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Regulatory Compliance Services, Multiple SFMTA Facilities, San Francisco  

AEW was retained by the SFMTA to develop corrective actions in response to exceedence of pH in industrial wastewater discharging to SFPUC's combined sewer system at a bus maintenance facility and to prepare regulatory compliance plans for various SFMTA's facilities in the San Francisco Bay, California.  Such plans included hazardous material business plans, spill prevention control and countermeasures plans, and underground storage plan monitoring plans.  AEW conducted the following key activities to identify, assist implementing, and monitor the effectiveness of corrective action in response to the pH in the discharge of the industrial waste water exceeding the SFPUC's sewer discharge limit at a bus maintenance facility:

  • Reviewed previous monitoring results on pH exceedence
  • Developed an understanding how the industrial wastewater was generated and flow direction and volume
  • Reviewed current operations of the pre-treatment system
  • Evaluated and identified potential sources causing the pH exceedance and pre-treatment corrective action alternatives
  • Conducted a bench scale and pilot study
  • Developed and implemented a real-time pH monitoring protocols at the treatment system and discharge point
  • Prepared and implemented a corrective action plan. 

AEW prepared HMBPs, SPCCPs, and UST Monitoring Plans for multiple facilities.  Key activities performed included:

  • Conducted a site visit and an interview of personnel at each facility
  • Performed chemical inventory stored at each facility
  • Identified the chemicals that would be subject to be included in the compliance plans
  • Prepared the appropriate regulatory agency's required forms for each plan
  • Identified and developed appropriate monitoring, inspection, and emergency response protocols
  • Identified spill prevention control and countermeasures protocols.