetic Metals submitted a letter outlining corrective action, including monthly testing for chromium, and pumping the concentrated ferric chloride solution directly into a plastic 55-gallon with a sump pump. Quarterly sampling was again in compliance. No further enforcement action is under consideration.

Nyala Screenprinting, Inc. (Permit No. 14-1-024)

Nyala Screenprinting, Inc. (Nyala) operates a silk-screening process that prints designs on t-shirts and sweatshirts. Wastewater is generated by screen cleaning. Filtering screens are placed in boxes over floor drains to catch dried inks, emulsified ink, and soap scum.

In September 2009, Nyala had a total toxic organics (TTO) violation. In October 2009, Nyala informed OCSD that Nyala found the source of TTOs in two products, “Instant Screen Opener” and “Clear Lacquer Blockout”. Nyala terminated the use of these two products in the manufacturing process. In the same month, Nyala pumped and cleaned the clarifier, and OCSD conducted a 30-day resampling for TTO. The results of all four grab samples showed compliance with discharge limits.

In January 2010, Nyala had another TTO violation. In March 2010, Nyala informed OCSD that the company had discovered that “Spot Cleaning Fluid” was the source of methylene chloride and tetrachlorothene. Nyala mandated employees to keep the spot cleaning fluids away from the screening process area where cross-contamination may occur.

4.21

In May 2010, OCSD renewed Nyala’s permit and increased TTO self-monitoring frequency from semi- annually to quarterly. OCSD will continue to monitor Nyala’s compliance status on a quarterly basis.

OC Alphanetics Inc. (Permit No. 1-1-136)

OC Alphanetics is a full-service manufacturer of printed circuit boards located in Santa Ana. The facility operates a continuous ion exchange pretreatment system for pretreatment of metal-bearing rinses. OC Alphanetics also operates a batch treatment system for spent solutions and ion exchange regenerant. The batch treatment system consists of pH adjustment, coagulation, flocculation, settling, and dewatering.

In November 2008, OCSD monitoring resulted in a copper violation. Following the violation, OC Alphanetics submitted a report that traced the violation to a plumbing repair performed on the drain line of the microetch in the shadow plating line. The pipe was erroneously connected directly to the clarifier, bypassing treatment. OC Alphanetics subsequently corrected the plumbing. In January 2009, OCSD staff conducted a compliance inspection and found that the plumbing had been corrected as detailed in the December letter. Sampling conducted since the inspection is in compliance.

In September 2009, the facility shut down without notice. OCSD terminated the permit in the same month.

Omni Metal Finishing, Inc. (Permit No. 2-1-520)

Omni Metal Finishing (Omni) is a large job shop that provides finishing services for aerospace, commercial, and military / defense applications. Omni performs electroplating, surface finishing, and painting on customer-supplied parts made of aluminum, brass, copper, Inconel, mild and stainless steel, titanium, and tungsten alloys. The major wet manufacturing processes include acid, alkaline and solvent cleaning, anodizing, black oxide coating, conversion coatings, black chemical finish, black oxide on copper and brass alloys, cadmium plating, copper plating, dry film lubricant, electroless nickel, nickel plating, passivation, phosphate coating, magnesium processing, tin / tin-lead plating, zincate, and associated rinses. The pretreatment system consists of equalization, two-stage cyanide destruct, a proprietary metal ion electrochemical precipitation system and filter, lamella clarification, and sludge dewatering. There are two closed-loop systems consisting of ion exchange columns with electrowinning units. Omni also operates a batch treatment system to treat concentrated solutions.

On March 30, 2010, Omni had a zinc violation.

Omni purchased a zinc lamp for their in-house AA unit, and sampled for four consecutive days to establish compliance. The 30-day resample and the routine quarterly sampling were both in compliance. Since Omni operates extensive pretreatment equipment beyond BAT and has augmented their in-house analytical capability, no further enforcement is under consideration.

Orange County Metal Processing (Permit No. 2-1-530)

Orange County Metal Processing (OCMP) is a job shop performing various surface treatments on customer-supplied parts constructed of steel and aluminum. Wet processes include alkaline cleaning, acid activation, anodizing, electroless nickel, nickel, and zinc plating, passivation, and chromate conversion coating. OCMP operates both continuous and batch pretreatment systems that include pH adjustment, hexavalent chrome reduction, cyanide destruct, polymer addition, clarification, sludge dewatering with a filter press and final pH adjustment.

In March 2009, OCSD monitoring of OCMP’s effluent showed a chromium violation. In April 2009, OCMP had a second violation of the chromium discharge limit. In May 2009 OCSD conducted an inspection and resample in response to the noncompliance. OCMP stated that the chromium violations were caused by mishandling of wastewater generated during a specific oversize rim plating job. The size of the rims necessitated the use of a larger rinse tank which is not plumbed to the

4.22 chromium reduction unit. The responsible employee received retraining, and procedures for handling of wastewater from such a job were conveyed to all other OCMP staff.

All subsequent samples collected have been in compliance. No further enforcement action is under consideration.

Orange County Register (Permit No. 1-1-016)

Orange County Register (OC Register) is a newspaper publisher with all administrative and manufacturing operations onsite. Manufacturing processes include photo processing and page layout, negative plate preparation and newspaper printing. Wet processes include photo processing of negative images, plate making (with gum arabic) including color lab, and fountain solution (removal of excess ink from printing plate) waste overflow. Pretreatment of photo processing wastewater is accomplished with electrolytic silver recovery followed by metallic replacement canisters.

In September 2006, OC Register notified OCSD of changes in their operations. The new equipment uses computer-to-plate (CTP) technology, replacing the photo processors and their associated discharges. The silver recovery equipment was taken offline when the CTP units were installed. OCSD inspected the facility on April 2007, to assess whether a Class I permit was required. It was observed that industrial wastewater discharge had been substantially eliminated; however, a grab sample of the remaining discharge collected during the inspection resulted in a violation of the total toxic organics (TTO) discharge limit. OCSD conducted additional sampling on May 2007, which also resulted in noncompliance with the TTO discharge limit.

In July 2007, OCSD held a compliance meeting to discuss the TTO violations. OC Register theorized that, since the primary constituent was chloroform, the source of the TTO's was most likely bleach. The company had only recently discontinued its use. Also in July 2007, an OCSD composite sample of OC Register’s discharge again showed noncompliance with TTO limits. In December 2007, an OCSD’s grab sample resulted in further noncompliance with TTO limits. Later in December 2007, OC Register submitted a letter detailing their renewed efforts to control TTO’s in the effluent, which were no longer attributed to the bleach. Their focus was now on the reagents used in the new CTP equipment.

OCSD issued a letter in January 2008, requiring OC Register to attend a compliance meeting later in the third quarter. Due to staff turnover at the facility, this notice did not reach the appropriate staff and OC Register failed to attend the meeting. In February 2008, OC Register’s new contact sent a letter updating OCSD on their efforts to track the source of TTO’s.

In March 2008, an OCSD grab sample resulted in a TTO violation. OCSD conducted a compliance inspection in May 2008 in response to the continued noncompliance. During the inspection and meeting, OC Register’s new contact was advised of the recurring TTO violations at the facility. Topics discussed included the solvents primarily responsible for the violations, potential changes to the self-monitoring requirements of their permit, and the probable outcome of continued TTO violations. In June 2008, another OCSD grab sample was in violation of TTO limits.

In July and September 2008 monitoring resulted in TTO violations. OCSD held a compliance meeting with OC Register in September 2008 to update OCSD on their ongoing efforts to resolve their TTO noncompliance issues. OC Register presented their proposal for installation of a carbon filtration system and plans for maintaining compliance in the interim.

In November 2008, OCSD conducted an inspection to determine the status of the proposed corrective measures. OCSD staff found that the industrial discharge had been contained and wastehauled since October and that installation of the new pretreatment equipment was nearing completion.

OCSD conducted another inspection of the facility to verify improvements to pretreatment in February 2009. The pretreatment system had been installed and was operational, and sewer discharge had

4.23 commenced after the unit was brought online. OC Register’s contractor provided a schematic with a written description of the equipment installed.

In April 2009, OC Register’s self-monitoring sample resulted in a TTO violation. Again in June 2009 an OCSD grab sample indicated continued noncompliance with TTO limits. On June 2009, OC Register advised OCSD that they intended to replace the existing Kodak CTP units with new units which do not use chloroform in the process chemistry.

In September 2009, OCSD held a compliance meeting to resolve the TTO noncompliance. During the meeting, OC Register detailed recent developments and shared additional sampling results. Also in September 2009, OC Register had a TTO violation.

OCSD issued a letter in November 2009 to OC Register that required documentation of the information presented at the meeting and to update OCSD regarding installation of the new CTS equipment. The company responded in a timely manner. OC Register installed the new CTS units during the third quarter of FY 2009/10, and should therefore achieve consistent compliance. OCSD will continue to sample OC Register on a quarterly basis.

Precision Anodizing and Plating, Inc. (Permit No. 52-1-809)

Precision Anodizing and Plating, Inc. (Precision Anodizing) is a large plating and anodizing job shop. Wastewater-generating processes include chromate conversion coating, acid pickling, alkaline cleaning, zinc plating, aluminum bright dip, and sulfuric acid anodizing. The continuous pretreatment system consists of chromium reduction, hydroxide precipitation, flocculation, lamella clarification, filter press, effluent pH control, and sludge dryer. Spent chemicals are batch-treated on site.

In February 2008, Precision Anodizing had chromium and zinc violations. Precision Anodizing attributed the violations to accumulation of solids in the sample box and clarifier. As a corrective measure, the contents of the clarifier were pumped and dewatered in the filter press. Resampling in March 2008 showed compliance. In June 2008, OCSD began a special sampling project at Precision Anodizing. The preliminary results showed low pH levels in the wastewater discharge, indicating potential violations.

Downstream sampling of Precision Anodizing’s discharge from June 28 through August 23, 2008 detected a total of 11 days of pH violations with several at hazardous levels (below 2.0). Analytical results yielded a total of 20 instantaneous (grab) violations and 7 daily (24-hr composite) violations of chromium, copper, nickel, lead, and zinc limits. In November 2008, OCSD issued an Order to Cease Noncompliant Discharges to Precision Anodizing.

In January 2009, OCSD held a compliance meeting with Precision to discuss the violations detected during the downstream sampling. Precision Anodizing stated that they were unaware that their pretreatment system had not been functioning properly because the effluent pH recorder and alarm had not been registering pH levels outside the discharge limits. In February 2008, Precision submitted a list of corrective actions to achieve compliance, which included changing pretreatment chemicals.

From March 2, 2009 through March 25, 2009, OCSD conducted a follow-up downstream sampling to determine the effectiveness of Precision Anodizing’s pretreatment system modifications. OCSD also conducted a compliance inspection, during which staff noted that the pH recorder was not recording the actual pH of the wastewater in the sample box. This followup downstream sampling detected further zinc violations on two separate days.

In April 2009, OCSD held a second compliance meeting with Precision Anodizing to inform them of OCSD’s decision to issue an Administrative Complaint and to discuss the potential penalties involved. OCSD issued the complaint in June 2009 with an administrative hearing scheduled for the end of July 2009.

4.24 When Precision Anodizing’s permit was renewed in May 2009, OCSD increased the frequency of self- monitoring for copper, chromium, lead, nickel and zinc from quarterly to weekly to more closely monitor Precision Anodizing’s discharge and compliance status.

In July 2009, Precision Anodizing had a zinc violation. The company submitted a written explanation and corrective action for the zinc violation. Resampling later in the same month showed compliance. At Precision Anodizing’s request, OCSD rescheduled the administrative hearing to late September 2009; it was later cancelled as Precision Anodizing opted instead to enter into a Settlement Agreement.

In October 2009, OCSD sent the Settlement Agreement to Precision Anodizing for signature. In December 2009, upon the Board of Director’s approval, OCSD entered into a Settlement Agreement with Precision Anodizing. In addition to monetary penalties, the Settlement Agreement requires Precision Anodizing to submit a Wastewater Characterization and Pollutant Identification Report, as well as a proposal for pretreatment system upgrade and/or modification to ensure long-term compliance.

In the next quarter, OCSD will continue to monitor Precision Anodizing’s discharge and track required submittals to ensure compliance with the Settlement Agreement.

Precon, Inc. (Permit No. 2-1-581)

Precon, Inc. (Precon) is a medium-sized machine shop that conducts bandsaw metal cutting, double-disc grinding, tumbling / deburring, precision thread gage manufacturing, and abrasive blasting. Wastewater is generated from the tumbling / deburring operations. Precon has a three-stage clarifier for solids settling. Spent chemicals are wastehauled offsite.

After multiple oil and grease violations in 2006 and 2007, OCSD issued an Order to Cease Noncompliant Discharges in February 2007, and required Precon to submit a description of corrective action to prevent further violations. In April 2007, Precon submitted a letter reporting the corrective actions implemented onsite. In late 2007, Precon had further oil and grease violations, as well as instantaneous zinc and copper violations. Resampling in December 2007 resulted in another instantaneous copper violation.

In January 2008, OCSD issued a second Order to Cease Noncompliant Discharges. In February 2008, OCSD held a compliance meeting with Precon during which OCSD emphasized the need for a pretreatment system to remove the oil and grease as well as the suspended solids that may be causing the heavy metal violations. In March, 2008, OCSD issued a Probation Order requiring: a) installation of the pretreatment system, b) weekly self-monitoring for oil and grease, copper and zinc, and c) submittal of bi-weekly progress reports.

In April 2008, Precon began submitting bi-weekly progress reports. Inspection of the facility in May 2008 confirmed installation of two in-series polishing filters through which wastewater from the third stage of the below-ground clarifier is routed prior to discharge to the sample point. When Precon’s permit was renewed in May 2008, OCSD increased the frequency of Precon’s oil and grease self-monitoring from quarterly to weekly to more closely monitor Precon’s discharge and compliance status.

In October 2008, Precon submitted a letter stating that the company had eliminated most sources of oil and grease in its processes, yet still experienced problems with oil and grease values as analyzed by EPA Method 1664. Precon also stated that testing of “Cleanzit” and burnishing compounds yielded high oil and grease values as well, and therefore had discontinued their use. In October 2008, Precon had two more oil and grease violations. From November 2008 through July 2009, Precon had no further oil and grease violations.

In August 2009, Precon had an oil and grease violation. Resampling in October 2009 showed compliance.

In April 2010, Precon had a copper violation. Precon conducts weekly self-monitoring for copper and zinc as part of previous enforcement action for heavy metals violations.

4.25

In 2007, OCSD staff discovered evidence of tampering in three of Precon’s self-monitoring reports, indicating potential falsification of test results. The case was referred to the Orange County District Attorney’s (OCDA) office. Records submitted by the laboratory confirmed Precon’s falsification of self- monitoring test results. In March 2010, OCDA met with Precon to present their findings. Precon voluntarily admitted falsification of data and is now in settlement negotiation with OCDA.

During the next quarter, OCSD will continue to monitor Precon’s discharge to determine the need for escalated enforcement action.

Private Label Laboratories, Inc. (Permit No. 52-1-755)

Private Label Laboratories (PLL) manufactures industrial soaps, detergents, and boiler and cooling tower treatment compounds from raw materials. Wastewater is generated from rinsing the mixing vats and drums, and washing the floor. Wastewater is collected in a holding tank, pH adjusted, and air- agitated. Prior to discharge to the sewer, PLL collects a sample for total toxic organics (TTO) analysis. If TTOs are present, the wastewater is pumped through activated carbon adsorbers to remove the TTOs. If TTOs are not present, the wastewater is discharged directly to the sewer. In February 2009, PLL had a zinc violation.

In April 2010, PLL had an instantaneous oil and grease violation.

During the upcoming renewal of PLL’s permit, OCSD may require PLL to conduct self-monitoring for oil and grease on a monthly basis. If further oil and grease violations occur, OCSD will require pretreatment for oil and grease.

Reid Metal Finishing (Permit No. 51-1-376)

Reid Metal Finishing (Reid) is a metal finisher that performs plating and anodizing on steel, stainless steel, aluminum, copper, brass, bronze, and die-cast zinc. Wastewater-generating processes include aluminum cleaning and etching, cadmium plating, chemfilm, chromic anodizing, copper plating, electroless nickel plating, chromate conversion coating, muriatic acid activation, nickel plating, passivation, red, blue, black, and gold dyeing, alkaline cleaning, sulfuric anodizing, zinc plating, and associated static and running rinses. Reid operates two continuous pretreatment systems consisting of chromium reduction, two-stage cyanide destruction, chemical precipitation, coagulation/flocculation and clarification followed by a polishing filter and two filter presses. All spent solutions including cleaners are wastehauled off site.

During fiscal year 2008/9, Reid had chromium and total cyanide violations. Reid implemented corrective measures by installing new analog pH and ORP controllers for the chromium reduction pretreatment system. Reid also discontinued the practice of feeding cyanide-bearing floor wastes to the continuous pretreatment system, and installed a spray rinse after the cadmium cyanide plating tank. OCSD conducted a compliance inspection in June 2009 to confirm that Reid had completed all proposed corrective measures.

In October 2009, Reid had a total toxic organics (TTO) grab violation. In November 2009, OCSD conducted a 30-day resample for TTO. The results of all four grab samples showed compliance with discharge limits. A review of sampling results showed that this is the only TTO violation that has occurred since July 2000. No further enforcement is presently under consideration.

Reliance Plating & Coating Inc. (Permit No. 53-1-423)

Reliance Plating & Coating Inc. (Reliance) is a job shop electroplating facility that performs surface finishing on aluminum and steel parts supplied by various manufacturers. Wet processes include electroless nickel, nickel, tin and zinc plating, anodizing, chemfilm, passivation, cleaning with caustic and acidic solutions, and miscellaneous shop cleanup. The facility operates an automated continuous

4.26 pretreatment system with segregated (acidic and alkaline) wastewater collection, pH adjustment, hexavalent chromium reduction, hydroxide precipitation, flocculent addition, clarification, and sludge dewatering with a filter press. Spent solutions are batch-treated in a single tank prior to discharge.

In July 2009, Reliance had a chromium violation. OCSD conducted a compliance inspection in September 2009. During the inspection, it was discovered that Reliance staff had turned on the pretreatment system so that the sampler would collect wastewater, even though the plating line was not in operation. The sudden upset of the system is believed to have led to some material reaching the sample point due to unsteady-state operation. Reliance was cautioned to operate the system only in conjunction with the plating line being operational. All subsequent samples collected have been in compliance. As a result of continued compliance, no further enforcement actions are presently necessary.

Remedy Environmental Services (2-1-421)

Remedy Environmental Services (Remedy) is a centralized waste treatment facility located in Anaheim, and operates as a support facility for the adjacent Adams Steel scrapyard. Remedy takes in nonhazardous wastewater (clarifier washouts, equipment washwater, food processing washwater, mop water) from various customers across Southern California, predominantly by tanker truck, then pretreats and cleans up the water for use in the scrapyard as cooling water for the metal shredding equipment. Infrequently, Remedy needs to discharge the treated water to the sewer when the shredding equipment is down for maintenance, or if there is a surplus of runoff water from rain events.

The batches of wastewater received at Remedy are pumped through a coarse solids filtration tank, then transferred either to an oil / water separation tank for removal of excess oil and grease, or into a flocculation / filtration system with filter press for solids removal. Decant from the oil and grease separator is pumped into the flocculation / filter system, while the separated oil and grease is collected in a storage tank for off-site disposal. Filtered water is then pumped through sand filter beds and polished in a carbon filter before storage in two 15,000 gallon bulk tanks. From there, the treated wastewater can be pumped over to the scrapyard for cooling use, or discharged to a sewer connection alongside the tank containment area.

In June 2010, Remedy had a vanadium violation. In the next quarter, OCSD will issue a Notice of Violation for the vanadium noncompliance and also collect a 30-day resample.

Republic Waste Services of So. Cal., LLC (Permit No. 2-1-169)

Republic Waste Services of So. Cal., LLC (RWS) is a material recycling facility. Materials recovered include construction debris, greens, and other recyclables. All of the trash collection trucks are serviced and maintained onsite. This includes fueling, welding, painting, engine work, and truck washing. Wastewater is generated from the washing of the trash collection trucks. Wastewater discharges to the sewer through a three-stage below-ground clarifier.

In October 2009, RWS had a total toxic organics (TTO) violation. Resampling in January 2010 showed compliance. Since no further violations were noted after the second quarter, no further action is warranted at this time.

Rigiflex Technology (Permit No. 2-1-187)

Rigiflex Technology, Inc. (Rigiflex) is a manufacturer of prototype rigid, flexible, and rigid / flex printed circuit boards. Wastewater-generating operations include film processing, developing, ammonia etching, scrubbing, resist stripping, acid cleaning, acid copper plating, tin plating, microetch,, sulfuric acid surface activation, screen cleaning, and associated rinsing. Continuous pretreatment includes equalization and ion exchange for the metal-bearing wastestreams, and pH adjustment for the nonmetal-bearing wastestreams. Spent chemicals including ion exchange regenerant are wastehauled offsite.

4.27 In April 2010, Rigiflex had a silver violation. In May 2010, OCSD conducted a compliance inspection and resampling. Rigiflex explained that their film processor had a leak and they disposed of the solution into the collection sump without pretreatment when they replaced the leaking pipe. OCSD advised Rigiflex to contain and reuse the solution if possible next time they have a leak. The resampling results showed compliance.

OCSD believes that the leak / silver violation was a rare and isolated incident. Therefore, no further enforcement action is warranted at this time.

SPS Technologies (Permit No. 1-1-310)

SPS Technologies (SPS) is a manufacturer of specialty fasteners, assemblies, and precision components for commercial and military aircraft, automotive, rail, trucks, farm, and construction equipment, industrial machinery, and commercial aircraft window channels. Wastewater-generating processes include ammonium nitrate stripping, cadmium plating, muriatic acid and chromic acid, copper cyanide and copper sulfate plating, electrocleaning, yellow chromate, nickel chloride and nickel sulfate plating, passivation, nitric rack stripping, olive drab chromate, silver plating, soap cleaning, sodium dichromate, and associated static and running rinses. SPS operates a continuous pretreatment system consisting of chromium reduction, two-stage cyanide destruction, equalization, chemical precipitation, coagulation/flocculation, clarification, sludge thickening, filter press, and an oil/water separator.

During fiscal year 2008/9, SPS had nickel and total cyanide violations. SPS implemented corrective measures by installing a spray rinse after the nickel plating tank and increasing drip time to reduce dragout into the continuous pretreatment system. OCSD conducted a compliance inspection in May 2009 to confirm completion of SPS’s corrective measures.

In July 2009, SPS had a total cyanide violation. Later that month, SPS informed OCSD that SPS had adjusted operating pH and increased retention time for cyanide treatment tanks, and installed flow restrictors on all cyanide rinse tanks. SPS also proposed to install ion exchange resin columns to treat cyanide complex ions generated from the plating process. In August 2009, SPS had another total cyanide violation.

In December 2009, SPS informed OCSD that SPS had completed installation of the resin columns to treat the complex cyanide wastewater. To verify the effectiveness of the new ion exchange system, SPS conducted self-monitoring for cyanide in September, October, November, and December 2009. Results of all four samples show compliance with cyanide discharge limits. Subsequent OCSD inspections and sampling results also showed compliance, confirming the effectiveness of the new ion exchange system.

No further enforcement is warranted at this time.

Santana Services (Permit No. 2-1-016)

Santana Services (Santana) is a job shop performing welding and brazing services on aluminum parts. Wet processes performed include alkaline cleaning and etching, acid cleaning and etching, de-ox cleaning and salt-based descaling. Pretreatment at the facility includes manual batch pH adjustment prior to discharge of the effluent tank.

In March 2010, Santana had a chromium violation. In May 2010, the OCSD conducted a compliance inspection at Santana to followup on the noncompliance. During the inspection, OCSD staff found that the batch discharge log, which is a requirement under Santana’s discharge permit, had not been maintained. As a result, no record of the discharge on the day in question was available. Santana surmised that the stainless steel baskets used to hold the parts to be cleaned may have been immersed in the solution too long and could have contributed the chromium found in the noncompliant sample.

4.28

Continued sampling for heavy metals will be reviewed to determine if additional enforcement is required.

Select Circuits (Permit No. 1-1-065)

Select Circuits is a printed circuits board manufacturer. Wastewater is generated from developing, resist stripping, scrubbing, cupric chloride etching, screen cleaning, acid cleaning, black oxide, and associated rinsing. Select Circuits operates a continuous pretreatment system consisting of equalization, chemical precipitation, coagulation/flocculation, clarification, and filter press. Spent chemicals are either treated on site or wastehauled off site.

In July 2009, Select Circuits had a copper violation. It was observed during this sampling event that there was soapy water overflowing in the sample box. The violation may have been caused by the interference of the soapy wastewater in the pretreatment system. OCSD advised Select Circuits to bypass any uncontaminated soapy wastewater to eliminate the treatment interference.

In September 2009, OCSD conducted a 30-day resample which showed compliance. Self-monitoring conducted in August 2009 also showed compliance. No further enforcement is required at this time.

Shepard Bros. Inc. (Permit No. 3-1-034)

Shepard Brothers, Inc.(Shepard Brothers) is a soap and detergent manufacturer that blends both liquid and dry components into a complete line of wet and dry cleaning products for the food and dairy industry. Additionally, the company buys products manufactured elsewhere, and then relabels and resells the product. Over 350 compounds, including liquid and powdered acids, alkalis, additives, chelants, and phosphates are handled and stored at the site. Shepard Brothers operates a batch pH adjustment system. The pH is checked and adjusted manually with caustic soda.

In March 2010, Shepard Brothers had an oil and grease violation. In April 2010, Shepard Brothers had another oil and grease violation. Shepard Brothers informed OCSD that the possible cause was a rinsing of hydrocarbon-contaminated utensils. Production employees were mandated to perform correct cleaning procedures to clean utensils prior to rinsing to prevent cross-contamination.

In June 2010, Shepard Brothers again had an oil and grease violation. To prevent further non- compliance, the company elected to install an alumino-silicate based filter to absorb petroleum products.

OCSD will verify the installation of the filter unit and continue to monitor Shepard Brothers in the next quarter.

Soldermask, Inc. (Permit No. 3-1-341)

Soldermask is a printed circuit board job shop. Wet processes include acid and alkaline cleaning, image developing, etching, scrubbing, and associated rinses. Pretreatment is limited to pH adjustment, filtration of scrubber wastes, and metallic replacement canisters for use on photoprocessing wastewater prior to discharge. Metal-bearing spent solutions are wastehauled.

In November 2008, Soldermask had a copper violation and a silver violation. In January 2009, Soldermask had a second silver violation. Soldermask submitted correspondence outlining their investigation into the recent noncompliance and the actions taken to remedy the problem in February 2009. The use of a new product, specifically a hand-applied coating used on certain jobs, was believed to be the source of the metals. Procedures for the handling of waste from these jobs, which included isolating the material and having it wastehauled separately, have been adopted.

4.29 OCSD conducted a compliance inspection in July 2009, to verify that compliance measures taken by Soldermask were being implemented. Sampling conducted during the inspection confirmed compliance with silver and copper discharge limits.

In February 2010, Soldermask had a total toxic organics (TTO) violation. OCSD conducted a compliance inspection and collected a 30-day resample in March 2010. This sample also resulted in noncompliance.

Soldermask stated in correspondence submitted in March 2010, that to the best of their knowledge based on a review of Material Safety Data Sheets (MSDS), the facility does not use any materials that contain the TTO constituent that resulted in the violation. Soldermask submitted correspondence updating their ongoing investigation of the source of TTO’s in April 2010. The company independently tested a solvent in use at Soldermask, and found high levels of the TTO, which the vendor had failed to disclose on the MSDS.

OCSD held a compliance meeting with Soldermask in June 2010. Soldmask has discontinued the use of the product and thoroughly cleaned the pretreatment system and sample point. Subsequent TTO analytical results will be reviewed to verify the elimination of the constituent.

South Coast Oil Co. (Permit No. 11-1-019)

South Coast Oil Co. (SCOC) operates crude oil producing wells located in Huntington Beach. Crude oil from the wells is pumped to a bulk oil/water separator to remove the product. Wastewater is directed through a clarifier prior to sewer discharge.

In October 2006, OCSD’s monitoring of SCOC showed a violation of the total toxic organics (TTO) discharge limit. In response to the violation, OCSD conducted a compliance inspection of the facility in January 2007. During the inspection, SCOC’s staff detailed a management reorganization that also included a change of the company’s name. OCSD informed the new contact of the violation as well as the company’s recent failure to submit self-monitoring reports. The contact, who had only recently been hired, stated that he would investigate the missing reports and review well operations immediately. In June 2007, OCSD’s monitoring showed another violation of the TTO discharge limit.

In December 2007, OCSD issued a letter requiring SCOC to attend a compliance meeting to resolve long- term issues about compliance, report submittal, and to settle the question of ownership of the wells. SCOC attended the meeting in January 2008. SCOC noncompliance issues were reviewed in detail. SCOC staff agreed to perform monitoring as required by the permit, and to provide complete company information. Subsequent self-monitoring was performed and submitted on time for a short while. The permit was renewed in February 2008 based on the available information.

SCOC violated TTO discharge limits frequently throughout 2008. OCSD issued a letter in December 2008 that required SCOC to attend a compliance meeting the following quarter.

In January 2009, OCSD held a compliance meeting with SCOC to discuss the violations. Also, SCOC’s self-monitoring delinquencies were discussed. The company stated that it had cleaned the clarifier and repaired or replaced associated equipment. OCSD issued an Order to Cease Noncompliant Discharges and Order to Cease Discharge without Authorization to SCOC in response to the multiple violations of TTO limits and the company’s failure to submit a permit renewal application in a timely manner.

OCSD samples collected in February 2009 were in violation of TTO limits, clearly indicating that the measures implemented by SCOC to date were inadequate. OCSD issued a letter requiring SCOC to attend another compliance meeting to address the various inadequacies.

In April 2009, OCSD conducted an inspection of SCOC’s facility to assess the facility in preparation for the upcoming compliance meeting. During the inspection, OCSD collected a grab sample for TTO. In April 2009, OCSD held the compliance meeting with SCOC, which was attended by a court-appointed

4.30 trustee. SCOC described additional changes to production and pretreatment units at the facility, which included removal of the air-injection header from the clarifier, ground-up rebuild of wash and collection tanks, and maintenance to pumps and associated piping. The sample collected during the fourth quarter was in compliance.

In July, August, and October 2009, and in February 2010, SCOC had TTO violations.

OCSD staff conducted a compliance inspection in February 2010, to assess the state of the facility prior to the meeting scheduled for the following week. In March 2010, OCSD held the compliance meeting, during which SCOC described recent maintenance and housecleaning activity performed at the site in February 2010. OCSD informed SCOC that if the measures taken were insufficient to ensure consistent compliance, an Administrative Complaint based on TTO discharge violations and unsubmitted self- monitoring reports would follow. In March 2010, a TTO violation again occurred.

In April 2010, SCOC had a TTO violation.

In June 2010, OCSD issued an Administrative Complaint seeking significant monetary penalties and pretreatment system upgrades. The hearing date is scheduled for July 2010.

Superior Plating (Permit No. 2-1-090)

Superior Plating is a medium-sized plating shop serving both aerospace and commercial customers. Wastewater-generating operations include acid activation, alkaline cleaning, alkaline tin plating, bright dip, bright gold plating, bright nickel plating, bright silver plating, bright tin plating, cadmium plating, chromate conversion coating, copper strike, de-scaling, electroless nickel plating, hot DI rinsing, matte silver plating, nickel plating, nickel strike, soft gold plating, tin-lead plating, and zincate. Superior Plating operates a continuous pretreatment system which includes cyanide destruction, hydroxide precipitation, flocculation, clarification, polishing filter, and filter press. Concentrated spent solutions are treated in a batch treatment system.

Downstream sampling conducted at Superior Plating in April 2006 detected cadmium violations on three separate days. Subsequent onsite sampling by OCSD from April to May 2006 again detected cadmium violations, as well as a nickel violation. In June 2006, OCSD prepared an administrative complaint against Superior Plating for the violations cited.

In September 2006, Superior Plating elected to enter a settlement agreement with administrative penalties. Upon renewal of Superior Plating’s permit in December 2006, OCSD increased the self- monitoring frequency for cadmium from quarterly to weekly.

From April through May 2007, OCSD conducted a Phase 2 downstream sampling to verify discharge compliance following the Settlement Agreement. The results showed pH, cadmium and cyanide violations. In July 2007, OCSD issued an Order to Cease Noncompliant Discharges. In August 2007, OCSD held a compliance meeting with Superior Plating to discuss the downstream violations and potential penalties. In September 2007, OCSD sent Superior Plating a letter that required implementation of corrective measures and submittal of a Compliance Progress Report by January 2008.

In May 2008, Superior Plating submitted a Wastewater Treatment Evaluation Report (WWTER) prepared by its consultant, which recommended replacement of all treatment tanks and process instrumentation. In December 2008, Superior Plating submitted the plans for its pretreatment system upgrade.

In March 2009, Superior Plating completed replacement of its pretreatment system. In April 2009, Superior Plating submitted revised / updated drawings of its new pretreatment system, as well as a copy of its wastewater treatment operations and maintenance manual in both English and Spanish versions.

4.31

In July 2009, Superior Plating had a cadmium violation. In August 2009, Superior Plating appealed the violation based on the results of the split sample which Superior Plating submitted to an independent laboratory for analysis and which showed compliance with the cadmium discharge limit. However, OCSD rejected the appeal based on the chain-of-custody record of the sample showing the temperature of the sample outside the acceptable range and the sample not having a custody seal.

In October 2009, Superior Plating submitted a letter detailing the corrective actions implemented to prevent further cadmium violations. These included installation of an additional treatment tank and augmented treatment chemistry for cadmium removal. In November 2009, OCSD conducted a compliance inspection and confirmed installation of the additional treatment tank as well as the presence of chemicals used to enhance cadmium removal.

In May 2010, Superior had a cadmium violation. In May 2010, Superior Plating submitted a request to switch from continuous to batch treatment of its light rinse wastestreams. In May 2010, OCSD required Superior Plating to submit additional information regarding the proposed batch treatment. In June 2010, Superior Plating submitted the required information. In June 2010, OCSD required submittal of additional site drawings and flow diagram.

During the next quarter, OCSD will continue to monitor Superior Plating’s discharge and evaluate the effectiveness of the pretreatment modifications.

Tayco Engineering Inc. (Permit No. 3-1-012)

Tayco Engineering Inc. (Tayco) is a large aviation and aerospace parts manufacturing company located in Cypress. Flexible heat / temperature sensors, heat sinks, thermal controllers and wiring harnesses are manufactured from Kevlar and Teflon substrates laminated with nichrome and hastelloy metal foils.

Wastewater is generated by developer, ferric chloride etch, fume scrubber, metal foil scrub, resist stripper, and associated rinses. Tayco employs a batch treatment system that consists of a collection and equalization tank followed by a conical-bottom batch treatment tank equipped with automated pH / ORP controls and air sparging. The decant from the batch tank is drained from a multi-level manifold into a sampling tank with sewer connection. Solids are withdrawn from the bottom of the tank and dewatered with a filter press. Tayco typically processes one batch of 300-400 gallons every five to ten work days.

In May 2010, Tayco had a nickel violation. Tayco believes an ORP probe used in the batch treatment process failed, and immediately replaced it. OCSD staff will conduct a 30-day resample and inspection in the next quarter.

TechPlate, Inc. (Permit No. 2-1-082)

TechPlate, Inc. (TechPlate) is a job shop that performs metal finishing services on steel and brass parts. The company specializes in custom plating of gun parts and refinishing of other specialty or antique items. Wastewater-generating operations include alkaline and electrocleaning, black oxide, chrome plating, manganese phosphating, nitric acid cleaning, rust inhibitor, zinc phosphating, and associated rinsing. Techplate operates a batch treatment system with pH adjustment.

In September 2009, TechPlate had a cadmium violation.

Resampling on May 6, 2010 showed compliance. Since no further violations were noted after the first quarter, no further action is warranted at this time.

4.32 Thompson Energy Resources, LLC (Permit No. 52-1-773)

Thompson Energy Resouces, LLC (Thompson Energy) is a large crude oil field site in Yorba Linda, comprised of two islands of oil wells; one with five wells and the other with nine. Extracted crude oil and groundwater is pumped to a tank farm for storage and wastewater treatment. Thompson Energy produces about 100 barrels of crude oil per day and treats/discharges approximately 800 barrels (30,000-35,000 gallons) of groundwater per day. Treatment consists of an initial 750-barrel oil / water separation tank,

Crude oil is decanted from the top into one of two 1000-barrel steel storage tanks, while groundwater is drained from the bottom through an intermediate clarifier equipped with an oil belt skimming device. The groundwater then flows into a final surge tank where compressed air is injected with an emulsifier to aid in separation of residual crude oil from the treated groundwater. The groundwater subsequently flows through an effluent meter and into a 4” standpipe and sewer connection.

In January 2010, Thompson Energy had a self-monitoring oil and grease violation. OCSD conducted a 30- day resample and compliance inspection in February 2010. The company informed OCSD that the chemical feed pump for the emulsifier had broken down in early January due to colder weather increasing the viscosity of the chemical and fouling the pump. Thompson Energy cleaned the chemical storage tank, overhauled the chemical feed pump, and mixed a fresh batch of emulsifier soon after the violation occurred. Both OCSD’s and Thompson Energy’s subsequent samples showed compliance. OCSD will continue to monitor Thompson Energy on a quarterly basis.

4.8 JOINT AGENCY INSPECTIONS

OCSD has participated in joint agency inspections of industries suspected of violating hazardous waste and sewer discharge regulations. This cooperative effort has involved other agencies responsible for environmental management and citizen safety such as the Environmental Management Agency, Orange County Health Care Agency (Waste Management Section), Orange County District Attorney's Office, CRWQCB, and city building and fire departments. These inspections have aided in correcting existing and potential discharge problems and have alerted each of the participating agencies to the concerns of the others.

4.33 chapter 5

NON-COMPATIBLE POLLUTANTS DISCHARGED BY INDUSTRY

Introduction Industrial Discharge of Metals Arsenic Mercury Cyanide Organic Priority Pollutants Radioactivity Overall Trends chapter 5

NON-COMPATIBLE POLLUTANTS DISCHARGED BY INDUSTRY

5.1 INTRODUCTION

The Orange County Sanitation District (OCSD) is required by its National Pollutant Discharge Elimination System (NPDES) permit to do influent and effluent wastewater analyses on a regular basis for more than 130 potentially toxic substances. Some of these substances are defined as non-compatible pollutants, which are pollutants that OCSD’s treatment facilities are not designed to treat or remove. Thus, they are the focus of pretreatment or source control efforts carried out through OCSD’s Wastewater Discharge Regulations (Ordinance). There are three potential sources of non-compatible pollutants: industrial wastewater, commercial wastewater, and domestic wastewater. By understanding how non-compatible constituents are used, OCSD can target potential industrial sources of discharge and provide meaningful guidance on how industries can achieve compliance with applicable pretreatment limits.

OCSD conducts daily, weekly, monthly, and quarterly sampling of wastewater from Reclamation Plant No. 1 and Treatment Plant No. 2 for various influent and effluent constituents. Of particular importance are the analyses of toxic pollutants. Analyses are done for the 128 priority pollutants and six groups of designated pesticides. Other organics not included on these listings are detected as part of this analytical effort. Analyses are performed by either OCSD’s Laboratory or outside contract laboratories.

This chapter presents the results of influent and effluent monitoring for non-compatible pollutants for FY 2009/10 plus historical influent and effluent data. Since 1976/77, when the original Ordinance was adopted, the total influent metal loadings have declined 85% and the total effluent metal loadings have declined 95%. This is particularly significant since OCSD’s service area has undergone substantial growth and development during the same time.

5.2 INDUSTRIAL DISCHARGE OF METALS

Table 5.1 presents the daily average influent mass loading of the seven primary metals (cadmium, chromium, copper, lead, nickel, silver, and zinc) to OCSD’s two treatment plants, the daily average metals mass loading from permitted dischargers, and the estimated daily metals mass from domestic sources. For FY 2009/10, 19% of the total influent metals mass was identified as originating from permitted industrial/commercial and wastehauler sources campared to 17% from last fiscal year. For all metals, the sum of the permitted industrial/commercial contribution and estimated domestic contribution was less than the daily average influent mass. Some disparities exist, which could be called non-routine discharges, and they may be the result of inherent anomalies in comparing different data bases, underestimates of the domestic contribution, or under reporting of the industrial/commercial contribution because of illegal discharges or highly variable discharges. In addition, OCSD does not have reliable discharge data for commercial-only discharges.

Comparisons of the results of routine on-site industrial sampling to the results of clandestine downstream sampling have shown that some industries discharge greater quantities of metals when OCSD’s on-site samplers are not in place. For silver, it is believed that non-routine discharges can be primarily attributed to a variety of small, diffuse commercial sources including one-hour photo processing companies, hospitals, clinics, and dentist and doctor offices. It should be noted; however, that present source control efforts have ensured there are no industrial pass-through or interference events at OCSD’s treatment facilities.

5.1

TABLE 5.1 Heavy Metal Mass Balance in Wastewater Tributary to OCSD’s Treatment Facilities (lb/day), Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Percentage of Constituents Known Avg. Attributed to Known Discharges OCSD’s Domestic Permittee Metals Influent Contribution Contribution Wastehaulers 2007-08 2008-09 2009-10

Cadmium 0.2 0.2 0.2 0.0 83 100 100 Chromium 13 1.7 4.3 0.5 41 37 50 Copper 181 89 28 4.1 61 73 67 Lead 6 2.6 0.4 0.5 53 58 58 Nickel 23 8 5.3 0.3 48 49 59 Silver 4 0.2 0.2 0.0 17 16 10 Zinc 273 141 45 8.5 67 63 71

Domestic/commercial heavy metal concentrations are updated when data suggests a change is appropriate. The domestic contribution is computed at 88% of the average combined influent flow of 207 MGD.

To enhance the general understanding of the contributory sources of metals to OCSD’s sewerage system, a sampling program for domestic and some limited commercial sources was completed during 1994, 1997, and 2004. The resulting data is used in Table 5.1 for determination of mass discharge from the combination of domestic and industrial/commercial sources.

To improve the detection of illegal discharges by industry, OCSD is continuing their program of downstream sampling. This program is directed at those industries suspected of illegally dumping non-compatible pollutants or altering their discharges at times when they are not being inspected or sampled by OCSD personnel. Target industries are selected based on the professional judgment of OCSD inspectors or on anonymous tips. For each downstream sampling event, a 24-hour composite sampler and a continuously recording pH meter are placed in a sewer downstream of the target industry (and in an upstream sewer if necessary). Additional information on downstream sampling can be found in Chapter 3.

5.2.1 Cadmium 140 Cadmium is used in electroplating, 120 pigments, chemicals, and metal Influent Effluent alloys. Manufacturers of various 100 products that require surface coatings l use cadmium, which can find its way b 80 to the sewer system from / electroplating operations. These d 60 products include household a y 40 appliances (refrigerators, washing machines, etc.), automobiles, 20 airplanes, agricultural tools, and industrial machinery. Additionally, 0 hand tools (pliers, wrenches, 78 81 84 87 90 93 96 99 02 05 08 screwdrivers) and fasteners of all kinds are often cadmium-plated. Cadmium compounds are used in the Figure 5-1 Average Yearly Influent and Effluent Cadmium plastics industry, photography, Orange County Sanitation District lithography, process engraving, rubber curing, the manufacturing of medical and dental supplies, as bearings for internal-combustion engines and aircraft, and for soldering and bronzing. Cadmium also is used in the production of automobile radiators, batteries, the manufacture of superphosphate fertilizers, and luminescent dials.

5.2 Cadmium is of particular public health concern for biosolids, which are treated and recycled from municipal wastewater treatment plants. If found in excessive amounts in biosolids to be recycled for agricultural use or home garden applications, its ability to concentrate in the edible portion of some crops can lead to possible chronic kidney disease in biota or humans if concentrations are excessive and higher than established regulatory limits.

During FY 2009/10, the influent cadmium mass to OCSD’s two treatment plants averaged 0.2 pounds per day (lb/day) as shown in Figure 5.1. Since FY 1976/77, influent cadmium has been reduced by over 99%. The effluent cadmium discharge averaged 0.09 lb/day.

5.2.2 Chromium 500 Chromium is used in steel and its alloys to increase the corrosion resistance and 400 Influent Effluent durability of metals. The use of chromium in the electroplating/metal l 300 finishing industry is widespread within b OCSD’s service area. Chromium / compounds are used in dyeing, d 200 manufacturing inks, varnishes, glazes of a y porcelain, and as abrasives. 100 Chromates are used as corrosion inhibitors, rust inhibitors, and scale 0 inhibitors in cooling towers, air conditioners, boilers, and some 78 81 84 87 90 93 96 99 02 05 08 pipelines. Chromates are used in primer paints and dips for metals, in paper matches, dry-cell batteries, and some Figure 5-2 Average Yearly Influent and Effluent Chromium Orange County Sanitation District fireworks. Chromium compounds are also used as topical antiseptics, astringents, defoliants, and in photographic emulsions.

Total chromium influent mass for FY 2009/10 averaged 13 lb/day. Since FY 1976/77, a 97% (408 lb/day) reduction in influent chromium has been achieved, as shown in Figure 5.2. The effluent mass discharge averaged 2 lb/day.

5.2.3 Copper 1000 Copper is used in the production of wire, Influent Effluent brass, electrical apparatus, printed circuit 800 boards, boilers, cooking utensils, automobile radiators, insecticides, fungi- l cides, and fertilizers. Copper is alloyed b 600 with tin, lead, zinc, aluminum, nickel, and / manganese. Compounds of copper are d 400 used in medical and veterinary supplies, a y pyrotechnics, paints, pigments, catalysts, 200 rayon manufacturing, and fabric printing and dyeing. This past year, the influent copper mass averaged 181 lb/day. Figure 0 5.3 shows that influent copper has 78 81 84 87 90 93 96 99 02 05 08 decreased 80% (709 lb/day) since FY 1976/77. Effluent copper averaged 28 lb/day compared with the 38 lb/day average Figure 5-3 Average Yearly Influent and Effluent Copper Orange County Sanitation District last year. This represents a 95% reduction in effluent copper since FY 1976/77.

5.3 5.2.4 Lead 350

Lead is used in alloys, ammunition, 300 Influent Effluent construction, storage batteries, gasoline 250 additives, pigments, caulking compounds l for plumbing, solder, exterior paints, and in b 200 the production of insecticides and circuit / boards. Lead compounds are also used in d 150 machines, explosives, printing and dyeing a fabrics, organic synthesis, photography, y 100 and veterinary supplies. 50

Figure 5.4 shows that since FY 1976/77, 0 the influent lead mass has been reduced by 77 80 83 86 89 92 95 98 01 04 07 10 285 lb/day (98%). During FY 2009/10, the influent mass averaged 6 lb/day. The effluent Figure 5-4 Average Yearly Influent and Effluent Lead averaged 0.4 lb/day. Orange County Sanitation District

5.2.5 Nickel 300

250 Nickel is used in the production of stainless Influent Effluent steel, nickel alloys, batteries, magnets, electrodes, electrical contacts, spark plugs, l 200 machinery parts, and in catalysts. b Compounds of nickel are used in paint, / 150 lacquer, cellulose compounds, detergents, and d 100 cosmetics. a y 50 Figure 5.5 shows that during FY 2009/10, the influent nickel mass averaged 23 lb/day. The 0 effluent nickel averaged 17 lb/day. Since 1976/77, effluent nickel has been reduced by 78 81 84 87 90 93 96 99 02 05 08 91%. Figure 5-5 Average Yearly Influent and Effluent Nickel 5.2.6 Silver Orange County Sanitation District 100 Silver is used in the manufacturing of electronics, jewelry, storage batteries, mirrors, Influent Effluent dental and medical supplies, explosives, 80 bearings, and solders. Silver also is used as a catalyst in some industrial operations. It is l 60 b believed most of silver discharged to OCSD’s / system is from commercial and home-operated d 40 photo processing, printing shops, and x-ray a facilities. Non-categorical small volume y 20 operations are not presently monitored.

0 Silver, as shown in Figure 5.6, is slightly less than last year, with a total influent loading of 4 77 80 83 86 89 92 95 98 01 04 07 10 lb/day. Silver levels in the effluent are 0.3 lb/day. Figure 5-6 Average Yearly Influent and Effluent Silver Orange County Sanitation District

5.4

5.2.7 Zinc 1400 Zinc is used extensively as a protective coating 1200 on metals to prevent corrosion, and is used in Influent Effluent alloys such as brass and bronze. Galvanized 1000 pipes, which contain a large quantity of zinc, l were once commonly used in domestic water b 800 systems. Zinc and its compounds are also / 600 constituents of many household items including d cosmetics, pharmaceutical powders and a 400 ointments, antiseptics, astringents, insecticides, y fungicides, glue, matches, inks, porcelain, 200 paints, varnishes, oil colors, linoleum, and 0 rubber. Industrially, zinc and zinc compounds are used in dyes and electrical apparatus. Zinc 77 80 83 86 89 92 95 98 01 04 07 10 is also used in the production of glass, castings, Figure 5-7 Average Yearly Influent and Effluent Zinc printing plates, building materials, automobile Orange County Sanitation District tires, dry-cell batteries, television screens, reducing agents, and parchment paper. Zinc compounds are used in hardeners of cement, weighting textiles, agricultural fertilizers, wood preservatives, and in paper bleaching.

Influent zinc has been reduced from 1,321 lb/day in FY 1976/77 to 273 lb/day as shown in Figure 5.7. The effluent level is at 47 lb/day.

20 5.3 ARSENIC

15 Influent Effluent Arsenic is used in wood preservatives, pigments in certain paints, fireworks, in the l 10 textile and tanning industries, and in making b / certain bronze and other alloys. Compounds of d arsenic are used in the production of glass, a 5 enamels, ceramics, oil cloth, semiconductors, y and photo conductors.

During FY 2009/10, the average influent mass 0 was 7.4 lb/day. The effluent arsenic averaged 93 95 97 99 01 03 05 07 09 5.7 lb/day.

Figure 5-8 Average Yearly Influent and Effluent Arsenic Orange County Sanitation District 5.4 MERCURY

Mercury is used in barometers, thermometers, hydrometers, pyrometers, in mercury arc lamps, switches, fluorescent lamps, mirrors, dentistry, electric rectifiers, pharmaceuticals and antifouling paints.

For FY 2009/10, the influent mass loading averaged 0.3 lb/day of mercury. Since 1986/87, the influent has been less than 2.0 lb/day. The effluent discharge averaged 0.03 lb/day for this fiscal year.

5.5 5.5 CYANIDE

Cyanides are contributed by metal cleaning, electroplating processes, and from chemical industries. For FY 2009/10, the influent mass loading averaged less than 5.0 lb/day of cyanide. The effluent discharge averaged 6.0 lb/day. An exact comparison of the average influent and effluent concentrations during the past five years is difficult to determine because of method detection limit changes and non-detected values during sample analysis.

5.6 ORGANIC PRIORITY POLLUTANTS

The discharge permit for OCSD requires the analysis of the influent, effluent and biosolids for the constituents appearing on the Environmental Protection Agency (EPA) Priority Toxic Pollutant List (excluding asbestos) as shown in Appendix C. For most of the constituents, the frequency of analyses is either monthly or quarterly. The analysis for some constituents is performed more frequently to support other programs within OCSD. Monthly and annual means for these constituents are reported in Appendix B.

The most consistently detected organic priority pollutants in the influent and effluent are some of the volatile organic compounds (VOC). These are determined by OCSD’s Environmental Laboratory and Ocean Monitoring Division (ELOM) using EPA Method 624.

The majority of the influent and effluent results reported in Appendix B are determined by the ESL. The analysis of biosolids for organochlorine pesticides (Method 8081), PCBs (Method 8082), organophosphorus pesticides (Method 8141), base/neutral/acid extractable organics (Method 8270), VOCs (Method 8260) and 2,3,7,8 TCDD (Method 1613B) are performed by the contract laboratories.

5.6.1 Influent/Effluent Organic Priority Pollutants 160 Influent Effluent Figure 5.9 presents the pounds per day of 140 influent and effluent organic priority pollutants. 120 To determine the loadings, organic pollutant l 100 data in Appendix B was summed when the b annual mean was greater than the detection / 80 limit. d 60 a y 40 For FY 2009/10, the influent mass loading averaged 131 lb/day of organic priority 20 pollutants compared to 119 lb/day in the 0 previous fiscal year. Effluent organic priority 97 98 99 00 01 02 03 04 05 06 07 08 09 10 pollutants averaged 30 lb/day compared with last year’s average of 29 lb/day. Figure 5-9 Average Yearly Influent/Effluent Organic Priority Pollutants Orange County Sanitation District 5.6.2 Polychlorinated Biphenyls (PCB)

Determination of PCB compounds in OCSD’s influent and effluent was performed using EPA Method 608. During FY 2009/2010, PCBs were not detected in OCSD’s influent or effluent. Using flow and analytical detection limit data, the PCB compounds discharged in the effluent averaged less than 0.40 lb/day.

5.6.3 Pesticides

EPA Method 608 was also used to determine organochlorine pesticides in the influent and effluent. There was a single event when Alpha-BHC, which does not have a discharge limit, was detected at 0.018 µg/L

5.6 during the year in the Plant 2 Influent. The trip water blank from the Plant 2 Influent set had a detection of Alpha-BHC of 0.014 µg/L. Both values were attributed to a contamination issue within the extraction laboratory. None of the method 608 constituents were detected in the effluent during FY 2009/2010. The permit limit for Chlordane, an organochlorine pesticide with a permit limit, is based on the sum of the concentrations of seven different chemicals. Certified analytical standards for two of these chemicals were no longer available after March 2004. The reporting rules for Chlordane and other summed constituents requires reporting the sum of all constituents in the group that have available certified standards.

5.6.4 Phenolic Compounds

Testing for chlorinated and nonchlorinated phenols is performed on the influent and effluent samples as part of the routine analysis for base/neutral/acid extractable organics using EPA approved methods. OCSD’s permit requires at least monthly testing for these compounds. Chlorinated phenols were not detected in the final effluent during FY 2009/2010. Detectable quantities of non-chlorinated phenols were reported throughout the year in the effluent with an annual average concentration of 5.4 g/L.

5.7 RADIOACTIVITY

Testing for gross alpha and beta radioactivity is performed monthly on the influent and effluent by a contract lab using EPA approved methods. The average gross alpha and beta radioactivity measured in the combined influent and final effluent during FY 2009/2010 was 9.3 pCi/L and 29 pCi/L respectively.

5.8 OVERALL TRENDS

A review of the data for the long-term shows there has been a steady decline in most constituents as shown by the tables and figures in this chapter. Since 1976/77, when the Source Control Ordinance was first adopted, the total influent metals have declined 85% and the total effluent metals have declined 95%. For FY 2009/10, total metals compared to last year decreased by 2% in the influent and decreased by 14% in the effluent. Influent mercury, cyanide, and PCB values have remained essentially the same during the past five years.

5.7 chapter 6

SOURCE CONTROL PROGRAM STAFFING, COSTS, AND FIELD EQUIPMENT

Introduction Staffing, Revenues, and Costs Field Equipment chapter 6

SOURCE CONTROL PROGRAM STAFFING, COSTS, AND FIELD EQUIPMENT

6.1 INTRODUCTION

This chapter discusses the Source Control Division staffing levels, program costs, payments to OCSD by permittees and equipment used by the Division in pursuit of its activities.

6.2 STAFFING, REVENUES, AND COSTS

6.2.1 Staffing

As of June 30, 2010, the Source Control Division staff is comprised of 1 Division Manager, 3 Supervisors, 9 Engineers, 4 Professional Staff, 12 Field Staff, and 6 Administrative Support Personnel for a total of 35 staff members.

6.2.2 Revenues

During FY 2009/10 a total of $16,096,968 in revenue payments was made to OCSD by Class I, Class II, Wastehauler, Special Purpose and FOG permittees. The following amounts were collected for the discharge of flow, biochemical oxygen demand (BOD), and suspended solids: Operation and Maintenance (O&M) fees $10,768,515, Supplemental Capacity Facilities Capacity Charge (SCFCC) fees $4,089,618, and Wastehauler User Fees $940,363. Permit fees in the amount of $298,471 were also collected. Because of the way the OCSD Accounting Department books their fees, the O&M and SCFCC fees represent the prior fiscal year, FY 2008/09.

Collected revenue helped to offset a portion of OCSD’s treatment costs and the $6,392,989 needed for labor, supplies, equipment, and overhead to administer the Source Control Program. These costs were associated with issuing permits, sampling, inspections, and laboratory analyses. The divisional breakdown was $5,759,956 for the Source Control Division and $633,033 for the Laboratory Division.

6.2.3 Program Costs

Overall pretreatment program implementation costs (including overtime) during the fiscal year increased 4.5% over the preceding year and show a 23.8% increase from program costs of five years ago. The cost per labor hour over the past five years has increased 30.4%, which is an average 6.1% per year increase. A comparison of the Source Control costs for the past five years are shown in Table 6.1.

TABLE 6.1 Summary of Total Costs and Total Labor Hours for the Source Control Program, Fiscal Years 2006-2010 Orange County Sanitation District, Source Control Division

Cost Per Fiscal Year Total Cost Labor Hours Labor Hour 2005-06 $5,165,082 87,928 $58.74 2006-07 $5,263,349 81,832 $64.32 2007-08 $5,615,631 86,474 $64.94 2008-09 $6,118,861 84,322 $72.57 2009-10 $6,392,989 83,476 $76.59

6.1

6.3 FIELD EQUIPMENT

6.3.1 Equipment Inventory

An inventory of major equipment used by OCSD for the Source Control Division is shown in Table 6.2. Eleven field personnel, each utilizing trucks and modern sampling equipment, maintain a high degree of visibility in the industrial community.

TABLE 6.2 Current Inventory of Major Equipment for the Source Control Division for Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Description Quantity

Vehicles 12

Equipment Cellular Phones 18 Composite Samplers, General Use 60 Composite Samplers, Special Purpose 8 Flow Meters, Portable 4 pH Meters, Recording 10 pH Meters, Portable 12 Gas Meters 2

6.2 chapter 7

SOURCE CONTROL PROGRAM STATUS

Introduction Public Participation Wastehauler Program Source Control Inspection and Sampling Quality Assurance and Quality Control Activities Total Toxic Organics Waiver Program chapter 7

SOURCE CONTROL PROGRAM STATUS

7.1 INTRODUCTION

The Orange County Sanitation District (OCSD) administers several different program elements designed to meet the goal of controlling discharges from industrial and non-industrial sources. These have a direct influence on OCSD's ability to meet federal, ocean discharge, biosolids reuse and disposal, and water reclamation requirements. This chapter outlines those program elements designed to enforce and enhance the federally approved pretreatment program, which include an industrial dischargers' public participation program; wastehauler monitoring program; quality assurance/quality control program; urban runoff program; Fats, Oils and Grease (FOG) program; total toxic organic (TTO) program, and pollution prevention program.

7.2 PUBLIC PARTICIPATION

A provision of 40 CFR 403.8 is to comply with the public participation requirements of 40 CFR Part 25 in the enforcement of National Pretreatment Standards. These procedures shall include provision for at least annual public notification in a newspaper(s) of general circulation that provides meaningful public notice within the jurisdiction(s) served by OCSD, of Industrial Users which, at any time during the previous 12 months, were in significant noncompliance with applicable Pretreatment requirements. This public notice is shown in Appendix F.

7.3 WASTEHAULER PROGRAM

OCSD operates a dedicated discharge site at Plant No. 1 for the disposal of septage, chemical toilet, and grease trap wastes collected by wastehaulers. The discharges are transferred via a pipeline to Plant No. 2 for treatment. The following sections provide the status of wastehauler permitting, discharges and monitoring conducted during FY 2009/10. Values provided in the tables are derived primarily from manifests provided by the wastehauler companies. The information is generally accurate, but OCSD has limited control over externally generated values and cannot guarantee that some inaccuracies will not occur. Values for gallons discharged are based on truck capacities, assuming full loads, and not measured values.

7.3.1 Wastehauler Permitting

Before a liquid waste pumper can obtain a Wastehauler Permit from OCSD, the company must register with the Orange County Health Care Agency (OCHCA) and have all pumper trucks intended for use in the County inspected. Numerical decals issued by both OCHCA and OCSD are affixed to all permitted pumper trucks. These decals aid in the identification of legal pumpers. Permits include rules for use of the wastehauler station, with enforcement for violations. Haulers must conduct their business using methods to reduce or eliminate odors.

Permits are renewed annually on January 1. Currently 38 wastehauler companies are under permit with OCSD, with a total of 118 trucks.

7.3.2 Wastehauler Discharges

During the past fiscal year, 17.0 million gallons of waste were discharged by permitted wastehaulers at the Plant No. 1 Wastehauler Station. The volume of waste accepted at the station was 11% less than the volume during FY 2005/06. The number of loads decreased by 17%. Wastehauler discharge data for the last five years are summarized in Table 7.1.

7.1

TABLE 7.1 Summary of Wastehauler Loads and Gallons Discharged into Plant No. 1 Disposal Station, 2006-2010 Orange County Sanitation District, Source Control Division

Loads Waste Received in Fiscal Year Delivered Millions of Gallons

2005-06 10,788 19.2

2006-07 10,561 21.0

2007-08 10,512 21.3

2008-09 9,975 18.5

2009-10 8,977 17.0

Wastehauler loads are classified into five types including brine, cesspool, chemical toilets, grease, septic tanks, and other sources. The total volumes and number of loads for each type are summarized in Table 7.2.

TABLE 7.2 Summary of Wastehauler Load Types Discharged into Plant No. 1 Disposal Station, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Loads Waste Received in Percent of Load Type Delivered Millions of Gallons Waste Received

Brine 18 0.06 0.33

Cesspool 3 0.004 0.02

Chemical Toilet 5,312 5.53 32.6

Grease 2,404 8.82 52.1

Septic Tank 1,240 2.53 14.9 Total All Types 8,977 17.0 100

The total volume and number of loads from septic tanks and cesspools is low due to the assumed decrease in the number of households not connected to a sewer system. During the past fiscal year, 8.8 million gallons of grease were discharged by permitted wastehaulers at the Plant No. 1 Wastehauler Station. This represents a 4% decrease from the volume of grease discharged during FY 2008/09. The five-year trend for grease is presented in Table 7.3.

7.2

TABLE 7.3 Summary of Wastehauler Grease Wastewater Loads into Plant No. 1 Disposal Station, Fiscal Years 2006-2010 Orange County Sanitation District, Source Control Division

Fiscal Year Loads Delivered Millions of Gallons

2005-06 2,350 8.8

2006-07 2,740 10.6

2007-08 3,013 11.8

2008-09 2,584 9.2

2009-10 2,404 8.8

7.3.3 Wastehauler Monitoring

Random sampling of the wastehaulers' loads is conducted to verify compliance with OCSD discharge limits. During FY 2009/10, the contents of 495 wastehauler trucks were sampled and 3,465 metal analyses were performed. The results of the sampling showed 97 metal violations in 72 loads that originated from either domestic sources or grease hauling. Violations were found in 3% of the analyses. The violations included chromium, copper and zinc, which are common metals found in domestic and commercial wastewater. Low concentrations of chromium are common in grease loads. Violations involving other metals result in field investigations to determine the origin of the metals. None of the violations originated from industrial sources, and no further enforcement actions were taken.

7.4 SOURCE CONTROL INSPECTION AND SAMPLING

OCSD schedules sampling and inspection of each Class I industry quarterly, samples selected Class II industries, and samples wastehaulers on a random basis. Companies are sampled for metals, cyanide, Total Toxic Organics (TTO), pH, Biochemical Oxygen Demand (BOD), and Suspended Solids (SS). Inspections are conducted before and after each 24-hour composite sampling, at the time of collecting a grab sample, and to determine compliance with other provisions of the Wastewater Discharge Regulations (Ordinance). Table 7.4 lists the number of inspections and sample analyses conducted from July 1, 2009, through June 30, 2010. Refer to the Monitoring and Compliance Status Report key in Appendix A for compliance definitions.

TABLE 7.4 – Class I Inspection and Sampling Summary, July 1, 2009 – June 30, 2010 Orange County Sanitation District, Source Control Division

July–Sept Oct–Dec Jan–Mar Apr–Jun 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total FCSa CSDOCb Total FCS CSDOC Total FCS CSDOC Total FCS CSDOC

Class I Industries 333 211 122 330 209 121 325 207 118 332 213 119 Industrial Sampling

Industry Composites 274 184 90 268 175 93 283 185 98 276 188 88 Industries Consistently 268 178 90 263 170 93 275 179 96 265 179 86

7.3

TABLE 7.4 – Class I Inspection and Sampling Summary, July 1, 2009 – June 30, 2010 Orange County Sanitation District, Source Control Division

July–Sept Oct–Dec Jan–Mar Apr–Jun 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Total FCSa CSDOCb Total FCS CSDOC Total FCS CSDOC Total FCS CSDOC Achieving Compliance Industries Non-Compliant 6 6 0 5 5 0 7 6 1 11 9 2 Industries Inconsistently 0 0 0 0 0 0 0 0 0 0 0 0 Achieving Compliance Insufficient Data 33 22 11 43 31 12 33 22 12 35 24 11 Cyanide Sampling

Industries Sampled 81 80 1 89 85 4 87 84 3 90 89 1 Industries In Compliance 80 79 1 89 85 4 87 84 3 89 88 1 Industries In Violation 1 1 0 0 0 0 0 0 0 1 1 0 TTO Sampling c

Industries Sampled 136 103 33 118 84 34 133 97 36 126 90 36 Industries In Compliance 131 102 29 116 83 33 129 96 33 123 90 33 Industries In Violation 5 1 4 2 1 1 4 1 3 3 0 3 Wastehauler Sampling

Loads Sampled 110 0 0 109 0 0 130 0 0 147 0 0 Loads In Compliance 82 0 0 96 0 0 112 0 0 134 0 0 Loads In Violation 28 0 0 13 0 0 18 0 0 13 0 0

Inspection/Samples Summary

Industrial Inspections d 381 0 0 362 0 0 375 0 0 374 0 0 Composite Samples 564 0 0 541 0 0 581 653 (Total) 0 0 0 0 Grab Samples (Total) 265 0 0 336 0 0 320 0 0 311 0 0 Downstream Samples 1 0 0 79 0 0 17 11 (Total) 0 0 0 0

e Total Samples Collected 830 0 0 956 0 0 918 0 0 975 0 0 Laboratory Analyses f 3943 0 0 4340 0 0 4372 0 0 6136 0 0

a Industries subject to Federal Categorical Standards (FCS). b Industries subject to OCSD’s local limits only. c TTO – Total Toxic Organics. d Value computed as the total number of composite samples for Class I and II, when grab samples were not collected during a composite sampling event, or during inspections where no samples were taken. e Includes composite, grab, and downstream samples. f Includes Class I and Class II companies and wastehaulers.

7.4

7.5 QUALITY ASSURANCE AND QUALITY CONTROL ACTIVITIES

7.5.1 Quality Assurance and Quality Control (QA/QC) Program Tasks

The objective of the QA/QC program is to ensure that all field sampling and monitoring is accurate and performed according to the Source Control Division's adopted policies and procedures, and that the sampling results will withstand any possible legal challenges. The QA/QC program is composed of the following tasks:

Equipment Blank – Composite samples are collected monthly to evaluate the cleaning procedures or automatic sampling equipment.

Archive Sample Check – Archive heavy metal samples are analyzed monthly to evaluate the effects of archive procedures.

Sample Collection Check – Composite samples are collected semi-annually to evaluate the precision of the sample collection method.

Trip Blank Evaluation – Measures the effects of transport and storage on Method 624 analyses.

Sample Collection/Handling Inspection Audit – Periodic reviews are conducted to assure that the inspectors conform to existing guidelines for inspection and sample collection, and that existing procedures continue to ensure representative data. Document reviews are completed to measure inspector performance.

During FY 2009/10, 24 composite samples were collected for equipment blank verification, 48 archived samples were analyzed to compare to previous analytical results, and 80 samples were collected from industrial discharges to audit collection methods. The test results for QA/QC samples collected are detailed in Appendix K. The overall results show that the procedures and their implementation for the collection of field samples are adequate to assure sample quality and consistency.

Calculation Methods

Methods for calculating deviations were refined beginning with data generated during 2005 to be more consistent with accepted laboratory standards for quality control. The prior use of PSES discharge limits to calculate percent deviations for duplicate samples has been replaced with the Relative Percent Difference (RPD) formula found in Standard Methods for the Examination of Water and Wastewater, 20th Edition, p.1-8.

Equipment Blank sampling is performed to find any concentration above the method detection limit (MDL). The RPD is calculated for this data, but the more important factor is the number of times a metal is detected above the MDL. Any detectable amount is treated as an indicator of possible contamination in the deionized water supply, detergent, containers or other sources.

RPD calculations are more important for the archive samples, which evaluate sample splitting and preservation techniques in the field. Standard Methods 18th Edition, Table 1020:I on p.1-4 includes values for acceptance limits for duplicate samples. These limits are the current standard for OCSD’s Environmental Sciences Laboratory. The precision of low-level duplicates, with concentrations less than 20 times the MDL, is ± 25%. The precision of high-level duplicates, with concentrations greater than 20 times the MDL, is ± 10%. These guidelines are used to present and calculate the archive sample data. If only one of two duplicate samples is greater than 20 times the MDL, then the more restrictive limit of 10% is used to evaluate precision. Only analysis results above five times the MDL are used in calculations.

7.5

A study conducted in 2009, including a review of relevant literature and OCSD data has confirmed that silver is relatively unstable under standard preservation and storage conditions, and cannot be used to evaluate precision and accuracy with the other metals listed below. Consequently, silver has been removed from the list of metals used to evaluate precision and accuracy.

The current method detection limits were used by OCSD’s Laboratory during FY 2009/10 and are used in calculations in Table 7.1 and all subsequent tables where MDL’s appear.

Cadmium Chromium Copper Nickel Lead Zinc

MDL (mg/L) .007 .01 .01 .01 .02 .03

7.5.2 QA/QC Sampling Results

Evaluation of Equipment Blank Sampling Results

To check for contamination of sampler and field equipment, composite samples were collected each quarter using clean, randomly chosen samplers. The samplers were set at the Source Control Division's field office to collect a sample from a deionized water supply in each of the 24 bottles. The samples were composited and preserved in the same manner as for actual industrial samples. Each composite sample was split into three separate volumes (18 splits), and analyzed individually by OCSD’s Laboratory for heavy metal constituents.

The results presented below show that 98% of the analyses (422 of the 432 analyses) are at or below the heavy metal constituent detection limits. The average deviations are summarized in Table 7.5.

TABLE 7.5 Equipment Blank Sampling Results, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Analyses at or Below Analyses Above Detection Limits Detection Limits Detection No. of No. of Avg. Constituent Limit (mg/L) Analyses Percentage Analyses % Deviation

Cadmium 0.007 71 99 1 0.002 Chromium 0.01 72 100 0 0.00 Copper 0.01 69 96 3 0.05 Nickel 0.01 72 100 0 0.00 Lead 0.02 72 100 0 0.00 Zinc 0.03 66 92 6 0.08 Summaries 422 98 10 0.02

Several metals were found above detection limits. These results are all less than five times the method detection limit (MDL) and therefore cannot be reliably distinguished from the MDL. The overall results indicate that equipment used to collect samples has been properly cleaned and stored. However, the detected metals will be addressed when the deionized water delivery systems are renovated in January 2011 to remove all metal fittings, a possible source of contamination.

7.6

Evaluation of Archived Samples

Archived samples are submitted to OCSD’s Laboratory to evaluate the effects of sample collection, splitting, and preservation techniques. The results of the archive analyses are compared with the original sample results and the relative percent difference is calculated for each metal. Results at or below the method detection limit (MDL) are calculated as equal to the MDL.

Of the 288 comparisons performed on the 96 samples (48 archived samples and 48 original samples), 97% of the results were within the acceptable percent difference. The Average Percent Difference is below the 10% guideline for all metals except zinc. The statistics on the archived samples and percent difference are summarized in Table 7.6 below. The data indicates that inspectors are using correct sample splitting and preservation methods. Incidents of comparisons outside acceptable RPDs originated from sample splitting and preservation errors. These issues were addressed through remedial training.

TABLE 7.6 QA/QC Evaluation of Archived Samples, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Comparisons Comparisons Percent within outside within Average Constituent Acceptable RPD Acceptable RPD Acceptable RPD % Difference Cadmium 48 0 100 1.7 Chromium 47 1 98 8.4 Copper 45 3 94 6.6 Nickel 47 1 98 6.7 Lead 48 0 100 0.6 Zinc 44 4 92 26.8

Summaries 279 9 97 8.5

Sample Collection Checks

Two composite samples are collected each quarter to verify the precision of the Source Control Division sample collection methods. In this task, two automatic samplers are installed adjacent to each other at a single industrial sample point to collect one composite sample from each sampler. Each composite sample is split into ten duplicate portions. Five duplicates from each sampler are analyzed by OCSD’s Laboratory for heavy metals and five are analyzed for total suspended solids (TSS).

The results for each constituent are evaluated by calculating the relative percent difference for each group of metals. For TSS, the percent difference is calculated by taking the average deviation of the ten results and dividing by the average result. Values above the accepted RPDs for metals and TSS are investigated, with causes identified whenever possible, and corrective action taken. This comparison is used to confirm that the sample location is appropriate, that the samplers are functioning properly and to help identify sample- splitting errors.

The results of the Collection Checks performed during the fiscal year show that the sample splitting procedures instituted in 2003 have significantly reduced the average percent difference between samples. With one exception, all comparisons showed excellent agreement among samples from the same sampler, and acceptable agreement between samplers at the same site. Overall, the sample locations and methods were adequate to provide representative samples for metals. The exception occurred at a site where an

7.7 uneven distribution of solids in the sample box resulted in detection of nickel in one sample but not the other. This location has been identified and will be corrected.

TABLE 7.7 QA/QC Sample Collection Checks, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Metals Qtr. Location Cadmium Chromium Copper Nickel Lead Zinc TSS Avg.

1 Sampler A 0.0 0.7 0.4 0.5 0.0 0.7 3.6 0.3 Sampler B 0.0 0.4 0.3 0.0 0.0 0.3 5.9 0.1 Site 0.0 0.0 0.0 1.3 0.0 0.0 2.8 0.2 2 Sampler A 0.0 0.0 0.0 0.0 0.0 0.6 3.4 0.1 Sampler B 0.0 0.0 0.0 0.0 0.0 0.5 1.1 0.1 Site 0.0 0.0 0.0 0.0 0.0 1.5 13.1 0.3 3 Sampler A 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Sampler B 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Site 5.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 4 Sampler A 0.0 0.0 0.0 0.0 0.0 0.0 26 0.0 Sampler B 0.0 0.0 0.5 2.7 0.0 0.0 21 0.5 Site 0.0 0.0 0.0 154.3 0.0 0.0 37 25.7

Avg. Sampler 0.0 0.1 0.2 0.4 0.0 0.3 7.6 0.1

Avg. Site 1.3 0.0 0.0 39 0.0 0.4 13.2 6.6

All results are in units of relative percent difference. TSS = total suspended solids

Trip Blank Evaluation for EPA Method 624 Analysis

Inspectors performed this test monthly. Prepared containers were obtained from OCSD’s Laboratory and carried with other samples during their work day. The containers were returned to the Lab and analyzed for volatile organics. Twelve trip blanks were analyzed for volatile organics using Method 624. All results were below the method detection limits.

Sample Collection and Inspection Audit

During FY2009/10, the Source Control Supervisor audited the sample collection and inspection procedures of individual inspectors. The audit of each inspector was accomplished by document review during performance evaluations. Opportunities for improvement were discussed with individual inspectors during the performance review process in July 2009 and January 2010.

7.5.3 Conclusions

The following findings support the general conclusion that the Source Control Division sampling procedures are being followed and that the samples are representative and free of contamination:

Results of the Equipment Blank Evaluation show that 98% of the equipment blank samples have concentrations at or below the heavy metal detection limits.

Results of the Archive Sample Evaluation show that 97% of the archive samples were within the

7.8

acceptable percent deviation range.

The Sample Collection Check results show excellent agreement for heavy metals among split samples for each sampler, indicating good splitting technique.

All Method 624 Trip Blanks were below detection limits.

The sample and inspection audit method was used again this year. The method involved a broad review of inspection and sampling records. The results of the audits were discussed with individual inspectors during their performance reviews.

7.6 TOTAL TOXIC ORGANICS WAIVER PROGRAM

Permittees subject to Federal Categorical Standards were first notified of OCSD's Total Toxic Organics (TTO) Control Program requirements on July 27, 1987. The current TTO Program is summarized below:

Categorical and noncategorical permittees who are required to conduct self-monitoring for Total Toxic Organics (TTOs) must collect composite samples at least twice a year. In accordance with OCSD's Wastewater Discharge Regulations, the composite sample consists of a minimum of four (4) grab samples where the concentration of a composite sample is obtained by analyzing the grab samples and compositing the results arithmetically.

Permittees who have not shown detectable levels of TTOs based on their wastewater discharge data for at least one year are eligible to waive the self-monitoring requirement if they can certify that TTOs are not used or present at their facility. The wastewater discharge data used in evaluating eligibility for this waiver include data for samples obtained by OCSD during routine monitoring and the self-monitoring results obtained by the company. The evaluation of wastewater discharge to determine the permittees that are eligible for this waiver is conducted in January and July of each year; see Table 7.8 for those companies that have successfully applied for a waiver. To be eligible for a waiver, the permittee must satisfy all of the following:

Permittee must not show sampling results with TTO concentrations greater than 0.05 mg/L detection limit for the monitoring period being considered.

Permittee must have complied with all TTO self-monitoring requirements during the monitoring period being considered.

Initial Permit Issue date is prior to the start of the baseline monitoring being considered.

Subsequently, permittees who have a TTO self-monitoring waiver renew their Certification of Non- Use of TTOs semi-annually during this period; otherwise, the waiver is cancelled. Issuance of a waiver does not constitute elimination of the self-monitoring requirement from the permit but merely a temporary discontinuance or suspension of the requirement.

The self-monitoring requirement waiver for any permittee is cancelled if sampling results from the permittee's self-monitoring or OCSD's sampling show detectable levels of TTOs. For these cases, the requirement to conduct self-monitoring at least twice a year is immediately reinstated.

Newly permitted categorical users and noncategorical users required to self-monitor will not be allowed to waive the self-monitoring requirement even if they can certify non-use of TTOs until they have demonstrated that there are no detectable levels of TTOs in their wastewater discharge based on wastewater discharge data for at least a year.

7.9

TABLE 7.8 Permittees with TTO Waivers, July 1, 2009 – June 30, 2010 Orange County Sanitation District, Source Control Division Permit No. Company Name Category 53-1-422 A & G Electropolish Metal Finishing PSNS 2-1-088 A & R Powder Coating Metal Finishing PSNS 2-1-192 A R O Service Metal Finishing PSNS 1-1-138 Accurate Circuit Engineering Metal Finishing PSNS 1-1-115 Active Plating, Inc. Metal Finishing PSNS 2-1-389 Advance Tech Plating Inc., #2 Metal Finishing PSNS 2-1-081 Alcoa Global Fasteners Metal Finishing PSES 3-1-110 All Metals Processing of O.C., Inc. Metal Finishing PSNS 1-1-073 Allied Electronics Services, Inc. Metal Finishing PSNS 1-1-036 Alloy Tech Electropolishing, Inc. Metal Finishing PSNS 1-1-133 Almatron Electronics, Inc. Metal Finishing PSNS 2-1-249 American Circuit Technology, Inc. Metal Finishing PSNS 52-1-798 Andres Technical Plating Metal Finishing PSNS 1-1-155 Anomil Ent. DBA Danco Metal Surfacing Electroplating >10K 3-1-137 Arrowhead Products Corporation Metal Finishing PSES 57-1-295 Astech Engineered Products, Inc. Metal Finishing PSNS 7-1-037 Aviation Equipment, Inc. Metal Finishing PSNS 3-1-052 B I Technologies Metal Finishing PSNS 3-1-094 Basic Electronics, Inc. Metal Finishing PSNS 51-1-370 Beo-Mag Plating Metal Finishing PSNS 2-1-213 Black Oxide Industries, Inc. Electroplating >10K 11-1-018 Boeing Company (Graham) Metal Finishing PSNS 51-1-368 Brasstech, Inc. Metal Finishing PSNS 51-1-076 CD Video, Inc. Metal Finishing PSNS 2-1-062 Cadillac Plating Metal Finishing PSNS 11-1-089 Cal-Aurum Industries, Inc. Metal Finishing PSNS 1-1-078 Cal-Tronics Metal Finishing PSNS 53-1-393 Caran Precision Engineering Metal Finishing PSNS 52-1-814 Cartel Electronics Metal Finishing PSNS 2-1-189 Central Powder Coating Metal Finishing PSNS 2-1-323 Circuit Access, Inc. Metal Finishing PSNS 2-1-133 Cirtech, Inc. Metal Finishing PSNS 2-1-199 Classic Plating, Inc. Metal Finishing PSNS 3-1-167 Coastline Metal Finishing Corp. Metal Finishing PSNS 2-1-290 Continuous Coating Corporation Coil Coating Sub 465.24 2-1-077 Copper Clad Multilayer Products, Inc. Metal Finishing PSNS 2-1-289 Crest Coating, Inc. Metal Finishing PSNS 6-1-002 Criterion Machine Works Metal Finishing PSES 2-1-297 Custom Enamelers Metal Finishing PSNS 2-1-379 Data Aire #2 Metal Finishing PSNS

7.10

TABLE 7.8 Permittees with TTO Waivers, July 1, 2009 – June 30, 2010 Orange County Sanitation District, Source Control Division Permit No. Company Name Category 1-1-142 Data Electronic Services, Inc. (P-1) Metal Finishing PSNS 52-1-761 Data Solder, Inc. Metal Finishing PSNS 2-1-325 Dunham Metal Processing Metal Finishing PSNS 2-1-246 Dynamic Details, Inc. Metal Finishing PSNS 1-1-064 EFT Fast Quality Service, Inc. Metal Finishing PSNS 57-1-304 Eaton Aerospace, LLC Metal Finishing PSNS 2-1-093 Econolite Control Products, Inc. Metal Finishing PSES 2-1-158 Electro Metal Finishing Corporation Metal Finishing PSNS 7-1-162 Electrolurgy, Inc. Electroplating-PM >10K 2-1-336 Electron Plating III, Inc. Metal Finishing PSNS 2-1-337 Electronic Precision Specialties, Inc. Metal Finishing PSNS 1-1-027 Embee Inc. #1 Electroplating >10K 1-1-025 Embee Inc. #2 Electroplating >10K 52-1-815 Excello Circuits Manufacturing Corp. Metal Finishing PSNS 1-1-068 Fabrication Concepts Corporation Metal Finishing PSNS 2-1-121 Fineline Circuits & Technology, Inc. Metal Finishing PSNS 57-1-312 GE Aviation Mechanical Systems Metal Finishing PSNS 7-1-172 Gemini Industries Inc. Nonferrous Metals Mfg. 52-1-774 Gerard Roofing Technologies, LLC CSDOC 2-1-352 Gomtech Electronics, Inc. Metal Finishing PSNS 3-1-043 Goodwin Company CSDOC 52-1-790 Hi Tech Solder Metal Finishing PSNS 2-1-185 Hightower Plating & Manufacturing Co. Electroplating >10K 3-1-027 I P C Cal Flex, Inc. Metal Finishing PSNS 2-1-041 Ideal Anodizing, Inc. Metal Finishing PSNS 52-1-756 Ikon Powder Coating, Inc. Metal Finishing PSNS 3-1-106 Imperial Plating Metal Finishing PSNS 52-1-771 Industrial Metal Finishing, Inc. Metal Finishing PSNS 7-1-034 Irvine Sensors Corp. Electrical & Electronic 57-1-292 Jazz Semiconductor Electrical & Electronic 3-1-270 Joint Forces Training Base, Los Alamitos CSDOC 3-1-026 K C A Electronics, Inc. Metal Finishing PSNS 2-1-171 Kenlen Specialties Inc. Metal Finishing PSNS 2-1-425 Kimberly-Clark Worldwide, Inc. Pulp-Paper-Paperboard 2-1-428 Kryler Corporation Metal Finishing PSNS 51-1-380 Lam Plate Tech, Inc. Metal Finishing PSNS 3-1-049 Logi Graphics, Inc. Metal Finishing PSNS 53-1-391 Magnetic Metals Corporation Metal Finishing PSNS 2-1-446 Marcel Electronics Metal Finishing PSNS 1-1-046 Markland Manufacturing, Inc. Metal Finishing PSNS 1-1-283 Mask Technology, Inc. Metal Finishing PSNS

7.11

TABLE 7.8 Permittees with TTO Waivers, July 1, 2009 – June 30, 2010 Orange County Sanitation District, Source Control Division Permit No. Company Name Category 3-1-091 Microsemi Corporation Electrical & Electronic 2-1-477 Multi-Fineline Electronix, Inc. Metal Finishing PSNS 52-1-811 Murrietta Circuits Metal Finishing PSNS 52-1-772 Neutronic Stamping and Plating Metal Finishing PSNS 52-1-801 Nobel Biocare, USA, LLC Metal Finishing PSNS 2-1-383 Nu-Tec Powder Coating Metal Finishing PSNS 1-1-136 O.C. Alphanetics, Inc. Metal Finishing PSNS 14-1-018 O.C. Waste & Recycling CSDOC 1-1-284 Olympic Powder Coatings, Inc. Metal Finishing PSNS 2-1-520 Omni Metal Finishing, Inc. Electroplating >10K 2-1-535 Orange County Plating Co., Inc. Electroplating >10K 2-1-070 Pacific Image Technology, Inc. Metal Finishing PSNS 52-1-795 Paramount Disc Manufacturing, Inc. Metal Finishing PSNS 52-1-783 Patio and Door Outlet, Inc. Metal Finishing PSNS 14-1-002 Parker Hannifin Corporation CSDOC 52-1-805 Performance Powder, Inc. Metal Finishing PSNS 2-1-563 Picofarad, Inc. Metal Finishing PSES 1-1-262 Pioneer Circuits Metal Finishing PSNS 52-1-809 Precision Anodizing and Plating, Inc. Metal Finishing PSNS 1-1-008 Precision Circuits West, Inc. Metal Finishing PSNS 1-1-277 Precision Powdercoating, Inc. Metal Finishing PSNS 2-1-581 Precon, Inc. CSDOC 52-1-767 Progressive Marketing Metal Finishing PSNS 3-1-186 Pure-Chem Products Company Inc. Soap-Detergent Mfg. 1-1-013 RBC Transport Dynamics Corp. Metal Finishing PSES 6-1-138 Railmakers Inc. Metal Finishing PSNS 51-1-376 Reid Metal Finishing Metal Finishing PSNS 53-1-423 Reliance Plating & Coating Metal Finishing PSNS 7-1-008 Ricoh Electronics #2 CSDOC 7-1-011 Ricoh Electronics, Inc. Metal Finishing PSNS 53-1-403 Rigid Flex International Metal Finishing PSNS 2-1-187 Rigiflex Technology, Inc. Metal Finishing PSNS 11-1-124 Rock Industries, Inc. Electroplating <10K 2-1-033 Roto-Die Company, Inc. Metal Finishing PSNS 57-1-298 SMC Corporation of America Metal Finishing PSNS 1-1-310 SPS Technologies Metal Finishing PSES 6-1-008 Sanmina Corporation (Airway) Metal Finishing PSNS 6-1-009 Sanmina Corporation (Redhill) Metal Finishing PSNS 2-1-016 Santana Services Metal Finishing PSNS 3-1-311 Scientific Spray Finishes, Inc. Metal Finishing PSNS 1-1-065 Select Circuits Metal Finishing PSNS

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TABLE 7.8 Permittees with TTO Waivers, July 1, 2009 – June 30, 2010 Orange County Sanitation District, Source Control Division Permit No. Company Name Category 3-1-341 Soldermask, Inc. Metal Finishing PSNS 51-1-383 South Bay Chrome Metal Finishing PSNS 1-1-030 South Coast Circuits, Inc. Metal Finishing PSNS 1-1-054 South Coast Circuits #2 Metal Finishing PSNS 1-1-069 South Coast Circuits #3 Metal Finishing PSNS 51-1-365 South Coast Circuits #4 Metal Finishing PSNS 11-1-129 Speedy Circuits, Div. of PJC Tech., Inc. Metal Finishing PSNS 2-1-672 Stainless Micro-Polish, Inc. Metal Finishing PSNS 3-1-058 Star Painting & Refinishing Metal Finishing PSNS 2-1-664 Statek Corporation Electrical & Electronic 52-1-777 Statek Corporation #2 Electrical & Electronic 2-1-090 Superior Plating Metal Finishing PSNS 57-1-309 TC Cosmotronic Inc., DBA Cosmotronic Metal Finishing PSNS 51-1-366 TTM Technologies #1 Metal Finishing PSNS 51-1-359 TTM Technologies, Inc. Metal Finishing PSNS 3-1-012 Tayco Engineering, Inc. Metal Finishing PSNS 2-1-082 Techplate, Inc. Metal Finishing PSNS 2-1-282 Thermal-Vac Technology Metal Finishing PSNS 52-1-773 Thompson Energy Resources CSDOC 11-1-132 Tiodize Company, Inc. Electroplating >10K 2-1-202 Transline Technology, Inc. Metal Finishing PSNS 14-1-163 Tropitone Furniture Co., Inc. Metal Finishing PSES 2-1-703 Ultra Pure Metal Finishing Inc. Metal Finishing PSNS 2-1-702 United Circuit Technology Metal Finishing PSNS 2-1-237 United Custom Polishing & Plating Metal Finishing PSNS 2-1-166 Veeco Electro Fab Inc. #2 Metal Finishing PSNS 3-1-035 Winonics (Brea) Metal Finishing PSNS

7.7 SPECIAL PURPOSE DISCHARGE PERMIT PROGRAM

A Special Purpose Discharge Permit (SPDP) is issued by OCSD for water and wastewater discharges to the sewerage system when no alternative discharge points exist other than the sewer system and/or alternate discharge methods pose an environmental impact or threat.

Wastewater discharges may include: 1) temporary facilities and projects such as groundwater cleanup, soil remediation, and site dewatering; 2) short-term or one-time water and wastewater discharges; 3) emergency discharges from facilities that have no other industrial or permitted discharge point; and 4) surface run-off from areas associated with an industrial or commercial facility.

7.13

7.7.1 Metrics and Trends

During fiscal year 2009/10, there were 14 new SPDPs issued. This is up from 12 issued in the previous fiscal year. The total number of active SPDP’s is 92, the same as the previous fiscal year. Active SPDP’s are renewed on a biannual basis.

Although the metrics show a relatively stationary trend, the number and complexity of new SPDP requests is increasing, impacting staff work hours, as explained below.

The driving force for the increase in SPDP activity is due to Regional Water Quality Control Board, Santa Ana Region 8 (RWQCB-SAR8) enforcement of Resolution No. R8-2004-0001, Updated Total Dissolved Solids (TDS) and Nitrogen Management Plan. Resolution No. R8-2004-0001 restricts discharge of wastewater into surface and ground water. For example, wastewater generated from construction dewatering activities were typically discharged to a storm drain. Now, under Resolution No. R8-2004-0001, if the wastewater contains TDS, nitrates, and/or selenium above a set limit, then the contaminants must either be removed before disposal to the storm drain or another disposal option must be considered.

As a result, wastewater which was traditionally discharged to the storm drain now may not be able to meet discharge limits. Therefore, these projects are applying for SPDP applications for disposal via OCSD’s sewerage system. Other dischargers affected include construction dewatering, mobile cleaners, water features such as pools, water well purging disinfection, subsurface parking structure dewatering, etc. Where once the bulk of the SPDP dischargers consisted of remediation of contaminated groundwater at gasoline service stations, the composition of SPDP permits is now more varied. These new dischargers are also unfamiliar with permitting and regulatory processes and pretreatment technology and budgeting. OCSD staff is expending more time to educate and guide the new dischargers to expeditiously gain a permit.

OCSD staff is also working with outside agencies such as the RWQCB-SAR8, Orange County Health Care Agency, cities to both coordinate and guide them on the SPDP process and OCSD’s Wastewater Discharge Regulations (Ordinance).

It is important to note that other past regulatory changes which have greatly impacted the SPDP program include RWQCB-SAR8 1995 Water Quality Control Plan and RWQCB-SAR8, Resolution No. R8-2000- 0027, Resolution Amending the Water Quality Control Plan For the Santa Ana River Basin to Incorporate Language Authorizing Compliance Schedules in NPDES Permits.

7.7.2 SPDP Program Response

In response to the growing number and new types of SPDP applicants, OCSD staff has initiated internal and external streamlining. Internal streamlining efforts focus on using program automation to facilitate the permitting process. Up to mid-FY2003-04, SPDP’s were processed manually and the data was manually transferred by OCSD staff to a database management program. Currently, SPDP data is manually entered by OCSD staff into a prototype permit generation program. Plans are being considered to shift data entry to the permittees, using a secured, web-based interface. This will speed up permitting for the applicants and allow OCSD staff to focus on regulatory, contaminant, collection system, and operational issues associated with these new types of SPDP dischargers.

External streamlining includes working with RWQCB-SAR8 to quickly identify candidate discharges to OCSD’s sewerage system. Prior to this streamlining initiative, RWQCB-SAR8 and OCSD had conflicting policies and procedures regarding wastewater discharges impacted by Resolution No. R8-2004-0001. Although Resolution No. R8-2004-0001 sets limits on TDS and nitrogen, dischargers still had a process with RWQCB-SAR8 by which they may obtain an NPDES permit, although the process may be longer and more expensive. Ultimately, after going through this process, dischargers may discover practical technical limitations in the pretreatment of their wastewater. 7.14

OCSD’s Ordinance prohibits discharge of groundwater into the sewerage system except under circumstances when no alternative method of disposal is reasonably available, or to mitigate an environmental risk or health hazard.

Alignment of both agencies to speed up the permitting process involved RWQCB-SAR8 identifying candidate dischargers where practical technical limitations would prohibit surface discharge. After identifying these candidates, RWQCB-SAR8 issued a letter stating that discharge to the sewer is the best practical and reasonable option, thereby satisfying the Ordinance.

7.7.3 SPDP Program Enforcement

For FY 2009/10, there have been no discharge violations and therefore no enforcement actions.

7.7.4 SPDP Regulatory Program

OCSD staff spent time revising the Ordinance and internal policies and procedures to address the new types of dischargers with the basic strategy of minimizing impacts to OCSD Reclamation Plant No. 1 and Treatment Plant No. 2.

Strategies include: diverting non-compatible discharges from Reclamation Plant 1 to Treatment Plant 2; coordinating more closely with Operations, Engineering and Safety on significant one-time discharges; requiring pretreatment for projects which may cross known contaminated underground plumes; requiring best management practices for small nuisance dischargers; and requiring significant construction dewatering dischargers to stop discharging during a rain/storm event.

7.8 INDUSTRIAL SELF-MONITORING PROGRAM

OCSD has an extensive industrial self-monitoring program, which is an intergral part of the Source Control Division’s enforcement program. OCSD’s industrial self-monitoring program meets and at times exceeds the minimum requirements of 40 CFR 403. To obtain a broad perspective of a permittee’s discharge quality and adequately determine their compliance status, OCSD tries to take a proactive approach by requiring self-monitoring more frequently in certain cases, as shown in the table below. OCSD determined that sampling at these frequencies is effective and generates sufficient data to make a fair determination of a permittee’s compliance status; yet balances the need for more data against the costs incurred by permittees. In addition, the sampling frequencies preclude permittees from being unduly classified as SNC for isolated process upsets.

Self-Monitoring Sampling Constituents Routine, All Non-Routine, Enforcement SIUs Heavy metals Quarterly Daily/Weekly/Monthly Total Toxic Organics Twice/Year* Quarterly/Monthly BOD and TSS Quarterly Daily/Weekly/Monthly Oil & Grease Quarterly Weekly/Monthly OCSD offers a TTO waiver program for permittees that qualify; this program waives the TTO sampling requirement for 6-month periods at a time.

For categorical metal dischargers, to more accurately determine compliance (per EPA’s recommendation),

7.15

SIUs discharing >5,000 gpd will be required to conduct monthly self-monitoring for specific heavy metals that each individual permittee may have difficulty with in meeting their discharge limits. This requirement went into effect July 1, 2009.

OCSD’s unique self-monitoring program is computerized. Self-monitoring is submitted on OCSD’s standardized Self-Monitoring Report (SMR) forms, which are computer-generated with unique SMR numbers that allow tracking and automatic generation of reminders, late and incomplete notices, violation notices with resample forms, and SNC notices. This tracking system has enabled OCSD to ensure that permittees comply with self-monitoring requirements.

Hundreds of permittees have been routinely entering their own self-monitoring results online. This is all done electronically, saving time and money for both the permittee and OCSD. A notice was sent to all permittees informing them of the online self-monitoring procedures, and it is hopeful that more permittees will begin utilizing the online submittal features.

7.9 INDUSTRIAL OPERATIONS AND MAINTENANCE IMPROVEMENT PROGRAM

To help businesses and industry in OCSD’s jurisdiction to attain compliance and remain a vital part of the community, and to enable OCSD to attain its environmental goals in cooperation with industry and the community, OCSD has established a Technical Assistance Program. The Program serves as both a resource for industry and a forum for discussing methods to carry out environmental requirements. The Program consists of outreach and education, which includes publications addressing Source Control program elements such as permitting, compliance and pollution prevention; brochures that address current, specific issues of environmental compliance; seminars and workshops; “compliance clinics,” and training.

Industrial Operations and Maintenance Improvement Program

The recent trend in industries’ discharge violations has shown that in the majority of cases, the violations are due to inadequate operations and maintenance of the industry’s pretreatment system and operator error. The U.S. EPA audit findings of 1998 stated that up to two-thirds of industry violations were due to operations and maintenance problems. As a result, EPA recommended that OCSD develop and implement an industrial operations and improvement program.

In 1999/2000, OCSD evaluated the needs of an industrial operations and maintenance program and developed a plan that included outreach and operator training, and enforcement of requirements for operator and operations and maintenance practices. Following EPA’s recommendation, OCSD determined that the majority of violations by industries were due to inadequate operation and maintenance practices at their pretreatment facilities. In response, OCSD developed and implemented the Industrial Operator training courses and industrial pretreatment operations and maintenance guidelines that cover practices and recordkeeping for industrial operators.

In August and September 2009, the course trainer completed wastewater audits at 28 industrial facilities with 42 wastewater operators who took the Advance Training Course III in April/May 2009. In October 2009 OCSD received wastewater audit reports from the trainer. The audit reports described each facility’s wastewater pretreatment system/management to evaluate proper implementation of operation and maintenance practices.

In November 2009, OCSD finalized the Advance Training Course III by issuing a Certification of Completion to 33 wastewater operators who passed both the class requirements and facility audit. Nine operators did not pass this course.

In April 2010, OCSD started a Comprehensive Training Course X by sending registration confirmation letters to 32 wastewater operators from 23 industrial facilities. This course consisted of five classes starting from

7.16

April 13 through May 11, 2010. The course includes wastewater audits at each operator’s facility, which account for 60% of the total score.

The wastewater audits are scheduled to be completed in July 2010.

7.10 SIGNIFICANT CHANGES IN OPERATING THE PRETREATMENT PROGRAM

Listed below is a brief description of any significant changes in the OCSD Pretreatment Program during FY 2009/10.

Changes to the administrative structure – No changes.

Changes to local limits – Analytical data were reviewed and no changes are required at this time.

Changes to monitoring program or monitoring frequencies – Some companies were required to do more routine self-monitoring. See Section 7.11 above. OCSD reduced the treatment plant influent/effluent metals sampling frequency in October 2009 from seven (7) sample days per month, to seven (7) sample days for only the first month of the quarter (July, October, January, April) then one (1) sample day for the remaining months.

Changes to legal authority – No changes.

Changes to enforcement policy – No changes.

Changes to funding levels – No changes.

Changes to staffing levels – Four employee positions were deleted; two Senior Regulatory Specialists and two Source Control Inspectors.

Significant organizational changes in the OCSD pretreatment program occurred after this fiscal year reporting period and will be discussed in the next semi-annual report in March 2011.

7.17

chapter 8

INTERACTION WITH OTHER AGENCIES

Introduction Revenue Zone 14 (Irvine Ranch Water District) Operating Permit, Regional Board Order 07-03 Reporting Requirements Additional Information Santa Ana Watershed Project Authority (SAWPA) SAWPA Direct Connections Direct SARI Connections – Temporary/Emergency Indirect Permits (Hauled Waste) SAWPA Sampling and Self-Monitoring Sampling Results Future Projects Affecting Discharge Quantity to SARI System Interaction with SAWPA National Association of Clean Water Agencies (NACWA) Water Environment Federation chapter 8

INTERACTION WITH OTHER AGENCIES

8.1 INTRODUCTION

This chapter is divided into three sections. The first section presents information on the Orange County Sanitation District (OCSD) interactions with the Irvine Ranch Water District (IRWD) during fiscal year 2009/2010; the second section presents information on the interactions with the Santa Ana Watershed Project Authority (SAWPA) during fiscal year 2009/2010; and the third section presents information on OCSD interactions with the Environmental Protection Agency (EPA). OCSD has entered into agreements and has developed Memorandums of Understanding (MOUs) with IRWD and SAWPA for accepting their wastewater flows and for implementing source control discharge, inspection, and enforcement requirements.

8.2 REVENUE ZONE NO. 14 (IRVINE RANCH WATER DISTRICT)

IRWD is a California Water District in central Orange County, California, which is served by several Revenue Zones within OCSD and other agencies. The northern and coastal parts of IRWD are served by OCSD. The pretreatment program in these sections is managed by OCSD staff. A small portion of the eastern part of IRWD, called Portola Hills, is currently sewered to Santa Margarita Water District, a member of the South Orange County Wastewater Authority (SOCWA). SOCWA administers the pretreatment program for its member agencies.

On January 1, 2001, the Los Alisos Water District (LAWD) consolidated with IRWD. LAWD owned and operated a 5.5-million-gallon-per-day (MGD) water reclamation plant whose effluent is used and administered by SOCWA under permits granted by both Region 8 and Region 9 Water Quality Control Boards. Wastewater effluent up to 7.5 MGD that is not recycled is discharged to the Aliso Creek ocean outfall in Laguna Beach. IRWD also uses its capacity in the Aliso Creek Ocean Outfall to dispose of brine from the Irvine Desalter. SOCWA administers the pretreatment program for discharges to the ocean outfall.

Most of IRWD is in Orange County Sanitation Revenue Zone No. 14, which collects sewage for treatment at either IRWD's Michelson Water Reclamation Plant (MWRP) or OCSD’s Reclamation Plant No. 1. Currently, most of the sewage generated within Revenue Zone No. 14 is treated at MWRP, which is a tertiary treatment plant with a design capacity of 18 MGD. MWRP's highly treated effluent meets all of the State of California Title 22 regulations for the reuse of recycled water. Sludge from MWRP is pumped to an OCSD sewer for treatment and disposal.

Prior to July 2008, the IRWD Harvard Area Trunk Sewer (HATS) discharged directly into OCSD’s Main Street sewer. IRWD constructed a lift station on the HATS and now pumps HATS sewage into the trunk sewer tributary to MWRP. As a result, the daily flow increased at MWRP by approximately 5 MGD. The significant flow increase is primarily responsible for any sudden increase in mass of pollutants reported herein.

OCSD and IRWD entered into an agreement to allow OCSD to install a ferrous chloride tank and pump station to feed ferrous chloride into the IRWD sludge line. The purpose of the ferrous chloride injection is to immobilize hydrogen sulfide and improve the settling characteristics at OCSD’s Reclamation Plant No. 1.

On July 1, 2003, IRWD assumed ownership of the sewage collection system in the Irvine Business Complex from OCSD. Prior to that, OCSD managed and maintained the sewage collection system and performed all source control activities. OCSD will still maintain source control activities including permit issuance and enforcement. Sewer service fees will be assessed by IRWD, in accordance with the IRWD Schedule of Rates and Charges.

IRWD joined OCSD in January 1986 to dispose of treated wastewater generated within IRWD's service area that was not needed for reclamation. In February 1987, IRWD and OCSD entered an MOU governing the

8.1 administration of the IRWD industrial waste program. The MOU brought industries considered as Class I industries by OCSD’s Wastewater Discharge Regulations (Ordinance) under a joint IRWD/OCSD’s Class I permit, which is administered by OCSD under OCSD’s Ordinance. The MOU also preserves the independent authority and responsibilities of both agencies, thereby allowing IRWD to operate its pretreatment program for MWRP to meet federal and state pretreatment regulations.

OCSD serves as the primary agency for sampling, inspecting, and permitting industries in those portions of the IRWD service area served by OCSD. To consolidate reporting requirements, IRWD submits its industrial waste program activities through OCSD, including those for Revenue Zone 14, which in turn are reported in OCSD’s semi-annual and annual Source Control Reports. The permit number identifier for each individual zone is shown by the first two digits of the permit number.

8.3 OPERATING PERMIT, REGIONAL BOARD ORDER 07-03

On November 30, 2007, the Santa Ana Regional Water Quality Control Board adopted Order R8-2007- 0003, (07-03), which renewed Order 01-95. Monitoring and Reporting Program No. 07-03 requires semi-annual reports of those constituents found during the annual monitoring. In addition, sludge monitoring is no longer required.

Order 07-03, Reporting Protocols, describes a specific protocol for reporting results. [For] sample results greater than or equal to the reported ML, [(results] shall be reported as measured by the laboratory (i. e., the measured chemical concentration in the sample). [For] sample results less than the reported RL, but greater than or equal to the laboratory’s MDL, [results] shall be reported as “Detected, but Not Quantified,” or “DNQ”. The estimated chemical concentrations of the sample shall also be reported and identified with “Estimated Concentration”. [ For] sample results less than the laboratory’s MDL, [results] shall be reported as “not detected” or “ND.” For the annual average, the reported value is the average of the quarterly results. ND values are considered as zero. If the annual average is less than the highest ML, the result is identified with ‖Estimated Concentration‖.

IRWD organic priority pollutant analyses for influent, effluent, and sludge are provided following the narrative. IRWD has scheduled priority pollutant monitoring more frequently than required by permit, in order to provide additional information to OCSD on the quality of wastewater and sludge in Revenue Zone 14. IRWD will continue to monitor the influent, effluent, and sludge quarterly.

The priority pollutant data follows the protocol established by the Regional Board. Values above the method limit, ML, are reported without comment. Values between the MDL, and the ML are reported but identified as an estimated concentration. Values below MDL are reported as non-detected, ND. For statistical purposes, averages consisting of numerical values are considered true averages. Averages consisting of numerical values and estimated concentrations, or solely estimated concentrations should be considered estimated averages. ND values are given a value of zero. A result of employing this averaging protocol is that many of the priority pollutants are identified and given an average concentration which may not be representative of actual concentration of the pollutant. IRWD suggests that estimated averages be used with circumspection.

8.4 REPORTING REQUIREMENTS

8.4.1 Analytical Reporting

Annually, the discharger shall submit…a summary of analytical results from representative, flow proportioned, 24-hour composite sampling of the POTW’s influent and effluent for those pollutants EPA has identified under Section 307(a) of the Act.

The collection points for the influent, effluent and sludge samples as follows:

Influent: Collected from the influent channel to the primary clarifiers.

8.2 Effluent: Collected at the end of the chlorine contact basin prior to entering the recycled water distribution system.

Sludge: Collected at the flow meter vault on the MPS-3 force main prior to ferrous chloride injection.

The sampling of influent, effluent, and sludge is performed by Water Quality personnel according to the following protocol:

1. Grab samples are collected quarterly for influent, effluent, and sludge samples and analyzed for volatile organic priority pollutants.

2. Composite samples are collected for BNA extractables, inorganic priority pollutants, pesticides/PCBs, and phenols at each location. This sampling is performed with a Sigma sampler that collects discrete samples at hourly intervals over a twenty-four hour period. The discrete samples are composited according to flow, and aliquots are distributed into the appropriate sample container. All of the samples are collected in glass bottles and distributed into the appropriate glass or plastic bottle.

Some samples are refrigerated and shipped on ice to Weck Laboratories in City of Industry, California for analysis. Weck Labs supplies all containers with the proper preservatives.

The detection limits may vary from quarter to quarter due to matrix interference and sensitivity of the analytical equipment; however, the results for each quarter are valid for the detection limit reported. IRWD and its contract laboratories have endeavored to meet or exceed reporting levels established in permits.

8.4.2 Inorganic Pollutants

General Minerals Michelson Water Reclamation Plant Monthly Effluent Total Dissolved Solids Because IRWD is a water reclamation 900 agency, MWRP effluent is subject to 850 general mineral requirements to protect 800 Basin Plan water quality criteria. IRWD 750 utilizes local groundwater and imported 700 water to supply its customer domestic water needs, and the quality of the 650 recycled water is based on the quality of 600 the domestic supply. The current Basin 550 Plan standard for the Irvine Groundwater 500 Basin is 910 mg/L Total Dissolved Solids 450 Total DissolvedTotal Solids mg/L in (TDS), and the current TDS for 400 02 03 04 05 06 07 08 09 10 01 02 03 04 05 06 07 08 09 ------discharges to recycled water reservoirs Apr Apr Apr Apr Apr Apr Apr Apr Apr Oct Oct Oct Oct Oct Oct Oct Oct Oct Jul Jul Jul Jul Jul Jul Jul Jul Jul designated as ―Waters of the State‖ is 720 Jan Jan Jan Jan Jan Jan Jan Jan Jan mg/L. As a purveyor of recycled water, the IRWD goal is to provide high quality Figure 8.1 Michelson Water Reclamation Plant Effluent Total Dissolved Solids Irvine Ranch Water District – Michelson Water Reclamation Plant water regardless of standards applied in Orange County Sanitation District the basin and has implemented several projects which improve the quality of the domestic water supply, which results in improvement in the quality of recycled water. In 1991, IRWD prepared the Michelson Influent Wastewater Quality Improvement Plan which identifies the procedures to be followed to produce the highest quality recycled water. An important feature of the plan is to maximize the delivery of high quality domestic water during the period of greatest recycled water consumption. In April 2002, IRWD commissioned its Deep Aquifer Treatment System plant, an 8 MGD membrane filtration plant, to provide additional high quality domestic water for its customers. The treatment plant removes natural organic matter in the form of color from a low TDS (290 mg/l, nominal) deep groundwater source. The treatment plant is designed to operate continuously, thereby decreasing

8.3 consumption of high TDS imported water, and improving mineral quality of the MWRP effluent. IRWD still needs to import some higher TDS water to meet its water supply needs.

In January 2007, IRWD commissioned the Irvine Desalter Plant, a 5.5 MGD reverse osmosis plant, to provide high quality domestic water for its customers. The treatment plant removes minerals from water in the Irvine Groundwater Basin to provide a target of 420 mg/L TDS in the final product water. The treatment plant is designed to operate continuously, thereby decreasing the consumption of high TDS imported water, and improving the mineral quality of the MWRP effluent. The minerals rejected by the reverse osmosis system are discharged into the ocean through the Aliso Creek Ocean Outfall. The Irvine Desalter Plant operation results in a net export of salt from the Irvine Groundwater Basin of approximately 3040 tons per year.

The seasonal change in MWRP effluent mineral quality is also shown in Figure 8.1. This figure shows that recycled water mineral quality, as expressed by total dissolved solids (TDS), varied by over 100 mg/l during 2009/2010, which is significantly lower than previous years. The effect of providing higher quality domestic water can be seen in the gradual reduction in TDS of the recycled water.

Total Heavy Metals Michelson Water Reclamation Plant Total Heavy Metals 50 IRWD has been analyzing the heavy metals on the list of inorganic 40 priority pollutants for the last 27 influent years at MWRP. During the 27-year 30 period, the total mass of heavy metals has increased from 5 to 20 30.96 pounds per day in the influent, a 24% decrease over the previous effluent Pounds/day 10 year, and has increased in the effluent from 2.7 to 7.29 pounds per 0 day in 2009/2010, a decrease of 3.29 pounds per day or 31% from 1983 1988 1993 Year 1998 2003 2008 the previous fiscal year. Figure 8.2 Michelson Water Reclamation Plant Influent and Effluent Heavy Metals Irvine Ranch Water District – Michelson Water Reclamation Plant Of all the priority pollutant heavy Orange County Sanitation District metals, only three, copper, lead, and zinc, were found in significantly greater concentrations than remaining metals. The sum of mass of copper, lead and zinc represents 74% of heavy metals found in the influent. IRWD analyzes for metals by ICP-MS, which is capable of reporting metals in the sub part per billion range. Figure 8.2 shows the annual mass of total heavy metals in the influent and effluent of MWRP. The major contributing heavy metal is zinc.

Copper

The major sources of copper are domestic water systems, and the printed circuit board industry. Both residential and nonresidential domestic water plumbing are predominantly copper. Currently, IRWD does not have printed circuit board manufacturing in the MWRP service area. The major commercial source of copper is believed to be radiator repair; however, copper from radiator repair activities is declining since many of the newer radiators are made from aluminum and plastic. The area tributary to MWRP has experienced rapid residential growth over the past several years even though growth has slowed recently, and as a result is experiencing an increase in the amount of copper Michelson Water Reclamation Plant being discharged from new Copper copper plumbing. It is expected 14 that the copper plumbing will take 12 several years to develop an inert influent lining, which will reduce the 10 discharge of copper into the 8 sewer system. 6

4

Pounds/day effluent 2 8.4 0 1983 1988 1993 1998 2003 2008 Year Figure 8.3 shows that the mass of copper in the influent has increased over the 27-year period from 3.5 to 4.4 pounds per day during the 2009/2010 fiscal year. The mass of copper entering the treatment plant has decreased by 7.9 pounds per day, or 64% from the 2008/2009 daily average. The mass of copper in the effluent has decreased by 1.22 pounds per day, or 77% from the previous fiscal year.

Lead

The major sources of lead are Michelson Water Reclamation Plant brass alloys and solder used in Lead domestic water systems, solder 6 used in vehicle radiators, and 5 solder used in the printed circuit board assembly industry. The 4 Figure 8.3 Michelson Water Reclamation Plant Influent and Effluent Copper use of lead based solder is no 3 Irvine Ranch Water District – Michelson Water Reclamation Plant longer allowed in domestic water Orange County Sanitation District influent systems. Figure 8.4 shows that 2 the mass of lead in the influent has remained essentially constant Pounds/day 1 effluent under one pound for the last 27 0 years and is 0.20 pounds per day 1983 1988 1993 1998 2003 2008 for 2009/2010, a decrease of 0.14 Year pounds per day, or 61% from the Figure 8.4 Michelson Water Reclamation Plant Influent and Effluent Lead previous fiscal year. Lead has Irvine Ranch Water District – Michelson Water Reclamation Plant Orange County Sanitation District shown three peaks in 1984, 1989 and 1996. The cause of the peaks was not identified. The concentration of lead in the effluent was 0.02 pounds per day, during the 2009/2010 fiscal year, a 51%, decrease from the previous fiscal year.

Michelson Water Reclamation Plant Zinc Zinc 30

Zinc is the predominant heavy 25 metal detected in both the influent and effluent. The major 20 influent sources of zinc are brass alloys 15 used in domestic water systems, water and oil based paints used 10 effluent by the building industry, and in Pounds/day 5 chemicals and coatings used by industry. 0 1983 1988 1993 1998 2003 2008 Year Figure 8.5 shows that the mass of zinc in the influent has Figure 8.5 Michelson Water Reclamation Plant Influent and Effluent Zinc increased from 4.5 pounds per Irvine Ranch Water District – Michelson Water Reclamation Plant Orange County Sanitation District day to 18.44 pounds per day over 27 years, with a decrease of 7.41 pounds per day or a 28% decrease from the previous fiscal year. The mass of zinc in the effluent has increased from 1 pound per day to 4.91 pounds per day during the 2009/2010 fiscal year, and saw a decrease of 2.24 pounds per day, or 31% from the previous fiscal year.

Michelson Water Reclamation Plant Total Toxic Organic Compounds 8.4.3 Organic Pollutants 20 18 IRWD has been analyzing for 16 14 organic pollutants on the list of effluent organic priority pollutants at 12 MWRP since 1983. The sampling 10 8 frequency has increased from influent

Pounds/day 6

4 2 8.5 0 1983 1988 1993 1998 2003 2008 Year once per year to quarterly sampling. Samples are collected from the influent, effluent, and sludge.

Over the last 27 years, the annual mass of total organic pollutants entering MWRP has decreased from a high of 16.82 pounds per day to 4.51 pounds per day, and has experienced a 58% decrease over the previous year. The mass of total Figure 8.6 Michelson Water Reclamation Plant Influent and Effluent Total Toxic organic priority pollutants leaving Organics MWRP decreased from 12.74 Irvine Ranch Water District – Michelson Water Reclamation Plant Orange County Sanitation District pounds per day in 2008/2009 to 5.33 pounds per day, a 20% decrease, in 2009/2010. The general increase in effluent organic pollutants above influent levels is attributed to an increase in trihalomethanes and other volatile organic compounds resulting from final effluent chlorination required to meet California Title 22 Water Recycling Criteria.

Figure 8.6 shows the annual mass of total organic pollutants in the influent and effluent of MWRP.

8.4.4 Report of Upset, Pass-Through and Interference Events

The discharger shall submit annually...a discussion of upset, interference, or pass-through incidents, if any, at the POTW which the discharger knows or suspects were caused by industrial users of the POTW system...

There were no upset, interference or pass-through incidents caused by industrial users during the reporting period.

8.4.5 Discussion of the List of Industrial Users

The discharger shall submit annually...an updated list of the discharger's significant industrial users...

Table 8.1 summarizes those companies in Revenue Zones Nos. 7 and 14 which were under permit and in business as of June 30, 2010. Class I industrial users in Revenue Zone 7 discharge to the IRWD collection system and treated at OCSD’s treatment plant. Class I industrial users in Revenue Zone 14 discharge to the IRWD collection system and are treated at MWRP and at OCSD’s treatment plant.

Table 8.1 Class I Industries Within Irvine Ranch Water District, Revenue Zones 7 and 14 Orange County Sanitation District/IRWD

Permit No. Company Name Sewer Street NAICS Code Classification Electroplating, Plating, Polishing, 7-1-162 Electrolurgy 1121 Duryea Ave. 332813 Anodizing, and Coloring

7-1-240 Royalty Carpet Mills 17352 Derian Ave. 314110 Carpet and Rug Mills Metal Coating, Engraving (except Jewelry 7-1-011 Ricoh Electronics 17482 Pullman St. 332812 and Silverware), and Allied Services to Manufacturers 20662 Newport 14-1-003 Gas Recovery Systems 221119 Other Electric Power Generation Coast Dr. Mayonnaise, Dressing, and Other 7-1-056 Todds a Division HJ Heinz 2450 White Road 311941 Prepared Sauce Manufacturing Pharmaceutical Preparation 14-1-007 Teva Parenteral Medicines Inc. 19 Hughes 325412 Manufacturing

8.6

Table 8.1 Class I Industries Within Irvine Ranch Water District, Revenue Zones 7 and 14 Orange County Sanitation District/IRWD

Permit No. Company Name Sewer Street NAICS Code Classification 14-1-163 Tropitone Furniture Co. 5 Marconi 337124 Metal Household Furniture Manufacturing 54-1-172 Alliance Medical Products 9342 Jeronimo Road 339115 Ophthalmic Goods Manufacturing 7-1-141 Cheek Engineering & Stamping 14341 Franklin Ave. 332116 Metal Stamping Noncellulosic Organic Fiber 7-1-054 B. Braun Medical 2525 McGaw Ave. 325222 Manufacturing Electroplating, Plating, Polishing, 57-1-298 S M C Corporation Of America 14191 Myford Rd. 332813 Anodizing, and Coloring Textile and Fabric Finishing (except 7-1-158 St. John Knits, 17422 Derian Ave. 313312 Broadwoven Fabric) Mills 7-1-235 Prudential Overall Supply 16901 Aston Street 812332 Industrial Launderers 14-1-012 Oakley 1 Icon 339115 Ophthalmic Goods Manufacturing 7-1-024 Maruchan 1902 Deere Ave. 311823 Dry Pasta Manufacturing Analytical Laboratory Instrument 7-1-038 Newport Corporation 1791 Deere Ave. 334516 Manufacturing 15800 Laguna 14-1-015 Maruchan # 2 311823 Dry Pasta Manufacturing Canyon Rd. Fluid Power Valve and Hose Fitting 57-1-294 F M H Investor Group 17072 Daimler St. 332912 Manufacturing 17835 Sky Park 57-1-303 Rayne Dealership Corporation 561990 All Other Support Services Circle, M Pharmaceutical Preparation 54-1-173 Anchen Pharmaceuticals 9601 Jeronimo Rd. 325412 Manufacturing TC Cosmotronic Inc.,dba 57-1-309 16721 Noyes Ave. 334412 Bare Printed Circuit Board Manufacturing Cosmotronic 14-1-023 Marukome U.S.A. 17132 Pullman St. 311823 Dry Pasta Manufacturing 17462 Von Karman 14-1-024 Nyala Screenprinting 323114 Quick Printing Ave. Graphic Packaging 1600 Barranca 57-1-314 322212 Folding Paperboard Box Manufacturing International Parkway 57-1-315 IHOI 14524 Myford Rd 311991 Perishable Prepared Food Manufacturing Pharmaceutical Preparation 54-1-174 Anchen Pharmaceuticals # 2 72 Fairbanks 325412 Manufacturing

Carburetor, Piston, Piston Ring, And 57-1-316 CP Pistons 1902 McGaw Ave. 336311 Valve Manufacturing Note: Permit numbers beginning with "14" and "54" have waste that flows to the Michelson Water Reclamation Plant for treatment. Permit numbers beginning with "57" and "7" discharge into IRWD's collection system, and flow to OCSD for treatment and disposal.

8.4.6 Discussion of Industrial User Compliance Status

The discharger shall submit annually...a list or table characterizing the industrial compliance status of each SIU...

The compliance status of each noncompliant SIU is shown in OCSD’s Source Control Annual Report.

8.4.7 Summary of SIU Compliance

The District shall submit annually...a compliance summary table...

8.7 A summary of compliance is shown in OCSD’s Source Control Annual Report.

8.4.8 Discussion of Significant Changes in the Pretreatment Program

The District shall submit annually...a short description of any significant changes in operating the pretreatment program which differ from the previous year…

There were no significant changes in operating the pretreatment program between the 2008/2009 and 2009/2010 fiscal years.

8.4.9 Pretreatment Program Costs

The District shall submit annually...a summary of the annual pretreatment budget and the pretreatment equipment purchases...

A financial summary of IRWD's pretreatment program is shown in Table 8.2. All of the expenses shown in Table 8.2 are related to the operation of IRWD's pretreatment program by IRWD staff. All expenses incurred by IRWD under the Memorandum of Understanding between IRWD and OCSD are summarized by OCSD.

Table 8.2 Summary of Irvine Ranch Water District Pretreatment Program Costs 2008-2009 and 2009-2010 Orange County Sanitation District/IRWD

Project Accounts 2009-2010 Accounts 2008-2009 No. Description Labor Payable Total Labor Payable Total 82790 Quarterly PP 16,179.52 222.75 16,402.27 7,892.04 362.40 8,254.44 82800 Baseline PP 6,254.63 601.00 6,855.63 10,796.23 756.66 11,552.89 82820 PP Surveillance 8,974.58 7,193.85 16,168.43 14,614.86 8,485.26 23,100.12 Compat. 82830 12,744.64 156.36 12,901.00 8,649.28 1,303.46 9,952.74 Surveillance 82850 Mgt. and Admin. 17,393.19 0.00 17,393.19 13,326.09 0.00 13,326.09 82860 Ind. Info. Coll. 41,496.57 0.00 41,496.57 26,165.26 971.96 27,137.22 82870 Eval Data/Rpts. 6,155.72 0.00 6,155.72 5,615.73 0.00 5,615.73 82890 OCSD/SOCWA 8,661.64 0.00 8,661.64 2,318.43 0.00 2,318.43 Total $126,034.45 $101,257.66

IRWD records expenses based on project numbers which represent specific activities or groups of related activities. The expenses are subdivided into labor plus overhead, and accounts payable (services and equipment). The accounts payable primarily represents laboratory analyses performed by outside laboratories. IRWD is reducing outside laboratory use, which is reflected in reduced accounts payable payments and increased labor payments. During fiscal year 2009/2010, IRWD spent $126,034 on the operation and maintenance of its pretreatment program, which is an increase of $24,777 from the previous year.

8.4.10 Equipment Purchases for FY 2009/2010

IRWD purchased replacement equipment in the 2009/2010 fiscal year. The current equipment inventory is shown in Table 8.3.

Table 8.3 Summary of Irvine Ranch Water District Pretreatment Equipment, Fiscal Year 2009-10 Orange County Sanitation District/IRWD

8.8 Quantity Description 1 Ford F250 2 Sigma Ultrasonic Flowmeters with Conductivity and pH 4 Sigma 900 Max Insulated Autosamplers with Conductivity and pH 1 Sigma SD 900 insulated Autosamplers 2 Spare compact insulated autosampler bases—Sigma 3 Spare large insulated autosampler bases-24 bottle configuration—Sigma 2 Spare large insulated autosampler bases-12 bottle configuration—Sigma 6 Sigma Lead-Acid Gel Cell Batteries 3 Sigma Battery Charger, 5 Stations 2 Sigma Data Transfer Unit and Software 1 Impact gas detector

8.4.11 Discussion of Public Participation Activities

The District shall submit annually...a summary of public participation activities...

IRWD has a standing program of MWRP tours, where the public is instructed on proper hazardous waste disposal practices. As Revenue Zones Nos. 7 and 14, IRWD is represented by OCSD in its public participation activities. As an operator of a sewage collection system, IRWD is enrolled under the statewide general permit to manage fats, oils and grease discharges from food service establishments. The public participation program is administered by MWRP staff.

8.4.12 Discussion of Sludge Disposal Activities

The District shall submit annually...a description of any changes in sludge disposal methods...

IRWD has made no changes in its sludge disposal methods. IRWD and OCSD have entered into an agreement to inject ferrous chloride into the sludge to reduce hydrogen sulfide downstream and improve settling at OCSD’s Reclamation Plant No. 1.

8.5 ADDITIONAL INFORMATION

The District shall submit annually...any concerns not described elsewhere in the report.

Michelson Water Reclamation Plant Flow

Figure 8.7 shows the wastewater flow received by MWRP over the last 27 years. MWRP flow increased annually until IRWD joined OCSD in 1986. Since 1986, IRWD has used its ability to reclaim water on an as needed basis. Average flow for the 2009/2010 fiscal year was 19.01 MGD, which is a 1.0% increase over the previous year. Michelson Water Reclamation Plant The Michelson Water Reclamation Average Daily Flow Plant is now operating at 106% of its 24 design capacity. However, as Revenue 22 Zone No. 14, IRWD owns additional 20 treatment capacity at OCSD, which 18 allows IRWD to operate its facilities near or at design capacity, and still 16 have reserve treatment capacity to 14 meet its future needs. By operating its MGD 12 reclamation facilities near or design capacity, and float its additional 10 8

6

4 8.9 1983 1988 1993 1998 2003 2008 Year treatment needs at OCSD facilities, IRWD is able to schedule additional recycled water supply as the demand for recycled water increases.

Michelson Water Reclamation Plant 10 Million Gallon per Day Expansion Figure 8.7 Michelson Water Reclamation Plant Influent Flow Irvine Ranch Water District – Michelson Water Reclamation Plant Project Orange County Sanitation District

IRWD is under construction of a 10 MGD biological nitrogen removal membrane filtration plant expansion at the MWRP. The project was approved by the IRWD Board of Directors, in the 2008/2009 fiscal year, and the construction contract was awarded in August 2009. The expansion will provide an additional 10 MGD of treatment capacity by July 2012. The membrane filtration plant will produce high quality partially denitrified recycled water meeting State of California Title 22 requirements.

Nitrification/Denitrification Facilities

IRWD completed a significant upgrade to its Michelson Water Reclamation Plant by installing a nitrification/denitrification system on its activated sludge system in the 1998-99 fiscal year. Plant effluent is now fully nitrified year round, and substantially denitrified during the months when recycled water is stored in IRWD open storage reservoirs. A fully nitrified effluent means that IRWD maintains a free chlorine residual rather than a combined chlorine residual. A free chlorine residual causes a greater formation of trihalomethanes and related volatile organic compounds, which is evident in the increase of effluent total toxic organic compounds. Fortunately, the quality of plant effluent, detention time in the plant, and short time before storage or use, keeps the level of toxic organic compounds below regulatory criteria, even though a relatively high chlorine dose is required to maintain bacterial quality. The operation of the nitrification/denitrification system has improved activated sludge operations, which in turn, has increased the quality of recycled water.

Industrial Parks Development Status

Since the early 1980's, MWRP has been receiving increased industrial wastewater flows from the Irvine Spectrum. The Irvine Spectrum is a large industrial park located near the former El Toro Marine Corps Air Station. In the past few years, the Foothill Ranch industrial area, located north and east of the El Toro Marine Corps Air Station, came on line. The El Toro Marine Corps Air Station is decommissioned and the future use of the site remains in the planning stage. Consequently, IRWD sees the potential for gradually increasing levels of organic pollutants and heavy metals as the Irvine Spectrum industrial park, Foothill Ranch, and the El Toro Marine Corps Air Station sites develop. The University of California, Irvine is expanding the University Research Park located on the southern portion of the university. IRWD sees a potential for organic priority pollutant and heavy metal discharges from the industrial/research parks. The 2008 recession has resulted in the closure of a significant number of industrial and commercial enterprises in the industrial parks, which has resulted in a significant reduction in wastewater generated.

Michelson Water Reclamation Plant Selenium Stormwater, Deminimis Discharges and Selenium 5 4.5 In May, 2009, the Santa Ana 4 Regional Water Quality Control Influent Board adopted the fourth term 3.5 Effluent influent Waste Discharge Requirements 3 for the County of Orange, 2.5 Orange, County Flood Control 2 District, and Incorporated Cities effluent Seleniuminµg/L of Orange County Within the 1.5 Santa Ana Region Areawide 1 Stormwater Runoff Orange 0.5 County, Order R8-2009-0030. A 0 2000 2002 2004 2006 2008 2010 8.10 Year Figure 8.8 Michelson Water Reclamation Plant Influent Selenium Irvine Ranch Water District – Michelson Water Reclamation Plant Orange County Sanitation District condition of this permit is a requirement that non-stormwater discharges be prohibited from discharge into the storm drain system except for urban runoff and certain authorized non-stormwater discharges. As a result, there has been an increase non-wastewater discharges into the sewer system. In general, these discharges contribute to the hydraulic loading to the sewer system, but are not a significant source of naturally occurring conventional and other pollutants. However, selenium is a naturally occurring pollutant in the watershed.

The northeastern side of the Irvine Basin is dominated by coastal foothills, and historically runoff from the foothills deposited in a seasonal marsh called the Cienega de las Ranas. Natural weathering of the coastal foothills has exposed and eroded the Monterey Formation containing significant amounts of selenium, which over time have accumulated in the seasonal marsh. In addition to runoff, rising groundwater in the area of the seasonal marsh has raised the concentration of selenium in surface water well above the California Toxics Rule criterion of 5 µg/L. The seasonal marsh has been drained, first to promote agriculture, and then the agricultural land has been converted into urban development. Surface waters in the watershed are listed on the Section 303(d) list for selenium impairment, and discharges of water into the surface water system above 5 µg/L are regulated under the Basin Plan.

The effect of the additional prohibition of non-stormwater discharging into the storm drain system has resulted in additional non-stormwater flows being discharged into the sewer system containing significant levels of selenium. Some of the discharges are tributary to OCSD’s sewer system, and the selenium is ultimately returned into the ocean. However, some of the discharges are tributary to the IRWD sewer system. IRWD has been tracking the fate and transport of selenium since 2002 to garner knowledge on the effect of the additional non-stormwater discharges on MWRP effluent quality. Currently, the effluent concentration is approximately 2.5 µg/L, or half the California Toxics Rule criterion. Prior to 2002, the concentration of selenium in the wastewater was negligible, because there was no selenium in the domestic water supply, there were no industries discharging selenium and non-wastewater discharges into the sewer system were prohibited. Because selenium toxicity is based on concentration, IRWD will continue to monitor the concentration of selenium in the influent and effluent from the MWRP.

IRWD Oversight Activities

IRWD monitored four major trunklines within its service area for priority pollutants. Commercial, residential and industrial areas are monitored on a semi-annual basis. One purpose of this monitoring is to establish a long-term history of priority pollutant discharges into the sewer system. Phthalates are used to maintain flexibility in plastic products and are commonly found. The low concentrations of these constituents are common and are considered emerging pollutants of concern.

Within the IRWD service area, industrial activities are regulated by the City of Irvine General Plan and Zoning Ordinances, which confines industrial uses to specific zones and the City of Lake Forest, which is the agency currently responsible for the Foothill Ranch Master Plan. Within the Irvine Spectrum and Foothill Ranch, IRWD monitors seven locations semi-annually for heavy metals and cyanide, as an independent confirmation of the quality of water received from those industrial areas. Monitoring locations will be increased or decreased after evaluation of results and identification of contributing industries.

The IRWD service area encompasses the San Diego Creek watershed, the largest watershed at 118 square miles that is tributary to Newport Bay. Newport Bay and its tributary watersheds are subject to Total Maximum Daily Load (TMDL) allocations for sediment, nutrients, pathogens, and toxics. IRWD does not discharge wastewater into surface waters, other than its open storage reservoirs; however, as the sole purveyor of water and recycled water in the watershed, IRWD has chosen to become involved with water quality management in the watershed. IRWD is constructing and managing wetlands, under the Natural Treatment Systems Project, which will remove pollutants of concern to the TMDL allocations. IRWD extends its services to assist commercial and industrial users to recognize the importance of site runoff water quality, point out sources of contamination and areas of potential contamination, and advise on corrective measures.

8.11 8.6 SANTA ANA WATERSHED PROJECT AUTHORITY (SAWPA)

SAWPA was formed in 1968 to develop a long-range plan for managing, preserving, and protecting the quality of water supplies in the Santa Ana River Basin. SAWPA is a Joint Powers Authority (JPA) consisting of five agencies: Eastern Municipal Water District (EMWD), Inland Empire Utilities Agency (IEUA), Orange County Water District (OCWD), San Bernardino Valley Municipal Water District (SBVMWD), and Western Municipal Water District (WMWD).

SAWPA's program in water quality management is integrated with those of other local, state and federal agencies. Three examples shown below are the Santa Ana Regional Interceptor (SARI) sewer, the Western Riverside County Regional Wastewater Reclamation Plant (WRCRWRP), and the Stringfellow Site Treatment Plant.

The SARI is a pipeline that was originally designed to carry saline wastewater from the Upper Basin to OCSD for disposal after treatment into the Pacific Ocean. The wastewater today consists of a mixture of not only desalter brine, and saline wastewater from industrial uses, but also from industrial and some residential domestic discharges. The wastewater is treated by OCSD to comply with environmental standards before discharge to the ocean outfall. The capacity of the SARI line available to SAWPA is 30 MGD. The current average daily discharge is 11.88 MGD for this reporting period, which leaves about 18.12 MGD of trunkline capacity available for future use.

The Western Riverside County Regional Wastewater Reclamation Plant (WRCRWRP) was designed and constructed to treat almost all the domestic wastewater that was previously discharged to SARI. The treated domestic wastewater can now be reused as a non-potable water supply. The project is expected to develop up to 8,000-acre feet of water per year for beneficial use. The WRCRWRP furnishes regional wastewater treatment services to areas such as Home Gardens Sanitary District (HGSD), City of Norco, Jurupa Community Services District (JCSD), and Western Municipal Water District (WMWD).

At the Stringfellow Site, a treatment plant is operated by the State of California where heavy metals are removed from the contaminated groundwater by lime precipitation, and organic pollutants are removed by activated carbon absorption. The treated water is then discharged to the SARI line, sludge is trucked to a Class I landfill and the supplier regenerates spent carbon.

8.6.1 SARI System Pretreatment Program Overview

SAWPA has a wastewater discharge ordinance, which regulates the discharge of wastewater to the sewer. It is essentially, with some modifications, the same as OCSD’s Wastewater Discharge Regulations Ordinance. In addition, a Memorandum of Understanding is in place to delineate pretreatment enforcement and reporting responsibilities between SAWPA and OCSD. SAWPA has entered into Multijurisdictional Pretreatment Agreements with IEUA, EMWD, SBVMWD and WMWD. These Agreements delineate the pretreatment responsibilities between SAWPA and the member agencies to carry out and enforce a pretreatment program to control discharges from industrial users located in their services areas.

SAWPA owns and operates the SARI above the Orange County line and has purchased 17 MGD of treatment and disposal capacity rights at OCSD's treatment facilities. There are a total of fifty-two (52) direct connections (including WRCRWRP, City of Corona Treatment Plant No. 1 and four truck disposal stations) discharging to the SARI. The four (4) SAWPA approved truck disposal stations are located in and operated by the following agencies: Eastern Municipal Water District (EMWD), Inland Empire Utilities Agency (IEUA), San Bernardino Valley Municipal Water District (SBVMWD), and Western Municipal Water District (WMWD).

EMWD permits two (2) industrial users to haul wastewater to the SAWPA approved truck disposal station located in EMWD’s service area at 29541 Murrieta Road, Sun City, CA. For FY2009/10 EMWD received 22.17 million gallons at EMWD’s truck disposal station, with an approximate average of 60,736 gallons per day.

8.12 IEUA permits nine (9) industrial users to haul wastewater to the SAWPA approved truck disposal station located in IEUA’s service area at 16400 El Prado Road, Chino CA. For FY2009/10 IEUA received 8.0832 million gallons at IEUA’s truck disposal station, with an approximate average of 22,329 gallons per day.

SBVMWD permits seventeen (17) industrial users to haul wastewater to the SAWPA approved truck disposal station located in SBVMWD’s service area at 399 Chandler Place San Bernardino, CA SBVMWD truck disposal station is operated by the City of San Bernardino Municipal Water Department (SBMWD) under a contract with SBVMWD. For FY2009/10 SBVMWD received 4.12 million gallons at SBVMWD’s truck disposal station, with an approximate average of 11,29 gallons per day.

WMWD permits twenty-two (22) industrial users to haul wastewater to the SAWPA approved disposal station located in The City of Corona’s Wastewater Treatment Plant No.1 at 2205 Railroad St. Corona, CA. For FY2009/10 WMWD received 20.3 million gallons at WMWD’s truck disposal station, with an average of approximately 56,077 gallons per day.

Santa Ana River Interceptor (SARI) A flow meter installed at the Orange County line measures SAWPA's discharge. For FY2009/10, a total of 4,312.31 million gallons was discharged to the SARI, for an approximate average of 11.8 MGD. The SAWPA effluent represents a mixture of desalter brine, domestic/industrial wastes, and industrial brine. The flow meter location at the Orange County line is sampled by SAWPA weekly.

Most of the direct connections to the SARI are sampled a minimum of once per month using both grab and composite techniques. All samples are properly preserved and iced for transport to the laboratory. Samples are tested for conventional and/or priority pollutants, including metals, biochemical oxygen demand, and total suspended solids. Appendix J of this report shows the individual results of the SAWPA sampling. The average yearly metals at the flow meter are shown in Table 8.4.

Table 8.4 Average Effluent Characteristics at the Green River Flow Meter for Fiscal Year 2009-10. Orange County Sanitation District/SAWPA Constituent mg/L Lb/day

Arsenic 0.0043 0.42 Cadmium 0.0006 0.06 Chromium 0.025 2.5 Copper 0.11 11.0 Lead ND — Mercury ND — Nickel 0.03 3.0 Silver ND — Zinc 0.16 15.74 BOD 163.5 16,090 TSS 314.48 30,949 Flow 11.8 MGD —

8.13

8.6.2 Equipment Inventory

A summary of the equipment available to the pretreatment program is shown below in Table 8.5.

Table 8.5 Santa Ana Watershed Project Authority – Summary of Pretreatment Equipment for Fiscal Year 2009-10 Orange County Sanitation District/SAWPA Quantity Description

1 Chevrolet One Ton Utility Truck, Diesel 1 Chevrolet ½ Ton Van 12 ISCO Autosamplers 5 ISCO Spare Sampler Bases 15 ISCO Batteries, NiCd 3 ISCO Battery Chargers, 5 Stations Each 1 ISCO Ultrasonic Flowmeter 8 Gastech gas detectors 8 Spill response kits in vehicles

8.7 SAWPA DIRECT CONNECTIONS

Table 8.6 summarizes those companies that were under permit and in business as of June 30, 2010.

Table 8.6 Santa Ana Regional Interceptor (SARI), Permitted Direct Connected Facilities, Fiscal Year 2009-10 Orange County Sanitation District/SAWPA

NAICS Company Service Address Code Category Permit No.

Aqua Mansa Power Plant 2040 Aqua Mansa Rd.Colton, CA 221122 Electrical generating facility 4E-03-S53 (SBVMWD) 92324 Arlington Basin Desalter 11615 Sterling, Riverside, CA 92503 221310 Desalter 4B-93-S22 Facility (WMWD) California Institution for 16756 Chino-Corona Road, Corona, 922140 Correctional Institution 4D-95-S26 Women (IEUA) CA 92880 California Rehabilitation Fifth and Western, Norco, CA 91860 922140 Correctional Institution 4B-94-S19 Center (WMWD) Chino I Desalter Facility 6905 Kimball Avenue, Chino, CA 221310 Desalter 4D-00-S34 (IEUA) 91710 Chino II Desalter Facility 11251 Harrel St, Mira Loma, CA 221310 Desalter 4D-06-S57 (SAWPA) 91752 City of Corona – Green River 815 W. Sixth Street, Corona, CA Sewer Connection 221320 Sewer Collection System 4B-93-S12 91720 (Emergency)(WMWD)

8.14 Table 8.6 Santa Ana Regional Interceptor (SARI), Permitted Direct Connected Facilities, Fiscal Year 2009-10 Orange County Sanitation District/SAWPA

NAICS Company Service Address Code Category Permit No.

City of Corona – Temescal 745 Corporation Yard Way, Corona, 221310 Desalter 4B-00-S32 Desalter (WMWD) CA 92880 City of Corona – Wastewater Treatment Plant No. 2205 Railroad St. Corona, CA 92880 221320 Treatment Plant 4B-06-SP59 1(WMWD) Corona Energy Partners 1130 W. Rincon St., Corona, CA 221112 Electric Power Generation 4B-93-S20 (WMWD) 92880 Dairy Farmers of America 1138 West Rincon Street, Corona, 325998 Water Distillery 4B-08-S63 (WMWD) CA Dart Container Corp. of CA 150 South Maple St. Corona, CA Produces disposable beverage 326140 4B-03-S50 (WMWD) 91720 containers Eastern Municipal Water Temescal Valley Regional District–Master Meter 2270 Trumble Rd. Perris, CA 92570 221320 5-02-S47 Interceptor (SAWPA) Eastern Municipal Water 2954 Murrieta Rd. Sun City, CA District- Menifee Desalter 221310 Desalter EMWD # 532 92586 Facility (EMWD) Eastern Municipal Water 2954 Murrieta Rd. Sun City, CA District-Perris Desalter 221310 Desalter EMWD # 542 92586 Facility (EMWD) Eastern Municipal Water District-Regional Reclaim 636 Minthorn St., Lake Elsinore, CA 221320 Out of Spec. Recycled Water EMWD # 550 Facility (Emergency) 92530 (EMWD) Eastern Municipal Water Railroad Canyon Rd., Canyon Lake, Emergency Wastewater District-Perris Moreno Valley 221320 EMWD # 545 CA 92587 Discharge Line (Emergency) (EMWD) Eastern Municipal Water 29285 Valley Blvd., Sun City, CA Emergency Wastewater District-Sun City Lift Station 221320 EMWD # 544 92586 Discharge (Emergency) (EMWD) Eastern Municipal Water District-Menifee Valley 29541 Valley Blvd., Sun City, CA Hauled Industrial Brine 221320 EMWD # 552 Trucked Waste Disposal 92586 Wastewater Facility (EMWD) Eastern Municipal Water 26226 Antelope Rd., Romoland, CA District-Inland Empire Energy 221112 Electric Power Generation EMWD # 554 92585 Center (EMWD) EnerTech Rialto Biosolids 503 east Santa Ana Avenue 562219 Biosolids Processing to SBVMWD Processing Facility produce E-Fuel 4E-07-S62 (SBVMWD) Bloomington, CA 92316 221320

Green River Golf Club 5215 Green River Drive, Corona, CA 713910 Public Golf Course 4-94-S25 (IEUA) 92880

Inland Empire Utilities 6075 Kimball Ave., Chino, CA 91710 221320 Sewer Collection System 4A-93-S05 Agency (SAWPA)

Inland Empire Utilities 6075 Kimball Ave. Chino, CA 91710 221320 Wastewater Discharge. 4A-05-SP58 Agency (IEUA)

Inland Empire Utilities Agency-Mission Uniform and 5400 Alton St., Chino, CA 91710 812332 Industrial Laundry SSP013 Linen Services (IEUA)

8.15 Table 8.6 Santa Ana Regional Interceptor (SARI), Permitted Direct Connected Facilities, Fiscal Year 2009-10 Orange County Sanitation District/SAWPA

NAICS Company Service Address Code Category Permit No.

Inland Empire Utilities 1401 Central Avenue, Chino, CA Agency-California Institution 922140 Correctional Institute SSP008 91708 for Men (IEUA)

Inland Empire Utilities 5601 Eucalyptus Ave., Chino, CA 221112 Electric Power Generation C-87-002-A Agency-OLS Energy (IEUA) 91710

City of Chino Hills – Fairfield Nitrate removal facility SSP016 Ranch Water Well no. 5

Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Archibald Metering 221320 Sewer Collection System 4D-04-S55 Station (Emergency) 91752 (WMWD) Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Celebration Metering 221320 Sewer Collection System 4D-03S54 91752 Station (WMWD) Jurupa Community Services District, Chandler 11201 Harrel St. Mira Loma, CA 221320 Sewer Collection System 4D-01-S36 Connection(Emergency) 91752 (WMWD) Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Cleveland 221320 Sewer Collection System 4D-00-S21 Connection (Emergency) 91752 (WMWD) Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Etiwanda Connection 221320 Sewer Collection System 4D-95-S28 91752 (WMWD) Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Hamner Connection 221320 Sewer Collection System 4D-98-S24 91752 (WMWD)

Jurupa Community Services 11201 Harrel St. Mira Loma, CA 221320 Sewer Collection System 4D-02-S49 District, Hamner Lift Station 91752 (Emergency) (WMWD) Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Harrison connection 221320 Sewer Collection System 4D-02-S48 91752 (Emergency) (WMWD) Jurupa Community Services 11201 Harrel St. Mira Loma, CA District, Wineville Connection 221320 Sewer Collection System 4D-98-S23 91752 (WMWD) Mountainview Power Co., 2492 San Bernardino Ave. Redlands, 221112 Electric Power Generation 4E-00-S35 LLC. (SBVMWD) CA 92374 Rubidoux Community 2100 Fleetwood Drive, Riverside, CA Nitrate Removal from 221310 4D-96-S29 Services District (WMWD) 92509 Groundwater Wastewater in the event RIX SBMWD Treatment Plant 399 Chandler Place, San 221310 Facility is unable to process 4E-05-S57 (SBVMWD) Bernardino, CA 92408 incoming wastewater. SBMWD WRP Truck 399 Chandler Place, San Hauled Industrial Brine 221320 4E-04-S56 Disposal Station. (SBVMWD) Bernardino, CA 92408 Wastewater SBVMWD required to SBVMWD Master Permit 380 E. Vanderbilt Way, San implement a pretreatment N/A 4E-09 (SAWPA) Bernardino, CA 92408 program within their service area SAWPA/WMWD Truck 2205 Railroad St. Hauled Industrial Brine 221320 4B-06-S60 Disposal Station (SAWPA) Corona, CA 92880 Wastewater Stringfellow Pretreatment 3450 Pyrite Street, Riverside, 562910 Cleanup of Contaminated 4D-98-S101

8.16 Table 8.6 Santa Ana Regional Interceptor (SARI), Permitted Direct Connected Facilities, Fiscal Year 2009-10 Orange County Sanitation District/SAWPA

NAICS Company Service Address Code Category Permit No.

Facility Cleanup and CA 92509 Groundwater Abatement Monitoring (SAWPA)

Wastewater is generated from Wellington Foods, Inc. 1930 California Ave. 311999 product spills, wash down and 5-10-S64 (WMWD) Corona, CA 92881 clean-in-place(CIP) discharges.

WMWD required to implement WMWD Master Permit 450 E. Alessandro Blvd. Riverside, N/A a pretreatment program within 4B & 4D-09 (SAWPA) CA 92508 their service area Western Riverside County Regional Wastewater Plant 671 N. Lincoln, Corona, CA 92993 221320 Sewage Treatment Plant 4D-06-S61 (SAWPA)

8.7.1 New Permits:

Permits issued during this reporting period (a brief description of the new SIUs and IUs is provided below):

Giuliano & Sons Briners, Inc (WMWD Permit No. DS-065)

Giuliano & Sons Briners, Inc. produces diced citrus peel, and pickles a variety of vegetables, such as jalapenos, cauliflower, celery, carrots, and Ortega chilies. Vinegar, acetic acid,sodium chloride, calcium chloride, and sulfur dioxide solutions are used to process the vegetables and fruit. The wastewater generated from these processes is hauled offsite to the SARI System for disposal.

Wellington Foods, Inc. (WMWD Permit No. 5-10-S64

Wellington Foods is a contract manufacturer that produces and packages a variety of liquid and powder nutritional supplements for the nutritional supplement industry.

8.7.2 Pending Permits

Temporary Domestic Connection, Alberhill Area (Elsinore Valley MWD): A new temporary domestic connection is planned to serve a new residential development in the north end of the City of Lake Elsinore. Initially this connection will add up to 0.30 MGD. The maximum flow is 1.0 MGD; it is expected that the flow will gradually increase from 0.3 to 1.0 MGD between 2007/8 and 2012. By agreement, this connection must be removed by 2012.

8.7.3 Closed Permits:

Permits that were closed during this reporting period (a brief description of the closed SIUs and IUs is provided below):

Gene Belk Fruit Packers (WMWD Permit No. DS-003)

This company produces diced citrus peel, and pickles a wide variety of vegetables. Wastewater is generated from washing and from brine spillage. Wastewater is screened, clarified, and hauled to the SARI Truck Disposal Station.

Gene Belk sold their company to Guiliano & Sons Briners Inc., so this Permit is closed.

8.17 Minegar Environmental Systems, Inc. (WMWD Permit No. DS-054)

Minegar Environmental Systems, Inc. is a company that provides a service to collect and haul concrete washout water from various job sites. Minegar generates wastewater from the washing of concrete trucks, as well as their fins and chutes. This company is now closed.

8.7.4 Direct Connections to the SARI

8.7.4.1 Aqua Mansa Power Plant (aka as EI Colton, LLC) (SBVMWD Permit No. 4E-03-S53) Aqua Mansa Power Plant is a 48-megawatt (MW) electrical generating facility comprised of a single natural gas-fired LM 6000 aeroderivative combustion turbine operating in a simple cycle mode. Aqua Mansa Power Plant is permitted to discharge RO reject water, filter backwash, spent evaporative cooling water and the clarified wastewater from the oil/grease separator. All turbine wash water is contained in the waste wash water tank and disposed of properly. Aqua Mansa began discharging in May of 2003.

8.7.4.2 Arlington Basin Desalter Facility (WMWD Permit No. 4B-93-S22)

Western Municipal Water District and Orange County Water District, member agencies of SAWPA, in cooperation with the Metropolitan Water District of Southern California and the State of California Water Resources Control Board constructed the Arlington Basin Desalter Plant. It was designed to accomplish four objectives:

1. Reduce salts entering the Santa Ana River,

2. Provide a clean water supply,

3. Restore the groundwater in the Arlington Basin to a usable condition, and

4. Restore the condition of the Arlington Basin for future water storage.

The plant is supplied with brackish water from five wells placed along Magnolia Avenue in Arlington. The brackish water (1,100 mg/L total dissolved solids, 90 mg/L nitrate) is converted to a potable water quality using reverse osmosis technology. The plant has capacity to produce 6 MGD of potable water with brine reject water of approximately 1.35 MGD discharging to SARI. During this reporting period (FY2009/10), brine reject water was 395.15 MG for an average daily brine discharge of 1.08 MGD at approximately 5,300 mg/L TDS. The desalter’s treated water augments the City of Norco’s potable water supply.

8.7.4.3 California Institution for Women (IEUA Permit No. 4D-95-S26)

California Institution for Women, Chino (CIW) is a state correctional facility for women. Wastewater is generated from water softener regeneration backwash, boiler blowdown, vehicle washing, print shop, medical and dental clinic, kitchen, and various domestic sewer connections throughout the facility.

This facility is located in IEUA’s service area and is currently being inspected by IEUA. The current SAWPA permit expired on December 30, 2007. IEUA is issuing the Industrial User Permit to CIW under a SAWPA/IEUA Multijurisdictional Pretreatment Agreement.

8.7.4.4 California Rehabilitation Center (WMWD Permit No. 4B-94-S19)

California Rehabilitation Center (CRC) is a state correction facility for men and women. Wastewater is generated from water softener regeneration backwash, boiler blowdown, print shop, medical and dental clinic, kitchen, and various domestic sewer connections throughout the facility.

Enforcement Action

8.18 On December 4, 2006, SAWPA Pretreatment Representatives met CRC personnel to inform them of some issues that were found to be violations. CRC was issued a Consent Order with Compliance Schedules to correct the following: 1. CRC’s A-5 kitchen will be required to install oil/grease interceptor. a. The oil/grease interceptor has been installed and is in operation as required. 2.. The main kitchen washdown and clean-up procedures. a. A new SOP for the washdown and clean-up procedures has been developed and implemented. All floor drains have secured screens installed and waste oil from the kitchen is contained in barrels and hauled off as required. A new 10,000-gallon oil/grease interceptor was scheduled to be installed as soon as funds are approved. The oil/grease interceptor has been resized to a 5,000-gallon interceptor. 3. Bar screen requirements at their connection to the SARI Line. a. CRC has submitted a request to the State of California for Capital Improvement funds to install a bar screen system for their discharge to the SARI Line. CRC has requested an extension to completion date of this project due to the CIP approval process of the State of California. The extension has been granted.

The October 1, 2009, Progress Report submitted by CRC stated that negotiations between the City of Norco, the Navy, and CRC will soon be ending. The Report states the City of Norco will be assuming the responsibility of the discharge from CRC and the installation of a muffin monster (bar screen). In addition the Progress Report states that as of July 1, 2009, the replacement or repair to the main kitchen oil/grease interceptor has been deferred due to budgetary constraints.

These two issues have languished in an unacceptable state for over two years without satisfactory completion. Further, SAWPA has no evidence of an imminent agreement that will transfer this problem, in part to the City of Norco. SAWPA can no longer allow these Consent Order issues to continue to be unresolved.

On November 19, 2009, SAWPA issued a Compliance Order and Compliance Order Schedules for the bar screen requirements, and repair or replacement of the main kitchen oil/grease interceptor.

Failure to comply with this Compliance Order shall constitute a violation of Ordinance No. 5, CRC’s Direct User Permit and this Compliance Order and may result in Civil Penalties being imposed.

On December 14, 2009, SAWPA received a Progress Report as required by the Compliance Order from CRC on the installation of the bar screen and repairs or replacement of the main kitchen grease interceptor. SAWPA reviewed this Progress Report and found it to be inadequate.

On December 29, 2009, SAWPA responded to the Progress Report requiring CRC to show progress and compliance with the milestone dates contained in the Compliance Order. Failure to show progress and compliance with the milestone dates will result in CRC being found to be in Significant Noncompliance (SNC) and possibly assessed civil penalties.

On January 13, 2010, SAWPA received a Progress Report as required by the Compliance Order from CRC on the installation of the bar screen and repair or replacement of the main kitchen oil/grease interceptor. In the progress report CRC reported that if SAWPA had any inquiries as to the progress of the installation of the bar screen to contact the City of Norco. CRC states that the award of a contract had gone to Inmate Labor and they expected the repairs or replacement of the main kitchen oil/grease interceptor to be completed at the end of January 2010.

On February 3, 2010, SAWPA received a letter from the City of Norco’s Public Works Director stating that the City of Norco had recently completed an execution of a Memorandum of Agreement (MOA) with the California Department of Corrections and Rehabilitation (CDCRC). A condition of the MOA was to transfer the CRC waste stream from the SARI into the City of Norco collection system which included the design, construction, operation and maintenance of a bar screen and/or

8.19 grinders.

The City of Norco stated they were not aware of the Compliance Order issued to CRC and that they would like to request an extension or modification of the Compliance Order to allow the parties the opportunity to develop a schedule and complete the infrastructure to permanently shift the CRC waste stream from the SARI system.

On February 4, 2010, SAWPA learned during a conference call with The Department of Corrections that CRC was entering into an MOA with the City of Norco and that the City of Norco would fund and construct bar screen when CRC’s waste stream is diverted. SAWPA informed CRC that they must follow the current Compliance Order requirements and if an extension is needed then CRC needs to request the extension.

On February 8, 2010, SAWPA sent a letter to CRC reiterating the requirements of the Compliance Order issued November 19, 2009 and memorializing the conference call on February 4, 2010.

On February 11, 2010, SAWPA received a letter from CRC requesting a ninety (90)-day extension for construction of the bar screen. Also provided were copies of CRC’s letter to the City of Norco requesting assistance in complying with the Compliance Order and a signed copy of the MOA was provided.

On February 22, 2010, SAWPA responded to CRC’s request for an extension with new milestone compliance dates. SAWPA granted this request. The first milestone compliance date was May 2, 2010. CRC was to submit plans detailing the type of system to be installed for the removal of solids, rags, towels etc., prior to being discharged to the SARI line.

SAWPA received a copy of a letter from CRC to the City of Norco dated March 26, 2010 confirming the City’s responsibility concerning the wastewater improvements associated with the MOA.

On April 21, 2010, an inspection was conducted at CRC and during inspection of the main kitchen it was verified that the oil/grease interceptor had been replaced as required.

On May 10, 2010, SAWPA sent a letter informing CRC that the first milestone of the modified Compliance Order had not been met and they would be issuing a Civil Penalty Order. The Civil Penalties are to be $3,000.00 each day from May 3, 2010 until CRC submits plans as required.

On May 17, 2010, SAWPA received the plans as required in the Compliance Order issued February 22, 2010.

On June 24, 2010, SAWPA issued a Civil Penalty for failure to meet the Compliance Order milestone of May 2, 2010. The Civil Penalty assessed was for $42,000.00 for the period of May 3, 2010 to May 16, 2010.

8.7.4.5 Chino I Desalter Facility (IEUA Permit No. 4D-00-S34)

During the second half of FY 1999/00, SAWPA completed the construction of the Chino I Desalter Facility. The Chino I Desalter was designed to accomplish the following objectives:

1. To provide a safe and dependable potable water supply source for local urban users,

2. To mitigate high TDS and nitrate levels in the local groundwater from many years of dairy farming in the area, and

3. To clean groundwater that ultimately makes its way to the Santa Ana River and augments Orange County’s water supply.

8.20 Ownership of the plant was transferred from SAWPA to the Chino Basin Desalter Authority (CDA) in early 2002.

The Chino Basin Authority expanded the Chino I Desalter to include an ion exchange treatment system, VOC removal tower, onsite Sodium Hypochlorite generation system. The addition of these new systems increased the daily discharge into the SARI Line by 0.3 MGD, from 1.7 MGD to 2.0 MGD.

The plant is supplied with brackish water from eleven (11) wells in the local area. The brackish water is converted to a potable water quality using reverse osmosis technology. The plant has capacity to produce 8 MGD of potable water with brine reject water of approximately 2.0 MGD discharging to SARI. The potable water produced augments supplies for four cities; Chino Hills, Chino, Norco, and Ontario, and Jurupa Community Services District.

During this reporting period (July 1, 2009 to June 30, 2010), brine reject water was 756.30 MG for an average daily brine discharge of 2.07 MGD at approximately 6,580 mg/L TDS.

This facility is located in IEUA’s service area and currently is inspected and permitted by IEUA.

8.7.4.6 Chino II Desalter Facility (SAWPA Permit No. 4D-06-S57)

The Chino II Desalter was designed to accomplish the following objectives:

1. To provide a safe and dependable potable water supply source for local urban users

2. To mitigate high TDS and nitrate levels in the local groundwater from many years of dairy farming in the area, and

3. To clean groundwater that ultimately makes its way to the Santa Ana River and augments Orange County’s water supply

The plant is supplied with brackish water from 9 wells in the local area. The brackish water is converted to a potable water quality using reverse osmosis technology. The plant has capacity to produce an average of 10 MGD and a maximum of 15 MGD of potable water with brine reject water of approximately 1.5 MGD at the Harrel Ave. connection and 0.2 at the Wineville Ave. connection that discharge to the SARI. The potable water produced augments supplies for three cities (Chino Hills, Chino, and Norco) and the Jurupa Community Services District.

During this reporting period (July 1, 2009, to June 30, 2010), brine reject water was 448.74 MG at the Etiwanda Ave. connection, for an average daily brine discharge of 1.21 MGD at approximately 3,150 mg/L of TDS. At the Wineville Ave. connection for this period the brine reject water was 24.94 MG, for an average daily brine discharge of 0.066 MGD at approximately 15,275 mg/L of TDS.

8.7.4.7 City of Corona – Temescal Desalter (WMWD Permit No. 4B-00-S32)

The City of Corona Temescal Desalter began operation in September 2001. It was designed to accomplish the following objectives:

1. To provide a safe and dependable potable water supply source for local urban users.

2. To mitigate high TDS and nitrate levels in the local groundwater, and

3. To clean groundwater that ultimately makes it way to the Santa Ana River and augments Orange County’s water supply.

During this reporting period (July 1, 2009 to June 30, 2010), brine reject water was 632.3 MG, for an average daily brine discharge of 1.705 MGD at approximately 5,925 mg/L of TDS.

8.21 8.7.4.8 Corona Energy Partners (WMWD Permit No. 4B-93-S20)

Corona Energy Partners (CEP) is a co-generation power plant that produces electrical power and steam. CEP discharges cooling tower blow-down, boiler blow-down, and demineralization unit regenerate wastewater to SARI at approximately 0.100 MGD.

8.7.4.9 Dairy Farmers of America (DFA) (WMWD Permit No. 4B-08-S62)

Dairy Farmers of America distilled water-plant produces distilled water.

The wastewater is generated from the RO brine blow-down, cooling tower blow-down, the clean–in–place procedures used to clean the distilled water plant and wash-down water with a maximum permitted flow of 400,000 gallons per day.

8.7.4.10 Eastern Municipal Water District, Master Meter (SAWPA Permit No. 5-02- S47)

Eastern Municipal Water District, Master Meter began operation in September 2002. Sources of discharges metered at this connection include discharges from EMWD’s Menifee Desalter, Perris Desalter, Inland Empire Energy Center, 3 Emergency Discharge Permits and EMWD’s Truck Disposal Station.

Menifee Desalter (EMWD Permit # 532)

The Eastern Municipal Water District, Menifee Desalter began operation in November 2001. The desalter has an estimated capacity to discharge 1.2 MGD. It was designed to accomplish the following objectives:

1. To provide a safe and dependable potable water supply source for local urban users

2. To mitigate high TDS and nitrate levels in the local groundwater, and

3. To clean groundwater that ultimately makes its way to the Santa Ana River and augments Orange County’s water supply

During this reporting period (July 1, 2009 through June 30, 2010) brine reject water was 338.69 MG, for an average daily brine discharge of 0.85 MGD at approximately 6,645 mg/L of TDS.

Perris Desalter (EMWD Permit # 542)

The Eastern Municipal Water District, Perris Desalter began operation in September 2005. The desalter has an estimated capacity to discharge 2.4 MGD. It was designed to accomplish the following objectives:

1. To provide a safe and dependable potable water supply source for local urban users.

2. To mitigate high TDS and nitrate levels in the local groundwater, and

To clean groundwater that ultimately makes its way to the Santa Ana River and augments Orange County’s water supply.

During this reporting period (July 1, 2009 through June 30, 2010) brine reject water was 261.13 MG, for an average daily brine discharge of 0.72 MGD at approximately 5,780 mg/L of TDS. Inland Empire Energy Center (EMWD Permit # 554)

8.22 Inland Empire Energy Center is a power plant and is classified as a Categorical Industrial User (CIU), Stem Electric power Generating, 40 CFR, Part 423.17, PSNS.

The wastewater generated at this facility is from cooling tower and boiler blowdown, with a maximum of 1.2 MGD.

8.7.4.11 EMWD Menifee Valley Trucked Waste Disposal Facility (EMWD Permit # 552)

This truck disposal station provides a brine disposal location for facilities located in EMWD’s service area. The wastewater hauled to the Trucked Waste Disposal Station is from the concrete washout water process. See Section 8.9 for further information.

8.7.4.12 EnerTech Rialto Regional Biosolids Processing Facility (SBVMWD Permit 4E-07-S62)

The EnerTech Rialto Regional Biosolids Processing Facility will process up to 750 tons per day of municipal biosolids, converting it into ―E-Fuel‖ using the SlurryCarbTM process. This process is a proprietary and confidential process and converts biosolids in a heated and pressurized reactor to SlurrySol, an energy rich fuel.

The wastewater generated at the EnerTech Rialto Regional Biosolids Processing Facility is from the centrifuge centrate, cooling tower blowdown, dryer scrubber and SOx scrubber blowdown. This facility wastewater treatment system consists of a high rate anaerobic system (HRAS) followed by a conventional activated sludge process treatment system.

The wastewater treated at the EnerTech Rialto Regional Biosolids Processing Facility will be discharged to the SARI system through a monitoring manhole, which contains a magnetic flow meter for flow measurement. The maximum flow permitted to be discharged is 220,000 gallons per day.

8.23 Enforcement Action:

A Notice of Violation (NOV) was issued on March 6, 2009 for exceeding permitted values for BOD and TSS. The facility was required to pay for exceeding the BOD and TSS limits in addition to identifying the cause and developing a plan to prevent any additional violations.

On 7/22/09 SBVMWD issued NOVs for violating discharge limits for TSS on 5/15/09, 6/5/09 and 6/24/09. The facility was required to submit a written response detailing the cause and what corrective actions would be taken to prevent additions TSS violations. On 7/31/09 EnerTech submitted a written response to NOV issued on 7/22/09 detailing actions to prevent TSS violations.

On 8/12/09, a pH violation was detected and the facility was ordered to cease their discharge until the pH problem could be resolved. An NOV was issued on 8/19/10 for a pH violation of 8/12/09. A Compliance Order was issued requiring EnerTech to install a pH alarm and control system to prevent any further pH violations. EnerTech completed the installation of the pH alarm and control system as required on 11/10/09.

An NOV was issued on 9/30/09 for BOD violations on 7/7/09, 7/16/09, 7/28/09, 8/4/09, 8/12/09, and 9/9/09. EnerTech was required to submit a written response detailing the cause and describing what corrective actions would be implemented to prevent further BOD violations. On 10/12/09 EnerTech submitted a written response to the NOV detailing actions to prevent further BOD violations.

On 12/21/09, SBVMWD responded to an SSO at EnerTech’s lateral connection to the SARI Line. EnerTech was ordered to clean up the spill and area impacted by the spill. During the investigation of the spill it was noted that a sludge-like material was being discharged and settling out in the SARI Line. In addition SAWPA was receiving odor complaints at various locations downstream of EnerTech’s connection.

On 12/22/09, SBVMWD issued a Cease and Desist Order until EnerTech can demonstrate compliance with its discharge permit and Ordinance No. 5.

On 12/23/09 SBVMWD received a letter from EnerTech outlining the actions EnerTech would be taking to comply with the cleanup and reporting requirements and to bring their discharge into compliance and comply with their discharge limit of 220,000 GPD.

On 12/28/09 SBVMWD responded to EnerTech’s e-mail request on 12/28/09 to allow EnerTech to discharge in the dryer-only operation. This request was denied until EnerTech submits the plans to achieve compliance as mentioned in their letter dated 12/23/09.

On 12/31/09 SBVMWD issued an NOV for a copper violation on 12/5/09, an NOV for a flow violation and for implementing process changes prior to notifying SBVMWD and being approved.

On 1/13/10 EnerTech submitted an engineering report summarizing the plant modifications and operational plans to achieve compliance and be allowed to discharge in the dryer-only operation.

On 1/28/10 SBVMWD received EnerTech’s response to the NOVs issued on 12/31/09.

On 2/1/10 SBVMWD received a request from EnerTech to make modifications to the existing wastewater treatment system. The modifications requested are to allow EnerTech to further reduce the solids and BOD5 in the effluent discharged to the SARI.

8.24 On 2/26/10 SBVMWD issued an amended Direct Discharge Permit to EnerTech from 2/26/10 to 8/26/10 for a dryer-only operation and to include the modifications requested on 2/1/10.

On 3/6/10 EnerTech notified SBVMWD an unapproved Baker Tank had been discharged to the SARI Line.

On 3/8/10 SBVMWD received a written notification of the unapproved Baker Tank discharge and the corrective actions taken to prevent this from happening again.

On 3/15/10 SBVMWD issued an NOV for the discharge of an unapproved Baker Tank to the SARI Line on 3/6/10.

On 3/21/10 SBVMWD issued an NOV for a TSS violation on 3/5/10-3/6/10.

On 6/28/10 SBVMWD issued NOVs for two (2) TSS and six (6) BOD violations for the month of April 2010 and seven (7) BOD violations during the month of May 2010.

8.7.4.13 Green River Golf Club (IEUA Permit No. 4-94-S25)

Green River Golf Club is connected to SARI at the golf course clubhouse. Discharge is from a combination of restrooms/showers and food services. A sand-oil separator at the golf cart wash area discharges onto a portion of the golf course as an irrigation source.

During the previous permit renewal application, GR was maintaining a Parshall flume to measure the discharge of wastewater to the SARI. However, due to the nature (sanitary) of the majority of GR’s wastewater, accuracy of the Parshall flume came into question. Due to this fact, on March 18, 2010, the flow monitoring requirements in GR’s permit were revised to utilize 100% of the incoming water meter flow. The incoming water meter is located outside of the kitchen on the west side of the Clubhouse.

8.7.4.14 Inland Empire Utilities Agency (SAWPA Permit No. 4A-93-S05)

Inland Empire Utilities Agency (IEUA) discharges non-reclaimable industrial wastewater and domestic wastewater to the SARI System. The sample location for this connection is located at the Mission Linen facility. The manhole is located in a landscape island where the loading dock area meets the asphalt of the employee parking area. There are fourteen (14) industries that discharge to the SARI System either by a direct connection or by truck hauling. IEUA monitors these companies for all conventional and priority pollutants. Quarterly and annual reports are submitted to SAWPA. The direct connect SIUs are as follows:

Mission Uniform and Linen Services Permit # SSP013 is an industrial laundry, which processes shirts, pants, uniforms, shop towels, floor mats, bed linens, bath towels, and tablecloths. The wastewater effluent to SARI is generated from laundry process water softener regenerate, and boiler blowdown. Approximate flow to SARI is 186,860 GPD.

Enforcement Action:

Oil/Grease violation on 8/13/09. Letter of Violation issued on 9/2/09.

On 9/16/09 Mission Linen Supply responded in a letter indicating that they were getting some carry over from their clarifier. This was corrected by slowing down the treatment system. A resample was taken which indicated compliance.

OLS Energy Permit # C-87-002-A generates electricity and steam for the California Institution for Men within which OLS is located. The wastewater effluent to SARI is generated from demineralization, boiler blowdown, and floor washdown. Approximate flow to SARI is 64,702 GPD.

8.25 California Institution for Men (CIM) Permit #SSP008 is a state correctional facility for men. The wastewater effluent to SARI is generated from water softener regenerate; all other wastewater generated is treated at the facility’s on-site wastewater treatment plant and discharge to the sewer system or used for land irrigation. Approximate flow to SARI is 56,766 GPD.

Enforcement Action:

Failure to Monitor Pollutants (BOD5), issued a Deficiency Notice 8/20/09.

CIM conducted a sampling event for BOD as required.

2/10/10 failure to report updated contingency plan and 24-hour emergency contact phone list. Issued Written Notice of Violation

City of Chino Hills-Fairfield Ranch Water Well No. 5 Permit #SSP016 Nitrate Removal Facility will discharge brine wastewater to the SARI. The operation of the facility has not been approved by DHS and there is no discharge to SARI at this time. The approximate flow to the SARI will be around 43,000 GPD when the facility begins discharging.

Enforcement Action:

Failure to report (24-hour emergency contact List and contingency plan). Verbal warning issued on 1/31/10. Report received 2/10/10.

Failure to Report (flow report). Late Notice issued on 4/8/10. Report received 4/9/10.

8.7.4.15 Inland Empire Utilities Agency (IEUA) Trucked Wastewater Disposal Facility (IEUA Permit NO. SSP027)

IEUA’s truck disposal station is located at 16400 El Prado Road, Chino, CA 91710. This truck disposal station provides a brine disposal location for facilities in IEUA’s service area.

IEUA permits nine (9) industrial users to haul wastewater to the SAWPA approved truck disposal station located in IEUA’s service area at 16400 El Prado Road, Chino CA. For FY2009/10 IEUA received 8.0832 million gallons (MG) at IEUA’s truck disposal station, with an approximate average of 22,329 GPD. For more information see Section 8.9.

8.7.4.16 Jurupa Community Services District, Celebration Dr. Metering Station (WMWD Permit No. 4D-03-S54)

This connection has no IUs or commercial facilities and consists of 733 apartments and 244 residential homes. The flow to this connection is permitted at .01 MGD. Only domestic wastewater from apartments and residential homes is generated and discharged through this connection. A new local sewer system is planned and will direct the flow from this connection to the WRCRWRP. Flow is approximately 72,885 GPD.

8.7.4.17 Jurupa Community Services District, Etiwanda Connection (WMWD Permit No. 4D-98-S28)

The Jurupa Community Services District (JCSD) connection to the SARI discharges non-reclaimable industrial wastewater and domestic wastewater to the SARI System. The discharge is monitored at the connection to SARI on Etiwanda Avenue. There are four SIUs located upstream from the SARI connection, which are permitted by JCSD. Additional flow to this connection is generated from a small number of commercial warehouses as domestic wastewater. JCSD monitors these companies for all conventional and priority pollutants. Flow is approximately 400,000 GPD. Quarterly and annual reports are submitted to SAWPA. The significant industrial users (SIUs) are:

8.26 Metal Container Corporation, (JCSD Permit #SARI-EMS-100) is an aluminum can manufacturer. The wastewater effluent to SARI is generated from can washer blowdown, oil splitter supernatant, water conditioning brines, cooling tower blowdown and boiler blowdown. Approximate flow to SARI is 173,674 GPD.

W.G.E. Company, (JCSD Permit #SARI-EMS-401) is a garlic powder manufacturer. The wastewater effluent to SARI is generated from garlic wash waste, distillation waste alcohol, and water conditioning brines. Approximate flow to SARI is 6,100 GPD.

Lynam Industries, (JCSD Permit #SARI-EMS-600) is a manufacturer of telecommunication products made from sheet metal (primarily ―rack rail‖). Production processes include metal forming, punching, threading and welding. This user is classified as a dry categorical. Flow to SARI is 0 GPD.

JCSD IXP – Roger D. Teagarden Ion Exchange Water Treatment Plant, (JCSD Permit #SARI- EMS-500) is a potable water treatment plant that utilizes ion exchange technology to remove nitrates from well water for delivery to JCSD’s customers. The IXP currently has capacity to treat up to 6 million gallons per day (MGD) and is undergoing an expansion to treat 16 MGD. wastewater is discharged from the nitrate and water softener vessel regeneration processes and from automatic nitrate and chlorine residual analyzers. Approximate flow to SARI is 60,000 GPD.

Del Real Foods, (JCSD Permit # SARI-EMS-600) is engaged in the business of preparing beef, pork, chicken, rice and beans for sale as ready-to-eat meals. Raw meat products are also prepared for sale in retail meat departments. A 2,000-gallon grease interceptor serves the raw meat processing area, kettle room, deep frying area and wash down room. A 1,000-gallon grease interceptor serves the cooked meat and packaging area and the contact cooling area. After passing through the interceptors, the waste flows to a flow equalization tank and then to a Dissolved Air Flotation system to remove oil and grease. The installation of the equalization tank and DAF fulfilled the requirements of the previous enforcement actions, up to the Consent Order. The IU is no longer under enforcement action. Discharges from the cooling tower, emergency ammonia dump, boiler and air compressor pass through an interceptors. Approximate flow to SARI is 27,367 GPD.

8.7.4.18 Jurupa Community Services District, Hamner Connection (WMWD Permit No. 4D-95-S24)

The JCSD connection to SARI at Hamner Avenue has no significant industrial users (SIUs). The flow to this connection is generated from a small number of commercial warehouses, a church, and a restaurant as domestic wastewater. Flow is approximately 52,000 GPD.

8.7.4.19 Jurupa Community Services District, Wineville Connection (WMWD Permit No. 4D-98-S23)

Jurupa Community Services District (JCSD) discharges non-reclaimable industrial wastewater and domestic wastewater to the SARI System. The discharge is monitored at the connection to SARI on Wineville Avenue. There is one SIU located upstream from the SARI connection, which is permitted by JCSD. Additional flow to this connection is generated from a small number of commercial warehouses as domestic wastewater. JCSD monitors this company for all conventional and priority pollutants. Quarterly and annual reports are submitted to SAWPA. Flow is approximately 90,000 GPD. The significant industrial user (SIU) is:

Adesa Los Angeles (JCSD Permit No. SARI-WMS-100) is an automobile reconditioning and wholesale auction facility. The wastewater effluent to SARI is generated from an automated car wash, maintenance shop, wet sanding, laundry, and cafeteria wastes. Approximate flow to the SARI is 11,989 GPD.

8.27

8.7.4.20 Mountainview Power Company, LLC (SBVMWD Permit No 4E-00-S35) Categorical IU 40 CFR Part 423.17, PSNS Steam Electric Power Generating

Mountainview Power Company located in Redlands is currently in the process of commissioning its cooling towers and will be in operation by the end of 2005. Electricity is generated from steam driven turbines and natural gas fired turbines. Boilers fired by natural gas will produce the steam. Wastewater is generated from cooling tower blowdown and process wastewater from equipment cleaning. Pretreatment consists of chemical precipitation, chlorination, filtration, and pH adjustment prior to discharging to the SARI Line. The facility is designed to generate 1,150 MW of electricity per day and is permitted to discharge up to 0.298 MGD of wastewater to the SARI Line.

8.7.4.21 Rubidoux Community Services District (WMWD Permit No. 4D-96-S29)

Rubidoux Community Services District (RCSD) has one connection to SARI that discharges brine waste from RCSD’s nitrate removal wellhead treatment plant (Anita B. Smith Water Treatment Facility). The treatment process utilizes an ion exchange for nitrate removal.

8.7.4.22 San Bernardino Valley Municipal Water District Water (Valley) Reclamation Plant SARI Truck Disposal Station (SBVMWD Permit No. 4E-04-S56)

Valley’s truck disposal station is located at the City of San Bernardino’s Water Reclamation Plant SARI connection located in Reach IV of the SARI System. This truck disposal station provides a brine disposal location for facilities in Valley’s service area.

Nineteen (19) Industrial Users are permitted to haul brine wastewater to the truck disposal station. No septic waste is accepted at the truck disposal station. The pH of each load is tested prior to discharge and must be between 6.0 and 12.0 units to be accepted. For the period July 1, 2009 through June 30, 2010, a total of 4.44 MG was received at the truck disposal station, with a daily average of 12,649 GPD. For more Information see Section 8.9.

8.7.4.23 San Bernardino Valley Municipal Water District Water Reclamation Plant SARI Connection (Permit No. 4E-05-S57)

San Bernardino Valley Municipal Water Department is a Municipal Water Department responsible for the implementation of the pretreatment program for the industries connected to their sewerage system. The wastewater discharged to the SARI line will only occur under extreme conditions in the event the offsite Rapid Infiltration and Extraction Facility is unable to process the incoming volume of wastewater.

8.7.4.24 SAWPA Truck Disposal Stations

Currently, there are four (4) SAWPA approved truck disposal stations and they are located in each of the following service areas: EMWD, IEUA, SBVMWD and WMWD. Each of these Truck Disposal Stations is identified in Part 8.6.1 of this report.

8.7.4.25 Stringfellow Pretreatment Facility – Cleanup and Abatement Monitoring (WMWD Permit No. 4D-98-S101)

The Stringfellow site is in the SAWPA service area and was used as a hazardous waste landfill from 1956 to 1972. During that period, approximately 34 MG of liquid industrial waste was deposited at the site. Included in this waste were acids, caustics, solvents, pesticides, cyanides, and metal compounds. The site closed

8.28 when liquid waste was apparently percolating from the waste pits and contaminating underlying soil and groundwater.

The contaminated groundwater is pumped to treatment units that remove the metals and organics. The treated water is then discharged to SARI. OCSD’s industrial waste inspectors visit monthly and review the Stringfellow logbooks, which show sample data. Sampling by SAWPA and analysis by a certified laboratory has confirmed that the discharge consistently meets the limit required by the discharge permit. The laboratory analyses are reviewed by SAWPA staff and data is recorded regarding constituent sample results and operational changes.

The on-site treatment plant processed and discharged a total of 38.367 MG during FY2009/10. Discharge volume and analytical data are shown in Table 8.7.

8.29

TABLE 8.7 Average Heavy Metal Discharge Concentrations and Treated Monthly Flows at the Stringfellow Cleanup Site, as Reported by the Santa Ana Watershed Project Authority (SAWPA), Fiscal Year 2009-10. Orange County Sanitation District, Source Control Division Discharge Constituent Concentrations (mg/L)* Total Discharge Cyanide Toxic Date Gallons Arsenic Cadmium Chromium Copper Lead Mercury Nickel Silver Zinc (Total) Organics

2009 July 3,622,838 ND ND ND ND ND ND ND ND ND ND 0.0005 August 2,929,104 ND ND ND ND ND ND ND ND ND ND ND September 3,106,752 ND 0.0017 ND ND ND ND 0.0346 ND 0.0046 ND 0.0004 October 3,287,371 ND 0.0006 ND ND ND ND 0.0177 ND ND ND 0.0028 November 3,008,857 ND 0.0012 ND ND ND ND 0.0347 ND 0.0145 ND 0.0002 December 3,187,631 ND 0.0017 ND ND ND ND 0.0322 ND 0.0062 ND 0.0023 2010 January 3,147,507 ND 0.00075 ND ND ND ND 0.0315 ND 0.0065 ND 0.0028 February 2,933,286 ND 0.00315 ND ND ND ND 0.0145 ND 0.0072 ND 0.0012 March 3,339,103 ND 0.00266 ND ND ND ND 0.0352 ND ND ND ND April 3,255,310 ND 0.00310 ND ND ND ND 0.0427 ND ND 0.5 ND May 3,408,524 ND 0.00220 ND ND ND ND 0.0362 ND ND ND ND June 3,140,537 ND 0.00392 ND ND ND ND 0.0496 ND ND ND ND

Summary Flow (gal) Average concentration (mg/L)

2009-10 38,366,820 ND 0.0018 ND ND ND ND 0.0297 ND 0.0033 0.0417 0.0009 2008-09 33,459,555 ND 0.0014 ND ND ND ND 0.0300 ND 0.0014 ND 0.0033 2007-08 41,358,321 0.0001 0.0005 0.0003 ND ND ND 0.0057 ND 0.0027 ND 0.0395 2006-07 41,984,020 0.0013 0.0016 ND ND ND ND 0.0207 ND 0.0030 0.0068 0.0150 2005-06 51,235,700 0.0020 0.0030 0.0005 ND ND ND 0.0319 ND 0.0055 ND 0.0138 Permit Discharge Not applicable 2.000 0.064 2.000 3.000 0.580 0.030 3.510 0.430 0.700 1.200 0.580 Limitation** ND = Not Detectable * This represents the average of all samples taken during the month. ** These values represent the discharge limits that must be achieved by the Stringfellow site in accordance with their discharge permit issued by SAWPA to California Department of Toxic Substances Control.

8.30 8.7.4.26 WMWD’s SAWPA Approved Truck Disposal Station (SAWPA Permit No. 4B-06-S60)

This truck disposal station located at the City of Corona’s Waste Water Treatment Plant No. 1 at 2205 Railroad St. began operations in April 2007.

Twenty-two (22) industrial users are permitted to haul wastewater to the truck disposal station. No septic waste is accepted at the truck disposal station. The pH of each load is tested prior to discharge and must be between 6.0 and 12.0 units to be accepted. For the period July 1, 2009 through June 30, 2010, a total of 19.47 MG was received at the truck disposal station, with a daily average of 47,863 GPD. A rotating quarterly sampling schedule is followed. Loads from categorical industrial users are sampled more frequently than loads from facilities discharging water softener regenerate. See Section 8.9 for more Information.

8.8 DIRECT SARI CONNECTIONS - TEMPORARY/EMERGENCY

8.8.1 Eastern Municipal Water District Temporary/Emergency Permits

Perris and Moreno Valley Line (EMWD Permit #545).

Permit issued by EMWD to allow emergency discharge to the SARI Line for emergency situations only (example; Reach 4 Recycled Water Dewatering). During the reporting period, there were no emergency discharges to the SARI.

Regional Reclaim Facility – Perris and Moreno Valley (EMWD Permit #550).

Permit issued by EMWD to allow emergency discharge to the SARI line. The wastewater discharged to the SARI line will only be made to relieve storage capacity problems or when the recycled water is off-spec due to high/low pH and/or chlorine residual. Maximum discharge is 3,000,000 GPD. The discharge must meet all discharge limits to the SARI Line.

Sun City Lift Station EMWD (Permit # 544).

Permit issued by EMWD to allow emergency discharge to the SARI Line for emergency situations only (example; raw sewage, brine and failure of a clarifier, etc.).

8.8.2 Inland Empire Utilities Agency Temporary/Emergency Permits

Inland Empire Utilities Agency (Permit No. 4A-05-SP58)

This is a temporary permit to discharge up to 1,000,000 gallons of run-off wastewater that accumulates in an equalization pond at the Regional Wastewater Treatment Plant No. 2 of the Inland Empire Utilities Agency. During this reporting period, there were no discharges to the SARI under this permit.

8.8.3 Western Municipal Water District Temporary/Emergency Permits

City of Corona - Wastewater Treatment Plant No.1 (WMWD Permit No. 4B- 06-SP59)

The City of Corona WTP connection to the SARI line is currently inactive. This permit is for emergency situations only. The City of Corona is not permitted to discharge any wastewater or the contents of any process tanks to the SARI Connection, at any time, without previously notifying SAWPA personnel of the proposed discharge. The City of Corona has scheduled to perform

8.31 maintenance and repairs to their Wastewater Treatment Plant No. 1 sometime in 2008. The City of Corona has entered into an Agreement with WRCRWA to divert up to 3.5 MGD of secondary treated wastewater to WRCRWA’s treatment plant. The City of Corona as part of their contingency plan has asked to divert this flow to the SARI in an emergency situation. A permit has been issued for this temporary discharge, should it be necessary.

City of Corona - Green River area (WMWD Permit No. 4B- 93-S12)

The City of Corona continues to route domestic wastewater from the Green River area to the Corona WWTP. The SARI connection remains in standby in case of an emergency. This is a domestic connection to the SARI System servicing four restaurants, two gasoline stations, a mobile home park, and two residential subdivision areas at the eastern end of Green River Canyon. As of 12/11/03, this connection no longer discharges to the SARI Line. All flows are now pumped to the City of Corona’s WWTP #1. The Permit will remain current in the event of emergency and the pump station is by-passed to the SARI Line. SAWPA/WMWD shall be notified when the by-pass occurs. The City has been required to install a permanent device that will prevent an accidental unauthorized discharge into the SARI system.

Jurupa Community Services District, Archibald Metering Station Connection (WMWD Permit No. 4D-04-S55)

This connection has no SIUs and is proposed for residential sewage disposal of 495 homes. Only domestic wastewater from the housing subdivision is generated. Discharge from this connection began in May 2004. This connection is currently inactive and the domestic flow was diverted to the WRCRWRP as of 3/22/07. This permit is for emergency situations only. JCSD is not permitted to discharge any wastewater to this SARI connection, at any time, without previously notifying WMWD personnel within 24 hours of the proposed discharge.

Jurupa Community Services District, Chandler Connection (WMWD Permit No. 4D-01-S36)

This connection has no SIUs and consists of tract residential homes. Only domestic wastewater is generated from this connection. This connection is currently inactive and the domestic flow was diverted to the WRCRWRP as of 3/22/07. This permit is for emergency situations only. JCSD is not permitted to discharge any wastewater to this SARI connection, at any time, without previously notifying WMWD personnel within 24 hours of the proposed discharge.

Jurupa Community Services District, Cleveland Connection (WMWD Permit No. 4D-00-S21)

The Jurupa Community Services District (JCSD) connection to SARI at Cleveland Road has no SIUs. This connection is currently inactive and the domestic flow was diverted to the WRCRWRP as of 3/29/07. This permit is for emergency situations only. JCSD is not permitted to discharge any wastewater to this SARI connection, at any time, without previously notifying WMWD personnel within 24 hours of the proposed discharge.

Jurupa Community Services District, Harrison Connection (WMWD Permit No. 4D-02-S48)

The JCSD connection to SARI at Harrison has no SIUs. The flow to this connection is domestic wastewater generated from residential homes. Initial discharge to the SARI system started in October 2002. This connection is currently inactive and the domestic flow was diverted to the WRCRWRP as of 3/28/07. This permit is for emergency situations only. JCSD is not permitted to discharge any wastewater to this SARI connection, at any time, without previously notifying WMWD personnel within 24 hours of the proposed discharge.

8.32 Jurupa Community Services District, Hamner Lift Station Connection (WMWD Permit No. 4D-02-S49)

The JCSD connection to SARI at Hamner Lift Station has no SIUs. The flow to this connection is domestic wastewater generated from residential homes. Discharge to the SARI system started in December 2002. This connection is currently inactive and the domestic flow was diverted to the WRCRWRP as of 4/20/07. This permit is for emergency situations only. JCSD is not permitted to discharge any wastewater to this SARI connection, at any time, without previously notifying WMWD personnel within 24 hours of the proposed discharge.

Western Riverside County Regional Wastewater Reclamation Plant (WRCRWRP) (WMWD Permit No. 4D-06-S61)

The WRCRWRP was designed and constructed to treat domestic wastewater that was previously discharged to SARI. The treated domestic wastewater can now be reused as a non-potable water supply. The project is expected to develop 8,000 acre-feet of water per year for beneficial use. The WRCRWRP furnishes regional wastewater treatment services to HGSD, City of Corona, City of Norco, JCSD, and WMWD.

The 8-MGD facility includes primary, secondary, and tertiary treatment processes. Approximately 40% to 50% of the facility’s influent is lifted through the South Regional Pump Station. A ―V‖ notch weir and a connection to SARI exist at this lift station as an emergency alternative to divert f low from the plant to SARI if a power outage or other situation were to occur. Western Riverside County Regional Wastewater Authority, a joint powers agency consisting of Norco, HGSD, JCSD, WMWD, and SAWPA, owns the WRCRWRP.

WRCRWRP discharged approximately 14.4 million gallons to the SARI from this lift station from June 8, 2010 through June 12, 2010. The discharge occurred while the County of Riverside was making repairs to the River Road Bridge and had to divert flow to install a new force main.

Enforcement Action:

WRCRWRP had a dissolved sulfide violation of 2.1 mg/L during the discharge period of June 8, 2010 through June 12, 2010. An NOV will be issued.

8.9 INDIRECT PERMITS (HAULED WASTE)

8.9.1 EMWD Menifee Valley Trucked Waste Disposal Facility (EMWD Permit #552)

EMWD permits two (2) industrial users to haul wastewater to the SAWPA approved truck disposal station located in EMWD’s service area at 29541 Murrieta Road, Sun City, CA. For FY2009/10 EMWD received 22.17 million gallons (MG) at EMWD’s truck disposal station, with an approximate average of 60,739 gallons per day (GPD). The two facilities permitted to haul waste brine to the disposal station are:

International Rectifier (Hexfet) (EMWD Permit # 522)

International Rectifier - HEXFET America takes precut silicon wafers and makes semiconductor computer chips, which are used for computer, peripheral, automotive, and cellular telephone applications. Acid etching and solvent etching of the wafers are performed at this location. The acid etching includes the use of hydrofluoric, sulfuric, hydrochloric, nitric, and phosphoric acids. The solvent etching includes the use of xylene and an ethyl lactate base solvent. The wastewater generated from the acid etching process is neutralized and discharged to two 35,000-gallon storage tanks (T-9 and T10) and/or a 39,000-gallon storage tank (T21) or tank (T-303). The contents of the

8.33 storage tanks are hauled offsite to the MVTWDF for disposal. Approximately 59,000 GPD are hauled and discharged to the SARI Line.

Minegar Environmental Systems (EMWD Permit #579)

Concrete hauling trucks wash out their trucks to portable collection tanks at job sites. This water used to be discharged to the ground, but due to storm water regulations, this is no longer allowed. Minegar Environmental Systems pumps out the tanks and transport the water to the MVTWDF. Approximately 2,000 gallons per week are hauled to be discharged to the SARI Line.

8.9.2 Inland Empire Utilities (IEUA) Trucked Waste Disposal Faclity (IEUA) Permit No. SSP027

IEUA permits nine (9) industrial users to haul wastewater to the SAWPA approved truck disposal station located in IEUA’s service area at 16400 El Prado Road, Chino CA. For FY2009/10 IEUA received 8.0832 million gallons (MG) at IEUA’s truck disposal station, with an approximate average of 22,329 GPD. The nine Industrial Users are as follows:

Clement Pappas & Co., Inc. Clement Pappas & Co., Inc. is a fruit juice bottling and packaging company. The wastewater is generated from fruit juice spillage, clean-in-place and floor wash down water. This facility also has a permit for their direct connection to the IEUA north Non- Reclaimable Wastewater System (NRWS), which discharges to the Los Angeles County Sanitation Districts. Currently all flow is being discharged through the direct connection. Industry has requested to keep their hauling permit as a back-up disposal option. When discharging to the SARI volumes are approximately 775 GPD.

Enforcement Action:

Wastewater with a pH <6.0 was detected at the truck disposal station on 4/22/10. A Letter of Violation was issued on 4/22/10. Company investigated and found inaccurate tank pH meter, which was replaced.

Late self-monitoring report. Verbal warning issued on 5/19/10. Company sent report on 5/20/10.

Late self-monitoring report. Late Notice sent 6/21/10. Company sent report on 6/25/10.

RMS Services, Inc. plates aluminum wheels with chrome and nickel. The process rinse wastewater makes up the majority of their discharge and is batch-treated for metal removal prior to being hauled to the SARI dumpsite. The approximate flow hauled to the SARI is 4,251 GPD.

CC Graber Company is an olive canning plant. The plant grades the olives and then cures and processes them. Next they are placed in concrete vats in a solution of KOH (potash) for a few days until the bitterness is removed. For several days the KOH solution is replaced with water,which is replaced with salt brine until the olives are ready for canning. The discharge of reverse osmosis concentrate wastewater and boiler blowdown makes up CC Graber’s wastewater. They are seasonal from around October through early January. The approximate flow hauled to the SARI is 2,400 GPD for the 92-day season.

Mizkan Americas, Inc is a manufacturer of cooking wine and vinegar. Mizkan’s wastewater is made up of spillage, equipment cleaning, and a small amount of equipment washdown. This industry did not discharge to the SARI during this reporting period.

8.34 Ludfords, Inc. is a manufacturer of juices. Ludford’s wastewater is generated from mixing tank wash water and equipment washdown. The approximate volume hauled to the SARI is 486.5 GPD. Enforcement Action

Late Self-Monitoring Report. A Late Notice was issued on 1/18/10. Company submitted report on 1/21/10. Late Self-Monitoring Report. A Letter of Violation was issued on 4/27/10. Company submitted the report on 4/29/10.

ICL Performance Products is a manufacturer of fire retardants. Wastewater is generated from the washdown of powder retardant containers and pallets. The approximate volume of wastewater hauled to the SARI Line during this reporting period was 3,061 gallons.

Ventura Foods, LLC generates wastewater from the manufacturing of margarine, spreads, oils, mayonnaise, sauces and salad dressing along with boiler blowdown and related utilities wastewater that is brine in nature. The wastewater is hauled to the SARI system via the SARI disposal site on El Prado Road. The approximate volume hauled to the SARI was 17,871 gallons.

Enforcement Action:

Oil/Grease violation on 2/2/10. NOV issued on 3/22/10. Resamples completed on 6/22/10.

Oil/Grease violations on 12/21/09 and 12/22/09. NOV/Order for Corrective Action issued on 1/13/10.

ShawCor Pipe Protection, LLC – Categorical IU, 40 CFR, Part 433.17 This company coats pre-manufactured steel pipe. Three coating operations are done on-site: Pritec®, multilayer, and fusion bond/powder coating. Acid wastewater is generated from the multilayer, and fusion bond/powder coating processes. The acid wastewater is stored in a tank and neutralized prior to being hauled to the SARI Truck Disposal Station. Company changed ownership in October 2002 to ShawCor Pipe Protection. The approximate volume hauled to the SARI was 83.5 GPD.

Enforcement Action:

Zinc violation on 8/6/09. Letter of Violation issued 9/3/09.

Failure to respond to Letter of Violation by required date.

E&M Ranch, a Norco Ranch Facility (IEUA Permit No. SSP031) generates wastewater from washing and sanitizing of chicken eggs, plant and equipment washdown and boiler blowdown. The total volume of wastewater hauled to the SARI during this reporting period was 1,579,960, or 4,329 GPD.

8.9.3 San Bernardino Valley Municipal Water District Water (Valley) Reclamation Plant SARI Truck Disposal Station (SBVMWD Permit No. 4E-04-S56)

Valley’s truck disposal station is located at The City of San Bernardino’s Water Reclamation Plant’s SARI connection located in Reach IV of the SARI System. This truck disposal station provides a brine disposal location for facilities located in Valley’s service area.

Nineteen (19) Industrial Users are permitted to haul brine wastewater to the truck disposal station. No septic waste is accepted at the truck disposal station. The pH of each load is tested prior to discharge and must between 6.0 and 12.0 units to be accepted. For the period July 1, 2009 through

8.35 June 30, 2010, a total 4.44 MG was received at the truck disposal station, with a daily average of 12,649 GPD. The 19 Industrial Users are as follows:

Angelica Textile Services (SBVMWD Permit No. SARI-IU-021)

Angelica Textile Services is an industrial laundry engaged in supplying on a rental or contract basis, work uniforms, towels and linens. A self-regenerating soft water system is used to soften the potable water supply prior to the washing process. The resin contained in the soft water tank is used to remove the Calcium and Magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution containing concentrated sodium. Approximately 43,909 gallons per month of spent brine solution is discharged to an onsite brine storage tank(s). The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Aztec Uniform and Towel Rental (SBVMWD Permit No. SARI-I-006)

Aztec Uniform & Towel Rental is an industrial laundry engaged in supplying on a rental or contract basis, work uniforms, towels and linens. A self-regenerating soft water system is used to soften the potable water supply prior to the washing process. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 4,832 gallons per month of spent brine solution is discharged to an onsite brine storage tank(s). The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Best Brands Corporation (SBVMWD Permit No. SARI-IU-024)

Best Brands Corporation is a large commercial bakery facility which houses refrigerated food products. The refrigeration process employs the use of anhydrous ammonia for cooling of the food products. Waste ammonia is occasionally generated which must be discharged offsite to a legal disposal facility. The spent ammonia solution is hauled offsite to the SBMWD SARI Truck Disposal Station.

Enforcement Action:

3/01/10 - EC sends written warning to IU for Valley 73 SARI 302.0(H) Wastewater Discharge Permit. IU required to submit an emergency contact list and discharge contingency plan to EC by 3/15/10.

3/15/10 - EC receives business plan containing emergency contact list from IU.

3/17/10 - EC leaves voicemail for company contact to submit a discharge contingency plan.

3/29/10 - IU fails to submit required information. EC issues IU an NOV for Valley 73 SARI 302.0 Wastewater Discharge Permit. The NOV includes a $100 penalty fee and all discharge privileges have been suspended until the required correspondence is received by EC. Violation closed.

4/1/10 - IU submits emergency contact list and discharge contingency plan. Compliance achieved.

City of Rialto/Chino #1 Well (SBVMWD Permit No. SARI-IU-013)

8.36 The City of Rialto - Chino Well #1, identified as an Industrial User, is a well water extraction and treatment site. Contaminated ground water is treated with an ion exchange treatment system. The ion exchange system consists of 32 ion exchange tanks, which contain resin used to remove perchlorate. The spent resin is recharged with a sweet brine solution, containing concentrated sodium. The wastewater is a sour brine solution generated by the resin regeneration and rinsing process. Approximately 4,800 gallons per day of the spent brine solution is discharged into four 83,000-gallon brine storage tanks. The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

City of Riverside J.W. North (SBVMD Permit No. SARI-IU-025)

The City of Riverside, identified as an Industrial User, produces drinking water using a submerged membrane process at the J.W. North site. Membranes are cleaned with low pH or highly chlorinated water. Cleaning waste is pumped to a 3,000-gallon tank where it is neutralized to a pH of 7.0 and any residual chlorine is removed using sodium hypochlorite, phosphoric acid and citric acids. The spent brine solution is hauled offsite to the SBMWD SARI Disposal Truck Station.

Enforcement Action:

3/01/10 - EC sends Written Warning to IU for Valley 73 SARI 302.0(H) Wastewater Discharge Permit. IU required to submit emergency contact list and discharge contingency plan to EC by 3/15/10.

3/16/10 - EC receives contact list and discharge contingency plan. Compliance achieved.

East Valley Water District Well #27 (SBVMWD Permit No. SARI-IU-023)

The East Valley Water District- Well #27, identified as an Industrial User, is a well water extraction and treatment site. Contaminated ground water is treated to remove nitrates and perchlorate with an ion exchange system. The exchange process uses a saturated salt solution. The regeneration and rinsing process generates a waste brine solution. Approximately 4,800 gallons per day of spent brine solution is discharged into two 5,500-gallon brine storage tanks. The spent brine solution is hauled offsite to the SBMWD SARI Truck Disposal Station.

East Valley Water District Well #107 (SBVMWD Permit No. SARI-IU-023)

The East Valley Water District-Well #107, identified as an Industrial User, is a well water extraction and treatment site. Contaminated ground water is treated to remove nitrates and perchlorate with an ion exchange system. The exchange process uses a saturated salt solution. The regeneration and rinsing process generates a waste brine solution. Approximately 5,000 gallons per day of spent brine solution is discharged into two 8,500-gallon brine storage tanks. The spent brine solution is hauled offsite to the SBMWD SARI Truck Disposal Station.

Farmdale Creamery (SBVMWD Permit No. SARI-IU-005)

Farmdale Creamery is a manufacturer of cheese, sour cream, buttermilk, and butter products. A self regenerating soft water system is used to soften the potable water supply prior to the washing process. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 200 gallons per day of spent brine solution is discharged to an onsite brine storage tank(s). The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Far West Meats (SBVMWD Permit No. SARI-IU-011)

8.37 Far West Meats is a meat processing (beef, pork, poultry) plant. Sodium, sodium nitrite, sugar, fructose, vitamin C and liquid smoke are the ingredients used in making up the brine cure for smoked meat products. Approximately 6,738 gallons per month of the spent brine solution is discharged to a 7,476 gallon brine storage tanker. The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Glen Helen Rehabilitation Center (SBVMWD Permit No. SARI-IU-010)

Glen Helen Rehabilitation Center is a correctional institution. A self-regenerating soft water system is used to soften the potable water supply prior to the boilers, which provides heated water for various operations throughout the facility. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 25,000 gallons per month of the spent brine solution is discharged into two 12,000 gallon onsite brine storage tanks. The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Juice Heads Inc., (SBVMWD Permit No. SARI-IU-022)

Juice Heads, Inc. is a manufacturer of fruit and citrus juices. A self-regenerating soft water system is used to soften the potable water supply prior to the boilers. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 200 gallons per day of spent brine solution is discharged to an onsite brine storage tank. The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Loma Linda East Campus (SBVMWD Permit No. SARI-IU-004)

Loma Linda University East Campus Hospital is a surgical and medical hospital. A self- regenerating soft water system is used to soften the potable water supply prior to the boilers, which provides steam to exclusively feed the autoclaves used in the operating room services. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 50 gallons per day of the spent brine solution is discharged to an onsite brine storage tank(s). The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Loma Linda Power Plant (SBVMWD Permit No. SARI-IU-003)

Loma Linda University Power Plant is an electrical generating facility. Two natural gas and one steam turbine generate approximately 11 megawatts of electricity for the Loma Linda University and Medical Center. An onsite water softening and reverse osmosis system are used to condition the water supplied to the boilers which generate the steamfor the turbine. The high EC water softening regeneration rinse is diverted from the domestic sewer to storage tanks. The only wastewater hauled to the SBMWD SARI Truck Disposal Station from this facility is generated from non- catergorical sources, specifically high-strength brine wastewater. The absence of categorical wastewater hauled off-site permits the Loma Linda University Power Plant to be classified as an Industrial User (IU) instead of a Catergorical Industrial User. Approxately 16,000 gallons per week of the spent brine solution is discharged to three 4,500-gallon brine storage tanks.

Loma Linda Veterans Affairs Medical Center (SBVMWD Permit No. SARI-IU-026)

Loma Linda Veterans Affairs Medical Center (LLVAMC), identified as an Industrial User, is a medical facility which provides full service hospital care for veterans. A self-regenerating soft water system is used to soften the potable water supply prior to feeding the boiler system. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing

8.38 concentrated sodium. Approximately 500 gallons per month of spent brine solution is diverted to a 7,000-gallon underground storage tank. When the storage tank level is approximately 5,000 gallons the spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Enforcement Action:

3/01/10 - EC sends Written Warning to IU for Valley 73 SARI 302.0(H) Waste Water Discharge Permit. IU is required to submit an emergency contact list and discharge contingency plan to EC by 3/15/10.

3/17/10 - EC received contact list and discharge plan. Compliance achieved.

Mars Petcare US, Inc. (SBVMWD Permit No. SARI-IU-014)

Mars Petcare US, Inc., identified as an Industrial User, manufactures private label dry pet food. Bulk dry and liquid ingredients are received at the facility by truck and rail. Ingredients are ground and sent to one of three raw mix bins. Materials in raw mix bins are then sent to one of three extruders. Prior to the extruders, steam and hot water are added to the granular pet food. Steam is generated by a boiler on site. A water softening system is used to condition the water supplied to the boiler. Air scrubbers are used on site to reduce nuisance odors. Each scrubber is coupled with a specific line dryer. Exhaust air and cooling air from the dryers are sent through the scrubbers. A continuous purge stream flow as well as a batch scrubber blowdown flow will be diverted to the brine storage tanks. Waste stream generated by the scrubbers contain varying concentrations of pet food particulates and organics, water, sodium hydroxide (NaOH) and sodium hypochlorite (NaOC1). In addition, wastewater including boiler blowdown and floor cleaning solution wastewater will be discharged to the SARI line. Approximately 2,000 gallons per day of spent brine solution is discharged to a 6,000 and a 10,000 gallon brine storage tank. The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Enforcement Action:

6/24/09 – IU waiting for laboratory to release sampling data. IU requests extension. IU required to submit sampling results by 7/2/09.

7/2/09 - IU submits discrete sample results. Sample data indicates SARI storage tank is source of TTO. IU to resample tank to confirm results with sample data submitted to EC by August 10, 2009.

8/11/09 - IU submits second set of discrete TTO sample results. Sample data reveals continued noncompliance for TTO. IU to suspend discharge to SARI dump station effective 8/14/09 to evaluate TTO source. IU to haul waste to KVAC until compliance can be achieved. Violation closed.

National Concrete Washout, Inc. (SBVMWD Permit No. SARI-IU-015)

National Concrete Washout, Inc., identified as an Industrial User, provides a truck washout service for concrete trucks located at various sites. The wastewater is generated from rinsing the inside of concrete trucks, as well as the fins and chutes. Concrete-laden wastewater is filtered to remove solids comprised of sand, gravel, and cement. Approximately 2,200 gallons of filtered water is stored onsite. The stored wastewater is hauled to the SBMWD SARI Truck Disposal Station.

Patton State Hospital (SBVMWD Permit No. SARI-IU-002)

8.39

Patton State Hospital is a state run psychiatric hospital. A self-regenerating soft water system is used to soften the potable water supply prior to the boilers, which provides heated water for various operations throughout the facility. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 2,000 gallons per month of the spent brine solution is discharged to an onsite brine storage tank(s). The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

Rayne Water Conditioning (SBVMWD Permit No. SARI-IU-007)

Rayne Water Conditioning is an Industrial User which regenerates resin contained in soft water exchange tanks for commercial and residential customers. The resin contained in the soft water tank is used to remove the calcium and magnesium ions (hardness) from the potable water supply. Spent resin is recharged with a sweet brine solution, containing concentrated sodium. Approximately 5,000 gallons per day of spent brine solution is discharged to an onsite brine storage tank(s). The spent brine solution is hauled to the SBMWD SARI Truck Disposal Station.

8.9.4 WMWD’s SAWPA Approved Truck Disposal Facility (WMWD Permit No. 4B-06-S60)

This truck disposal station located at the City of Corona’s Water Reclamation Facility No. 1 at 2205 Railroad St. began operations in April 2007.

Twenty-one (21) industrial users are permitted to haul wastewater to the truck disposal station. No septic waste is accepted at the truck disposal station. The pH of each load is tested prior to discharge and must be between 6.0 and 12.0 units to be accepted. For the period July 1, 2009 through June 30, 2010, a total 19.47 MG was received at the truck disposal station, with a daily average of 47,863 GPD. The 21 Industrial Users are as follows:

Access Business Group, LLC – Nutrilite Division (formerly Amway Corporation) (WMWD Permit No. DS-039)

Nutrilite produces pharmaceuticals and powder drinks. Water softener systems supply soft water to boilers that provide steam for the fruit blanching process. Water softener regeneration rinse water is sent to a storage pond for evaporation. Haul off to the SARI Truck Disposal Station occurs when the wastewater influent rate exceeds the pond evaporation rate, which is typically during the rainy season. No industrial waste is hauled to the SARI Truck Disposal Station.

Aramark Uniform & Career Apparel, LLC (WMWD Permit No. DS-059)

Aramark Uniform & Career Apparel, LLC is an industrial laundry facility, which specializes in cleaning uniforms. The wastewater generated at the facility consists of concentrated brine waste from the water softening processes. A self-regenerating soft water system is used at the facility to reduce the hardness of the incoming water prior to washing clothes. Aramark Uniform & Career Apparel, LLC discharges concentrated brine waste from the water softening processes to the brine storage tank. The contents of the brine storage tank are hauled offsite to the SARI System for disposal.

California School for the Deaf (WMWD Permit No. DS-010)

The school is a state institution for the hearing impaired. An on-site water softening system supplies soft water to boilers that provide hot water and steam for space heating and cooking.

8.40 High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

Corona Regional Medical Center (WMWD Permit No. DS-002)

This is a full-service medical facility with a 140-bed capacity. A water softening system supplies soft water to boilers that provide domestic hot water and steam throughout the facility. High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

Decra Roofing, Inc. (WMWD Permit No. DS-015)

This company manufactures metal roofing products. The company formulates their own water- based acrylic paint on-site. Wastewater generated on-site is from the overspray/overglaze process, paint formulation cleanup, and process area floor cleanup. The wastewater is treated on-site. The treated wastewater is hauled off to the SARI Truck Disposal Station.

Flavor Specialties, Inc. (WMWD Permit No. DS-061)

Flavor Specialties, Inc. is a facility that produces flavor bases for the food industry.

The wastewater generated at Flavor Specialties Inc., which is to be hauled to the SARI System, consists of dryer, blender and bottling rinse waters. The first rinse of each process area is captured and shipped offsite for further processing and use. The second rinse waters are captured, conveyed through a clarifier, flow equalized, pH adjusted and ultimately loaded to a permitted liquid waste hauler for disposal at WMWD’s SAWPA approved Truck Disposal Station.

Food For Life Baking Co., Inc. (WMWD Permit No. DS-063)

Food For Life Baking Co., Inc. is a facility that produces Sprouted Grain Breads and Tortillas.

The industrial wastewater generated at Food For Life Baking Co., Inc. is from the washdown of the equipment, floors and the spent steeping water. The wastewater is then conveyed to various holding tanks and loaded to a permitted liquid waste hauler for disposal at WMWD’s SAWPA approved Truck Disposal Station.

Fresh & Easy Neighborhood Market, Inc. (WMWD Permit No. DS-060)

Fresh & Easy Neighborhood Market, Inc. operates a food processing facility at 14950 Innovation Dr., Riverside, CA. The products produced include sandwiches, pastas, cooked meats, sushi, cooked and fresh vegetables, sauces and salad dressings.

The industrial wastewater generated at this location is from the cleaning of equipment both clean- in-place and cleaning in the equipment wash room for wheel mounted equipment, floor drains and utensil sinks. Wastewater is generated from the oven loading area. In addition there is discharge from the cooling tower, boiler blowdown and from the trailer wash facility.

Frontier Aluminum Corp. (WMWD Permit No. DS-064) Categorical IU, 40 CFR 467.36

Frontier Aluminum Corp. is an aluminum extrusion facility, which operates a paint line for coating the aluminum extrusions. Aluminum extrusions are cleaned in a caustic bath and then rinsed prior to treatment. The extrusions are then treated with a chrome phosphate pre-treatment to improve paint adhesion to the aluminum and then rinsed twice to remove particulates. The rinse water is treated with sodium metabisulfite to reduce chrome. The rinse water is then treated with magnesium oxide to reduce fluoride levels. The water is then pH adjusted and the Cr (+3) which is derived

8.41 during treatment and then allowed to precipitate from solution and to settle in the tank. The clean water is then decanted from the top of the tank. The sludge is then processed through the filter press. The filter cake is disposed of as a hazardous waste. Both decanted water and filter press filtrate wastewater are sent to the facilities SARI storage tank and hauled offsite to the SARI System for disposal.

Giuliano & Sons Briners, Inc. (WMWD Permit No. DS-065)

Giuliano & Sons Briners, Inc. produces diced citrus peel, and pickles a variety of vegetables, such as jalapenos, cauliflower, celery, carrots, and ortega chilies. Vinegar, acetic acid, sodium chloride, calcium chloride, and sulfur dioxide solutions are used to process the vegetables and fruit. The wastewater generated from these processes is hauled offsite to the SARI System for disposal.

International Rectifier, Hexfet America (WMWD Permit No. DS-012) Categorical IU, 40 CFR, Part 469.18

Hexfet takes precut silicon wafers and makes computer chips for computer, peripheral, automotive, and cellular telephone applications. Acid etching and solvent etching of the computer wafers are done at this site. The plating is done in Mexico. A 39,000-gallon tank is used to contain the acidic rinse water. The company neutralizes this wastewater, but it cannot be discharged to the local sewer because of high TDS. The company currently hauls its rinse water to the EMWD Truck Disposal Station for disposal, but still retains its SAWPA discharge permit to use the SARI truck disposal station as an alternative disposal site.

La Sierra University (WMWD Permit No. DS-004)

The university uses a water softening system to supply soft water to boilers that provide domestic hot water throughout the campus. High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

Loma Linda University Community Medical Center (WMWD Permit No. DS-028)

This is a full-service medical center, which is a subpart of the larger Loma Linda University Medical Center, which is located approximately 1/2 mile west. The uses of the soft water generated on-site are for steam and hot water. High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

Norco Ranch Inc. (WMWD Permit No. DS-058)

Norco Ranch, Inc. was issued a permit to haul approximately 65,000 GPD to WMWD’s SAWPA approved truck disposal station. Norco Ranch Inc. produces and packages a variety of egg products. Their wastewater is generated form washing and sterilization of eggs and equipment wash down. Facility has closed.

Prudential Overall Supply (WMWD Permit No. DS-016)

This company is a commercial account laundry cleaning facility. High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

Qualified Mobile, Inc. (WMWD Permit No. DS-045)

Qualified Mobile, Inc. performs mobile off-site vehicle washing services. An ion exchange system located at the main facility is used to reduce the hardness of the water used to clean the automobiles. This reduces the spotting effect the rinse water has on serviced automobiles. High-

8.42 strength brine wastewater generated from the ion exchange unit is hauled to the SARI Disposal Station.

Rancho Springs Medical Center (WMWD Permit No. DS-043)

This is a full service medical facility with a 99-bed capacity. A water softening system supplies soft water to boilers that provide domestic hot water and steam throughout the facility. High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

Sierra Aluminum Company (WMWD Permit No. DS-001) Categorical IU, 40 CFR 467.36

Sierra Aluminum produces extruded aluminum for use in window and doorframes in commercial, residential, and motor home installations. Wastewater generated from cooling tower blowdown, quenching process, and reverse osmosis reject are stored in a 5,000-gallon brine storage tank for haul off to the SARI Truck Disposal Station.

Triple H Food Processors (WMWD Permit No. DS-053)

Triple H Food Processors, Inc. is a facility that produces juices, sauces, marinades, and bar mixes, located in Riverside California. The wastewater generated at Triple H Food Processors, which is to be hauled to the SARI system, consists of wastewater from packaging and bottling processes. These processes include CIP wastestream, cooling tower blowdown, conveyance line lubricant and spillage that won’t meet the City of Riverside’s TDS limits.

TRM Manufacturing, Inc. (WMWD Permit No. DS-062)

TRM Manufacturing, Inc. is a plant that manufactures plastic film from raw polyethylene resin. The wastewater generated at the facility is from the cooling tower blowdown. City water is used to cool down co-generation units that run on natural gas. No other manufacturing processes in the plant create a wastewater stream. The plant manufactures plastic film from raw polyethylene resin.

V.A. Medical Center (WMWD Permit No. DS-026)

This is a full-service medical center for military veterans of the U.S. Armed Forces, which provides in and out patient care and nursing home services. An on-site water softening system supplies boilers and R.O. equipment. High EC water softener regeneration rinse water is diverted from the domestic sewer to a storage tank for haul off to the SARI Truck Disposal Station.

8.10 SAWPA SAMPLING AND SELF-MONITORING SAMPLING RESULTS

The tables in Appendix J show sample results for each industrial user.

8.11 FUTURE PROJECTS AFFECTING DISCHARGE QUANTITY TO SARI SYSTEM The California Rehabilitation Center - CRC and the City of Norco continue to negotiate the plan to divert CRC domestic flows to the WRCRWRP plant. As part of the negotiations, The City of Norco will be required to construct and maintain the required bar screen and Muffin Monster at CRC’s discharge point. No dates are set at this time.

8.43 The City of Corona – The City of Corona has entered into an Agreement with WRCRWA to divert up to 3.5 MGD of secondary treated wastewater to WRCRWA’s treatment plant. The City of Corona as part of their contingency plan has asked to divert this flow to the SARI in an emergency situation. A permit has been issued for this temporary discharge, should it be necessary.

Inland Empire Utilities Agency - IEUA RP-2 and RP-5 connections to the SARI line are currently inactive. The RP-5 permit will be for emergency situations only and will not be permitted to discharge any wastewater or the contents of any process tanks to the SARI Connection, at any time, without previously notifying SAWPA personnel of the proposed discharge. The RP-2 permit was not approved in August 2007. RP-2’s filtrate is currently being pumped back to RP-5 for treatment.

Temporary domestic connection, Alberhill area (Elsinore Valley MWD) - A new temporary domestic connection was planned during 2007 (currently on hold) serving a new residential development in the North end of the City of Lake Elsinore. Initially this connection will add up to 0.30 MGD. The maximum flow is 1.0 MGD; it is expected that the flow will gradually increase from 0.3 to 1.0 MGD between 2007/8 and 2012. By agreement, this connection must be removed by 2012.

Desalters

Perris South Desalter – This Desalter is in the design phase and when completed will discharge up to 1.0 MGD of R.O. reject water.

8.12 INTERACTION WITH SAWPA

Industrial pretreatment agreements exist between SAWPA and EMWD, IEUA, SBVMWD and WMWD with these agencies issuing permits within their service areas and conducting the pretreatment program. SAWPA performs periodic quality assurance reviews of these programs. OCSD received and reviewed draft permit renewals from SAWPA during the period and provided feedback as needed.

A new database including all SAWPA area dischargers is currently being constructed. Permittee locations, SAWPA boundaries and member agency boundaries are being added to GIS. A SharePoint site has been set up to communicate and organize the activities and data exchanges between OCSD and SAWPA staff. Biannual meetings are now being held to further enhance coordination between the two groups.

8.13 NATIONAL ASSOCIATION OF CLEAN WATER AGENCIES (NACWA)

National Pretreatment & Pollution Prevention Workshop

The National Association of Clean Water Agencies (NACWA), formerly known as AMSA, annually holds the National Pretreatment & Pollution Prevention meeting for NACWA members, EPA representatives and other interested parties including EPA and state coordinators, and business representatives. In May 2010, NACWA held a National Pretreatment and Pollution Prevention Workshop entitled ―P3: The Next Generation - Its Continuing Mission to Clean the Nation’s Water” in Phoenix, Arizona. A staff member from OCSD’s Source Control Division attended the sessions regarding new challenges that today’s pretreatment program coordinators are facing. These sessions included presentations for pretreatment and control of new pollutants of concern such as endocrine disrupters, pharmaceuticals, and personal care products (the next generation of pollutants), new challenges such as non-flushable wipes that cause an increase in sewer spills and operation and maintenance costs, and the Regional Roundtable discussion with EPA. Staff also participated in an EPA Region 9 workgroup meeting led by Keith Silva who provided legislative and regulatory updates impacting the pretreatment program.

8.44 8.14 WATER ENVIRONMENT FEDERATION

In October 2009, the 82st Annual Water Environment Federation Technical Exhibition and Conference (WEFTEC 2009) was held in Orlando, Florida. A Source Control staff member presented ―Predictive Source Control: Application of Advanced Numerical Methods and Surrogate Monitoring for Microconstituents in Water Reclamation,‖ ―Key Fate and Effects Issues with Microconstituents and How to Communicate to the Public,‖ and is an appointed member of the Water Environment Federation Water Reuse and Microconstituents Community of Practice Committees. Source Control has had an increasing role in controlling newly emerging pollutants through its non-industrial source control program, and controlling constituents of concern for groundwater reclamation.

8.45 chapter 9

SOLIDS MANAGEMENT PROGRAM

Introduction Biosolids Quality chapter 9

SOLIDS MANAGEMENT PROGRAM

9.1 INTRODUCTION

This section provides an overview of the Biosolids Management Program for the Orange County Sanitation District (OCSD) focusing on the quality with respect to metals. Biosolids are the treated solids resulting from the process of separating solids from water in the wastewater treatment process.

OCSD’s biosolids management program has maintained certification with the National Biosolids Partnership (www.biosolids.org) since 2003. The Source Control program is a key element in maintaining this certification as well as maintaining our continued goal of recycling our biosolids through their minimization of negative constituents into the collection system and ultimately the solids.

OCSD’s annual biosolids compliance report is completed and posted online in February. Visit OCSD.com’s Document Center and search for “503” to access the most recent document that contains our Biosolids Management Program history, certifications, regulations, quantities, and how and where biosolids are recycled. OCSD also produced an annual biosolids brochure summarizing our program accomplishments and future goals (search the Document Center for “bmpp”).

9.2 BIOSOLIDS QUALITY

Biosolids quality plays an important role in determining the feasibility of recycling versus disposal options. OCSD's Source Control Program has been very effective in reducing and maintaining levels of pollutants. The ceiling concentrations and EQ (exceptional quality) concentrations promulgated by the EPA's sludge regulations (40 CFR 503) are presented in the figures as a reference. For FY 20009/10, OCSD's biosolids met the EQ limits for all the regulated parameters.

The levels in trace metals, illustrated in Figures 9.1 through 9.10, have provided opportunity for beneficial recycling of biosolids including direct application to agricultural land and composting for use as a soil amendment.

TABLE 9.1 Trends in Trace Metal Content of Biosolids, Fiscal Years 2000–2010 (Concentration in mg/kg, dry weight) Orange County Sanitation District, Source Control Division

Exceptional Plant No. 1 Plant No. 2 Fiscal Quality Metal Year Limits Min. Max. Avg. Min. Max. Avg. Arsenic 41 1999-00 5.5 9.7 8.5 6.9 12 8.5 2000-01 1.4 8.1 6.3 3.1 9.7 7.8 2001-02 3.7 6.5 4.9 4 7.5 6.4 2002-03 4.2 6.4 5.4 5.3 9 7 2003-04 3.5 5 4.3 4 6.7 5.7 2004-05 3.3 6.7 5 5.8 9.1 7 2005-06 0.9 7.7 4.4 4.6 9.8 6.9 2006-07 2.7 7.2 5.3 5.1 11 7.3 2007-08 2.9 9.0 6.2 4.1 14 7.9 2008-09 4.3 12 7.1 3.5 13 9.0 2009-10 2.0 10.0 5.2 4.4 10.0 7.2

9.1 TABLE 9.1 Trends in Trace Metal Content of Biosolids, Fiscal Years 2000–2010 (Concentration in mg/kg, dry weight) Orange County Sanitation District, Source Control Division

Exceptional Plant No. 1 Plant No. 2 Fiscal Quality Metal Year Limits Min. Max. Avg. Min. Max. Avg. Cadmium 39 1999-00 14 24 20 8 11 10 2000-01 15 37 22 7 13 10 2001-02 9 16 12 8 14 10 2002-03 8 11 9 6 8 7 2003-04 7 19 13 3 9 6 2004-05 11 22 17 6 10 8 2005-06 5 11 7 3 8 6 2006-07 3.7 6.1 5 2 4 3.3 2007-08 3.2 11 5.5 2.6 6.4 3.8 2008-09 2.5 6.20 4.1 1.7 4.4 3.0 2009-10 1.1 4.4 2.9 1.0 4.8 2.81 Chromium ** 1999-00 86 110 100 84 120 100 2000-01 99 227 149 82 140 101 2001-02 90 217 120 92 163 120 2002-03 71 120 97 76 110 90 2003-04 71 260 113 38 100 78 2004-05 75 140 99 59 75 66 2005-06 55 78 63 47 60 54 2006-07 51 77 62 47 86 60 2007-08 50 62 54 46 77 60 2008-09 44 65 55 42 88 62.3 2009-10 29 56 44 30 54 47 Copper 1,500 1999-00 750 920 851 783 900 838 2000-01 810 1,100 938 670 960 885 2001-02 540 820 710 650 720 690 2002-03 660 830 710 560 810 660 2003-04 620 790 680 490 700 600 2004-05 570 690 623 500 680 593 2005-06 600 710 641 520 680 603 2006-07 600 800 686 540 620 576 2007-08 500 650 570 460 630 538 2008-09 500 590 560 500 540 523 2009-10 420 620 543 370 560 497 Lead 300 1999-00 48 57 53 40 53 47 2000-01 51 86 63 38 64 51 2001-02 35 57 44 30 69 42 2002-03 30 46 36 28 38 32 2003-04 27 47 35 22 29 26 2004-05 27 41 32 16 26 22 2005-06 18 32 27 14 29 22 2006-07 23 30 26 14 24 21 2007-08 6 30 20 6 24 14

9.2 TABLE 9.1 Trends in Trace Metal Content of Biosolids, Fiscal Years 2000–2010 (Concentration in mg/kg, dry weight) Orange County Sanitation District, Source Control Division

Exceptional Plant No. 1 Plant No. 2 Fiscal Quality Metal Year Limits Min. Max. Avg. Min. Max. Avg. 2008-09 11 25 21 6 21 15 2009-10 9 44 23 9 20 17 Mercury 17 1999-00 1.5 2.4 1.9 1.3 2.7 2 2000-01 1.5 2.3 1.9 1 2.7 1.8 2001-02 1.7 2.6 2.2 1.6 2.4 2 2002-03 1.7 2.6 2.2 1.6 2.4 2 2002-04 1.4 2.2 1.7 1.4 2.3 1.7 2004-05 1 2.4 1.8 1.1 2.2 1.4 2005-06 1.5 2 1.7 1.2 6.4 2.1 2006-07 1.1 2.4 1.6 1.3 2.5 1.7 2007-08 1.1 4.2 1.9 1.3 2.6 1.6 2008-09 1.0 1.9 1.4 1.0 2.6 1.4 2009-10 1.0 3.2 1.4 0.9 1.6 1.3 Molybdenum ** 1999-00 18 26 21 17 22 20 2000-01 15 22 18 11 23 16 2001-02 15 21 18 12 18 14 2002-03 16 26 20 10 18 13 2003-04 17 24 20 12 17 14 2004-05 14 19 17 10 18 15 2005-06 9 18 15 12 18 15 2006-07 13 22 18 14 18 16 2007-08 12 17 13 12 18 15 2008-09 12 16 15 8 16 14 2009-10 6 16 13 6 14 10 Nickel 420 1999-00 105 180 130 102 180 126 2000-01 140 240 203 71 217 121 2001-02 100 237 150 83 123 100 2002-03 95 160 120 58 97 77 2003-04 90 300 170 54 83 72 2004-05 69 150 114 36 62 48 2005-06 58 87 66 32 60 39 2006-07 44 60 54 28 44 34 2007-08 34 58 45 24 56 31 2008-09 30 41 35 22 37 29 2009-10 12 36 28 9 27 21 Selenium 100 1999-00 4.7 15 10 3.2 9.3 7.5 2000-01 4.4 22 9.7 4.2 12 8.4 2001-02 4.1 17 8.2 2.8 16 8.3 2002-03 4 10 8 5 12 7 2003-04 3.2 14 8 2.1 12 6 2004-05 3.6 11 7.2 1.3 10 4.7

9.3 TABLE 9.1 Trends in Trace Metal Content of Biosolids, Fiscal Years 2000–2010 (Concentration in mg/kg, dry weight) Orange County Sanitation District, Source Control Division

Exceptional Plant No. 1 Plant No. 2 Fiscal Quality Metal Year Limits Min. Max. Avg. Min. Max. Avg. 2005-06 5.5 12 7.8 3 9.5 6 2006-07 4.7 13 8.2 1.8 14 5.8 2007-08 3.0 14 8 1.4 11 5.6 2008-09 2.5 14.0 9.7 2.8 13 7.5 2009-10 2.7 18 7.3 2.8 16 5.6 Silver ** 1999-00 41 72 59 23 74 41 2000-01 8 76 49 36 42 39 2001-02 37 61 45 33 43 36 2002-03 40 53 44 29 39 32 2003-04 34 43 38 25 27 26 2004-05 38 52 43 17 25 23 2005-06 ND ND ND ND ND ND 2006-07 28 36 31 ND ND ND 2007-08 19 25 22 10 15 13 2008-09 19 24 20.8 9.5 13 11.6 2009-10 10 18 15 7.4 13 10 Zinc 2,800 1999-00 640 798 736 752 900 827 2000-01 760 1,100 865 710 925 810 2001-02 630 817 730 750 893 830 2002-03 650 790 710 640 830 760 2003-04 660 820 750 630 760 690 2004-05 640 800 720 600 720 663 2005-06 700 910 801 680 900 760 2006-07 820 1100 900 720 930 790 2007-08 740 890 806 680 790 716 2008-09 720 870 785 700 800 749 2009-10 560 810 741 520 790 710 ** No 40 CFR Part 503 Exceptional Quality Criteria. ND = Non-detectable

9.4 4000

3500 Plant No. 1 Plant No. 2

3000

2500 m g / 2000 Exceptional Quality EPA Biosolids Pollutant k Concentration Limit 2800 mg/kg (Feb. 1993) g 1500

1000

500

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-1 Trends in Concentrations of Arsenic in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

45

40 Plant No. 1 Plant No. 2

35

30

Exceptional Quality EPA Biosolids Pollutant m Concentration Limit 39 mg/kg (Feb. 1993) g 25 / k 20 g

15

10

5

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-2 Trends in Concentrations of Cadmium in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

9.5 750

Plant No. 1 Plant No. 2

600

There are no biosolids limits for chromium m 450 g / k g 300

150

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-3 Trends in Concentrations of Chromium in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

2000

1800 Plant No. 1 Plant No. 2 Exceptional Quality EPA Biosolids Pollutant Concentration Limit 1500 mg/kg (Feb. 1993) 1600

1400

m 1200 g / 1000 k g 800

600

400

200

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-4 Trends in Concentrations of Copper in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

9.6 500

Plant No. 1 Plant No. 2 400

m 300 g Exceptional Quality EPA Biosolids Pollutant / Concentration Limit 300 mg/kg (Feb. 1993) k g 200

100

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-5 Trends of Concentrations of Lead in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

40

35 Plant No. 1 Plant No. 2

30

25 m g Exceptional Quality EPA Biosolids Pollutant Concentration Limit 17 mg/kg (Feb. 1993) / 20 k g 15

10

5

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-6 Trends in Concentrations of Mercury in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

9.7 80

70 Ceiling Concentration 75 mg/kg (Feb. 1993) Plant No. 1 Plant No. 2

60

50 m g No Exceptional Quality EPA Biosolids Pollutant / 40 Concentration Limit k g 30

20

10

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-7 Trends in Concentrations of Molybdenum in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

450

400 Plant No. 1 Plant No. 2 Exceptional Quality EPA Biosolids Pollutant Concentration Limit and Ceiling Limit 420 mg/kg 350 (Feb. 1993)

300 m g 250 / k 200 g 150

100

50

0

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-8 Trends in Concentrations of Nickel in Biosolids, Fiscal Years, 1990-2010 Orange County Sanitation District

9.8 110

100 Plant No. 1 Plant No. 2 Exceptional Quality EPA Biosolids 90 Pollutant Concentration Limit & Ceiling Concentration 100 mg/kg

80

70 m g 60 / k 50 g 40 Concentration less than method detection 30 limit of 63 mg/kg limit in 1993

20

10

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-9 Trends in Concentrations of Selenium in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

4000

3500 Plant No. 1 Plant No. 2

3000

2500 m g / 2000 Exceptional Quality EPA Biosolids Pollutant k Concentration Limit 2800 mg/kg (Feb. 1993) g 1500

1000

500

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Figure 9-10 Trends in Concentrations of Zinc in Biosolids, Fiscal Years 1990-2010 Orange County Sanitation District

9.9 chapter 10

NON-INDUSTRIAL SOURCE CONTROL (NISC) PROGRAM

Introduction Regulatory Obligations and Legal Authority Fats, Oils, and Grease (FOG) Control Radiator Shops Dry Cleaners Urban Runoff Mercury Constituents of Emerging Concern chapter 10

NON-INDUSTRIAL SOURCE CONTROL PROGRAM STATUS

10.1 INTRODUCTION

In response to regulatory mandates and current concerns regarding constituents of emerging concern (CECs), OCSD has expanded its Source Control Program to include not only industrial sources but non-industrial sources as well. This chapter summarizes the regulatory framework for the Non-industrial Source Control (NISC) Program and the programs currently being implemented and under development, as summarized below.

TABLE 10.1 NISC Programs, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Program Status FOG Control - Commercial and Residential Implementing Radiator Shops Implementing Dry Cleaners Implementing Urban Runoff Implementing Constituents of Emerging Concern (CECs) Implementing Countywide Pollution Prevention Partnership (C4P) Implementing Pharmaceuticals - Residential and Industrial Manufacturers Implementing Pharmaceuticals - Commercial Under Development Pollutant Prioritization Under Development

10.2 REGULATORY OBLIGATIONS AND LEGAL AUTHORITY

For each program, legal authority is often a necessary component. The following table lists OCSD’s significant regulatory obligations, the NISC Program(s) associated with those obligations, and the legal authorities for the programs.

TABLE 10.2 NISC Program Regulatory Objectives and Legal Authority by Program, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Regulatory Obligation(s) Program Legal Authority Prevent pass through or interference; All Programs 40 CFR 403; Clean Water Act; California Water Code; OCSD improve opportunities for wastewater and Ordinance No. OCSD-39 sludge reclamation Implement an expanded source control All Programs SWRCB Order No. R8-2008-0058; Ordinance No. OCSD-39; program to protect the GWRS and OCSD Resolution No. 08-02; OCSD-OCWD Joint Exercise of drinking water supply Powers Agreement; Draft California Code of Regulations, Title 22 Zero preventable sanitary sewer FOG Control SWRCB Order No. 2006-0003; Ordinance No. OCSD-25; overflows Program OCSD Resolution No. OCSD 05-04 Prevent beach closures Urban California Health & Safety Code; County of Orange D01-105 Runoff Agreement; OCSD Resolution No. 01-04; City of Huntington Program Beach and Irvine Ranch Water District Agreements

10.1 10.3 FATS, OILS, AND GREASE (FOG) CONTROL

Background

A frequent cause of Sanitary Sewer Overflows (SSOs) is grease accumulation in the small- to medium-sized sewer lines, which are typically owned and operated by the cities and local sewering agencies. In April 2002, the California Regional Water Quality Control Board, Santa Ana Region (RWQCB) issued Order No. R8-2002-0014, General Waste Discharge Requirements (WDR), which required Orange County cities and sewering agencies (WDR Co-Permittees) to monitor and control SSOs. One element in the Order is for each WDR Co-Permittee to implement a FOG Control Program by December 2004. Based on the success of the RWQCB’s WDR, in May 2006 the State Water Resources Control Board (SWRCB) adopted Statewide General Waste Discharge Requirements for Sanitary Sewer Systems, Water Quality Order No. 2006-0003 (Statewide WDR), which required a similar effort statewide. Based on the SWRCB’s actions, the RWQCB rescinded its WDR as of December 2006.

As required, after characterizing its jurisdictional boundaries, potential sources, and collection system “trouble spots” (areas requiring frequent cleaning), OCSD implemented a FOG Control Program effective January 1, 2005. OCSD’s program encompasses both the commercial and residential communities, and it is administered through a combination of permitting, compliance tracking, reporting, inspection, enforcement, and outreach. The significant efforts for the past fiscal year are summarized below.

10.3.1 FOG Control Commercial

Permitting

Food service establishments (FSEs) are the primary FOG dischargers to the sewer; however, not all FSEs cause or contribute to SSOs. After studying the issues, OCSD developed six categories of FSE permits, and issued two-year permits to FSEs subject to five of those categories. The categorization is based upon the FSE’s discharge of FOG, the requirements of Ordinance No. OCSD-25, whether the FSE has FOG pretreatment, and the potential of the FSE to impact known or potential trouble spots. The counts by category are shown below.

TABLE 10.3 FSEs by Category, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division FSEs by Category Count Category 1 – grease interceptor (GI) installed 54 Category 2 – no GI but contributing to a trouble spot 13 Category 3 – no GI and not a significant contributor to a trouble spot 50 Category 4 – no GI required at this time 86 Category 5 – insignificant FOG discharger, not permitted 50 Category 6 – property owner maintains a shared GI 3 Category 86 – FSEs that went out of business 3 Total FSEs 256

Ordinance No. OCSD-25 requires that every FSE operate and maintain a grease interceptor; however, waivers to the requirement may be issued depending on the site-specific conditions. FSEs subject to FOG Permit Categories 1 and 6 have grease interceptors installed. FOG Permit Categories 2, 3, and 4 are issued permits with a Conditional Waiver, granting a temporary waiver from the requirement to install, operate, and maintain a grease interceptor. The current count of FOG Permits with a waiver is enumerated below.

10.2 TABLE 10.4 Status of FSEs with GIs, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division FSE Status Count FSEs with Grease Interceptors (Categories 1, 6) 57 FSEs with Grease Interceptor Waivers (Categories 2,3, and 4) 149

Self-Monitoring Report

As a condition of their FOG Permits, FSEs are required to implement BMPs, maintain their GIs, and submit periodic self-monitoring reports to inform OCSD of their BMP efforts and GI maintenance activities. Violation of these requirements can lead to issuance of a Corrective Action Notice (CAN), a Notice of Violation (NOV), or an assessment of noncompliance fees. Statistics from the past fiscal year are shown in the table below:

TABLE 10.5 FSE Monitoring Reports and NOVs, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division FSEs by Category Issued Received Percent Received BMPs Monitoring Reports 338 335 99.1% G.I. Monitoring Reports 88 87 98.9% Notices of Violation 4 N/A N/A

Inspection

Routine FSE inspections are conducted to confirm 1) whether the business is still is operation, 2) whether the FSE is implementing the required kitchen BMPs, and 3) whether the GI is being maintained and pumped out regularly to comply with the 25% rule. Routine inspections are also opportunities to interface with the FSEs, which helps boost compliance with the permit requirements by creating opportunities for educational outreach and reinforcement about the importance of the kitchen BMPs to minimize the FOG discharged to the sewer. Since 2005, OCSD has outsourced much of this work. At the end of each month, OCSD receives completed inspection reports along with any CANs issued. However, during Fiscal Year 2009/10, there was a delay in the awarding of the contract, so that after July 2009, no inspections occurred until February 2010. The counts of BMPs and GI inspections and the CANs issued are listed in the table below.

TABLE 10.6 FSE Inspection Activities, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Actions Taken Count BMPs Inspections* 100 GI Inspections* 20 Corrective Action Notices issued* 110 Deficient BMPs/GI Monitoring Report Compliance Inspection† 8 BMPs/GI Monitoring Report Late Submittal Compliance Inspection† 5 Permit Application (Renewal) Late Submittal Compliance Inspection† 8 FSE Inventory Management Inspection† 32 Total Actions Taken 163 * Conducted by Private Contractor † Conducted by OCSD

10.3 Another element of the FOG Control Program is enforcement, typically in the form of a compliance inspection. Such an inspection is conducted on an as-needed basis, usually following up a previous inspection or correspondence issue, such as a CAN or NOV or a failure to submit a required report. Since the objective is to gain the FSE’s cooperation and voluntary compliance, the general approach is to conduct a tactful compliance inspection, review the permit requirements and FOG regulations, and provide forms and educational materials that would help assist the FSE’s return to compliance. The table above also shows the breakdown of compliance inspections performed over the past fiscal year.

FOG Control Program Effectiveness

Monitoring the effectiveness of the FOG Control Program enables OCSD to refine its program implementation as necessary to comply with its requirement to eliminate preventable SSOs. OCSD uses a geographic information system (GIS) to analyze the relationship between trouble spots, FSEs, and SSOs. Areas of concern are evaluated and prioritized based on the impact of FSE proximity, tributary residential density, and FOG accumulation in the sewer line (as determined by both CCTV and field crew observations). In combination with efforts of the Collections Division, the FOG Control Program is effectively reducing FOG discharge to the sewer, which resulted in fewer spills. Data from the past two fiscal years are presented below:

TABLE 10.7 FOG Control Program Effectiveness, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Spills FY 2008-09 FY 2009-10 Collection system spills attributable to FSE FOG 0 0 Collection system spills attributable to residential FOG 1 2 Private lateral spills attributable to FOG 0 2 Total FOG-related Spills 1 4

10.3.2 FOG Residential

Background FOG contributing to SSOs is also from residential sources. The discharge of FOG to the sewer is especially critical when there is a high concentration of residents in a small area, such as an apartment, townhome, and condominium complex. Dealing with this issue is challenging, because OCSD relies on residential education and outreach programs to help achieve an awareness of the proper method for disposing of FOG.

FOG Implementation Plan In September 2006, OCSD developed a Residential Outreach Program. OCSD created focused outreach materials specifically to address FOG discharge from high-density and single-family residences. OCSD’s program has both proactive and reactive components. The materials used and their intended audiences are summarized below.

10.4

TABLE 10.8 FOG Residential Outreach Materials, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Proactive or Notification Newsletter Grease Can Audience Poster Postcard Other Reactive Letter Ads Can Liner Apartment Both       Complexes Town Home/Condo Both       Associations Single Family Both   Owner Cities of Tustin and public service Orange Proactive  announcements, website

Proactive Outreach

For those residents living close to a trouble spot, OCSD conducts proactive outreach to provide those residents with focused outreach materials (e.g., Kitchen BMPs) to reduce FOG discharged to the sewer. Over the past fiscal year, OCSD targeted a significant number of households that are tributary to its worst trouble spots. The counts for each are listed below.

TABLE 10.9 FOG Residential Proactive Outreach, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Count Households targeted 3,830 Trouble spots tributary to households targeted 14

Another effort is the distribution of FOG Move-in Kits. At a bi-monthly group meeting of T.E.A.M., the Tustin Effective Apartment Managers association, a cooperative program facilitated by the City of Tustin Community Services Program, the group had asked OCSD to provide FOG information to the T.E.A.M. members. In March 2010, OCSD gave a presentation about FOG-related SSOs and using kitchen BMPs. At the presentation, OCSD also introduced the FOG Move-in Kits for new tenants who move into the City of Tustin. In June 2010, FOG Move-in Kits were distributed to the interested T.E.A.M. members.

Reactive Outreach

Occasionally, FOG-related SSOs still do occur. When there is an incident, OCSD uses GIS and spill notification data to delineate the residential sewershed contributing to the SSO and identifies residential addresses to target the outreach, which typically consists of notifying the residents of the spill and providing them with outreach materials to encourage kitchen BMPs to reduce FOG discharges, thereby minimizing a recurrence of an SSO. The SSOs to which OCSD responded over the past fiscal year are described below.

10.5

TABLE 10.10 FOG-Related SSO Responses, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Date Location Response Near 600 6th Street and west of B Distributed focused FOG BMP materials to residents at the 10/18/2009 Street, City of Tustin nearby condominium complex (~188 condos) Near 13628 Estero Circle, City of Distributed focused FOG BMP materials to 50 neighboring 1/6/2010 Tustin apartments Intersection of Park Skyline and Distributed focused FOG BMP materials to 73 parcels 1/30/2010 Skyline Drive, City of Tustin (single-family homes) in the neighborhood

10.4 RADIATOR SHOPS

The Radiator Shop Certification Program aims to prevent the sewer discharge of heavy metals, oil and grease, or other solvent-containing wastes from the repair and rebuilding of radiators. The program consists of a biennial certification that the facility complies with the following requirements:

1) does not discharge any industrial wastewater to the sewer, 2) all floor drains in the wet process areas are permanently sealed, 3) any wastewater recycling system is not connected to the sewer, and 4) maintains its wastehauling records on-site and must make them available for review upon request.

After the certification has been submitted, an audit inspection is conducted to verify the information. Fiscal Year 2009/10 was a year for recertification. The statistics for the recertification are itemized in the following table.

TABLE 10.11 Radiator Shops Program, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Activity Count Certification notification letters sent 30 Certifications submitted 26 Audit inspections conducted 25 Radiator shops out of business 2 Permitted radiator shops 28

Follow-up certification enforcement and inspections will be continued during the next fiscal year.

10.5 DRY CLEANERS

To prevent soil and groundwater from being contaminated with perchloroethylene (perc) and other dry cleaning solvents, OCSD implemented a program to control and eliminate the sewer discharge of solvent- containing wastes from dry cleaning operations. Of primary concern is the contaminated water from the solvent/water separator (separator water), which is typically managed either by wastehauling off-site or by performing on-site evaporation. The program consists of requiring dry cleaning establishments to certify annually that the following are true: 1) no solvent-containing wastes are discharged to the sewer, 2) there is no connection to the sewer from any dry cleaning apparatus, 3) floor drains are secured from spills and accidental discharges, and 4) all solvent waste is either wastehauled off-site or evaporated. Furthermore, each facility must maintain their wastehauling records on-site and make them available upon request. After

10.6 receipt of the certifications, audit inspections are conducted to verify the information. An inventory count by the type of dry cleaning process used in OCSD’s jurisdiction is listed in the table below. At this time, only the Perc and Agency-Only shops with equipment are inspected by OCSD.

TABLE 10.12 Dry Cleaner Inventory, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Count Perchloroethylene (Perc) Facilities 136 Hydrocarbon (Petroleum) Facilities 171 Green Earth (D5-Siloxane) Facilities 29 Agency-Only Facilities (With Equipment On Site) 14 Agency-Only Facilities (No Equipment On Site) 128 Aqueous Cleaning ( Wet-Washing) Facilities 24 Total Facilities 502 Dry Cleaning Facilities out of business 4

In July 2009, OCSD mailed out the initial notification letter and annual Certification form for Fiscal Year 2009/10 to 368 dry cleaning shops. Submittals were tracked, and information regarding ownership, solvent(s) used, and the number and model/year of the dry cleaning machines were updated as necessary. During the second quarter, dry cleaning facilities that had not already submitted their certifications were phoned or visited to remind them to submit the certifications. Contacting the dry cleaners revealed that many required assistance to complete the forms due to language issues. This effort accounted for the majority of the forms received in the second quarter. In January 2010, inspection reports were distributed to OCSD’s field staff for verifying the current ownership of the facility, shop operations and waste handling procedures, wastehauling records, and floor drain spill containment. By March 2010, 366 certifications had been returned (99.5%) and entered into the database. New certification forms were hand delivered to the two outstanding dry cleaners; depending on their responses, enforcement actions may be required. The statistics from this year’s recertification are listed below.

TABLE 10.13 Dry Cleaner Program, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Activity Count Certification notification letters sent 368 Certifications submitted 366 Audit inspections conducted 366 Pending enforcement actions 2

Enforcement actions and inspections will be continued during the next fiscal year.

10.6 URBAN RUNOFF

Urban Runoff is contaminated wastewater that is the result of daily activities such as over-irrigating landscape, cleaning streets and sidewalks, and washing cars. This wastewater contains numerous pollutants, such as pesticides, heavy metals, toxic organics, pathogens, and other pollutants that flow into storm drain systems and are eventually discharged onto the shoreline, causing beach closures.

10.7 Dry Weather Diversion Systems and Urban Runoff Flow

To help reduce impacts to Orange County beaches, OCSD has been working closely with the state and local agencies in Orange County to divert urban runoff into OCSD’s sewer system for treatment during the dry- weather season from April to October. Details on the individual diversion locations, average discharge volumes, and trunkline/tributary destinations are shown in the table below.

TABLE 10.14 Average Urban Runoff Discharge Volume by Diversion, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Average Urban Runoff Diversions Location Trunkline Tributary Discharge (MGD)*

No. Description Owned and Managed by City of Huntington Beach Coast (via Atlanta 1 Atlanta Pump Station 8151 Atlanta Avenue Plant 2 0.18 Interceptor) 2 Banning Pump Station 2201 Malibu Lane Miller-Holder Plant 2 0.10

Coast (via Atlanta 3 Newland Pump Station 8612 Hamilton Street Plant 2 0.19 Interceptor) a 4 Indianapolis Pump Station 9221 Indianapolis Miller-Holder Plant 2 0.03 5 Hamilton Station 10101 Hamilton Avenue Miller-Holder Plant 2 0.12

6 Meredith Pump Station 20192 Mainland Lane Miller-Holder Plant 2 0.02 b 7 Flounder Pump Station 9731 Flounder Drive Bushard Plant 2 0.01

8 Yorktown Pump Station 9211 Yorktown Avenue Miller-Holder Plant 2 0.01 9 Adams Pump Station 19661 Chesapeake Lane Miller-Holder Plant 2 0.03

10 Scenario Pump Station 4742 Scenario Drive Knott Plant 1 0.02 c 11 1st Street PCH CDS 1ST and PCH Coast Plant 2 0.002 Owned and Managed by County of Orange d 12 Talbert Channel Yorktown Avenue Miller-Holder Plant 2 0.10 e 13 Greenville-Banning Channel Atlanta Avenue Interplant Plant 2 0.43 Huntington Beach Pump 8092 Adams Avenue, Coast 14 Plant 2 0.18 Station Huntington Beach (via Delaware) f 15 Santa Ana River Channel Adjacent to OCSD Plant 1 Sunflower Plant 1 0.13 Owned and Managed by Irvine Ranch Water District Pacific Coast Highway 16 Los Trancos Pump Station South Coast Plant 2 0.14 across Crystal Cove Pacific Coast Highway 17 Muddy Canyon Pump Station South Coast Plant 2 0.01 across Crystal Cove Owned and Managed by City of Newport Beach

Newport Dunes (Gravity South Coast g 18 1131 Back Bay Dr. NB Plant 2 0.05 Flow) (via Back Bay) Owned and Managed by The Irvine Company Pelican point Dr. and 19 Pelican Point South Coast Plant 2 0.10 Cameo Shores Rd. Total of the Average Daily Discharges (July 2009 - June 2010) 1.76 MGDh

10.8 TABLE 10.14 Average Urban Runoff Discharge Volume by Diversion, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division

Average Urban Runoff Diversions Location Trunkline Tributary Discharge (MGD)* *MGD = Million Gallons per Day a. Indianapolis - System shut down Oct 1 thru Nov 30, ten month daily average (Jul, Aug, Sep, Dec, Jan, Feb, Mar, Apr, May, Jun). b. Flounder - System shut down Sep 1 thru Nov 30, nine month daily average (Jul, Aug, Dec, Jan, Feb, Mar, Apr, May, Jun). c. 1st Street CDS – System shut down Nov 1 thru Apr 14. No effluent flow meter, daily average is based on flow study. d. Talbert – System shut down Jan 1 thru Feb 28, ten month daily average (Jul, Aug, Sep, Dec, Jan, Feb, Mar, Apr, May, Jun). e. Greenville-Banning – System shut down Jul 1 thru Jan 31 & Apr 1 thru May 31, three month daily average (Feb, Mar, Jun). f. Santa Ana River – System shut down Nov thru May, five month daily average (Jul, Aug, Sep, Oct, Jun). g. Newport Dunes – System shut down Jan 1 thru Mar 31. No effluent flow meter, daily average is based on flow study. h. Individual daily averages calculated using (cumulative flow total for the year / number of discharge days).

Figure 10.1 is a map of the diversion system locations, and Figure 10-2 shows the average gallons per day diverted by month.

Proposed Urban Runoff Diversion Systems

The County of Orange and several coastal cities are also proposing to construct additional diversion systems. The anticipated flow from the proposed diversion projects is expected to add 1.7 MGD of urban runoff to the current volume received by OCSD. Because of the limited collection and treatment capacity, OCSD established a maximum collection limit of 10 MGD of urban runoff. Pursuant to OCSD’s current Dry Weather Urban Runoff Policy, no fees or charges are to be imposed until the accumulative discharge of urban runoff from all sources exceeds 4 MGD; however, when the discharge surpasses 4 MGD, OCSD will impose an operation and maintenance fee, along with any related administrative costs, to cover the cost of treating this flow. OCSD has been working with the Orange County Resource Development and Management Department (OCRDMD) to prioritize these proposed diversion projects to ensure that OCSD’s limited capacity is utilized effectively, while helping to improve water quality. During this fiscal year, the total urban runoff volume remained at less than half of the 4-MGD threshold for eleven out of twelve months, and no new permits were issued. Pertinent statistics are summarized below.

TABLE 10.15 Urban Runoff Program, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Item Count New permits issued 0 Permitted diversions 19 Total average daily discharge 1.76 MGD Daily discharge range on a monthly basis 0.538 - 2.21 MGD Proposed diversions 23 Proposed additional daily discharge 1.7 MGD Urban Runoff Payment Threshold 4 MGD Urban Runoff Cap 10 MGD

10.9

Figure 10-1 Dry Weather Urban Runoff Diversion System Locations in Orange County

10.10

Figure 10-2 Average Gallons per Day of Dry Weather Urban Runoff Diverted into the OCSD Sewer System for Treatment

10.11 Dry Weather Urban Runoff Quality

As illustrated in Figure 10-1 above, the diversion systems are located within four delineated watersheds in Orange County: Talbert/Greenville-Banning, Lower Santa Ana River, Costa Mesa/Newport, and Los Trancos/Muddy Canyon. These watersheds encompass a variety of designated land uses such as residential, commercial, industrial, and agriculture. OCSD conducts sampling and analysis of the urban runoff discharges to ensure discharge limit compliance for the various regulated constituents. The table below summarizes the minimum and maximum concentrations detected in the urban runoff during the reporting period. For comparison, OCSD’s permitted Instantaneous Discharge Limits are also listed.

TABLE 10.16 Urban Runoff Compliance, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Minimum Maximum Instantaneous Constituent Concentration Concentration Discharge Limit (mg/L) Reported (mg/l) Reported (mg/L) Ammonia N ND* (<.05) 4.81 N/A BOD ND (<20) 60 N/A TSS ND (<10) 2220 N/A Cadmium ND (<.01) 0.03 1.0 Chromium ND (<.01) 0.03 2.0 Copper ND (<.01) 0.29 3.0 Lead ND (<.02) 0.08 2.0 Nickel ND (<.01) 0.08 10.0 Zinc ND (<.02) 2.44 10.0 Oil & Grease Min. ND (<.7) 9.23 100 Sulfide (Dissolved) ND (<.1) 14.0** 0.5 Sulfide (Total) ND (<.1) 4.65 5.0 Pesticides ND (<.002) 0.004 0.01 Total Toxic Organics ND (<.01) 0.001 0.58

*ND - Non-Detectable (below analytical detection limits) **One exceedance of the instantaneous discharge limit for dissolved sulfide during this annual reporting period.

10.7 CONSTITUENTS OF EMERGING CONCERN

In January 2008, OCSD and OCWD commissioned the Ground Water Replenishment System (GWRS), which reclaims up to 70 MGD of treated effluent from OCSD and processes it into drinking water for indirect reuse. Because of the very stringent drinking water quality limits, even low levels of constituents from residential and commercial facilities, such as pharmaceuticals, personal care products, and household chemicals, are presenting challenges to water reclamation. Therefore, as part of the permits for the GWRS, OCSD is required to implement an expanded Source Control Program, also referred to as the NISC Program, to address CECs from all sources.

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10.7.1 Countywide Pollution Prevention Partnership Program (C4P)

Since the startup of the GWRS, OCSD continued to strategize and enhance its source control programs to target CECs. However, the diffuse nature of the CECs and the volume of light industrial, commercial, and residential dischargers throughout OCSD’s service area required a strategy to conduct outreach to these dischargers while operating with limited resources. In June 2009, OCSD formally introduced the C4P Program to its member agencies at a kickoff meeting. OCSD reviewed the C4P Program objectives, presented an overview of the secure web portal (extranet) for ordering materials and facilitating communications among members, and indicated that OCSD would contact each agency to review and reinforce the C4P Program. During this fiscal year, OCSD completed the follow-up visits to the member agencies and provided guidance on how to utilize the C4P extranet to communicate media requests from OCSD. The C4P Program saw modest utilization.

Participating agencies also requested, received, and distributed materials on behalf of the C4P Program. Items include public service announcements (PSAs), prepared newsletter articles, magnets, pens, utility bill inserts, and freestanding kiosk banners, which OCSD developed and produced. Below is a summary of the materials procured and distributed. In whole, 11 of the 22 participating C4P agencies assisted OCSD’s efforts.

TABLE 10.17 C4P Materials Distributed, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Participating Bill Inserts Info Cards Kiosks Public Service Announcements Agency Anaheim NDDTD Cypress Pharm (18,400) NDDTD HHW(100), Pharm(100) Fountain Valley Garden Grove Irvine HHW (1,800); Pharm (1,000) Pharm (2) Orange Pharm (1000) Pharm (2) Placentia Pharm (2) Santa Ana HHW (500); Pharm (500) Pharm(500) Pharm (1) Stanton NDDTD Tustin NDDTD Pharm (2) Program Codes: NDDTD: No Drugs Down the Drain HHW: Household Hazardous Waste Pharm: Pharmaceuticals (#): Number of items

NISC Program Outreach Accomplishments

As a part of the C4P Program, OCSD coordinated with watershed protection staff from other agencies and participated in outreach events where the public received coordinated communication about what is allowed to the sewer and storm drain. At these events, OCSD typically staffed a booth or gave a talk. OCSD initiated conversations with the public, introduced water quality protection concepts, and presented topics relating sewage discharge to water reclamation needs. The outreach events resulted in approximately 1,200 conversations with members of the public. In addition, OCSD also distributed handout materials and give-away items it developed, so that the public has a vehicle by which to recall

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the conversation later. A listing of the outreach events in which OCSD participated and the presentations which OCSD gave is summarized in the tables below.

TABLE 10.18 C4P Outreach Events, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Date Event Audience Subject(s) 9/2009 Public Works Open House Residents of Irvine NISC 9/2009 Pollution Prevention Awareness County of Orange employees NISC 10/2009 Public Works Open House Residents of Garden Grove NISC 10/2009 Tustin Tiller Days Residents of Tustin NISC 11/2009 Yorba Linda City Council Meeting Yorba Linda Council members C4P 12/2009 Christmas Holiday Residential 5 high-density residential sites in FOG Control Outreach Distribution City of Tustin 1/2010 Superbowl Residential Outreach 8 high-density residential sites in FOG Control Distribution City of Tustin 4/2010 Earth Day Agnes L. Smith Elementary School NISC 6/2010 Street Faire and Chili Cook-Off Residents of Tustin NISC

TABLE 10.19 NISC Presentations, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Date(s) Audience Subject 9/2009 LA County Sanitation District NISC Program Presentation 2/2010 Southern California agencies FOG Program 3/2010 City of Tustin T.E.A.M. Association Meeting members. FOG 5/2010 4/2010 California Pharmacists Association pharmaceutical disposal 5/2010 University of California Irvine Wellness and Safety Fair pharmaceutical disposal, household hazardous waste 5/2010 Industrial Environmental Coalition of Orange County NISC Program, SPDPs, GWRS 5/2010 City of San Diego Reservoir Augmentation Team NISC Program 5/2010 Southern California Alliance of Publicly Owned NISC Program Treatment Works (SCAP) Water Issues Committee Meeting

10.7.2 Pharmaceuticals

OCSD’s NISC Program is also addressing pharmaceuticals. Studies by the USGS and others have indicated the presence of some pharmaceuticals in receiving waters downstream of wastewater treatment plants, in drinking water, and in biosolids.

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10.7.2.1 Residential “No Drugs Down the Drain”

One source of the pharmaceuticals in the sewers is residents flushing unused and unwanted medications down the toilet. Because of the magnitude of the efforts required, a regional Pharmaceuticals Program was launched in April 2006. The original members included Los Angeles County Sanitation District, City of Los Angeles Bureau of Sanitation, City of San Diego, and OCSD. Since then, new agencies have joined, including the Inland Empire Utility Agency, City of Riverside, and Municipal Water District of Orange County. The product of this collaboration is the “No Drugs Down the Drain” (NDDTD) Program. For details, visit the www.nodrugsdownthedrain.org website.

For residential pharmaceuticals in OCSD’s area, OCSD partnered with Orange County Waste and Recycling to develop disposal options. With the support of the California Pharmacists Association, OCSD then distributed posters and postcards with program information in English and Spanish to local area pharmacies to raise awareness of disposal options. The posters keep the public informed about the program should the postcards temporarily be unavailable. Pharmacies were requested to display the poster and include the card in the packages when the public picked up their medications. On an annual basis, pharmacies in the program are visited to determine if additional program materials need to be delivered. Periodically lists of pharmacies in OCSD’s service area are obtained. Any new pharmacies that are identified are visited, and an introduction to the program and program materials are provided to a pharmacist on duty. Through the C4P Program, OCSD also disseminated NDDTD program information to local communities through water bills and other media. For more information, refer to the C4P program.

During the next fiscal year, OCSD will continue to deliver additional program information to the pharmacies and participate in public outreach events.

10.7.2.2 Pharmaceuticals – Industrial Manufacturers

Because pharmaceutical manufacturers are a significant potential source of pharmaceuticals to the sewer, during this fiscal year OCSD implemented a program to address these dischargers also. Each of the existing permitted pharmaceutical manufacturers was inspected in relation to their production, waste generation, and waste handling and disposal practices. Most discharges result from wash down operations for cleaning equipment. Although all manufacturers complied with sampling requirements under the existing federal categorical standards, current categorical standards do not include any limits for pharmaceutical discharges. After the initial inspections, OCSD met with each pharmaceutical manufacturer and developed an interim solution in lieu of no discharge standards for pharmaceutically- active compounds (PhACs). All pharmaceutical manufacturing permits were revised to include requirements for reporting all PhACs manufactured and for wastehauling all bad batches. By the end of the fiscal year, all PhACs manufacturers reported on what they had manufactured, and a database was established. Should any particular PhAC become a problem, OCSD will know all manufacturing sources and the approximate volumes discharged, and OCSD will be able to meet with the appropriate manufacturers to address any potential problem.

During the next fiscal year, OCSD will monitor the situation and make enhancements as resources allow.

10.7.2.3 Pharmaceuticals – Commercial Health Service Facilities

The third tier of the Pharmaceutical Program addresses commercial-based entities known as “Health Service Facilities” (HSFs). OCSD identified HSFs through contact with the two county agencies that oversee the combined group of HSFs of interest to OCSD. Seven hundred fifty-one commercial HSFs within OCSD’s service area were identified and surveyed to determine their potential for discharge not in conformance with existing Pharmaceuticals Program guidelines. However, OCSD became aware that EPA is currently studying HSFs and will report their findings during the next fiscal year. Therefore,

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OCSD has suspended further action for now. Upon the report’s release, OCSD will review EPA’s findings and recommendations about HSFs then develop a commercial Pharmaceutical Program.

10.7.3 Pollutant Prioritization

Due to a large number of CECs that would need to be monitored and potentially controlled and in an effort to implement a practical source control program with the limited resources available, OCSD began a project to prioritize the constituents to identify a short list of Priority Pollutants. For example, there are 148 CECs that are currently regulated under Title 22 of California’s Code of Regulations, and there are numerous other public health goals established by the Department of Health services. There are also unregulated CECs that have no known immediate or apparent toxicity at low concentrations but are known to be persistent in the environment. By targeting the constituents needing the most attention, OCSD can better ensure that source control efforts are focused where they are needed to achieve maximum pollutant reduction efficiently.

To derive the Priority Pollutant list, sampling and characterization of CECs were conducted on the influent and secondary effluent streams of OCSD Reclamation Plant No. 1. The study was conducted in four phases over a period of 24 months from April 2007 to April 2009 to obtain a representative average. Sampling in this manner achieved the following objectives:

1) The sampling helped determine whether any CECs are formed within OCSD’s treatment processes. This provided a reasonable assessment whether the CEC concentration levels are significant enough to impact the maximum allowable concentration levels at the GWRS effluent.

2) The sampling also provided information for determining the removal rates of pollutants at OCSD’s treatment plants that can be used to establish pollutant action levels.

Prioritization is based on the CECs reasonable potential to affect GWRS in meeting the required standards. Identifying the pollutants that need to be controlled and regulated from this perspective serves as the starting point for formulating and implementing effective source control strategies. Of the 433 constituents that were sampled, 287 were detected. The following 22 Priority Pollutants were identified for further investigation.

TABLE 10.20 Priority Pollutants, Fiscal Year 2009-10 Orange County Sanitation District, Source Control Division Base Neutral Acid Semi-Volatiles Volatile Organic Compounds 1,4-dichlorobenzene methylene chloride bis(2-ethylhexyl)phthalate tert-butyl alcohol 2,4,6-trichlorophenol 1,4-Dioxane and Nitrosamines Aldehydes and Oxyhalides 1,4-dioxane Formaldehyde N-nitrosodimethylamine Perchlorate N-nitrosomorpholine Metals Inorganics aluminum iron Total Kjeldahl Nitrogen antimony manganese Total Dissolved Solids arsenic mercury boron nickel chromium vanadium

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The Priority Pollutants were organized by their functional uses into commercial sectors for further review. Currently, commercial sector impact analysis is being conducted on three sectors: cleaners and degreasers, coatings, and coloring agents and dyes. The purpose of this analysis is to characterize and quantify the collective discharges of priority CECs from various commercial sectors that have been identified to be potential sources. Comparing this information with OCSD’s influent loading will determine whether a particular sector is a significant contributor and will provide data on whether a sector source control program is needed. The scope of the implementation plan includes the following: Wastewater Characterization: OCSD is analyzing discharges from commercial sectors that are potential sources of priority CECs to confirm their presence and determine concentration levels.

Determination of Sector Contribution: OCSD will estimate the pollutant loadings from commercial sectors and the collective loading from all sources and will compare them with the influent loading to OCSD to assess the extent of each sector’s contribution.

Impact Analysis: OCSD will analyze source control options available to reduce the discharge of CECs from the identified sources; estimate the load reductions that may be achieved; itemize the time and material costs required; analyze adverse impacts to commercial businesses; and conduct a cost-benefit analysis.

During the next fiscal year, OCSD will continue to work on the pollutant prioritization and sector-based investigations.

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