Dear Chair Esquivel:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide comments on the Draft Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California; and Toxicity Provisions, July 7, 2020 version(Toxicity Provisions). CVCWA is an association of municipalities and local agencies in the Central Valley that provide wastewater collection, wastewater treatment, clean energy, and water recycling services to millions of Californians. We have been an active partner in the development of the proposed Toxicity Provisions since their inception, and respectfully submit the following comments to further our constructive input on the proposed regulatory framework.

View Entire CVCWA Comment Letter on Toxicity Provisions here.

Dear Mr. Ceccarelli:
The Central Valley Clean Water Association (CVCWA) actively participated in the California Environmental Laboratory Accreditation Program’s (ELAP) development and review of the adopted ELAP Regulations regarding accreditation, and appreciates the opportunity to comment on the proposed ELAP Fee Structure. CVCWA is a non-profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses.

Full Letter – CVCWA Comments – Proposed Revised ELAP Fee Structure

State Water Resources Control Board


WATER CODE SECTIONS 13267 AND 13383 ORDER FOR THE DETERMINATION OF THE PRESENCE OF PER- AND POLYFLUOROALKYL SUBSTANCES AT PUBLICLY OWNED TREATMENT WORKS

ORDER WQ 2020-0015-DWQ

Pursuant to Water Code sections 13267 and 13383, the State Water Resources Control Board (State Water Board) requires you to submit information as described herein. Failure to comply with this Order may subject you to civil liability of up to $10,000 per day for each day in which the violation occurs.

Full Order – PFAS – Publicly Owned Treatment Works – Final Order

Dear Mr. Waggoner:


The Southern California Alliance of Publicly Owned Treatment Works (SCAP), Central Valley Clean
Water Association (CVCWA), Bay Area Clean Water Agencies (BACWA) and California Association of
Sanitation Agencies (CASA) appreciate the opportunity to comment on the February 2020 Draft
Supplemental Guidance: Screening and Evaluating Vapor Intrusion (Draft Supplemental Guidance)
document.

Full Letter – Comments – February 2020 Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion

CVCWA appreciates the opportunity to comment on this document and to participate
as a stakeholder providing input into the process of adopting a maximum contaminate level
(MCL) for Hexavalent Chromium. CVCWA is a non-profit association of public agencies
located within the Central Valley region that provide wastewater collection, treatment, and
water recycling services to millions of Central Valley residents and businesses. CVCWA
members have a strong commitment to the protection of municipal and domestic beneficial
uses in Central Valley waters. To provide input to the Division of Drinking Water in its
evaluation of the economic feasibility of the proposed MCL, CVCWA offers the following
comments and recommendations.

Full Article – Comments on White Paper Discussion on: Economic Feasibility Analysis in Consideration of a Hexavalent Chromium MCL dated February 2020

Dear Ms. Townsend:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide comments on the Proposed Definition of Microplastics in Drinking Water. CVCWA is a non-profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses. CVCWA members have a strong commitment to the protection of municipal and domestic beneficial uses in Central Valley waters.

Full Letter – Comments Regarding Proposed Definition of Microplastics in Drinking Water

Per- and polyfluoroalkyl substances (PFAS), including perfluorooctane sulfonic acid (PFOS) and Perfluoroocanoic Acid (PFOA), is a family of environmentally persistent substances that have been in the headlines lately and subject of a Hollywood movie, Congressional task force, California Legislative and State Water Board regulatory actions and public concern. PFAS were used extensively in the United States and globally since the 1940s with peak production years in the United States between 1970 and 2002 due to their unique ability to reduce the surface tension of liquids. PFAS chemicals are resistant to heat, water, stains, grease and oil and are found in every American household in products as diverse as non-stick cookware, furniture, clothing, dental floss, cosmetics, lubricants, paint, carpets, pizza boxes, popcorn bags, etc.  They are extremely mobile in water and can make their way to wastewater treatment plants, although this chemical is ubiquitous due to its widespread use.  The State Water Resource Control Board (SWB) is investigating the presence of PFAS in California waters and is implementing a three phased plan which requires monitoring for some PFAS compounds to better understand locations, sources and fate of PFAS to California waters[DW1] . 

Some PFASs are no longer manufactured in the United States due to a voluntary phase-out program, although it is still used in some industrial processes such as in semiconductors, printed circuits, aviation equipment, defense, pesticides, and solar panels.  Other countries still produce PFOA and PFOS and products that contain them may be imported into the United States.  There is some evidence that exposure to PFAS at certain levels can lead to adverse health outcomes in humans, while health outcomes are still largely unknown as well as the most significant pathways.

To address this concern, nationally at USEPA, and in California at departments including the SWB, Office of Environmental Health Hazard Assessment (OEHHA), the Department of Toxic Substance Control (DTSC), and the California Air Resources Board (CARB), regulatory agencies are all taking actions to protect public health.  CVCWA is monitoring actions being taken by the SWB which has to date included establishing notification levels for drinking water systems at 6.5 parts per trillion for PFOS and 5.1 parts per trillion for PFOA.  The SWB is also working with OEHHA to establish primary drinking water standards for certain PFAS compounds and is implementing its three phase PFAS investigation.

Phase 1 of the SWB’s PFAS Phased Investigative Approach included investigative orders at airports, municipal solid waste landfills and nearby drinking water systems as well as impacted drinking water sources.  Phase 2 includes primary manufacturing facilities (likely not present in California), refineries, bulk terminals and non-airport fire training areas, and 2017-18 urban wildfire areas. As the SWB is learning more and as analytical methods are being developed, the SWB is modifying its investigation.  Recently a 13267 letter was sent to chrome platers and some drinking water systems.  These letters may include a questionnaire, and typically require development and implementation of a monitoring workplan which is typically reviewed and approved by the appropriate Regional Water Board.

Currently wastewater treatment plants are identified in the third phase of the State Water Board’s investigation plan, the third phase being set to begin no earlier than mid-February 2020.  CVCWA is working with our other clean water partners (CASA – California Association of Sanitation Agencies, BACWA – Bay Area Clean Water Agencies, and SCAP – Southern California Alliance of POTWs) and SWB Staff concerning the PFAS monitoring scope at wastewater treatment plants (WWTPs).  SWB Staff is currently planning to issue 13267 letters for influent, effluent, and biosolids testing at a subset of WWTPs based on factors such as facility size, relative location to known hotspots, and proximity to sensitive watersheds. Collaborative efforts will be considered.  If your WWTP has tested for PFAS, CVCWA would like to know as it may help reduce the monitoring levels for the WWTP sector.  Please email Debbie Webster at eofficer@cvcwa.org if your WWTP has conducted PFAS monitoring.  Late this spring, the Delta Regional Monitoring Plan is set to begin monitoring for PFAS as part of its Contaminants of Emerging Concern (CEC) pilot program, which will include some WWTP monitoring as well as stormwater and ambient monitoring.

CVCWA has compiled this list of resources below to help you communicate about PFOS with your customers and stay apprised of these regulatory efforts.

Fact Sheets to help you communicate within your agency and to your customers:

State Water Board Websites for PFAS:

USEPA


The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the California Environmental Laboratory Accreditation Program’s (ELAP) Draft Emergency Regulations governing fees for the program. CVCWA is a non-profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses. We approach these matters with the perspective of balancing environmental and economic interests consistent with state and federal law.

Many of CVCWA’s member agencies operate ELAP-accredited laboratories, and pay ELAP’s fees accordingly. However, these agencies’ labs are typically smaller and have tighter budgets. Thus, fee increases for ELAP accreditation is important to the bottom line for these laboratories.

On July 16, 2019, the State Water Resources Control Board (Board) will be considering a proposed Resolution adopting an emergency regulation amending the Environmental Laboratory Accreditation Program Fee Schedules in Title 22, California Code of Regulations Section 64806, which increases fees by 20 percent. Specifically, the base/administrative charge would increase from $1,890 to $2,268, and the Field of Testing fee would increase from $851 to $1,021. CVCWA would like to express its concern regarding these large increases, the need for service performance from ELAP, the overall cost of compliance of both these fees and ELAP regulation proposals, and the need for additional stakeholder involvement in future fees. State Water Resources Control Board.

Since the Board took oversight and operation of ELAP five years ago, ELAP fees have already increased by 97 percent. The current proposal would increase the current fees by an additional 20 percent, which would equate to a total 136 percent increase in fees since ELAP moved over to the Board from the Department of Public Health (DPH). CVCWA recognizes that when this occurred the program was underfunded, and that increases in fees were both needed and expected for the program to be self-sustaining. However, despite the almost doubling of fees to date, we are still concerned that the program is still not functioning at a level needed to provide an adequate level of service both needed and expected by the laboratory community. Primarily, these service concerns surround timely accreditation renewals, including addressing the backlog of audit inspections needed for accreditation and communication between ELAP and the laboratory community when changes are made to the application or compliance process.

In addition to these large fee increases, CVCWA’s main concern continues to be the overall cost of compliance if and when new accreditation standards are adopted, and the long-term viability of our small laboratories to provide the essential support services to our treatment plants. CVCWA urges ELAP staff to continue to work with the stakeholder community and to incorporate a California quality management system that would enhance the viability of our small laboratories.

A framework for a new fee structure for ELAP has been recently presented to stakeholders on June 13, 2019. This was the first meeting to discuss a revised framework since 2017. CVCWA is supportive of the development of a new framework, but hopes that Board staff will continue to involve stakeholders in its development going forward. Relatedly, we request that Board staff publish a schedule for the fee restructuring process and opportunities for stakeholders to remain engaged.

CVCWA appreciates the opportunity to provide comments on this matter. Please contact me for any further assistance you may need at (530) 268-1338 or eofficer@cvcwa.org.

The Regional Water Board’s Tentative Order for would require Mariposa County Lake Don Pedro Wastewater Treatment Facility to submit an individual, facility-specific Salinity Management Plan. The groundwater in the area is of good quality well below the recommended secondary MCL. In addition, the source water is a combination of very low salinity surface water and low salinity groundwater. CVCWA commented that it does not believe that a Salinity Management Plan is warranted for this facility considering its specific circumstances.

Dear Mr. Palmer:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Linda County Water District’s (District) Wastewater Treatment Plant (WWTP). CVCWA is a non-profit organization representing more than 50 publicly owned treatment works throughout the Central Valley Region in regulatory matters affecting surface water discharge, land application, and water reuse. We approach these matters with a perspective to balance environmental and economic interests consistent with state and federal law.