Thermal Plan Exceptions

RBI served as the lead consultant for special studies conducted to support obtaining Clean Water Act Section 316(a) exceptions to California Thermal Plan temperature objectives applied in NPDES permits. Approval of the exceptions by the Central Valley Regional Water Quality Board (Regional Water Board) and fish resource agencies – California Department of Fish and Game, NOAA Fisheries, and U.S. Fish and Wildlife Service was also obtained by RBI on behalf of our clients. RBI has developed, or is currently developing, exceptions to the state Thermal Plan for the following clients:

• California Department of General Services (DGS). RBI completed a study for DGS evaluating the temperature-related effects the Central Heating and Cooling Plant discharges to the Sacramento River on migrating fish. Based on RBI’s study, its findings, and the concurrency of these findings by the fish resource agencies, the Regional Water Board issued a Thermal Plan Exception to DGS, resulting in a cost-effective solution to DGS’s temperature compliance issue. 
• Brentwood Wastewater Treatment Plant. RBI completed a study evaluating the temperature regime of Marsh Creek under the influence of the plant’s discharge and whether the regime could continue to support the indigenous aquatic life, as part of developing information to support a Thermal Plan Exception. Developed alternative temperature limitations to protect the Marsh Creek aquatic life and also resolve the temperature compliance issue. RBI facilitated concurrence of alternative temperature limitations by the fish resource agencies.

Thermal Effects Study — Sacramento Regional Wastewater Treatment Plant Discharge to the Sacramento River

Robertson-Bryan, Inc. (RBI) was the lead technical consultant in developing and implementing a study of the potential temperature-related effects of the Sacramento Regional Wastewater Treatment Plant (SRWTP) discharge on the aquatic resources of the lower Sacramento River—a study required by the SRWTP’s NPDES permit adopted by the Central Valley Regional Water Quality Control Board in 2010.  The purpose of the temperature study was to determine whether conditions in the lower Sacramento River, as regulated by the current Thermal Plan exceptions and temperature limitations in the 2010 NPDES permit, are protective of aquatic life in the Sacramento River, and to further determine if alternative requested exceptions to the Thermal Plan would be protective of aquatic life in the river.  RBI led the following activities in this study.

• Convened a Working Group of resource agency staff members from the Central Valley Regional Water Quality Control Board, U.S. Fish and Wildlife Service, National Marine Fisheries Service, and California Department of Fish and Wildlife.
• Managed and coordinated seven sub-consultants: Larry Walker Associates, Hydroacoustic Technology, Inc., FISHBIO, JD Richey, Fishery Foundation of California, Flow Science, and Daniel B. Hayes, Ph.D.
• Developed a comprehensive study design consisting of eight study elements.
• Coordinated development of a work plan to guide data collection, analyses, and reporting.
• Provided oversight of all data collection and analyses.
• Prepared the temperature study report, and coordinated and incorporated sections prepared by subconsultants.

RBI conducted consultation with federal resource agencies to secure the necessary approvals and permit to conduct the field study, which involved tracking and capturing fish, and installation and use of associated equipment.  RBI also led the presentation results to the Regional San and federal and state resource agencies.