WWTPActionPlan

NPDES Permit Compliance Action Plan: 

NPDES Permit Compliance Action Plan Presentation to the Galt City Council January 24, 2006

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

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 Council’s views and input.

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

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

Option A is a Laguna Creek seasonal discharge alternative.: 

Option A is a Laguna Creek seasonal discharge alternative.

Slide6: 

WWTP PROCESS SCHEMATIC FOR OPTION A (WINTER OPERATION) TREATMENT WETLANDS FILTERS

Option B involves discharging to Laguna Creek on a year-round basis.: 

Option B involves discharging to Laguna Creek on a year-round basis.

Slide8: 

WWTP PROCESS SCHEMATIC FOR OPTION B FILTERS TREATMENT WETLANDS NEED FOR/ADEQUACY OF WETLANDS IS DEPENDENT UPON OUTCOME OF WATER QUALITY STUDIES, DILUTION CREDIT, PILOT TESTING

Option C is a Sacramento River discharge option requiring construction of a 12 mile long pipeline and river outfall facilities. : 

Option C is a Sacramento River discharge option requiring construction of a 12 mile long pipeline and river outfall facilities.

Option D would eliminate effluent discharge altogether through reuse and storage.: 

Option D would eliminate effluent discharge altogether through reuse and storage.

Estimated capital costs and O&M costs for each option at 3 mgd: 

Estimated capital costs and O&M costs for each option at 3 mgd These costs are based on existing information and assumptions, and are subject to change.

Comparison of Capital Costs 3 mgd and 6 mgd: 

Comparison of Capital Costs 3 mgd and 6 mgd

Major Conclusions and Recommendations: 

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/operation of the system will be difficult and complex Recommendation: Eliminate Option D from the list of alternatives.

Key Decisions : 

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

Major Conclusions and Recommendations: 

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.

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

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.

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

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.

Major Conclusions and Recommendations: 

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

Major Conclusions and Recommendations: 

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

Key Decisions (revisited) : 

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

Major Conclusions and Recommendations: 

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 Conduct Receiving Water Analyses Refine List of Problem Constituents Submit RWD/NDPES Permit Application Pursue Dilution Credit, Negotiate NPDES Permit Requirements WWTP Improvements Export Pipeline OR Define & Implement Wellhead Treatment for Arsenic Identify & Implement Other Cost-Effective Source Control Measures It will be imperative to coordinate with the Regional Board on all of the activities listed above.

RECOMMENDED ACTION PLAN: 

RECOMMENDED ACTION PLAN

Recommended Action PlanImmediate Action Items (2006-2008): 

Recommended Action Plan Immediate 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.

If the Sacramento River option is preserved, additional costs would be incurred to advance this alternative.: 

If the Sacramento River option is preserved, additional costs would be incurred to advance this alternative.

Recommended schedule for near-term projects related to Options A and B.: 

Recommended schedule for near-term projects related to Options A and B.

Recommended Action Plan Schedule: 

Recommended Action Plan Schedule