AR 041806 G&G Environmental Compliance

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ITEM #21 CITY OF COLTON AGENDA REPORT FOR THE COLTON UTILITY AUTHORITY MEETING OF APRIL 18, 2006 TO: HONORABLE CHAIRPERSON AND UTILITY AUTHORITY MEMBERS FROM: ERIC R. FRASER, DIRECTOR OF WATER & WASTEWATER OPERATIONS SUBJECT: APPROVAL OF EXTENSION TO THE CONTRACT FOR INDUSTRIAL PRETREATMENT PROGRAM SERVICES TO G&G ENVIRONMENTAL COMPLIANCE, INC., IN AN AMOUNT NOT TO EXCEED $92,000 FOR FY06/07 DATE: APRIL 18, 2006 BACKGROUND: The City of Colton's Pretreatment Program is required under existing federal pretreatment program regulations (40CFR403) and NPDES Permit No. CA0105236. California Regional Water Quality Control Board, Santa Ana Region adopted Order No. R8-2005-0075 on September 30, 2005. The adopted Order issued the NPDES Permit. The essential program elements required under this permit include permitting, inspection, monitoring, enforcement, and regulatory reporting. One of the requirements associated with the issuance of the new NPDES Permit is to re-evaluate the local wastewater discharge limits (limits) to determine if the existing limits still provide adequate protection to upsets, interference, or pass-through of pollutants which may originate from commercial/industrial discharges. Domestic (residential), industry, and treatment plant sample data will be collected to gather the necessary information. The new information will then be analyzed to determine the best strategies for allocating pollutant limitations in a manner that creates the least impact on our commercial/industrial users. DISCUSSION/ANALYSIS: G&G Environmental Compliance, Inc. (G&G) has been retained since January 2004 to provide the essential program services including inspection, monitoring, reporting, and compliance related activities for the Pretreatment Program. The City's Wastewater Reclamation Facility (WRF) has added treatment capacity since the previously issued permit and the discharge limits, contained in the new NPDES Permit No. CA 0105236, have changed to reflect new water quality standards established by the State of California. As a result of the aforementioned changes, the permit requires the City to re-evaluate the existing local discharge limits for commercial and industrial discharges to ensure adequacy and that the limits reflect current conditions. G&G has completed the initial review for "pollutants of concern" which is the first step in this re-evaluation process. The existing contract with G&G expires on June 30, 2006. The local limits evaluation process is a 5-6 month process which involves, collecting additional treatment plant monitoring data, analyzing the data to determine treatment plant pollutant removal rates, inhibition (interference) rates for the biological processes, developing a draft local limits document, meeting with affected commercial/industrial dischargers to discuss the potential impacts on their operations, review and approval of the State and US EPA, Public Hearing(s) and adoption of the approved limits by the City of Colton. The City of Colton's WRF remains in compliance with effluent limitations in their current permit however; the existing local limits were adopted prior to employing the treatment provided by the Rapid Infiltration/Extraction (RIX) Facility, which provides tertiary treatment. The new local limits must consider the treatment provided by both facilities to be technically based and legally defensible. G&G personnel are very familiar with the City of Colton's wastewater treatment capabilities; the permitted industrial user contributions; and have the experience needed to prepared technically based and legally defensible local limits.