FOR THE COUNCIL MEETING OF JUNE 4, 2024
COUNCIL AGENDA REPORT
TO: City Council
FROM: Interim City Manager Alex Posada
BY: Director of Utilities Shad S. Springer
SUBJECT: Adoption of a Resolution Authorizing Submission of a Time Schedule Compliance Plan to the Central Coast Regional Water Quality Control Board for the City’s Wastewater Treatment Plant
Description:
The City Council will consider authorizing the submission of a time schedule compliance plan to the Central Coast Regional Water Quality Control Board for the City’s Wastewater Treatment Plant to comply with the Notice of Applicability.
Environmental Notice: The time schedule compliance plan is not a “Project” as defined under Section 15378 of the California Environmental Quality Act (CEQA) State Guidelines; therefore, pursuant to State Guidelines Section 15060(c)(3) no environmental review is required.
RECOMMENDATION:
Adopt a Resolution authorizing and directing the submission of a time schedule compliance plan to the Central Coast Regional Water Quality Control Board to comply with the Notice of Applicability for enrollment in General Waste Discharge Requirements Order No. R3-2020-0020.
BACKGROUND:
The City’s Wastewater Treatment Plant (WWTP) at 601 South Black Road treats domestic, commercial, and industrial wastewater from its service area , which serves a population of more than 107,000. The treatment process includes primary clarifiers, trickling filters, secondary clarifiers, and then the discharge of the treated wastewater to land via percolation ponds. This discharge is permitted by the Central Coast Regional Water Quality Control Board (RWQCB).
In September 2020, the RWQCB adopted General Waste Discharge Requirements Order No. R3-2020-0020 (General Order). On November 5, 2021, the RWQCB sent notice to the City requiring the City to submit a Notice of Intent (NOI) to enroll in the General Order by February 5, 2022. City staff requested additional time to put the information together for the NOI and the RWQCB granted a six -month extension to August 5, 2022. The City Council approved Resolution 2022-81 at its meeting on August 2, 2022, authorizing the submission of the NOI to the RWQCB.
2 The City’s WWTP cannot meet the discharge requirements of the General Order without significant modifications, upgrades, and/or reconstruction. Therefore, in March 2023, City staff issued a Request for Proposals for Wastewater Treatment Plant Program Management Services for a consultant to assist the City in developing a program to comply with the General Order. The City Council approved an agreement for professional services with Carollo Engineers, Inc. (Carollo) to provide WWTP Program Management Services at its meeting of December 5, 2023.
Meanwhile, the RWQCB issued a Notice of Applicability (NOA) to the City on June 16, 2023, which described the wastewater system operation summary, specific requirements, timelines, limitations, and monitoring and reporting program requirements.
The City is unable to implement new treatment processes to comply with the General Order’s final effluent limits by the RWQCB’s deadline of June 2025. To provide additional time for the City to comply with the new effluent limits required under the General Order, the NOA allows the City to submit a Time Schedule Compliance Plan (TSCP). The deadline for the City to submit the TSCP to the RWQCB is June 16, 2024. As part of the WWTP Program Management Services, Carollo drafted the TSCP for the City to submit to the RWQCB. The TSCP lists actions completed by the City to date, as well as clear milestones the City must achieve on its pathway to compliance with the General Order.
DISCUSSION:
The draft TSCP (Attachment “A”) includes the following items required by the RWQCB:
1. Comparison of the current effluent quality to the effluent and groundwater limitations in General Order Tables 3 to 6.
2. Identification of the City’s choice for compliance for each constituent pursuant to General Order Section V.A.2 Option 1 or Option 2 (complying with an effluent limit or demonstrating compliance through a groundwater monitoring program).
3. A detailed description and chronology of efforts, since issuance of the NOA, to reduce wastes.
4. Justification of the need for additional time to achieve the effluent limitations in General Order Tables 3 to 6.
5. A detailed time schedule of specific actions the City will take to achieve the effluent limitations.
6. A demonstration that the time schedule requested is as short as possible, considering the technological, operation, and economic factors that affect the design, development, and implementation of the meas ures that are necessary to comply with the effluent limitation(s).
7. If the requested time schedule exceeds one year, the proposed schedule shall include interim requirements and the date(s) for their achievement. The interim requirements shall include both of the following:
a. Effluent limitation(s) for the pollutant(s) of concern. 3 b. Actions, measurable milestones, and tangible products leading to compliance with the effluent limitation(s).
To comply with the NOA and provide the City time to achieve compliance with the General Order, City staff recommends submission of a finalized TSCP to the RWCQB. Submission of the finalized TSCP will continue the City’s efforts to meet timeline requirements of the NOA as the City establishes the framework to achieve compliance with the General Order. The RWQCB will review the City’s TSCP and provide comments or recommended modifications. In the meantime, City staff and Carollo will continue developing the program for the City’s WWTP to, ultimately, meet the discharge requirement s of the General Order.
Alternative(s)
The City Council may reject the draft TSCP and direct City Staff to work with Carollo on a new TSCP. This will result in additional staff time and costs. The additional time will result in the City violating the NOA issued by the RWQCB.
Fiscal Considerations
There are no additional costs associated with submission of the TSCP to the RWQCB.
Impact to the Community
The City intends to modify the existing WWTP to serve the community’s current and future growth in a sustainable, reliable, cost-effective, and resilient manner. These modifications must be managed in a smooth and integrated manner with active WWTP operations and to comply with the Central Coast Water Board’s General Order.
ATTACHMENTS
Attachment “A” Time Schedule Compliance Plan - Draft