City of Burlingame NPDES Permit Fact Sheet Order No. 02____
NPDES Permit No. CA0037788 p. 1 of 18
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
1515 CLAY STREET, SUITE 1400
OAKLAND, CA 94612
(510) 622 – 2300 Fax: (510) 622 - 2460
FACT SHEET
for
NPDES PERMIT and WASTE DISCHARGE REQUIREMENTS for
CITY OF BURLINGAME
Wastewater Treatment Plant
BURLINGAME, SAN MATEO COUNTY
NPDES Permit No. CA0037788
TABLE OF CONTENTS
I. PUBLIC NOTICE: 3
1. Written Comments 3
2. Public Hearing 3
3. Additional Information 3
II. INTRODUCTION 3
III. DESCRIPTION OF EFFLUENT 4
IV. GENERAL RATIONALE 5
V. SPECIFIC RATIONALE 6
1. Recent Plant Performance 6
2. Impaired Water Bodies in 303(d) List 6
3. Basis for Prohibitions 7
4. Basis for Effluent Limitations 7
5. Basis for Receiving Water Limitations 17
6. Basis for Self Monitoring Program Requirements 17
7. Basis for Sludge Management Practices 17
8. Basis for Provisions 17
VI. WRITTEN COMMENTS 20
VII. PUBLIC HEARING 20
VIII. WASTE DISCHARGE REQUIREMENT APPEALS 20
IX. ADDITIONAL INFORMATION 21
X. ATTACHED TABLES 21
LIST OF TABLES
Table A. Summary of Effluent Data for Outfall E001 4
Table B. Summary of Reasonable Potential Results 11
Table C. Polynuclear Aromatic Hydrocarbons 14
Table D. Previous Permit Limits for Toxic Pollutants 14
Table E. Water Quality Objectives/Criteria for Pollutants with RP 15
I. PUBLIC NOTICE:
1. Written Comments
- Interested persons are invited to submit written comments concerning this draft permit.
- Comments should be submitted to the Regional Board no later than 5:00 p.m. on October 31, 2001January 21, 2002.
2. Public Hearing
- The draft permit will be considered for adoption by the Regional Board at a public hearing during the Regional Board’s regular monthly meeting at: Elihu Harris State Office Building, 1515 Clay Street, Oakland, CA; 1st floor Auditorium.
- This meeting will be held on: January 16February 20, 2002, starting at 9:00 am.
3. Additional Information
- For additional information about this matter, interested persons should contact Regional Board staff member: Mr. Ken Katen, Phone: (510) 622-2431; email:
This Fact Sheet contains information regarding an application for waste discharge requirements and National Pollutant Discharge Elimination System (NPDES) permit for the City of Burlingame for discharges from the City’s secondary level wastewater treatment plant. The Fact Sheet describes the factual, legal, and methodological basis for the proposed permit and provides supporting documentation to explain the rationale and assumptions used in deriving the limits.
II. I. INTRODUCTION
The City of Burlingame (the Discharger) applied to the California Regional Water Quality Control Board, San Francisco Bay Region, (the Regional Board) for reissuance of its NPDES permit for discharge of pollutants from its wastewater treatment plant (the WWTP) into State Waters.
The Discharger owns and operates the WWTP, which provides secondary level treatment of wastewater from domestic, commercial and industrial sources within the City of Burlingame (present population of about 37,000). The treatment process consists of bar screening, vortex grit removal, two primary clarifiers, biological secondary treatment via activated sludge, secondary clarification, and chlorination. Treated effluent flows via pipeline to the North Bayside System Unit (NBSU) dechlorination facility. In transit or at the NBSU dechlorination facility, treated effluent is combined with effluent from the cities of Millbrae, South San Francisco, and San Bruno and industrial and sanitary wastewater from San Francisco International Airport. The combined effluent is dechlorinated prior to discharge to San Francisco Bay. The Discharger effluent comprises approximately 25 percent of the combined NBSU flow. The Discharger plant has an average dry weather flow design capacity of 5.5 million gallons per day (MGD), an average dry weather flow of 3.56 MGD, an annual average flow of 4.08 MGD (1999 data), and a maximum wet weather flow of 14.17 MGD (1999 data) {do we want to simplify this discussion a la Millbrae?}. Treated wastewater is discharged through the NBSU outfall to waters of San Francisco Bay through a submerged deepwater outfall (lat. 37º39’35”, long. 122º21’41”). The U.S. Environmental Protection Agency (the U.S. EPA) and the Regional Board have classified the WWTP as a major Discharger and a deep water discharge. The plant has an average dry weather flow design capacity of 5.5 million gallons per day (MGD) and a peak wet weather secondary treatment capacity of 16 MGD. The discharger has a primary treatment capacity of 25 MGD and disinfection capacity of 20 MGD. During wet weather operations, the aeration basins and secondary clarifiers may be bypassed, with the final effluent being a blend of disinfected, primary-treated effluent and disinfected, secondary-treated effluent. Blending is done to avoid hydraulic overload of the activated sludge process and associated solids inventory washout. The plant presently discharges an average dry weather flow of 3.56 MGD, an annual average flow of 4.08 MGD, and maximum wet weather flow rate of 14.17 MGD (1999 data).
The receiving waters for the subject discharges are the waters of San Francisco Bay. Beneficial uses for the San Francisco Bay receiving water, as identified in the Basin Plan and based on known uses of the receiving waters in the vicinity of the discharge, are:
- Industrial Service Supply
- Navigation
- Water Contact Recreation
- Noncontact Water Recreation
- Ocean Commercial and Sport Fishing
- Wildlife Habitat
- Preservation of Rare and Endangered Species
- Fish Migration
- Fish Spawning
- Estuarine Habitat
The Order uses the California Toxics Rule (CTR) as the basis for establishing the salinity characteristics (i.e., fresh water vs. salt water) of the receiving water for all water quality objectives (WQO) because the CTR procedures for salinity are more scientifically justified than those in the Basin Plan. Salinity data were obtained from the three Regional Monitoring Program (RMP) stations nearest to the NBSU outfall, Alameda, Oyster Point, and San Bruno Shoal, for the period from 1993 to 1998 to determine the receiving waters’ salinity. This assessment indicates the receiving waters are marine by the CTR’s definition of having salinities above 10 ppt more than 95 percent of the time. Therefore, the Order’s effluent limitations are based on the salt water WQOs.
III. II. DESCRIPTION OF EFFLUENT
Board Order No. 95-208, as amended by Order 98-117 (collectively the previous permit), presently regulates the discharge from the WWTP. The Discharger’s treated wastewater has the characteristics summarized in Table A. For all parameters except organic pollutants - other than phenol and polynuclear aromatic hydrocarbons (PAHs) – the Table A data represent at least monthly monitoring performed from January 1998 through July 2001. For organic pollutants - other than phenol and PAHs – the previous permit required the Discharger to collect and analyze five samples for selected organic parameters during the permit’s term. Those samples were collected from 1997 to1999. Results for detected organic constituents are included in Table A. All other organic constituents were not detected. The average values in Table A reflect the averages of only the detected values for each parameter. Where a parameter was only detected once, the value is included as both the average and maximum.
Table A. Summary of Effluent Data for Outfall E001
Constituent / Average / MaximumpH, range min/max (s.u.) / 7.0 / 8.1
BOD5 (mg/L) / 13 / 74 (29)1
TSS (mg/L) / 13 / 101 (48)2
Arsenic (mg/L) / 1.66 / 4.0
Cadmium (mg/L) / 0.07 / 0.07
Chromium (mg/L) / 1.73 / 4.7
Copper (mg/L) / 9.0 / 17.0
Lead (mg/L) / 2.0 / 4.0
Mercury (mg/L) / 0.047 / 0.554
Nickel (mg/L) / 4.6 / 8.7
Selenium (mg/L) / 0.93 / 1.22
Silver (mg/L) / 1.1 / 4.0
Zinc (mg/L) / 38.7 / 60
Cyanide (mg/L) / 5.0 / 20.5
Phenols (mg/L) / 17 / 48
Polynuclear Aromatic Hydrocarbons (mg/L) / 1.22 (0.3)3 / 1.22 (0.3)3
Total Oil and Grease (mg/L) / 47 / 210
Chloroform (mg/L) / 3.6 / 6.0
Methylene Chloride (mg/L) / 9.2 / 9.2
Toluene (mg/L) / 0.5 / 0.5
Alpha-BHC (mg/L) / 0.04 / 0.04
Dieldrin (mg/L) / 0.075 / 0.075
Footnotes for Table A:
1. Maximum BOD of 74 mg/L reported in January 1999, possibly an unusually high result (next highest was 29 mg/L).
2. Maximum TSS of 101 mg/L reported in January 1999, possibly an unusually high result (next highest was 48 mg/L)
3. Maximum PAH of 1.22 mg/L was reported in January 1998; only other detection is shown in parentheses.
IV. III. GENERAL RATIONALE
The following documents are the bases for the requirements contained in the proposed Order, and are referred to under the specific rationale section of this Fact Sheet.
- Federal Water Pollution Control Act, as amended (the CWA).
- Code Federal of Regulations, Title 40 - Parts 122-129 (40 CFR Parts 122 - 129) - Protection of Environment, Chapter 1, Environmental Protection Agency, Subchapter D, Water Programs.
- The Regional Board’s Water Quality Control Plan, San Francisco Bay Basin(Region 2) (the Basin Plan). The Basin Plan defines beneficial uses and contains WQOs for waters of the State within the San Francisco Bay region, including Lower San Francisco Bay. The Regional Board adopted the Basin Plan on June 21, 1995 , State Water Resources Control Board (the State Board) approved it on July 20, 1995 the Office of Administrative Law approved it on November 13, 1995.
- California Toxics Rule (the CTR), Federal Register, Vol. 65, No. 97, May 18, 2000 .
- National Toxics Rule (the NTR) 57 FR 60848, December 22, 1992, as amended .
- State Board’s May 1, 2000 Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California (the State Implementation Policy, or SIP).
- the U.S. EPA’s 1986 Quality Criteria for Water, 440/5-86-001,.
- The U.S. EPA’s January 1986 Ambient Water Quality Criteria for Bacteria – 1986, 440/5-84-002,.
V. IV. SPECIFIC RATIONALE
Several specific factors affecting the development of limitations and requirements in the proposed Order are discussed as follows:
1.1. Recent Plant Performance
Section 402(o) of the CWA and 40 CFR 122.44(l) require that water quality-based effluent limits (WQBELs) in re-issued permits be at least as stringent as in the previous permit. The SIP specifies that interim effluent limitations, if required, must be based on current treatment facility performance or on existing permit limitations whichever is more stringent. Regional Board staff used best professional judgment (BPJ) to evaluate recent plant performance. Effluent monitoring data collected from 1998 to 2001 are considered representative of recent plant performance, based on the following rationale:
- It accounts for flow variation due to wet and dry years; and
- For most of the organic pollutants, 3 years of data were used as this provides an adequate set of effluent data for determining their reasonable potential.
2. 2. Impaired Water Bodies in 303(d) List
The U.S. EPA Region 9 office approved the State’s 303(d) list of impaired waterbodies on May 12, 1999. The list was prepared in accordance with Section 303(d) of the CWA to identify specific water bodies where it is not expected water quality standards will be met after implementation of technology-based effluent limitations on point sources. The current 303(d) list includes San Francisco Bay as impaired by copper, mercury, nickel, exotic species, total PCBs, dioxin and furan compounds, chlordane, DDT, dieldrin, diazinon, and dioxin-like PCBs.
The SIP requires final effluent limits for all 303(d)-listed pollutants to be based on total maximum daily loads (TMDL) and wasteload allocation (WLA) results. The SIP and federal regulations also require that final concentration limits be included for all pollutants demonstrated to have reasonable potential to cause or contribute to exceedence of water quality objectives (have reasonable potential). The SIP requires permits to establish interim performance-based concentration limits (concentration-based IPBLs), and performance-based mass limits for bioaccumulative pollutants, where the Discharger has demonstrated infeasibility to meet the final WQBELs, together with a compliance schedule for attainment of the final WQBELs. The SIP also requires the inclusion of appropriate provisions for waste minimization and source control in these cases.
3.3. Basis for Prohibitions
a) Prohibition A.1 (no discharges other than as described in the permit): This prohibition is based on the Basin Plan, previous permit and BPJ.
b) Prohibition A.2 (10:1 dilution): This prohibition is based on the Basin Plan. The Basin Plan prohibits discharges not receiving 10:1 dilution (Chapter 4, Discharge Prohibition No. 1). The Basin Plan also identifies exceptions that may be granted under certain conditions.
c) Prohibition A.3 (no bypass): This prohibition is based on the Basin Plan. The Basin Plan prohibits the discharge of partially treated and untreated wastes (Chapter 4, Discharge Prohibition No.15). This prohibition is based on general concepts contained in Sections 13260 through 13264 of the California Water Code that relate to the discharge of waste to State waters without filing for and being issued a permit. Under certain circumstances, as stated in 40 CFR 122.41 (m) and (n), the facilities may bypass waste streams in order to prevent loss of life, personal injury, or severe property damage, or if there were no feasible alternatives to the bypass and the Discharger submitted notices of the anticipated bypass.
d) Prohibition A.4 (flow limit): This prohibition is based on the reliable treatment capacity of the plant. ExceedanceExceedence of the treatment plant's average dry weather flow design capacity of 5.5 MGD may result in lowering the reliability of achieving compliance with water quality requirements, unless the Discharger demonstrates otherwise through an antidegradation study. This prohibition is based on 40 CFR 122.41(l).
e) Prohibition A.5 (no stormwater pollution, toxic and deleterious substances, contamination): This prohibition is based on the Basin Plan to protect beneficial uses of the receiving water from un-permitted discharges, and the intent of sections 13260 through 13264 of the California Water Code relating to the discharge of waste to State Waters without filing for and being issued a permit.
4.5. Basis for Effluent Limitations
a) Effluent Limitations B.1 (Discharges to San Francisco Bay; listed below):
Permit Monthly Weekly Daily Instantaneous
Limit Parameter Units Average Average Maximum Maximum
B.1.a. Biochemical Oxygen Demand (BOD) mg/L 30 45 60 --