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HomeMy WebLinkAboutExplanationEXPLANATION SUMMARY City of National City has been a partner in the San Diego Metro Wastewater System since 1944. The PLWTP, constructed in 1963, is the backbone of the Metro System. City of National City is one of 12 participating agencies (PAs) that convey wastewater to the Metro System for treatment. The Metropolitan Wastewater Commission (Metro Commission) was formed in 1998 pursuant to the terms of the Regional Wastewater Disposal Agreement between PAs and San Diego. The Metro Commission is an advisory body to the San Diego City Council. The Regional Wastewater Disposal Agreement stipulates that the City of San Diego owns the Metro System and that all decisions with respect to the planning, design, construction, operation and maintenance shall rest with the City of San Diego in consultation with the Metro Commission. The City of San Diego has requested that the Metro Commission support San Diego's modified NPDES permit application for the Point Loma Wastewater Treatment Plant. The PLWTP operates under an NPDES from the Environmental Protection Agency (EPA). Each permit is good for five years following issuance. The current permit expires in July 2015 and must be submitted for renewal in January 2015. The San Diego City Council plans to take action on the permit application on October 28, 2014, therefore San Diego staff have requested the Metro Commission to provide input on the permit application prior to this date. The Metro Commission will consider this item either during its regularly scheduled meeting on October 2, 2014 or at a special meeting on October 16, 2014. This report is presented to the National City Council at this time for discussion of the permit application and direction to its Metro Commission representative prior to the upcoming Metro Commission meeting. DISCUSSION The PLWTP is permitted as a 240 million gallons per day (MGo) advanced primary plant that discharges treated wastewater through an ocean outfail 4:5 miles out at a depth of 320 feet. A diffuser pipe at the end of the outfall spreads the effluent over one mile. Wastewater Treatment Wastewater treatment is the process of removing solids from the wastewater. • Primary treatment plants remove about 60% of the solids. • Advanced primary treatment plants, such as ; oint Loma, use chemicals to remove about 85% of the solids. • Secondary treatment plants follow primary treatment with a biological treatment that removes about 90% of the solids. Tertiary treatment plants, like the North City and South Bay Water Reclamation Plants which are also part of the Metro System, have both primary and secondary treatment followed by filtration, resulting in removing about 99% of the solids. Wastewater Treatment Regulation The federal Clean Water Act (1972) required that all wastewater treatment plants be permitted, California's permitting process involves the EPA, the local Regional Water Quality Control Board, the State Water Resources Control Board and the California Coastal Commission. The Clean Water Act required wastewater treatment plants to treat wastewater to at least a secondary level. The required treatment varies depending on discharge to a lake, river or ocean, and the particular characteristics of the receiving body of water. A number of dischargers are required to go to higher levels of treatment than secondary. Several years ago, the Clean Water Act was amended to allow a modified permit (waiver of secondary) if the discharger could demonstrate the safe discharge of wastewater to receiving water. Initially, San Diego applied for a modified permit for Point Loma but later withdrew the application and began planning to convert Point Loma to secondary treatment. Subsequently, the EPA and several environmental groups sued San Diego for not being at secondary. in 1994, the federal Ocean Pollution Reduction Act (OPRA) gave San Diego the opportunity to apply for a modified permit for Point Loma. In return, San Diego agreed to construct 45 MGD of reclaimed water capacity. North City Water Reclamation Plant, the South Bay Water Reclamation Plant and the South Bay Ocean Outfall were then constructed. San Diego was granted a modified permit for Point Loma in 1994 with environmental stakeholder support because of the development of reclaimed water capacity. Point Loma Permit Requirements to Date San Diego must apply for a new permit or modified permit every five years for Point Loma. San Diego agreed to complete a wide range of studies, as described below, to secure initial support from the environmental community for a modified permit: ▪ Secondary Conversion Cost — The Navy, Cabrillo National Monument, the mean and a ciiff hem in Point Loma are site constraints that lead to higher construction costs for the addition of secondary treatment to the site. An initial study indicated a capital cost of $1 billion. When updated to current dollars, and including wet weather peaking needs, the cost has increased to an estimated $2.1 billion. • Additionally, secondary treatment requires a great deal of electricity, Point Loma would go from being a net energy provider to the grid to one of the top 20 loads in San Diego. Annual operating and energy costs would increase by about $44 million, • Enhanced Ocean Monitoring — San Diego hired experts from scientific organizations such as Scripps and Woods Hole to review and enhance the Ocean Monitoring Program. The expanded monitoring program includes over 150,000 samples taken annually. Over 20 years of data indicate no adverse impact to the ocean environment from Point Loma discharge. Point Loma's 4.5 mile long outfall (one of the longest in the country) terminates in a dispersal structure that spans a mile across at 320 feet deep (the deepest in CV the United States). The unique natural ocean environment particular to Point Loma further diffuses any potential discharge impacts. Optimizing Wastewater Reuse — While the original settlement included construction of reclaimed water facilities as noted above, the agreement also required further study of additional water reuse possibilities, which were presented in "The Recycled Water Study" (2012). The product of years of collaboration between stakeholders and technical experts, the Recycled Water Study outlines a concept to divert almost 100 MGD of wastewater that would otherwise have to be treated, thereby allowing the permitted capacity of Point Lorna to be reduced from 240 MGD to 143 MGD. San Diego constructed a one MGD demonstration projected at North City and pursued studies of San Vicente Reservoir to determine the feasibility of implementing an indirect potable reuse effort there, The demonstration project and studies showed that wastewater could be treated at North City to a level sufficient for safe placement in San Vicente Reservoir for subsequent treatment at a water treatment plant for potable water uses. Current status The current modified permit for Point Loma expires on July 31, 2015. The application for a new permit must be submitted no later than January 2015. It takes approximately one year to collect and assemble the data required for the permit application. That process began in January 2014. Even though the PLWTP is operating within the current law and has demonstrated through 20 years of extensive ocean monitoring that there is no harm to the environment, there is significant political pressure to convert the PLWTP from an advanced primary plant to a secondary plant. The plant currently discharges approximately 160 MGD of treated wastewater effluent which almost meets all the criteria required of a secondary plant. The PLWTP has been reported to be the last large scale wastewater treatment plant not to convert to secondary. In 2010, the Honolulu, Hawaii wastewater treatment plant entered into a consent decree with the EPA to convert its facilities to secondary treatment. This action is thought to have made San Diego the last operating primary plant. The EPA and California Coastal Commission have threatened San Diego in the past that it should not continue to assume that it will be granted waivers. Environmental stakeholders have sued San Diego in the past and have threatened to do so again if San Diego submits waiver applications without some type of progressive improvement to environmental protection. This uncertainty creates a significant amount of risk and instability for San Diego and the 12 PAs in the Metro System. The main concern at Point Loma has been to avoid wasting billions of dollars on a conversion to secondary. Science has proved that conversion is unnecessary. Converting would therefore create a stranded asset. But politics has driven the issue with the mantra being, "everyone else is a secondary, why aren't you?' Secondary Equivalency A strategy was developed using the improvements proposed in the 2012 San Diego Recycled Water Study to achieve equivalent treatment to secondary within the Metro System. Flows would be offloaded from Point Loma to other facilities within the system reducing the discharges at Point Loma to levels below that required by secondary. In addition, proven technology was available to convert these offloaded flows into potable drinking water. Two problems could be fixed with one solution. Offloaded flows from Point Loma could be used as a new, reliable, and greatly needed water source for San Diego. Since June 2013, representatives from the PAs, City of San Diego and environmental stakeholders (Surfrider, Coastkeeper, Audubon Society and Coastal Environmental Rights Foundation) have met to iron out details for secondary equivalency and the appropriate language to include in the NPDES permit. On September 24, 2013 Scott Tulloch gave a presentation to the City Council regarding secondary equivalency and a regional water reuse plan. The Metro Commission sought support from each PA on the plan associated with the Point Loma permit renewal, For secondary equivalency to work, a federal legislative change is likely necessary. In order to commit to a level of facility investment, the PAs needed something in return. Draft legislation entitled the Ocean Pollution Reduction Act (OPRA) II defines secondary equivalency. It was important to obtain support environmental stakeholders' for the legislative change as they can be helpful in achieving legislative change. San Diego, the PAs and environmental stakeholders recently reached concurrence on the definition of secondary equivalency and the parameters of the Point Loma NPDES permit. An agreement was also prepared between the City of San Diego and environmental stakeholders that assures environmental stakeholder support for NPDES permits at Point Loma and OPRA II. NPDES Permit The Permit application will include the following: 1. Point Loma will remain as an Advanced Primary Treatment Plant with a capacity of 240 MGD; 2. It will contain new enforceable provisions as follows: a. A cap on Total Suspended Solids (TSS) mass emissions from 13,598 metric tons/year in the current permit to 12,000 metric torisiyear by December 31, 2015; b. A requirement to issue a Notice of Preparation for a Programmatic FIR no later than January 30, 2015; c. A requirement to issue a Notice to Proceed for the first project design for at least 15 MGD no later than January 30, 2017. 3. Included in the application as future goals, subject to passage of legislation securing secondary equivalency: a. Ongoing reductions of TSS mass emissions as follows: i. 11,500 metric tons/year by December 31, 2025; ii. 9,942 metric tons/year by December 31, 2027 which is equivalent to Point Loma at full capacity of 240 MGD at secondary treatment. h. Production of at least 15 MGD of potable reuse water no later than December 31, 2023; c. Production of at least 30 MGD (cumulative total) of potable reuse water rio later than December 31, 2027; d. Production of at least 83 MGD (cumulative total) of potable reuse water no later than December 31, 2035. These future goals will be included in the permit submittal so that regulatory agencies reviewing the modified permit application can evaluate it within the larger program and goal of achieving secondary equivalency at Point Lorna while also delivering a new local water supply. San Diego has met with both EPA staff and legislators regarding these plans for the Metro System and San Diego region. Feedback has been generally positive and the concepts weii-received. This innovative solution could be a model tor others to follow. Next Steps The San Diego City Council is expected to consider approval of the Point Loma NPDES Permit application on October 28, 2014. Therefore, the Metro Commission will attempt to provide San Diego with its position on the permit application at its meeting on October 2, 2014 or at a special meeting on October 16, 2014. Discussion regarding cost allocation and benefit sharing beginning will continue through 2015. CONCLUSION: Although a waiver from secondary treatment at Point Loma was successfully secured in 2010, there is consensus that there is significant risk in applying for future waivers and that they might not be granted. The uncertain and time-consuming process of stakeholder negotiation that accompanies the waiver application process is a significant resource drain and creates sewer rate and infrastructure planning issues. The concept of secondary equivalency and adoption of federal legislation to secure it along with the beneficial reuse of offioaded flows from Point Loma is a viable option that deserves serious consideration. VVith ail stakeholders in agreement, there is momentum for these strategies to provide significant long term benefits to wastewater and water customers in the region. A draft resolution has been attached for the Metro Commission that supports the above approach (Exhibit A). Staff recommends that the City of National City provide direction to its Metro Commission representative to support the attached resolution which supports the City of San Diego's NPDES Modified Permit application for the Point Loma Wastewater Treatment Plant. CURRENT YEAR FISCAL IMPACT None at this time. Cost allocation scenarios are currently under discussion with the City of San Diego. ONGOING FISCAL IMPACT Future project could have sewer rate impacts. Administrative, planning and environmental review costs are anticipated in the next five to seven years. Secondary equivalency at the PLWTP will avoid approximately $300 million in modifications to the Plant. Stafwill return to the Council to discuss sewer rates in 2015. Exhibit A RESOLUTION NO. 14- A JOINT RESOLUTION OF THE METRO WASTEWATER .IPA AND METRO COMMISSION, SUPPORTING THE CITY OF SAN DIEGO'S NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MODIFIED PERMIT FOR THE POINT LOMA WASTEWATER TREATMENT PLANT WHEREAS, the Point Loma Wastewater Treatment Plant (PLWTP) is a regional facility in the Metro Wastewater System, operated by the City of San Diego, permitted to treat 240 million gallons of wastewater per day to an Advanced Primary Level. serving a 12 member Joint Powers Authority that comprises approximately 35% of the total flow in the Metro Wastewater System/ PLWTP; and WHEREAS, the Clean Water Act of 1972 requires that wastewater be treated to achieve certain protections before ocean discharge and the permitting of wastewater treatment plants, and wastewater treatment plant permits must be renewed every five years; and WHEREAS, the Ocean Pollution Reduction Act (OPRA) of 1994 allowed the City of San Diego to apply for modified NPDES permits allowing PLWTP to continue operating at an Advanced Primary Treatment Level while meeting or exceeding all general and specifically negotiated regulatory obligations including ocean protection requi.tements; and WHEREAS, the City of San Diego has 20 years of ocean monitoring data demonstrating that the Advanced Primary PLWTP consistently protects the ocean environment; and WHEREAS, the City of San Diego has determined that instead of converting the Point Loma Wastewater Treatment Plant to a secondary treatment plant, equivalent results can be achieved by offloading wastewater flow from the Plant to other existing and new facilities (secondary equivalency) for potable water reuse; and WHEREAS, the Metro Cornrnission sees the Pure Water Program, the City of San Diego's 20-year program to produce purified water to supplement San Diego's drinking water supply, as a first step toward realizing the possibility of fully utilizing wastewater supplies to maximize development of local water supply acknowledging that future expansion and ability to minimize flows to wastewater treatment plants will depend on technological and legislative advances, cost benefit analysis, and actual flows compared to projections; and WHEREAS, the strategy of achieving secondary equivalency at the Point Loma Wastewater Treatment Plant through potable reuse of wastewater has included within the Pure Water San Diego program; and WHEREAS, the City of San Diego, the member agencies of Metro Wastewater JPA, members of the Metro Commission, and stakeholders from the environmental community have agreed upon a definition for secondary equivalency and will use their best efforts to have federal legislation passed in accordance with the proposal called the Ocean Pollution Reduction Act II (OPRA II). Generally, OPRA II will allow the City's NPDES permit to be based on secondary Resolution No. 14- Page 2 equivalency that includes a commitment to implement potable reuse of wastewater and allows the PLWTP to remain operating at the Advanced Primary Treatment Level; and WHEREAS, the current modified permit for the PLWTP expires on July 31, 2015, and City of San Diego staff need to submit an application to renew the NPDES permit by January 30, 2015. NOW, THEREFORE, BE IT RESOLVED by the Board of the Metro Wastewater JPA and Metro Commission as follows: Section 1: That the Metro Wastewater JPA and Metro Commission support the Point Loma Wastewater Treatment Plant to remain operating at an Advanced Printery Treatment Level. Section 2: That Metro Wastewater JPA and Metro Commission support the concept of secondary equivalency for the Point Loma Wastewater Treatment Plant and supports proposing the passage of federal legislation in accordance with the proposal titled the Ocean Pollution Reduction Act II (OPRA II), attached hereto as Exhibit "A" and incorporated herein, OPRA II will allow the City's NPDES permit to be based on secondary equivalency that includes a commitment to implement potable reuse of wastewater and allows the PLWTP to remain operating at the Advanced Primary Treatment Level. Section 3: That Metro Wastewater JPA and Metro Commission support the City of San Diego's NPDES Modified Permit application for the Point Loma Wastewater Treatment Plant as further described in the Basis of Point Loma Permit Application, attached hereto as Exhibit "B" and incorporated herein, PASSED AND ADOPTED at a regular meeting of the Board of the Metro Wastewater JPA and Metro Commission on the day of October, 2014: AYES: NOES: ABSENT: ABSTAIN: Cheryl Cox, Chair ATTEST: Lori Anne Peoples, Secretary