NPDES Permit Compliance Action Plan

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NPDES Permit Compliance Action Plan

• Presentation to the
• Galt City Council
• January 24, 2006

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This presentation is structured to outline our
recommended course of action for NPDES compliance.

• Background - Describe the 4 remaining NPDES
  compliance options that received further study
  under this phase of the project.
• Recommendations - Present our recommended
  compliance option and describe the factors that
  support this recommendation.
• Implementation - Recommended next steps, near
  term and long-term.
• Plan Adoption or Modification - Obtain City
  Councils views and input.

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Four discharge/reuse alternatives for NPDES
compliance were evaluated under this phase of the
project.

• Option A Laguna Creek Seasonal Discharge with
  Continued Reclamation
• Option B Laguna Creek Year-Round Discharge
• Option C Sacramento River Discharge
• Option D Zero Discharge with Full Reclamation

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Option A is a Laguna Creek seasonal discharge
alternative.
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TREATMENT WETLANDS
FILTERS
WWTP PROCESS SCHEMATIC FOR OPTION A (WINTER
OPERATION)
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Option B involves discharging to Laguna Creek on
a year-round basis.
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TREATMENT WETLANDS
FILTERS
NEED FOR/ADEQUACY OF WETLANDS IS DEPENDENT UPON
OUTCOME OF WATER QUALITY STUDIES, DILUTION
CREDIT, PILOT TESTING
WWTP PROCESS SCHEMATIC FOR OPTION B
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Option C is a Sacramento River discharge option
requiring construction of a 12 mile long pipeline
and river outfall facilities.
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Option D would eliminate effluent discharge
altogether through reuse and storage.
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Estimated capital costs and OM costs for each
option at 3 mgd
These costs are based on existing information and
assumptions, and are subject to change.
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Comparison of Capital Costs 3 mgd and 6 mgd
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Major Conclusions and Recommendations

• Option D, zero discharge with full reclamation,
  is no longer considered a viable alternative.
• Highest cost alternative
• Acquisition of property in the vicinity of the
  WWTP
• For 3 mgd, competing land interests complicate
  acquisition
• Beyond 3 mgd, remote sites are necessary,
  substantially increasing costs
• Current market value of reclaimed water is low
• Development of properties, and management/operatio
  n of the system will be difficult and complex

Recommendation Eliminate Option D from the list
of alternatives.
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Key Decisions

• Option C Retain until NPDES permit is received
  vs. Abandon in favor of Option A/B
• Option A Retain until benefits of dilution are
  known vs. Abandon in favor of Option B
• Option B Pursue now and abandon Options A C
  vs. Retain as the fallback option

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Major Conclusions and Recommendations

• Laguna Creek discharge (Options A and B) and
  Sacramento River discharge (Option C) are
  competitive, feasible alternatives.
• Continuation of a Laguna Creek discharge is our
  recommended implementation approach.
• Despite distinct risks, the potential benefits
  associated with a Sacramento River discharge are
  attractive.
• Council may want to consider preserving this
  option while additional information is developed.

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The Laguna Creek option is preferred, in part,
because of the potential risks associated with
the Sacramento River discharge option.

• Permit requirements for a Sacramento River
  discharge can only been estimated. The actual
  requirements, and therefore the viability of this
  option, are unknown until an NPDES permit is
  obtained.
• Public opposition to a new Sacramento River
  discharge may surface during the CEQA process.
• Potential future regulatory changes may
  eventually nullify the key benefits of this
  option.
• Dilution is a critical element of this option.
  Continuation of current policies regarding
  dilution credits/mixing zones is not guaranteed
  in the long run.
• Possible future mass-based effluent limits (e.g.,
  for mercury) are independent of dilution
• Compliance with other possible future effluent
  limits (e.g., pharmaceuticals) cannot be
  predicted at this time.

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The Laguna Creek discharge option offers
distinct benefits that make this the preferred
alternative.

• There is very little risk that constructed
  improvements will be throwaway if regulations
  change.
• This option provides flexibility to move from
  Option A to Option B to create cost-effective
  solutions as the project develops over time.
• The ability to phase construction of improvements
  allows costs to be effectively managed over time.
  
• Safety considerations favor this option.
• Discontinued use of chlorine disinfection.
• Eliminates safety concerns related to pipeline
  maintenance.

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Major Conclusions and Recommendations

• There are potential risks/disadvantages
  associated with a Laguna Creek discharge.
• Requires significant additional treatment
  processes over Option C (e.g., filtration, UV
  disinfection)
• Possible future effluent limits (e.g., salinity)
  may be difficult to meet without advanced
  treatment processes
• Wetlands performance needs to be confirmed
  through pilot testing additional or alternative
  advanced treatment processes may ultimately be
  needed
• Dilution benefit decreases as effluent flow
  increases

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Major Conclusions and Recommendations

• Council may wish to preserve the Sacramento River
  discharge option
• Lower cost for 6 mgd and beyond (given the
  assumptions of this analysis)
• Reduced risk of needing advanced treatment
  processes (e.g., MF/RO) in the event of future
  stringent water quality regulations
• Impractical to delay implementation until the
  Laguna Creek option proves unfavorable

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Key Decisions (revisited)

• Option C Retain until NPDES permit is received
  vs. Abandon in favor of Option A/B
• Option A Retain until benefits of dilution are
  known vs. Abandon in favor of Option B
• Option B Pursue now and abandon Options A C
  vs. Retain as the fallback option

Recommendation Pursue Option A/B consider
preserving Option C until NPDES permit is
received
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Major Conclusions and Recommendations

• Irrespective of the selected option, an
  integrated approach optimizes your ability to
  achieve NPDES permit compliance.

Refine/Expand Effluent Water Quality Analyses
Pursue Dilution Credit, Negotiate NPDES Permit
Requirements
WWTP Improvements
Define Implement Wellhead Treatment for Arsenic
OR
Conduct Receiving Water Analyses
Submit RWD/NDPES Permit Application
Export Pipeline
Identify Implement Other Cost-Effective Source
Control Measures
Refine List of Problem Constituents
It will be imperative to coordinate with the
Regional Board on all of the activities listed
above.
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RECOMMENDED ACTION PLAN
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Recommended Action PlanImmediate Action Items
(2006-2008)

• Take action on Option C (if Council decides it is
  warranted).
• Conduct flow and water quality analyses for
  Laguna Creek.
• Begin pilot test of filtration system.
• Construct and test a pilot-scale treatment
  wetlands to confirm performance.
• Begin preliminary design of selected improvements
  (filtration, UV disinfection) and final design of
  solids processing improvements.
• Use an integrated approach.
• Continue source control efforts.
• Refine sampling techniques and analytical
  testing.
• Develop water quality and flow analyses to
  support NPDES permit negotiations.

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If the Sacramento River option is preserved,
additional costs would be incurred to advance
this alternative.
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Recommended schedule for near-term projects
related to Options A and B.
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Recommended Action Plan Schedule
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