Alameda County wastewater Disposal Survey
Street Sweepers and Catch Basin Cleaning activities, August 3,1992
Dear Ms. Heinze:
To begin, I want to thank you for including the Bancroft Guardian Coalition on your mailing list. We recognize you haven't had adequate time to respond to our first letter, but thought it important to write a second. After receiving notice of your subcommittee's scheduled discussion on the 5th of August we wanted to contribute our group's ideas to both the disposal issue and the Maintenance Questionnaire. Your survey begins:
Do you think disposal of wastewater generated by municipal maintenance practices is a problem that could be improved by the Maintenance Subcommittee developing Best Management Practices?
It is first important to restate that the disposal practices as seen in Alameda County are varied. The process for development of disposal practices for municipal maintenance activities has already begun. As I understood, the BMPs for disposal of wastewater were being developed and recently were released by your group. The survey question should more appropriately read "... by the Maintenance Subcommittee changing its Best Management Practices?" The BMPs for disposal were incomplete. The omission of a Tier I for disposal did make it appear that the CWP had not fully contemplated the problem. Our coalition's first response to the other participating cities was to ask what their current disposal practices were. This particular question begs the issue of "uniform practice." BMP development is important for this reason alone.
On the phone I discussed how important I thought appropriate municipal disposal activities were to an effective runoff program. Two months ago, the CWP had assigned a relatively low priority to defining disposal standards. The Maintenance Questionnaire sent out by your subcommittee reflects the CWP's changing sense of priority in this area. I think it is easy to assign low priority to those things we know little about, and so early development of BMPs is important. The efforts of your subcommittee's work over the first part of this year is evidence that BMP development is essential and ongoing.
There are many options to the disposal of wastewater generated by municipal maintenance activities. The June '92 BMPs, Tier II, for the CWP suggests the use of "impermeable containment, evaporation (drying bed) and/or wastewater drained to the sanitary sewer system." A problem of this approach is making some determination concerning the strength of the wastewater stream directed to EBMUD, given the variables in each municipal maintenance activity.
Several months ago, I spoke with Thomas C. Paulson, EBMUD Industrial Discharger Section Supervisor, Source Control Division. Our conversation focused on the strength of wastewater streams in relationship to the permit process for municipalities who might decide to use their system (see enclosed application form for wastewater Discharge Permit). Depending upon the characteristics of the wastewater discharge, a municipality may or may not be subject to a permit process. This determination is left up to the discharger (municipality). The permit allows for regular monitoring and testing of discharges to the sanitary drain system (sounds like a good idea).
A new procedure has been developed to enable some municipal facilities to obtain permits more easily. The PBR, Permit By Rule, was designed for those who otherwise would be required to obtain a full hazardous waste facility permit. This permit process is controlled by the California Department of Toxic Substance Control (DTSC). The City of Berkeley petitioned for information concerning this permit process. I don't believe they have filed for a permit with regard to the use of the sanitary drain system and their changing practices. Berkeley's Public Works has stated that they didn't feel a need to file for an permit. Mr. Paulson (EBMUD) stated the permit issue was unclear for municipalities.
Wastewater reduction should be the goal of every municipality. To minimize the use of wash water naturally follows. The recycling of water is the next most desirable option for disposal of waste/wash waters in either a wastewater oil recycler or wastewater recycler.
Berkeley is purchasing an oil recycler for their vehicle steam cleaning activities. When it is installed it will be capable of reclaiming the water by separating it from oil and particulates. The water will then be reused. I spoke to a supervisor of Berkeley's Corporation Yard and he said the wastewater systems he had recently reviewed for their yard were costly and also labor intensive.
At least one municipality processes storm drain inlet debris leachate into a sediment basin where the solids settle and the liquid either evaporates or percolates into the ground. Solids are then removed to the local landfill. This practice probably will not become the standard for the program. There is obvious potential to harm the groundwater with exposure to high concentrations of catch basin and sweeper wastewater collections and wash water. This was the point made at the end of the video. Is this a wastewater program or a runoff program? We think it is both. The use of the term "runoff" at times makes us forget the wastewater part.
There is one other BMP that our coalition thinks should be emphasized and that is the tarping of municipal trucks. I think there exists a notion that "around town" it is not necessary to tie down debris collected from municipal maintenance activities. Our group made formal request of our Public Works Department to be more conscious of this problem. Residents were tired of our neighborhood being dusted down by dirt arid debris. Our city trucks were not being tarped. Heightened awareness to this (local) issue would contribute to litter control and the street sweeper program.
I want to say that we were very pleased to see your questionnaire and particularly with its focus on disposal. We recognize this as the beginning of serious discussions on the matter.
Respectfully, L A Wood
cc: Jack A. Lindley, Water Resources Manager, CWP Robert Marek, City of Berkeley, Engineering Jordan M. Rich, Asst. City Mgr. Public Works, Berkeley
Best Management Practices for Street Cleaning and Storm Drainage Facilities
Diane Heinze, P. E. Interim Chairperson Maintenance Subcommittee, ACURCWP
Oakland, CA, July 22, 1992
Dear Ms. Heinze:
It was good to talk to you on the telephone last week concerning the Best Management Practices for Street Cleaning and Storm Drainage Facilities. As you know, the Bancroft Guardian Coalition's interest in the Alameda County Urban Runoff Clean Water Program (CWP) was as a consequence of a neighborhood action. In order to understand the problems with our own city's Public Works Department, we were compelled to consider the Runoff Program. Our attempt to informally survey the participating cities made us recognize that the disposal problem was not exclusive to the City of Berkeley. We hoped that our video, "Berkeley's Storm System: Portal to the Bay," and our survey would contribute to the awareness of storm drain disposal pollution.
A portion of the video was devoted to a discussion of runoff content and strength. The storm drain inlet debris collection, in an urban context, represents more than storm water or runoff. It is generally recognized that wastewater strength varies in storm drain collections given any number of variables, including illicit discharges. The ability of a given municipality to determine specific content of its disposal collections can only be done by testing. This is generally not cost effective.
Our preliminary survey has shown municipalities' disposal activities to be varied. The concern of our group was that a minimum standard of practice be recognized by the CWP, given the limitations of illicit disposal detection and runoff content.
Last month, your Maintenance Subcommittee issued its Best Management Practices (BMP) for street cleaning and storm water collection. This is a two tier program that reflects shrt range (Tier I) and long-range (Tier II) municipal maintenance activities (goals). On the issue of "Disposal of Material" (III), the BMPs list Tier I activity. This we thought was an implied acknowledgement that any current disposal activity is acceptable or to be tolerated by the program. It was our public perception that the perimeters of the Tier I disposal practices were too broad. The Tier II schedule reads:
Store material removed from storm drainage facilities on a concrete pad or other impermeable material and drain wastewater to the sanitary sewer system or allow to evaporate to prevent discharges to the storm drain system.
In our conversation you mentioned that our group's concerns had been heard at the County level. You said that the proposed Tier II for Disposal of Material-BMP's was being changed to read Tier I. The Coalition sees this as a significant change. First and foremost, it reflects a sensible approach to the problem. Secondly, because of the sensitivity to costs surrounding the issue, most municipalities require additional regulatory direction. The integrity of the CWP is hurt when the issue of disposal is not addressed openly and with the emphasis that it deserves.
You also said that our video was going to be shown at the beginning of the next Maintenance Subcommittee meeting on August 5th. We would be interested in any feedback from your group concerning this showing and also your ideas concerning our group's impact on the Best Management Practices of the CWP.
We are encouraged by your openness to our inquiry and the the idea of our group working with the CWP to the betterment of the San Francisco Bay and Region.
