Casey Claborn San Jose Water Company -...

Casey Claborn

San Jose Water Company

Discharges covered by this permit Requirements of the new state permit ◦ Notification (pre- and post-discharge) ◦ BMP Implementation ◦ Monitoring ◦ Record Keeping/Reporting

SJWC’s experiences so far

State-wide permit first proposed for adoption in 1996 but was not adopted

In Region 2 (San Francisco Bay) drinking water systems have been discharging under the Municipal Regional Stormwater Permit (MRP) issued to MS4 Operators

Drinking water systems that did not operate an MS4 were not permitted but complied with the C15 Section of the MRP

State Board issued and adopted a state wide permit in November of 2014

Permit covers discharges from Drinking Water System to ◦ receiving water ◦ storm drain

Types of Discharges ◦ Planned discharges ◦ Emergency discharges

Supply well blowoff Tank or reservoir releases Trench dewatering (tie-ins) Distribution system flushing

Water treatment plant operations (excluding filter backwash discharged to receiving water)

Emergency drinking water system failures and repairs - includes transmission and distribution systems

Operation errors

Catastrophic events

Notification BMP Implementation Monitoring Record Keeping Reporting

Planned discharge ≥ 325,850 gallons (1 af) 3 days prior OR 24 hrs after Discharger informed to conduct

an urgent planned discharge Must notify ◦ Regional Board ◦ MS4 operator, if applicable

Within 24 hrs of becoming aware of adverse effect/impact on RW due to ◦ non-compliance, ◦ system failure or ◦ emergency

Must notify ◦ Regional Board ◦ MS4, if applicable

Additional written report within 5 days

At all Planned Discharges At Emergency Discharges as soon as feasible ◦ Concurrently protecting public health & safety

Maintain log of BMPs implemented for different types of discharges ◦ Field documentation ◦ Standard Operating Procedures (SOPs)

Planned discharges only Event Monitoring ◦ Superchlorinated ◦ Well Development and/or Rehab. ◦ Large Volume > 325,850 gallons

Annual Representative Monitoring ◦ All other discharges ◦ Same source, treatment, and BMPs

In State Permit, “Monitoring” means taking samples for Chlorine, Turb., and possibly pH

Chlorine Residual ◦ Effluent limit = 0.019 mg/L ◦ Out of Compliance if ≥ 0.1 mg/L Based on field monitoring equipment accuracy Reading not used for compliance if False Positive

Applies to ◦ All superchlorinated discharges ◦ Planned discharges directly into or within 300 feet

of creek

Monitoring Effluent Limit Applies

Well development/rehabilitation No, non-chlorinated discharges are not sampled for chlorine residual

Superchlorinated discharges Yes, to all discharges Large volume discharges ≥ 325,850 gallons

If direct discharge or discharge within 300 feet of a receiving water

Annual Representative Monitoring locations

If direct discharge or discharge within 300 feet of a receiving water

Sample collected at valid compliance sampling point but not required

If direct discharge or discharge within 300 feet of a receiving water

Turbidity Action Level = 100 NTU Applies to Groundwater Wells ◦ Development ◦ Rehabilitation or ◦ Operation discharges

Exceedance requires discharger to modify, change or enhance BMPs

# of direct discharges to RW >50,000 gal Volume discharged to RWs Volume directed to beneficial use Discharge monitoring data

Annual Report Due March 1st

Several distinct departments, each with multiple discharge types ◦ Operations ◦ Distribution Services ◦ Construction ◦ And others

BMPs were in place already, but needed

new/different paperwork on account of the new permit

Needed to advise each group in a way that was focused on their specific needs for discharge compliance ◦ Tailored SOP Development ◦ Employee Training ◦ Field Support ◦ Documentation

Manages facilities like tanks, booster pumps, and well sites

Two primary discharge types ◦ Well blowoff to waste ◦ Tank draining

Highest likelihood of exceeding 1 acre-foot threshold ◦ Sometimes difficult to predict total discharge

volume ◦ Ex: Returning a groundwater well to service

Responds to leaks, main breaks ◦ Classified as emergency discharges ◦ Limited data collection requirements, however:

For emergency discharges next to a creek, permit requires notification if an adverse effect or impact is observed

SJWC’s environmental team learned through this process that DS was also responsible for installing some new mains ◦ Planned discharges, which do require monitoring

SJWC’s Construction Department manages several contractors that conduct main replacements and other capital projects

Additional challenge of non-SJWC staff still

operating under SJWC’s permit

Most challenging planned discharges ◦ Tie-ins/trench dewatering (highly turbid) ◦ Flushing of new mains (superchlorinated)

Some low-impact SJWC operations don’t require much to ensure compliance ◦ Water quality sampling ◦ Meter testing ◦ Service flushing

Generally low-volume, ordinary drinking

water quality Often never reach surface waters ◦ Covered under “beneficial re-use” provisions

Still in development ◦ Additional BMP refinement ◦ Electronic data management ◦ Assessing need for additional training

Happy to collaborate further

Casey Claborn San Jose Water Company

casey.claborn@sjwater.com