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HomeMy WebLinkAbout2000-06-13 - AGENDA REPORTS - SCRIVER CHLORIDE STANDARD REV (2)NEW BUSINESS DATE: SUBJECT: DEPARTMENT: CITY OF SANTA CLARITA AGENDA REPORT City Manager Approval: Item to be presented b June 13, 2000 REVISION OF SANTA CLARA RIVER CHLORIDE STANDARD Planning & Building Services RECOMMENDED ACTION Receive staff report, adopt Resolution supporting the proposed amendment to the Los Angeles Regional Water Quality Control Board (RWQCB) Basin Plan's chloride objective to 143 mg/liter and designate a City Council representative to speak at the June 29, 2000, RWQCB Public Hearing. BACKGROUND On June 29, 2000 the RWQCB will be deciding whether or not to require the installation of expensive treatment upgrades to the two water reclamation plants (WRPs) in Santa Clarita. The treatment upgrades, if required, will increase residential sewer rates from approximately $112 per year to over $450 per year. The RWQCB has determined that the amount of chloride in the Santa Clara River is too high. The treatment upgrades required at the sewer plants will greatly reduce the amount of chloride that enters the River. Regional Board staff and other stakeholders have recommended raising the objective in Santa Clarita to 143 mg/L. The Sanitation Districts of Los Angeles County operate the two WRPs in Santa Clarita. The Districts have been working with RWQCB staff and other stakeholders for the past three years to develop an effective response to the RWQCB's original finding that the historical and current chloride levels in the Santa Clara River are too high. A stakeholder group made up of RWQCB, landowners, WRPs, agriculture and others was convened. This group evaluated historical surface and ground water quality data collected over the past 50 years to determine if in fact chloride levels in the Santa Clara River have changed and if the existing chloride levels are detrimental to wildlife, plants, humans and/or agriculture. This effort resulted in agreement among the stakeholders that current chloride levels in the Santa Clara River are not harmful to any "beneficial uses" of the water and that chloride levels in the River have remained virtually the same since 1975, when the Basin Plan objectives were originally established. The RWQCB staff recommended changing the acceptable level for chloride in the Santa Clara River from 100 mg/liter to 143 mg/liter. This was agreed upon by a consensus of the stakeholders over the course of three years of meetings. The proposed increase for the chloride objective in the Basin Plan was necessary to account for the utilization of new sampling locations by the RWQCB. The original 100 mg/L chloride objective was based on water quality data collected at the Los Angeles/Ventura County line and The Old Road/Hwy 99 monitoring stations, both of which are well downstream from the respective WRP discharge points. In 1996, the RWQCB's water samples used for the impairment determination were taken much closer to the WRP discharge points, which resulted in higher readings for chloride. The chloride readings at the County line are virtually the same as they were in 1975. The RWQCB is aware of these data and understand that water quality in the Santa Clara River has not substantially changed. The issue the RWQCB members are struggling with is the perception of a degradation of water quality that is associated with raising the Basin Plan objective. The Board is under pressure from Heal the Bay, Bay Keeper, and Natural Resource Defense Counsel to avoid setting a precedent of "degrading water quality" through increasing the allowable concentration of a chemical in a water body. These groups are not concerned with the scientific analysis that shows that chloride levels in the Santa Clara River are virtually the same today as they were in 1975 and that an objective of 143 mg/liter is still protective of the most sensitive beneficial uses of the surface water (avocados and strawberries). The RWQCB staff has also determined that the citizens of Santa Clarita can afford to have their sewer rates quadrupled, based on a boilerplate EPA affordability analysis. However, this analysis does not consider whether or not quadrupling sewer rates would provide any benefits; it only considers the ability of Santa Clarita residents to pay for the cost of the advanced treatment necessary to meet current chloride objectives. Staff feels that the RWQCB will likely impose the requirement to upgrade the WRPs at the June 29, 2000 public hearing due to pressure from the environmental community. The City should be prepared to comment at the public hearing on behalf of the citizens of Santa Clarita regarding the fact that the expensive treatment that would be required does not provide any quantifiable benefits for the citizens of Santa Clarita, agricultural uses or the environment and is not warranted for the protection of beneficial uses of the Santa Clara River. ALTERNATIVE ACTIONS 1. City Council support continuance of the existing Basin Plan chloride objective of 100 mg/liter and support implementation of costly treatment upgrades at the WRPs. 2. Other actions determined by the City Council. FISCAL IMPACT Significant fiscal impact to the citizens will result if the RWQCB chooses to keep the water quality objective for chloride at 100 mg/liter. This fiscal impact would include: 1) the cost to upgrade the treatments at both the Saugus and Valencia WRPs (significant capital and O&M costs, $136 million and $7.7 million, respectively) and 2) the cost to residents of the City of Santa Clarita that would quadruple existing sewer service rates. The only direct impact to the City's budget would be for increased sewer service charges for City facilities. ATTACHMENTS Resolution No. Detailed Explanation of Chloride History AJR: S: \ PBS \ENVSRVCS\NPDES2\tmdl\ CitySCChloridelA.doc Detailed Explanation of Chloride History In 1998, the portion of the Santa Clara River between Bouquet Canyon Road in Santa Clarita and the Los Angeles/Ventura County Line was identified by the RWQCB as impaired due to high chloride concentrations in the water. The Sanitation Districts disagreed with the RWQCB's determination based on the following: 1) there was no evidence that the most sensitive beneficial use (specifically the agricultural use) was impaired in either Los Angeles or Ventura County; 2) the original chloride objective, established in 1975, was incorrectly set (overly restrictive) and did not accurately reflect water quality conditions near the discharge of the Valencia and Saugus Water Reclamation Plants (WRPs); 3) the Santa Clara River chloride concentrations at the Los Angeles/Ventura County Line have remained virtually the same for the past 30 years and; 4) the RWQCB's impairment determination did not use all available water quality data. Based on these concerns, the State Water Resources Control Board (SWRCB) overturned the RWQCB's decision of impairment. However, subsequent to the SWRCB's decision, the U.S. Environmental Protection Agency (EPA), using the same incomplete water quality data set as the RWQCB, determined that the Santa Clara River was impaired due to chloride. As a result of the EPA's decision, in 1999, the Sanitation Districts filed a Notice of Intent to sue EPA based on authorization received from the Boards of Directors for County Sanitation Districts 26 and 32. The consequence of EPA's impairment decision is that chloride concentrations discharged from the Saugus and Valencia WRPs would have to be significantly reduced in order to comply with the original chloride standard of 100 mg/L. In order to attain the needed reduction in effluent chloride concentrations, upgrades in treatment at both the Saugus and Valencia WRPs would be required at significant capital and annual operation and maintenance costs ($136 million and $7.7 million per year, respectively). In addition to the treatment upgrades, the construction of a 30 -mile brine line from the WRPs to the ocean would be required (included in the cost estimate). The upgrade to the WRPs would quadruple existing sewer service rates to Santa Clarita residents, and would not result in any tangible benefit in water quality or to the downstream agricultural uses. EPA's action of identifying the Santa Clara River as impaired resulted in a review of water quality conditions in the Santa Clara River Watershed by stakeholders (including agriculture representatives, wastewater management agencies and water purveyors) as part of the RWQCB's on-going Chloride Drought Policy Workshops. The studies conducted by various stakeholders (including the Sanitation Districts) showed that both surface water and ground water chloride concentrations were protective of agricultural uses within the watershed and have remained virtually the same for the past 30 years. At the conclusion of these stakeholder studies, the RWQCB staff recommended that the Los Angeles Basin Plan be amended to raise the chloride objective from 100 mg/L to 143 mg/L, and to implement a monitoring assessment program so that changes in river and ground water quality conditions can be more effectively evaluated. On April 13, 2000, the RWQCB held a public hearing on the proposed amendment to the Basin Plan. Also considered at the hearing was a Tentative Resolution that recognized that residential self -regenerating water softeners are a significant contributor to chlorides and encouraged local agencies to take appropriate actions to control contamination due to self - regenerating water softeners.' The Basin Plan amendment was supported by the Chloride Drought Policy Workshop stakeholders (including agriculture representatives, wastewater management agencies, and water purveyors) who were present and testified at the public hearing. The only opposition to the proposed Basin Plan amendment came from three environmental groups (Friends of the Santa Clara River, Heal the Bay and the Santa Monica Baykeeper). Two of the groups, Heal the Bay and the Santa Monica Baykeeper, testified at the hearing. They opposed the revision of the chloride objective on the basis that: 1) the RWQCB had conducted an analysis that demonstrated the community of Santa Clarita could afford the necessary treatment plant upgrades to meet the original chloride objective of 100 mg/L and 2) relaxing a Basin Plan objective would establish an undesirable precedent. Because of this testimony by the environmental groups, the RWQCB did not approve the recommendation to revise the chloride objective. Instead, a decision was postponed until the June 29, 2000 Board meeting.z This additional time was provided so that RWQCB staff could respond to the environmental groups' concerns and investigate whether the cost estimates for treatment plant upgrades provided by the Sanitation Districts are accurate. The Sanitation Districts are currently in the process of updating the cost estimates for WRP upgrades and evaluating the affordability analysis performed by the RWQCB staff. Based on the outcome of the April 13, 2000 RWQCB hearing, it is recommended that the Santa Clarita community show their support of the revised chloride objective at the June 29, 2000, RWQCB public hearing. If the proposed Basin Plan Amendment is not adopted, significant and costly treatment upgrades will have to be provided for the Valencia and Saugus WRPs, with no apparent environmental benefit. Even if the amendment is adopted, the issue of water softeners remains and it will be necessary to work with the Sanitation Districts to come up with a plan of action. ' Representatives from the POTW community present at the public hearing testified to the Board that the water softener resolution was virtually meaningless since, by law, there are severe restrictions on regulating the use of water softeners. 2 The agenda for the June 29, 2000, RWQCB public hearing has not yet been finalized. It is possible that the amendment to the Basin Plan's chloride objective may be heard at RWQCB Public Hearing earlier in June.