HomeMy WebLinkAbout99.01-SAWPA Remedial Plan Report.pdf Santa Ana Watershed
Project Authority
(SAWPA) Remedial Plan
Report
March 19 , 2014
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Prepared by:
Orange County Sanitation District
10844 Ellis Avenue
Fountain Valley, California 92708-7018
TABLE OF CONTENTS
ES EXECUTIVE SUMMARY..............................................................................................................E.1
ES.1 Introduction ......................................................................................................................E.1
ES.2 Background......................................................................................................................E.1
ES.3 Objective of the SAWPA Remedial Plan .........................................................................E.2
ESA Methodology for the SAWPA Remedial Plan...................................................................E.2
ES.5 Outcome...........................................................................................................................E.3
ES.6 Conclusion .......................................................................................................................E.3
ES.7 Requirements and Recommendations.............................................................................EA
1.0 BACKGROUND ...............................................................................................................................1
1.1 SAWPA...............................................................................................................................1
1.2 2012 Audit Triggers.............................................................................................................2
1.3 Major 2012 Audit Findings..................................................................................................3
2.0 SAWPA REMEDIAL PLAN..............................................................................................................4
2.1 SAWPA Remedial Plan Gate Process and Life Cycle........................................................6
2.2 SAWPA Remedial Plan Execution......................................................................................7
3.0 SAWPA PRETREATMENT PROGRAM FUTURE DEVELOPMENT AND IMPLEMENTATION...........8
3.1 Requirements 2 and 6.........................................................................................................8
3.2 Requirement 3...................................................................................................................10
3.3 Requirement 7...................................................................................................................10
3.4 Requirement 8...................................................................................................................11
3.5 Implementation..................................................................................................................11
4.0 FUTURE DISCUSSIONS.....................................................................................................................11
4.1 YVWD as a Contract Agency............................................................................................12
4.2 Requests for Wastewater Originating Outside SAWPA's SARI Service Area.................. 12
4.3 Stormwaler........................................................................................................................13
4.4 Reclaimable Wastewater..................................................................................................13
4.5 Pre-approved Situations ...................................................................................................13
4.6 Substantially Similar Programs.........................................................................................14
4.7 PPCD................................................................................................................................14
5.0 CONCLUSION...............................................................................................................................14
6.0 REQUIREMENTS AND RECOMMENDATIONS...........................................................................15
6.1 For SAWPA.......................................................................................................................15
6.2 For OCSD.........................................................................................................................15
7.0 ACKNOWLEDGEMENTS..............................................................................................................15
7.1 SAWPA.............................................................................................................................16
7.2 OCSD................................................................................................................................16
TABLES
Table 2.1 SAWPA Remedial Plan Thirteen Requirements.................................................................5
Table2.2 Punch List Groupings..........................................................................................................7
APPENDICES
Volume I—Governing Control Documents for SAWPA-OCSD Pretreatment Relationship
• Appendix A 1991 Pretreatment Memorandum of Understanding
• Appendix B 1996 Wastewater Treatment and Disposal Agreement
• Appendix C 2012 SAWPA Pretreatment Program Audit
• Appendix D OCSD Wastewater Discharge Regulations (OCSD Ordinance No. 39)
• Appendix E 2013 SAWPA Remedial Plan
• Appendix F SAWPA Remedial Plan Gate Process
• Appendix G SAWPA Remedial Plan Deliverable Expectations
• Appendix H SAWPA Remedial Plan Communication Plan
Volume 11—SAWPA Remedial Plan Project Documents
• Appendix I SAWPA Remedial Plan Overview
(including the Work Breakdown Structure and Complete Gate Overview)
• Appendix J Requirements Activities
• Appendix K SAWPA Remedial Plan Punch List
• Appendix L SAWPA Pretreatment Program Evaluation(by Dudek)
• Appendix M Post SAWPA Remedial Plan Side Letter
• Appendix N 2012 Audit Response Deliverable Summary
Volume III—Updated and/or New SAWPA Pretreatment Program Control Documents
• Appendix O SAWPA Ordinance No. 7
• Appendix P Inland Empire Brine Line Multijurisdictional Pretreatment Agreement
• Appendix Q SAWPA Pretreatment Program Policies
• Appendix R SAWPA Pretreatment Program Enforcement Response Plan
• Appendix S SAWPA Procedures
ES EXECUTIVE SUMMARY
ESA Introduction
As the holder of an NPDES Permit with a large base of industrial dischargers, the Orange County
Sanitation District(OCSD)instituted a Pretreatment Program, which has been approved by the California
Regional Water Quality Control Board, Santa Ana Region and the U.S. Environmental Protection Agency,
Region IX. Since OCSD has an approved Pretreatment Program, OCSD must fulfill its role as the Control
Authority by controlling all dischargers into its collection and treatment systems. This is done through the
adoption of wastewater discharge regulations that stipulate issuing permits for industrial and commercial
facilities and by enforcing permit conditions.
To facilitate the cleanup of groundwater containing high levels of Total Dissolved Solids(TDS) in an area
of the Inland Empire defined in the 1996 Wastewater Treatment and Disposal Agreement(1996
Agreement)as"SAWPA's SARI Service Area,"OCSD and the Santa Ana Watershed Project Authority
(SAWPA)entered into agreements starting in the 1970s that allow SAWPA to discharge wastewater
containing high TDS into OCSD's collection system through a specific sewer trunk that connects the two
agencies. This trunk is referred to by OCSD as the"Santa Ana River Interceptor' (SARI)Line.
Agreements governing the usage of the SARI Line and requirements resulting therefrom include the 1991
Memorandum of Understanding between SA WPA and CSDOC Governing Quality Control of Wastewater
Discharged to the SARI(1991 MOU)and the 1996 Agreement. Through these agreements, OCSD, as
the Control Authority for its Pretreatment Program, granted SAWPA authority to control the dischargers in
SAWPA's area;therefore, SAWPA is OCSD's Delegated Control Authority and is responsible to OCSD
for running a Pretreatment Program to issue permits and enforce permit conditions for all discharges from
SAWPA's SARI Service Area to OCSD.
The SAWPA Pretreatment Program is an extension and a critical part of OCSD's own Pretreatment
Program. As the Control Authority, OCSD is required to have a Pretreatment Program, and, thus, OCSD
has required that SAWPA establish a substantially similar or more stringent (hereafter referred to as
"substantially similar") Pretreatment Program than that of OCSD's Pretreatment Program, because
OCSD's Pretreatment Program is approved by EPA and the RWQCB, and OCSD is responsible to these
regulators to ensure that SAWPA maintains compliance with applicable Pretreatment regulations and
conditions for discharging into OCSD's SARI Line and wastewater treatment facilities.
Some of the major elements of the Pretreatment Program include the issuance of permits, the
performance of inspections, the collection of samples ("monitoring"), the review of permittee self-
monitoring reports, and the initiation of enforcement activities, when necessary. The relationship between
OCSD, as the Control Authority, and SAWPA, as the Delegated Control Authority, for the SARI Line is
governed by the requirements, responsibilities, and practices as specified in the following documents or
their successors: NPDES Permit No. CA011 0604; OCSD's Wastewater Discharge Regulations,
Ordinance No. OCSD-39, SAWPA's Brine Line Ordinance No. 7; and the agreements between OCSD
and SAWPA, in particular the 1991 MOU and the 1996 Agreement.
ES.2 Background
Since 2011, OCSD staff began to observe that SAWPA had violated provisions of the 1991 MOU and the
1996 Agreement. Furthermore, in March 2012, OCSD staff became aware that SAWPA had allowed the
unauthorized discharge of nine million gallons of mining wastewater that originated outside SAWPA's
SARI Service Area into a facility connected to the SARI Line. Although the facility was permitted by one
of SAWPA's Member Agencies, the permit for the facility did not have the proper permit category, limits,
and requirements for wastewater resulting from mining operations. Upon becoming aware of the
discharge, OCSD issued an Order to Cease Noncompliant Discharge to SAWPA.
The magnitude and significance of the violations of the agreements warranted OCSD to exercise its right
under the 1991 MOU to audit the SAWPA Pretreatment Program. The goal of the audit was to ensure
that SAWPA and any other agency having discharge rights to the SARI Line pursuant to contracts with
EA
SAWPA are adequately administering and diligently enforcing Pretreatment Programs in conformance
with federal Pretreatment regulations (40 CFR 403), the 1991 MOU and 1996 Agreement, and OCSD's
regulations, requirements, and practices for discharges to the SARI Line. These other agencies are
SAWPA's four Member Agencies: Inland Empire Utilities Agency (IEUA), Eastern Municipal Water
District (EMWD), Western Municipal Water District (WMWD), and San Bemadino Valley Municipal Water
District (SBVMWD). OCSD retained Environmental Engineering & Contracting, Inc. (EEC)to perform the
comprehensive audit between August and November of 2012. The audit revealed that SAWPA and its
Member Agencies did not always follow important program requirements, responsibilities, and practices
and did not always comply with the 1991 MOU and 1996 Agreement. The November 2012 audit report
contained seventy-five (75)findings, many of which required further action.
ES.3 Objective of the SAWPA Remedial Plan
On January 23, 2013, OCSD's Board of Directors issued a Remedial Plan to SAWPA to correct
deficiencies in SAWPA's Pretreatment Program. The Remedial Plan, referred to as the SAWPA
Remedial Plan (SRP), was developed by OCSD staff to ensure that SAWPA addressed the items in its
Pretreatment Program identified during the 2012 audit by OCSD (EEC) as well as any items that were
encountered by SAWPA or OCSD during SAWPA's effort to address the audit findings and to bring
improvements to SAWPA's overall Pretreatment Program. However, in the early stages of the SAWPA
Remedial Plan, SAWPA informed OCSD that it did not have a Pretreatment Program; therefore, the focus
then shifted from improving an existing program to building the SAWPA Pretreatment Program.
To build the SAWPA Pretreatment Program, SAWPA had to revise existing Pretreatment Program Control
Documents and create new ones. This effort entailed revising SAWPA's current Ordinance; developing
and entering into a new Multijurisdictional Pretreatment Agreement (MJPA) with the SAWPA Member
Agencies and other agencies (known as"Contract Agencies"); and developing new Policies, Procedures,
Standard Operating Procedures (SOP), and an Enforcement Response Plan (ERP). The Pretreatment
Program Control Documents are critical for establishing the legal authority and foundation for the SAWPA
Pretreatment Program to allow SAWPA to issue industrial user (IU) discharge permits that are adequate
and enforceable.
Before creating these documents, one of the decisions was how the SAWPA Pretreatment Program
would function and be implemented. OCSD's contractual agreement is with SAWPA and does not extend
to the Member or Contract Agencies. OCSD holds SAWPA responsible for the SAWPA Pretreatment
Program under any arrangement between SAWPA and its Member and Contract Agencies. SAWPA's
compliance with all Pretreatment and agreement requirements is the ultimate objective. Therefore, the
SRP was developed based on the idea and recommendation that SAWPA runs its own Pretreatment
Program and directly controls all dischargers to the SARI Line.
SAWPA hired a consultant, Dudek, to review the options and recommend a method for managing the
SAWPA Pretreatment Program. As a result, SAWPA informed OCSD of its desire to run a SAWPA-
directed Pretreatment Program, in which SAWPA would be responsible and liable directly to OCSD but
would also continue to administer the existing Pretreatment Program. Such an arrangement would entail
SAWPA doing some Pretreatment work to prevent conflict of interest issues in situations where Agencies
permitted their own facilities. Aside from addressing conflict of interest situations, SAWPA would primarily
oversee and direct the work of the Member and Contract Agencies, who act as SAWPA's "boots on the
ground:'
ESA Methodology for the SAWPA Remedial Plan
With the understanding that transforming the conditions contributing to the identified omissions and
deficiencies in SAWPA's program requires a sustained effort, OCSD followed a systematic approach
emphasizing the importance of establishing a recognized legal authority enabling SAWPA to implement
and enforce a delegated Pretreatment Program substantially similar to that of OCSD's Pretreatment
Program. OCSD's method included a framework consisting of a sequence of project progress stages to
be achieved for SAWPA to complete the SAWPA Remedial Plan. In the initial step, OCSD created a
E.2
Work Breakdown Structure (WBS)for the thirteen SAWPA Remedial Plan Requirements. In addition, a
Communication Plan was developed to provide a structured path for interaction between OCSD and
SAWPA and to define roles and responsibilities of the staff involved with the SAWPA Remedial Plan. The
achievement of each project Requirement progress was marked by a decision Gate.
A decision Gate indicated a milestone in the SAWPA Remedial Plan sequence where the current state of
the SAWPA Remedial Plan implementation, or more specifically a Requirement, was evaluated. For each
decision Gate, OCSD defined the Deliverable for submittal,which consisted of one or more items. Based
on the submitted documentation, OCSD decided whether the SAWPA Remedial Plan progress stage was
completed successfully and whether the next SAWPA Remedial Plan stage was ready to be entered. In
addition to the Gate meetings, Technical Discussions were often held to discuss items in greater detail.
OCSD also transmitted Submittal Review Comments or drafts Submittal Review Comments to help
SAWPA make the corrections necessary or to provide guidance.
ES.5 Outcome
Since the issuance of the SAWPA Remedial Plan, SAWPA worked to develop a new unified Pretreatment
Program that would address the concerns identified during the 2012 SAWPA Audit and the SAWPA
Remedial Plan. SAWPA established two new groups, the Pretreatment Working Group and the
Pretreatment Management Team, in which SAWPA has extended an invitation for OCSD to sit in on to
provide technical support and to facilitate communication and accountability among SAWPA and its
Member and Contract Agencies.
OCSD worked with SAWPA to pass as many Requirements, Gates, and Conditions as possible before
the January 17, 2014, deadline. SAWPA passed through all 21 Gates, and SAWPA successfully
completed 7 of 13 SRP Requirements and 52 of 72 Gate Conditions. After collaborating with SAWPA,
OCSD issued a side letter on March 13, 2014, to capture some of the understandings between the parties
not otherwise documented in the SAWPA Remedial Plan. Issues listed in the side letter include
interpretation of definitions, practices acceptable to OCSD, and expectations of the SAWPA Pretreatment
Program. Remaining items are continuing and are slated to be addressed by June 30, 2014. The
remaining items that are discrete tasks were memorialized in a Punch List. A listing of the general
groupings of the tasks in the Punch List is provided below:
GroupSubject
A Establishment of Substantial) Similar Pretreatment Programs
B I Revision of Pretreatment Program Control Documents
C I Data Management System
At the completion of the SAWPA Remedial Plan, SAWPA had developed five Pretreatment Program
Control Documents that constitute the legal basis, foundation, and framework for its Pretreatment
Program. The Pretreatment Program Control Documents encompass SAWPA's revised Ordinance and
newly developed MJPA, ERP, Policies, and Procedures. Due to modifications made to the SAWPA
Pretreatment Program and the amount of work required to draft the Pretreatment Program Control
Documents, SAWPA's Pretreatment Program Control Documents will be improved over time. Moreover,
for the SAWPA Pretreatment Program to be substantially similar to OCSD's Pretreatment Program,
SAWPA must further align its Pretreatment Program Control Documents with OCSD's Pretreatment
Program, and whenever OCSD revises its Pretreatment Program Control Documents, SAWPA will be
required to update its Pretreatment Program Control Documents to ensure that its Pretreatment Program
remains substantially similar.
ES.6 Conclusion
OCSD and SAWPA invested a considerable amount of time and effort in creating the SAWPA
Pretreatment Program. SAWPA decided to implement a directed Pretreatment Program, in which
SAWPA simultaneously remains responsible and liable to OCSD at all times, while primarily coordinating,
E.3
directing, and reviewing the Pretreatment Program efforts of the Member and Contract Agencies.
SAWPA appears ready to maintain, improve/enhance, and sustain all SAWPA Pretreatment Program
elements established under the SRP, including Pretreatment Program staffing and resources. In turn,
OCSD will continue to oversee SAWPA's efforts and will conduct future audits to verify that the SAWPA
Pretreatment Program development is essentially completed and that its implementation is in compliance
with all regulations and requirements.
SAWPA must continue to align the SAWPA Pretreatment Program with OCSD's Pretreatment Program.
Without substantially similar Pretreatment Programs, both OCSD and SAWPA are always at a significant
risk when undergoing a regulatory inspection or audit. During the SAWPA Remedial Plan, OCSD
assisted SAWPA to establish a Pretreatment Program substantially similar to OCSD's Pretreatment
Program. SAWPA must carefully fill its Manager of Pretreatment and Permitting and obtain other
necessary expert resources to help achieve the SAWPA Remedial Plan objectives and requirements in a
timely, effective, and efficient manner. If SAWPA wishes to retain a SAWPA-directed program, SAWPA
must be able to retain in-house staff to ensure that there is continuity for the SAWPA Pretreatment
Program.
Changes to the SAWPA Pretreatment Program need to be made in a manner transparent to OCSD to
ensure that the SAWPA Pretreatment Program is developed and implemented properly at all times.
OCSD will host recurring meetings regularly with SAWPA and SAWPA's Member and Contract Agencies
to help all agencies fulfil their respective duties and obligations.
Moving forward and after one year of working together on the SRP, OCSD and SAWPA will begin a new
chapter in their working relationship. A positive vision for a new era is envisioned by OCSD and SAWPA.
OCSD and SAWPA desire to build a new working relationship and to implement activities to foster regular
communication, collaboration, and cooperation. The primary concerns at OCSD include the protection of
OCSD's wastewater collection, treatment, and reclamation facilities, the health and safety of its workers,
the current and future biosolids reuse, compliance with its NPDES Permit regulating discharge to the
Pacific Ocean, and the Groundwater Replenishment System. It is important to mention that as a result of
the 2012 audit and SRP implementation, the risk to OCSD has been reduced; however, the risk would be
reduced further if SAWPA and OCSD implemented the requirements and recommendations listed below.
ES.7 Requirements and Recommendations
For SAWPA:
1. SAWPA shall address the Punch List items by June 30,2014. SAWPA shall provide progress
updates to OCSD on a monthly basis.
2. SAWPA shall meet approximately quarterly with OCSD to address Pretreatment Program issues
of concern.
For OCSD:
1. OCSD will provide updates to the OCSD Steering Committee on the status of the SAWPA
Pretreatment Program.
2. OCSD will conduct regular audits of the SAWPA Pretreatment Program starting in the fall of 2014
after SAWPA has had time to implement the SAWPA Pretreatment Program,e.g., issue some
permits and conduct some enforcement activities. OCSD will audit the SAWPA Pretreatment
Program to verify whether the agencies are fulfilling their respective obligations and requirements
and assess whether additional modifications are required.
3. OCSD will establish quarterly Pretreatment Program Coordination Meetings with SAWPA and the
Member and Contract Agencies to promote coordination,cooperation, collaboration, and
alignment of the two Pretreatment Programs. OCSD will also participate in SAWPA's
Pretreatment Working Group and Pretreatment Management Team meetings.
4. OCSD will provide information on the state of SAWPA's Pretreatment Program to SAWPA based
on internal review and third party audit of the SAWPA Pretreatment Program. OCSD will provide
SAWPA advanced notice of any planned or required changes to the OCSD approved
Pretreatment Program.
EA
1.0 BACKGROUND
In accordance with the Code of Federal Regulations (40 CFR 403), the Orange County Sanitation District
(OCSD), as the holder of a National Pollutant Discharge Elimination System (NPDES)Permit, NPDES
Permit No. CA011 0604, and with a large base of industrial dischargers, instituted a Pretreatment
Program to control wastewater pollutants that may impact its collection system and wastewater treatment
facilities. OCSD's Pretreatment Program,also known as its Source Control Program, has been approved
by the California Regional Water Quality Control Board, Santa Ana Region (RWQCB)and the U.S.
Environmental Protection Agency, Region IX(EPA). Because OCSD has an approved Pretreatment
Program, OCSD by definition is the Control Authority (CA)over wastewater discharges to its collection
system that are subject to National Pretreatment Standards.
One source of such wastewater is from the Inland Empire area. To facilitate the reclamation of
groundwater with high levels of Total Dissolved Solids(TDS),typically salts, in the Inland Empire from an
area defined in the 1996 Wastewater Treatment and Disposal Agreement(1996 Agreement,Appendix B)
as"SAWPA's SARI Service Area,"OCSD and the Santa Ana Watershed Project Authority(SAWPA)
entered into agreements starling in the 1970s that allow SAWPA to discharge wastewater containing high
TDS into OCSD's collection system through a specific sewer trunk. In addition to wastewater from the
groundwater reclamation sites,the discharge to the SARI Line also contains industrial wastewater,
including wastewater subject to the National Pretreatment Standards, that is considered nonreclaimable,
typically because of high TDS levels. The sewer trunk into which SAWPA discharges and that ultimately
connects the two agencies is referred to by OCSD as the"Santa Ana River Interceptor" (SARI)Line.
SAWPA has connected extensions, known as reaches, to the SARI Line throughout SAWPA's area of
jurisdiction. SAWPA previously referred to the SARI Line as the"Santa Ana Regional Interceptor'Line,
but around 2009, SAWPA renamed the SARI Line with the reaches to the"Inland Empire Brine Line"
(IEBL). For this report,the term"SARI Line"will be used.
Agreements governing the usage of the SARI Line and requirements resulting therefrom include the 1991
Memorandum of Understanding between SAWPA and CSDOC Governing Quality Control of Wastewater
Discharged to the SARI(1991 MOU,Appendix A)and the 1996 Agreement. Collectively,the 1991 MOU
and 1996 Agreement are referred to as the"Agreements." Through such agreements, OCSD, as the CA,
granted SAWPA authority over the dischargers in SAWPA's area; therefore, SAWPA is OCSD's
Delegated Control Authority(DCA)and is responsible to OCSD for running a Pretreatment Program
similar to OCSD's Pretreatment Program to control discharges from SAWPA's SARI Service Area to
OCSD.
1.1 SAWPA
In 1972 SAWPA became a Joint Powers Authority with a mission is to build facilities to protect the quality
of the water in the Santa Ana River Basin. Final agreements for the current agency became effective in
1975 ("Meet-Us." www.sawoa.ora. n.p. 2012. March 10, 2014, htto://www.sawpa.org/meet-us/; 2012-
2013 Orange County Sanitation District Pretreatment Program Annual Report, P. 8.12). SAWPA's water
quality management program is integrated with those of other local, state, and federal agencies. For
example, SAWPA and OCSD jointly own and operate the SARI Line(2006 SARI Business Plan, p. 8).
The SARI Line is intended to provide a cost-effective, sustainable means of disposal of nonreclaimable
wastewater high in TDS for utilities and industries within SAWPA's SARI Service Area. The highest and
best use of the SARI Line is the removal of salts from the watershed, thereby expanding the ability to
reclaim water and maximizing the use of limited groundwater resources ("Brine-Line." www.sawpa.oro.
n.p. 2012. March 10, 2014, htto://www.sawpa.orcl/brine-linel). Due to the size and nature of SAWPA's
jurisdiction, an extensive collection system does not exist. SAWPA primarily has trunk lines, what it calls
"reaches." Therefore, wastewater is discharged into the SARI Line in a manner that is different from
many sewering agencies. Direct-discharge users are located close enough to the SARI Line or a reach to
construct a direct connection, and the users produce enough TDS waste to economically justify the
connection cost. Indirect users dispose of their wastewater using permitted commercial liquid waste
1
haulers (LWH), which dispose of the wastewater at one of the four SARI Line Liquid Waste Hauler
Collection Stations. The volume of wastewater generated by indirect dischargers can vary from one or
two truckloads per week to 100,000 gallons per day. Every discharger within SAWPA's SARI Service
Area is located less than 20 miles from an LWH Collection Station (2012 SAWPA Pretreatment Program
Compliance Audit Report, p. 7). The nonreclaimable wastewater from utilities and industry within
SAWPA's SARI Service Area is currently transported via the SARI Line to OCSD Treatment Plant No. 2.
After treatment by OCSD, the effluent is discharged to the Pacific Ocean. In contrast, the majority of
wastewater received at OCSD Reclamation Plant No. 1 is treated and is further processed by the
Groundwater Replenishment System (GWRS) located on the Orange County Water District's (OCWD)
property next door to OCSD. After undergoing additional treatment, the water is sent up to the Anaheim
area to recharge the groundwater aquifers. At some point in the future, the GWRS may reclaim flows
currently going to OCSD Treatment Plant No. 2 as well.
To discharge wastewater into the SARI Line legally, SAWPA must be in compliance with federal, state,
and local regulations, including the agreements between SAWPA and OCSD. The relationship between
OCSD as the CA and SAWPA as the DCA for the SARI Line is governed by the following documents or
their successors: NPDES Permit No. CA011 0604; OCSD's Wastewater Discharge Regulations; and the
agreements between OCSD and SAWPA, in particular the 1991 MOU and the 1996 Agreement. The
Agreements require SAWPA to meet certain quality criteria on wastewater strength and characteristics as
provided in OCSD's Wastewater Discharge Regulations, of which the current version is Ordinance No.
OCSD-39(Appendix D).
In addition, SAWPA is required by the Agreements to comply with certain program requirements, such as
implementing a Pretreatment Program in accordance with 40 CFR 403. OCSD considers the SAWPA
Pretreatment Program an extension and a critical part of OCSD's own Pretreatment Program. As the CA
for all wastewater discharges into its facilities, OCSD is required to have a Pretreatment Program, and,
thus, OCSD has required that SAWPA establish and implement a substantially similar or more stringent
(hereafter referred to as "substantially similar") Pretreatment Program than that of OCSD's approved
Pretreatment Program for the dischargers in its area of jurisdiction. Some major elements of the
Pretreatment Program include the issuance of permits, inspections, the collection and analysis of
samples ("monitoring"), the review of permittee self-monitoring reports, and enforcement activities, when
necessary. As the CA, OCSD has the responsibility to ensure that SAWPA complies with all applicable
Pretreatment regulations and requirements. In turn, SAWPA is required to ensure that discharges into
the SARI Line comply with all applicable regulations and requirements, including the Agreements with
OCSD.
1.2 2012 Audit Triggers
Since 2011, OCSD staff began to observe that SAWPA had violated provisions of the Agreements.
Examples include the following: SAWPA failed to do its duty when it passed along permits to OCSD for
its concurrence review that had major and obvious problems, including different company names in a
single permit, obsolete legal citations, and incorrect permit categorization. SAWPA even failed to
produce a list of permittees upon request, because it did not have such a list. The situation reached a
tipping point in early 2012.
In March 2012, OCSD became aware that SAWPA had been allowing a significant unauthorized, illegal
discharge to the SARI Line. Over a period of four months, Western Municipal Water District (WMWD)
allowed Corona Resource Recovery (CRR), who had leased the Dairy Farmers of America property, to
discharge more than 9 million gallons of mining wastewater into the Dairy Farmers of America's facility,
which discharges to the SARI Line. The mining wastewater was from Molycorp, whose facility is located
in Mountain Pass, CA near the borders of California, Nevada, and Arizona, which is outside SAWPA's
SARI Service Area. Not only was this action done with SAWPA's approval but without written approval
from OCSD as required in the 1996 Agreement, but neither SAWPA nor WMWD, despite using the same
consultant for Pretreatment work, issued the facility a permit with the correct federal category, categorical
discharge limits, and appropriate requirements as required. In addition, neither SAWPA nor WMWD
conducted due diligence by collecting samples to confirm the constituents present in the wastewater or
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inspecting the mining operation. Coincidental to this time frame, OCSD experienced higher than normal
levels of arsenic in its biosolids. A later inquiry revealed that the wastewater had been previously rejected
by an Arizona sewering agency nearer to the original source of the wastewater due to the detection of
radioactivity. Upon becoming aware of the illegal discharge and because SAWPA and WMWD failed to
permit the CRR operation properly, OCSD issued SAWPA an Order to Cease Noncompliant Discharge.
Due to the magnitude and significance of the failure to uphold the Pretreatment standards and regulations
and the violations of the Agreements that culminated in the discharge of illegal wastewater into OCSD's
facilities, OCSD exercised its right under the 1991 MOU to audit SAWPA's and its Member Agencies'
Pretreatment Programs in regards to discharges to the SARI Line. OCSD retained Environmental
Engineering and Contracting, Inc. (EEC) to perform a comprehensive audit of SAWPA's and its Member
Agencies' Pretreatment Programs between August and November of 2012. The goal was to verify that
SAWPA and any other agency having discharge rights to the SARI Line system pursuant to contracts with
SAWPA, i.e., one of SAWPA's four Member Agencies (Inland Empire Utilities Agency (IEUA), Eastern
Municipal Water District (EMWD), WMWD, and San Bernadino Valley Municipal Water District
(SBVMWD)), are adequately administering and diligently enforcing Pretreatment Programs in
conformance with federal Pretreatment regulations (40 CFR 403), the Agreements, and OCSD's
regulations, requirements, and practices.
1.3 Major 2012 Audit Findings
The audit revealed that SAWPA and its Member Agencies did not always follow required Pretreatment
Program requirements, nor did they comply with the Agreements and OCSD's Pretreatment Program.
EEC's audit report (Appendix C) identified specific findings of violations, noncompliance, deficiencies,
program effectiveness issues, and best management practices, and EEC presented recommendations to
address the various findings. The audit report was issued in November 2012 and contained 75 findings,
of which 88% were negative findings and many required further action. The Pretreatment Program
deficiencies covered the entire gamut, including problems with administration, conflict of interest
situations, oversight, permitting, monitoring, inspection, enforcement, and data management. In
particular, SAWPA lacked sufficient Pretreatment expertise and oversight to effectively manage
discharges to the SARI Line. Examples of specific findings in the Audit Report include, but were not
limited to, the following:
1. Legal Authority
a. SAWPA lacked the legal authority to exercise its authority and carry out enforcement actions
in areas under the jurisdiction of its Member and other Agencies.
b. Existing industrial user discharge permits did not reference current, valid legal documents nor
did they reference OCSD's legal authority to administer Pretreatment Programs.
2. Oversight: SAWPA failed to perform the proper monitoring of its Member Agencies'
Pretreatment Programs.
a. WMWD allowed Jurupa Community Services District(JCSD)and SBVMWD allowed the City
of San Bernadino Municipal Water Department(SBMWD)to run their own Pretreatment
Programs in violation of the 1991 MOU, and WMWD and SBVMWD did not notify OCSD of
this arrangement nor did they notify SAWPA, presumably.
b. SAWPA did not independently confirm whether inspections of industrial users were
adequately and regularly performed.
3. Agreement Provisions
a. SAWPA did not seek OCSD's approval before allowing WMWD to grant permission to an
industrial user to accept waste originating from outside the SAWPA SARI Service Area from
at least two facilities as required in the 1996 Agreement.
b. SAWPA failed to submit reports and data as required.
c. SAWPA did not perform due diligence in preparing permits for OCSD's concurrence review.
4. Conflict of Interest
a. SAWPA and two of the Member Agencies (SBVMWD and WMWD)retained the same staff
from the same consulting firm, G&G Environmental Compliance, Inc., to implement their
3
individual Pretreatment Programs. The arrangement made it impossible for SAWPA to
maintain unbiased oversight and control over these agencies.
b. SAWPA allowed Member Agencies to permit their own collection stations and desalter
facilities.
5. Permitting
a. SAWPA would not produce a list of IU permits with pertinent related information, such as the
permit basis documents and permit expiration dates.
b. Some permits were based on inaccurate and erroneous information, citations in the permits
were incorrect and outdated, incorrect categorizations were selected, the wrong permittee
name was mentioned in some sections of the permit, and the permits were not renewed in a
timely manner.
6. Monitoring
a. Monitoring of the IU facilities was deficient in terms of the amount and type of monitoring
conducted.
b. Sample points were not correctly identified or used.
7. Inspections
a. The inspections conducted at the permitted facilities were insufficient in terms of quantity and
quality.
b. Inspections are announced ahead of time; therefore, SAWPA and the Member Agencies
lacked a crucial method for independently verifying the true status of industrial user facilities
as required by 40 CFR 403.
6. Enforcement
a. Where they existed, Enforcement Response Plans(ERPs)lacked the legal authority under a
Multijurisdictional Pretreatment Agreement for SAWPA to carry out enforcement actions
against permitted facilities.
b. Required reviews of compliance data were not performed or were performed very late.
Consequently,violations were not identified, leading to a lack of enforcement actions that
should have included resampling and notification to OCSD and other regulators, such as the
RWQCB and EPA.
9. Data Management: Data management and a quality assurance and quality control program
were lacking.
10. Reporting: Despite the fact that the 1991 MOU clearly states that SAWPA must provide monthly
reports to OCSD, IEUA was the only agency submitting these reports to OCSD. Just before the
2012 SAWPA Audit, SAWPA and the other three Member Agencies resumed submitting the
reports.
11. Program Resources
a. SAWPA,WMWD, and SBVMWD lacked staff and in-house expertise that is essential for the
implementation of adequate Pretreatment Programs.
b. SAWPA and its Member Agencies did not dedicate sufficient time or resources to their
respective Pretreatment Programs as they relate to the SARI Line.
As a result of the audit, EEC recommended that major improvements be implemented at all levels of the
Pretreatment Programs to ensure SAWPA's compliance with its obligations and responsibilities and to
minimize the risk of repeated instances of significant violations. One of the recommendations in EEC's
final audit report was for SAWPA to"manage all aspects of the pretreatment program rather than
delegate permitting, monitoring, and enforcement to its member agencies."
2.0 SAWPA REMEDIAL PLAN
In accordance with the provisions of the 1991 MOU, on January 23, 2013, OCSD's Board of Directors
issued SAWPA a remedial plan, which is referred to as the SAWPA Remedial Plan (SRP, Appendix E).
The SRP contained a description of the nature of the Pretreatment Program deficiencies, an enumeration
of steps to be taken by SAWPA, and a time schedule for attaining compliance with the Pretreatment
requirements. The 2012 audit findings were symptomatic of a deficient Pretreatment Program, so initially
4
the objective of the SRP was to ensure that SAWPA addressed all deficiencies in its Pretreatment
Program by assuming control of all Pretreatment activities and by addressing the problems.
The SRP consisted of 13 Requirements (see Table 1 below), with each Requirement addressing a
deficiency or a category of deficiencies. The Requirements were arranged in a manner to allow SAWPA
sufficient time to work through them. The first Requirement addressed those findings from the 2012 Audit
that could be readily corrected. The rest of the Requirements addressed policies, procedures, data
management and QAIQC(quality assurance and quality control) both internal to the SAWPA organization
as well as with SAWPA as the oversight authority over its Member Agencies, agreement issues, and the
adequacy of resources at SAWPA necessary for implementing an effective Pretreatment Program.
Initially, the SRP Requirements focused on SAWPA developing and implementing new policies,
procedures, and practices to enhance what was already in place. However, early in the SRP
implementation phase, SAWPA informed OCSD that it did not have a Pretreatment Program. The SRP
focus then shifted from improving the SAWPA Pretreatment Program to developing a SAWPA
Pretreatment Program. (Note: If a Member or Contract Agency has its own wastewater treatment
plant(s), the Member or Contract Agency may have its own separate Pretreatment Program. The focus
here is on the SAWPA Pretreatment Program, because discharges to the SARI Line are governed by that
program.) Although the scope of the SRP changed, the method and tools for addressing the issues
remained that same. Table 1 presents the 13 Requirements and the completion status for each of them.
Table 2.1: SAWPA Remedial Plan Thirteen Requirements
Requirement Requirement
Number
1 SAWPA shall provide a response for each audit finding.
2 SAWPA shall submit a detailed plan, including a transition plan, how
SAWPA will manage the Pretreatment Program excluding the Member
Agencies. SAWPA shall establish sufficient Pretreatment Program
oversight and provide a timeline and an initial organization chart for
providing long-term staffing and consultants for ongoing and continuous
management of the program.
3 SAWPA shall settle all agreement issues with OCSD.
4 SAWPA shall settle all conflict of interest issues.
5 SAWPA shall notify OCSD which Best Management Practices (BMPs) it
will implement.
6 SAWPA shall establish sufficient Pretreatment Program oversight and
provide a timeline and a final organization chart for providing long-term
staffing for ongoing and continuous management of the program.
7 SAWPA shall update its Pretreatment Policies and Procedures.
8 SAWPA shall issue new or revised permits in accordance with the
updated Policies and Procedures. SAWPA shall identify the problem
permits and submit a separate timeline for resolving these permits.
9 SAWPA shall obtain compliance with the Pretreatment Policies and
Procedures.
10 SAWPA shall address data management issues.
11 SAWPA shall be in full compliance with all requirements.
12 SAWPA shall conduct monthly progress meetings.
13 SAWPA shall submit Quarterly Progress Reports.
"Since Febmary 21, 2014, the SAWPA Manager of Permitting and Pretreatment position is vacant,
and SAWPA is trying to fill it. Meanwhile, SAWPA created and filled a second position for a Senior
Pretreatment Compliance Specialist. The new hire started work on Febmary 27,2014.
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2.1 SAWPA Remedial Plan Gate Process and Life Cycle
With the understanding that transforming the conditions contributing to the identified deficiencies in the
SAWPA Pretreatment Program required a sustained effort, OCSD followed a systematic approach that
consisted of a framework with a sequence of project progress stages to be achieved during the SRP.
As a component of the SRP and along with the Requirements and the schedule for meeting each
requirement, OCSD employed a system of Gates. The Gate Process and Life Cycle methodology and
execution were used for Requirements 1-11 (Requirements 12 and 13 are reporting requirements). The
achievement of each project Requirement progress was marked by a decision Gate. In essence,for each
Requirement, an Entry Gate and an Exit Gate were assigned. Since Requirement 5 required only one
Gate for SAWPA to declare which BMPs it would implement, the SRP had a total of 21 Gates through
which SAWPA had to pass to complete the SRP. A Gate indicated a milestone in the SRP sequence,
where the current state of a Requirement was evaluated. For each Gate, OCSD defined the required
Deliverable for submittal, which typically consisted of one or more items.
To open a Gate, SAWPA reviewed and clarified the Deliverable with OCSD, and then SAWPA developed
a plan of action to achieve the expected Deliverable. Specific to Entry Gates, they were generally
scheduled at the 10% completion phase in the lifecycle of a Requirement. This gave SAWPA an
opportunity to develop a plan for proceeding through a particular Requirement and allowed OCSD to
make modifications to a plan and to define the Deliverable early on, hence saving SAWPA time and effort
that might be lost proceeding down the wrong track. In the same manner, Exit Gates were generally
scheduled at 90% completion to allow OCSD the opportunity to review SAWPA's progress and specify
any required course corrections before the Requirement had been deemed completed. If SAWPA
desired to open a Gate, SAWPA had to comply with the SAWPA Remedial Plan Gate Process (in
Appendix 1) and Work Breakdown Structure (WBS, in Appendix 1) and send its submittal to OCSD for
review at least one week ahead of the Gate Meeting. If all conditions for holding a Gate Meeting were
met,the Gate Meeting proceeded typically in the following manner:
1. SAWPA officially presented its submittal to OCSD and sought OCSD's approval to proceed
through the Gate.
2. OCSD asked questions about the submittal and tried to develop an understanding of what
SAWPA proposed to do or had done.
3. OCSD evaluated the situation and deliberated to determine if the conditions for passing the Gate
were met and SAWPA's submittal was satisfactory to fulfill the Deliverable requirements. The
possible Gate Meeting outcomes were as follows:
• Pass: the Requirement proceeds to the next Gate, or
• Pass with Conditions: the Requirement conditionally proceeds and SAWPA is required to
address the conditions specified, or
• Fail: the Requirement is not met and notification is sent to OCSD's Steering Committee,
Board of Directors, and General Manager for further direction.
4. OCSD announced its decision and issued a Gate Approval Report to SAWPA.
To help SAWPA attain compliance with the SRP, OCSD developed and transmitted materials to SAWPA,
including the following: a Communication Plan (Appendix H), the WBS, and a set of Deliverable
Expectations (Appendix G). At SAWPA's request, OCSD also assembled and provided information about
OCSD's Pretreatment Program, including documents related to OCSD's approved Pretreatment Program
(including OCSD's Pretreatment Program Control Documents (PPCD)) and OCSD's policies and
procedures related to administration, sampling, and inspection. OCSD also shared with SAWPA some of
its forms and example documents. In some situations due to the complexity of Deliverables, OCSD
transmitted Submittal Review Comments (SRC) or drafts of SRC to help SAWPA make the corrections
necessary or to provide guidance for developing or correcting its submittals (see Appendix J).
Noteworthy is the fact that SAWPA was not always receptive to the SRC, and in one instance, SAWPA
refused to receive OCSD's SRC. On a few occasions, a Technical Discussion was requested by SAWPA
or proposed by OCSD to discuss, in depth, the details of a Deliverable. The technical meetings
presented a forum for an open face-to-face discussion that led for a better understanding of the
Deliverable and the sharing of ideas on the best approach for SAWPA to meet the Requirement.
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2.2 SAWPA Remedial Plan Execution
Despite the change from improving an existing to developing a new SAWPA Pretreatment Program,
SAWPA generally followed the SRP. Some of SAWPA's decisions and the resources SAWPA provided
for the SRP affected the order and timing of some of the Requirements. In such cases, SAWPA
discussed the situation with OCSD, and OCSD generally accommodated SAWPA's requests. Developing
a SAWPA Pretreatment Program meant establishing the legal basis and contractual agreements between
SAWPA and its Member and Contract Agencies. It also meant addressing the key requirements of a
Pretreatment Program including:
• Establishing legal authority to implement and enforce the Pretreatment Program;
• Developing policies and procedures for permitting, inspection, sampling, reporting, enforcement,
and other activities to ensure compliance with the requirements of the Pretreatment Program
(through statute, ordinance, or contract);
• Dedicating resources and qualified personnel to implement the Pretreatment Program;
• Enforcing developed or adopted local limits;
• Developing an ERP to investigate and respond to violations in an objective and equitable manner
with pathways that are clearly defined;
• Producing a work process to continually develop and maintain an inventory of facilities that meet
the criteria of"Significant Industrial User"(SIU); and
• Developing and implementing oversight processes to ensure compliance with the SAWPA
Pretreatment Program requirements(i.e., self-accountability).
Although OCSD cooperated with SAWPA to allow SAWPA to pass as many Requirements, Gates, and
Conditions as possible before the January 17, 2014, Final Compliance Date, it became apparent to
OCSD several months before the deadline that SAWPA would not be able to successfully pass all the
Gates. OCSD advised SAWPA on several occasions that additional time was required for SAWPA to
complete all the tasks required in the SRP; however, SAWPA expressed its discontent that the SRP was
administratively burdensome despite having assured OCSD that it would do whatever is required to
establish its Pretreatment Program and regain OCSD's confidence in its management of its Pretreatment
Program. Therefore, in the spirit of cooperation, OCSD allowed SAWPA to use a Punch List to capture
discrete tasks that would be addressed after the Final Compliance Date.
By the Final Compliance Date, SAWPA passed through all 21 Gates with either a "Pass" or "Pass with
Conditions," and SAWPA successfully completed 7 of 13 SRP Requirements and 52 of 72 Gate
Conditions. The Complete Gate Overview for the entire SRP is presented in Appendix I.
OCSD issued 72 Gate Conditions and 76 Gate Notes. All Gate Conditions, Gate Notes, and outstanding
tasks were initially transferred to a "Pre-punch List" to be addressed after the SRP Final Compliance
Date. There are a total of 197 items on the Pre-punch List. SAWPA addressed and cleared many of the
items on the Pre-Punch List. OCSD collaborated with SAWPA, and OCSD issued aside letter to SAWPA
on March 13, 2014, to capture some of the understandings between the parties not otherwise
documented in the SAWPA Remedial Plan, and which addressed many more of the items on the Pre-
Punch List. Issues listed in the side letter include interpretation of definitions, practices acceptable to
OCSD, and expectations of the SAWPA Pretreatment Program. As a result of both SAWPA's and
OCSD's efforts, the final Punch List contains 14 tasks that are still open. These 14 tasks were grouped
into three categories,as shown in Table 2.2 below.
Table 2.2: Punch List Groupings
Grou Subject
A Establishment of Substantial) Similar Pretreatment Programs
B I Revision of Pretreatment Program Control Documents
C Data Management System
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The Punch List is composed of these three groupings (see Appendix K), and SAWPA and OCSD will
work to address the items on the Punch List by June 30,2014.
3.0 SAWPA PRETREATMENT PROGRAM FUTURE DEVELOPMENT AND IMPLEMENTATION
Despite SAWPA's effort to develop a new unified Pretreatment Program to address the concerns
identified during the 2012 SAWPA Audit and to meet the requirements and obligations defined by the
Agreements, not all Requirements were met in a satisfactory manner. Even with the significantly higher
level of effort that was required when the SRP focus switched from a Pretreatment Program improvement
to a Pretreatment Program development endeavor, activities throughout the SRP implementation still
proceeded in accordance with the WBS, and the SRP addressed the development of all aspects of the
SAWPA Pretreatment Program. The specific Requirements and Gates allowed close monitoring of the
various activities and ensured that Requirements were addressed according to the schedule. SAWPA
completed many activities generally within the scheduled time frame; however,due the complexity of
some Deliverables, follow up actions are required to ensure that all Requirements are fully addressed.
Issues with Requirements 2/6, 3, 7, 8, 9,and 11 are outlined below and the details were included as Gate
Conditions:
3.1 Requirements 2 and 6: Requirements 2 and 6 required SAWPA to submit a detailed plan,
including a transition plan, on how it will manage its Pretreatment Program with sufficient
resources and oversight. Unresolved issues with SAWPA's responses to date on these
requirements are described below:
SAWPA-Directed Pretreatment Program: On multiple occasions, lengthy discussions between
OCSD and SAWPA focused on the implementation aspect of the SAWPA Pretreatment Program.
OCSD's contractual agreement only recognizes the SAWPA organization and does not extend to
SAWPA's Member and Contract Agencies. As a result, OCSD holds SAWPA solely responsible
for the SAWPA Pretreatment Program under any arrangement between SAWPA and its Member
and Contract Agencies. SAWPA's compliance with all Pretreatment and agreement requirements
is the ultimate objective. The SRP was developed based on SAWPA implementing its own
Pretreatment Program and directly handling all dischargers to the SARI Line. Such a stipulation
was based, to a great extent, on the consequences of SAWPA's delegation of its responsibilities
in the past and the conflict of interest issue resulting in a significant unauthorized discharge in
2012.
To assist in defining its Pretreatment Program, SAWPA retained a consultant, Dudek, to review
the options and recommend a method for managing the SAWPA Pretreatment Program. The
study (Appendix L) recommended a "SAWPA-directed Pretreatment Program." Based on the
study, SAWPA decided to continue to manage its Pretreatment Program as it had been managing
it; however, under the SAWPA-directed Pretreatment Program, SAWPA would remain
responsible directly to OCSD but would also continue to administer its Pretreatment Program
through its Member Agencies and some Contract Agencies, with these agencies performing as
SAWPA's "boots on the ground." Such an arrangement would entail SAWPA doing some
Pretreatment work to prevent conflict of interest issues in which the Agencies permitted their own
facilities, but SAWPA would primarily direct the work of the Member and Contract Agencies.
SAWPA informed OCSD of its decision.
In addition to the four Member Agencies, SAWPA entered into a Multijurisdictional Pretreatment
Agreement with SBMWD and JCSD, rather than require the Member Agencies with jurisdiction
over SBMWD and JCSD to administer the Pretreatment Programs. SAWPA also decided to
enter into the Multijurisdictional Pretreatment Agreement (MJPA) with the Yucaipa Valley Water
District (YVWD) as a Contract Agency, although OCSD has not yet accepted any wastewater
from YVWD or accepted YVWD as a new Contract Agency.
8
Due to the complexity and the level of coordination and oversight required by SAWPA to make
the SAWPA-directed arrangement work and based on past experiences, OCSD expressed
reservations over the SAWPA-directed Pretreatment Program. SAWPA responded that it would
make the SAWPA Pretreatment Program work.
To address the present situation, OCSD defined for SAWPA six"pillars"with which SAWPA must
comply to demonstrate sufficient Pretreatment oversight. The six pillars are as follows:
• Pillar 1: SAWPA shall have clear lines of authority and accountability.
• Pillar 2: SAWPA shall have clearly-defined roles and responsibilities.
• Pillar 3: SAWPA shall provide adequate resources and qualified personnel.
• Pillar 4: SAWPA shall clearly define the jurisdictional boundaries and the Agency with
jurisdiction over each boundary.
• Pillar 5: SAWPA shall retain the right to reject unqualified personnel from working in the
SAWPA Pretreatment Program.
• Pillar 6: SAWPA shall outline recourses if a Member or Contract Agency fails to perform
or improperly performs any obligations.
The overarching objective is for SAWPA to maintain a uniform, effective, self-sustaining,
Pretreatment Program that is fully-compliant with all regulations and the Agreements. To that
end, OCSD will closely monitor how SAWPA completes the development and begins the
implementation of the SAWPA Pretreatment Program. In the future, OCSD will audit the SAWPA
Pretreatment Program to verify whether the SAWPA and the Member and Contract Agencies are
fulfilling their respective obligations and requirements and to assess whether additional
modifications are required.
Resources: To help achieve compliance, SAWPA increased its access to resources to help
develop and administer the SAWPA Pretreatment Program. SAWPA created two new positions,
including a Manager of Permitting and Pretreatment and a Senior Pretreatment Program
Specialist position, to perform Pretreatment Program-related activities. Through the MJPA,
SAWPA created the ability to access support from a Member or Contract Agency on a temporary
basis. SAWPA established two new groups, the Pretreatment Working Group and the
Pretreatment Management Team, in which SAWPA has extended an invitation for OCSD to sit in
on to provide technical support and to facilitate communication and accountability between
SAWPA and its Member and Contract Agencies. SAWPA also purchased, installed, and began
using a new Pretreatment software system, which Agencies will be able to access remotely. This
new program is currently in the startup mode, but a full implementation is expected in April 2014.
This program is the same one that OCSD will be purchasing, so OCSD and SAWPA will be able
to capitalize on data access and transfer capabilities.
Adequate resources and qualified personnel are critical requirements of any Pretreatment
Program. Therefore, OCSD directed SAWPA to obtain adequate in-house staffing and resources
to develop, maintain, and sustain the SAWPA Pretreatment Program. In addressing its staffing
needs for the SAWPA Pretreatment Program, SAWPA initially created a position of Manager of
Permitting and Pretreatment. The position was filled on July 1, 2013, after a long search by
SAWPA for a qualified Pretreatment Program manager. Before that time, SAWPA had a
consultant working on the SRP Requirements, SAWPA had weekly contact with staff from the
Member and Contract Agencies, and SAWPA was advised during Gate Meetings by two technical
experts from two Member Agencies. Before and after SAWPA recruited a Manager of Permitting
and Pretreatment, OCSD detected problems with SAWPA's ability to deliver on the SRP
Requirements and daily administration items. In particular, SAWPA still had a problem with
submitting deficient draft IU permits for OCSD's review. SAWPA's inability to produce adequate
IU permits is a serious concern for OCSD, because permits are critical control instruments, and
accurate permits are fundamental to ensuring that proper limits, conditions, and requirements are
conveyed to the permittees to limit pollutant concentrations in wastewater discharges.
9
Moreover, on February 10, 2014, SAWPA notified OCSD that the Manager of Permitting and
Pretreatment position would be vacated as of February 21, 2014; however, SAWPA also notified
OCSD that the newly-created Senior Pretreatment Program Specialist position, a field position,
would be filled on February 27, 2014. Based on a recent conversation between OCSD and
SAWPA, SAWPA does not have a deadline for replacing the Manager of Permitting and
Pretreatment, probably due in part to the specialized knowledge, skills, abilities, and experienced
required for the position.
Determining an optimal staffing level for SAWPA requires an approach that takes into
consideration SAWPA's decision for implementing a complex management arrangement while
SAWPA fulfils its mandate to ensure compliance with Pretreatment regulations and contractual
agreements. SAWPA still has much to do until it reaches the implementation stage. SAWPA
may avail itself of the opportunities to work with OCSD, the Pretreatment Management and
Working Groups, and consultants to ensure that resources are available during this critical phase
of program development and implementation, but SAWPA should aggressively pursue hiring a
new Manager of Permitting and Pretreatment and seek to maintain having both SAWPA
Pretreatment Program positions filled at all times.
Based on its decision for implementing its Pretreatment Program, SAWPA has lost two
employees in the course of one year. OCSD is very concerned about SAWPA's ability to retain
employees with experience in developing and managing Pretreatment Programs, who are able to
manage the Member and Contract Agencies, and who maintain a thorough understanding of the
agreements between SAWPA and OCSD. Continuity is vital to the successful operation of the
SAWPA Pretreatment Program and will be critical if SAWPA wishes to demonstrate that it is
capable of successfully managing the SAWPA Pretreatment Program, protect the SARI Line and
OCSD's facilities, and ultimately to regain OCSD's confidence that SAWPA is able to manage the
SAWPA Pretreatment Program. To this end, OCSD will allow SAWPA some time to complete the
development of its PPCD, to align the SAWPA Pretreatment Program with OCSD's approved
Pretreatment Program, and to demonstrate its capabilities and sustain a Pretreatment Program
long-term.
3.2 Requirement 3: Requirement 3 required SAWPA to settle all agreement issues with OCSD. As
required in the WBS, SAWPA and OCSD assembled a list of issues with the Agreements. After
many discussions, OCSD prepared and issued a"side letter"on March 13, 2014, (see Appendix
M)that served to memorialize the resolution of many of the agreement issues where they were
not clearly addressed in SAWPA's PPCD. Issues listed in the side letter include interpretation of
definitions, practices acceptable to OCSD, and expectations of the SAWPA Pretreatment
Program. The side letter also recorded OCSD's statements regarding acceptable implementation
of the Agreements, which remain in effect.
3.3 Requirement 7: Requirement 7 required SAWPA to update its Policies and Procedures. The
development of adequate, appropriate, and accurate PPCD constitutes the most important output
due to the significance of the five documents, especially the Ordinance, MJPA, and ERP in
establishing the legal basis for the SAWPA Pretreatment Program. With an established legal
basis for its Pretreatment Program and in-house staff with Pretreatment expertise, SAWPA
should have the fundamental programmatic wherewithal necessary for implementing a
Pretreatment Program and should be able to issue permits that are effective at controlling
discharges into OCSD's treatment and reclamation facilities.
SAWPA was faced with some significant challenges in this regard. Probably the biggest
challenge was its lack of a uniform PPCD, because SAWPA had relied solely on its consultant
and SAWPA's Member and Contract Agencies to manage their Pretreatment Programs.
Therefore, SAWPA had to establish a new set of PPCD. This effort entailed revising SAWPA's
current Ordinance (Appendix O); SAWPA developing and entering into a new MJPA with the
SAWPA Member and Contract Agencies(Appendix P); and developing new Policies(Appendix
Q), Procedures (Appendix S), ERP(Appendix R), and Standard Operating Procedures (SOP).
10
The PPCD are critical for establishing the legal authority and basis for the SAWPA Pretreatment
Program,which would allow SAWPA to issue industrial user(IU)discharge permits that are
accurate and enforceable. SAWPA also had to work with the Member and Contract Agencies to
develop PPCD with which all agencies would align. OCSD also informed SAWPA on multiple
occasions that the SAWPA Pretreatment Program must align with OCSD's Pretreatment
Program, because OCSD's Pretreatment Program is the approved Pretreatment Program. The
last challenge after creating the PPCD is the adoption of the PPCD through the required public
participation process.
OCSD supplied numerous SRC for SAWPA throughout the SRP, but due to modifications made
to the SAWPA Pretreatment Program and the amount of work required to draft the PPCD,
SAWPA's PPCD will be improved over time. SAWPA will be required over time to resolve the
PPCD SRC with OCSD, since SAWPA was required to address these SRC in Gate Conditions,
which were then transferred to the Punch List for completion. Furthermore, as SAWPA
implements the SAWPA Pretreatment Program, additional or revised policies and procedures will
be required. Moreover, for the SAWPA Pretreatment Program to be substantially similar to
OCSD's Pretreatment Program, SAWPA must further align its PPCD with OCSD's Pretreatment
Program, and whenever OCSD revises its PPCD, SAWPA will be required to update its PPCD to
ensure that its Pretreatment Program remains substantially similar.
3.4 Requirement 8: Requirement 8 required SAWPA to update its permits to be in accordance with
the updated Policies and Procedures; however, because SAWPA did not complete its Policies
and Procedures, SAWPA cannot revise its permits to be in complete compliance at this time.
Furthermore, despite OCSD advising SAWPA to devote sufficient time and resources to ensure
that all the permits are correct, SAWPA notified OCSD that it would only revise the permits
identified as having problems during the 2012 audit and those permits that came up for renewal
during the SRP. OCSD mentioned that SAWPA could do a blanket change to the permits by
issuing a letter amendment. Subsequently, SAWPA issued a letter amendment to all permittees
to convert all permits, effective January 2014, to SAWPA permits and to correct the most
significant deficiencies, such as outdated legal citations. SAWPA informed OCSD that it would
physically revise all the permits when they came up for renewal to avoid duplication of efforts.
Therefore, not all permits will be physically revised before 2015-2016. For most permits, SAWPA
and the Member Agency both sign the permit("dual-signature permits"); however, SAWPA alone
issues the permits to the Member and Contract Agencies whenever the Member and Contract
Agencies own the permitted facilities. In this manner, the Member and Contract Agencies can
avoid any appearance of conflict of interest.
3.5 Implementation: For Requirements 9 and 11,the actual verification by OCSD of the fulfilment of
these two Requirements was not possible, because Requirement 9 required SAWPA to
implement its policies and procedures developed during Requirement 7,and Requirement 11 was
full compliance of all the Requirements. SAWPA did open the Exit Gales for both Requirements
9 and 11, and OCSD gave a conditional approval for both Requirements based on SAWPA
addressing the Gate Conditions for these Requirements under the Punch List.
Verification by OCSD of the completion and implementation of the Deliverables and clearance of
Gate Conditions will be accomplished during a later time, such as during another audit. Without a
full implementation of the newly developed SAWPA Pretreatment Program,a determination of the
degree to which outputs and results contributed to improvements to the SAWPA Pretreatment
Program cannot be assessed accurately at this time.
4.0 FUTURE DISCUSSIONS
The SRP presented the need and the opportunity to resolve differences between OCSD and SAWPA.
Differences have arisen due to OCSD's and SAWPA's interpretation of important elements and key terms
in the 1991 MOU, 1996 Agreement, and regulations. After discussions between OCSD and SAWPA,
11
general agreements were reached on some issues, or OCSD gave SAWPA direction on some matters.
OCSD finalized and issued the side letter as described in Section 3.2 above.
There were also unresolved items. After the SRP, OCSD and SAWPA will continue to discuss and
address these items. OCSD believes that it is important to come to an agreement on the unresolved
issues as soon as possible. SAWPA was reminded that the purpose of the SRP was to return to
compliance with federal, state, and local (including OCSD)regulations and the existing 1991 MOU and
1996 Agreement between SAWPA and OCSD. In the event of a dispute between what was
accomplished during the SRP and what is written in the regulations and the 1991 MOU and 1996
Agreement,the regulations and Agreements shall prevail. One of the results of recent collaboration and
cooperation with SAWPA is the establishment of the OCSD-SAWPA Policy Committee. OCSD will
continue to work with SAWPA to address the following issues, but resolution to these items may
ultimately be carried out through the OCSD-SAWPA Policy Committee as outlined in the side letter.
4.1 YVWD as a Contract Agency: A"Contract Agency" is an Agency that is not one of the four
SAWPA Member Agencies(i.e., IEUA, EMWD,WMWD, or SBVMWD) but is under contract with
SAWPA to implement a Pretreatment Program for facilities within its jurisdictional boundaries,
which must lie within the jurisdictional boundaries of an existing Member Agency. For SAWPA to
add a new Contract Agency, SAWPA must submit a request in writing to OCSD on behalf of the
Contract Agency, SAWPA and the proposed Contract Agency must commit to and comply with
OCSD's terms and conditions, and the Contract Agency must enter into the same MJPA with
SAWPA as the existing SAWPA Member and Contract Agencies before the new Contract Agency
is allowed to participate in the SAWPA Pretreatment Program.
Currently there are two Contract Agencies, SBMWD and JCSD. Both of these Contract Agencies
were originally allowed to operate Pretreatment Programs without the knowledge and consent of
OCSD and presumably SAWPA. In violation of Section 6.0 of the 1991 MOU, two of the Member
Agencies(SBVMWD and WMWD)made arrangements directly with other agencies, SBMWD and
JCSD, respectively, so that the Contract Agencies performed the duties of the Pretreatment
Program within their respective areas. In both cases, no formal agreement, such as an
interjurisdictional agreement, was entered into by the agencies involved before the SRP. During
the SRP, when SAWPA requested to implement the SAWPA-directed Pretreatment Program,
SAWPA identified all four Member Agencies, the two Contract Agencies, and one new Contract
Agency, YVWD,as agency participants in the program. OCSD acknowledged that all three
Contract Agencies may be participants: however, in the case of YVWD,a formal request to
OCSD has not been properly fled yet, and a portion of YVWD's jurisdiction extends beyond
SAWPA's SARI Service Area. Therefore, SAWPA must complete the process before YVWD is
allowed to become a Contract Agency.
4.2 Requests for Wastewater Originating Outside SAWPA's SARI Service Area: The 1996
Agreement provision addressing wastewater originating from outside SAWPA's SARI Service
(1996 Agreement, C.24—see below)will continue to be enforced.
Limitation on Discharge. Except to the extent connections presently exist, SAWPA shall not
allow, directly or indirectly, the discharge to the SARI of any wastewater originating outside
SAWPA's SARI Service Area, unless SAWPA first obtains Districts' [OCSD's] written
approval of such discharge.
To successfully make such a request, SAWPA must first submit an out-of-area discharge request
in writing for OCSD's consideration. OCSD will make a determination and may establish
conditions for the discharge. One such condition will be that SAWPA enters into an MJPA with
the agency having jurisdiction over the area from which the discharge originates. SAWPA must
receive written approval from OCSD before accepting any wastewater from outside the SAWPA's
SARI Service Area.
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During the course of the SRP,there was much confusion about the phrase, -Except to the extent
connections presently exist."
• SAWPA interpreted the phrase to mean that facilities that were permitted before the 1996
Agreement were exempt from the prohibition for accepting wastewater from outside
SAWPA's SARI Service Area. OCSD asked SAWPA whether any such connections were
present at the eight active facilities still operating since 1996, and SAWPA did not identify any
existing connections nor operations that are active and are accepting waste from outside the
SAWPA's SARI Service Area; therefore, SAWPA is always required to notify OCSD before
allowing any facility to accept wastewater from outside SAWPA's SARI Service Area.
• SAWPA also erred in its contention that the actual physical connection point to the sewer was
exempted. As explained by OCSD and its consultant, Greg Arthur, formerly a Compliance
Officer from EPA Region IX who reviewed both OCSD's and SAWPA's Pretreatment
Programs during his 30 years at EPA, the business operation is the defining point according
to Pretreatment regulations. Once a business operation ceases, subsequent businesses are
required to comply with the existing code.
4.3 Stormwater: In accordance with the 1996 Agreement(C.28), stormwater discharges to the SARI
Line are not authorized. Until further notice from OCSD, SAWPA may implement a stormwater
policy as a means to address the stormwater provision of the 1996 Agreement. OCSD specified
that the stormwater policy must be no less stringent than OCSD's business rule for wash pads, a
copy of which was provided to SAWPA, or must require operational controls to minimize the
stormwater that is discharged. SAWPA's stormwater policy shall comply with OCSD's
specifications, or SAWPA shall strictly adhere to the 1996 Agreement.
4.4 Reclaimable Wastewater: In accordance with the 1996 Agreement(C.7), SAWPA must
demonstrate and document its good faith and reasonable efforts to minimize reclaimable
wastewater to the SARI Line. SAWPA erroneously included in its Procedures dated January 15,
2014, the following:
In some cases, reclaimable wastewater discharges were approved prior to the 1996
Agreement and currently meet the "good faith and reasonable effort"standard to minimize the
discharge to the Brine Line. This policy was verified during the 2012-2013 Remedial Plan.
SAWPA then proceeded to list 16 permittees that it believed fell under this exemption. (Note: At
lead three of the facilities did not exist before 1996.) SAWPA did discuss a few cases (e.g.,
Green River Golf Club, Stringfellow, JCSD)with OCSD to determine what the term "reasonable"
may entail, but OCSD did not make the blanket evaluation statement or give its approval for any
exemptions for permittees in existence before 1996. In fact, OCSD made it clear on multiple
occasions that the three JCSD connections, which are on the list,were problematic and needed
to be addressed. Therefore, OCSD staff has referred this matter to the OCSD General Manager
for further consideration.
4.5 Pre-approved Situations: The following items deal with pre-approved situations. OCSD and
SAWPA need to meet and discuss these matters further.
4.5.1 Requesting Data from SAWPA(1103.09, Punch List#170): OCSD is not required in
accordance with the 1991 MOU (Section 3)to seek SAWPA's approval before obtaining
data for 5-01 and Stringfellow. OCSD owns 5-01; therefore, it has a right to inspect,
handle, and obtain data from its own equipment. Stringfellow is a special situation,
because Stringfellow's permit is a negotiated permit that was the result of a negotiation
among the EPA, RWQCB, the general public, the Orange County Water District, OCSD's
Board of Directors, and OCSD staff.
4.5.2 Pre-Approved Situations (R03.08, Punch List#169): Permit renewal, modifications, or
changes in terms or conditions must normally be reviewed by OCSD for concurrence.
SAWPA has requested to discuss whether in some cases reviews may be"pre-approved,'
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i.e., reviews by OCSD would not be necessary. SAWPA cited examples, including the
following: addition of trucks to LWH permits and permit extensions which are not the fault
of the Permittee. SAWPA shall develop and submit a proposal containing scenarios with
justification for OCSD's consideration. OCSD will then meet with SAWPA to discuss the
proposal.
4.6 Substantially Similar Programs: During the 2012 Pretreatment Compliance Audit, OCSD
asked the auditors whether a DCA had to align to the CA's approved Pretreatment Program, and
the auditors responded, "Yes." Some differences may exist(e.g.,fees charged),and a DCA may
impose more stringent requirements or conditions to satisfy needs specific to its local conditions.
Therefore, the term"substantially similar' (i.e., substantially similar or more stringent than)has
been coined, and OCSD has directed SAWPA repeatedly to establish a Pretreatment Program
substantially similar to or more stringent than OCSD's Pretreatment Program. The definition of
"substantially similar'poses a challenge for determining the required degree of alignment
between OCSD's and SAWPA's programs, and agreement on this point requires further
discussion. Potential alignment issues to be discussed include frequency of inspections
performed, number of samples collected, number of sample points, etc. Without substantially
similar Pretreatment Programs, both OCSD and SAWPA are always at a significant risk when
undergoing a regulatory inspection or audit.
4.7 PPCD: See 3.3 above. Despite multiple conversations and Si sent to SAWPA, SAWPA's
PPCD still contain significant differences when compared to OCSD's approved Pretreatment
Program.
5.0 CONCLUSION
OCSD and SAWPA invested a considerable amount of time and effort in creating the SAWPA
Pretreatment Program. SAWPA decided to implement a directed Pretreatment Program, in which
SAWPA simultaneously remains responsible to OCSD at all times, while primarily coordinating, directing,
and reviewing the Pretreatment Program efforts of the Member and Contract Agencies. As a result,
OCSD expects that SAWPA will remain fully committed to the SAWPA-established framework for the
SAWPA Pretreatment Program to prevent future situations like the previous states of its permitting,
enforcement, inspection, and monitoring activities. SAWPA appears ready to maintain, improvelenhance,
and sustain all SAWPA Pretreatment Program elements established under the SRP, including
Pretreatment Program staffing and resources. In turn, OCSD will continue to oversee SAWPA's efforts
and will conduct future audits to verify that the SAWPA Pretreatment Program development is essentially
completed and that its implementation is in compliance with regulations and requirements.
SAWPA must continue to align the SAWPA Pretreatment Program with OCSD's Pretreatment Program.
Without substantially similar Pretreatment Programs, both OCSD and SAWPA are always at a significant
risk when undergoing a regulatory inspection or audit. During the SAWPA Remedial Plan, OCSD
assisted SAWPA to establish a Pretreatment Program substantially similar to OCSD's Pretreatment
Program. SAWPA must carefully fill its Manager of Pretreatment and Permitting and obtain other
necessary expert resources to help achieve the SAWPA Remedial Plan objectives and requirements in a
timely, effective, and efficient manner. If SAWPA wishes to retain a SAWPA-directed program, SAWPA
must be able to retain in-house staff to ensure that there is continuity for the SAWPA Pretreatment
Program.
Changes to the SAWPA Pretreatment Program need to be made in a manner transparent to OCSD to
ensure that the SAWPA Pretreatment Program is developed and implemented properly at all times.
OCSD will host recurring meetings regularly with SAWPA and SAWPA's Member and Contract Agencies
to help all agencies fulfil their respective duties and obligations.
Moving forward and after one year of working together on the Si OCSD and SAWPA will begin a new
chapter in their working relationship. A positive vision for a new era is envisioned by OCSD and SAWPA.
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OCSD and SAWPA desire to build a new working relationship and to implement activities to foster regular
communication, collaboration, and cooperation. The primary concerns for OCSD include the protection of
OCSD's wastewater collection, treatment, and reclamation facilities; the health and safety of its workers;
the current and future biosolids reuse; compliance with its NPDES Permit regulating discharge to the
Pacific Ocean; and the GWRS. OCSD knows that SAWPA shares similar concems through its exemplary
One Water, One Watershed planning process. Therefore, OCSD and SAWPA will commit to a new start
and a better future for all residents of the Santa Ana River Watershed.
It is important to mention that as a result of the 2012 audit and SRP implementation, the risk to OCSD
has been reduced; however, the risk may be reduced further if SAWPA and OCSD implemented the
requirements and recommendations listed below.
6.0 REQUIREMENTS AND RECOMMENDATIONS
6.1 For SAWPA:
6.1.1 SAWPA shall address the Punch List items by June 30,2014. SAWPA shall provide
progress updates to OCSD on a monthly basis. (see 2.2)
6.1.2 SAWPA shall meet approximately quarterly with OCSD to address Pretreatment Program
issues of concern.
6.2 For OCSD:
6.2.1 OCSD will provide updates to the OCSD Steering Committee on the status of the
SAWPA Pretreatment Program.
6.2.2 OCSD will conduct regular audits of the SAWPA Pretreatment Program starting in the fall
of 2014 after SAWPA has had time to implement the SAWPA Pretreatment Program,
e.g., issue some permits and conduct some enforcement activities. OCSD will audit the
SAWPA Pretreatment Program to verify whether the agencies are fulfilling their
respective obligations and requirements and to assess whether additional modifications
are required. (see 3.5)
6.2.3 OCSD will establish quarterly Pretreatment Program Coordination Meetings with SAWPA
and the Member and Contract Agencies to promote coordination, cooperation,
collaboration, and alignment of the two Pretreatment Programs.
SAWPA requested that OCSD improve its communication with SAWPA and Member and
Contract Agencies. In response, OCSD will host recurring meetings with SAWPA and
the Member and Contract Agencies to create additional opportunities for OCSD to
answer quesfions and to provide information and guidance to help the Agencies fulfil their
respective duties and obligations. OCSD will also participate in SAWPA's Pretreatment
Working Group and Pretreatment Management Team meetings.
6.2.4 OCSD will provide information on the state of SAWPA's Pretreatment Program to
SAWPA based on internal review and third party audit of the SAWPA Pretreatment
Program. OCSD will provide SAWPA advanced notice of any planned or required
changes to OCSD's approved Pretreatment Program.
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7.0 ACKNOWLEDGEMENTS
Teams from OCSD, SAWPA, and two of the Member Agencies (as technical experts) were formed
specifically for the SRP implementation. The following are the significant individuals that were involved.
7.1 SAWPA
7.1.1 SAWPA's Internal Team
• Celeste Cantu, SAWPA General Manager
• Richard E. Haller, P.E., SAWPA Executive Manager of Engineering &Operations and
SRP Project Manager for SAWPA
• Rosanna Lacarra,former SAWPA Manager of Permitting and Pretreatment
• David Ruhl, SAWPA Program Manager(SRP responses and scheduler)
• Dean Unger, SAWPA Information Systems&Technology Manager
• Carlos Quintero, SAWPA Project Manager(SAWPA Sampling Program)
• Regina Patterson, SAWPA Sr.Administrative Assistant
• Sara Villa, SAWPA Administrative Assistant II
7.1.2 SAWPA's Consultants
• Sharon Guilliams, P.E., Sharon Guilliams Engineering (SGE), Principal (Pretreatment
consultant)
• D. Michael Melts, P.E., Dudek, Principal (project and database management
consultant)
• Lisa Ohlund, Ohlund Management & Technical Services, Principal, subconsultant to
Dudek(management&technology services consultant)
• Ray P. Goebel, P.E., Manager of Operations, EOA Inc. (Pretreatment consultant)
• Kristin A. Kerr, P.E., Managing Engineer, EOA Inc. (Pretreatment consultant)
7.1.3 SAWPA's Technical Experts
• Gregg Murray, EMWD, Manager, Source Control Division
• Craig Proctor, IEUA, Pretreatment and Source Control Supervisor
7.1.4 Pretreatment Groups: representatives from the Member and Contract Agencies
• Pretreatment Management Team
• Pretreatment Working Group
7.2 OCSD
7.2.1 OCSD's Internal Team
• Jim Herberg, P.E., OCSD General Manager
• Nick Kanetis, P.E.,former OCSD Director of Engineering
• Jim Colston, Esq., OCSD Environmental Compliance Manager
• Julian F. Sabri, P.E., PMP, OCSD Engineering Supervisor
• Mark Kawamoto, P.E., OCSD Engineer and SRP Project Manager for OCSD
• Tom Gaworski, OCSD's Principal Env. Specialist and SAWPA Liaison
• Mike Zedek, P.E., OCSD Engineer(schedulerttechnical expert)
• Oanh Nguyen, OCSD Program Assistant
7.2.2 OCSD's Consultants
• Najib Saadeh, EEC, Senior Regulatory Specialist and EEC Project Manager
• Greg V. Arthur, EEC, Senior Regulatory Specialist (formerly an EPA Region IX
Compliance Officer for over 30 years)
• Jim Wybenga, Independent, (OCSD retiree,former OCSD SAWPA liaison)
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