Fairfield
- Suisun Sewer District 2003 NPDES Permit Renewal 

### Infeasibility Analyses June 17 , 2003 **Introduction** These infeasibility

analy ses and resulting requests for compliance schedule and interim limits are submitted to the Regional Water Quality Contr ol Board (RWQCB) by Fairfield
- Suisun Sewer District to demonstrate the District’s inability to comply

with the proposed water
- quality based effluent limits for copper, mercury , cy anide, dichorobromomethane, bis(2
- ethylhexy l) phthalate, 4,4’
- DDE, and dieldr in. **Background** The Policy

for I mplementation of Toxics Standards for Inland Surface Waters, Enclosed Bay s and Estuaries of California (known as the State Implementation Policy (SI P), March, 2000) establishes statewide policy for NPDES permitting. The SI P provides for the situation where an existing NPDES discharger cannot immediately comply with an effluent limitation derived from a California Toxics Rule (CTR) or Basin Plan criterion. The SI P allows for the adoption of interim effluent limits and a s chedule to come into compliance with the final limit in such cases. To qualify

for interim limits and a compliance schedule, the SI P requires that an existing discharger demonstrate that it is infeasible to achieve immediate compliance with the CTR
- or Ba sin Plan
- based limit. The term “infeasible” is defined in the SI P as “not capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors.” Th e SI P requires that the following information be submitted to the Regional Board to support a finding of infeasibility : (a) documentation that diligent efforts have been made to quantify pollutant levels in the discharge and sources of the pollutant in the was te stream, including the results of those efforts; (b) documentation of source control and/or pollution minimization efforts currently under way or completed; (c) a proposed schedule for additional or future source control measures, pollutant minimization or waste treatment; and (d) a demonstration that the proposed schedule is as short as practicable.2

**Pollutants to be Evaluated** The pollutants for which interim limits are needed for the District are as follows:

 copper  mercury  cy anide  dichlorobromomethane  bis(2
- e thy lhexy l) phthalate  4,4’
- DDE  Dieldrin **Effluent Limit Attainability** The proposed final and interim effluent limits contained in the draft tentative order for copper, mercury , cy anide, dichlorobromomethane, bis (2 ethylhexy l)phthalate , 4,4’
- DDE, and dieldrin are compared to the maximum observed effluent concentrations for these constituents in Table 1.

**Table 1. Proposed Effluent Limits for Fairfield -**  **Suisun Sewer District**

**Pollutant Water Quality Based**  **Effluent Limits Performance**  ****

**Based Interim Effluent Li**  **mits Fairfield**  ****

**Suisun Effluent**  **Quality AMEL**  1 **MDEL** 2 **Daily Max.**  **Monthly**

**Avg. MEC**  **3** Copper 4.7 7.5 12 .3 10 Mercury 0.021 0.04 0 0.023 0.021 Cy anide 0.4 1.0 32 28 Dichlorobromomethane 46 88 75 55 Bis(2
- ethylhexy l) phthalate 5.9 11.8 13 13 4,4’
- DDE 0.00059 0.00118 0.05 <0.001 Dieldrin 0.00014 0.00028 0.01 <0.002 All values in μg/L. 1 AMEL : average monthly effluent limit 2 MDEL : maximum daily

effluent limit 3 MEC: maximum effluent concentration The final effluent limits shown above are calculated u sing procedures described in Section 1.4 of the SI P. Background values are based on Regional Monitoring Program (RMP) data collected at the Sacramento River Station. Dilution was taken as zero and the receiving water was classified as estuarine (i.e., lo west of freshwater and saltwater criteria is used for effluent limit calculation). Hardness, wher e applicable, was assumed to be 268 mg/L. Other variables in the effluent limit calculation included coefficients of variation for different pollutants in di fferent effluents.3

Maximum observed effluent concentrations are based on recent plant effluent quality data (2000
- 2002). As shown in the table above, the District will not be able to immediately comply with proposed effluent limits for copper, mercury , c yanide, dichlorobromomethane, Bis(2
- ethylhexy l)phthalate, 4,4’
- DDE, and dieldrin. The feasibility analy ses for these constituents are discussed below. **Source Control and Pollution Prevention Efforts** Inaddition to its pretreatment program which regulate s 11 industries and 3 groundwater remediation sites, the District has an active pollution prevention program that has been in place since 1992. Currently , the District considers mercury , organophosphate pesticides, perchloroethylene, copper, nickel, lead and zinc to be pollutants of concern. Mercury has the highest priority

(A) while pesticides and perchloroethylene are assigned a B priority and the metals are priority

C. The District has implemented a variety of activities targeting these pollutants over the y ears. Some of these activities are highlighted in Table 2.

**Table 2. Fairfield -**  **Suisun Pollution Prevention Program Activities Pollutant of Concern**  **Source Control Activities** Mercury Thermometer exchanges, Dental outreach Organophosphate pesticides Restaurant I PM inspections, school outreach, theatre slides, public events, PCO workshops Perchloroethylene Dry cleaner inspections Copper, nickel, lead, zinc In spections/ BMPs for vehicles service facilities, metal fabricators, and industry ; surface c leaner workshops Several of the activities listed above have been conducted in cooperation with other local agencies in Vacaville, Vallejo, Fairfield and Suisun City . The District is also an active participant and supporter of several regional groups an d programs, including:

 Bay Area Pollution Prevention Group (BAPPG)  Bay Area Clean Water Agencies (BACWA)  Bay Area Stormwater Management Agencies Association (BASMAA)  North Bay

Source Control Group  Napa/ Solano Regional Environmental Public Education Group  Solano County

Environmental Management Local Task Force  Napa/Solano Air Resource Team Additional information on pollution prevention activities targeting each constituent requiring interim effluent limits is discussed below.4

**Copper** The maximum observ ed effluent concentration for copper is 10 μg/L (measured in June 2000) which would exceed a final MDEL of 7.5 . The maximum average monthly copper value of 8.5 (measured January

2001) exceeds the proposed final AMEL of 4.7 . I n addition, 3 of 78 samples taken between January

2000 and December 2002 have copper concentrations that would exceed 7.5 (the proposed final MDEL ) and 14 of 36 calculated monthly average values would exceed 4.7 (the proposed final AMEL ). The District will not be able to immediately comply with the proposed final limits
. The District has identified copper as a priority C pollutant of concern and has conducted pollution prevention targeting copper sources including corrosion of copper plumbing, root control products, vehicle service facilities, mobile surface cleaners, and metal fabricators. Pollution prevention activities have contributed to a 34% reduction in copper influent levels between 1992 (59 μg/L) and 2000 (39 μg/L). The District has conducted source control for most of the common copper sources so it is not clear how much more reduction may be achieved. The District will review its current copper pollution prevention activities and modify as needed. **Mercury** The maximum observed effluent concentration for mercury is 0.021 μg/L (measured in October 2002) which is equal to the proposed final AMEL of 0.021 μg/L . The maximum average monthly mercury value of 0.015 μg/L

(measured in October 2002) does not exceed the final AMELof 0.021. The District will have difficulty consiste ntly

complying with the proposed effluent limits. Mercury is a 303(d)
- listed parameter and is the subject of a TMDL currently nearing completion. Final effluent limits for this pollutant will be derived from the wasteload allocation established under the TMDL . The final effluent limit listed above for this pollutant is projected to change based on the results of the TMDL and wasteload allocation. Available information indicates that mercury is a legacy

pollutant in San Francisco Bay resulting from past a ctivities and that ongoing loadings from POTWs are not a significant source of this pollutant. As a result, costly measures for either advanced treatment or zero discharge to control mercury loading from POTWs are not expected to be required. Given that POTWs are not a significant source of mercury in the Bay , in addition to the District’s existing high quality

effluent, residential service area, and favorable discharge location, it is not immediately

evident the extent to which additional pollution preve ntion efforts would be effective or have any

detectable beneficial impact on the receiving water. Certainly , the highest value measured by

the District is below the water quality objective. Reasonable potential was only triggered by

background ambient da ta. However, the District has a identified mercury as a pollutant of concern and has conducted pollution prevention activities for mercury sources including thermometer exchange programs in cooperation with other local agencies, and outreach to dentists i n the District’s service area. In addition, the District conducted a study of the impact of its effluent on methyl mercury levels in Suisun Marsh. The District will continue its efforts targeting mercury sources. Specifically , the5

District has survey ed l ocal dentists regarding their amalgam waste management practices and will develop future outreach based on the results of the survey
. **Cyanide** The maximum observed effluent concentration for cy anide is 28 μg/L(measured in June 2001) whi ch would exceed a f

inal MDELof 1. 0 μg/L
. The maximum average monthly cy anide value of 17 (measured June 2001) exceeds the proposed final AMEL of 0.4 μg/L
. . I n addition, 3 2 of 74 samples taken between January 2000 and December 2002 have cy anide concentrations that would e xceed 1. 0 (the proposed final MDEL ) , one sample has a cy anide concentration of 1 μg/L, and the remaining 41 samples have cy anide concentrations below the detection limit of 3 μg/L
. All the calculated monthly average values would exceed 0.4 μg/L (the propo sed final AMEL ). The District will not be able to immediately comply with the proposed final limits and will have difficulty consistently

complying with the proposed interim limits. Cy anide has been detected occasionally (i.e., 6 of 30 samples from January 2000

– December 2002) but not consistently in the District’s influent. Ty pically , cy anide is not present in wastewater influent but is generated in the treatment plant disinfection process. For example, based on a review of the literature 1 (including a study being conducted by

water Environment Research Foundation (WERF)), effluent cy anide levels may be due to chlorination processes or may be the result of analy

tical interferences. The District has not previously identified cy anide as a pollutant of concern and, therefore, has not conducted source investigations for this constituent. In addition, as noted above, it is unlikely that these investigations would be fruitful based on the influent data. A special study is being conducted under a region
- wid e effort to develop a site
- specific objective for cy anide which is expected to more closely

represent actual water quality conditions than current water quality objectives. The District is participating in this study . I n addition, in accordance with the requirements of its NPDES permit, the District conducted a Cy anide Reduction Study focusing on determining if cy anide was being generated in the treatment process. The study determined that it was likely

that cy anide levels in the effluent were an artifac t of the chlorination/dechlorination process. This study was submitted to the Regional Board in February 2000. **Dichlorobromomethane** The maximum observed effluent concentration for dichlorobromomethane is 55 μg/L(measured in September 2002) which would exceed the proposed final AMEL of 46 μg/L
. . Of the 6 samples taken between January 2000 and December 2002, two have dichlorobromomethane concentrations that would exceed 46 μg/L (the proposed final AMEL ). The District will not be able to immediately

comp ly with the proposed final limits
. Dichlorobromomethane is generated as a by product of chlorination of water and wastewater and does not ty

pically have influent sources. The District has not previously identified dichlorobromomethane as a pollutant of co ncern and, therefore, has not conducted pollution prevention activities for this constituent. Influent levels of dichlorobromomethane average less than 1 μg/Land have not exceeded 2.1 μg/L . Therefore, it is unlikely that there are significant6

sources o f dichlorobromomethane in the influent, making source investigations and source control activities unlikely to be fruitful. With only six influent and effluent samples in 3 y ears, there is not enough information to completely assess the District’s ability to comply with the proposed interim or final limits. Should reductions be necessary , the District will evaluate its treatment plant processes to determine if there are opportunities to optimize its processes to reduce generation of dichlorobromomethane. **Bis(2 -**  **Ethylhexyl)Phthalate** The maximum observed effluent concentration for bis(2
- ethylhexy l)phthalate is 13 μg/Lwhich exceeds the proposed final MDEL of 11.8 μg/L and the proposed final AMEL of 5.9 μg/L
. . Only 7 data points are available for January 2 000 through December 2002 with the two earliest samples having high detection limits (i.e., 25 μg/L ). The District will have difficulty complying with the proposed interim and final limits but insufficient data are available to assess compliance with any certainty
. Bis(2
- ethylhexy l)phthalate (Bis
- 2) is a plasticizer. Approximately 97% of the Bis
- 2 produced annually is used as a plasticizer for PVC and other plastics. Because of the widespread use of plastics in every

facet of every day

life, Bis
- 2 is ubi quitous. I nfluent levels of Bis
- 2 average 30 μg/L. The District has not previously identified Bis
- 2 as a pollutant of concern and, therefore, has not conducted pollution prevention activities for this constituent. With only seven effluent samples in 3 y ears and six influent samples, there is not enough information to completely assess the District’s ability

to comply

with the proposed interim or final limits. Since high levels of Bis
- 2 in POTW effluent are usually associated with sampling and/or laborator y analy sis conditions, the District proposes to conduct a special study to determine if cleaner sampling and analy sis techniques can reduce the amount of Bis
- 2 in the effluent. **4,4’ -**  **DDE, Dieldrin** The chlorinated pesticides, 4,4’
- DDE and dieldrin , have not been detected in the District’s effluent and have been below reporting limits of 0.01 μg/L . The reporting limits and the detection limits (0.001 μg/L for 4,4’
- DDE and 0.002 μg/Lfor dieldrin) exceed the proposed final limits for both constituents. The refore, there is insufficient information to determine if the District is able to comply with the proposed effluent limits. 4,4’
- DDE is a decomposition product of DDT, which was banned in the US for most uses in 1972 and all remaining uses in 1988. Dieldrin was banned for most uses in 1974 and all remaining uses in 1987. Dieldrin is also a decomposition product of Aldrin whose use was also discontinued in the late 1980’s. The District has not previously identified 4,4’
- DDE or dieldrin as pollutants of c oncern and, therefore, has not conducted pollution prevention activities that directly target these constituents. However, the District has an ongoing pesticide pollution prevention program that includes a restaurant Integrated Pest Management (I PM) educa tion program, residential outreach (theatre slides, bus boards, public events), school outreach and PCO workshops. As noted above, there is insufficient information to completely assess the District’s ability

to comply

with the proposed effluent limits fo r 4,4’
- DDE and dieldrin. Since reasonable potential for these constituents is triggered only b y background ambient conditions, the District will continue existing efforts for pesticides generally
.7

**Summary** This evaluation indicates that immediate complia nce with projected final effluent limits for copper, mercury , cy anide, bromodichloromethane, bis(2
- ethylhexy l) phthalate, 4,4’
- DDE and dieldrin is not feasible for the District. Inaccordance with the requirements of the SI P, the District requests that th e Regional Board refrain from the adoption of final effluent limits for these constituents. I n lieu of final limits, the NPDES permit should include the interim performance based limits with which the District can comply
. Proposed source control actions are shown in Table 3 below. **Table 3. Proposed Source Control Actions Constituent**  **Proposed Action Estimated Time to**  **Complete** Copper Existing outreach to municipal water supply agencies, plumbers, vehicle service facilities, metal fabricators, and surface cleaners Ongoing
Mercury No additional activity since RP triggered by background data N/A Cy anide Participate in study to develop site
specific objective June, 2003 Dichlorobomomethane Conduct source identification across plant processes Three y ears af ter permit adoption Bis(2
- Ethy lhexy l)Phthalate Conduct study to evaluate clean sampling Three y ears after permit adoption 4,4’
- DDE No additional activity since RP triggered by background data N/A Dieldrin No additional activity since RP triggered by bac kground data N/A