2014

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 Service 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........................................................... 25

3.1 Pretreatment Program Changes and Highlights................................................................................. 25

3.2 Pretreatment Program Staffing and Budget....................................................................................... 25

3.3 Permit Types...................................................................................................................................... 29

3.4 Resource Recovery Program ............................................................................................................. 30

3.5 Inspection and Sampling Procedures................................................................................................. 32

3.5.1Business Classification Code Inspection............................................................................................. 32

3.5.2In-Depth Inspection............................................................................................................................. 33

3.5.3Inspection - Significant Industrial User and Non-Significant Industrial User .................................... 33

3.5.4Inspection - Zero Discharge ................................................................................................................ 35

3.5.5Inspection - Pollution Prevention........................................................................................................ 36

3.5.6Inspection - Special Discharge............................................................................................................ 37

3.5.7Violation Follow-Up Inspection.......................................................................................................... 37

3.5.8Resource Recovery (R2) Program Random Field Audit Program...................................................... 37

3.6 Enforcement Procedures.................................................................................................................... 38

3.6.1Legal Authority ................................................................................................................................... 38

3.6.2Enforcement Response........................................................................................................................ 38

3.7 Local Limits....................................................................................................................................... 39

4. PRETREATMENT PROGRAM - INDUSTRIAL USER INFORMATION.......................................... 41

4.1 Federal Categories............................................................................................................................. 41

4.2 Baseline Monitoring Report Update.................................................................................................. 41

4.3 Summary of Activity for Permitted Industrial Users......................................................................... 41

4.4 Updated List and Compliance Activities for CIUs, SIUs, and Other Regulated Facilities............... 41

4.5 July-December Semiannual Report................................................................................................... 41

4.5.1Significant Industrial User - Categorical............................................................................................. 42

4.5.2Significant Industrial User - Local...................................................................................................... 42

4.6 Public Participation Summary......................................................................................................... ..43

5. POLLUTION PREVENTION PROGRAM............................................................................................... 77

5.1 Pollution Prevention Program Highlights for 2013........................................................................... 77

5.2 Description of SD-1 Treatment Facilities and Service Area ............................................................. 79

5.3 Current Pollutants of Concern ........................................................................................................... 79

5.4 Source Identification and Reduction Programs................................................................................. 79

5.4.1Mercury............................................................................................................................................... 79

5.4.2Fats, Oil, and Grease (FOG)................................................................................................................ 81

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5.4.3Copper................................................................................................................................................. 85

5.4.4Cyanide ............................................................................................................................................... 89

5.4.5Polychlorindated Biphenyls (PCBs).................................................................................................... 91

5.4.6Pharmaceutical Disposal ..................................................................................................................... 91

5.4.7Pesticides............................................................................................................................................. 92

5.5 Green Chemistry & Producer Responsibility .................................................................................... 92

5.6 Outreach to EBMUD Employees...................................................................................................... 92

5.6.1Employee Events & Activities............................................................................................................ 92

5.6.2Employee Electronic Communications............................................................................................... 93

5.7 Public Outreach Programs................................................................................................................. 93

5.7.1Outreach to Industrial/Commercial Facilities and Government Agencies.......................................... 94

5.7.2Outreach to Non-governmental Organizations (NGOs)...................................................................... 94

5.7.3Outreach to Schools ............................................................................................................................ 94

5.7.4Outreach to Residential Community ................................................................................................... 94

5.8 Criteria used to Measure the Programs’ and Tasks’ Effectiveness ................................................... 99

5.9 Pollution Prevention and Zero Discharge Permits .............................................................................. 99

5.9.1Reduction of Pollutants in Plant Influent .......................................................................................... 100

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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 – Trucked 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

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TABLE OF FIGURES

Page

Figure 2-A – EBMUD Plant Loading 1974, 1988, 2014 – Zinc, Chromium, 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 Influent 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 -

Chromium (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 Pollution Prevention Program – Measure of Effectiveness 1988-2014 -

Toluene (μg/l) in Wastewater Treatment Plant Influent ..................................................................... 106

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EXHIBITS

Exhibit 4-A – Notice of Significant Wastewater Violation .............................................................................. 43

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

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 Multifamily 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 Pollutants Out of the Drain Customer Pipeline 

publication

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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 (BMPs): 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 include 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 sewage 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 streams 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 standard.

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 requirements 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: Determined 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 quarterly as consistent compliance, 

inconsistent compliance, significant non-compliance, or unknown.

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

violation during the last reporting quarter and no unresolved significant 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 representative.

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 California, 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 enacted 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) penalties for violations of the Ordinance, revision effective August 22, 2013.

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 issued 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 discharger having one or 

more violations during a reporting quarter, which did not result in significant non-compliance, and no 

long-term pattern of violations.

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Indirect Discharge: The introduction of pollutants into a publicly owned treatment works from any nondomestic 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 intercepting 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 Disposal 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 Air 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 may 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, facility 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) The 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 extent 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, or adds to existing 

process or production equipment.

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(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, assembly, 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 source 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 Standards.

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 agency 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 such 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 conjunction 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 Prevention (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 eliminate 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 wastewater 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)]

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Reclassified (RC): An IU regulated under a Minimization (federal categorical or local), Estimation or 

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

Recycling: Reuse of materials that would otherwise be considered waste.

Recycled Water: Wastewater that has been treated to reduce 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 Permit: A mandatory permit that regulates the trucked materials arriving at the SD-1 

Wastewater Treatment Plant for treatment.

RWQCB: The San Francisco Bay Regional Water Quality Control Board.

Significant Industrial User (SIU):

1. A user subject to Categorical Pretreatment Standards; 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 standard 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 industrial 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, defined 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 Review 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, fats, oil and grease.

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 

x
determines has caused, alone or in combination with other discharges, interference or pass through 

(including endangering the health 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 discharge.

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, within 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 violation 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 

violation 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 

materials 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. May 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 

exceptional 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 days 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 Suspended 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. 

Wastewater 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 billing 

conditions for unique wastewater strengths and flow as applicable.

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Waste 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

BMPs: 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 Pollutant Discharge Elimination System

POTW: Publicly Owned Treatment Works

RC: Reclassified

RCRA: Resource Conservation and Recovery Act

RI: Reissued

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RMP: 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: Wet Weather Facility

WWTP: Wastewater Treatment Plant

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1. INTRODUCTION

This 2014 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 (EBMUD 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 individual 

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 Main Wastewater Treatment Plant (MWWTP), the interceptors, the 

District’s deep-water outfall, and three wet weather facilities (WWF). The Department also operates the 

District's joint water and wastewater laboratory, and three water recycling facilities. Detailed information

about the District facilities is provided below. 

• The District's wastewater service area is 88 square miles, including 1,700 miles of community owned

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

interceptors 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 includes

approximately 175,000 accounts, of which over 18,000 are commercial, 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 maximum wet

weather capacity including storage is 415 MGD. The 2014 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 WWFs

undergoes screening, chlorination, and dechlorination; and Oakport and Point Isabel WWFs

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

storage so the flow can be discharged back to the interceptor system for treatment at the

MWWTP 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 Wastewater District’s Water Pollution Control Plant

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

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

recycled water.

1 
b) The Richmond Advanced Recycled Expansion (RARE) Water Project treats secondary

effluent from West County’s WPCP to a high level of purity for use in the boilers at the

Chevron Richmond refinery.

This facility currently provides up to 3.34 MGD of recycled water to the refinery. The District

is currently undertaking a feasibility study evaluating the potential to expand recycled water

at North Richmond Water Reclamation Plant and RARE.

c) The East Bayshore Water Recycling Plant is designed to treat 2.5 MGD of the MWWTP’s

secondary effluent. The recycled water is currently used for landscape irrigation, toilet/urinal

flushing 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 pretreatment and pollution prevention (P2) program. The District's 

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

the District's wastewater treatment facilities. This report summarizes the pretreatment and P2 program 

activities implemented by the Environmental Services Division in 2014. 

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

initiated in 2011 to create efficiencies while still meeting regulatory requirements. At the end of 2014, 

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 groundwater, 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. 

The Environmental Services Division performed inspections with sampling to assess compliance by 

permitted industrial users. District staff also conducted P2 and Business 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. 

The Environmental Services Division maintains 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 program. 

1.4 Pretreatment Program Evaluation

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

conducted 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 

2 
to 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, there 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, there were no discharges from industrial users that were identified as causing the MWWTP upsets, 

interference or pass-through resulting in any violations of the District’s NPDES permit limitations. 

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 during 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. The 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 surge 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 corrected in the system.

2.3 Biosolids Storage, Land Application and Disposal Practice

The District produces Class B biosolids with an average of 23% total solids. 

Biosolids are collected in an enclosed air-scrubbed hopper located next to the Dewatering Building at the 

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

200,000 lbs or 150 cubic yards.

In 2014, 100% of the 73,922 wet tons of biosolids produced were beneficially reused with 48% used as a soil 

amendment 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 2014 influent and effluent metals, volatile 

organic compounds and semi-volatile organic compounds, respectively. Reductions in heavy metals 

loadings and selected organics concentrations to the MWWTP are summarized in Figures 2-A, 2-B and 2-C. 

Figure 2-D illustrates influent and effluent metals monitoring results for the past five years. Additional 

information on heavy metals loading and organics concentrations can be found in Chapter 5.

Generally, metals results trended downward in 2014 compared to previous years. Mercury influent monthly 

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

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

4
results 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 the analytical results of 5-day composite biosolids samples collected during 2014.

2.5 Plant Operating Data

Table 2-E summarizes the wastewater treatment plant operating data for 2014.

5
TABLE 2-A

2014 METALS INFLUENT AND EFFLUENT MONITORING

Arsenic Cadmium

Influent Effluent Influent Effluent

Month SM3114B Units SM3114B Units Month 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

October 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 SM3113B 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 ug/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 September 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

6
Cyanide: total Lead

Influent Effluent Influent Effluent

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 0.0024 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

7
Selenium 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.

8
TABLE 2-B

2014 624 INFLUENT AND EFFLUENT 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-TRICHLOROETHANE 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 ND

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-TRICHLOROBENZENE 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-CRESOL 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

BENZO(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

10
EPA 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

HEXACHLOROBUTADIENE 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-CHLORO-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.

11
TABLE 2-D

2014 BIOSOLIDS MONITORING RESULTS

5-DAY COMPOSITE SAMPLES (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

BROMOCHLOROMETHANE 0.14 U 0.14 U

BROMODICHLOROMETHANE 0.14 U 0.14 U

BROMOFORM 0.098 U 0.098 U

12
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.

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-BUTYLBENZENE 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

DIBROMOCHLOROPROPANE 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

13
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.

DIISOPROPYL 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

FLUOROTRICHLOROMETHANE 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 0.12 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-TRICHLOROBENZENE 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

14
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.

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

ANTHRACENE 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 PHENYL 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

15
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.

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

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

HEXACHLOROBUTADIENE 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-METHYLPHENOL 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-NITROSODIMETHYLAMINE 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

16
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.

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

WASTEWATER 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 EFFICIENCY

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

18
0

50

100

150

200

250

300

350

400

450

500

Zinc Chromium Copper Lead

Kg/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 Silver

Kg/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 Toluene

μg/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 (IUs) that handle pollutants of concern. Pollutant control mechanisms include the issuance of 

wastewater discharge permits with general provisions and site-specific requirements. The different permit 

types are detailed below under section 3.3.

3.1 Pretreatment Program Changes and Highlights

During 2014, the District completed 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 effectively. The District is reviewing new permit nomenclature for 

clarification and pretreatment program streamlining. 

In 2014, the District’s pretreatment permit program included 21 Non-Significant Categorical Industrial Users

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

information about these NSCIUs is provided in Chapter 4. 

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

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 discharge contained regulated process wastewater. Although 

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

wastewater is subject to regulation under the pharmaceutical manufacturing guidelines. Furthermore, they 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 annual report. The Boardworks is classified as an NSCIU since they discharge 

≤ 100 gallons per day.

 

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 the 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 Services 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 for 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 wastewater 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

27
The 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) San Francisco

Bay Commercial P2 Fee, charged to all industrial and commercial accounts, $5.48/month in 2014 and 2) San 

Francisco Bay Residential P2 Fee, charged to all residential customers, $0.20/month in 2014. 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 2014, ESD budget and special 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-charges-and-fees

EXPENDITURES DOLLARS ($)

Personnel

$4,791,340

Equipment, Operations & Maintenance, Training & Travel

$252,625

Professional Services 

$114,006

Laboratory Analyses 

$155,037

Total $5,313,008

Industrial Permit Application Fees

Discharge Minimization Permit $2,450 Annual1

Discharge Estimation Permit $920 Annual2

Special Discharge Permit $995 Annual

Wastewater Disposal Treatment Charges

Treatment Depends on Strength (CODF & TSS) and Volume

Monitoring Fees

Labor and Equipment $1,070.00

Resource Recovery Non-Hazardous Materials Program Fees

Permit Application Fee $300.00 (Annual)

Treatment Depends on strength of waste

Other Fees

SF Bay Commercial Pollution Prevention Fee3 $5.48/month

SF Bay Residential Pollution Prevention Fee4 $0.20/month per dwelling unit

1 Annual increase for 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 applies to all residential accounts. Fee will be charged per dwelling unit

up to 5 dwelling units.

TABLE 3-A

ESD Expenditures – Calendar Year 2014

TABLE 3-B

Wastewater System Special Fees

Effective July 1, 2014

28

 
TABLE 3-B 

Wastewater System Special Fees

Effective July 1, 2014

Violation Follow-Up Fees

Stage One $670.00 + laboratory charges for tests performed

Stage Two $1,410.00 + 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. 

Wastewater 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. The permit application requires in-depth information on the facility’s operations, including a 

description of all processes 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 Director, 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. Dischargers 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 Pretreatment Streamlining Rule. NSCIU permits are issued to:

• Categorical 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 

are not used or generated at the facility.

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

previously held a wastewater discharge permit (described above).

29
In 2014, the District updated its annual zero discharge permit certification form to accommodate all NSCIUs. 

The form, now titled Discharge Prevention Compliance Report, 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 includes a review of onsite 

documents/waste manifests that support the facility’s NSCIU status, confirming 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. Facilities may be inspected to ensure compliance with their permit 

requirements. The P2 permit program is funded through the P2 Fee. The District issues P2 permits to the 

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

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

Special Discharge Permit

A special discharge permit 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 site 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 of 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 

MWWTP. Since its inception, the program has established 493 customer accounts; currently 271 accounts are

active, holding 423 active waste disposal agreements. Typical materials hauled to the MWWTP 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; 

groundwater and storm water. 

The program uses available excess capacity at the MWWTP, allowing for a larger customer base over which 

to distribute operating costs. It provides for a cost-effective, economically-sound disposal alternative for 

customers, and increases the MWWTP'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 significant greenhouse gas source. This service 

30
represents 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 multiple 

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, comparison 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 

such 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 with 

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

Resource Recovery – Trucked Materials, Volumes and Descriptions

31
Category 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

High 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 byproducts.

Winery processing 

(high strength) 

waste

High strength winery processing waste water, for example lees. 

Waste contains contaminants consistent with the main WWTP’s 

influent waste stream.

Rendering waste Animal (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

High strength waste consisting of chicken and turkey blood. 

Turkey and chicken lungs waste contains some pathogens in 

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

Beef, sheep, and 

swine processing 

waste

High 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 BCCs 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 facility 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.

32
3. Observe other operating conditions. Observations may be forwarded to other agencies.

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

Wastewater Control Ordinance limits and/or if wastewater 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 generated and 

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

identification of a representative sample location(s), and potential of hazardous materials entering the 

sanitary sewer. Pollution prevention opportunities may be discussed in addition to identifying environmental 

cross-media issues. 

The inspections 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 Inspections - Significant Industrial User and Non-Significant Industrial User

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 noncategorical facilities include compliance history of the discharger, relative consistency of pollutant 

concentrations 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 frequencies.

33
Discharger 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 also 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 issues. 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 status 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 observations 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 and 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 forwarded 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 failure

• operating records are up to date

7. Review 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 deliver 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-Significant Categorical Industrial Users discharging no more than 

100 gallons per day of regulated wastewater and Zero Dischargers are monitored at the same frequency. 

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

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

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

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

statement required in 40 CFR 403.12 (q), and must not have discharged 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 

compare with their stated water uses such as sanitary, non-contact cooling water, and boiler blowdown wastewater.

Inspection

1. Interview the facility contact to determine if there is discharge of regulated process 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 the 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 ensure 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.

35
6. Inspect facility for presence of containers, hoses, or other conveyances which may be used for the 

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 

frequency for each P2 category is being reviewed to focus efforts on types of sites with the most potential 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 Control 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. Conduct 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. Pretreatment 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 posters 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 collect samples as indicated by the 

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

its best management practices. Inspectors determine 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 information 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 analyses 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 Services 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 Inspection is performed after a discharge violation is found during an inspection, a 

self-monitoring event, or a District sampling event. The Violation Follow-Up Inspection focuses on specific 

areas associated with the cause of the violation. In addition, the Violation Follow-Up Inspection verifies the 

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

incremental remedial measures. The account is charged a Violation 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 

conditions. 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 waste, 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 

37
orientations include orientation to plant hazards, rules of conduct, and specific discharge 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 NPDES 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 establishes 

regulations for the control, interception, treatment, and disposal of wastewater. In addition, it provides 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 language and ensure consistent 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-controlordinance-8-22-2013.pdf

3.6.2 Enforcement Response

The District’s established Enforcement Response Plan (ERP) remains in effect. 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 enhancements 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. 

38
Informal Action

• Informal Notice

• Informal Meeting

• Notice of Violation/Follow-Up Fees:

o Reporting/Non-Discharge Violation: Stage One, $670

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 Facility

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

39
a. 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 locations 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 have an adverse or harmful effect on or overload District facilities 

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

in Wastewater Discharge Permits to control the quantity and rate of flow of wastewater 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 governmental agency empowered to regulate the use of radioactive 

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

Regulatory Commission regulations and recommendations for safe disposal and in compliance with 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 Industrial Users

Approximately 56 permits were in effect on December 31, 2014, and include: 

o 8 SIU Categorical

o 13 SIU Non-Categorical

o 14 Non-SIU

o 21 NSCIU

Table 4-B summarizes monitoring and violations for these permitted IUs.

Other permits effective on December 31, 2014, were:

o 12 Groundwater

o 31 Estimation

o 15 Special Discharge

o 1,135 P2 permits for commercial businesses.

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

Types and Waste Streams are presented in Table 3-C. More information about the types of permits issued 

by EBMUD may be found in Section 3.3.

4.4 Updated 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

• Significant Industrial Users – Categorical: Table 4-C

• Significant Industrial Users – Non-Categorical: Table 4-D

• Non-Significant Industrial Users: Table 4-E

• Non-Significant Categorical Industrial Users: Table 4-F

4.5 July-December Semiannual Report

The Semiannual Pretreatment Report for the period of July 2014 through December 2014 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. R2-2011-0009, 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 along with the status of facilities listed in the 

previous semi-annual 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 organized in order 

of categorical classification.

LIST 1

SIGNIFICANT INDUSTRIAL USERS - CATEGORICAL 

COMPLIANCE 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 Street

Emeryville CA, 94608

12/18/2014 SM 0 0.036 mg/L

(4-day Federal 

average 

exceedence)

0.4 mg/L

Compliance History by Quarter1: 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. Therefore, 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 facilities were in compliance during 2014. 

The following facilities had two or more quarters of consistent compliance summarized in the previous semiannual pretreatment report and are no longer included the report. 

NAME

SVC Manufacturing

Takara Sake

42
CEASE 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 publishes annually in the Oakland Tribune a list of 

industrial users which at any time during the reporting year were in Significant Noncompliance with 

applicable pretreatment requirements. Exhibit 4-A includes a copy of the public notice to be submitted for 

publication 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 dischargers listed below are identified as critical industries as established by EBMUD 

Ordinance, Title IV, Section 1a.(2). EBMUD found these dischargers to be in Significant Noncompliance 

(SNC) during calendar year 2014.

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 examine 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 violation.

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

Daily Local Limit 

Maximum

Average 

Consecutive 

4-Day 

Maximum

E-D Coat, Inc.(1) Not 

Applicable(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 Permits 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

Daily Local Limit

Maximum

Average 

Consecutive 

4-Day 

Maximum

Metalco 10/25/19 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 Metals - - -

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 Ind. 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 Permits 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-Decane 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 Permits 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 applications. 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 Permits and Standards for Categorical Industrial Users

Metal Molding and Casting Point Source 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 

Casting 

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 & 

Grease

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 EBMUD IU Total

No. of 

Violations-

(1)

No. of 

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 PHARMACEUTICALS 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 Categorical

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 EBMUD IU Total

No. of 

Violations-

(1)

No. of 

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 SIU 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 3200 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 EBMUD IU Total

No. of 

Violations-

(1)

No. of 

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

* Investigation at ED Coat, Inc. is ongoing. This value represents a total number of investigation samples collected by EBMUD through 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 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.

RECLASSIFIED - An IU regulated under a SIU, Estimation or Pollution Prevention permit which becomes regulated under a different one of these permits.

REISSUED - Existing Pollution Prevention permits which are renewed.

52
TABLE 4C

2014 Monitoring, Enforcement and Status: Significant Industrial Users – Categorical

CATEGORY

Facility

Qtr

(1)

Compl.

Status

(2)

EBMUD

Inspections

SAMPLES ENFORCEMENT

Orders Comments

EBMUD IU No. of

Violations.

No. of

NOVs 

(3)

Viol.

Fees

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 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.

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, Inc.

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 selfmonitoring 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
TABLE 4C

2014 Monitoring, Enforcement and Status: Significant Industrial Users – Categorical

CATEGORY

Facility

Qtr

(1)

Compl.

Status

(2)

EBMUD

Inspections

SAMPLES ENFORCEMENT

Orders Comments

EBMUD IU No. of

Violations.

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 wastewater 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 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: 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 Lucasey 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 Compliance 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 Scientific 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 Report, an annual selfmonitoring/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
TABLE 4C

2014 Monitoring, Enforcement and Status: Significant Industrial Users – Categorical

CATEGORY

Facility

Qtr

(1)

Compl.

Status

(2)

EBMUD

Inspections

SAMPLES ENFORCEMENT

Orders Comments

EBMUD IU No. of

Violations.

No. of

NOVs 

(3)

Viol.

Fees

40 CFR 437 - Centralized Waste Treatment

NRC Environmental Services, 

Inc.

Wharf 2 Ferry Point

Alameda, 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

Oakland, 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 

3 C 2 4 0 0 0 0 EBMUD inspections per year. 

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
TABLE 4C

2014 Monitoring, Enforcement and Status: Significant Industrial Users – Categorical

CATEGORY

Facility

Qtr

(1)

Compl.

Status

(2)

EBMUD

Inspections

SAMPLES ENFORCEMENT

Orders Comments

EBM

UD IU No. ofViols.

No. of

NOVs 

(3)

Viol.

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 Casting 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
TABLE 4C

2014 Monitoring, Enforcement and Status: Significant Industrial Users – Categorical

(1) Calendar Quarter (4th Qtr is Oct -

Dec)

(2) Compliance Status Key: C - Consistent Compliance

IC - Inconsistent Compliance

SNC - Significant NonCompliance

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 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 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.

RI (Reissued) - Existing Pollution Prevention permits which are renewed.

57
TABLE 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 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 

manufacturer and bottler. The permit includes 

best management practices in lieu of selfmonitoring 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 discharge 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). According 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
TABLE 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 Sake

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: 8/20/2019 

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 determined 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
TABLE 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 consistent 

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 5th 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
TABLE 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 Seminary 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
TABLE 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
TABLE 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 - Inconsistent 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 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 regulated under a different 

one of these permits.

RI (Reissued) - Existing Pollution Prevention permits which are renewed.

63
TABLE 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

California 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 

Totals: 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
TABLE 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

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 that 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 the 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 that 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 Gelatin Mfg.: 1 0 1 0 0 $0 

65
TABLE 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 estimation 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 Recovery 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

Expires: 

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
TABLE 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

Schnitzer 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 to 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 implementation 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 standards. 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
TABLE 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 Collection 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
TABLE 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 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 such 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 regulated under a 

different one of these permits.

RI (Reissued) - Existing Pollution Prevention permits which are renewed.

69
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant 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 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 

Melrose Metal Finishing, Inc.

10222 Pearmain Street

Oakland, CA 94603

Permit 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 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 Electroplating: 0 0 0 0 0 $0 

70
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant 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 Finishing

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 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 

71
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant 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 California

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 California 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 

Lawrence Berkeley National Laboratory, Bldg. 77

1 Cyclotron Road

Berkeley, CA 94720

Permit No. 50238911

Expires: 4/7/2017

4 C 0 0 0 0 0 0 In 2014, Lawrence Berkeley National Laboratory, 

Bldg. 77certified 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. 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 

Metro Lighting

2240 San Pablo Ave

Berkeley, CA 94702

Permit No. 35611516

Expires: 7/1/2015

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
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant 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

Expires: 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 standards. 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

Expires: 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
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant 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: 12/31/2014

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 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 

Mussi Artworks Foundry, LLC

729 Heinz Ave #10

Berkeley, 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 

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 

74
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant 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

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 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 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. 07314653

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
TABLE 4F

Monitoring, Enforcement and Status: Non-Significant Categorical 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 

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 such 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 regulated 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, 2014 through December 

31, 2014 reporting period. The report was prepared in accordance with the District’s NPDES Permit No. CA0037702 

adopted on March 10, 2010, under Order No. R2-2010-0060.

5.1 Pollution Prevention Program Highlights for 2014

EBMUD continued P2 activities for its commercial and residential customers. Highlights for 2014 are noted in the 

table below.

Highlights

Copper

• A section on copper-free guidelines for pools was developed for the Residential P2

page of the District’s website at https://www.ebmud.com/water-andwastewater/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 identified as caused or contributed to by food service establishments 

(FSEs). Hotspot investigations have resulted in issuing numerous GCD installation 

and maintenance requirement letters. GCD installations and improved grease 

interceptor pump out and maintenance 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 residential 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 facility 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, including 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-pollutant 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

77
Highlights

cause chronic problem, including blockages, SSO, expensive repair and 

maintenance issues in the sanitary sewer systems. See Exhibit 5-A.

Delivered 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 37% increase over last year’s residential outreach efforts.

• Total number of customer inquiries for free FOG scrapers via the EBMUD on-line 

store and the EBMUD phone hotline was 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 that alerts staff of 

overloaded gravity grease interceptors (GIs) which require immediate follow-up 

with FSEs. This system facilitates routine maintenance of GIs and on-going 

compliance of FSEs. 

• Utilized the hotspot density analysis map created for the City of Oakland in ongoing effort to streamline the decision-making process for residential FOG 

outreach. 

• Continued maintenance and updates 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/pollutionprevention/residential-cooking-oil-and-grease-drop-program with an added link on 

resources page to www.baywise.org website for 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 collected 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 for 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 

Constituents 

Basis for Determination 

Mercury Permit No. CA0037702, Order No. R2-2007-0077 – TMDL

FOG Potential to cause sanitary sewer overflows; provide support to regional 

satellite agencies

Copper Permit 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 details EBMUD’s approach to identifying sources for pollutants of concern, in addition to developing

effective control measures. 

5.4.1 Mercury

Commonly identified sources of mercury include dental facilities, educational institutions, electrical/electronic 

sources, hospitals/medical facilities, veterinary clinics, biological and pharmaceutical laboratories, and residential 

dischargers. 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 2014, EBMUD continued its focus on dental facilities and hospitals. The following are specific tasks 

implemented in 2014 and/or scheduled for 2015. 

 Mercury Source Reduction in Dental Facilities

• Dental Facilities Pollution Prevention Permit 

1. Continued to regulate amalgam waste through the permit terms and conditions, including the annual 

report requirement documenting the handling of amalgam waste for the 12-month reporting period. 

2. Continued to identify new facilities and maintain the Dental Facilities Permit database.

3. Continued to determine facilities’ compliance with the existing permit 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 Bay Area Pollution Prevention Group 

(BAPPG) and agencies developing/implementing new programs.

5. In 2015, plan to reissue permit with new requirements including a one-time cleaning/replacement of 

p-traps impacted with amalgam waste. A self-certification report will be required documenting the p79
traps cleaning and the appropriate handling of the generated waste. The permit will continue to 

require the installation of an amalgam separator (new facilities) and ongoing maintenance, in addition 

to the annual self-certification report, documenting/reporting the handling of amalgam waste and 

spent fixer.

 Mercury Source Reduction in Educational Institutions

The District’s Mercury Reduction Program for Educational Institutions (Program) was developed through a 

joint District and University 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. The 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 District implemented a service area-wide program from 2005 through May 2010, partnering with two 

colleges and six schools/school districts within SD-1 wastewater service area. Over 500 lbs of mercury 

waste, including laboratory thermometers, small measuring devices, 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 Program 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 2014. The District will continue to accept mercury thermometers 

if requested, but is no longer conducting exchange events given the reduced need in the community.

 Mercury Source Reduction at EBMUD 

EBMUD has an ongoing mercury-containing device recycling program for its facilities. In 2014, a total of 

18,836 pounds of universal waste was recycled, including 3,045 pounds of fluorescent lamps. The following

table details the waste type and quantities recycled:

Fluorescent 

Lamps

HID 

Lamps

Pb Acid 

Batteries

Alkaline

Batteries E-Waste

NonPCB 

Ballast

Lithium Ion 

Batteries

All 

Recycled 

Sources

Total lbs 3,045 463 7,671 2,963 4,157 385 152 18,836

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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 

participated in EBMUD’s Mercury Reduction 

Program.

• Number 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.”

• Accept mercury thermometers on an as-needed

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 Program development templates and permit requirements for mercury source reduction in dental 

facilities

o Template and related information for EBMUD’s Mercury Reduction Program for Educational 

Institutions

5.4.2 Fats, Oil, and Grease (FOG)

The Regional FOG Control Program includes residential and commercial components to address FOG-related 

sanitary sewer overflows (SSOs) and blockages (hotspots) in the sanitary sewer collection systems. In response to 

FOG-related SSOs and blockages, the program implements field investigations. This may include FSE inspections, 

camera investigations, and/or gravity grease 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 

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are designed 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 information; and 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 years, EBMUD has conducted 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 FOG Source Reduction Tasks and Timeline

In 2014, EBMUD conducted the tasks summarized below. 

 Commercial FOG Program

• Continued 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 contributed 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’ requirements and provide 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 document 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 collection system agencies in 

EBMUD service area to document all of the efforts and progress over the course of the year, servicearea-wide. 

• Continued to maintain a FOG control database, integrate FOG database with GIS capabilities, and add 

new functions to enhance the user experience. Completed the 2014 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 and 

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 

documents 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/ourwater/wastewater-treatment/fats-oils-and-grease

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 Residential FOG Program

• Residential used cooking oil collection program (ongoing)

o Continued availability of residential FOG drop-off at EBMUD’s MWWTP. 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 collected cooking oil into a biofuel.

o Continued support of two residential cooking oil drop-off sites within 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 wastewater 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 MWWTP, 

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 15 local independent retailers of 

turkey fryers and oil jugs.

 Distributed 706 FOG scrapers via the EBMUD on-line store 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 hanger 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 

residential web page: www.ebmud.com/cleanbay

• Developed 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. In 2014, delivered 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. 

• Updated and maintained 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 community events, including Solano 

Stroll, the City of Oakland Earth Expo, Alameda Earth Day events, 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 meetings with collection 

system agency staff for program development.

• Customized (per individual agency) approved 

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.

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Residential/

Commercial

Effectiveness Measure for FOG Source 

Control & Reduction

Progress in FOG Source Control and Reduction

• Expand outreach efforts by 

including FOG-oriented outreach in 

newsletters and other outreach 

vehicles of a wide range of 

stakeholders.

• Outreach vehicles include:

- Community/City newsletters/websites

- 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 FOGrelated issues. 

• 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 GCDs requirement letters were 

delivered in 2014 requiring FSEs to either install 

approved GCDs or maintain already existing 

grease traps. Communities also require GCDs

for new or remodeled FSEs.

Residential • Number of local stores conducting 

FOG holiday outreach.

• Number of door hangers providing 

residential “hotspot” outreach to 

targeted areas.

• Number of FOG scrapers requested 

via EBMUD on-line store and 

phone hotline.

• 15 local stores participated. This was an 

increase compared to 2013, in which 13 local 

stores 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 2013) 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 gallons of residential cooking oil 

collected in residential collection bins was 

diverted from the collection system. 

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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 FOG 

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 database to increase program effectiveness. Developed and 

implemented an automatic notification system to flag gravity GIs that were found to be overloaded. An 

automatic notification facilitates 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 sanitary 

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.

• Developed 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 residents 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 Exhibits 5-H, 5-I, and 5-J. 

5.4.3 Copper

Copper is found in tap water 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 issues 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 implementation of permitspecific BMPs for facilities in the vehicle repair, printing, radiator, and boatyard business types.

Copper loading to the EBMUD MWWTP initially decreased with the issuance of the permit types listed above and 

has remained approximately the same in the years after, as shown in Figure 5-C. The total copper loading to 

EBMUD’s WWTP was 16.678 kg/day in 2014. EBMUD has initiated a Copper Action Plan, described below, to 

address overall copper contributions and control.

Element Description 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

The 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 Description 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 

purveyors 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 

wastewater 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 increasing, 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 for 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 January 17, 

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Element Description Deadline Status

which the above will be accomplished 

and describe the studies to be 

performed with an implementation 

schedule. To satisfy this requirement, 

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

Inventory 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, Oakland 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 Embarcadero, 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, Berkeley 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 Platers, 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, Berkeley 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, Berkeley 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 NRC 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 Laundry

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 types 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 fountains 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 existing facilities and issue new permits to new facilities.

• Conduct inspections. 

• Conduct outreach using brochures developed by EBMUD, BAPPG, DTSC, Green Business Program 

and other agencies while conducting facility inspections.

In addition to these activities, the following business-specific activities were undertaken.

 Copper Source Reduction in Boatyards

• Developed BMPs for boatyards (2011). 

• As a member of a Technical Advisory Committee that includes the Department of Boating & 

Waterways; California Coastal Commission; Department of Pesticide Regulations; San Francisco 

Department of Public Health; Institute for Research and Technical Assistance; industry representatives;

and Baykeeper, EBMUD participated in development of the Boatyards Pollution Prevention 

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 Copper 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 maintain P2 permits to 

dischargers with potential to discharge 

copper.

• Pretreatment permits include terms for P2 practices; 20

categorical IUs are zero dischargers

• P2 permit holders in compliance and implementing 

BMP requirements include:

o vehicle repair shops: 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 Cyanide

The District has taken/is taking the following measures in response to the regional Cyanide Action Plan, required 

through Permit No.CA0037702. EBMUD does not have any cyanide contributors because all potential sources either 

do not use cyanide or are zero dischargers.

Element Description Deadline Status

(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 cyanide 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, 2010 -

2011 Annual P2 

Report.

i. Inspect 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 control program annually.

Not required

(no contributors of 

cyanide)

89
Element Description Deadline Status

iii. Develop and distribute educational 

materials to contributing sources and 

potential contributing sources regarding 

the need to prevent cyanide discharges.

Not required

(no contributors of 

cyanide)

iv. Prepare an emergency monitoring and 

response plan to be implemented if a 

significant cyanide discharge occurs.

Not required

(no contributors of 

cyanide, however, one 

had been drafted (see 

section 5.4.4.1))

(3) 

Implement 

Additional 

Measures

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 ambient 

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.

Annually 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 Electroplating 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

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Discharger 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 

California 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 cyanide 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 cyanide 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 included in the District’s Significant Cyanide Discharge Response Plan.

A. EBMUD defines a significant cyanide discharge as influent 24 ug/L, based on the highest concentration at 

the main WWTP from 2010-2014. EBMUD has established electronic outlier notifications for all analyses 

and associated parameter discharge limits/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 through 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 potential contributors.

C. If the cyanide source is identified, enforcement action may be taken against the facility.

D. An incident summary report outlining the actions taken will be included in the District’s subsequent Annual 

Pretreatment and P2 Report. 

5.4.5 Polychlorinated 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 sponsors nine pharmaceutical collection sites within our wastewater service area. In 2014, 

we participated in two public pharmaceutical collection events. 

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• The Pharmaceutical Take-back Program has collected over 15,900 pounds of expired/unwanted 

pharmaceuticals since the program’s inception in 2009. In 2014, EBMUD collected over 5,100

pounds of unwanted/expired medication. 

• EBMUD continued to support the Product Stewardship Institute in their efforts to move 

Congressional legislation forward to reduce barriers for establishing pharmaceutical collection 

programs.

• EBMUD continued to support the Alameda County Safe Medicine Disposal Ordinance through 

membership in the Alameda County MEDS Coalition.

• EBMUD continued the Keep the Bay off Drugs campaign at 132 billboard and bus shelter locations 

throughout the wastewater service area. See Exhibits 5-B and 5-C.

• EBMUD developed 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 Endangered Species Act 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 various outreach activities including working with pesticide 

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 pest control 

companies for its facilities and uses only non-restricted pesticides in its watershed.

5.5 Green Chemistry & Producer Responsibility

EBMUD continued to participate in initiatives at the state and national levels regarding green chemistry and producer 

responsibility. As noted in the previous section, EBMUD staff has continued to collaborate with the Product 

Stewardship Institute on pharmaceutical disposal 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 15th Annual Earth Day Event was held on 

April 23, 2014. This well-attended event included exhibitors from 8 District workgroups and 12 local 

agencies, environmental organizations and green vendors with the purpose of educating employees 

and visitors about sustainable practices and assisting them in expanding 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.

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• 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 reduce greenhouse gas emissions.

• Greenhouse Gas Reductions - The District continues to maintain a fleet of hybrid vehicles and 

implement energy efficiency programs such as biogas use to power the MWWTP and installation of 

solar panels and natural gas microturbines at EBMUD’s Administration Building. 

• During 2014, the District’s Sustainability and Recycling Committee 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 Up Event, which is a bi-annual event, took place during the week of August 25 -

29. The District collected 1,728 pounds of electronic and universal waste to be recycled. The next 

District-wide clean-up event will take place in 2016. 

• 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 began 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 

consumption, 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:

• includes information on Household Hazardous Waste Facilities; links to the residential P2 webpage 

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;

• encourages use of the public EBMUD website for industrial, commercial, and residential 

pretreatment and P2 information; and 

• reports on the District’s sustainable efforts to minimize waste, conserve energy/natural resources,

promote long-term economic viability and support safety/well-being for employees, communities, 

and customers.

The Sustainability & Recycling Committee increased its focus on employee communication by publishing 19

articles on sustainability in Splashes, the District’s internal newsletter, which reaches more than 2000 

employees and retirees. Articles included:

• District facility energy conservation efforts

• Ongoing information regarding the composting and recycling programs

• Bike to Work activities

• 2014 Earth Day Fair and activities

• EBMUD’s food waste to energy program

• Reducing fire fuel

5.7 Public Outreach Programs

The District’s outreach efforts to industrial/commercial facilities, government agencies, non-governmental 

organizations, schools, and residential communities are detailed below and summarized in the following tables. 

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5.7.1 Outreach to Industrial/Commercial Facilities and Government Agencies

EBMUD provides relevant outreach material to its permitted industrial and commercial facilities. In addition, the 

District provides P2 information to other business categories to educate on specific pollutants of concern. Questions 

from non-permitted facilities regarding the handling of various wastes are frequently received through the 

Environmental Services Division Hotline (details are provided in Section 5.7.4).

EBMUD provides interagency coordination of pretreatment and P2 activities, including:

 Interagency referrals (i.e. the California Department of Toxic Substances Control; stormwater agencies) 

regarding pretreatment or P2 issues at facilities within EBMUD’s wastewater service area 

 Active participation in the California Water Environment Association (CWEA) Pretreatment, P2, and 

Stormwater Committees to focus on pretreatment and P2 education and training

 Active participation in the BAPPG on FOG, pharmaceuticals, pesticides, and other emerging contaminants 

 Assistance 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 activities: 

 Continued partnership with Baykeeper to address residential FOG

 Collaborated with the Product Stewardship Institute on reducing federal barriers to pharmaceutical disposal

 Engaged various NGOs to participate in annual Employee Earth Day event

5.7.3 Outreach to Schools

EBMUD provides teachers with P2 curricula upon request. In 2014, EBMUD staff presented P2 topics, including 

FOG and “disposable” wipes/trash to 2nd graders from a number of schools in Berkeley and Oakland. 

5.7.4 Outreach to Residential Community

As previously noted, EBMUD conducted several residential FOG and pharmaceutical outreach events in 2014. The 

District provides ongoing outreach to residents through its website and hotline number. The hotline number is 

referenced on the website and included 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 materials 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 slogans planned for more than 100 billboards and bus shelters as well as the EBMUD 

Customer Pipeline newsletter articles.

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COMMUNITY EVENTS AND FESTIVALS IN 2014

Events Audience Time of 

Year

Benefit Comments

EBMUD Earth 

Day

EBMUD 

Employees

April Distributed FOG scrapers and Bayfriendly 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 Disposal

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

YearroundReduction of pharmaceutical 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

Yearround

P2 inspections Business 

Operators

YearroundPromote understanding of P2 permit 

conditions and BMPs

Inspectors provide outreach 

materials (some multi-lingual) and 

discuss BMPs with facility 

contacts.

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P2 BROCHURES AND MATERIALS PRODUCED AND/OR DISTRIBUTED BY EBMUD

Material 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 permit 

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 on 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 multipollutant information and proper 

disposal options for household and 

personal hygiene products that 

should never be flushed. 

Distributed during 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 grease 

“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 major 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 Food 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.

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P2 BROCHURES AND MATERIALS PRODUCED AND/OR DISTRIBUTED BY EBMUD

Material Audience Message Comments

FOG Brochure Food Service 

Establishments

“Controlling FOG in Food 

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 specific 

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 keeping 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, Spas 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 disposal 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 toxics 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

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OTHER OUTREACH TOOLS AND RESOURCES

Activity Audience Message Comments

Environmental 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 the 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 cause 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.baywise.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 Baywise.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 General 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 other 

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 

businesses. Has positive 

relationship w/ businesses.

CWEA P3S Committee Pretreatment, P2 

and Stormwater 

Staff

Coordination with other agencies Includes training conference and 

technical meetings.

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5.8 Criteria used to Measure the Programs’ and Tasks’ Effectiveness 

EBMUD uses the following criteria to measure the effectiveness of its established P2 programs:

• Changes in pollutant concentration levels in the District’s MWWTP influent

• Number of people who visit EBMUD’s P2 webpages

• Number of gallons of residential cooking 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 Discharge Permits 

Through its P2 permit program, EBMUD has developed specific control measures, including discharge prohibition 

and/or best management practices, for point source categories 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 2014, EBMUD continued to regulate the following permitted commercial categories:

• Boatyards

• Commercial photoprocessors

• Dental facilities

• Drycleaning facilities

• Furniture stripping facilities

• Hospital campuses

• Printing shops

• Radiator shops

• Vehicle repair facilities, including repair; autobody; and fleet maintenance facilities

• Vehicle washing facilities 

The P2 permits for boatyards were renewed in 2013. Renewal of permits for all remaining listed categories is in 

process. The following table shows a chronology of the District’s P2 and zero discharge permit programs: 

Facility Type Permit Requirements Initial Permit 

Implementation Date

Zero Discharge Permits –

Federal and local 

Process Discharge Prohibition 1983, revised 2008

Radiator Repair Process Discharge Prohibition & BMPs 1989, revised 2004

Dry Cleaners Process Discharge Prohibition & BMPs 1990 revised 2004

Photo Processors Silver Removal Pretreatment & BMPs 1990, revised 2009

Vehicle Repair/Body Shops, 

including gasoline stations; 

dealerships and fleet yards 

Process Discharge Prohibition & 

BMPs, car wash water BMPs (auto 

body permit shops permitted 1995)

1992, revised process 

specific BMPs 1999 

Printing and allied Industries Process BMPs 1994, renewed 2004

Boatyards Process BMPs 1994, renewed 2013

Furniture Refinishing Process Discharge Prohibition & BMPs 1996, revised 2008

Vehicle Washing Facilities Process Discharge Prohibition & BMPs 2001, revised 2007

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Facility Type Permit Requirements Initial Permit 

Implementation Date

Dental Facilities Self-certification report including: 1) 

mercury amalgam use; 2) best 

management practices implementation 

for amalgam/x-ray spent fixer control; 

and 3) staffs’ review 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 and renew the P2 permits in order of permit expiration date. Two permit 

classes, dry cleaning and printing 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 not 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 2014, 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 levels for heavy metals and organic solvents 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 implementation of the P2 program’s initial element - radiator 

shops) to December 31, 2014 are presented in Figures 5-A through 5-K. The following tables compare the plant 

influent loadings of metals (between 1974, 1988 and 2014) and organics (between 1988 and 2014), respectively 

showing significant reductions. Since 1973, when EBMUD began one of the nation's first pretreatment programs, 

heavy metals have declined overall by 95%, from 1170 kg/day to 61.8 kg/day.

EBMUD Treatment Plant Influent Loading Reductions

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%

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EBMUD 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.

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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 the 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

Pollution Prevention Article on Keeping Pollutants Out of the Drain

Customer Pipeline publication