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Basin Plan Amendment to Establish SF Bay Mercury Water Quality Objectives and Revised TMDL

Basin Plan Amendment to Establish SF Bay Mercury Water Quality Objectives and Revised TMDL. August 9, 2006 Adoption Hearing Carrie Austin Thomas Mumley. Presentation Overview. Basin Plan amendment New water quality objectives TMDL revisions Key comments Changes in response to comments

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Basin Plan Amendment to Establish SF Bay Mercury Water Quality Objectives and Revised TMDL

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  1. Basin Plan Amendment to Establish SF Bay Mercury Water Quality Objectives and Revised TMDL August 9, 2006 Adoption Hearing Carrie Austin Thomas Mumley

  2. Presentation Overview • Basin Plan amendment • New water quality objectives • TMDL revisions • Key comments • Changes in response to comments • Remand and response

  3. History • TMDL and Implementation Plan adopted by Water Board (Sept. 2004) • State Water Board remand (Sept. 2005) • Water Board Testimony Hearing (June 2006)

  4. PROPOSED Water Quality Objectives in SF Bay 0.2 ppm mercury in large predator fish 0.03 ppm mercuryin prey fish California least tern

  5. Revisions to TMDL • Reduction in wastewater wasteload allocation

  6. NPDES Permits Sources, Loads, and Allocations

  7. Sources, Loads, and Allocations

  8. Key Comments • U.S. EPA support • Wastewater – reducing allocations • Pollutant offsets • CEQA and regulatory analysis • Wastewater – enforceable limits

  9. Implementation of Wastewater Wasteload Allocations • Combination of numeric and narrative effluent limitations • Consistent with but more stringentthan 2004 • Individual wasteload allocations  enforceable limits

  10. Enforcement of Effluent Limitations • Individual numeric annual mass limits • Enforcement tied to aggregate allocation • Consistent with wasteload allocations • Individual numeric triggers • Immediate corrective action • Narrative requirements

  11. Key Changes Made in Response to Comments • Board Member Comments: • Removed urban runoff “deemed in compliance” • Clarified “methylmercury” issues • Wastewater to conduct methylmercury studies • Adaptive Implementation – new evidence – may justify a methylmercury TMDL or allocations

  12. Key Changes Made - continued - • Written Comments: • Implement corrective actions when a trigger is exceeded • Board will pursue enforcement

  13. Remand • Wastewater allocations should reflect best pollution prevention and treatment • Require methylmercury monitoring • Clarify consistency with dredge disposal Long Term Management Strategy

  14. Remand, continued • Inventory and prioritize legacy sources • Address risk reduction concerns • Revise wildlife target • Resolve USEPA concern with outdated water quality objective

  15. Other Approaches • Considerable time and effort for no water quality benefit • More technical and regulatory analyses • New public notice • May compromise other components • Special studies • Risk reduction

  16. Benefits of our Approach • Reflects and promotes discharger collaboration to solve mercury problem, address risk, and other impairments • Triggers ensure immediate individual accountability and corrective action • Allows for adaptive implementation

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