# 201 4

Pretreatment

and Pollution

Prevention Report

East Bay Municipal Utility District



# Wastewater Department

### TABLE OF CONTENTS

Page

DEFINITIONS & ABBREVIATIONS........................................................................

. ......... . .iii

1. INTRODUCTION

................................ ................................ ................................ ................................ ........ .. 1

1.1 EBMUD Background Information

................................ ................................ ................................ ...... 1

1.2 Wastewater Ser vice Area and Facilities

................................ ................................ .............................. 1

1.3 Pretreatment and Pollution Prevention Program

................................ ................................ ................. 2

1.4 Pretreatment Program Evaluation

................................ ................................ ................................ ........ 2

2

. PLANT INFORMATION

................................ ................................ ................................ .............................. 

### 4

2 .1 Upset, Interference and Pass

- Through

................................ ................................ ................................ . 4

2 .2 Compliance with NPDES Permit Limitations

................................ ................................ ..................... 4

2 .3 Biosolids Storage, Land Application and Disposal Practice

................................ ............................... 4

2 .4 Influent, Effluent and Biosolids Monitoring Results

................................ ................................ ........... 4

2 .5 Plant Operating Data

................................ ................................ ................................ ........................... 5

3

. PRETREATMENT PROGRAM

- GENERAL INFORMATION

................................ ........................... 2 5

3 .1 Pretreatment Program Changes and Highlights

................................ ................................ ................. 2 5

3 .2 Pretreatment Program Staffing and Budget

................................ ................................ ....................... 2 5

3 .3 Permit Types

................................ ................................ ................................ ................................ ...... 2 9

3 .4 Resource Recovery Program

................................ ................................ ................................ ............. 30

3 .5 Inspection and Sampling Procedures

................................ ................................ ................................ . 3 2

3 .5. 1 Business Classification Code Inspection

................................ ................................ ............................. 3 2

3 .5.2 In

- Depth Inspection

................................ ................................ ................................ ............................. 3 3

3 .5.3 Inspection

- Significant Industrial User and Non

- Significant Industrial User

................................ .... 3 3

3 .5.4 Inspection

- Zero Discharge

................................ ................................ ................................ ................ 3 5

3 .5.5 Inspection

- Pollution Preventi on

................................ ................................ ................................ ........ 3 6

3 .5.6 Inspection

- Special Discharge

................................ ................................ ................................ ............ 3 7

3 .5.7 Violation Follow

- Up Inspection

................................ ................................ ................................ .......... 3 7

3 .5.8 Resource Recovery (R2) Program Random Field Audit Program

................................ ...................... 3 7

3 .6 Enforcement Procedures

................................ ................................ ................................ .................... 3 8

3 .6.1 Legal Authority

................................ ................................ ................................ ................................ ... 3 8

3 .6.2 Enforcement Response

................................ ................................ ................................ ........................ 3 8

3 .7 Local Limits

................................ ................................ ................................ ................................ ....... 3 9

4

. PRETREATMENT PROGRAM

- INDUSTRIAL USER INFORMATION

................................ .......... 4 1

4 .1 Federal Categories

................................ ................................ ................................ ............................. 4 1

4 .2 Baseline Monitoring Report Update

................................ ................................ ................................ .. 4 1

4 .3 Summary of Activity for Permitted Industrial Users

................................ ................................ ......... 4 1

4 .4 Updated List and Compliance Activities for CIUs, SIUs, and Other Regulated Facilities

............... 4 1

4 .5 July

- December Semiannual R eport

................................ ................................ ................................ ... 4 1

4.5.1 Significant Industrial User

- Categorical

................................ ................................ ............................. 4 2

4.5.2 Significant Industrial User

- Local

................................ ................................ ................................ ...... 4 2

4 .6 Public Participation Summary

................................ ................................ ................................ ......... .. 4 3

5

. POLLUTION PREVENTION PROGRAM

................................ ................................ ............................... 7 7

5 .1 Pollution Prevention Program Highlights for 201 3

................................ ................................ ........... 7 7

5 .2 Description of SD

- 1 Treatment Facilities and Service Area

................................ ............................. 7 9

5 .3 Current Pollutants of Conce rn

................................ ................................ ................................ ........... 7 9

5 .4 Source Identification and Reduction Programs

................................ ................................ ................. 7 9

5.4.1 Mercury

................................ ................................ ................................ ................................ ............... 7 9

5.4. 2 Fats, Oil, and Grease (FOG)

................................ ................................ ................................ ................ 81

- i

-5. 4. 3 Copper

................................ ................................ ................................ ................................ ................. 8 5

5.4.4 Cyanide

................................ ................................ ................................ ................................ ............... 8 9

5.4.5 Polychlorindated Biphenyls (PCBs)

................................ ................................ ................................ .... 91

5.4. 6 P harmaceutical Disposal

................................ ................................ ................................ ..................... 91

5.4.7 Pes ticides

................................ ................................ ................................ ................................ ............. 92

5.5 Green Chemistry & Producer Responsibility

................................ ................................ .................... 92

5. 6 Outreach to EBMUD Employees

................................ ................................ ................................ ...... 92

5

. 6 .1 Employee Events & Activities

................................ ................................ ................................ ............ 92

5

. 6 .2 Employee Electronic Communications

................................ ................................ ............................... 93

5.7 Public Outreach Programs

................................ ................................ ................................ ................. 93

5

. 7 .1 Outreach to Industrial/Commercial Facilities and Government Agencies

................................ .......... 94

5

. 7 .2 Outreach to Non

- governmental Organizations (NGOs)

................................ ................................ ...... 94

5

. 7 .3 Outreach to Schools

................................ ................................ ................................ ............................ 94

5.7.4 Outreach to Residential Community

................................ ................................ ................................ ... 94

5

. 8 Cr iteria used to Measure the Programs’ and Tasks’ Effectiveness

................................ ................... 9 9

5

. 9 Pollution Prevention and Zero Discharge Permits

................................ ................................ .............. 9 9

5

. 9

. 1 Reduction of Pollutants in Plant Influent

................................ ................................ .......................... 10 0

- ii

-

### TABLE OF TABLES

Page

Table 2

- A

– 2014 Metals Influent and Effluent Monitoring

................................ ................................ .............. 6

Table 2

- B

– 2014 624 Influent and Effluent Monitoring

................................ ................................ ................... 9

Table 2

- C

– 2014 EPA 625 Influent and Effluent Monitoring

................................ ................................ ........ 10

Table 2

- D

– 2014 Biosolids Monitoring Results

– 5

- Day Composite Samples (MG/KG)

............................. 12

Table 2

- E

– Wastewater Treatment Plant Operating Data

– 2014

................................ ................................ . 18

Table 3

- A

– ESD Expenditures

– Calendar Year 2014

................................ ................................ .................... 28

Table 3

- B

– Wastewater System Special Fees

– Effective July 1, 2014

................................ .......................... 28

Table 3

- C

– Resource Recovery

– Tru cked Materials, Volumes and Descriptions

................................ ...... 31

Table 3

- D

– EBMUD Minimum Monitoring Frequency

................................ ................................ ................. 34

Table 3

- E

– Enforcement Response Procedure Summary

................................ ................................ .............. 39

Table 4

- A

– Wastewater Discharge Permits and Standards for Categorical Industrial Users

.................... 44

Table 4

- B

– 2014 Monitoring and Violations Summary

................................ ................................ .................. 50

Table 4

- C

– 2014 Monitoring, Enforcement and Status: Significant Industrial Users

– Categorical

......... 53

Table 4

- D

– Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

.......... 58

Table 4

- E

– Monitoring , Enforcement and Status: Non

- Significant Industrial Users

................................ .. 64

Table 4

- F

– Monitoring, Enforcement and Status: Non

- Significant Categorial Industrial Users

............... 70

- iii

-

### TABLE OF FIGURES

Page

Figure 2

- A

– EBMUD Plant Loading 1974, 1988, 2014

– Zinc, Chro mium, Copper and Lead Reduction 19

Figure 2

- B

– EBMUD Plant Loading 1974, 1988, 2014

– Cadmium, Nickel and Silver Reduction

............. 19

Figure 2

- C

– EBMUD Influent Concentrations 1988, 2014

– Selected Organics Reduction

........................ 20

Figure 2

- D

– 5

- Year Graph of Metals Influe nt and Effluent

................................ ................................ .......... 21

Figure 5

- A

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

Cadmium (kg/day) in Wastewater Treatment Plant Influent

................................ ............................. 101

Figure 5

- B

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Ch romium (kg/day) in Wastewater Treatment Plant Influent

................................ ........................... 102

Figure 5

- C

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Copper (kg/day) in Wastewater Treatment Plant Influent

................................ ................................ . 102

Figure 5

- D

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Lead (kg/day) in Wastewater Treatment Plant Influent

................................ ................................ ..... 103

Figure 5

- E

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Mercury (kg/day) in Wastewater Treatment Plant Influent

................................ ............................... 103

Figure 5

- F

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Nickel (kg/day) in Wastewater Treatment Plant Influent

................................ ................................ ... 104

Figure 5

- G

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Silver (kg/day) in Wastewater Treatment Plant Influent

................................ ................................ .... 104

Figure 5

- H

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Zinc (kg/day) in Wastewater Treatment Plant Influent

................................ ................................ ...... 105

Figure 5

- I

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Methylene Chloride (ug/l) in Wastewater Treatment Plant Influent

................................ ................. 105

Figure 5

- J

– EBMUD Pollution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Tetrachloroethene (μg/l) in Wastewater Treatment Plant Influent

................................ .................... 106

Figure 5

- K

– EBMUD Po llution Prevention Program

– Measure of Effectiveness 1988

- 2014

-

Toluene (μg/l) in Wastewater Treatment Plant Influent

................................ ................................ ..... 106

- iv

-

### EXHIBITS

Exhibit 4

- A

– Notice of Significant Wastewater Violation

................................ ................................ .............. 43

Exhibit 5

- A

– Pollution Prevention and FOG Outreach for T rash and “Disposable”

Consumer Products

Exhibit 5

- B

– Keep the bay off Drugs Billboard

Exhibit 5

- C

– Keep the bay off Drugs Campaign

Exhibit 5

- D

– Pollution Prevention and FOG Outreach Brochure for Oakland Residents

Exhibit 5

- E

- Pollution Prevention an d FOG Outreach Refrigerator Magnet for Customers in Oakland

Exhibit 5

- F

- Pollution Prevention and FOG Outreach Postcard Mailer for Property Managers of Multi

family Dwellings in Oakland

Exhibit 5

- G

- Pollution Prevention and FOG Outreach at the Emery Bay Village Homeowners’

Association in Emeryville

Exhibit 5

- H

- Pollution Prevention and FOG Outreach Article in the Park Street Business Association

Newsletter in Alameda

Exhibit 5

- I

- Pollution Prevention and FOG Outreach Article in EBMUD Splashes Newsletter

Exhibit 5

- J

- Pollution Prevention and FOG Outreach Article in EBMUD Splashes Newsletter

- continued

Exhibit 5

- K

- EBMUD Issued Letter through BACWA to RWQCB Regarding Funding for the Regional

Monitoring Program for Water Quality in San Francisco Bay (RMP)

Exhibit 5

- L

- EBMUD Issued Letter through BACWA to RWQCB Regarding Funding for the Regional

Monitoring Program for Water Quality in San Francisco Bay (RMP)

- continued

Exhibit 5

- M

- Pollution Prevention Article on Keeping Polluta nts Out of the Drain Customer Pipeline

publication

- v

-

## DEFINITIONS AND ABBREVIATIONS

**Definitions**

Baseline Monitoring Report (BMR): The report required by the Control Authority from industrial users

subject to Categorical Pretreatment Standards. The BMR due dates and contents are cited in 40 CFR403.6

and 403. 12.

Best Management Practices (BMP s ): Schedules of activities, prohibitions of practices, maintenance

procedures, and other management practices to implement the prohibitions listed in EBMUD Wastewater

Control Ordinance , Title II, Section 2. BMPs also inc lude treatment requirements, operating procedures,

and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw

materials storage.

Biosolids: The solid organic matter made from the anaerobic digestion of se wage sludge.

Business Classification Code (BCC): A classification of dischargers based on the 1987 Standard

Industrial Classification Manual, Office of Management and Budget of the United States of America.

Bypass: The intentional diversion of waste stre ams from any portion of a treatment facility.

Categorical Industry: An industry that must comply with National Categorical Pretreatment Standards

as published by EPA.

Categorical Industrial User (CIU ) : A discharger subject to a categorical pretreatment s tandard.

Categorical Pretreatment Standards: Any regulation containing pollutant discharge limits promulgated

by the EPA in accordance with Section 307(b) and (c) of the Clean Water Act, which applies to Industrial

Users. Includes prohibitive discharge limits established pursuant to 40 Code of Federal Regulations,

403.5. [Ref. 40 Code of Federal Regulations, 403.3(j)]

.

Cease and Desist Order (CDO): An order issued by the Director of Wastewater directing a discharger to

achieve compliance with permit req uirements and/or EBMUD Wastewater Control Ordinance

.

Chemical Oxygen Demand (COD)

- filtered: The amount of Chemical Oxygen Demand passing through

a glass filter as measured in conformance with the District's approved method. Chemical oxygen demand is

the measure of the oxygen equivalent of the organic matter of a sample that is susceptible to oxidation by a

strong chemical oxidant.

Closed (CL) Facility : A facility that no longer operates within the EBMUD SD

- 1 service area.

Compliance Schedule: Action(s) required of an industrial discharger to comply with pretreatment

regulations. A compliance schedule may be included as a condition of the industrial discharger's

wastewater discharge permit, or by an Administrative or Judicial Order.

Compliance Status: D etermined through review of monitoring data and other information to assess an

industrial discharger's compliance with schedules, reporting requirements, and applicable pretreatment

standards. An industrial discharger's compliance status is reported quarte rly as consistent compliance,

inconsistent compliance, significant non

- compliance, or unknown.



### viConsistent Compliance (C): The compliance status assigned to an industrial discharger having no

violation during the last reporting quarter and no unresolved si gnificant non

- compliance issues from the

previous reporting quarter.

Delist: The removal of an industrial user from EBMUD’s Significant Industrial Users list

.

Director: Director of the Wastewater Department of the EBMUD or his/her designated representati ve.

Discharge Minimization Permit: Mandatory permit that includes monitoring and /or reporting

requirements.

East Bay Municipal Utility District (EBMUD): A municipal utility district formed under Division 6 of

the Public Utilities Code of the State of Cal ifornia, also known as the Municipal Utility District Act

(MUD Act), which provides water and wastewater service to East Bay communities. [Ref. MUD Act,

Division 6, Chapter 1, Article 1, Section 11503]

EBMUD Wastewater Control Ordinance : The Ordinance ena cted by the EBMUD Board of Directors

establishing regulations for: 1) the interception, treatment, and disposal of wastewater and industrial

wastes, 2) control of wastewater, including discharger classification and issuance of permits, 3) charges,

and 4) p enalties for violations of the Ordinance , revision e ffective August 22 , 20 1 3

.

EBMUD Special District No. 1 (SD

- 1): The special district for sewage disposal created under Division 6

of the Public Utilities Code of the State of California, also known as the Municipal Utility District Act

(MUD Act), to provide treatment of wastewater from East Bay communities. [Ref. MUD Act, Division 6,

Chapter 8, Article 1, Section 13451]

.

Estimation Permit: Optional permit issued to dischargers who request an estimation of wastewater flow

or whose discharge is less than the normal range of wastewater strength for the BCC to which it is

assigned.

Federal Categorical: See Categorical Industry.

Food Service Establishment (FSE): Any facility preparing and/or serving food for commercial use or

sale. This includes restaurants, cafes, lunch counters, cafeterias, hotels, hospitals, convalescent homes,

factory or school kitchens, catering kitchens, bakeries, grocery stores with food preparation and

packaging, and meat cutting and preparation (excluding grocery stores with only food warming

operations), meat packing facilities and other FSEs not listed above where cooking fats, oils and grease

may be introduced into the community sewer system.

General Pretreatment Regulations: Any regulations promulgated by the EPA in accordance with

Sections 307(b) and (c) and 402(b)(8) of the Act (33 U.S.C. 1347) for the implementation, administration

and enforcement of pretreatment standards.

Groundwater Permit: Discharge minimization permit iss ued to dischargers of groundwater that serves

as a waiver to the prohibition of groundwater discharges found in EBMUD Wastewater Control

Ordinance, Title I, Section 5.

Inconsistent Compliance (IC): The compliance status assigned to an industrial discharge r having one or

more violations during a reporting quarter, which did not result in significant non

- compliance, and no

long

- term pattern of violations.



### viiIndirect Discharge: The introduction of pollutants into a publicly owned treatment works from any non

d omestic source regulated under section 307(b), (c) or (d) of the Clean Water Act. [Ref. 40 Code of

Federal Regulations, 403.3(g)]

.

Industrial User (IU): A source of indirect discharge. [Ref. 40 Code of Federal Regulations, 403.3(h)]

.

Interceptor: An int ercepting sewer found and determined by the Board of Directors of the District to be

such and owned and operated by the District.

Interference: A discharge

, which, alone or in conjunction with a discharge or discharges from other

sources, both:

1. Inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or

disposal; and

2. Therefore is a cause of a violation of any requirement of the POTW's NPDES permit (including an

increase in the magnitude or duration of a violation) or of the prevention of sewage sludge use or

disposal in compliance with the following statutory provisions and regulations or permits issued

thereunder (or more stringent State or local regulations): Section 405 of the Clean Water Act, the Solid

Waste Di sposal Act (SWDA) (including Title II, more commonly referred to as the Resource

Conservation and Recovery Act (RCRA)), and including State regulations contained in any State

sludge management plan prepared pursuant to subtitle D of the SWDA), the Clean Ai r Act, the Toxic

Substances Control Act, and the Marine Protection, Research and Sanctuaries Act. [Ref. 40 Code of

Federal Regulations, 403.3(h)]

Mandatory Permit: A permit that must be obtained by dischargers who are in the categories cited in the

EBMUD Wastewater Control Ordinance , Title IV, Section 1.a.

National Pollutant Discharge Elimination System (NPDES): The national program established under

the Clean Water Act to regulate discharges to the navigable waters of the United States. [Ref. Clean

Water Act, Title IV, Section 402]

.

New Permit : A Minimization, Estimation or Pollution Prevention Permit that was not in effect during the

previous reporting year.

New Source:

(1) Any building, structure, facility, or installation from which there is or ma y be a discharge of

pollutants, the construction of which commenced after the publication of proposed pretreatment standards

which will be applicable to such source if such standards are thereafter promulgated, provided that:

(i) The building, structure, facil ity or installation is constructed at a site at which no other

source is located; or

(ii) The building, structure, facility or installation totally replaces the process or production

equipment that causes the discharge of pollutants at an existing source; or

(iii) Th e production or wastewater generating processes of the building, structure, facility or

installation are substantially independent of an existing source at the same site. In

determining whether these are substantially independent, factors such as the exten t to

which the new facility is integrated with the existing plant, and the extent to which the

new facility is engaged in the same general type of activity as the existing source should

be considered.

(2) Construction on a site at which an existing source is located results in a modification rather than a

New Source if the construction does not create a new building, structure, facility or installation meeting

the criteria of paragraphs (1)(ii) or (1)(iii) of this section, but otherwise alters, replaces, o r adds to existing

process or production equipment.



### viii(3) Construction of a new source as defined under this paragraph has commenced if the owner or operator

has:

(i) Begun, or caused to begin as part of a continuous onsite construction program:

a. Any placement, a ssembly, or installation of facilities or equipment; or

b. Significant site preparation work including clearing, excavation, or removal of

existing buildings, structures, or facilities which is necessary for the placement,

assembly, or installation of new sou rce facilities or equipment; or

(ii) Entered into a binding contractual obligation for the purchase of facilities or equipment

, which are intended to be used in its operation within a reasonable time. Options to

purchase or contracts which can be terminated or modified without substantial loss, and

contracts for feasibility, engineering, and design studies do not constitute a contractual

obligation under this paragraph.

Non

- Categorical Industry: An industry that is exempt from the Categorical Pretreatment Stand ards.

Non

- Significant Categorical Industrial User 

### A categorical industrial user that meets the following

criteria:

Never discharges more than 100 gallons per day of total categorical wastewater and

a. Has consistently complied with all applicable categorical pretreatment standards and

requirements

b. Annually submits the certification statement required in 40 CFR 403.12(q)

c. Never discharges any untreated concentrated wastewater.

NPDES Permit: The regulatory agency document issued either by a federal or state ag ency which is

designed to control all discharges of pollutants into navigable waters from all point sources of pollution,

including industries and publicly owned treatment works.

Optional Permit: A permit that may be issued to dischargers who apply for su ch permit as cited in the

EBMUD Wastewater Control Ordinance , Title IV, Section 1.b.

Pass

- Through: Discharge which exits a publicly owned treatment works (POTW) into waters of the

United States in quantities or concentrations which, alone or in conjunctio n with a discharge or discharges

from other sources, is a cause of violation of any requirement of the POTW's NPDES permit (including

an increase in the magnitude or duration of a violation). [Ref. 40 Code of Federal Regulations, 403.3(n)]

Pollution Preve ntion (P2) : An activity that eliminates or reduces the amount of any pollutant from

entering the waste stream or the environment.

Pollution Prevention (P2) Permit: Mandatory permits for certain BCCs that contain best management

practices to reduce or el iminate pollutants discharged to the sanitary sewer.

Publicly Owned Treatment Works (POTW): A treatment works as defined by Section 212 of the Clean

Water Act, which is owned by the District. This definition includes any District

- owned devices and

systems used in the storage , treatment, recycling and reclamation of municipal sewage or industrial

wastes of a liquid nature. It also includes District

- owned sewers, pipes and other conveyances that convey

wastewater to that portion of the POTW which is designed to provide treatment (including recycling and

reclamation) of municipal sewage and industrial waste.

Pretreatment: The reduction of the amount of pollutants, the elimination of pollutants or the alteration of

the nature of pollutant properties in wastew ater through physical, chemical or biological processes or

process changes prior to or in lieu of discharging these pollutants into a POTW. [Ref. 40 Code of Federal

Regulations, 403.3(q)]



### ixReclassified (RC): An IU regulated under a Minimization (federal ca tegorical or local), Estimation or

Pollution Prevention Permit that becomes regulated under a different one of these permits.

Recycling: Re use of materials that would otherwise be considered waste.

Recycled Water: Wastewater that has been treated to redu ce contaminants to low enough levels to enable

the water to be used again safely for certain beneficial uses or controlled uses that would not otherwise

occur.

Reissued (RI): Existing P2 Permits that are renewed.

Resource Recovery Permi t : A mandatory p ermit that regulates the trucked materials arriving at the SD

- 1

Wastewater Treatment Plant for treatment.

RWQCB: T he San Francisco Bay Regional Water Quality Control Board

.

Significant Industrial User (SIU):

1. A user subject to Categorical Pretreatment Sta ndards; or

2. A user that:

(i) Discharges an average of twenty

- five thousand (25,000) gallons per day or more of

process wastewater to the POTW (excluding sanitary, noncontact cooling, and boiler

blowdown wastewater);

(ii) Contributes a process wastestream which makes up five (5) percent or more of the average

dry weather hydraulic or organic capacity of the POTW treatment plant; or

(iii) Is designated as such by the District on the basis that it has a reasonable potential for

adversely affecting the POTW' s operation or for violating any pretreatment standard or

requirement.

3. Upon a finding that a user meeting the criteria in Subsection (2.) above has no reasonable potential

for adversely affecting the POTW's operation or for violating any pretreatment stan dard or

requirement, the District may at any time, on its own initiative or in response to a petition received

from a user, determine that such user should not be considered a significant industrial user.

Significant Noncompliance: A significant industria l user (or any IU which violates paragraphs 3, 4, or 8

below) is in significant noncompliance with applicable pretreatment requirements if any violation meets

one or more of the following criteria:

1. Chronic violations of wastewater discharge limits, define d as those in which sixty

- six percent or more

of all of the measurements taken during a six

- month period exceed (by any magnitude) a numeric

pretreatment standard or requirement, including instantaneous limits, as defined by 40 CFR 403.3(l).

2. Technical Revi ew Criteria (TRC) violations, defined as those in which thirty

- three percent or more of

all of the measurements for each pollutant parameter taken during a six

- month period are equal or

exceed the product of the numeric pretreatment standard or requirement including instantaneous

limits, as defined by 40 CFR 403.3(l) multiplied by the applicable TRC.

TRC = 1.4 for BOD, TSS, f ats, o il and g rease.

TRC = 1.2 for all other pollutants (except pH).

3. Any other violation of a pretreatment standard or requirement as defined by 40 CFR 403.3(l) (daily

maximum or longer

- term average , instantaneous limit, or narrative standard ) that the District



### xdetermines has caused, alone or in combination with other discharges, interference or pass through

(including endangering the he alth of POTW personnel or the general public).

4. Any discharge of a pollutant that has caused imminent endangerment to human health, welfare or to

the environment or has resulted in the POTW's exercise of its emergency authority to halt or prevent

such a dis charge.

5. Failure to meet, within 90 days after the 

### due date

, a compliance schedule milestone contained in a

local control mechanism or enforcement order for starting construction, completing construction, or

attaining final compliance.

6. Failure to provide, w ithin 45 days after the due date, required reports such as baseline monitoring

reports, 90

- day compliance reports, periodic self

- monitoring reports, and reports on compliance with

compliance schedules.

7. Failure to accurately report noncompliance.

8. Any other vio lation or group of violations which the District determines, will adversely affect the

operation or implementation of the local pretreatment program.

Slug Discharge or Loading: 

### Any discharge at a flow rate or concentration, which could cause a

violatio n of the prohibited discharge standards the EBMUD Wastewater Control Ordinance , Section 2.2.

A slug discharge is any discharge of a non

- routine, episodic nature, including but not limited to an

accidental spill or non

- customary batch discharge which has a reasonable potential to cause interference

or pass through, or in any other way violate the District’s regulations, local limits or permit conditions

.

Source Control: Any activity that prevents the generation of hazardous waste through a change in raw

mat erials or product reformulation (material substitution), or operational or process improvements

(process modification).

Special Discharge Permit: Mandatory permit for unique or intermittent discharges that do not require a

Discharge Minimization Permit. M ay include reporting and monitoring requirements.

Terminated (T): A Minimization , Estimation or Pollution Prevention Permit that ceases to be in effect

due to reasons such as business closure, business name change or regulated process change. In

exception al cases, the Director may terminate a permit for violation of the permit terms and conditions or

the EBMUD Wastewater Control Ordinance provisions. A discharger who has a permit terminated by the

Director is required to apply for a new permit within 30 da ys of notice of termination.

Total Identifiable Chlorinated Hydrocarbons (TICH): The sum of the concentrations of all

quantifiable values equal to or greater than the detection limit for all chlorinated hydrocarbons identified

by EPA Method 624.

Total Su spended Solids (TSS) : The concentration of nonfilterable residue dried at 103° to 105°C on a

filter in conformance with the District's approved method.

Upset: An exceptional incident in which there is unintentional and temporary non

- compliance with an

IU’ s discharge limitations because of factors beyond the reasonable control of the IU.

Violation Follow

- Up Inspection: An inspection specifically conducted to continue investigation of a

past violation and assess the industry's compliance status.

Wastewate r Control Ordinance: See EBMUD Wastewater Control Ordinance

.

Wastewater Discharge Permit: This permit type establishes general and site

- specific compliance and

reporting requirements, applicable discharge limitations self

- monitoring requirements and billi ng

conditions for unique wastewater strengths and flow as applicable.



### xiWaste Minimization: See Pollution Prevention.

Wastewater Treatment Plant (WWTP): the District’s Main Wastewater Treatment Plant located at

2020 Wake Avenue, Oakland, California.

Wet Weather Facility: A remote wastewater facility designed to provide treatment of additional wet

weather flows. EBMUD’s Wet Weather Facilities were built to provide additional wet weather flow

capacity and reduce overflows of untreated wastewater during peak storm events.



### Abbreviations

BCC: Business Classification Code

BMP s : Best Management Practices

BMR: Baseline Monitoring Report

C: Consistent Compliance

CDO: Cease and Desist Order

CL: Closed

CODF: Chemical Oxygen Demand (filtered)

EBMUD: East Bay Municipal Utility District

EPA: United States Environmental Protection Agency

FY: Fiscal Year

IC: Inconsistent Compliance

IU: Industrial User

MGD: Million gallons per day

NOV: Notice of Violation (Violation Notice)

NPDES: National Pol lutant Discharge Elimination System

POTW: Publicly Owned Treatment Works

RC: Reclassified

RCRA: Resource Conservation and Recovery Act

RI: Reissued



### xiiRMP: Regional Monitoring Program

RWQCB: The San Francisco Bay Regional Water Quality Control Board

SD

- 1: EBMUD Special District No. 1

SIU: Significant Industrial User

SNC: Significant Non

- compliance

SWDA: Solid Waste Disposal Act

T: Terminated

TTO: Total Toxic Organics

TRC: Technical Review Criteria

TSS: Total Suspended Solids



### WWF: W et Weather Facility

WWTP: Wastewater Treatment Plan t

xiii

## 1. INTRODUCTION

This 201 4 report includes the Pretreatment Annual Report and the Pollution Prevention Annual Report.

The Pollution Prevention (P2) Report is fully contained in Chapter 5.



### 1.1 **EBMUD Background Information**

The East Bay Municipal Utility District (E BMUD or District) is a publicly owned utility formed under

the Municipal Utility District (MUD) Act that was passed by the California state legislature in 1921. In

accordance with the MUD Act’s provisions, voters in the East San Francisco Bay Area created EBMUD

in 1923 to provide water service. The MUD Act was amended in 1941 to enable formation of special

districts. In 1944, voters in six East Bay cities elected to form EBMUD’s Special District No. 1 (SD -1) to

provide treatment of wastewater discharged to the San Francisco Bay. In 1971, the Stege Sanitary District

was annexed to SD-1.



### 1.2 **Wastewater Service Area and Facilities**

EBMUD formed the Wastewater Department following approval of SD

- 1. The Wastewater Department is

responsible for treatment and disposal of domestic, commercial and industrial wastewater from the cities

of Alameda, Albany, Berkeley, Emeryville, Oakland, Piedmont and the Stege Sanitary District, which

includes the City of El Cerrito, the Richmond Annex and unincorporated Kensington. The ind ividual

communities maintain their own collection systems (sewers and pumping stations) that discharge to one

of five District -operated interceptors. The EBMUD Wastewater Department is responsible for the

administration and operation of the M ain Wastewater Treatment Plant ( M WWTP), the interceptors, the

District’s deep -water outfall, and th ree w et w eather facilities (WWF). The Department also operates the

District's joint water and wastewater laboratory, and t hree water recycling facilities. Detailed informa tion

about the District facilities is provided below.

• T he District's wastewater service area is 88 square mile s, including 1,700 miles of community owne d

an d maintained sanitary sewers, 15 District pumping stations , and 29 miles of District gravity sewer

intercept ors ranging from 12 inches to 9 feet in diameter and 8 miles of sewer force mains

.

• The District ’s Wastewater Department serves a population of approximately 650,000, which includ es

a pproximately 175,0 00 accounts, of which over 18, 000 are commerci al , industrial, and institutional

users.

• The District’s wastewater facilities are as follows:

a) The MWWTP that provides secondary treatment for a design capacity of 168 million gallons

per day (MGD). Primary treatment is provided for up to 320 MGD. The maxi mum wet

weather capacity including storage is 415 MGD. The 201 4 average influent daily flow was 52

MGD.

b) The Oakport, Point Isabel, and San Antonio Creek WWFs provide additional wet weather

capacity of 158 MGD, 100 MGD and 51 MGD, respectively. The flow to all the WWF s

unde rgoes screening, chlorination, and dechlorination; and Oakport and Point Isabel WWFs

also provide sedimentation. The sedimentation basins at these two facilities can provid e

st orage so the flow can be discharged back to the interceptor sys tem for treatment at th e

MW WTP once peak flows have subsided.

• The District’s water recycling facilities are as follows:

a) The North Richmond Water Reclamation Plant is designed to produce a peak of 5.4 MGD of

recycled water from West County Wast ewater District’s Water Pollution Control Plan t

( WPCP) for use in cooling towers at the Chevron U.S.A Inc. oil refinery in Richm ond,

C alifornia. In 2014, Chevron’s cooling towers used an annual average of 3.6 MGD of

recycled water.



### 1b) The Richmond Advanced Re cycled E xpansion (RARE) Wa ter P roject treats secondary

effluent from Wes t C ounty’s WPC P to a high l evel o f purity f or u se in t he boiler s at t he

Chevron Richmond refinery.

This facility currently pr ovides up to 3.3 4 MGD o f r ecycled w ater to t he refinery. The D istrict

is currently unde rtaking a feasibility st udy ev aluating t he potential t o exp and r ecycled w ater

at N orth Richmond Water Reclamation Plant and RARE.

c) T he East Bayshore Water Recycling Plant is designed to treat 2. 5 MGD of the M WWTP’ s

seco ndary effluent. The recycled water is currently used for landscape irrigation, toilet/urina l

f lushing in EBMUD’s office building, a commercial cooling tower at Pixar Studios, and

construction dust control. Current customer use is about 0.15 MGD

.



### 1.3 **Pretreatment and Pollution Prevention Program** 

The EBMUD Wastewater Department is organized into four Divisions: Wastewater Treatment,

Wastewater Engineering, Laboratory Services , and Environmental Services. The Environmental Services

Division includes EBMUD's p retreat ment and p ollution prevention (P2) program. The District's

p retreatment and P2 program monitors and controls the quality and quantity of wastewater discharged to

the District's wastewater treatment facilities. Th is r eport summarizes the pretreatment and P2 p rogram

activities implemented by the Environmental Services Division in 201 4.

D uring 2014, the District continued implementing changes to the industrial permit program that were

initiated in 2011 to creat e efficiencies while still meeting regulatory req uirements

. At the e nd of 201 4,

the District’s industrial permit program included 8 significant industrial users ( SIU ) categorical , 13 SIUs

non- categorical , 14 non- SIUs, and 21 non- SIU zero discharge– categorical permits in. The District also

issued groundw ater, special discharge, and estimation permits. More details on the permitted accounts and

monitoring are provided in Chapter 4. The District’s P2 permits were in effect for approximately 1, 135

commercial businesses such as vehicle washing facilities, photo processing businesses , and hospitals.

More details on P2 permits and activities are summarized in Chapter 5

.

T he Environmental Services Division performed inspections with sampling to assess compliance by

permitted industrial users. District staff al so conducted P2 and B usiness Classification Code (BCC)

inspections and participated in public outreach activities. More information on industrial users and public

outreach activities can be found in Chapters 4 and 5.

T he Environmental Services Division ma intains an inventory of industrial and commercial facilities in the

SD -1 service area which is continually updated based on process surveys, field inspections, city business

licenses, phone book lists, other agency lists, and industrial association lists. New water customers in the

SD

- 1 service area are classified by BCC at the time service is established through the EBMUD New

Business Office. Inspections are performed to verify that the BCC assigned to a business is consistent

with the quantity and quality of the wastewater discharge and to determine if the facility should be

regulated under the pretreatment or P2 p rogram.



### 1.4 **Pretreatment Program Evaluation**

O n April 22 and 23, 2013, United States Environmental Protection Agency ( EPA ) representatives

conducte d a Pretreatment Compliance Audit (PCA) of the District’s pretreatment program. On July 8,

2013, EPA provided a PCA findings report to the District. On September 5, 2013, the District responded



### 2to the findings report

, stating that all required corrections and recommended actions had been completed

or were scheduled to be implemented as described.

On August 22, 2013, the District’s amended Wastewater Control Ordinance (Ordinance) was adopted by

the Board of Directors to include regulatory requirements and recommendations based on the San

Francisco Bay Regional Water Quality Control Board’s (RWQCB) June 2011 sewer use Ordinance

review findings . The 2013 PCA requirements will be reviewed and captured, as needed, during the next

Ordinance update. In 2014, the re have not been adopted changes to the Ordinance pertaining to the

pretreatment program.



### 3

## 2. PLANT INFORMATION

**2.1 Upset, Interference and Pass** 

**- Through** 

In 2014, t here were no discharges from industrial users that were identified as causing the M WWTP upsets,

interference or pass

- through resulting in any violations of the District’s NPDES permit limit ation s

.



### 2.2 **Compliance with NPDES Permit Limitations**

No violations of any effluent limitations for the MWWTP were recorded in 2014, and the MWWTP

performed as expected. One unauthorized discharge of treated, chlorinated effluent from the MWWTP

occurred dur ing an intense rainstorm in December 2014, and is further described below:

• On December 11, 2014, around 10:00am, an unauthorized discharge of an estimated 40,000 gallons

of chlorinated, treated effluent occurred at the northwest edge of the main WWTP. T he discharge

occurred during heavy rains and it is believed that some of the effluent mixed with rain water may

have reached a storm drain to San Francisco Bay. The chlorine residual of the treated effluent

released was 1.8

- 2.6 milligram per liter (mg/L) as indicated by a nearby online analyzer in the

effluent channel. The discharge occurred when effluent pumping was maximized during a storm and

the increased pumping rate caused the effluent pump surge chamber to overflow. Operators were

watching the sur ge chamber level on the control system screen at the time but an incorrect control

system tag for the top of the surge chamber made it appear that the surge was contained, when in fact

it was overflowing. The inaccurate control system tag has been correct ed in the system.



### 2.3 **Biosolids Storage, Land Application and**  **Disposal Practice**

The District produces Class B biosolids with an average of 2 3 % total solids.

Biosolids are collected in an enclosed air

- scrubbed hopper located next to the Dewatering Building at the

District’s ma in wastewater treatment plant. The hopper consists of three bins, each with a capacity of

200,000 lbs or 150 cubic yards.

In 201 4 , 100% of the 73

, 922 wet tons of biosolids produced were beneficially reused with 48 % used as a soil

amen dment at land

- application sites and 52 % used as alternative daily cover at landfills.



### 2.4 **Influent, Effluent and Biosolids Monitoring Results**

Tables 2

- A , 2

- B and 2

- C summarize the analytical results for 201 4 in fluent and effluent metals, volatile

organic co mpounds and semi

- volat ile organic compounds , respectively

. Reductions in heavy metals

loadings and selected organics concentrations to the M WWTP are summarized in Figures 2

- A, 2

- B and 2

- C.

Figure 2

- D illustrates influent and effluent metals monitoring res ults for the past five years. Additional

information on heavy metals loading and organics concentr ations can be found in Chapter 5

.

Generally, metals results trended downward in 2014 compared to previous years

. M ercury influent monthly

averages for 2014 w ere all below 0.16 ug/L, which is consistently below the previous years’ averages

. Mercury 201 4 effluent results were comparable to those of the previous 5 years. Trends for 2014 organics



### 4results were generally comparable to those from the last few years. The biosolids monitoring results met all

the 40 CFR Part 503 standards for the use and disposal of Class B biosolids.

Table 2

- D presents t he analytical results of 5

- day composite biosolids samples collected during 201 4

.



### 2.5 **Plant Operating Data**

Table 2

- E s ummarizes the wastewater treatment plant operating data for 201 4

.



### 5TABLE 2

- A

2014 METALS INFLUENT AND EFFLUEN T MONITORING

Arsenic Cadmium

Influent Effluent Influent Effluent

Month SM3114B Units SM3114B Units Mon th EPA 200.8 Units EPA 200.8 Units

January 2 ug/L 1.1 ug/L January 0.3 ug/L 0.01 ug/L

February 2 ug/L 1.4 ug/L February 0.29 ug/L 0.04 ug/L

March 2.7 ug/L 1.5 ug/L March 0.37 ug/L 0.04 ug/L

April 3.4 ug/L 2.7 ug/L April 0.36 ug/L 0.05 ug/L

May 3.9 ug/L 2.2 ug/L May 0.35 ug/L 0.04 ug/L

June 2.9 ug/L 1.9 ug/L June 0.38 ug/L 0.05 ug/L

July 6.5 ug/L 3.1 ug/L July 0.45 ug/L 0.15 ug/L

August 2.6 ug/L 1.9 ug/L August 0.39 ug/L 0.05 ug/L

September 3.7 ug/L 2.3 ug/L September 0.38 ug/L 0.03 ug/L

O ctober 3.2 ug/L 2.4 ug/L October 0.38 ug/L 0.04 ug/L

November 3.5 ug/L 2.4 ug/L November 0.38 ug/L 0.06 ug/L

December 5.7 ug/L 3.4 ug/L December 0.3 ug/L 0.05 ug/L

Chromium Copper

Influent Effluent Influent Effluent

Month SM3113B Units SM311 3B Units Month EPA 200.8 Units EPA 200.8 Units

January 5.92 ug/L 0.8 ug/L January 70.2 ug/L 5.5 ug/L

February 5.28 ug/L 1.4 ug/L February 55.25 ug/L 8.7 ug/L

March 5.88 ug/L 0.8 ug/L March 69.5 ug/L 5.4 ug/L

April 14.83 ug/L 0.72 ug/L April 67.5 u g/L 7.4 ug/L

May 5.12 ug/L 0.81 ug/L May 76.4 ug/L 6.4 ug/L

June 6.08 ug/L 0.8 ug/L June 76.75 ug/L 8.7 ug/L

July 6.56 ug/L 0.69 ug/L July 97.8 ug/L 13 ug/L

August 5.78 ug/L 0.86 ug/L August 87.5 ug/L 6.9 ug/L

September 6.05 ug/L 0.77 ug/L Septem ber 90 ug/L 6.5 ug/L

October 5.32 ug/L 0.52 ug/L October 77.4 ug/L 7.2 ug/L

November 4.18 ug/L 0.74 ug/L November 75.5 ug/L 6.9 ug/L

December 5.86 ug/L 1 ug/L December 59 ug/L 6.95 ug/L



### 6Cyanide: total Lead

Influent Effluent Influent Effluen t

Month SM4500

- CN C, E Units SM4500

- CN C, E Units Month EPA 200.8 Units EPA 200.8 Units

January 0.01 mg/L 0.0015 mg/L January 6.82 ug/L 0.37 ug/L

February 0.0015 mg/L 0.0015 mg/L February 8.3 ug/L 0.55 ug/L

March 0.0015 mg/L 0.0015 mg/L March 10.55 ug/L 0.51 ug/L

April 0.0015 mg/L 0.0015 mg/L April 9.53 ug/L 0.69 ug/L

May 0.0015 mg/L 0.0098 mg/L May 6.94 ug/L 0.54 ug/L

June 0.0032 mg/L 0.0015 mg/L June 10.53 ug/L 0.69 ug/L

July 0.0015 mg/L 0.009 mg/L July 9.22 ug/L 1.2 ug/L

August 0.006 mg/ L 0.0015 mg/L August 9.15 ug/L 0.69 ug/L

September 0.0015 mg/L 0.0015 mg/L September 9.23 ug/L 3.3 ug/L

October 0.006 mg/L 0.003 mg/L October 14.34 ug/L 0.62 ug/L

November 0.003 mg/L 0.013 mg/L November 8.18 ug/L 0.75 ug/L

December 0.0015 mg/L 0.00 24 mg/L December 11.32 ug/L 1.2 ug/L

Mercury Nickel

Influent Effluent Influent Effluent

Month EPA

245.1 Units EPA

1631 Units Month EPA 200.8 Units EPA 200.8 Units

January 0.083 ug/L 0.005 ug/L January 7.16 ug/L 4.2 ug/L

February 0.071 ug/L 0. 0055 ug/L February 8.15 ug/L 5 ug/L

March 0.1138 ug/L 0.0044 ug/L March 7.7 ug/L 4.2 ug/L

April 0.154 ug/L 0.0078 ug/L April 21.83 ug/L 6.2 ug/L

May 0.0954 ug/L 0.0051 ug/L May 9.58 ug/L 5.7 ug/L

June 0.0938 ug/L 0.0057 ug/L June 9.78 ug/L 8.1 ug/ L

July 0.0652 ug/L 0.0038 ug/L July 10.82 ug/L 7.4 ug/L

August 0.1078 ug/L 0.0046 ug/L August 9.73 ug/L 8.5 ug/L

September 0.1313 ug/L 0.0039 ug/L September 10.45 ug/L 7.3 ug/L

October 0.84 ug/L 0.0043 ug/L October 8.1 ug/L 6 ug/L

November 0.0925 ug/L 0.006 ug/L November 7.18 ug/L 4 ug/L

December 0.1106 ug/L 0.0262 ug/L December 10.26 ug/L 7.1 ug/L



### 7Selenium Silver

Influent Effluent Influent Effluent

Month SM3114B Units SM3114B Units Month EPA 200.8 Units EPA 200.8 Units

January 1 ug /L 0.35 ug/L January 0.66 ug/L 0.06 ug/L

February 1 ug/L 0.33 ug/L February 0.56 ug/L 0.02 ug/L

March 1.1 ug/L 0.55 ug/L March 0.75 ug/L 0.02 ug/L

April 1 ug/L 0.58 ug/L April 0.61 ug/L 0.04 ug/L

May 1.1 ug/L 0.2 ug/L May 0.87 ug/L 0.04 ug/L

June 1 ug/L 0.2 ug/L June 0.62 ug/L 0.04 ug/L

July 1.7 ug/L 0.43 ug/L July 1.39 ug/L 0.1 ug/L

August 0.99 ug/L 0.2 ug/L August 1.12 ug/L 0.1 ug/L

September 1 ug/L 0.2 ug/L September 1.37 ug/L 0.04 ug/L

October 1.1 ug/L 0.2 ug/L October 1.4 ug/L 0.1 ug /L

November 1.4 ug/L 0.8 ug/L November 1.11 ug/L 0.04 ug/L

December 1.1 ug/L 0.69 ug/L December 0.51 ug/L 0.04 ug/L

Zinc

Influent Effluent

Month EPA 200.8 Units EPA 200.8 Units

January 158 ug/L 28 ug/L

February 140 ug/L 57 ug/L

March 165 ug/L 29 ug/L

April 152.5 ug/L 36 ug/L

May 174 ug/L 47 ug/L

June 185 ug/L 46 ug/L

July 218 ug/L 84 ug/L

August 195 ug/L 58 ug/L

September 202.5 ug/L 52 ug/L

October 176 ug/L 47 ug/L

November 177.5 ug/L 21 ug/L

December 138 ug/L 34.5 ug/L

Results are averaged over each month.

NDs are averaged as half of the MDL.



### 8TABLE 2

- B

2014 624 INFLUENT AND EFFLUEN T MONITORING

EPA 624 Average

Influent Average

Effluent

(ug/L) (ug/L)

1,1,1

- TRICHLOROETHANE ND ND

1,1,2,2

- TETRACHLOROETHANE ND ND

1,1,2

- T RICHLOROETHANE ND ND

1,1

- DICHLOROETHANE ND ND

1,1

- DICHLOROETHENE ND ND

1,2

- DICHLOROBENZENE ND ND

1,2

- DICHLOROETHANE ND ND

1,2

- DICHLOROPROPANE ND ND

1,3

- DICHLOROBENZENE ND ND

1,4

- DICHLOROBENZENE 0.133 ND

2

- CHLOROETHYLVINYL ETHER ND ND

ACROLEIN ND N D

ACRYLONITRILE ND ND

BENZENE ND ND

BROMODICHLOROMETHANE 0.22 0.28

BROMOFORM ND ND

BROMOMETHANE ND ND

CARBON TETRACHLORIDE ND ND

CHLOROBENZENE 0.105 ND

CHLOROETHANE 1.145 0.45

CHLOROFORM 9.75 7.6

CHLOROMETHANE 3.755 ND

CIS

- 1,3

- DICHLOROPROPENE ND ND

DIBROMOCHLOROMETHANE ND ND

ETHYL BENZENE 0.41 ND

FLUOROTRICHLOROMETHANE ND ND

METHYLENE CHLORIDE 0.825 0.75

TETRACHLOROETHENE 0.75 0.32

TOLUENE 5 2

TRANS

- 1,2

- DICHLOROETHENE ND ND

TRANS

- 1,3

- DICHLOROPROPENE ND ND

TRICHLOROETHENE 0.325 ND

VINYL CHLORIDE ND ND

ND = Not Detected.

Results are averaged over the entire year. NDs are averaged as half of the MDL.



### 9

### Table 2

- C

2014 EPA 625 INFLUENT AND EFFLUENT MONITORING

EPA 625 Average

Influent Average

Effluent

(ug/L) (ug/L)

1,2,4

- TRICHLOROBE NZENE ND ND

2,4,5

- TRICHLOROPHENOL ND ND

2,4,6

- TRICHLOROPHENOL ND ND

2,4

- DICHLOROPHENOL ND ND

2,4

- DIMETHYLPHENOL ND ND

2,4

- DINITROPHENOL ND ND

2,4

- DINITROTOLUENE ND ND

2,6

- DINITROTOLUENE ND ND

2

- CHLORONAPHTHALENE ND ND

2

- CHLOROPHENOL ND ND

2

- CRESO L ND ND

2

- METHYLNAPHTHALENE ND ND

2

- NITROANILINE ND ND

2

- NITROPHENOL ND ND

3,3'

- DICHLOROBENZIDINE ND ND

3

- ,4

- METHYLPHENOL 62 1.2

3

- NITROANILINE ND ND

4,6

- DINITRO

- O

- CRESOL ND ND

4

- BROMOPHENYL PHENYL ETHER ND ND

4

- CHLOROANILINE ND ND

4

- CHLOROPHENYL PHENYL ETHER ND ND

4

- NITROANILINE ND ND

4

- NITROPHENOL ND ND

ACENAPHTHENE ND ND

ACENAPHTHYLENE ND ND

ANILINE ND ND

ANTHRACENE ND ND

AZOBENZENE ND ND

BENZIDINE ND ND

BENZO(A)ANTHRACENE ND 0.5

BENZO(A)PYRENE ND ND

BENZO(B)FLUORANTHENE ND 0.48

BEN ZO(GHI)PERYLENE ND ND

BENZO(K)FLUORANTHENE ND ND

BENZOIC ACID 350 6.9

BENZYL ALCOHOL 68 ND

BIS(2

- CHLOROETHOXY)METHANE ND ND

BIS(2

- CHLOROETHYL)ETHER ND ND



### 10EPA 625 Average

Influent Average

Effluent

(ug/L) (ug/L)

BIS(2

- CHLOROISOPROPYL)ETHER ND ND

BIS(2

- ETHYLHEXYL)PHTHALATE 11.25 4.6

BUTYLBENZYL PHTHALATE 4 3.8

CHRYSENE ND ND

DI

- N

- BUTYL PHTHALATE 1.3 ND

DI

- N

- OCTYL PHTHALATE 1.2 ND

DIBENZO(A,H)ANTHRACENE ND ND

DIBENZOFURAN ND ND

DIETHYL PHTHALATE 1.285 ND

DIMETHYL PHTHALATE ND ND

FLUORANTHENE ND ND

FLUORENE ND ND

HEXACHLOROBENZENE ND ND

HEXACHLOROB UTADIENE ND ND

HEXACHLOROCYCLOPENTADIENE ND ND

HEXACHLOROETHANE ND ND

INDENO(1,2,3

- CD)PYRENE ND ND

ISOPHORONE ND ND

N

- NITROSODI

- N

- PROPYLAMINE ND ND

N

- NITROSODIMETHYLAMINE ND ND

N

- NITROSODIPHENYLAMINE ND ND

NAPHTHALENE ND ND

NITROBENZENE ND ND

P

- C HLORO

- M

- CRESOL ND ND

PENTACHLOROPHENOL ND ND

PHENANTHRENE ND ND

PHENOL 15 ND

PYRENE ND ND

PYRIDINE ND ND

ND = Not Detected.

Results are averaged over the entire year. NDs are averaged as half of the MDL.



### 11TABLE 2

- D

2014 BIOSOLIDS MONITORING R ESULTS

5

- DAY COMPOSITE SAMPLE S (MG/KG)

METHOD

PARAMETER Centrifuge

Wet

Season

24

- Feb to

28

- Feb

23 % Centrifuge

Dry

Season

07

- Jul to

11

- Jul

24 %

PARAMETER RESULT QUAL. RESULT QUAL.

EPA 6010

BARIUM 52.4 62.5

BERYLLIUM 0.065 0 .034

CADMIUM 0.444 0.406

COBALT 0.779 0.758

CHROMIUM 12.1 10.6

COPPER 81.3 85

MOLYBDENUM 2 2

NICKEL 7.29 5.85

LEAD 9.69 9.42

ANTIMONY 1.36 U 1.25 U

THALLIUM 1.19 0.855 U

VANADIUM 5.4 4.93

ZINC 164 167

EPA 7060

ARSENIC 1.36 1.44

EPA 7471A

MERCURY 0.18 N 0.19 N

EPA 7740

SELENIUM 0.5 U 0.405

EPA 7761

SILVER 0.78 0.73

EPA 8260B

ACETONE 0.26 * 2.1 N,*

ACROLEIN 0 .17 U,N 0.17 U,N

ACRYLONITRILE 0.22 U 0.22 U,N

ALLYL CHLORIDE 0.11 U,N 0.11 U

TERT

- AMYL METHYL ETHER 0.12 U 0.12 U

BENZENE 0.14 U 0.14 U

BIS(2

- CHLOROISOPROPYL)ETHER 0.12 U 0.12 U,*

BROMOBENZENE 0.19 U 0.19 U

BROMOCHLOROMET HANE 0.14 U 0.14 U

BROMODICHLOROMETHANE 0.14 U 0.14 U

BROMOFORM 0.098 U 0.098 U



### 12METHOD

PARAMETER Centrifuge

Wet

Season

24

- Feb to

28

- Feb

23 % Centrifuge

Dry

Season

07

- Jul to

11

- Jul

24 %

PARAMETER RESULT QUAL. RESULT QUAL.

BROMOMETHANE 0.32 U,N 0.32 U,N

1,3

- BUTADIENE 0.086 U 0.086 U

TERT

- BUTYL ALCOHOL 0.7 U,N 0.7 U,N,*

N

- BUTYLBENZENE 0.14 U 0.14 U

SEC

- BUTYLBENZE NE 0.14 U 0.14 U

TERT

- BUTYLBENZENE 0.17 U 0.17 U

CARBON DISULFIDE 0.11 U,N 0.11 U

CARBON TETRACHLORIDE 0.12 U 0.12 U

CHLOROACETONITRILE 0.5 U 0.5 U,N,*

CHLOROBENZENE 0.13 U 0.13 U

1

- CHLOROBUTANE 0.13 U 0.13 U

CHLOROETHANE 0.088 U,N 0.088 U,N,*

2

- CHLOROETHYLVINYL ETHER 0.14 U 0.14 U

CHLOROFORM 0.15 U 0.15 U

CHLOROMETHANE 0.14 U 0.14 U

O

- CHLOROTOLUENE 0.14 U 0.14 U

P

- CHLOROTOLUENE 0.14 U 0.14 U

DIBROMOCHLOROMETHANE 0.098 U 0.098 U

DIBROMOCH LOROPROPANE 0.11 U 0.11 U

DIBROMOMETHANE 0.17 U 0.17 U

1,2

- DICHLOROBENZENE 0.13 U 0.13 U

1,3

- DICHLOROBENZENE 0.15 U 0.15 U

1,4

- DICHLOROBENZENE 0.15 U 0.15 U

TRANS

- 1,4

- DICHLORO

- 2

- BUTENE 0.19 U 0.19 U

DICHLORODIFLUOROMETHANE 0. 074 U,N 0.074 U

1,1

- DICHLOROETHANE 0.16 U 0.16 U

1,2

- DICHLOROETHANE 0.14 U 0.14 U

1,1

- DICHLOROETHENE 0.13 U 0.13 U

CIS

- 1,2

- DICHLOROETHENE 0.16 U 0.16 U

TRANS

- 1,2

- DICHLOROETHENE 0.16 U 0.16 U

1,2

- DICHLOROPROPANE 0.11 U 0.11 U

1,3

- DICHLOROPROPANE 0.1 U 0.1 U

SEC

- DICHLOROPROPANE 0.13 U 0.13 U

1,1

- DICHLORO

- 2

- PROPANONE 0.13 U 0.13 U,N

1,1

- DICHLOROPROPENE 0.13 U 0.13 U

CIS

- 1,3

- DICHLOROPROPENE 0.11 U 0.11 U

TRANS

- 1,3

- DICHLOROPROPENE 0.1 U 0.1 U



### 13METHOD

PARAMETER Centrifuge

Wet

Season

24

- Feb to

28

- Feb

23 % Centrifuge

Dry

Season

07

- Jul to

11

- Jul

24 %

PARAMETER RESULT QUAL. RESULT QUAL.

DIISOP ROPYL ETHER 0.13 U 0.13 U

ETHYL ACETATE 0.19 U 0.19 U,N

ETHYL BENZENE 0.12 U 0.12 U

ETHYL

- T

- BUTYL ETHER 0.17 U 0.17 U

ETHYLENE DIBROMIDE 0.12 U 0.12 U

ETHYL ETHER 0.13 U 0.13 U

ETHYLMETHACRYLATE 0.15 U 0.15 U

FLUOROTRICHL OROMETHANE 0.13 U 0.13 U,N

1,1,2

- TRICHLORO

- 1,2,2

- TRIFLUOROETHANE 0.16 U 0.16 U

HEXACHLOROBUTADIENE 0.17 U 0.17 U

HEXACHLOROETHANE 0.16 U,N 0.16 U

2

- HEXANONE 0.13 U 0.13 U,N,*

IODOMETHANE 0.3 U,N 0.3 U

ISOPROPYLBENZENE 0.14 U 0.14 U

P

- ISOPROPYLTOLUENE 0.18 0.14 U

METHYLACRYLATE 0.2 U 0.2 U

METHYLACRYLONITRILE 0.17 U 0.17 U,N

METHYL

- T

- BUTYL ETHER 0.28 U 0.28 U

2

- BUTANONE 0.16 U 0.78 N,*

METHYLENE CHLORIDE 0.13 U 0.13 U

4

- METHYL

- 2

- PENTANONE 0.1 2 U 0.12 U,N

METHYLMETHACRYLATE 0.17 U 0.17 U,N

NAPHTHALENE 0.17 U 0.17 U

NITROBENZENE 0.16 U 0.16 U,N

2

- NITROPROPANE 0.13 U 0.13 U,N,*

PENTACHLOROETHANE 0.4 U,N 0.4 U

N

- PROPYLBENZENE 0.15 U 0.15 U

STYRENE 0.15 U 0.15 U

1,1,1,2

- TETRACHLOROETHANE 0.15 U 0.15 U

1,1,2,2

- TETRACHLOROETHANE 0.15 U 0.15 U

TETRACHLOROETHENE 0.12 U 0.12 U

TETRAHYDROFURAN 0.13 U 0.13 U,N

TOLUENE 0.21 0.16 U

1,2,3

- TRICHLOROBENZENE 0.15 U 0.15 U

1,2,4

- TRICHLOROBENZEN E 0.18 U 0.18 U

1,1,1

- TRICHLOROETHANE 0.13 U 0.13 U

1,1,2

- TRICHLOROETHANE 0.12 U 0.12 U



### 14METHOD

PARAMETER Centrifuge

Wet

Season

24

- Feb to

28

- Feb

23 % Centrifuge

Dry

Season

07

- Jul to

11

- Jul

24 %

PARAMETER RESULT QUAL. RESULT QUAL.

TRICHLOROETHENE 0.16 U 0.16 U

1,2,3

- TRICHLOROPROPANE 0.17 U 0.17 U

1,2,4

- TRIMETHYLBENZENE 0.17 U 0.17 U

1,3,5

- TRIMETHYLBENZENE 0.15 U 0 .15 U

VINYL ACETATE 0.14 U,N 0.14 U

VINYL CHLORIDE 0.086 U,N 0.086 U

O

- XYLENE 0.15 U 0.15 U

M+P XYLENES 0.3 U 0.3 U

EPA 8270C

ACENAPHTHENE 0.054 U,N 0.054 U

ACENAPHTHYLENE 0.096 U 0.096 U

ANILINE 0.11 U 0.55

A NTHRACENE 0.15 U 0.15 U

AZOBENZENE 0.16 U 0.16 U

BENZIDINE 2 U 2 U

BENZO(A)ANTHRACENE 0.16 U 0.16 U

BENZO(B)FLUORANTHENE 0.1 U 0.1 U

BENZO(K)FLUORANTHENE 0.084 U 0.084 U

BENZO(GHI)PERYLENE 0.24 U 0.24 U

BENZO(A)PYRENE 0. 13 U 0.13 U

BENZOIC ACID 2 U 2 U

BENZYL ALCOHOL 0.17 U 0.17 U

BUTYLBENZYL PHTHALATE 0.16 U 0.16 U

BIS(2

- CHLOROETHOXY)METHANE 0.11 U 0.11 U

BIS(2

- CHLOROETHYL)ETHER 0.068 U 0.068 U

BIS(2

- CHLOROISOPROPYL)ETHER 0.12 U 0.12 U,*

BIS(2

- ETHYLHEXYL)PHTHALATE 2.8 15

4

- BROMOPHENYL PHENYL ETHER 0.36 U 0.36 U

4

- CHLOROANILINE 0.11 U 0.11 U

P

- CHLORO

- M

- CRESOL 0.11 U 0.11 U

2

- CHLORONAPHTHALENE 0.078 U 0.078 U

2

- CHLOROPHENOL 0.058 U,N 0.058 U

4

- CHLOROPHENYL PH ENYL ETHER 0.1 U 0.1 U

CHRYSENE 0.12 U 0.12 U

DIBENZO(A,H)ANTHRACENE 0.13 U 0.13 U

DIBENZOFURAN 0.09 U 0.09 U

DI

- N

- BUTYL PHTHALATE 0.32 U 0.32 U



### 15METHOD

PARAMETER Centrifuge

Wet

Season

24

- Feb to

28

- Feb

23 % Centrifuge

Dry

Season

07

- Jul to

11

- Jul

24 %

PARAMETER RESULT QUAL. RESULT QUAL.

1,2

- DICHLOROBENZENE 0.13 U 0.13 U

1,3

- DICHLOROBENZENE 0.15 U 0.15 U

1,4

- DICH LOROBENZENE 0.15 U 0.15 U

3,3'

- DICHLOROBENZIDINE 0.16 U 0.16 U

2,4

- DICHLOROPHENOL 0.09 U 0.09 U

DIETHYL PHTHALATE 0.2 U 0.2 U

2,4

- DIMETHYLPHENOL 0.11 U 0.11 U

DIMETHYL PHTHALATE 0.11 U 0.11 U

4,6

- DINITRO

- O

- CRESOL 2 U 2 U

2,4

- DINITROPHENOL 2 U 2 U

2,4

- DINITROTOLUENE 0.15 U,N 0.15 U

2,6

- DINITROTOLUENE 0.14 U 0.14 U

DI

- N

- OCTYL PHTHALATE 0.11 U 0.11 U

FLUORANTHENE 0.4 U 0.4 U

FLUORENE 0.078 U 0.078 U

HEXACHLOROBENZENE 0.18 U 0.18 U

HEXACHLORO BUTADIENE 0.17 U 0.17 U

HEXACHLOROCYCLOPENTADIENE 2 U 2 U

HEXACHLOROETHANE 0.16 U,N 0.16 U

INDENO(1,2,3

- CD)PYRENE 0.14 U 0.14 U

ISOPHORONE 0.11 U 0.11 U

2

- METHYLNAPHTHALENE 0.13 U 0.13 U

2

- CRESOL 0.11 U 0.11 U

3

- ,4

- METHYL PHENOL 0.4 0.85

NAPHTHALENE 0.17 U 0.17 U

2

- NITROANILINE 0.14 U 0.14 U

3

- NITROANILINE 0.12 U 0.12 U

4

- NITROANILINE 0.22 U 0.22 U

NITROBENZENE 0.16 U 0.16 U,N

2

- NITROPHENOL 0.052 U 0.052 U

4

- NITROPHENOL 2 U 2 U

N

- NI TROSODIMETHYLAMINE 0.084 U 0.084 U

N

- NITROSODIPHENYLAMINE 0.58 U 0.58 U

N

- NITROSODI

- N

- PROPYLAMINE 0.084 U,N 0.084 U

PENTACHLOROPHENOL 2 U,N 2 U,N

PHENANTHRENE 0.12 U 0.12 U

PHENOL 0.42 N 2.5



### 16METHOD

PARAMETER Centrifuge

Wet

Season

24

- Feb to

28

- Feb

23 % Centrifuge

Dry

Season

07

- Jul to

11

- Jul

24 %

PARAMETER RESULT QUAL. RESULT QUAL.

PYRENE 0.3 U,N 0.3 U

PYRIDINE 2 U 2 U

1,2,4

- TRICHLOROBENZENE 0.18 U 0.18 U

2,4,5

- TRICHLOROPHENOL 0.16 U 0.16 U

2,4,6

- TRICHLOROPHENOL 2 U 2 U

EPA 9010

CYANIDE: TOTAL 0.2 ND 0.2 U

EPA 9034

SULFIDE: TOTAL 1300 230

Qualifier Legend

RL1

- Reporting limit raised due to sample matrix effects.

RL3

- Reporting limit raised due to high concentrations of non

- target

analytes.

ND = Not Detected

U = Analyte not detected.

* = Duplicate values outside of control limits.



### 17

### TABLE 2

- E

WAS TEWATER TREATMENT PLANT OPERATING DATA

– 2014

Units Jan Feb Mar April May Jun Jul Aug Sept Oct Nov Dec Total Avg Min. Max.

GENERAL PLANT DATA

FLOW DATA

Daily Average MG 48 66 60 64 49 48 46 45 47 47 49 96 55 45 96

Daily Minimum MG 41 47 45 50 45 45 44 41 42 42 44 54 45 41 54

Daliy Maximum MG 52 155 104 148 53 55 52 49 53 51 72 256 92 49 256

Monthly Total MG 1,486 1,840 1,864 1,914 1,524 1,428 1,430 1,402 1,395 1,449 1,461 2,982 20,175 1,681 1,395 2,982

INFLUENT QUALITY

CBOD (avg.) mg/l 298 261 281 282 282 312 340 343 366 358 358 227 309 227 366

TSS (avg.) mg/l 336 345 391 416 449 560 451 483 483 362 386 335 416 335 560

pH (avg.) pH 6.7 7.1 7.1 7.2 7.0 7.0 6.9 6.6 6.6 6.7 6.8 6.9 6 .9 6.6 7.2

EFFLUENT QUALITY

CBOD (avg.) mg/l 10 11 9 8 15 10 8 8 8 9 10 12 10 8 15

TSS (avg.) mg/l 15 16 16 12 26 24 21 13 14 12 14 15 17 12 26

pH (avg.) pH 6.8 6.8 6.8 6.8 6.7 6.7 6.7 6.6 6.6 6.7 6.8 6.8 6.7 6.6 6.8

OVERALL REMOVAL EFFI CIENCY

CBOD % 96 95 97 97 94 97 97 98 98 98 97 94 97 94 98

TSS % 96 95 96 97 94 94 94 97 97 96 96 94 96 94 97

POWER GENERATION

Electricity Produced (net) MWh 5,144 4,455 5,119 4,597 4,619 4,191 4,500 4,516 4,415 4,333 4,422 4,510 54,819 4 ,568 4,191 5,144

Power Exported MWh 1,883 1,358 1,483 1,148 1,427 967 1,182 1,295 1,377 1,522 1,244 644 15,529 1,294 644 1,883

Power Used on Site MWh 3,261 3,098 3,636 3,449 3,192 3,224 3,319 3,221 3,037 2,811 3,177 3,866 39,291 3,274 2,811 3,866

PG&E Power Purchased MWh 38 345 115 247 399 469 149 216 102 435 65 660 3,240 270 38 660

Total Power Used at WWTP MWh 3,299 3,442 3,751 3,696 3,591 3,693 3,468 3,437 3,139 3,246 3,243 4,525 42,531 3,544 3,139 4,525

PG&E % of Total Power Used % 1% 10% 3% 7% 11% 13% 4% 6% 3% 13% 2% 15% 7% 1% 15%

Production in Excess of Plant Needs % 56% 29% 36% 24% 29% 13% 30% 31% 41% 33% 36% 0% 30% 0% 56%

BIOSOLIDS

LANDFILL (wet tons) tons 5,376 5,949 6,482 5,125 1,650 1,291 1,423 1,286 1,246 1,382 1,243 6 ,351 38,804 3,234 1,243 6,482

LAND APPLICATION (wet tons) tons 0 0 0 1,344 4,692 4,454 4,610 4,923 5,204 5,270 4,521 101 35,119 2,927 0 5,270

SEED SLUDGE EXPORTED (wet

tons) tons 113 0 0 0 0 0 0 0 0 0 0 0 113 9 0 113



### 180 50 100 150 200 250 300 350 400 450 500

Zinc Chromium Copper LeadKg/Day FIGURE 2

- A

EBMUD Plant Loading 1974 and 2014

Zinc, Chromium, Copper, & Lead Reductions

1974

2014

0 5 10 15 20 25 30 35 40

Cadmium Nickel SilverKg/Day FIGURE 2

- B

EBMUD Plant Loading 1974 and 2014

Cadmium, Nickel, & Silver Reductions

1974

2014

1974 Silver loading not available.0 10 20 30 40 50 60 70

Methylene Chloride Tetrachloroethene Tolueneμg/L FIGURE 2

- C

EBMUD Influent Concentrations 1988 and 2014

Selected Organics Reduction

1988

2014

### Arsenic Influent Arsenic Effluent

Cadmium Influent Cadmium Effluent

Chromium Influent Chromium Effluent

Copper Influent Copper Effluent Figure 2-D

5-Year Graph of Metals Influent and Effluent

### Copper Influent Copper Effluent

Lead Influent Lead Effluent

Mercury Influent Mercury Effluent

Nickel Influent Nickel Effluent Figure 2-D

5-Year Graph of Metals Influent and Effluent

### Nickel Influent Nickel Effluent

Selenium Influent Selenium Effluent

Silver Influent Silver Effluent

Zinc Influent Zinc Effluent Figure 2-D

5-Year Graph of Metals Influent and Effluent

### Zinc Influent Zinc Effluent Figure 2-D

5-Year Graph of Metals Influent and Effluent

## 3. PRETREATMENT PROGRAM

- GENERAL INFORMATION

Through its Pretreatment Program, EBMUD regulates process wastewater discharges from identified

industrial users ( IU s ) that handle pollutants of concern

. Pollutant control mechanisms include the issuance of

wastewater discharge permit s with general provisions and site

- specific requirements. The different permit

types ar e detailed below under section 3 .3.



### 3.1 **Pretreatment Program Changes and Highli ghts** 

During 20 1 4

, the District co mpleted the in

- depth review of its Wastewater Control Ordinance and all

elements of its pretreatment permit program , confirming that the EPA’s Pretreatment Streamlining Rule has

been implemented appropriately and effective ly. The District is reviewing new permit nomenclature for

clarification and pretreatment program streamlining

.

In 201 4 , the District’s p retreatment permit p rogram included 2 1 N on

- S ignificant C ategorical I ndustrial U sers

(NSCIUs)

. 18 of the NSCIUs do not discharge regulated process wastewater to the sanitary sewer . Detailed

information about the se NSCIUs is provided in Chapter 4.

In 2014, one categorical facility, Libby Laboratories Inc., was reclassified from a zero discharger to a n

NSCIU. Historically, Libby Laboratories was classified as a zero discharger because this facility had

reported that they do not discharge any regulated process wastewater to the community sewer. However,

Libby was reclassified as an NSCIU since its disc harge contained regulated process wastewater. Although

Libby Laboratories has never used any of the regulated parameters in their p rocesses, their process

wastewa ter is subject to regulation under the pharmaceutical manufacturing guidelines. Furthermore, t hey are

not considered a zero discharger because they discharge < 100 gallons per day of process wastewater.

In 2014, staff noted that The Boardworks was inadvertently reported as an SIU in the annual report. Staff is

correcting the oversight in this annu al report. The Boardworks is classified as an NSCIU since they discharge

≤ 100 gallons per d ay.

In 2014

, a total of 2 non

- categorical SIU facilities

, Brittell Environmental Corporation (Brittell) and CEMEX

Construction Materials Pacific (CEMEX) were delisted as SIUs because of consistent compliance with their

respective permit terms. CEMEX’s permit with zero discharge of process wastewater to the community

sewer remains active. Brittell no longer requires regulatory oversight for discharges to th e sanitary sewer

, as

the facility’s current core business is handling photoprocessing solid waste.

In 2014

, a total of 7 new Special Discharge Permits were issued

, mainly for construction dewatering. A total

of 3 new groundwater remediation permits were also issued

. A total of 6 Special Discharge Permits were not

renewed due to completion of the regulated discharge to the sanitary sewer.



### 3.2 **Pretreatment Program Staffing and Budget**

The District’s Pretreatment Program is implemented by the Environmental Serv ices Division (ESD), under

the direction of the Environmental Services Manager. The Division consists of the following four work

groups:



### 25

### • Resource Recovery: uses excess wastewater treatment capacity to provide an

environmentally

- friendly and economical disposal alternative fo r customers, and to increase

the MWWTP's production of biogas that is used for power generation.

• Private Sewer Lateral: works to reduce wet weather flows, which can overwhelm

wastewater treatment facilities and lead to the release of partially treated wast ewater into the

Bay, by preventing the infiltration of rainwater into private sewer laterals (PSLs).

• Field Services: supports the Industrial Discharge, Resource Recovery, and PSL Programs by

performing site inspections and sampling.

Staffing for these four work groups is shown on the chart below.



### 26

### ESD Organizational Chart

27The District’s pretreatment budget is funded through permit holder fees and charges, including an annual

permit fee, monitoring/testing fees, and violation follow

- up fees/penalties. P2 activities are funded through

two discrete fee assessments on customers within the District’s wastewater service area: 1) S an F rancisco

Bay Commercial P2 Fee

, charged to all industrial and commercial accounts, $5.48/month in 201 4 and 2) S an

F rancisco Bay Residential P2 Fee , charged to all residential customers, $ 0

. 20/month in 201 4 . The fees

support P2 program development and outreach. The District’s P2 program is detailed in Chapter 5

. The

District’s PSL and R2 programs are funded through PSL and R2 fees , respectively

.

The 201 4

, ESD budget and specia l fees are summarized in Table 3

- A and 3

- B

. The wastewater rates, fees,

and charges are available on the EBMUD website at :

http://www.ebmud.com/water

- and

- wastewater/wastewater

- rates

- charge s

- and

- fees

EXPENDITURES DOLLARS ($)

Personnel $4,791,340

Equipment, Operations & Maintenance, Training & Travel $ 252,625

Professional Services $ 114,006

Laboratory Analyses $ 1 55,037

Total $ 5

, 313

, 00 8

Industrial Permit Application Fees

Discharge Minimization Permit $2,450 Annual 1

Discharge Estimation Permit $920 Annual 2

Special Discharge Permit $995 Annual

Wastewater Disposal Treatment Charges

Treatment Depends on Strength (CODF & TSS) and Volume

Monitoring Fees

Labor and Equipment $ 1,0 7 0.00

Resource Recovery Non

- Hazardous Materials Program Fees

Permit Application Fee $ 3 00.00 ( Annual )

Treatment Depends on strength of waste

Other Fees

SF Bay Commercial Pollution Prevention Fee 3 $5.48/month

SF Bay Residential Pollution Prevention Fee 4 $0.20/month per dwelling unit

1 Annual increase fo r existing customer permits will be limited to 10%

2 Annual increase for existing customer permits will be limited to 10%.

3 SF Bay Commercial Pollution Prevention Fee applies to non

- residential customers.

4 SF Bay Residential Pollution Prevention Fee appl ies to all residential accounts. Fee will be charged per dwelling unit

up to 5 dwelling units. TABLE 3

- A

ESD Expenditures

– Calendar Year 201 4

TABLE 3

- B

Wastewater System Special Fees

Effective July 1, 201 4



### 28TABLE 3

- B

Wastewater System Special Fees

Effective July 1, 201 4

Violation Follow

- Up Fees

Stage One $6 7 0.00 + laboratory charges for tests performed

Stage Two $1, 41 0.00 + laboratory charges for tests performed

Stage Three $2, 950 .00 + laboratory charges for tests performed



### 3.3 **Permit Types**

EBMUD currently issues the following permits.

Waste water Discharge Permits

This permit type establishes general and site

- specific compliance and reporting requirements, applicable

discharge limitations self

- monitoring requirements and billing conditions for unique wastewater strengths

and flow. Th e permit application requires in

- depth information on the facility’s operations

, including a

description of all process es and handling of generated waste, schematic flow diagrams, facility layouts, and a

comprehensive water balance. The application becomes part of the permit once issued. All dischargers in the

following categories must obtain a wastewater discharge permit:

1. Significant Industrial Users, as defined in Title I, Section 3 of the District’s Wastewater Control

Ordinance.

2. Dischargers identified by the Di rector

, so that wastewater disposal charges based on flow and waste

strength may be established , including :

i. Dischargers whose average wastewater strength cannot be established on a BCC basis, because

of seasonal or other variations in operations.

ii. Dischar gers whose wastewater strength exceeds the normal range of wastewater strength for

the business classification code to which the discharger is assigned.

iii. Dischargers using an unmetered source of water.

3. Other dischargers determined by the Director to require individual or general permits as necessary to

carry out the purposes of the District’s Wastewater Control Ordinance.

Non

- Significant Categorical Industrial User Permit

This permit category is allowed under the P retreatment S treamlining R ule. NSCIU permits are issued to :

• C ategorical facilities that do not discharge regulated process wastewater

. The District previously

issued these facilities a zero discharge permit . Permit holders include :

a. Facilities with categorical processes that report zero discharge of regulated process

wastewater to the community sewer.

b. Pharmaceutical facilities with categorical processes that discharge process wastewater, but

are able to certify and confirm through analysis of the discharge that the regulated pollutants

ar e not used or generated at the facility.

• C ategorical facilities that discharge ≤100 gpd of regulated process wastewater. These facilities

previously held a wastewater discharge permit ( described above )

.



### 29In 2014

, the District updated its annual zero discha rge permit certification form to accommodate all NSCIUs

. The form

, now titled D ischarge P revention C ompliance R eport, Annual Certification for Non

- Significant

Categorical Industrial Users , includes the required EPA certification statement

. In addition to the annual

certification, the District is requiring an annual water balance review to support a facility’s NSCIU status.

The District inspects each NSCIU facility once every five years

. The inspection includ es a review of onsite

documents/ waste manif ests that support the facility’s NSCIU status

, confirm ing that generated wastes are

appropriately handled. The District’s NSCIU Permit Program is funded through the District’s San Francisco

Bay Commercial Pollution Prevention Fee (P2 Fee) , assessed on all industrial and commercial accounts.

Pollution Prevention (P2) Permit

A P2 permit establishes best management practices (BMPs) for identified commercial categories that

generate pollutants of concern. BMPs may include discharge prohibitions and/or process wastewater

treatment specific to each category. F acilit ies may be inspected to ensure compliance with their permit

requirements. The P2 permit program is funded through the P2 Fee

. The District issues P2 permit s to the

following categories : boat yards , dental practices, dry cleaning, furniture stripping, hospitals , photo

processing, printing, radiator repair, vehicle repair, and vehicle washing.

Special Discharge Permit

A s pecial d ischarge p ermit regulates nonpermanent wastewater discharges that require limited control

measures. Examples of sources include: construction dewatering projects

, episodic cleaning activities,

groundwater monitoring well testing, or other limited

- term activities that generate wastewater with pollutants

of concern. The permit term is sit e specific. Wastewater treatment costs are the same as the rates established

for the respective waste streams under the District’s Resource Recovery Program (described in the following

section)

.

Discharge Estimation Permit

An estimation permit is issued to facilities that request a District estimation of wastewater flow because more

than 20% of their metered consumption is not discharged to the community sewer

. The District may issue an

estimation permit with a <20% diversion o f metered flow if the facility demonstrates the diversion is

significant. The permit establishes wastewater flow and billing conditions , allowing a credit for the water

diversion.



### 3.4 **Resource Recovery Program** 

EBMUD’s Resource Recovery Program manages the disposal of permitted trucked materials to the District’s

M WWTP. Since its inception, the program h as es t ablished 493 customer accounts; current l y 271 accounts are

active

, holdi n g 423 a ctive waste disposal agreements. Typical materials hauled to the M WWTP include

septage; food industry waste, including winery and brewery , dairy, and high total dissolved solids waste,

animal process waste, food grade fats, oils, and greases; municipal/water and wastewater sludges;

ground water and storm water.

The program uses available excess capacity at the M WWTP

, allowing for a larger customer base over which

to distribute operating costs. It provides for a cost

- effective, economically

- sound disposal alternative for

customer s, and inc reases the M WWTP's production of methane gas that is used for power generation. Many

of the materials delivered to the program have been diverted from landfill disposal

, and therefore the capture

and destruction of methane represents destruction of a signi ficant greenhouse gas source. This service



### 30represents a preferred environmental alternative where the level of treatment is enhanced over other viable

options.

Materials must meet a rigorous review process prior to acceptance to ensure compliance with mul tiple

criteria including: workplace health and safety issues, plant process impact, NPDES permit, air permits, and

biosolids regulations. The materials acceptance and control process includes material profiling, site

inspections, sampling and analysis, com parison with waste acceptance criteria, permitting, first load

confirmation sampling, and an on

- going audit program. The audit program consists of site inspections and

sampling

, and periodic unannounced field and lab sampling for constituents of concern , e.g., organics and

metals

.

Table 3

- C summarizes a description of trucked materials and volumes

.

Category Material Type Gallons/ 2014 Description

Septage Septage 17,124,361 Domestic sewage from septic tanks & portable toilets.

Sludge Potable water

treatment sludge

9,131,515 Sludge from drinking water treatment facilities including well

head treatment: sludge from the various processes used to remove

suc h impurities as sediment, bacteria, algae and other

microorganisms.

Wine lagoon sludge Sludge from winery lagoon cleaning, containing organic residues

from wine making and contaminants consistent with the main

WWTP influent waste stream.

Municipal

wastewater sludge Sludge from municipal anaerobic digester cleaning, primary or

secondary sludge tank cleaning or diversion, consistent with the

main WWTP’s sludges.

Potable water

reservoir bottoms Solids from drinking water reservoirs, contains contaminants

consistent with the main WWTP’s influent waste stream

. Fat, oil & grease

(FOG) FOG 12,258,265 Restaurant and food handling facilities grease trap & interceptor

waste.

Non

- contact process

water Non

- contact process cooling water from equipment testing,

cleaning, or cooling towers. Waste contains contaminants

consistent with the main WWTP’s influent waste stream

. Rinse water Wash water from interior or exterior of tanks used in the storage

and treatment of potable water, or from boiler and/or cooling

tower maintenance, or from tank cleaning for product, process or

waste storage tanks. Waste contains contaminants consistent wit h

the main WWTP’s influent waste stream.

Industrial Water/wastewater

treatment waste

123,213,165 Waste product from water or wastewater treatment, such as

polymer or sodium hypochlorite. Waste from pretreated car wash

water and water treatment residuals. Waste contains chemicals

used in the wastewater treatment plant process.

Waste from sewer

line cleaning Waste from sanitary sewer line cleaning. Waste contains

contaminants consistent with the main WWTP’s influent waste

stream

. Winery processing

(low strength) waste Low strength winery processing waste water. Waste contains

contaminants consistent with the main WWTP’s influent waste

stream

. TABLE 3

- C

R esource Recovery

– Trucked Materials, Volumes and Descriptions



### 31Category Material Type Gallons/ 2014 Description

Bridge construction

waste Seawater, drilling slurry, and non

- hazardous concrete wash water.

Contains bay mud, seawater, and contaminants consistent with the

main WWTP’s influent waste stream

. Biotech processing

waste Pasteurized fermentation waste and non

- hazardous alcohol

wastewaters (flashpoint > 140 deg F) from pharmaceutical biotech

companies. This waste may be categorically regulated and must

meet those requirements prior to being accepted for discharge.

Pre

- treated car wash

waste Wastewater from the pre

- treatment of car

- wash water.

Final rinse water

from biodiesel

processing Wastewater from the production of biodiesel fuels that is captured

in the final step multi

- rinse process.

Groundwater/

Stormwater Groundwater and stormwater from construction sites, stormwater

collection systems, installation of monitoring wells, or existing

monitoring wells. Waste contains contaminants consistent with

the main WWTP’s influent waste stream.

Food and animal

processing Waste glycerin

87,774,579 The byproducts from biodiesel production, often refined for

animal feed; very high strength material.

Food and beverage

processing waste H igh strength waste from the manufacturing of food and

beverages. Includes pre

- sorted ground food waste, waste or

expired product, wash down water by

- products, food

- compatible

cleaning products, and off

- spec wastes, and dairy process by

products.

Winery processing

( high strength)

waste High strength winery processing waste water, for example lees.

Waste contains contamina nts consistent with the main WWTP’s

influent waste stream

. Rendering waste A nimal (beef, chicken, fish and pork) residuals, which have been

heat or chemically treated in accordance with California

Department Food and Agriculture requirements.

Poultry processing

waste H igh strength waste consisting of chicken and turkey blood.

Turkey and chicken lungs waste contains some pathogen s in

quantities similar to the main WWTP’s influent waste stream.

Beef, sheep, and

swine processing

waste H igh strength waste consisting of beef, sheep, and swine blood.

Waste contains some pathogens similar to the main WWTP’s

influent stream.

Alkaline Hydrolysis High strength waste consisting of dissolved organic matter from

expired animals.



### 3.5 **Inspection and Sampling Procedures** 

3.5.1 Business Classification Code Inspection

The District classifies customers using BCC s for specific business activities and established specific strength

(CODF and TSS) values for each BCC. The purpose of a BCC inspection is to verify that a fac ility is

classified correctly. The inspection may include the following:

1. Observe facility processes that generate wastewater.

2. Review water uses and discharges and when there are multiple accounts, verify if their use is

consistent with their SD code

, agency rate qualifier

.



### 323. Observe other operating conditions. Observations may be forwarded to other agencies.

4. Collect samples if process waste water discharges have the potential of violating the EBMUD

Wastewater Control Ordinance limits and/or if waste water strength information is needed. Potential

sampling location(s) is documented for future sampling.

5. Document significant observations made during the inspection on a BCC Field Inspection sheet. The

sheet may include sketches, diagrams of plant layout , blueprints and flow charts of processes.

6. Report whether assigned BCC and SD codes are correct or if a change is required.



### 3.5.2 Initial Industrial User Inspection

The initial IU inspection includes a comprehensive review of the types of processes, wastes gene rated an d

method(s) of waste disposal. The primary concerns are water use, process wastewater discharge,

identification of a representative sample loc ation(s), and potential of hazardous material s entering the

sanitary sewer. P ollution prevention opportun ities may be discussed in addition to identifying environmental

cross

- media issues

.

The i nspection s may include the following:

Pre

- Inspection

1. Collect historical information including water consumption history.

Inspection

1. Interview facility contact.

2. Inspect the facility thoroughly with emphasis on:

• processes contributing to the waste stream

• materials entering the waste stream

• process flow

• pretreatment processes

• sampling location(s)

• waste and product storage areas

• Material Safety Data Sheets for hazardous chemicals used in process

• Existing pre

- treatment systems and the potential to bypass.

Post

- Inspection

1. Complete a Special District 1 Wastewater System Inspection Report (SD

- 124 form) with

accompanying sketches of the plant, process flow diagrams and facility schematics, as appropriate.

2. Review inspection results with a Wastewater Control Representative to determine if sampling or a

Wastewater Discharge Permit is required.



### 3.5.3 Inspection s

- Significant Industrial User and Non

- Significant Industrial Use r

The monitoring frequency for a facility is determined by the minimum required monitoring frequencies

through the federal standards for categorical industrial users

. Additional factors for categorical and non

categorical facilities include complianc e his tory of the discharger, relative consistency of pollutant

conc entrations in the discharge, discharge volume, and the nature of the pollutants discharged. Table 3

- D

describes the industrial user types and the respective minimum federal monitoring frequencie s.



### 33Discharger Category Industrial User EBMUD

SIUs:

• CIU >5,000 gpd

• Non

- Categorical SIU

• CIU

- Mid Tier ≤5,000 gpd Once every six months

Once per year Once per year

Once every two years

Non

- SIUs Typically BMP

requirements Every two to five years, site specific

NSCIU ≤100 gpd Not applicable 1 evaluation per year

Categorical Zero Dischargers Not applicable Once every 5 years

The monitoring frequency for SIUs is equal to or greater than the minimum required through the federal

categorical regulations. The monitoring frequency for non

- SIUs may be based on strength concerns for

billing purposes and local limits. These permits may als o be focused on the implementation of specific BMPs

rather than monitoring the discharge.

The inspections and sampling events are generally unannounced, except where coordination is necessary to

sample batch discharges or there are security or access issu es. Inspectors are responsible for scheduling

inspections of their assigned accounts during the year. Accounts are rotated so that all inspectors become

familiar with all facilities under the pretreatment program. The inspection may include the following:

Pre

- Inspection

1. Collect information from the inspection program, permit, permit review notes, previous inspection

reports, and the assigned Wastewater Control Representative.

2. Review inspection program for site specific information. The inspection program may contain:

• safety precautions

• special instructions

• sample types and analyses required

3. Gather equipment according to the requirements of the sampling program established for the facility.

The sampling program will specify the equipment and any unique materials needed.

Inspection

1. Take grab samples and install sampler upon arrival.

2. Read water service meters and sub

- meters.

3. Interview the facility contact to determine the level of production, types of products and wastes

currently being generated, the sta tus of any pretreatment system

, and to answer specific questions

listed in the inspection program.

4. Conduct a walk

- through of the facility with the facility contact. Verify information obtained in the

interview.

5. Observe facility operations.

• Compare observ ations with information in the permit and from the contact interview.

• Verify plant layout and update as necessary.

• Observe wastewater flow and make visual assessment of discharge quality.

• Evaluate the potential for accidental spills to wastewater stream. Every two years, conduct Slug

Control Plan Evaluation to determine if the facility needs a Slug Control Plan.

• Document secondary water uses such as boilers, air scrubbers, cooling water a nd clean up.

• Review private meter calibration records. TABLE 3

- D

EBMUD Minimum Monitoring Frequency



### 34• Locate areas where rainwater or groundwater might collect and flow into the sanitary sewer.

• Observe other operating conditions. Observations may be forward ed to other agencies.

6. Pretreatment System. Determine if:

• system is functioning

• necessary chemicals are in inventory

• routine preventive maintenance procedures are being performed and by whom

• a contingency plan is in place in case of a treatment system fail ure

• operating records are up to date

7. Re view self

- monitoring procedures including sampling frequency, sampling methods, sampling

location, and chain

- of

- custody annually with responsible personnel.

Post

- Inspection

1. Complete a sample description form and deli ver samples to the laboratory for analysis with the

chain

- of

- custody record.

2. Complete an inspection report detailing the inspection results.

3. Inform the assigned Wastewater Control Representative of any unusual conditions or observations,

including the need for a Slug Control Plan.



### 3.5.4 Inspection

- Zero Discharge

The Zero Discharge Categorical facilities are inspected to verify that there is no discharge of regulated

process wastewater to the sanitary sewer. The methods of recycling and/or off

- hauling of process wastewater

are reviewed during the inspection. Sampling is performed only when discharge violations are suspected or

as follow

- up to a permit violation. Non

- Significa nt Categorical Industrial Users discharging no more than

100 gallons per day o f re gulated wastewater and Zero Dischargers are monitored at the same frequency.

These IUs are required to submit an annual dischar ge prevention compliance report for EBMUD’s annual

evaluation of their discharge status. In addition, EBMUD conducts facility ins pections at each NSCIU and

ZD at least once every five years. T o qualify for this reduced monitoring frequency , the discharger must have

complied with all applicable categorical pretreatment standards and requirements, submit ted the certification

statement required in 40 CFR 403.12 (q), and must not have discharge d any federally regulated process

wastewater. Sampling is performed only when discharge violations are suspected or as follow

- up to a permit

violation.

Zero

- discharge inspections may include the following:

Pre

- Inspection

1. Collect information from the Inspection Program, Permit, previous inspection reports and the

assigned Wastewater Control Representative.

2. Review water consumption history from Customer Information System to determine water usage and

compar e with their stated water uses such as sanitary, non

- contact cooling water

, and boiler blow

down wastewater.

Inspection

1. Interview the facility contact to determine if there is discharge of regulated pr ocess wastewater or

wastewater of local toxic concern to the sanitary sewer.

2. Ask about the level of production, types of products and wastes being generated, status of

pretreatment system and the method of wastewater disposal.

3. Conduct a walk

- through of t he facility with the facility contact.

4. Observe other operating conditions. Observations may be forwarded to other agencies.

5. Determine if appropriate safeguards are in place to en sure process wastewater is not discharged to the

sanitary sewer. Safeguard examples include permanent sealing of the sanitary sewer and floor drains,

installation of berms, and capping or removal of process wastewater discharge pipes.



### 356. Inspect facility for presence of containers, hoses, or other conveyances which may be used for t he

temporary discharge of process wastewater to the sanitary sewer.

7. Determine if there have been any changes to the premises or operations which may result in discharge

of process wastewater.

Post Inspection

1. Complete the Inspection Report detailing the inspection results.

2. Inform the assigned Wastewater Control Representative of any unusual conditions or observations.



### 3.5.5 Inspection

- Pollution Prevention

Commercial facilities issued P2 permits were previously inspected once every five years. Inspection

fre quency for each P2 category is being reviewed to focus efforts on types of sites with the most p otential for

discharge violations, and inspection frequency will vary among P2 permit groups as well as among sites

within individual P2 groups. Some sites may be inspected annually while others may not need regularly

scheduled inspections.

P2 inspections may include the following:

Pre

- Inspection

1. Collect information from the Inspection Program, permit, previous inspection reports and the assigned

Wastewater C ontrol Representative.

2. Industry specific Inspection Programs are used to conduct inspections and to notify operators

immediately of violations.

Inspection

1. Industry specific Inspection Programs contain:

 compliance checklist for permit requirements

 general information

 comment section

2. Interview the facility contact to determine the level of production, types of products and wastes being

generated, status of pretreatment system and to answer any specific questions appearing on the

Inspection Program.

3. C onduct a walk

- through of the facility with the facility contact. Verify information obtained in the

interview. Note violations and comments in the inspection report.

4. Observe other operating conditions. Observations may be forwarded to other agencies.

5. Pr etreatment System. Determine if:

• system is functioning

• necessary chemicals are in inventory

• operating manuals are on

- site and current

• routine preventive maintenance procedures are being performed and by whom

• operating records are current

6. Take measurements of grease interceptors at food handling facilities

. 7. Present business

- specific educational materials to facility contact, if appropriate. Materials may

include BMPs, discharge prohibition poste rs or frequently asked question and answer information

sheets.

Post Inspection

1. Complete an Inspection Report detailing the inspection results.

2. Inform the assigned Wastewater Control Representative of any unusual conditions or observations

. 3. If requested, provide compliance information to the county Green Business Program

.



### 36

### 3.5.6 Inspection

- Special Discharge

A Special Discharge Permit term ranges from 90 days to five years

, and the discharge volume varies

depending on the type of discharge. Inspections are scheduled as needed and may include sampling. The

sampling depends on the source and volume of discharge. Inspectors colle ct samples as indicated by the

Inspection P rogram. Inspectors verify that the facility is utilizing its pretreatment unit and/or implementing

its best management practices. Inspectors determ ine if the process diagram, the pretreatment system, and the

discharge location correspond to information submitted as part of the Special Discharge Permit application.

Special Discharge inspections may include the following:

Pre

- Inspection

1. Collect info rmation from the inspection program, permit, and the assigned Wastewater Control

Representative.

2. Review the inspection program for site

- specific information. The inspection program may

contain:

• safety precautions

• special instructions

• sample types and anal yses required

3. Contact the facility to determine time and day of discharge.

Inspection

1. Interview the facility contact to obtain answers to specific questions appearing on the inspection

program.

2. Conduct a walk

- through of the facility with the facility contact. Verify information obtained in the

interview.

Post

- Inspection

1. Deliver any samples to the District's laboratory for analysis accompanied by the chain

- of

- custody

and EBMUD Laboratory Servic es Special Discharge Program Field Services Sampling Request

Form.

2. Complete Special Discharge inspection report.

3. Inform the assigned Wastewater Control Representative of any conditions or observations that

suggest non

- compliance with the permit.



### 3.5.7 Violation Follow

- Up Inspection

A Violation Follow

- Up I nspection is performed after a discharge violation is found during a n inspection, a

self

- monitoring event, or a District sampling event. The Violation Follow

- Up Inspection focuses on specific

areas associated w ith the cause of the violation. In addition, the Violation Follow

- Up I nspection verifies the

corrective actions reported by the facility, as well as adherence to any compliance time schedules or

inc remental remedial measures. The account is charged a Vio lation Follow

- up Inspection Fee plus analytical

charges.



### 3.5.8 Resource Recovery (R2) Program Random Field Audit Program

As part of EBMUD’s R2 program

, a field audit inspection program is in place to test consistency with permit

conditio ns. The audit is conducted by wastewater staff and typically includes review of a truck driver’s paper

work (permit number, hauling company name, waste generator name, volume of tanker, and description of

waste characterization), physical inspection of was te, and sampling . In addition

, all drivers receive site

orientations before discharging for the first time at each of the truck receiving stations at the plant. The site



### 37orientations include orientation to plant hazards, rules of conduct, and specific disc harge instructions for each

disposal location.



### 3.6 **Enforcement Procedures**

3.6.1 Legal Authority

In November 1944, under the provisions of the amended MUD Act, EBMUD created SD

- 1 to collect and

treat wastewater from cities within the SD

- 1 service area. The wastewater is collected through EBMUD’s

interceptor system and treated at the District’s wastewater treatment plant. The treatment plant operates

under N PDES No. CA0037702, effective May 1, 2010, through RWQCB Order No. R2

- 2010

- 0060.

The District implements and enforces its approved pretreatment program in accordance with 40 CFR 403,

RWQCB Order No. R2

- 2010

- 0060, and EBMUD Wastewater Control Ordinance. The Ordinance establis hes

regulations for the control, interception, treatmen t, and disposal of wastewater. In addition

, it provi des for

enforcement and penalties for violations of the established regulations. The Ordinance was amended

effective August 22, 2013 to include enhancements to Title VI

– Enforcement and Penalties, for more

effective enforcement actions consistent with EPA regulations and California State law. Minor updates were

made throughout the document to remove outdated lang uage and ensure c onsistent use of defined terms.

Title VIII

– Regulation of Private Sewer Laterals, was removed and adopted as a stand

- alone document

titled, Regional Private Sewer Lateral Ordinance

.

The Ordinance is available online at: http://www.ebmud.com/sites/default/files/pdfs/wastewater

- control

ordinance

- 8

- 22

- 2013.pdf



### 3.6.2 Enforcement Response

The District’s established Enforcement Response Plan (ERP) rem ains in e ffect. The ERP, which provides

guidance for enforcement of Federal regulations and Ordinance provisions

, was last amended in July 1996.

The District is updating its ERP to include the August 2013 adopted enforcement enhanc e ments to the

Ordinance and to ensure that all elements of the document are in effect

. Table 3

- E summarizes the District’s

current enforcement response procedures.



### 38Informal Action

• Informal Notice

• Informal Meeting

• Notice of Violation /Follow

- Up Fees:

o Reporting/Non

- Discharge Violation: Stage One, $6 7 0

o Discharge Violation: Stage Two, $1, 410 *

o Discharge Violation under Director’s Order: Stage Three, $2, 950 *

*does not include testing fees

Formal Action

Administrative

Director’s Orders

• Schedule of Remedial or Preventive Measures

• Cease and Desist Orders

• Facility Damage Cost Recovery

• Termination of Service Director’s Enforcement Remedies and Penalties

• Civil Liability Complaints

• Civil Liability Penalties

o Failure to Submit Report: $1,000/day

o Hazardous Waste Discharge/ Reporting Falsified

Information: $5,000/day

o Discharge in Violation of Order/Prohibition:

$10/gallon

Formal Action

Judicial

Criminal Penalties

• Intentional Discharge in Violation of Director’s Order

Resulting in Pollution: Misdemeanor, $1,000/day

• Reporting Falsified Information/Tampering with

Monitoring Devices: $25,000 Fine and/or 6 Months

Imprisonment Civil Enforcement Remedies and Penalties

• Civil Enforcement Penalties

o Failure to Comply with District Order:

$10,000/day

o Intentional or Negligent Pollution under District

Order: $25,000/day

• Injunction

o Discharge in Violation of Ordinance Causes/

Threatens to Cause Pollution

o Failure to Submit Required Report

o Failure to Allow District Access to Fac ility



### 3.7 **Local Limits**

In 2012 the District conducted a review of its local limits as required by the pretreatment regulations. The

detailed report was submitted to the California RWQCB , San Francisco Bay Region

, on January 8, 2013.

Below are EBMUD's local discharge limits as found in the Ordinance, Title II, Section 3 a. through f: TABLE 3

- E

Enforcement Response Procedure Summary



### 39a. Wastewater Strength Limits . No person shall discharge wastewater from a side sewer into a community

sewer if the strength of the wastewater exceeds the following:

Arsenic 2 mg/L

Cadmium 1 mg/L

Chlorinated Hydrocarbons (total identifiable) 0.5 mg/L

Chromium (total) 2 mg/L

Copper 5 mg/L

Cyanide 5 mg/L

Iron 100 mg/L

Lead 2 mg/L

Mercury 0.05 mg/L

Nickel 5 mg/L

Oil and Grease 100 mg/L

pH not less than 5.5 S.U.

Phenolic compounds 100 mg/L

Silver 1 mg/L

Temperature 150 ( 5 ) o F

Zinc 5 mg/L

b. Additional Wastewater Strength Limits . Wastewater strength limits for constituents not listed in Section 3a

may be established in a wastewater discharge permit based on available treatment technology, existing

wastewater conditions in the District's facilities

, or other factors as determined by the Director. The

Director may also establish wastewater strength limits in wastewater discharge permits at locat ions within a

premise whenever non

- process water may dilute the wastewater discharging from side sewers.



### c. Best Management Practices . The District may require BMPs as an alternative to numeric limits that are

developed to protect the POTW, water quality, and sewage sludge.

d. Quantity and Rate of Flow Limits . No person shall discharge wastewater into a community sewer in

quantities or at rates of flow which may ha ve an adverse or harmful effect on or overload District facilities

or cause excessive or additional District treatment costs. The Director may esta blish mass discharge limits

in Wastewater Discharge P ermits to control the quantity and rate of flow of wast ewater discharges.

e. Radioactive Limits . No person shall discharge or cause to be discharged any radioactive wastewater into a

community sewer except when the person is authorized to use radioactive material by the Nuclear

Regulatory Commission or other gov ernmental agency empowered to regulate the use of radioactive

materials . In these cases, wastewater must be discharged in strict conformity with current Nuclear

Regulatory Commission regulatio ns and recommendations for safe disposal and in compliance wit h all

rules and regulations of State and local regulatory agencies.

f. Deny or Condition New or Increased Contributions. The Director may deny or condition new or increased

contributions of pollutants, or changes in the nature of pollutants, to the District’s wastewater treatment

facility by Industrial Users where such contributions do not meet applicable Pretreatment Standards and

Requirements or where such contributions would cause the District to violate its NPDES permit.

5 150 ° F (65.5 ° C), or any thermal discharge, which as a result of temperature and/or volume causes the influent of the

wastewater treatment plant to exceed 104 ° F (40 ° C).



### 40

## 4. PRETREATMENT PROGRAM

- INDUSTRIAL USER INFORMATION

**4.1 Federal Categories** 

A summary of the categorical industrial users (CIUs) regulated under the EBMUD pretreatment program

and the corresponding federal categorical standards and local limits are presented in Table 4

- A

.



### 4.2 **Baseline Monitoring Report Update**

No new CIUs were added to the pretreatment program in 2014; therefore there is no Baseline Monitoring

Report update.



### 4.3 **Summary of Activity for Permitted I ndustrial**  **Us ers** 

Approximately 56 permits were in effect on December 31, 201 4

, and include:

o 8 SIU C ategorical

o 1 3 SIU Non

- Categorical

o 1 4 Non

- SIU

o 21 N SCIU

Table 4

- B summarizes monitoring and violations for these permitted IUs.

Other permits effective on December 31, 201 4 , were :

o 1 2 G roundwater

o 3 1 E stimation

o 1 5 S pecial D ischarge

o 1, 135 P2 permits for commercial businesses

.

In 2014, there were 271 R2 waste accounts holding 423 active waste disposal agreements. The R 2 User

Types and Waste Streams are presented in Table 3

- C

. More information about the types of pe rmits issued

by EB MUD may be found in Section 3 .3.



### 4.4 **Upd** 

### ated List and Compliance Activities for CIUs, SIUs, and Other Regulated

**Facilities**

The following tables summarize the compliance activities for IUs:

• Monitoring and Violations Summary

– Table 4

- B

• Signi ficant Industrial Users

– Categorical: Table 4

- C

• Significant Industrial Users

– Non

- Categorical: Table 4

- D

• No n

- Significant Industrial Users: Table 4

- E

• Non

- Significant Categorical Industrial Users : Table 4

- F



### 4.5 **July**

**- December Semiannual**  **Report**

The Semiannual P retreatment Report for the period of July 201 4 through December 201 4 is prepared in

accordance with Order No. R2

- 2010

- 0060, NPDES Permit No. CA0037702 adopted on March 10, 2010, and in

accordance with Pretreatment Amendment Order No. R2

- 2011

- 0 0 09, adopted March 9, 2011. The report is

presented in the following sections.



### 41

### 4.5.1 **Significant Industrial User**

**– Categorical** 

The following is a summary of facilities that are listed in this report a long with the status of facilities listed in the

previous semi

- an nual report:

NAME CATEGORY CURRENT STATUS PREVIOUS STATUS

Qtr 4 Qtr 3 Qtr 2 Qtr 1

Metalco, Inc. Electroplating SNC C C C

C = Consistent Compliance, SNC = Significant Noncompliance, IC = Inconsistent Compliance, CL = Closed

T = Terminated

EBMUD monitoring and enforcement actions for categorical industries are presented in List 1 shown below. This

list provides a detailed description of compliance activities for each reported facility. The list is o rganized in order

of categorical classifi cation.

LIST 1

SIGNIFICANT INDUSTRIAL USERS

- CATEGORICAL

COMPLI ANCE STATUS REPORT: July 1, 2014 THROUGH December 31, 2014

Name/Address Date of

Violation Sampled

By Flow**

(gpd) Parameter(s)/

Result(s) Federal

Limit

(mg/L)



### Metalco, Inc.

1475 67th Stree t

Emeryville CA, 94608 12/18/2014 SM 0 0.036 mg/L

( 4

- day Federal

average

exceedence ) 0. 4 mg/L

Compliance History by Quarter 1 : SNC C, C, C

Comments: Metalco, Inc. ’s compliance status for the 4th quarter of 2014 was Significant Non

- Compliance

(SNC) due to a Technical Reporting Criteria (TRC) violation of the 4

- day average for lead that occurred on

December 18, 2014 . A violation fee was paid for the initial October 2013 violation, therefore

, no fee was

assessed for the TRC. Metalco self

- monitors twice a year and EBMUD samples every other year . T herefore, the

4

- day average spanned over a one year period (and also included the District ’s follow up sample to the initial

violation).



### 4.5.2 **Significant Industrial User**

**- Local** 

All non

- categorical faciliti es were in compliance during 2014.

The following facilities had two or more quarters of consistent compliance summarized in the previous semi

annual pretreatment report and are no longer included the report.



### NAME

SVC Manufacturing

Takara Sake

42C EASE AND DESIST ORDERS

CDO/ACL Facility Action Dates Parameter Status

93

- 2 E

- D Coat, Inc. CDO 93

- 2 issued 08/10/93

, amended 6/14/95 CN, Zn T

09

- 01 E

- D Coat, Inc. ACL 09

- 01 issued 09/8/09

Director’s Order No. 09

- 01 09/08/09 T



### E

- D Coat, Inc. (E

- D Coat) is regulated under 40 CFR Part 413

- Electroplating standards. The

appeal process for the District's June 4, 2012 termination of the facility's wastewater discharge

permit is ongoing. The facility has been required to cease all facility operations. The District

continues to conduct ongoing monitoring of the facility's neighboring sanitary sewer lines to

verify that there is no process wastewater discharge from E

- D Coat.

**4.6 Public Participation Summary** 

As required by 40 CFR 403.8(f)(2)(viii), EBMUD publish es annually in the Oakland Tribune a list of

industrial users which at any time during the reporting year were in S ignificant N oncompliance with

applicable pret reatment requirements. Exhibit 4

- A includes a copy of the public notice to be submitted for

publ ication in the Oakland Tribune.

EXHIBIT 4

- A

Notice of Significant Wastewater Violation

Federal Pretreatment Regulations require wastewater service providers to inform the public of significant

wastewater violations and what steps violators have taken to pretreat wastewater discharges to ensure

future compliance.

The wastewater discharger s listed below are identified as critical industr ies as established by E BM UD

Ordinance, Title IV, Section 1a .( 2)

. EBMUD found th ese di scharger s to be in Significant Noncompliance

(SNC) during calendar year 201 4

.



### Metalco, Inc.

1475 67th Street

Emeryville CA, 94608

VIOLATION: On January 28, 2015, Metalco, Inc. was issued a Notice of Violation for

Significant Non

- Compliance (SNC) of the Technical Reporting Criteria

(TRC) 4

- day average for lead which occurred on December 18, 2014 . The

original violation of 16.6 mg/L occurred in October 2013 . Metalco

exceeded the 0.4 mg/L Federal 4

- day average for lead

.

ACTIONS TAKEN: Metalco continues to examin e all of their processes which involve lead; the

cause of the violation remains undetermined

.

PENALTIES: No violation fee was assessed for the TRC violation. Metalco was

assessed a stage

- two violation fee of $1,495 for the October 2013 violati on.



### 43

### TABLE 4

- A

Wastewater Discharge Permits and Standards for Categorical Industrial Users

Electroplating Category > 10,000 GPD

- 40 CFR

413.14 Limits (mg/L)

Industry Name Permit

Exp. Date BMR

Due

Date BMR

Accepted Parameter Federal

EBMUD

Local Limit Daily

Maximum Average

Consecutive

4

- Day

Maximum

E

- D Coat, Inc. (1) Not

Ap plicable (2) 09/26/81 03/16/84 Arsenic

- - 2

Cadmium 1.2 0.7 1

Chromium 7.0 4.0 2

Copper 4.5 2.7 5

Cyanide

(Total) 1.9 1.0 5

Iron

- - 100

Lead 0.6 0.4 2

Mercury

- - 0.05

Nickel 4.1 2.6 5

Oil & Grease

- - 100

pH

- - Not <5.5

(1) The combined wastestream formula will apply only in

the event that stormwater; well/metered potable water ; Phenols

- - 100

or non 40 CFR 413 process wastewater combines with Silver

- - 1

the 40 CFR 413 process wastestream. Temperature

- - 150 ° F

TICH

- - 0. 5

Total Metals 10.5 6.8

- (2) E

- D Coat, Inc.’s permit was terminated on 6/4/12

because of failure to comply with Director’s Order 09

- 01

and to correct ongoing permit violations. TTO 2.13

- -

Zinc 4.2 2.6 5



### 44

### TABLE 4

- A

Wastewater Discharge Permit s and Standards for Categorical Industrial Users

Electroplating Category < 10,000 GPD

- 40 CFR

413.44 Limits (mg/L)

Industry

Name Permit

Exp. Date BMR

Due Date BMR

Accepted Parameter Federal

EBMUD

Local Limit Daily

Maximum Average

Consecutive

4

- Day

Maximum

Metalco 10/25/1 9 09/26/81 03/08/84 Arsenic

- - 2

Cadmium 1.2 0.7 1

Chromium

- - 2

Copper

- - 5

Cyanide

(Amenable) 5.0 2.7 5

Iron

- - 100

Lead 0.6 0.4 2

Mercury

- - 0.05

Nickel

- - 5

Oil & Grease

- - 100

pH

- - Not <5.5

Phenols

- - 100

Silver

- - 1

Temperature

- - 150 ° F

TICH

- - 0.5

Total Metal s

- - -

TTO 4.57

- -

Zinc

- - 5



### 45

### TABLE 4

- A

Wastewater Discharge Permits and Standards for Categorical Industrial Users

Metal Finishing Category

- 40 CFR 433.17, New Source Limits (mg/L)

Industry Name Permit

Exp.

Date BMR

Due Date BMR

Accepted Parameter Federal EBMUD

Local

Limit Daily

Maximum Maximum

Monthly

Average

Fryer I nd. dba

Dougco 01/20/16 01/15/90 02/8/90 Cadmium 0.11 0.07 1

Lucasey

Manufacturing 04/18/18 08/26/88 12/15/88 Chromium 2.77 1.71 2

Scientific Platers 11/10/15 12/03/97 12/23/97 Copper 3.38 2.07 5

Cyanide (Amenable) 0.86 0.32

- Cyanide (Total) 1 .20 0.65 5

Iron

- - 100

Lead 0.69 0.43 2

Mercury

- - 0.05

Nickel 3.98 2.38 5

Oil & Grease

- - 100

pH

- - Not <5.5

Phenols

- - 100

Silver 0.43 0.24 1

Temperature

- - 150 ° F

TICH

- - 0.5

Total Metals

- - -

TTO 2.13

- -

Zinc 2.61 1.48 5



### 46

### TABLE 4

- A

Wastewater Discharge Permit s and Standards for Categorical Industrial Users

Centralized Waste Treatment

- 40 CFR 437.25, Existing

Source Limits (mg/L)

Industry Name Permit

Exp.

Date BMR

Due

Date BMR

Accepted Parameter Federal EBMUD

Local

Limit Daily

Maximum Maximum

Monthly

Average

NRC Environmental

Services, Inc. 04/20/18 06/20/04 07/27/04 Chromium 0.947 0.487 2

Cobalt 56.4 18.8

- Copper 0.405 0.301 5

Lead 0.222 0.172 2

Tin 0.249 0.146

-

Zinc 6.95 4.46 5

Bis(2

- ethylhexyl)

phthalate 0.267 0.158

-

Carbazole 0.392 0.233

-

n

- Decan e 5.79 3.31

-

Fluoranthene 0.787 0.393

-

n

- Octadecane 1.22 0.925

-

Oil and Grease

- Hydrocarbon - - 100

pH

- - not < 5.5

Arsenic

- - 2

Cadmium 1

Cyanide (T)

- - 5

Iron

- - 100

Mercury

- - 0.05

Nickel

- - 5

Phenols

- - 100

Silver 1

Temperature

- - 150 ° F



### 47

### TABLE 4

- A

Wastewater Discharge Permit s and Standards for Categorical Industrial Users

Transportation Equipment Cleaning Category

- 40 CFR

442.15 Limits (mg/L)

Industry

Name Permit

Exp.

Date BMR

Due Date BMR

Accepted Parameter Federal

Daily Maximum EBMUD

Local Limit

Harkrader

Trucking

(HTI) 1/24/17 02/10 /01 ** Non

- Polar

material 100

(SGT

- HEM)

Arsenic

- 2

Cadmium

- 1

Copper 0.84 5

Chromium

- 2

** HTI was not required to submit a BMR. All information

required in a BMR was submitted by HTI in past periodic

reports and permit applicat ions. The information has been Iron

- 100

Lead

- 2

Mercury 0.0031 0.05

compiled. Nickel

- 5

Oil &

Grease - 100

pH

- Not <5.5

Phenols 100

Silver

- 1

Temperature

- 150 ° F

TICH

- 0.5

Zinc

- 5



### 48

### TABLE 4

- A

Wastewater Discharge Permit s and Standards for Categorical Industrial Users

Metal Molding and Casting Point S ource Category

Subpart C

- Ferrous Casting Subcategory

- 40 CFR 464.34,

New Source Limits (mg/L)

Industry Name Permit

Exp. Date BMR

Due Date BMR

Accepted Parameter Federal EBMUD

Local

Limit Daily

Maximum Maximum

Monthly

Average

Pacific Steel

Ca sting 11/07/18 12/31/13 12/13/13 Arsenic

- - 2

Cadmium

- - 1

Chromium

- - 2

Copper 0.0138 0.0076 5

Cyanide

(Amenable) - - -

Cyanide

(Total) - - 5

Iron

- - 100

Lead 0.376 0.0185 2

Mercury

- - 0.05

Nickel

- - 5

Oil &

Greas e 1.43 0.476 100

pH 7

- 10 7

- 10

- Not <5.5

Phenols

- - 100

Silver

- - 1

Temperature

- - 150 ° F

TICH

- - 0.5

Total Metals

- - -

TTO 0.257 0.00838

-

Zinc 0.699 0.266 5



### 49

### Table 4B

2014 Monitoring and Violations Summary

2014 PERMIT SUMMARY SAMPLING EVENTS VIOLATIONS COMPLIANCE

STATUS

12/31/2014

In Effect

12/31/2014 New Closed/

Terminated/

Re

- Classified EBMUD

Inspections E BMUD I U Total No. o f

Violations

- (1) No. o f

Novs

(2) Fees 

### C

(3) IC

(4) SNC

(5) U

(5)

SIU PERMITS

Categorical

40 CFR 413 ELECTROPLATING 2 0 0 0 9 * 1 10 1 1** $0 0 0 1 0

40 CFR 433 METAL FINISHING 4 0 1 4 2 1 3 0 0 $0 4 0 0 0

40 CFR 437 CENTRALIZED WASTE

TREATMENT 1 0 0 2 2 0 2 0 0 $0 1 0 0 0

40 CFR 439 PHARMACEUTICAL S 1 0 1 1 0 0 0 0 0 $0 0 0 0 0

40 CFR 442 TRANSPORTATION

EQUIPMENT CLEANING 1 0 0 4 8 0 8 0 0 $0 1 0 0 0

40 CFR 464 METAL MOLDING AND

CASTING 1 0 0 0 0 0 0 0 0 $0 1 0 0 0

Sub

- total for SIU

- Categorical 8 0 2 11 21 2 23 1 1 $0 7 0 1 0

Non Categori cal

BCC 2080 BEVERAGE MANUFACTURE 3 0 0 1 1 2 3 0 0 $0 3 0 0 0

BCC 2600 PULP AND PAPER PRODUCTS

MFG 1 0 0 2 2 0 2 0 0 $0 1 0 0 0

BCC 2830 DRUGS MANUFACTURING 1 0 0 2 0 0 0 0 0 $0 1 0 0 0

BCC 4000 RAILROAD

TRANSPORTATION 1 0 0 0 3 1 4 0 0 $0 1 0 0 0

BCC 4100 LOCAL AND SUBURBAN

TRANSIT 3 0 0 3 3 8 11 0 0 $0 3 0 0 0

BCC 4500 AIR TRANSPORTATION 1 0 0 2 4 8 12 0 0 $0 1 0 0 0

50

### Table 4B

2014 Monitoring and Violations Summary

2014 PERMIT SUMMARY SAMPLING EVENTS VIOLATIONS COMPLIANCE

STATUS

12/31/2014

In Effect

12/31/2014 New Closed/

Terminated/

Re

- Classified EBMUD

Inspections E BMUD I U Total No. o f

Violations

- (1) No. o f

Novs

(2) Fees 

### C

(3) IC

(4) SNC

(5) U

(5)

BCC 4950 SANITARY COLLECTION AND

DISPOSAL 0 0 1 0 0 0 0 0 0 $0 0 0 0 0

BCC 7218 INDUSTRIAL LAUNDRIES 1 0 0 5 8 8 16 0 0 $0 1 0 0 0

BCC 7300 LABORATORIES 1 0 0 1 8 4 12 0 0 $0 1 0 0 0

BCC 8200 SCHOOLS 1 0 0 5 6 0 6 0 0 $0 1 0 0 0

Sub

- Total for SIU

- Local 13 0 1 21 35 31 66 0 0 $0 13 0 0 0

Sub

- Total SIU Permits 21 0 3 32 56 32 85 1 1 $0 20 0 1 0

Non S IU Permits

BCC 2040 GRAIN MILLS 1 0 0 0 0 0 0 0 0 $0 1 0 0 0

BCC 2050 BAKERIES 2 0 0 2 0 0 0 0 0 $0 2 0 0 0

BCC 2080 BEVERAGE MANUFACTURE 0 0 1 1 0 0 0 0 0 $0 0 0 0 0

BCC 2891 ADHESIVES AND GELATIN

MFG. 2 0 0 1 0 1 1 0 0 $0 2 0 0 0

BCC 32 00 EARTHENWARE

MANUFACTURING 2 0 0 2 0 0 0 0 0 $0 2 0 0 0

BCC 3300 PRIMARY METALS

MANUFACTURING 1 0 0 0 0 0 0 0 0 $0 1 0 0 0

BCC 4000 RAILROAD

TRANSPORTATION 1 0 0 0 0 2 2 0 0 $0 1 0 0 0

BCC 4400 WATER TRANSPORTATION 1 0 0 0 0 0 0 0 0 $0 1 0 0 0

BCC 4950 SANITARY COLLECTION AND

DISPOSAL 2 0 0 0 0 0 0 0 0 $0 2 0 0 0

BCC 5093 RECYCLING CENTER 2 1 1 0 0 0 0 0 0 $0 1 0 0 0

Sub

- Total for Non

- SIU

- Local 14 1 2 6 0 3 3 0 0 $0 13 0 0 0

51

### Table 4B

2014 Monitoring and Violations Summary

2014 PERMIT SUMMARY SAMPLING EVENTS VIOLATIONS COMPLIANCE

STATUS

12/31/2014

In Effect

12/31/2014 New Closed/

Terminated/

Re

- Classified EBMUD

Inspections E BMUD I U Total No. o f

Violations

- (1) No. o f

Novs

(2) Fees 

### C

(3) IC

(4) SNC

(5) U

(5)

Non

- Significant Categorical IU Permits 21 3 5 3 1 1 2 0 0 $0 21 0 0 0

Grand Totals 56 4 10 41 57 36 90 1 1 $0 54 0 1 0

* Inv estigation at ED Coat, Inc. is ongoing. This value represents a total number of investigation samples collected by EBMUD thro ugh the course of 2014.

** On January 28, 2015, Metalco, Inc. was issued a Notice of Violation for Significant Non

- Compliance (SNC) of the Technical Reporting Criteria (TRC) 4

- day average for lead which occurred

on December 18, 2014.

(1),(2)

- All violations are included in NOVs (3) C

- Consistent Compliance (4) IC

- Inconsistent Compliance (5) SNC

- Significant Non

- Compliance (6) U

- Unknown NA

- Not

Applicable

NEW

- A Minimization, Estimation or Pollution Prevention permit which was NOT IN effect during the previous reporting year.

CLOSED

- A facility which no longer operates in the EBMUD SD

- 1 service area.

TERMINATED

- A permit which ceases to be in effect due to reasons such as business closure, business name change or regulated process chan ge. In exceptional cases, the Director may

terminate a permit for violation of the permit terms and conditions or the EBMUD Ordi nance No. 311A

- 03 provisions. A discharger who has a permit terminated by the Director is required to

apply for a new permit within 30 days of notice of termination.

RECLASSIFIED

- An IU regulated under a SIU, Estimation or Pollution Prevention permit wh ich becomes regulated under a different one of these permits.

REISSUED

- Existing Pollution Prevention permits which are renewed.

52

### T ABLE 4C

2014 Monitoring, Enforcement and Status: Significant I ndustrial Users

– Categorical

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments

EBMUD IU No. of

Viol ations

. No. of

NOVs

(3) Viol.

Fe es

40 CFR 413

- Electroplating

E

- D Coat, Inc.

715 4th Street

Oakland, CA 94607

Permit No. 03300871

Expires: 4 T 0 2 0 0 0 0 CDO No. 93

- 2

issued

08/10/1993

amended

06/14/1995

ACL No. 09

- 01

issued

09/08/2009 E

- D Coat, Inc. (E

- D Coat) is regulated unde r 40 CFR Part

413

- Electroplating standards. The appeal process for the

District's June 4, 2012 termination of the facility's

wastewater discharge permit is ongoing. The facility has

been required to cease all facility operations. The District

continues to conduct ongoing monitoring of the facility's

neighboring sanitary sewer lines to verify that there is no

process wastewater discharge from E

- D Coat. 3 T 0 3 0 0 0 0

2 T 0 2 0 0 0 0

1 T 0 2 0 0 0 0

Totals: 0 0 0 0 0 $0

Metalco, In c.

1475 67th Street

Emeryville, CA 94608

Permit No. 07390021

Expires: 10/25/2019 4 SNC 0 0 1 1 0 0 Metalco, Inc. compliance status for the 4th quarter of 2014

was Significant Non

- Compliance (SNC) due to a

Technical Reporting Criteria (TRC) violation of the 4

- day

average for lead. A violation fee was assessed and paid for

the initial October 2013 violation, therefore, no fee was

assessed for the TRC. Metalco, Inc. conducts self

monitoring twice a year and EBMUD samples every other

year, therefore, the 4

- day average spanned over a one year

period (and also included the Districts follow up sample to

the initial violation). 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 1 1 0 $0

Totals for Electroplating: 0 9 1 1 0 $0

53

### T ABLE 4C

2014 Monitoring, Enforcement and Status: Significant I ndustrial Users

– Categorical

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments

EBMUD IU No. of

Viol ations

. No. of

NOVs

(3) Viol.

Fees

40 CFR 433

- Metal Finishing

Fryer Industries Inc./dba

Dougco

1073 34th Street

Oakland , CA 94608

Permit No. 26414503

Expires: 1/20/2016 4 C 1 1 0 0 0 0 DOUGCO/Fryer Industries, Inc. is an existing source

metal finishing job shop facility and is subject to 40 CFR

433.17. This facility is considered a middle

- tier CIU

because the wastewate r discharge does not exceed 5,000

gpd. The permit requires 1 self

- monitoring event per

permit year, 1 EBMUD sampling event and/or inspection

every two years, and the submittal of an annual Total

Toxic Organics (TTO) Compliance Report. EBMUD may

increase mo nitoring in the future as necessary. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 1 0 0 0 $0

Lucasey Manufacturing

2744 E 11th Street

Oakland, CA 94601

Permit No. 31518763

Expires: 4/18/2018 4 C 0 0 0 0 0 0 Lucas ey is subject to 40 CFR 433.17, Metal Finishing

categorical pretreatment standards. Lucasey is considered

a middle

- tier CIU because its categorical wastewater

discharge does not exceed 5,000 gpd. The permit requires

the submittal of an annual TTO Complianc e Report and

annual EBMUD inspections. 3 C 0 0 0 0 0 0

2 C 2 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 2 0 0 0 0 $0

Scientific Platers, Inc.

9809 Kitty Lane

Oakland, CA 94603

Permit No. 14322574

Expires: 11/10/2015 4 C 1 1 0 0 0 0 S cientific Platers is subject to 40 CRF 422.17 pretreatment

standards. EBMUD classifies this account as a middle tier

CIU because its categorical wastewater discharge doesn't

exceed 5,000 gpd. The permit includes the submittal of an

annual TTO Compliance Re port, an annual self

monitoring/sampling event and EBMUD's

sampling/inspection events once every two years. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 1 0 0 0

Totals: 1 1 1 0 0 $0

Totals for Metal Finishing: 4 2 1 0 0 $0

54

### T ABLE 4C

2014 Monitoring, Enforcement and Status: Significant I ndustrial Users

– Categorical

CATEGO RY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments

EBMUD IU No. of

Viol ations

. No. of

NOVs

(3) Viol.

Fees

40 CFR 437

- Centralized Waste Treatment

NRC Environmental Services,

Inc.

Wharf 2 Ferry Point

Al ameda, CA 94501

Permit No. 50371433

Expires: 4/20/2018 4 C 0 0 0 0 0 0 NRC Environmental Services, Inc. is subject to 40 CFR

437.25 categorical pretreatment standards. This permit

requires semi

- annual self

- monitoring events, and 2

EBMUD inspections per year. 3 C 1 1 0 0 0 0

2 C 1 1 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 2 2 0 0 0 $0

Totals for Centralized Waste Treatment: 2 2 0 0 0 $0

40 CFR 442

- Transportation Equipment Cleaning

Harkrader Trucking, Inc.

9957 Medford Ave

Oaklan d, CA 96051

Permit No. 50066572

Expires: 1/24/2017 4 C 1 2 0 0 0 0 Harkrader is regulated under 40 CFR 442.15

- Transportation Equipment Cleaning. This permit requires 4

EBMUD inspections per year. 3 C 2 4 0 0 0 0

2 C 0 0 0 0 0 0

1 C 1 2 0 0 0 0

Totals: 4 8 0 0 0 $0

Totals for Transportation Equipment

Cleaning: 4 8 0 0 0 $0

55

### T ABLE 4C

2014 Monitoring, Enforcement and Status: Significant I ndustrial Users

– Categorical

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments

EBM

UD IU No. of

Viols. No. of

NOVs

(3) Vio l.

Fees

40 CFR 464

- Metal Molding And Casting

Pacific Steel Casting

1333 2nd Street

Berkeley, CA 94710

Permit No. 10690011

Expires: 11/7/2018 4 C 0 0 0 0 0 0 Pacific Steel Casting (PSC) is an SIU subject to 40 CFR 464,

Subpart C Ferrous Castin g Subcategory Casting Quench

pretreatment standards. The permit requires 2 self

- monitoring

events per permit year, 1 EBMUD sampling event and/or

inspections every year, and the submittal of an annual Total

Toxic Organics (TTO) Compliance Report. EBMUD may

increase monitoring in the future as necessary. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Metal Molding And Casting: 0 0 0 0 0 $0

Totals: 8 21 2 1 0 $0

56

### T ABLE 4C

2014 Monitoring, Enforcement and Status: Significant I ndustrial Users

– Categorical

( 1 ) Calendar Quarter (4th Qtr is Oct

- Dec)

( 2 ) Compliance Status Key: C

- Consistent Compliance

IC

- Inconsistent Compliance

SNC

- Significant Non

Compliance

CL

- Closed

T

- Terminated

RC

- Reclassified

RI

- Reissued

U

- Unknown

( 3 ) All violations are includ ed in NOVs

New

- A Minimization, Estimation or Pollution Prevention permit which was not in effect during the previous reporting year.

CL (Closed)

- A facility which no longer operates in teh EBMUD SD

- 1 service area.

T

(Terminated) - A permit which ceases to be in effect due to reasons such as business closure, business name change or regulated process change. In exceptio nal cases, the

Director may terminate a permit for violation of the permit terms and conditions or the EBMUD Ordinance No. 311A

- 03 provisions. A discharger who has a

permit terminated by the Director is required to apply for a new permit within 30 days of notice of termination.

RC

(Reclassified) - An IU regulated under a Minimization (federal categorical or local), Estimation or Poll ution Prevention permit which becomes regulated under a different one of

these permits.

RI (Reissued)

- Existing Pollution Prevention permits which are renewed.

57

### T ABLE 4D

Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders C omments EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees

BCC 2080

- Beverage Manufacture

SVC Manufacturing

5625 International Blvd.

Oakland, CA 94621

Permit No. 50367682

Expires: 11/6/2018 4 C 0 0 0 0 0 0 SVC Manufacturing is a beverage

m anufacturer and bottler. The permit includes

best management practices in lieu of self

monitoring and 2 EBMUD inspection and

sampling events a year (CODF and pH

testing). 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Safeway Beverage Plant

1921 San Joaquin Street

Richmond, CA 94804

Permit No. 05900451

Expires: 10/30/2016 4 C 0 0 1 0 0 0 Safeway Beverage Plant is a carbonated drink

manufacturer and bottler located in Richmond,

CA. A wastewater disc harge permit is issued to

Safeway Beverage because its wastewater

strength is significantly different from its BCC

strength. The BCC for Safeway Beverage is

2080

- Beverage Manufacturer. The Permit

also monitors for pH and Oil & Grease

(hydrocarbon). Accor ding to Safeway, its

product has a pH of 4 or less. A new on

- line

pH system was added to the wastewater

treatment process at this plant in 2014. The

permit is currently in process of being revised

to update these changes to the treatment

system. 3 C 1 1 0 0 0 0

2 C 0 0 1 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 1 2 0 0 $0

58

### T ABLE 4D

Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees

Takara S ake

708 Addison Street

Berkeley, CA 94710

Permit No. 10600278

Expires: 6/14/2019 4 C 0 0 0 0 0 0 Takara Sake has been operating under a

compliance schedule since December 2013

taking specific actions to ensure pH discharge

compliance. During 2014, EBMUD was unable

to perform periodic sampling events due to

safety issues at the facility. EBMUD and

Takara staff collaborated on a solution to

rectify on

- site sampling safety issues. EBMUD

will resume sampling in January 2015. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Beverage Manufacture: 1 1 2 0 0 $0

BCC 2600

- Pulp And Paper Products Mfg

Longview Fibre Company

8511 Blaine Street

Oakland, CA 94621

Permit No. 17300112

Expires: 8/20/20 19 4 C 1 1 0 0 0 0 Longview Fibre has a mandatory permit for

being a critical industry whose average

wastewater strength cannot be established on a

BCC basis [EBMUD Wastewater Control

Ordinance, Title IV, Section 1a(5)] and other

dischargers determ ined by the Manager to

require special regulations or source control

[EBMUD Wastewater Control Ordinance,

Title IV, Section 1a.(5)]. The federal paper

manufacturing regulations listed in 40 CFR

430 do not apply to this facility. 3 C 0 0 0 0 0 0

2 C 1 1 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 2 2 0 0 0 $0

Totals for Pulp And Paper Products Mfg: 2 2 0 0 0 $0

59

### T ABLE 4D

Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No.

of

Viols

. No. of

NOVs

(3) Viol.

Fees

BCC 2830

- Drugs Manufacturing

Bayer Corporation

4th & Parker Streets

Berkeley, CA 94701

Permit No. 10600333

Expires: 6/28/2019 4 C 2 0 0 0 0 0 Bayer Corporation is permitted as a Local

Limits SIU and maintained con sistent

compliance during 2014. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 2 0 0 0 0 $0

Totals for Drugs Manufacturing: 2 0 0 0 0 $0

BCC 4000

- Railroad Transportation

Union Pacific Railroad Company

1851

- B 5t h Street

Oakland, CA 80221

Permit No. 02300371

Expires: 8/23/2019 4 C 0 0 1 0 0 0 Union Pacific Railroad Company is permitted

as a Local Limits SIU and maintained

consistent compliance in 2014. 3 C 0 1 0 0 0 0

2 C 0 1 0 0 0 0

1 C 0 1 0 0 0 0

Totals: 0 3 1 0 0 $0

Totals for Railroad Transportation: 0 3 1 0 0 $0

BCC 4100

- Local And Suburban Transit

AC Transit

- Emeryville

1177 47th Street

Emeryville, CA 94612

Permit No. 04391161

Expires: 10/30/2016 4 C 0 0 1 0 0 0 AC Transit

- Emeryville permit regulates the

discharge of wastewater generated during fleet

maintenance activities. 3 C 0 0 0 0 0 0

2 C 1 1 1 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 1 2 0 0 $0

60

### T ABLE 4D

Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

CATEGORY

Facility Qtr

(1) Compl

. Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees

AC Transit

- International

10626 International Blvd.

Oakland, CA 94612

Permit No. 19526191

Expires: 10/30/2016 4 C 1 0 1 0 0 0 AC Transit

- International permit regulates the

discharge of wastewater generated during fleet

maintenance activities. 3 C 0 0 0 0 0 0

2 C 0 0 1 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 0 2 0 0 $0

AC Transit

- Seminary

1100 Seminar y Avenue

Oakland, CA 94612

Permit No. 14300671

Expires: 10/30/2016 4 C 0 0 2 0 0 0 AC Transit

- Seminary permit regulates the

discharge of wastewater generated during fleet

maintenance activities. 3 C 1 2 0 0 0 0

2 C 0 0 2 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 2 4 0 0 $0

Totals for Local And Suburban Transit: 3 3 8 0 0 $0

BCC 4500

- Air Transportation

Port Of Oakland

- Oakland

International Airport

Doolittle & Airport Drive

Oakland, CA 94607

Permit No. 17300332

Expires: 8 /25/2016 4 C 1 2 2 0 0 0 ACL

No.

2011

- 01

issued

09/14/20

11 Oakland International Airport (OIA) has a

mandatory wastewater discharge permit

because it discharges an un

- metered source of

water and it is designated as a SIU by EBMUD

on the basis that it has a reasonable potential for

adversely affecting the WWTPs operation, or

the operation of nearby Pump Station G, or for

violating EBMUDs Wastewater Control

Ordinance. OIA discharges an average of over

250,000 gpd into the sanitary sewer. 3 C 1 2 2 0 0 0

2 C 0 0 2 0 0 0

1 C 0 0 2 0 0 0

Totals: 2 4 8 0 0 $0

61

### T ABLE 4D

Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

CATEGORY

Facility Qtr

(1) Compl

. Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees

Totals for Air Transportation: 2 4 8 0 0 $0

BCC 7218

- Industrial Laundries

Aramark Uniform Services

330 Chestnut Street

Oakland, CA 94607

Permit No. 03300801

Expires: 11/9/2018 4 C 1 2 2 0 0 0 Aramark Uniform Services has a mandatory

permit as a SIU that discharges 25,000 gpd or

more of process wastewater. Aramark Uniform

Services maintained consistent compliance

during 2014. 3 C 2 2 2 0 0 0

2 C 0 0 2 0 0 0

1 C 2 4 2 0 0 0

Totals: 5 8 8 0 0 $0

Totals for Industrial Laundries: 5 8 8 0 0 $0

BCC 7300

- Laboratories

Lawrence Berkeley National

Laboratory

1 Cyclotron Road

Berkeley, CA 94720

- 8282

Permit No. 06600791

Expires: 7/7/2017 4 C 0 0 0 0 0 0 This local permit regulates LBNL except for the

groundwater discharge and the metal finishing

operations in Building 77. This account

maintained consistent compliance during 2014. 3 C 1 4 2 0 0 0

2 C 0 0 0 0 0 0

1 C 0 4 2 0 0 0

Totals: 1 8 4 0 0 $0

Totals for Laboratories: 1 8 4 0 0 $0

BCC 8200

- Schools

Regents Of The University Of

California, Berkeley

Berkeley Campus

Berkeley, CA 94720

Permit No. 06600592

Expires: 11/16/2018 4 C 1 2 0 0 0 0 Regents of the University of California,

Berkeley permit regulates the discharge of

wastewater generated from academic and

research laboratory activities. 3 C 2 0 0 0 0 0

2 C 1 2 0 0 0 0

1 C 1 2 0 0 0 0

Totals: 5 6 0 0 0 $0

62

### T ABLE 4D

Monitoring, Enforcement and Status: Significant Industrial Users

– Non

- Categorical

CATEGORY

Facility Qtr

(1) Compl

. Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees

Totals for Schools: 5 6 0 0 0 $0

Totals: 13 21 35 31 0 0 $0

( 1 ) Calendar Quarter (4th Qtr is Oct

- Dec)

( 2 ) Compliance Status Key: C

- Consistent Compliance

IC

- Inconsist ent Compliance

SNC

- Significant Non

- Compliance

CL

- Closed

T

- Terminated

RC

- Reclassified

RI

- Reissued

U

- Unknown

(3) All violations are included in NOV



### New

- A Minimization, Estimation or Pollution Prevention permit which was not in effect during the previous reporting year.

CL (Closed)

- A facility which no longer operates in teh EBMUD SD

- 1 service area.

T (Terminated)

- A permit which ceases to be in effect due to reasons such as business closure, business name change or re gulated process change. In exceptional cases, the

Director may terminate a permit for violation of the permit terms and conditions or the EBMUD Ordinance No. 311A

- 03 provisions. A discharger who has a

permit terminated by the Director is required to apply for a new permit within 30 days of notice of termination.

RC

(Reclassified) - An IU regulated under a Minimization (federal categorical or local), Estimation or Pollution Prevention permit which becomes regulated under a different

one of these permits.

R I (Reissued)

- Existing Pollution Prevention permits which are renewed.

63

### T ABLE 4E

Monitoring, Enforcement and Status: Non

- Significant Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No. of

Viols. No. of

NOVs

( 3 ) Viol.

Fees

2040

- Grain Mills

Cal ifornia Cereal Products

1267 14th Street

Oakland, CA 94607

Permit No. 03301042

Expires: 4 C 0 0 0 0 0 0 California Cereal has a process discharge of <25,000

GPD and has no reasonable potential for adversely

affecting the wastewater treatment plant or violating

pretreatment standards. The permit includes

implementation of BMPs plus one inspection and three

TSS and CODF samples every five years. The District

may increase monitoring as necessary. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Grain Mills: 0 0 0 0 0 $0

2050

- Bakeries

New Desserts Inc.

550 85th Avenue

Oakland, CA 94621

Permit No. 50471294

Expires: 4 C 0 0 0 0 0 0 New Desserts, Inc. has a process discharge of <25,000

GPD and has no reasonable potential for adversely

affecting the wastewater treatment plant or violating

pretreatment standards. The permit includes

implementation of BMPs and an annual inspection. 3 C 1 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Total s: 1 0 0 0 0 $0

Svenhards Swedish Bakery

335 Adeline Street

Oakland, CA 94607

Permit No. 02300241

Expires: 4 C 1 0 0 0 0 0 Svenhard’s Swedish Bakery permit regulates the

discharge of wastewater generated from large

- scale

baking activities. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 0 0 0 0 $0

Totals for Bakeries: 2 0 0 0 0 $0

64

### T ABLE 4E

Monitoring, Enforcement and Status: Non

- Significant Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No. of

Viols. No. o f

NOVs

( 3 ) Viol.

Fees

2080

- Beverage Manufacture

Pyramid Breweries

901 Gilman Street

Berkeley, CA 94710

Permit No. 50352621

Expires:

Closed: 4/17/2014 4 CL 0 0 0 0 0 0 Pyramid Breweries, coded BCC 2080, was a beverage

manufacturing facility tha t has a BMP permit with no

expiration date. The permit was terminated in 2014 due

to facility closure. 3 CL 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 1 0 0 0 0 0

Totals: 1 0 0 0 0 $0

Totals for Beverage Manufacture: 1 0 0 0 0 $0

2891

- Adhesives And Gelatin Mfg.

Adhesive Products

520 Cleveland Avenue

Albany, CA 94710

Permit No. 10600761

Expires: 4 C 0 0 1 0 0 0 Adhesive Products, Inc. has a process discharge of

<25,000 GPD and has no reasonable potential for

adversely affecting t he wastewater treatment plant or

violating pretreatment standards. The permit includes an

annual sampling inspection and a self

- monitoring annual

event. The inspection for 2014 was conducted on

January 27,2015. The delay was due to a scheduling

conflict th at has been resolved. Another inspection will

be conducted in 2015 for the 2015 period. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 1 0 0 $0

Henkel

742 Grayson Street

Berkeley, CA 94710

Permit No. 10600742

Expires : 4 C 1 0 0 0 0 0 Henkel permit regulates the discharge of wastewater

generated from adhesive manufacturing activities. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 0 0 0 0 $0

Totals for Adhesives And Gela tin Mfg.: 1 0 1 0 0 $0

65

### T ABLE 4E

Monitoring, Enforcement and Status: Non

- Significant Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No. of

Viols. No. of

NOVs

( 3 ) Viol.

Fees

3200

- Earthenware Manufacturing

CEMEX Construction Materials

Pacific, LLC

333 23rd Avenue

Oakland, CA 95762

Permit No. 13300311

Expires: 11/16/2018 4 C 2 0 0 0 0 0 CEMEX Construction Materials Pacific, LLC (CEMEX)

is a ready

- mix concrete batching facility. In 2014

CEMEX was delisted as a Significant Industrial User

( SIU) because of consistent compliance with its permit

terms. CEMEX was classified as an SIU in 2008

because of the discharge of cementitious material to the

sanitary sewer creating an obstruction in the sewer line.

Prior to that CEMEX held an optional esti mation of

wastewater flow permit due to the majority of its water

consumption diverted to product. In 2008 CEMEX was

issued a zero discharge permit, off hauling excess

wastewater to the District's wastewater treatment plant

through EBMUD's Resource Recover y Program. The

zero

- discharge permit remains in place. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 2 0 0 0 0 $0

Owens

- Brockway Glass Containers,

Inc

3600 Alameda Avenue

Oakland, CA 94601

- 3329

Permit No. 14300262

Ex pires: 4 C 0 0 0 0 0 0 Owens

- Brockway Glass Containers, Inc. permit

regulates the discharge of wastewater generated from

glass manufacturing activities. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Earthenware Manufacturing: 2 0 0 0 0 $0

66

### T ABLE 4E

Monitoring, Enforcement and Status: Non

- Significant Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No. of

Viols. No. of

NOVs

( 3 ) Viol.

Fees

3300

- Primary Metals Manufacturing

Sch nitzer Steel Products

1101 Embarcadero West

Oakland, CA 94604

Permit No. 02300311

Expires: 12/19/2019 4 C 0 0 0 0 0 0 Schnitzer Steel Products is a scrap metal dealer located

in Oakland. In December 2014, Schnitzer's estimation

permit was changed t o local limits Wastewater

Discharge Permit. This action was necessitated by CA

Regional Water Quality Control Board Cleanup and

Abatement Order No. R2

- 2012

- 0083. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Primary Metals Manufacturing: 0 0 0 0 0 $0

4000

- Railroad Transportation

AMTRAK

- National Railroad

Passenger Corp

1303

- 3rd Street

Oakland, CA 94607

Permit No. 50534001

Expires: 4 C 0 0 1 0 0 0 Amtrak permit includes impleme ntation of BMPs in lieu

of EBMUD yearly sampling and one inspection and

sampling event every five years. The District may

increase monitoring, if necessary. 3 C 0 0 0 0 0 0

2 C 0 0 1 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 2 0 0 $0

Totals for Railroad Transportation: 0 0 2 0 0 $0

4400

- Water Transportation

EBMUD San Pablo Water Treatment

Plant

- RCO

300 Berkeley Park Blvd

Kensington, CA 94607

Permit No. 00690013

Expires: 4 C 0 0 0 0 0 0 The San Pablo Water Treatment Plant is a standby

facility that is not considered a significant industrial user

due to its process discharge of <25,000 GPD and the

fact that it has no reasonable potential for adversely

affecting the wastewater treatment plant or violating

pretreatment standa rds. The permit is for intermittent

tunnel flush water to the sanitary sewer

, as the sulfide

levels are too high for discharge to the creek. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Water Transportation: 0 0 0 0 0 $0

67

### T ABLE 4E

Monitoring, Enforcement and Status: Non

- Significant Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

(2) EBMUD

Inspections SAMPLES ENFORCEMENT

Orders Comments EBMUD IU No. of

Viols. No. of

NOVs

( 3 ) Viol.

Fees

4950

- Sanitary Collection And Disposal

EBMUD

- East Bayshore Water

Recycling Project

2020 Wake Avenue

Oakland, CA 94623

Permit No. 50620251

Expires: 4 C 0 0 0 0 0 0 EBMUD

- East Bayshore Water Recycling Project permit

regulates the discharge of filter back

- washwater

generated from wastewater recycling processes at

EBMUD's wastewater treatment plant. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Swissport Fueling, Inc.

1 Edward White Way

Oakland, CA 94621

Permit No. 50652491

Expires: 12/7/2015 4 C 0 0 0 0 0 0 Swissport Fueling Inc.(previously Port of Oakland

SFTF) has been a non

- SIU since December 2010 and

maintains consistent compliance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Sanitary Co llection And Disposal: 0 0 0 0 0 $0

5093

- Recycling Center

Lakeside Non

- Ferrous Metals

412 Madison Street

Oakland, CA 94607

Permit No. 22313221

Expires: 4 C 0 0 0 0 0 0 Lakeside Non

- Ferrous Metals, a metal recycling facility,

is regulated for the discharge of polluted stormwater that

cannot be discharged to the storm drain system. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals: 0 0 0 0 0 $0

Totals for Recycling Center: 0 0 0 0 0 $0

Totals: 14 6 0 3 0 0 $0

68

### T ABLE 4E

Monitoring, Enforcement and Status: Non

- Significant Industrial Users

( 1 ) Calendar Quarter (4th Qtr is Oct

- Dec)

( 2 ) Compliance Status Key: C

- Consistent Compliance

IC

- Inconsistent Compliance

SNC

- Significant Non

- Compliance

CL

- Closed

T

- Terminated

RC

- Reclassified

RI

- Reissued

U

- Unknown

- 3 All violations are included in NOVs

New

- A Minimization, Estimation or Pollution Prevention permit, which was not in effect during the previous r eporting year.

CL (Closed)

- A facility which no longer operates in the EBMUD SD

- 1 service area.

T (Terminated)

- A permit which ceases to be in effect due to reasons such as business closure, business name change or regulated process chan ge. In exceptio nal cases,

the Director may terminate a permit for violation of the permit terms and conditions or the EBMUD Ordinance No. 311A

- 03 provisions. A discharger

who has a permit terminated by the Director is required to apply for a new permit within 30 days of notice of termination.

RC (Reclassified)

- An IU regulated under a Minimization (federal categorical or local), Estimation or Pollution Prevention permit which becomes regulated under a

different one of these permits.

RI (Reissued)

- Existing Pollution P revention permits which are renewed.

69

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

( 2 ) EBMUD

Inspections SAMPLES ENFORCEMENT Comments

EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees Orders

40 CFR 413

- Electroplating

Gold Seal Plating

3125 E 7th Street

Oakland, CA 94601

Permit No. 31390241

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Gold Seal Plating certified that their

classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Johnson Plating

2526 Telegraph Avenue

Oakland, CA 94612

Permit No. 25390261

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Johnson Plating certified that their

classification r emains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Melrose Metal Finishing, Inc.

10222 Pearmain Street

Oakland, CA 94603

Perm it No. 14390462

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Melrose Metal Finishing, Inc. certified

that their classification remains valid. They

submitted certification statements and

supplemental water balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Monsen Plating Silversmith

3370 Adeline Street

Berkeley, CA 94703

Permit No. 02690041

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Monsen Plating Silversmith certified that

their classificatio n remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Electroplating: 0 0 0 0 0 $0

70

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

CATEGORY

Facility Qtr

( 1) Compl.

Status

( 2 ) EBMUD

Inspections SAMPLES ENFORCEMENT Comments

EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees Orders

40 CFR 420

- Iron And Steel

Pacific Galvanizing

715 46th Avenue

Oakland, CA 94601

Permit No. 29525411

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Pacific Galvanizing certified that their

classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Iron And Steel: 0 0 0 0 0 $0

40 CFR 421

- Non

- Ferrous Metals I

CASS, Inc.

2730 Peralta Street

Oakland, CA 94607

Permit No. 24513862

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, CASS, Inc. certified that their

classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Non

- Ferrous Metals I: 0 0 0 0 0 $0

40 CFR 433

- Metal Fin ishing

Able Metal Plating, Inc.

932 86th Avenue

Oakland, CA 94621

Permit No. 13390735

Expires: 7/1/2015 4 C 0 0 0 0 0 0 In 2014, Able Metal Plating, Inc. certified that their

classification remains valid. They submitted

certification statements and su pplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

71

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

( 2 ) EBMUD

Inspections SAMPLES ENFORCEMENT Comments

EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees Orders

Electro

- Coatings Of Calif ornia

893 Carleton Street

Berkeley, CA 94710

Permit No. 10600343

Expires: 7/1/2015 4 C 0 0 0 0 0 0 In 2014, Electro

- Coatings Of Calif ornia certified

that their classification remains valid. They

submit ted certification statements and

supplemental water balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Lawrence Berkeley National Laboratory, Bldg. 77



### 1 Cyclotron Road

Berkeley, CA 94720

Permit No. 5023 8911

Expires: 4/7/2017 4 C 0 0 0 0 0 0 In 2014, Lawrence Berkeley National Laboratory,

Bldg. 77 

### certified that their classification remains

valid. They submitted certification statements and

supplemental water balance. 3 C 1 1 1 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 1 1 0 0 $0

Mercurius Company

3224 Brookdale Ave

Oakland, CA 94602

Permit No. 42426923

Expires: 7/1/2015 4 C 0 0 0 0 0 0 In 2014, Mercurius Company certified that their

classification remains valid. T hey submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Metro Lighting

2240 San Pablo Ave

Berkeley, CA 94702

Permit No. 35611516

Expires: 7/1/201 5 4 C 0 0 0 0 0 0 In 2014, Metro Lighting certified that their

classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

72

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

( 2 ) EBMUD

Inspections SAMPLES ENFORCEMENT Comments

EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees Orders

Rolls

- Royce Engine Svcs

7200 Earhart Road

Oakland, CA 94621

- 4504

Permit No. 50244512

Ex pires: 7/1/2015 4 C 1 0 0 0 0 0 In 2014, Rolls

- Royce Engine Svcs certified that

their classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 1 0 0 0 0 $0

The Boardworks

499 Embarcadero

Oakland, CA 94606

Permit No. 50194641

Expires: 1/9/2016 4 C 0 0 0 0 0 0 The Boardworks is a printed circuit board

manufacturer and is subject to 40 CFR 433.17

categorical pretreatment sta ndards. EBMUD has

opted to maintain this facility under the SIU listing

due to the discharge of federally regulated

wastewater. The permit requires 1 EBMUD

inspection every 5 years with no sampling and the

submittal of an annual TTO Compliance Report. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Metal Finishing: 2 1 1 0 0 $0

40 CFR 439

- Pharmaceuticals

Libby Laboratories, Inc.

1700 Sixth Street

Berkeley, CA 94710

Permit No. 08622681

Expire s: 7/22/2019 4 C 0 0 0 0 0 0 Libby Laboratories, Inc. was reclassified from a

zero discharger to an NSCIU. Libby certifies

annually that the facility does not use or generate

regulated parameters. Pretreatment standards

require annual confirmation by way of chemical

analysis with a non

- detect value for each regulated

parameter. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 1 0 0 0 0 0

Totals: 1 0 0 0 0 $0

Totals for Pharmaceuticals: 1 0 0 0 0 $0

73

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

( 2 ) EBMUD

Inspections SAMPLES ENFORCEMENT Comments

EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees Orders

40 CFR 446

- Paint Formulating

Precision Technical Coatings

1220 4th Street

Berkeley, CA 94710

Permit No. 10614512

Expires: 12/31/2 014 4 C 0 0 0 0 0 0 In 2014, Precision Technical Coatings certified

that their classification remains valid. They

submitted certification statements and

supplemental water balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Paint Formulating: 0 0 0 0 0 $0

40 CFR 464

- Metal Molding And Casting

A B And I

7825 San Leandro Street

Oakland, CA 94621

Permit No. 17300701

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, A B And I certified t hat their

classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Mussi Artworks Foundry, LLC

729 Heinz Ave #10

Be rkeley, CA 94710

Permit No. 08624073

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Mussi Artworks Foundry, LLC certified

that their classification remains valid. They

submitted certification statements and

supplemental water balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Pressure Cast Products

4210 E 12th Street

Oakland, CA 94601

Permit No. 34314282

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Pressure Cast Products certified that their

clas sification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

74

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

CATEGORY

Facility Qtr

(1) Compl.

Status

( 2 ) EBMUD

Inspectio ns SAMPLES ENFORCEMENT Comments

EBMUD IU No.

of

Viols. No. of

NOVs

(3) Viol.

Fees Orders

Sks Die Casting Machining

1849 Oak Street

Alameda, CA 94501

Permit No. 50381881

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Sks Die Casting Machining cer tified that

their classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Metal Molding And Casting: 0 0 0 0 0 $0

40 CFR 467

- Aluminum Forming

Berkeley Forge & Tool Inc.

1331 Eastshore Hwy

Berkeley, CA 94710

- 1320

Permit No. 10614524

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Berkeley Forge & Tool Inc. certified that

their classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Coulter Forge Technology

1494 67th Street

Emeryville, CA 94608

Permit No. 0731465 3

Expires: 12/31/2014 4 C 0 0 0 0 0 0 In 2014, Coulter Forge Technology certified that

their classification remains valid. They submitted

certification statements and supplemental water

balance. 3 C 0 0 0 0 0 0

2 C 0 0 0 0 0 0

1 C 0 0 0 0 0 0

Totals: 0 0 0 0 0 $0

Totals for Aluminum Forming: 0 0 0 0 0 $0

Totals: 21 3 1 1 0 0 $0

75

### T ABLE 4F

Monitoring, Enforcement and Status: Non

- S ignificant Categorical Industrial Users

(1) Calendar Quarter (4th Qtr is Oct

- Dec)

(2) Compliance Status Key: C

- Consistent Compliance

IC

- In c onsistent Compliance

SNC

- Significant Non

- Compliance

CL

- Closed

T

- Terminated

RC

- Reclassified

RI

- Reissued

U

- Unknown

(3) All violations are included in NOVs

New

- A Minimization, Est imation or Pollution Prevention permit which was not in effect during the previous

reporting year.

CL (Closed)

- A facility which no longer operates in the EBMUD SD

- 1 service area.

T (Terminated)

- A permit which ceases to be in effect due to reasons suc h as business closure, business name change or

regulated process change. In exceptional cases, the Director may terminate a permit for violation of the permit

terms and conditions or the EBMUD Ordinance No. 311A

- 03 provisions. A discharger who has a permit

terminated by the Director is required to apply for a new permit within 30 days of notice of termination.

RC

(Reclassified) - An IU regulated under a Minimization (federal categorical or local), Estimation or Pollution Prevention permit

which becomes reg ulated under a different one of these permits.

RI (Reissued)

- Existing Pollution Prevention permits which are renewed.

76

## 5. POLLUTION PREVENTION PROGRAM

This chapter includes EBMUD ’s annual Pollution Prevention ( P2 ) Report for the January 1, 2 0 1 4 through December

31, 20 1 4 reporting period

. The report wa s prepared in accordance with the D istrict’s NPDES Permit No. CA0037702

adop ted on March 10, 2010

, under Order No. R2

- 2010

- 0060

.



### 5.1 **Pollution Prevention Program Highlights for 20**  **1 4** 

EBMUD continued P2 activities for its commercial and residential customers

. H ighlights for 201 4 are noted in the

table below

.

Highlights

Copper

• A sec tion on c opper

- free guidelines for pool s was developed for the Residential P2

page of the District’s website at https://www.ebmu d.com/water

- and

wastewater/pollution

- prevention/maintaining

- copper

- free

- pools

- spas

- and

- fountains

and posted in January 2014.

FOG

• Continued to provide assistance to EBMUD’s seven satellite collection system

agencies in accordance with their fats, oil, and grease (FOG) program requirements

and ensured consistency of program activities.

• Conducted hotspot response to FOG

- related SSOs and blockages reported by

EBMUD’s satellite agencies. There were 127 grease blockage reports submitted ; of

these, 30 were iden tified as caused or contributed to by food service establishments

( FSE s) . Hotspot investigations have resulted in issuing numerous GCD installation

and maintenance requirement letter s . GCD installations and improved grease

interceptor pump out and maintena nce at FSEs have occurred following

inspections and investigations

.

• Continued gravity grease interceptor inspections; provided enforcement support to

satellites, hotspot status reporting, database management, as well as residential and

commercial outreach.

• Completed the 2014 Regional FOG Program Annual Report for satellite use

. This

comprehensive report documents all of the efforts and progress, over the course of

the year to address FOG

- related issues service area

- wide.

• Continued availability of residenti al FOG drop

- off at EBMUD’s MWWTP

, the El

Cerrito Recycling Center and the Oakland Whole Foods grocery store.

• Continued promotion of Richmond’s West County Resource Recovery facility and

Central Contra Costa Sanitary District’s household hazardous waste fa cility as

locations that accept residential FOG. All three facilities’ collected cooking oil is

recycled into a biofuel.

• Presented information about FOG issues and distributed FOG outreach materials at

local outreach events for restaurants and residents, i ncluding the annual Solano

Stroll, Alameda Earth Day, the City of Oakland Earth Expo event

, and Healthy

Living Festival at the Oakland Zoo.

• Developed a new outreach tool (spin wheel) for community events. This new spin

wheel, which contains multi

- pollutan t information/questions, including FOG,

attracts events’ visitors, enhances their engagement and learning experience.

• Developed a new “Think Before You Flush” brochure to address

wipes/”disposable” consumer products, which often come in tandem with FOG and



### 77Highlights

cause chronic problem, including blockages, SSO, expensive repair and

maintenance issues in the sanitary sewer systems. See Exhibit 5

- A

. D elivered over 600 personalized FOG and “wipes/trash” related personalized

letters and “Think Before You Flush” brochures (in addition to residential FOG

brochures) to residents in identified hotspot areas.

• Continued holiday FOG partnership with Baykeeper, distributing information for

residents on the Baykeeper website as well as on EBMUD’s website

.

• Continued holiday FOG outreach to 15 local independent retailers, including

Whole Foods, Piedmont Grocery, Ace Hardware, Trader Joe’s, and other stores in

EBMUD’s service area.

• Door hangers with scrapers and residential outreach brochures were distributed to

4,665 residents in areas associated with SSOs/blockages as well as for preventative

education

. This was a 3 7% increase over last year’s residential outreach efforts.

• T otal number of customer inquiries for free FOG scrapers via the EBMUD on

- line

store and the EBMUD phone hotline wa s over 700, which is a slight decrease from

966 in 2013

.

• Continued enhancement of FOG program database to increase program

effectiveness.

• Continued use of a data

- driven automatic notification system t hat alert s staff of

overloaded gravity grease interceptors (GIs) which require immediate follow

- up

with FSEs. This system facilitates ro utine maintenance of GIs and on

- going

compliance of FSEs

.

• Utilized the hotspot density analysis map created for the City of Oakland in on

going effort to streamline the decision

- making process for residential FOG

outreach.

• Continued maintenance and updat e s for various EBMUD web pages relating to

residential FOG which included www.ebmud/cleanbay and the EBMUD

- FOG

residential disposal web page, https://www.ebmud.com/environment/pollution

prevention/residential

- cooking

- oil

- and

- grease

- drop

- program with an added link on

resources page to www.baywise.org website fo r regional FOG disposal

information.

Pharmaceutical

• Continued the Keep the Bay off Drugs customer outreach campaign through March

2014. See Exhibits 5

- B and 5

- C.

• In 2014, the District c ollected over 5,150 pounds of unwanted/expired

pharmaceuticals through several one

- day events and nine permanent collection

sites

.

• Continued support of Alameda County Safe Medicine Disposal Ordinance through

membership in the Alameda County MEDS Coalition

. PCBs

• Continued to implement PCBs sampling and analyses requirements fo r dewatering

sites and to conduct influent and effluent monitoring to track regulatory

compliance.

New P2 Category

• The District continued to evaluate the feasibility of adding long

- term care facilities

as a potential P2 category

, focusing on rags, trash, and wipes

.



### 78

### 5.2 **Description of SD**

**- 1 Treatment Facilities and Service Area** 

The EBMUD WWTP facilities and its service area are described in Section 1.2 of this Annual Report.



### 5.3 **Current Pollutants of Concern**

The table below presents the pollutants of concern for EBMUD and the basis for this determination. The following

sections discuss EBMUD’s efforts to address these pollutants , as well as other emerging contaminants (e.g.,

pharmaceuticals and pesticides)

.

Pollutants of Concern

and Additional Target

Constit uents Basis for Determination

Mercury P ermit No. CA0037702

, Order No. R2

- 2007

- 0077

– TMDL

FOG Potential to cause sanitary sewer overflow s; provide support to regional

satellite agencies

Copper P ermit No. CA0037702

- Copper Action Plan

Cyanide Permit No. CA0037702

- Cyanide Action Plan

PCB Order No. R2 2012

- 0096

- TMDL



### 5.4 **Source Identification and Reduction Programs**

This section d etails EBMUD ’s approach to identif y ing sources f or pollutants of concern , in addition to develop ing

effective control measu res

.



### 5.4.1 M ercury

C ommonly identified sources of mercury include dental facilities

, educational institutions

, electrical/electronic

sources, hospitals / medical facilities

, veterinary clinics, biological and pharmaceutical laboratories

, and residential

dischar gers

. EBMUD has focused its source reduction efforts on dental, educational institutions, medical

, and

residential sources.



### 5.4.1.1 Mercury Source Reduction Tasks and Timelines

During 20 1 4

, EBMUD continued its focus on dental facilities and hospitals. The followi ng are specific tasks

implemented in 20 1 4 and/ or scheduled for 20 1 5

.

 

### Mercury Source Reduction in Dent al Facilities

• Dental Facilities Pollution Prevention Permit

1. C ontinued to regulate amalgam waste through the permit terms and conditions, including the an nual

report requirement documenting the handling of amalgam waste for the 12

- month reporting period

. 2. Continued to identify new f acilities and maintain the Dental Facilities Permit database

. 3. Continue d to determine facilities ’ compliance with the existing p ermit requirements, including the

installation and maintenance of an ISO 11143 Standard

- certified amalgam separator and the handling

of amalgam waste and spent fixer solution

. 4. Continued to provide support on dental amalgam issues to B ay Area Pollution Pr evention Group

(B APPG ) and agencies developing/implementing new programs.

5. In 2015, p lan to reissue permit with new requirements including a one

- time cleaning / replacement of

p

- traps impacted with amalgam w aste. A self

- certification report will be required documenting the p



### 79traps cleaning and the appropriate handling of the generated waste. The permit will continue to

require the installation of an amalgam separator (new facil ities) and ongoing maintenance , i n addition

to the annual self

- certification report , d ocumenting/reporting the handling of amalgam waste and

spent fixer

.



###  M ercury Source Reduction in Educational Institutions

The District’s Mercury Reduction Program for Educational Institutions (Program) was developed through a

joint District and Universit y of California (UC) pilot project implemented at the UC Berkeley campus. The

project

, partially funded through an EPA P2 grant , was conducted from 2002 through 2005. T he District

documented the successful pilot project in a template

, available at www.ebmud.com

, for agencies that want

to implement a similar program. The template includes established resources such as checklists to facilitate a

mercury source inventory and a list of non

- mercury alternatives

.

The Distric t im plemented a service area

- wide p rogram from 2005 through May 2010 , partnering with two

colleges and six s chools/school districts within SD

- 1 wastewater service area. Over 500 lbs of mercury

waste , including laboratory thermometers, small measuring devic es, and mercury

- containing chemicals, was

removed from the environment

.

EPA recognized the District’s Program through the agency’s National Partnership for Environmental

Priorities’ Mercury Challenge Program : a regional award in June 2010, followed by a national leadership

award in October 2011

.

Currently the P rogram is inactive as Educational Institutions that required assistance with mercury disposal

have already participated

. The District will reactivate the Program if there is a need in the future. Program

information and tools that were developed are available on the District’s website

.



###  Residential Mercury Thermometer Exchange Program

No mercury thermometers were collected in 201 4 . The District will continue to accept mercury thermometers

if request ed, but is no longer conduct ing exchange events given the reduced need in the community

.



###  Mercury Source Reduction at EBMUD

EBMUD has a n ongoing mercury

- containing device recycling program for its facilities . In 201 4

, a total of

1 8,836 pounds of u niversal w aste was recyc led

, including 3,045 pounds of fluorescent lamps. The follo w in g

table details the waste type and quantit ies recycled :

Fluorescent

Lamps HID

Lamps Pb Acid

Batteries Alkaline

Batteries E

- Waste Non

PCB

Ballast Lithium Ion

Batteries All

Recyc led

Sources

Total lbs 3,045 463 7, 6 71 2,963 4,157 385 152 18,836



### 80

### 5.4.1.2 Effectiveness Measures and Progress for Mercury Reduction Programs

Effectiveness Measure for Mercury Source

Control & Reduction Progress in Mercury Source Control &

Reduction

• Percent of dentists who certify that they have

installed an amalgam separator.

• Percent of dentists who certify that they are

handling their mercury waste appropriately.

• Number of schools and colleges that

participat ed in EBMUD’s Mercury Reduction

Program

.

• Num ber of pounds of mercury waste collected

from local schools and colleges since the joint

UC Berkeley pilot project

.

• Number of hospitals and other sources who

have begun implementing BMPs to reduce

mercury.

• Number of mercury thermometers collected

during residential exchange events. • Approximately 95 % certification of amalgam

separator installation

.

• Approximately 95% certification of appropriate

handling of mercury waste

.

• Two colleges, one private/one public, and six

local school districts participated

.

• Over 500 pounds of mercury waste collected

from local schools and colleges since the pilot

project with UC Berkeley.

• All five of EBMUD’s hospitals (total of seven

hospital campuses) have conducted facility

audits and are “virtually mercury free.”

• Accep t mercury thermometers on a n as

- need ed

basis. Demand has decreased significantly over

the past two years.

• Reduction in influent, effluent, biosolids

mercury massing loading at main wastewater

treatment plant. • Significant reductions have been measured in

the influent and biosolids (Figure 5

- E and Tabke

2

- D ).



### 5.4.1.3 Additional Achievements in Mercury Reduction Programs

• Uploaded mercury program information on EBMUD’s website

o P rogram development templates and permit requirements for m ercury s ource r eduction in d en tal

f acilities

o T emplate and related information for EBMUD’s Mercury Reduction Program for Educational

Institutions



### 5.4.2 F ats, Oil, and Grease (FOG)

The Regional FOG Control P rogram includes residential and commercial components to address FOG

- related

sanitary s ewer overflows (SSOs) and blockages (hotspots) in the sanitary sewer collection system s

. In response to

FOG

- related SSOs and blockages, t he program implements field investigations . This may include FSE inspect ions

, camera investigations, and /or gravity gre ase interceptor inspections in FOG related SSO and blockage areas.

Collection system agencies within EBMUD ’s wastewater service area report FOG

- related SSOs and blockages to

EBMUD

. EBMUD staff determine whether the blockages are in a commercial drainage basin, and if so, EBMUD

staff inspect the FSEs in the basin . Those FSEs that generate grease and are found to cause or contribute to a

blockage or SSO are required to install grease control device ( GCD )

. FSEs with existing grease interceptors, which



### 81are de signed to be pumped by a licensed grease hauler, are required to increase pumping frequencies of their grease

interceptors as needed

.

As part of the Regional FOG Control Program, EBMUD performs routine gravity grease interceptor inspections in

non

- hotspot areas ; provides enforcement support for agencies ; reports all work activities and progress in quarterly

hotspot reports; provides routine database management with annual updates to remove old or outdated data and

update database with new and current FSE i nformation; a nd conducts commercial and residential FOG outreach.

EBMUD identifies priority areas for targeted residential outreach, distributes outreach materials in identified areas,

and reports investigation results to agencies.

Over the last ten year s, EBMUD has co nduct ed outreach to businesses, universities and residents, both throughout

the year and during the holidays. EBMUD continues to implement multi

- lingual targeted outreach in residential areas

that have SSOs and blockages. In addition, EBMUD provides support to the BAPPG ’s FOG holiday outreach efforts

and partners with Baykeeper to educate residents about preventing sewage backups caused by FOG.



### 5.4.2.1 F OG Source Reduction Tasks and Timeline

In 201 4

, EBMUD conducted the tasks summarized below

.



###  Comm ercial FOG Program

• Continue d hotspot investigation procedures for grease

- related SSOs and blockages reported by

EBMUD’s wastewater service area agencies

. There were 127 grease blockage reports submitted

, with

30 being identified as being caused by or contr ibuted to by FSEs.

• Continued to implement a Grease Generating Capability Checklist to record findings during FSE

inspections and support the decision

- making process pertaining to GCD requirements.

• Continued to implement the agencies’ requirement s and pr ovide enforcement support to agencies for the

installation of GCDs and grease interceptor pumping at facilities shown to cause or contribute to FOG

related SSOs or blockages.

• Continued field inspections at FSEs with gravity grease interceptors to documen t compliance and

ensure sufficient cleaning and maintenance of grease interceptors.

• Continued to provide quarterly hotspot progress reports to individual collection system agencies.

• Continued to provide the Regional FOG Program Annual Report to collecti on system agencies in

EBMUD service area to document all of the efforts and progress over the course of the year

, se rvice

area

- wide.

• Continue d to maintain a FOG control database , integrate FOG database with GIS capabilities, and add

new functions to enhan ce the user experience

. Completed the 201 4 annual FOG database update.

• Continued collaboration with the environmental community to promote FOG outreach for FSEs.

Presented information about FOG controls, sustainable food service establishment practices a nd

distributed commercial FOG outreach materials at the “Greener Restaurants” seminar organized by the

Food Service Technology Center and StopWaste.org.

• Participated in Bay Area

- wide collaboration efforts on FOG issues. Examples of FOG

- related outreach

doc uments developed in collaboration with BAPPG and other stakeholders are available at

www.bappg.org

.

• Continued to update and maintain the EBMUD commercial FOG web page: www.ebmud.com/our

water/wastewater

- treatment/fats

- oils

- and

- grease



### 82

###  Residential FOG Program

• R esidential used cooking oil collection program (ongoing)

o Continued availability of resi dential FOG drop

- off at EBMUD ’s M WWT P . Continued promotion of

Richmond’s West County Resource Recovery facility and Central Contra Costa Sanitary District’s

household hazardous waste facility through outreach about their acceptance of residential FOG. All

three facilities’ recycle the collec ted cooking oil into a biofuel.

o Continued support of two residential cooking oil drop

- off sites with in the EBMUD service area at a

recycling center and a local biofuel facility in Berkeley

.

o EBMUD facilitated the placement of another bin outside our wastewa ter service area at the Whole

Foods store in Lafayette.

o Collected over 2,113 gallons of used cooking oil and grease from residents at EBMUD’s M WWTP

, El Cerrito Recycling Center and the Oakland Whole Foods residential cooking oil drop

- off locations

.

o As in previous years, updated and expanded outreach for Residential FOG Collection Program:

 With Baykeeper’s help, continued holiday outreach to 1 5 local independent retailers of

turkey fryers and oil jugs.

 Distributed 706 FOG scrapers via the EBMUD on

- line sto re and the EBMUD phone hotline,

primarily in response to Customer Pipeline newsletter outreach.

 Distributed a total of 4,665 door hangers in three languages (English, Chinese, and Spanish)

to residents within EBMUD’s wastewater service area. Each door han ger contained a FOG

scraper with message to encourage scraping pots and pans before washing , and residential

outreach brochure on how to prevent grease

- related issues.

 Continued to update and maintain the EBMUD residential FOG information on our

residenti al web page: www.ebmud.com/cleanbay

• Develo ped a new “Think Before You Flush” br ochure to address wipes/”disposable” consumer

products , which often come in tandem with FOG and cause chronic problem, including blockages, SSO,

expensive repair and maintenance issues , in the sanitary sewer systems. In 2014, delivered over 600

personalized FOG and “wipes/trash” related personalized letters and “Think Before You Flush”

brochur es (in addition to residential FOG brochures) to residents in identified hotspot areas.

• Updated and m aintained the EBMUD

- FOG residential disposal web page

,

http://www.ebmud. com/wastewater/residential_pollution_prevention/

, with added link on resources

page to www.baywise.org website for regional FOG disposal information.

• Continued distribution of residential FOG outreach materials at c ommunity events , including Solano

Stroll, the City of Oakland Earth Expo

, Alame da Earth Day event s

, and Healthy Living Festival at the

Oakland Zoo

.



### 5.4.2.2 Effectiveness Measures and Progress for FOG Programs

Residential/

Commercial Effectiveness Measure for FOG Source

Control & Reduction Progress in FOG Source Control and Reduction

Both • Collaborate with collection system

agencies to abate grease

- related

SSOs and blockages in community

sewers.

• Obtain hotspot reports from

collection system agencies

. • On

- going face

- to

- face m eetings with collection

system agency staff for program development

.

• Customized (per individual agency) a pproved

GCDs

.

• Streamlined hotspot investigation process by

implementing a grease generating capability

trigger for GCD requirements.

• Over 1,050 hotspot reports received to date

, follow

- up ongoing

.



### 83Residential/

Commercial Effectiveness Measure for FOG Source

Control & Reduction Progress in FOG Source Control and Reduction

• Expand o utreach e fforts by

including FOG

- oriented outreach in

newsletters and other outreach

vehicles of a wide range of

stakeholders

. • Outreach vehicles include:

- Community/City newsletters / web sites

- EBMUD’s Customer Pipeline

, and website

- Community events

Commercial • Inspect FSEs in hotspot areas as

part of the hotspot response

procedures

.

• Inspect FSEs with gravity grease

interceptors to ensure proper

maintenance and to prevent FOG

related iss ues.

• Ensure FSEs install and properly

maintain GCDs

. • Conducted approximately 186 FSE inspections

in 2014 that included over 50 gravity grease

interceptor (GI) inspections which resulted in

improved GI pump out and maintenance at

FSEs.

• Over 70 GCD s requ irement letters were

delivered in 201 4 requiring FSEs to either install

approved GCD s or maintain already existing

grease trap s

. Communities also require GCDs

for new or remodeled FSEs

. Residential • Num ber of local stores conducting

FOG holiday outreach

.

• Number of door hangers providing

residential “hotsp ot” outreach to

targeted areas

.

• Number of FOG scrapers requested

via EBMUD on

- line store and

phone hotline

. • 1 5 local stores participated. This was an

increase compared to 2013, in which 13 local

stor es participated.

• 4,665 door hangers with FOG scrapers and

residential outreach brochures were distributed

in hotspot areas as well as for preventative

measures. This was a 40% increase compared to

2013 in which 3,407 door hangers were

delivered.

• 706 FOG scrapers (compared to approximately

966 in 201 3 ) were distributed for free via the

EBMUD on

- line store (free) and the EBMUD

phone hotline

.

• Increase in FOG scrapers requests

and FOG

- related information

inquiries as a result of specific

outreach efforts.

• Number of newly established

residential cooking oil drop

- off

sites.

• Number of gallons of residential

cooking oil collected at residential

collection bins. • Hotline inquires for FOG scrapers increased

from 3 to 12 times the normal volume during the

weeks when the City of Oakland’s multi

- family

residential postcards, which had a reference to

EBMUD’s hotline, were delivered to over

60,000 garbage customers.

• A new residential cooking oil drop

- off location

was established in Lafayette.

• Over 2,113 ga llons of residential cooking oil

collected in residential collection bins was

diverted from the collection system.



### 84

### 5.4.2.3 Additional Achievements in FOG Programs

• Provided support to the City of Oakland staff to develop a FOG outreach message for the City’s FO G

brochure (Exhibit 5

- D), FOG magnet (Exhibit 5

- E), and postcard for property managers of multi

- family

dwellings in Oakland (exhibit 5

- F). During the weeks when the postcards were mailed out, EBMUD’s

hotline inquires for FOG scrapers increased from 3 to 12 times the normal volume.

• Continued enhancement of FOG program data base to increase program effectiveness. Developed and

implemented an automatic notification system to flag gravity GIs that were found to be overloaded. An

automatic notification facilitat es prompt follow

- up by staff with the FSEs in question.

• Provided data for hotspot density analysis GIS map to the City of Oakland staff for them to facilitate

their sanitary sewer maintenance work and focus on areas of high accumulations of FOG in the san itary

sewer system.

• Developed a new outreach tool (spin wheel) for community events. This new spin wheel, which

contains multi

- pollutant information/questions, including FOG, attracts events’ visitors, enhances their

engagement and learning experience.

• De veloped a new “Think Before You Flush” brochure to address wipes/”disposable” consumer

products, which often come in tandem with FOG and cause chronic problem, including blockages, SSO,

expensive repair and maintenance issues in the sanitary sewer systems. See Exhibit 5

- A

.

• Developed and distributed residential FOG and “disposable” wipes/trash articles for resident s of large

apartment complexes and long term care facilities. See Exhibit 5

- G

. Developed and distributed FOG

articles to local media sources during the holiday months . See Exhi bit s 5

- H

, 5

- I , and 5

- J

.



### 5.4.3 C opper

Copper is found in tap wate r from corrosion. In addition, known commercial and industrial sources of copper

identified include vehicle repair shops, printing shops, radiator shops, electroplating/metal finishing facilities,

transportation equipment cleaning and boatyards. EBMUD issu es permits and conducts inspections, as needed, to

ensure ongoing implementation of pretreatment requirements for facilities in the electroplating, metal finishing, and

transportation equipment cleaning categories . EBMUD also issues P2 permits requiring im plement ation of permit

specific BMPs for facilities in the vehicle repair, printing, radiator, and boatyard business types.

Copper loading to the EBMUD M WWTP initially decreased with the issuance of the permit types listed above and

has remained approxima tely the same in the years after, as shown in F igure 5

- C

. The total copper loading to

EBMUD’s WWTP was 1 6

. 67 8 kg/da y in 20 14

. EBMUD has initiated a Copper Action Plan, described below, to

address overall copper contributions and control.



### Element Descript ion Deadline Status

(1) Review Potential

Copper

Contributors The Discharger shall submit an

inventory of potential copper sources

to the wastewater treatment plant. July 1, 2010 Submitted in the 2010

Annual Report.

(2) Implement

Copper Control

Program T he Discharger shall submit a plan for,

and begin implementation of, a

program to reduce copper discharges

identified in Task (1) consisting, at a

minimum, of the following elements: February 28,

2011, with

2010

Annual P2

Report.

i. Provide education and outreach to

the public (e.g. focus on proper pool

and spa maintenance and plumbers’

roles in reducing corrosion). • Created a Maintaining

Copper

- free Pools, Spas

and Fountains brochure

(2012); identified over

1700 public and private



### 85

### Element Descript ion Deadline Status

pool owners, including

pool maintenance

companies; mailed

brochures to each.

• Supported BAPPG to

develop a Fact Sheet for

Maintenance Tips for

‘Pools, Spas and

Fountains’

ii. If corrosion is determined to be a

significant copper source, work

cooperatively with local water

p urveyors to reduce and control water

corrosivity as appropriate, and ensure

that local plumbing contractors

implement best management practices

to reduce corrosion of pipes. The aggressive nature of

EBMUD’s source water is a

source of copper to

wastewate r influent. EBMUD

already adjusts the pH of its

water to reduce its

aggressiveness. EBMUD

Wastewater will continue to

work collaboratively with our

intra

- agency colleagues to

identify ways to reduce

copper due to source water.

(2) Implement

Copper Control

Program iii. Educate plumbers, designers, and

maintenance contractors for pools and

spas to encourage best management

practices that minimize copper

discharges. Outreach conducted on an

ongoing basis through

BAPPG.

(3) Implement

Additional Measures If the Regional Water Board notifies

the Discharger that the three

- year

rolling mean dissolved copper

concentration of Central San Francisco

Bay exceeds 2.2 ug/L, then the

Discharger shall evaluate the effluent

copper concentration trend. If the trend

is incr easing, within 90

- days of the

notification, the Discharger shall

develop and begin implementation of

additional measures to control copper

discharges, and shall report annually

on the progress and effectiveness of

measures taken together with a

schedule fo r measures to be taken in

the next 12 months. Report in

Annual P2

Report

starting with

the report

due

after the

notification. SFEI analyzed available

RMP data and determined

that the copper triggers for

additional measures were not

exceeded, so no further

actions are required at this

time. Please see BACWA

letter to RWQCB dated

January 17, 2014.

(4) Studies to Reduce

Copper Pollutant

Impact Uncertainties The Discharger shall conduct or cause

to be conducted studies to investigate

possible copper sediment toxicity and

studies to investigate sublethal effects

on salmonids. Specifically, the

Discharger shall include the manner in With Annual

P2 Report

due

February 28,

2011. EBMUD through BACWA

is funding RMP to better

understand the impacts of

copper on salmonids. See

letter from BACWA to

RWQCB dated Januar y 17,



### 86

### Element Descript ion Deadline Status

which the above will be accomplished

and describe the studies to be

performed with an implementation

schedule. To satisfy this requ irement,

dischargers may collaborate and

conduct these studies as a group. 2014 , Exhibits 5

- K and 5

- L

.

(5) Report Status of

Copper Control

Program Submit a report to the Regional Water

Board documenting implementation of

the copper control program. Annually

with P2

report due

February 28 Ongoing



### Copper Action Plan

Inve ntory of Potential Copper Contributors

# Discharger Service Address Industry Category

1 E

- D Coat, Inc. 715 4th Street, Oakland Electroplating

2 Gold Seal Plating 3125 E 7th Street, Oakland Electroplating

3 Johnson Plating 2526 Telegraph Avenue, Oaklan d Electroplating

4 Monsen Plating Silversmith 3370 Adeline Street, Berkeley Electroplating

5 Metalco, Inc 1475 67th Street, Emeryville Electroplating

6 Melrose Metal Finishing, Inc. 10222 Pearmain Street, Oakland Electroplating

7 Boardworks 499 Embarc adero, Oakland Metal Finishing

8 Lawrence Berkeley National

Laboratory Bld. 77 1 Cyclotron Road, Berkeley Metal Finishing

9 Able Metal Plating, Inc. 932 86th Avenue, Oakland Metal Finishing

10 Electro

- Coatings Of California 893 Carleton Street, Berkel ey Metal Finishing

11 Mercurius Company 3224 Brookdale Ave, Oakland Metal Finishing

12 Lucasey Manufacturing 2744 E 11th Street, Oakland Metal Finishing

13 Fryer Industries, Inc./dba Dougco 1073 34th Street, Oakland Metal Finishing

14 Scientific Plate rs, Inc. 9809 Kitty Lane, Oakland Metal Finishing

15 Rolls

- Royce Engine Svcs 7200 Earhart Road, Oakland Metal Finishing

16 A B And I 7825 San Leandro Street, Oakland Metal Molding and Casting

17 Mussi Artworks Foundry, LLC 729 Heinz Ave #10, Berke ley Metal Molding and Casting

18 Pacific Steel Casting 1333 Second Street, Berkeley Metal Molding and Casting

19 Pressure Cast Products 4210 E 12th Street, Oakland Metal Molding and Casting

20 Sks Die Casting Machining 1849 Oak Street, Alameda Metal Molding and Casting

21 AC Transit

- Emeryville 1177 47th Street, Emeryville Local and Suburban Transit

22 AC Transit

- International 10626 International Blvd., Oakland Local and Suburban Transit

23 AC Transit

– Seminary 1100 Seminary Avenue, Oakland Local and Suburban Transit

24 Union Pacific Railroad 1851

- B 5th Street, Oakland Railroad Transportation

25 Oakland International Airport Doolittle & Airport Drive, Oakland Air Transportation

26 Berkeley Forge & Tool Inc. 1331 Eastshore Hwy, Berkel ey Aluminum Forming

27 Coulter Forge Technology 1494

- 67th Street, Emeryville Aluminum Forming

28 Custom Alloy Scrap Sales 2730 Peralta Street, Oakland Non

- Ferrous Metals

29 Precision Coatings Corp. 1220 4th Street, Berkeley Paint Formulating

30 N RC Environmental Services, Inc. Wharf 2 Ferry Point, Alameda Centralized Waste Treatment

31 Harkrader Trucking, Inc. 9957 Medford Ave, Oakland Transportation Equipment



### 87# Discharger Service Address Industry Category

Cleaning

32 Aramark Uniform Services 330 Chestnut Street, Oakland Industrial Laun dry

33 Longview Fibre Paper and Packaging,

Inc. 8511 Blaine Street, Oakland Pulp and Paper

Products/Printing

In addition to the individual industrial accounts listed, EBMUD permits and regulates a wide variety of commercial

facilities. The business ty pes that are potential contributors of copper are listed below. A current list of businesses is

available upon request.

Business Type Number of Facilities

Boatyards 6

Vehicle repair facilities 624

Vehicle washing facilities 78

Radiator facilities 5

Printing facilities 68

In the EBMUD wastewater service area there are numerous community, institutional and private pools as well as

pool maintenance and design companies. EBMUD mailed outreach information on maintaining copper

- free pools,

spas and foun tains in 2013. A distribution list can be obtained upon request.



### 5.4.3.1 Copper Source Reduction Tasks and Timeline

For known commercial and industrial sources of copper identified, EBMUD conducts the following source reduction

activities :

• Maintain permits for ex isting facilities and issue new permits to new facilities.

• Conduct inspections

.

• Conduct ou treach using brochures developed by EBMUD , BAPPG, DTSC, Green Business Program

and other agencies while conducting facility inspections.

In addition to these activ ities, the following business

- specific activities were undertaken.



###  Copper Source Reduction in Boaty ards

• Developed BMPs for boatyards (2011).

• As a member of a Technical Advisory Committee that includes the Department of Boating &

Waterways ; California Coas tal Commission; Department of Pesticide Regulations ; San Francisco

Department of Public Hea lth; Institute for Research and Technical Assistance; industry representatives ;

and Baykeeper, EBMUD participated in development of the Boatyards Pollution Preventio n

Recommended Practices Toolkit for controlling pollutants in wastewater discharges for the State of

California . The toolkit materials were finalized and released in 2013.

• In 2013, EBMUD renewed pollution prevention BMP

- based permits for all boatyards in its service area.



###  Copper Source Reduction in Plumbing

• Supported BAPPG efforts to conduct outreach to Bay Area plumbers’ unions , contractors, building

inspectors and colleges on proper copper pipe installation.



### 88

### 5.4.3.2 Effectiveness Measures and Progress for Cop per Source Control and Reduction

Effectiveness Measure for Copper Source

Control & Reduction Progress in Copper Source Control & Reduction

• Document of P2 efforts by industrial

facilities that are actual or potential

dischargers of copper.

• Issue and/or ma intain P2 permit s to

dischargers with potential to discharge

copper. • Pretreatment permits include terms for P2 practices ; 2 0

categorical IUs are zero dischargers

• P2 permit holders in compliance and implementing

BMP requirements include :

o vehi cle repair s hops : seal floor drains

o printing shops : Eliminate or pretreat discharge of

copper

- containing solutions

o radiator repair shops : no process discharge

o boatyards : eliminate or pre

- treat process discharge



### 5.4.4 C yanide

The District has taken/is taking the following measures in response to t he regional C yanide A ction P lan

, required

through Permit No. CA 0037702

. EBMUD does not have any cyanide contributors because all potential sources either

do not use cyanide or are zero dischargers.

Element Description Deadline Sta tus

(1) Review

Potential

Cyanide

Contributors The Discharger shall submit an inventory of

potential contributors of cyanide to the

wastewater treatment plant (e.g., metal

plating operations, hazardous waste

recycling, etc.).

If no contributors of cyanid e are identified,

Tasks 2 and 3 are not required, unless the

Discharger receives a request to discharge

detectable levels of cyanide to the sanitary

sewer. If so, the Discharger shall notify the

Executive Officer and implement Tasks 2

and 3. July 1, 2010 Complete

(2)

Implement

Cyanide

Control

Program The Discharger shall submit a plan for, and

begin implementation of a

program to minimize cyanide discharges to

the sanitary sewer system consisting, at a

minimum, of the following elements:

February 28, 201 0

-

201 1 Annual P2

Report. i

. Inspec t each potential contributor to assess

the need to include that contributing

source in the control program. Complete

, see the

Cyanide Action Plan

below.

ii. Inspect contributing sources included in

the contro l program annually. Not required

(no contributors of

cyanide)



### 89Element Description Deadline Sta tus

iii. Develop and distribute educational

materials to contributing sources and

potential contributing sources regarding

the need to prevent cyanide discharges. Not required

(no contributors o f

cyanide)

iv. Prepare an emergency monitoring and

response plan to be implemented if a

significant cyanide discharge occurs. Not required

( no contributors of

cy a nide, however, one

had been drafted (see

section 5.4.4.1 ))

(3)

Implement

Additional

Measu res If the Discharger is notified by the Regional

Water Board that ambient

monitoring shows cyanide concentrations of

1.0 μg/L or higher in the main body of San

Francisco Bay, then within 90 days of the

notification, the Discharger shall begin

taking actions to identify and abate cyanide

sources responsible for the elevated ambie nt

concentrations and report annually on these

actions. Report in Annual P2

Report starting with

the

report due after the

notification San Francisco Estuary

Institute’s analysis of

available Regional

Monitoring Program

ambient water quality

data show that the

cyanide concentration

trigger was not

exceeded, so no further

actions are required at

this time.

(4) Report

Status of

Cyanide

Control

Program Submit a report to the Regional Water Board

documenting implementation

of the cyanide control program. Annua lly with P2

Reports due

February 28 Ongoing

Cyanide Action Plan

Inventory of Potential Cyanide Contributors

The following table includes EBMUD's list of facilities that may handle cyanide. Currently there are no cyanide contributors as detailed below:

Discharger Service Address Regulatory

Category Summary of Cyanide Use, "ZD" =

zero discharger

E

- D Coat, Inc. 715 4th Street, Oakland Electroplating Facility currently closed due to

ongoing enforcement action

Metalco, Inc 1475 67th Street, Emeryville Ele ctroplating No cyanide use

Gold Seal Plating 3125 E 7th Street, Oakland Electroplating ZD, cyanide waste offhauled

Johnson Plating 2526 Telegraph Avenue,

Oakland Electroplating ZD, cyanide waste offhauled

Monsen Plating Silversmith 3370 Adeline Street, Berkeley Electroplating ZD, cyanide waste offhauled

Boardworks 499 Embarcadero, Oakland Metal

Finishing No cyanide use

Lawrence Berkeley

National Laboratory Bld.

77 1 Cyclotron Road, Berkeley Metal

Finishing No cyanide use

Lucasey Manufacturing 2744 E 11th Street, Oakland Metal

Finishing No cyanide use



### 90Discharger Service Address Regulatory

Category Summary of Cyanide Use, "ZD" =

zero discharger

Fryer Industries, Inc./dba

Dougco 1073 34th Street, Oakland Metal

Finishing No cyanide use

Scientific Platers, Inc. 9809 Kitty Lane, Oakland Metal

Finishing No cyanide use

Electro

- Coatings Of

Califor nia 893 Carleton Street, Berkeley Metal

Finishing ZD, cyanide waste offhauled

Melrose Metal Finishing,

Inc. 10222 Pearmain Street,

Oakland Metal

Finishing ZD, cyanide waste offhauled

Able Metal Plating 932 86th Avenue, Oakland Metal

Finishing ZD, no cyan ide use

Mercurius Company 3224 Brookdale Ave, Oakland Metal

Finishing ZD, no cyanide use

Pacific Galvanizing 715 46th Avenue, Oakland Iron & Steel

Mfg ZD, no cyanide use

Bayer Corporation 4th & Parker Streets, Berkeley Pharmaceutical potential cyani de use, waste offhauled

Libby Laboratories, Inc. 1700 Sixth Street, Berkeley Pharmaceutical No cyanide use

Novartis 5401 Chiron Way, Emeryville Pharmaceutical No cyanide use



### 5.4.4.1 Cyanide Emergency Monitoring and Response Plan

The following steps are inclu ded in the Di s trict’s S ignificant C yanide D ischarge Response Plan.

A. EBMUD defines a significant cyanide discharge as influent 2 4 ug/L, based on the highest concentration at

the main WWTP from 20 10

- 201 4

. EBMUD has established e lectronic outlier notificatio n s for all analyses

and associated parameter discharge limit s /triggers. If a cyanide result is greater than or equal to the defined

triggers, all applicable wastewater staff, including the Supervising Wastewater Control Representative , will

be alerted thro ugh the District’s email system.

B. An investigation team will be formed to identify the cyanide source . The investigation may include:

interceptor sampling

, point source sampling

, and a phone survey of p otential contributor s.

C. If the cyanide source is identif ied, en forcement action may be taken against the facility

. D. A n incident summary report outlining the actions taken will be included in the District’s subsequent Annual

Pretreatment and P2 Report.



### 5.4.5 P olychlorinated Biphenyls (PCBs)

In 2014

, EBMUD continued to conduct work with identified/controllable sources, implement PCBs sampling and

analyses requirements for dewatering sites

, and to conduct influent and effluent monitoring to track regulatory

compliance.



### 5.4.6 Pharmaceutical Disposal

• EBMUD spons o rs nine phar maceutical collection sites within our wastewater service area. In 2014,

we participated in two public pharmaceutical collection events.



### 91• The Pharmaceutical Take

- back Program has collected over 1 5

, 9 00 pounds of expired/unwanted

pharmaceuticals since the pr ogram’s inception in 2009. In 201 4 , EBMUD collected over 5,100

pounds of unwanted/expired medication.

• EBMUD c ontinue d to support the Product Stewardship Institute in their efforts to move

Congressional legislation forward to reduce barriers for establishi ng pharmaceutical collection

programs.

• EBMUD c ontinued to support the Alameda County Safe Medicine Disposal Ordinance through

membership in the Alameda County MEDS Coalition.

• EBMUD c ontinued the Keep the Bay off Drugs campaign at 132 billboard and bus shel ter locations

throughout the wastewater service area . S ee Exhibits 5

- B and 5

- C

.

• EBMUD d eveloped and distributed P2 and pharmaceuticals outreach for residents of long term care

facilities

.



### 5.4.7 Pesticides

• As a member of BAPPG, EBMUD submitted comment letters on several EPA pesticide registration

reviews and CA Department of Pesticide Regulation’s pesticide re

- registrations, including PHMB,

Dichlobenil, Prallethrin, Bactiblock and Clothianidin. Comments were also submitted on the EPA’s

proposal for E ndangered S pec ies A ct enhanced stakeholder input.

• EBMUD supports the Our Water, Our World (OWOW) program through BAPPG. The program’s

website offers alternatives to manage residential/garden pests, while protecting the environment. In

addition

, BAPPG/OWOW conducted var ious outreach activ ities including working with p esticide

manufacturers to set up eco

- friendly displays of less

- toxic pesticide in Home Depot.

• EBMUD continues to sell its award

- winning Plants and Landscapes for Summer Dry Climates book.

• EBMUD distributes “Grow It!” guides by request / at public events , which provide information on

less

- toxic pesticide alternatives. The booklet is also available for access on the EBMUD Clean Bay

website.

• Per EBMUD ’s Sustainability Policy (Policy 7.05) , the District contracts with certified p est c ontrol

companies for its facilities and uses only non

- restricted pesticides in its watershed.



### 5.5 **Green Chemistry & Producer Responsibil i**  **ty**

EBMUD c ontinued to participate in initiatives at the state and national levels regarding green ch emistry and producer

responsibility. As noted in the previous section, EBMUD staff ha s continued to collaborate with the Product

Stewardship Institute on pharmaceutical dispo sal and provided support for the San Francisco pharmaceutical product

stewardship ordinance.



### 5.6 **Outreach to EBMUD**  **Employees**

In 2014

, EBMUD continued employee outreach to reduce the pollutants to the environment

.



### 5.6.1 Employee Events & Activities

• EBMUD Earth Day Event for District Personnel

- The 1 5 th Annual Earth Day Event was held on

April 2 3 , 201 4

. Th is w ell

- attended event included exhibitors from 8 District workgroups and 1 2 local

agencies, environmental organizations and green vendors with the purpose of educating employees

and visitors about sustainable practices and assist ing them in ex panding their Reduction, Recycling,

Reuse, and Reclamation efforts . E

- waste, reading glasses , clothing, and squeeze balls (for cerebral

palsy patients) were collected for proper disposal, recycling and/or re

- use.



### 92• Bike to Work Month

– The EBMUD Bike

- to

- Work Month team had 62 riders that pedaled a total of

8, 195 miles during the month of May. Bicycling and other alternative commute programs help

EBMUD r educe greenhouse gas emissions.

• Greenhouse Gas Reductions

- T he District continues to maintain a fleet of hy brid vehicles and

implement energy efficiency programs such as biogas use to power the MWWTP and install ation of

solar panels and natural gas microturbines at EBMUD’s Administration B uilding

.

• During 201 4 , the District’s Sustainability and Recycling Commi ttee continued education efforts to

encourage employees’ proper use of the green compost and blue recycling bins. The Committee also

participated in the RFP process to consolidate recycling and composting contracting for EBMUD

facilities in Alameda County to ensure compliance with the Alameda County ordinance that requires

facilities to compost and recycle items.

• District

- wide Clean U p Event , which is a bi

- annual event, took place during the week of August 25

-

29

. The District collected 1,728 pounds of ele ctronic and universal waste to be recycled. Th e next

District

- wide clean

- up event will take place in 201 6

.

• EBMUD has an ongoing collection program for employee e

- waste and spent batteries as part of its

established Universal Waste Program

.

• The District’s Print Shop was recertified as a Green Business.

• The District’s janitorial staff b egan a pilot project for dispensing/mixing third

- party certified green

chemicals for all

- purpose cleaning. The goals of the pilot are to reduce packaging waste and material

co nsumption, and reduce the potential chemical exposure to employees.



### 5.6.2 Employee Electronic Communications

EBMUD’s Sustainability and Recycling Committee maintains a P2 website for employees that :

• i ncludes information on Household Hazardous Waste Facilities ; links to the resid ential P2 web page

on Bay

- friendly car washing and household cleaning ; and includes information on the proper

disposal of residential FOG

, household mercury

- containing devices

, and unwanted / expired medicine ;

• e ncourage s use of the public E BMUD website for industrial

, commercial

, and residential

pretreatment and P2 information ; and

• r eports on the District’s sustainable efforts to minimize waste

, conserve energy / natural resources

, promote long

- term economic viabilit y and support safety / well

- being for employees , communities,

and customers

.

The Sustainability & Recycling Committee increased its focus on employee communication by p ublish ing 19

articles on sustainability in Splashes

, the District’s internal newsletter, which reach e s more than 20 00

employees and retirees . A rticles include d :

• District facility e nergy conservation efforts

• Ongoing information regarding the composting and recycling programs

• Bike to W ork activities

• 201 4 Earth Day Fair and activities

• EBMUD’s food waste to energy program

• Reducing fire fuel



### 5.7 **Public Outreach Program s** 

The District’s outreach efforts to industrial/commercial facilities

, government agencie s, non

- governmental

organizations

, school s, and residential communities are detailed below and summarized in the following tables

.



### 93

### 5.7.1 Outreach to Industr ial/ Commercial Facilities and Government Agencies

EBMUD provides relevant outreach material to its permitted industrial and commercial facilities. In addition

, the

District provide s P2 information to other business categories t o educate on specific pollutant s of concern

. Questions

from non

- permitted facilities regarding the handling of various wastes are frequent ly received through the

Environmental Services Division Hotline (details are provided in Section 5.7.4)

.

EBMUD provid es interagency coordination of pretreatment and P2 activities , including :

 I nteragency referrals (i.e. the California Department of Toxic Substances Control; stormwater agencies)

regarding pretreatment or P2 issues at facilities within EBMUD ’s wastewater s ervice area

 A ctive participation in the C alifornia Water Environment Association (C WEA ) Pretreatment, P2 , and

Stormwater Committee s to focus on pretreatment and P2 education and trainin g

 A ctive participation in the BAPPG on FOG

, pharmaceutical s

, pestic ides

, and other emerging contaminants

 A ssist a nce to BACWA in providing comments to EPA on its pending dental amalgam regulations



### 5.7.2 Outreach to Non

- governmental Organizations (NGOs)

EBMUD continued its partnerships with NGOs, including the following activit ies:

 C ontinued partnership with Baykeeper to address residential FOG

 C ollaborated with the Product Stewardship Institute on reducing federal barriers to pharmaceutical disposal

 E ngaged various NGOs to participate in annual Employee Earth Day event



### 5.7.3 Outrea ch to Schools

EBMUD provides teachers with P2 curricula upon request

. In 2014, EBMUD staff presented P2 topics, including

FOG and “disposable” wipes/trash to 2 nd grader s from a number of schools in Berkeley and Oakland.



### 5.7.4 Outreach to Residential Community

As previously noted

, EBMUD c onducted several residential FOG and pharmaceutical outreach events in 201 4

. T he

Di s trict provides ongoing outreach to residents through its website and hotline number

. The hotline number is

referenced on the website and include d in all outreach materials. It serves as an alternate means for contacting

EBMUD staff directly to ask general questions or request informational material such as brochures, grease scrapers,

and “how

- to” guides to help with their P2 needs. In 2014, over 260 hotline inqueries were addressed by EBMUD

staff. The District also communicates P2 information through its Pipeline publication bill insert , see Exhibit 5

- M

. Available P2 material s are mailed to customers upon request.

Additional P2 outreach efforts were curtailed by statewide drought issues which affected the continued use and

development of graphics and slogan s planned for more than 100 billboards and bus shelters as well as the EBMUD

Customer Pipeline newsletter articles.



### 94COMMUNITY EVENTS AND FES TIVALS IN 2014

Events Audience Time of

Year Benefit Comments

EBMUD Earth

Day EBMUD

Employees April Distributed FOG scrapers and Bay

friendly house cleaning tips.

Education about the reduction of

potential mercury and pharmaceutical

sources to employees.

Alameda Earth

Day Festival General

public April Presented and distributed residential

FOG outreach information. Education

about pharmaceutical contamination;

Grow It! and Clean It! guides were

also distributed along with water

conservation information. Approximately 550 people visited

EBMUD booth to learn about FOG

issues.

Oakland Earth

EXPO General

public April Education about and reduction of

potential mercury, Information on

FOG and pharmaceutical

contamination was distributed along

with Grow It ! and Clean It! guides

and water conservation information. EBMUD shared a booth with the

City of Oakland Sewer

Maintenance Department to

educate the event attendees about

FOG issues. The City staff

demonstrated their Aquatech sewer

cleaning equipment to show the

environmental impacts of FOG in

the collection system.

Healthy Living

Festival Seniors July Education about pharmaceutical

disposal. Collected 97 lbs of

unwanted/expired medication.

Albany Solano

Stroll

–

Thermometer

Exchange and Safe

Medicine D isposal General

public September Education about and reduction of

potential mercury and pharmaceutical

contamination. Grow It! and Clean It!

guides were also distributed along

with water conservation information. Distributed approximately500

FOG scrapers , 500 residential

FOG brochures,, approximately

450 Clean it Guides, and

40homeowners guides to finding

leaks. Approximately 545people

visited EBMUD’s booth.

No Drugs Down

the Drain General

public and

EBMUD

Employees Year

round Reduction of pharmaceutica l disposal

via the sewer or trash. Nine sites collected over 5,100

pounds of unwanted/expired

medication.

OUTREACH FOR BUSINESSES IN 2014

Activity Audience Time of

Year Benefit Comments

P2 Inspections Business

Operators Year

round

P2 inspections Bu siness

Operators Year

round Promote understanding of P2 permit

conditions and BMPs Inspectors provide outreach

materials (some multi

- lingual) and

discuss BMPs with facility

contacts.



### 95P2 BROCHURES AND MATERIALS PRODUCED AND/OR DISTRIBUTED BY EBMUD

Mat erial Audience Message Comments

Dry Cleaner Newsletter Permitted & Potential

New Permitees EBMUD phasing out dry cleaner

permits for those who choose to

eliminate perchloroethylene and

other solvents, Information on safer

spot cleaners and California Air

Resources Board’s financial

assistance for replacing perc

systems with non

- toxic, non

- smog

forming systems. Outreach to inform dry cleaners

of success in decreasing amount

of perc discharge to sanitary

sewer over the past 20 years and

EBMUD’s planned perm it

changes and incentive to

eliminate perc.

Vehicle Wash Signs Vehicle Wash

Facilities “Discharge of Brake and Engine

Cleaners to the Sewer is

Prohibited” Distributed during facility

inspections as needed.

Grow It! Guides Residents Provides information o n pesticide

alternatives, drought

- tolerant and

native plants, and proper disposal

information for household toxics. EBMUD provided native and

drought

- tolerant plants lists for

this BAPPG project. EBMUD

also tailored several pages to be

East Bay

- relevant.

“Think Before You Flush”

Brochure Residents Emphasizes the message that toilet

is not a trash can. Provides multi

pollutant information and proper

disposal options for household and

personal hygiene products that

should never be flushed. Distributed duri ng community

events and residential hotspot

areas where FOG and “flushable”

wipes/trash related

blockages/overflows occur.

FOG Scrapers Residents ”Use This Scraper To Prevent

Sewage Backups” These are distributed to areas

where there are residential grea se

“hotspots” and/or areas of

concern.

FOG Turkey Fryer Stickers Residents “Recycle Cooking Oil” Stickers placed on turkey fryers

sold at major and local

independent markets.

FOG Residential Grease

Sign Residents “Recycle Cooking Oil” Placed at some ma jor and local

independent markets near fryers,

oil or turkey displays during the

holidays.

FOG Residential Grease

Tear

- off Pad Residents “Recycle Cooking Oil” Placed at some local grocery

stores near oil displays at the

holidays.

FOG Brochure and Door

hanger Residents How to properly dispose of

cooking FOG Includes information on large

quantity disposal (i.e. from turkey

fryers) and use of kitchen scrap

recycling programs. Door hanger

has translated information in

Spanish and Chinese.

FOG BMP Poster Fo od Service

Establishments (FSEs) “FOG Friendly Tips” for food

service establishments provide

information about FOG and ways

to prevent FOG issues. . Distributed to FSEs in EBMUD

service area.



### 96P2 BROCHURES AND MATERIALS PRODUCED AND/OR DISTRIBUTED BY EBMUD

Mat erial Audience Message Comments

FOG Brochure Food Service

Establishments “Controlling FOG in Fo od

Handling Facilities” brochure:

Frequently asked questions on

FOG and FOG disposal Distributed to FSEs in EBMUD

service area.

FOG Flyer Food Service

Establishments “Best Management Practices for

Food

- Related Fats, Oils, and

Grease” flyer Business specif ic

practices to keep FOG out of the

sewer Distributed to FSEs in EBMUD

service area.

“Guidelines for Film

Processors/Printers” Photoprocessing and

Printing Facilities BMPs and treatment requirements

to keep silver rich wastewater out

of the sewer These are distributed at time of

P2 photo and printer permit

issuance or renewal.

“P2 Practices for

Automotive Facilities”

(BMP brochure) Businesses P2 for vehicle service facilities

EBMUD “Pollution

Prevention Self

- Audit

Checklist” Businesses Good house kee ping practices and

Business

- specific waste reduction

practices Covers 13 business categories

modeled after DTSC HWM

checklist

“The Tardy Twins Meet

Polluto” Schools Wastewater treatment and source

control EBMUD comic

- book format

distributed to schools

P2 Bookmarks Schools /General

Public EBMUD recognition

Clean It! Guides General Public Household Waste Control, less

toxic cleaning product use. Guides are mailed to customers

upon request or via online

through Admail.

Maintaining Copper

- Free

Pools, Sp as and Fountains Public & Private pool

owners and pool

maintenance

companies General information on the harmful

effects to the ecosystem of copper

accumulation in the Bay from

discharges. Best Management

Practices for reducing copper use

and proper disposa l of pool water.

OTHER OUTREACH TOOLS AND RESOURCES

Activity Audience Message Comments

Neighborhood and City

Council Member listservs,

All

- employees email

distribution Various Announcements of upcoming

opportunities/events to dispose of

household tox ics conveniently and

properly.

Bill Inserts ( Pipeline )

Articles General Public/

Businesses Various P2/wastewater messages. Each P2 article featured in the

Pipeline Newsletter reaches 1.2

million customers.

Pollution Prevention web

pages Residential and

Industrial/Commercial P2 messages, residential page,

industrial and commercial source

control pages, events and FAQs.

EBMUD Recycling

Committee Intranet Web

Page EBMUD employees P2/Waste reduction Coordination with District

recycling committee



### 97OTHER OUTREACH TOOLS AND RESOURCES

Activity Audience Message Comments

Environm ental Services

“Hotline” Information line General Public/

Businesses Program and general information. Provides information on

programs as well as answer

specific questions/requests for

information.

Billboard and Bus Shelter

Posters General Public Keep th e Bay off Drugs campaign Three slogans were used at 132

locations

OUTREACH THROUGH INTER

- AGENCY COORDINATION

Activity Audience Message Comments

Regional FOG Disposal

Website

www.baywise.org General Public “Cooking oil and grease can clog

plumbing and c ause sewage backups

into your home, neighborhood streets

and even San Francisco Bay. Prevent

backups by disposing of cooking oils

and grease by going to baywise.org

to find a local drop

- off. EBMUD staff continued to

maintain and update baywise.org

www.bay wise.org (also

. info) General Public Web portal for accessing Bay

- related

links and information EBMUD staff continued to update,

improve and streamline the

Baywise.org website. EBMUD,

Palo Alto and Mountain View

Sanitation District staff maintained

the Bay wise.org website.

Copper Plumbing Outreach Plumbers’ unions

and

plumber/contractor

courses BMPs for reducing copper pollution

from plumbing, i.e. correct soldering

techniques Coordinated through BAPPG.

Univision Spanish Radio

Outreach (sponsored by

BAPPG ) Spanish customers Residential FOG public service

announcement and ads Reaches the largest Spanish

population in the Bay Area. Timed

at the Thanksgiving and winter

holidays when turkey fryers used

and other rich foods are prepared.

Our Water Our World G eneral Public Less

- toxic pest control. Support of program through

BAPPG.

Asian Language FOG

Outreach Speakers of

Mandarin or

Cantonese,

Tagalog Residential FOG public service

announcement and ads

Golden Gate Pollution

Prevention Committee Public and oth er

agencies Coordination with other agencies

Alameda County Green

Business Program/

EBMUD Partnership General Public/

Businesses Businesses beyond compliance EBMUD provides funds to ACGBP

and does Green Business

inspections for certain types of

businesse s. Has positive

relationship w/ businesses.

CWEA P3S Committee Pretreatment, P2

and Stormwater

Staff Coordination with other agencies Includes training conference and

technical meetings.



### 98

### 5.8 **Cri te**  **ria used to Measure the Program s**  **’ and Tasks’ Effectiveness** 

EBMUD uses the following criteria to measure the e ffectiveness of its established P2 programs :

• Changes in pollutant concentration levels in the District’s M WWTP influent

• Number of people who visit EBMUD’s P2 webpage s

• Number of gallons of residential coo king oil collected

• Number of pounds of unwanted /expired pharmaceuticals collected

• Number of facilities in compliance with the terms/conditions of their P2 permit



### 5.9 **Pollution Prevention and Zero Dis**  **charge Permits**

Through its P2 permit program, EBMUD has dev eloped specific c ontrol measures , including discharge prohibition

and/or b est management practices

, for point source cate go ries that handle identified pollutants of concern. These

permits are generic , requiring no application or fee . The permit program is funded through a San Francisco Bay

Pollution Prevention Fee , currently at $ 5.48 /month, assessed on all nonresidential wastewater service accounts

.

In 201 4

, EBMUD continued to regulate the following permitted commercial categories :

• B oatyards

• C ommercial ph otoprocessors

• D ental facilities

• Drycleaning facilities

• Furniture stripping facilities

• Hospital campuses

• P rinting shops

• R adiator shops

• Vehicle repair facilities, including repair ; autobody ; and fleet maintenance facilities

• V ehicle washing facilities

The P2 permits for boatyards were renewed in 2013

. Renewal of p ermits for all remaining listed categorie s is in

process

. The following table shows a chronology of the District’s P2 and zero discharge permit programs:

Facility Type Permit Requirements Init ial Permit

Implementation Date

Zero Discharge Permits

–

Federal and local Process Discharge P rohibition 1983

, r evised 2008

Radiator Repair Process Discharge P rohibition & BMPs 1989

, revised 2004

Dry Cleaners Process Discharge P rohibition & BMPs 1990 r evised 2004

Photo Processors Silver Removal Pretreatment & BMPs 1990 , r evised 2009

Vehicle R epair / B ody S ho ps

, including gasoline stations;

dealerships and fleet yards Process Discharge P rohibition &

BMPs , car wash water BMPs (auto

body permit shops pe rmitted 1995) 1992

, r evised process

specific BMPs 1999

Printing and a llied Industries Process B MPs 1994

, r enewed 2004

Boatyards Process BMPs 1994

, r enewed 2013

Furniture Refinishing Process Discharge P rohibition & BMPs 1996

, r evised 2 008

Vehicle Wash ing Facilities Process Discharge P rohibition & BMPs 2001

, r evised 2007



### 99Facility Type Permit Requirements Init ial Permit

Implementation Date

Dental Facilities Self

- certif ication report includ ing: 1)

mercury amalgam use; 2) best

management practice s implementation

for amalgam/x

- ray spent fixer control;

and 3) staffs ’ revie w of American

Dental Association's prescribed

mercury BMPs

Process Discharge Prohibition

Pretreatment requirement for mercury

amalgam/spent fixer solution

Reporting requirements 2002

Revised 2003

Hospitals Process BMPs 2007

With the revision of the Wastewater Control Ordinance that took effect on August 22, 2013, and the simplification of

industrial permit fees in the FY14 rates and fees, some of the concerns that delayed renewal of the P2 permits have

been clarified. The District plans to review an d renew the P2 permits in order of permit expiration date

. Two permit

classes, d ry cleaning and p rinting have undergone technological shifts that warrant review. Some drycleaners have

switched to new, “greener” cleaning chemicals, and appropriate controls for these facilities need to be developed.

Many printing facilities are now digital

- only and may no t require P2 permits at all. The photo processing industry

has also undergone significant changes in the past few years . The District plans to review this business class to

determine if permits are still necessary.

In 201 4 , the District continued its review of the new business class of long

- term care facilities for potential P2

permitting.



### 5.9.1 Reduction of Pollutants in Plant Influent

EBMUD’s WWTP influent l evels for h eavy metals and organic solvent s have declined significantly since the

implementation of the District’s P2 program , in addition to its established pretreatment program

. The influent data,

reflecting source reductions from 1988 ( year prior to imp lementation of the P2 program’s initial element

- radiator

shops ) to December 31, 201 4 are presented in Figures 5

- A through 5

- K. T he following t ables compare the plant

influent loadings of metals (between 1974, 1988 and 20 1 4 ) and organics (between 1988 and 20 1 4 ), respectively

showing significant reductions. Since 1973

, when EBMUD began one of the nation's first pretreatment programs,

heavy metals have declined overall by 9 5 % , from 1170 kg/day to 61 .8 kg/day

.

EBMUD Treatment Plant Influent Loading Reduction s

of Selected Metals

(see Figures 5

- A

- H)

Parameter 1974

kg/day 1988

kg/day 2014*

kg/day % Reduced

Since 1988 % Reduced

Since 1974

Cadmium 7 1.1 0.08 93% 99%

Chromium 209 14 1.43 90% 99%

Copper 318 28 16.8 40% 95%

Lead 106 12 2.11 82% 98%

Nickel 35 12 2.25 81% 94%

Zinc 495 110 38.7 65% 92%

Total 1170 183.6 62.3 66% 95%



### 100EBMUD Treatment Plant Influent Concentration Reductions

of Selected Organic Priority Pollutants

(see Figures 5

- I

- K )

Parameter 1988

μg/L 2014

μg/L % Reduced since

1988

Methylene Chloride 23 0.83 96%

Tetrachloroethene 62 0.75 99%

Toluene 31 5.00 84%

*The required monthly influent monitoring is reported in Tables 2

- A, 2

- B, and 2

- C.



### 101

### 102

### 103

### 104

### 105

### 106

### Exhibit 5

- A



## Pollution Prevention and FOG Outreach for Trash

and “Disposable” Consumer Products

### Exhibit 5

- B



## Keep the Bay off Drugs Billboard

### Exhibit 5

- C



## Keep the Bay off Drugs Campaign

Keep the Bay off drugs

The District continued its pharmaceutical campaign in support of a regional pollution prevention effort to

raise awareness of th e harmful effects of improper disposal

.

### Exhibit 5

- D



## Pollution Prevention and FOG Outreach Brochure for

Oakland Residents

### Exhibit 5

- E



## Pollution Prevention and FOG Outreach Refrigerator Magnet for

Customers in Oakland

### Exhibit 5

- F



## Pollution Prevention and FOG Outreach Postcard Mailer for Property

Managers of Multi

- family Dwellings in Oakland

### Exhibit 5

- G



## Pollution Prevention and FOG Outreach at the Emery Bay Village

Homeowners’ Association in Emeryville

### Exhibit 5

- H



## Pollution Prevention and FOG Outreach Article in the Park Street

Business Association Newsletter in Alameda

### Exhibit 5

- I



## Pollution Prevention and FOG Outreach Article in

EBMUD Splashes Newsletter

### Exhibit 5

- J



## Pollution Prevention and FOG Outreach Article in

EBMUD Splashes Newsletter

- continued

### Exhibit 5

- K



## EBMUD Issued Letter through BACWA to RWQCB Regarding

Funding for the Regional Monitoring Program for Water Quality

in San Francisco Bay (RMP)

### Exhibit 5

- L



## EBMUD Issued Letter through BACWA to RWQCB Regarding

Funding for the Regional Monitoring Program for Water Quality

in San Francisco Bay (RMP)

- continued

### Exhibit 5

- M



## P ollution Prevention Article on Keeping Pollutants Out of the Drain

Customer Pipeline p ublication