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2018 Point Loma Pretreatment Report

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2018 Point Loma Pretreatment Report SAN DIEGO') Public Utilities Department Environmental Monitoring and Technical Services Division March 20, 2019 VIA E-MAIL Mr. David W. Gibson, Executive Officer California Regional Water Quality Control Board 2375 Northside Drive, Suite 100 San Diego, CA 92108 Subject: 2018 Pretreatment Annual Report for the Point Loma POTW Board Order No. R9-2017-0007 Dear Mr. Gibson: An amended San Diego Wastewater Pretreatment Program Annual Report is hereby submitted in accordance with the requirements of NPDES Permit No. CA0107409, adopted by the Regional Water Quality Control Board on April 12, 2017 and issued by the U.S. Environmental Protection Agency on October 1, 2017. Because flows from industries tributary to the South Bay Water Reclamation Plant can be diverted to the Point Loma POTW, this Report also includes data for industries tributary to the South Bay Water Reclamation Plant and Ocean Outfall. The City is committed to protecting public health and the environment through a program of environmental management, which includes source control, wastewater treatment, an improved ocean outfall, and extensive monitoring. One key element of the program is an aggressive pretreatment and pollution prevention program to minimize toxic discharges to the sewerage system. This report includes a summary of Pretreatment Program activities and accomplishments throughout jurisdictions tributary to the Metropolitan Sewerage System, which includes the Point Loma Wastewater Treatment Plant, the North City Water Reclamation Plant, and the South Bay Water Reclamation Plant. The Industrial Wastewater Control Program (IWCP) was created in 1982 after being formally approved by the U.S. Environmental Protection Agency. Since that time, significant enhancements have been made to the program including: (1) implementation of an Enforcement Response Plan in 1987, (2) implementation of an Annual Local Limits Re­ Evaluation in 1998, and (3) establishment of a focused Enhanced Source Control group in 2003. However, with the exception of these enhancements, the program has not changed significantly since its inception. With the City's Pure Water Program coming on-line, the Public Utilities' Department determined that critical evaluation of the IWCP and its effectiveness in protecting human and environmental health was necessary. In June 2018, the City embarked on an evaluation of the IWCP by engaging two external consultants with extensive experience in managing and evaluating large municipal pretreatment programs. The City's IWCP was evaluated for the following six areas including: (1) Permit processing, (2) Compliance inspection, (3) 2392 Kincaid Rd, Mail Station 45A T (619) 758-2301 San Diego, CA 92101 sandiego.gov [email protected] Page 2 Mr. David W. Gibson March 20, 2019 Compliance enforcement, (4) Industrial discharge monitoring, (5) Records management, and (6) Organization. Multiple areas for improvement were documented. Beginning April 20, 2019, major changes to the IWCP will occur that will improve management oversight, work processes, efficiencies, and data quality. It is the Department's plan that all changes should be implemented by the end of calendar year 2019. This report was generated using the current data available in the IWCP's Pretreatment Information Management System (PIMS). The consultants identified issues with how some data are managed within the PIMS, and actions to correct these deficiencies are underway. Until these corrections are made, the state of the data presented here is the most accurate the program is able to provide. However, the program has flagged data on several pages throughout the report to indicate numbers that are expected to change once programmatic improvements occur. Brief explanations regarding how and why numbers may change are provided where applicable. Should you have any questions concerning the information provided herein, or wish to discuss the report in detail, please contact John Steger of my staff, at (858) 654-4103. Sincerely, L ~~ Peter S. Vroom, Ph.D. Deputy Director, Public Utilities Department JAS/rd cc: [email protected] John Helminski, Assistant Director of Public Utilities, City of San Diego 2392 Kincaid Road Mail Station 45A T (619) 758-2301 San Diego, CA 92101 sandiego.gov [email protected] P01W PRETREATMENT ANNUAL REPORT COVERSHEET NPDES Permit Holder or Sewer Authority Name: =C=ity.y~o=f~S=a=n~D=1=·eceg-=o__ ________ Report Date: =M=a=r=c=h....,.1.,...1 =2=-o-19L--------- ---­ Period Covered by This Report: January 1, 2018 to December 31 1 2018 Period Covered by Previous Report: January 11 2017 to December 31, 2017 Name of Wastewater Treatment Plant(s) Point Loma Wastewater Treatment Plant NPDES Permit Number =C=A~O=l=Oc-,.7.,,.4=0_.,,_g ____________ Person to contact concerning information contained in this report: Name: John Steger Title: Industrial Wastewater Control Program Manager Mailing Address: 9192 Topaz Way, MS 901D San Diego, CA 92123-1119 Telephone No.: (858) 654-4103 I have personally examined and am familiar with the information submitted in this document and attachments. Based upon my inquiry of those individuals immediately responsible for obtaining the information reported herein, I believe that the submitted information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. ~ 1-;Jo-acict ~~ Date Peter Vroom, Ph.D. Deputy Director Public Utilities PRETREATMENT ANNUAL REPORT PCS Data Entry Form PPS1 POTW NAME: City of San Diego EW Blom Point Loma Metropolitan Wastewater Treatment Plant Includes Industrial Users tributary to the City of San Diego South Bay Water Reclamation Plant and Ocean Outfall NPDES Permit #: CA0107409 and CA0109045 Period Covered by This Report: 01/01/18 (PSSD) 12/31/18 (PSED) Start Date End Date Number of Significant Industrial Users in SNC with 0 (SSNC) Pretreatment Compliance Schedule: Number of Notices of Violation and Administrative Orders 193 (FENF) Issued Against Significant Industrial Users: Number of Civil & Criminal Judicial Actions against 0 (JUDI) Significant Industrial Users: Number of Significant Industrial Users with Significant 11 (SVPU) Violations Published: Number of Industrial Users from Which Penalties Have 0 (IUPN) Been Collected: E.W. BLOM POINT LOMA METROPOLITAN WASTEWATER TREATMENT PLANT PRETREATMENT ANNUAL REPORT NPDES PERMIT NO. CA 0107409 SDRWQCB ORDER NO. R9-2017-0007 JANUARY 1 – DECEMBER 31, 2018 Environmental Monitoring and Technical Services Public Utilities Department 2392 Kincaid Road Mail Station 45A San Diego, CA 92101 CERTIFIED Tel (619) 758-2310 • Fax (619) 758-2309 ISO 14001 INFORMATION ABOUT THIS REPORT The Industrial Wastewater Control Program (IWCP) was created in 1982 after being formally approved by the U.S. Environmental Protection Agency. Since that time, significant enhancements have been made to the program including: (1) implementation of an Enforcement Response Plan in 1987, (2) implementation of an Annual Local Limits Re- Evaluation in 1998, and (3) establishment of a focused Enhanced Source Control group in 2003. However, with the exception of these enhancements, the program has not changed significantly since its inception. With the City’s Pure Water Program coming on-line, the Public Utilities’ Department determined that critical evaluation of the IWCP and its effectiveness in protecting human and environmental health was necessary. In June 2018, the City embarked on an evaluation of the IWCP by engaging two external consultants with extensive experience in managing and evaluating large municipal pretreatment programs. The City’s IWCP was evaluated for the following six areas including: (1) Permit processing, (2) Compliance inspection, (3) Compliance enforcement, (4) Industrial discharge monitoring, (5) Records management, and (6) Organization. Multiple areas for improvement were documented. Beginning April 20, 2019, major changes to the IWCP will occur that will improve management oversight, work processes, efficiencies, and data quality. It is the Department’s plan that all changes should be implemented by the end of calendar year 2019. This report was generated using the current data available in the IWCP’s Pretreatment Information Management System (PIMS). The consultants identified issues with how some data are managed within the PIMS, and actions to correct these deficiencies are underway. Until these corrections are made, the state of the data presented here is the most accurate the program is able to provide. However, the program has flagged data on several pages throughout the report to indicate numbers that are expected to change once programmatic improvements occur. Brief explanations regarding how and why numbers may change are provided where applicable. Peter S. Vroom Deputy Public Utilities Director TABLE OF CONTENTS Chapter Subject Page Chapter 1: Executive Summary Executive Summary ……………………………………………………… 1-1 1.1 Introduction ………………………………………………………………. 1-1 1.2 Program Effectiveness ……………………………………………………. 1-1 1.3 Program Summary ………………………………………………………. 1-1 Chapter 2: Program Structure 2.1 Program Jurisdiction ……………………………………………………. 2-1 2.2 Program Organization ……………………………………………………. 2-1 Area Map ………………………………………………………………. 2-2 Org Chart ………………………………………………………………. 2-3 2.3 Personnel and Budget ……………………………………………………. 2-4 2.4 Program Changes and Developments ……………………………………. 2-4 2.5 Household Hazardous Waste Program ………………………………… 2-5 2.6 Storm Water Compliance Inspections …………………………………….
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