May 2, 2022
Transportation and Environment Committee
Discharge Regulations & Future Impacts on the RWF
Eric Dunlavey
Jason Nettleton
Jennifer Voccola Brown
2 Regional Wastewater Facility
County
Sanitation
District 2-3
City of Santa Clara
City of Milpitas
Burbank Sanitary District
City of San José
Cupertino Sanitary
District
West Valley
Sanitation District
RWF
Operating since 1956
Largest advanced
wastewater facility in West
– 167 MGD capacity
– 2,600-acre site
Serves
– 1.5 million people
– 17,000 businesses
– 8 cities & County areas
Subject to multiple permits
Regulatory Permits: Water & Air Quality
Permit Permit
Effective
Expected
Reissuance Regulator
Air Emissions Permits
Title V – Federal Air Operating Permit March 2017 May 2022 EPA/BAAQMD Permit to Operate July 2021 Renewed
Annually BAAQMD
Wastewater Discharge Permits
RWF NPDES Permit April 2020 April 2025 SF Water Board
Nutrients NPDES Permit for POTWs July 2019 July 2024 SF Water Board Mercury and PCBs NPDES Permit for
POTWs December 2017 December 2022 SF Water Board
3 New/Updated BAAQMD Regulations
Regulation 2, Rule 5 – New Source Review of
Toxic Air Contaminants
Regulation 11, Rule 18 – Reduction of Risk
From Air Toxic Emissions at Existing Facilities
Regulation 13, Rule 4 – Sewage Treatment and
Anaerobic Digestion
4 Work Group Formed During Adoption of
Regulation 2, Rule 5
– Bay Area Clean Water Agencies (BACWA)
– BAAQMD Management
– Reports to BAAQMD Board of Directors
Project/Permit Experience
– Source Test Group
– Enforcement
– Engineering (permits)
BAAQMD Engagement
5 Regulatory Permits: Water & Air Quality
Permit Permit
Effective
Expected
Reissuance Regulator
Air Emissions Permits
Title V – Federal Air Operating Permit March 2017 May 2022 EPA/BAAQMD Permit to Operate July 2021 Renewed
Annually BAAQMD
Wastewater Discharge Permits
RWF NPDES Permit April 2020 April 2025 SF Water Board
Nutrients NPDES Permit for POTWs July 2019 July 2024 SF Water Board Mercury and PCBs NPDES Permit for
POTWs December 2017 December 2022 SF Water Board
6 Updated Regulations: Nutrient Limits
Nitrogen Limits 2024
Bay science studies
will inform need for
further reductions
Proactive monitoring
and collaborative
engagement by staff
7 Potential Regulations: CECs
Constituents of
Emerging Concern
8 Microplastics
Collaboration
PFAS
Forever
chemicals
Broad uses
Ubiquitous
Image from:
mn-net.com
9 SB 1383 Regulation Integration into Operations
Sludge Dewatering Facility 2025
Biosolids Transition Strategy has
co-benefits
1. Odor Management
2. Positions RWF better for diversion
to meet SB 1383
Conclusion – Ongoing Actions
Continue Tracking Regulations and Legislation
– Positions taken are science-based and practical
Engaging with Regulators
– Establish stronger connection with BAAQMD Leadership
– Maintain relationship with Water Board
Building Flexibility into Capital Projects
– Adapting where/when needed as regulations change
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