Advanced Wastewater Treatment Plant Program
NPDES Permit and Background
SRCSD is responsible for conveying and treating the region's wastewater. The level of treatment required before the water can be released back into the environment is dictated by a National Pollutant Discharge Elimination System (NPDES) permit. This permit is issued by the Central Valley Regional Water Quality Control Board (CVRWQCB) - the State of California's governmental agency that regulates wastewater dischargers in our region. Discharge permits must be renewed every five years.
In December 2010, the CVRWQCB issued a new wastewater discharge permit to SRCSD. The new discharge permit was one of the most restrictive wastewater treatment permits ever issued in the State of California. The permit requires special studies, pollution prevention plans, extensive infrastructure additions and an aggressive compliance schedule for treatment process selection, pilot studies, design, construction and commissioning. The new treatment processes must be fully operational and in permit compliance by 2021. It is estimated that these new processes will cost approximately $2 billion to construct.
The CVRWQCB's adoption of the permit was based on their view that constructing new treatment processes at SRCSD's wastewater treatment plant will significantly improve water quality in the Sacramento River and the Delta, thereby reversing some of the ecological problems that currently exist in the Delta. SRCSD disagreed with this hypothesis but was unsuccessful in convincing the CVRWQCB of this position.
What New Treatment Processes Are Required By The Permit?
Among other things, the permit contains mandates that require SRCSD to plan, design and construct new treatment facility upgrades for ammonia removal, nitrate removal, filtration and disinfection. These new processes are very expensive and include:
Nitrification refers to the biological oxidation of ammonia with oxygen into nitrate.
Denitrification refers to the process of removing nitrate from the wastewater by converting it to nitrogen gas.
Filtration is used in wastewater treatment plants to remove very small particles and pathogens from the treated effluent.
Disinfection inactivates pathogenic microorganisms, including bacteria and viruses.
SRCSD Challenge to New Permit Requirements
In January 2011, SRCSD appealed the discharge permit decision to the State Water Resources Control Board (SWRCB) with the following key arguments: (1) some of the new mandates were not justified by sound science; (2) the Central Valley Regional Water Quality Control Board did not adequately consider the high costs for facility upgrades; and (3) legal and regulatory requirements for setting permit conditions were not properly used.
During the appeal, SRSCD was required to continue moving forward in complying with the discharge permit's conditions until a decision on the appeal was rendered. In December 2011, while waiting for a decision, SRCSD filed a lawsuit in Sacramento Superior Court challenging the conditions in the permit. The court issued a "stay" for the filtration and disinfection requirements while the SWRCB considered SRCSD's appeal.
In October of 2012, the SWRCB finally issued a draft order essentially upholding all of the conditions of the permit. On April 29, 2013, SRCSD announced a partial settlement of the litigation, dropping its challenge to the permit provisions requiring removal of ammonia and nitrate from its treated effluent. This now clears the way for expedient compliance with these conditions of the permit. However, SRCSD continues its challenge to the requirements mandating new filtration and disinfection. The parties have agreed to “stay” certain requirements related to these facilities, pending final legal resolution. It is anticipated a hearing in Superior Court on the case will occur in spring 2014.
Advanced Wastewater Treatment Plant Program
Needing to begin the effort to comply with the new permit even during the appeal process, SRCSD immediately began work upon the permit's issuance. One of the key initial tasks was to develop an Advanced Wastewater Treatment Plant (AWTP) program management structure. The District hired Brown and Caldwell/HDR Engineering Inc., a Joint Venture (B&C/HDR), to provide Program Management services. Together with District staff, B&C/HDR formed an integrated Program Management Office to oversee the Program to make sure that the facilities are developed in a cost-effective manner while meeting permit and schedule requirements and assuring that the project works as intended. The Program Management Office will also provide oversight and review of work by separate designers and constructors.
AWTP Pilot Project now in operation at the Regional Treatment Plant.
Advanced Wastewater Treatment Plant Pilot Project
Another early activity needed to plan the full-scale plant improvements is detailed pilot testing. This is being done via construction and operation of a small-scale "pilot project." The pilot project is studying and testing various treatment methods and alternatives in order to identify the treatment technology that is the most feasible, cost-effective and efficient for the full-scale Advanced Wastewater Treatment Plant (AWTP).
Cost Effective Design and Construction to Assure Project Value for our Rate Payers
During the project, key decisions will need to be made that affect the overall cost of the project including materials of construction, equipment selection and layout, and methods of construction. Much effort has been placed and will continue to be placed on selecting the most cost-effective technologies.
Some of the many techniques that will be used to control costs during design and construction include:
- Reliability Centered Design: Install appropriate size and number of facilities and avoid overbuilding facilities that will have higher upfront costs as well as higher operation and maintenance costs.
- Business Case Evaluations (BCE): Use robust and thorough BCE processes to ensure significant life cycle costs, risk and facility performance are evaluated to provide the best value project.
- External Third Party Review: Use external industry experts to review key project design and construction assumptions to confirm appropriate and cost effective projects are being developed.
- Project Benchmarking: Survey other projects of similar scope and magnitude to identify "lessons learned" and opportunities for improvement.
Customer Rates and Impact Fees
SRCSD has prepared, and continues to refine, rate and fee projections for construction and operation of the treatment plant upgrades. Rate and fee projections may continue to be refined based on detailed and updated cost estimates of the selected treatment upgrades, debt financing method, outcomes of appeal and litigation and external funding assistance.
Financing Full-Scale Facilities & New Treatment Processes
SRCSD is working hard to optimize financing mechanisms to help pay for the AWTP Program. A project of this scale requires careful financial planning. Bond funding will be necessary for the bulk of the AWTP Program, but there may be opportunities to save money through strategic timing of bond issues.
Seeking Funding Assistance
SRCSD is actively seeking funding from outside the Sacramento region to assist ratepayers. To the extent that funding can be obtained, the costs to ratepayers may ultimately be lower. Below are some efforts that are underway.
- In 2011, Assembly Bill 134 was signed into law which allows SRCSD to seek water rights through the SWRCB for water that it discharges to the Sacramento River. To the extent that any rights can actually be obtained, there is the potential to generate revenue for SRCSD. SRCSD is currently studying opportunities for marketing its wastewater.
- A future State Water Bond may be a potential source of revenue for District work. SRCSD continues to track and participate in efforts related to the bond.
- Federal and State grants are difficult to obtain in the current economic climate; however, SRCSD staff seeks grant opportunities and applies for grants where possible.
- Notice of Preparation for a Draft Environmental Impact Report (1,240K pdf* file)
- February 2012 Project Management Services Board Letter (155K pdf* file)
- January 2012 Press Release: SRCSD Files Lawsuit Requesting Relief from Wastewater Discharge Permit Requirements (450K pdf* file)
- Bay Delta Conservation Plan (BDCP)
- Bay Delta Office (USFWS)
- Bay-Delta Program (SWRCB)
- California Department of Water Resources (DWR)
- Central Valley Clean Water Association
- Delta Coalition
- Delta Conservancy
- Delta Protection Commission
- Delta Stewardship Council
- Ecosystem Restoration Program (CDFW)
- National Academy of Sciences - Sustainable Management in the Delta
- North State Water Alliance
- Regional Water Authority (RWA)
- Sacramento River Delta
- US Army Corps of Engineers
- US Bureau of Reclamation
- US Environmental Protection Agency
- Water Reuse Association
Want More Information?
Maintaining communication with the community throughout this project is very important to SRCSD. We encourage you to visit www.SewerSense.com for updated project information. If you'd like to speak with a representative regarding the Advanced Wastewater Treatment Plant Program, please contact the Program Manager, Vick Kyotani, by email at email@example.com or phone at (916) 875-9001.