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.