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HomeMy WebLinkAbout2002-02-05 - AGENDA REPORTS - SANTA CLARA RIVER CHLORIDE (2)CITY OF SANTA CLARITA INTEROFFICE MEMORANDUM TO: Mevor F and Memb rs of the City Council / �� -a a FROM: eorge A! aravalh ity Manager DATE: February 5, 2002 SUBJECT: PROPOSED SANTA CLARA RIVER CHLORIDE TMDL RECOMMENDED ACTION Council receive presentation from the Los Angeles County Sanitation Districts regarding the proposed chloride TMDL for the Santa Clara River. BACKGROUND At the November 27 City Council meeting, staff was directed to invite the Regional Water Quality Control Board (Regional Board) to do a presentation to the City Council on the upcoming chloride Total Maximum Daily Load (TMDL). Based on this direction, the Regional Board was invited to attend the February 12, 2002 City Council meeting to provide a presentation on the following: a) Why a TMDL is necessary, and if there are alternatives, why they were rejected in favor of a TMDL; b) What the proposed TMDL seeks to achieve from public policy, public health, and water quality perspectives; and c) What range of costs may be expected from the implementation of the proposed TMDL. Since December 2001, staff has been working with other elected officials to help educate them on the issue and to demonstrate the City and Sanitation Districts' concerns with the chloride TMDL. The City's process and desire to elevate the TMDL discussion from a technical to a policy -based level was well received. On January 16, 2002, staff was informed by Dennis Dickerson, Executive Officer of the Regional Board, that the Regional Board declined the City's invitation. In addition, Mr. Dickerson noted that the release of the draft TMDL was delayed again, and that he expected it to be released during the week of January 22. This delay has resulted in another postponement of the Regional Board approval hearing of the chloride TMDL from February 28 to March 28. Agenda Item: /mom The purpose of this study session is for the Sanitation Districts to brief the Council on the chloride issue, including concerns and cost implications from the proposed TMDL, and for the Council to discuss future next steps. The Sanitation District attachments have been presented to the Sanitation Districts Boards 26 and 32 and provide background information on the chloride TMDL and water softeners. The Regional Board attachments are letters in response to the City's invitation. ALTERNATIVE ACTIONS No alternative actions have been identified. FISCAL IMPACT None by this action. ATTACHMENTS Los Angeles County Sanitation Districts Chloride TMDL Issue Paper Los Angeles County Sanitation Districts Water Softener Issue Paper Regional Water Quality Control Board Response Letter to decline invitation Regional Water Quality Control Board Response Letter to answer City's questions GAC:JAF:TL:sm S:/PBS/FOSSELMAN/ES/PMDLa/Chloride/2-5 SS chloride memo.doc PROPOSED SANTA CLARA RIVER CHLORIDE TOTAL MAXIMUM DAILY LOAD ISSUE PAPER JANUARY 2002 Background The Santa Clara River flows westerly approximately 45 miles with its origin east of the City of Santa Clarita in Los Angeles County and terminates at the Pacific Ocean in the City of Oxnard in Ventura County. The Los Angeles County Sanitation Districts (LACSD) own and operate the Valencia and Saugus Water Reclamation Plants (WRPs) which discharge tertiary treated wastewater effluent into reaches 7 and 8 of the Santa Clara River in the Santa Clarita Valley in northern Los Angeles County (See Figure 1). In the dry season, flow in the river essentially begins at the Saugus WRP outfall located in Reach 8 at Bouquet Canyon Road. Existing chloride water quality objectives for Reaches 7 and 8 are 100 milligrams per liter (mg/L) and were established in 1978, based on a limited assessment of existing water quality at the Los Angeles/Ventura County Line and the Old Road Hwy 99 Bridge, respectively. The 100 mg/L chloride objective was also believed to be an appropriate threshold for the protection of agriculture, the most sensitive beneficial use identified in the SCR watershed. The human health criterion for protecting drinking water (secondary Maximum Contaminant Level) is 250 mg/I for chloride. The EPA chronic, or long term average, water quality criterion for aquatic life protection is 230 mg/I for chloride, with an acute, or short term maximum, criterion of 860 mg/l. From 1979-1989, the Saugus and Valencia WRPs had no effluent limits for chlorides. Prior to 1979, the effluent limits varied from 125 up to 250 mg/I, despite there being a chloride objective of 100 mg/I for these reaches. In 1989, the WRPs were given a daily maximum, end -of -pipe limit of 100 mg/I, but because cyclic drought conditions caused potable water chloride concentrations to increase to as much as 120 mg/I, dischargers throughout the Los Angeles Region were given interim discharge limits. Originally, the interim limits were based on chloride levels in the water supply plus a reasonable loading factor; in 1997 they were set at a daily maximum of 190 mg/l. These limits expired in January 2001. In early 1997, the Regional Board directed the staff to work with stakeholders to conduct studies on the chloride level needed to protect agricultural crops grown in the watershed. Between 1997 and 2000, studies were conducted that showed that if the water quality objective for chloride were raised to 143 mg/I of chloride, even sensitive crops such as avocados would be protected. In February 2000, the Regional Board issued a staff report and draft Basin Plan amendment, proposing to raise the objective to 143 mg/I. On December 7, 2000, the Regional Board decided not to revise the chloride objective to 143 mg/I, as had been previously proposed by staff. This decision reflected Regional Board staff, s new concern that more recent data, which had been received by staff just prior to the December 7 board hearing, showed an increasing trend in chloride levels in surface waters leaving Reach 7. Regional Board staff were concerned that the trend jeopardized the ability of Reach 6 to meet its existing water quality objective of 100 mg/I, which had not been proposed to be changed. In truth, the Regional Board changed its mind based on a perceived threatened condition to water quality that in fact is part of the recurring long term cycle in the region due to the climate and associated fluctuations in the water quality of the imported water supply. Additionally, the Saugus and Valencia WRPs have complied with an interim chloride limit of 190 mg/L for 10 years with no evidence of impairment of beneficial uses within Reaches 7 and 8 or downstream of these reaches even during drought conditions. In fact, farming industry representatives have stated on many occasions that chloride concentrations are of good quality in the Santa Clara River watershed, and bumper crops of avocados have been harvested during the years with relatively high (and allegedly impaired) chloride levels (e.g. 1993 and 2001) (see Figure 2). The Chloride TMDL In the meantime, Reaches 7 and 8 of Santa Clara River were listed by the Regional Board on the 303(d) list as impaired due to chloride in 1998 because the 100 mg/1 water quality objective was not being met in these two reaches. At the time, it was thought that a Total Maximum Daily Load (TMDL) might not be necessary because the objective was being reevaluated and was expected to be reset at a higher level. However, based on the December 2000 decision not to revise the chloride objective, the Regional Board now plans to adopt a TMDL for chloride in early 2002. Although the Regional Board has not yet released the proposed TMDL for public review, staff have indicated that the likely outcome will be imposition of something in the range of 90-106 mg/I as a running annual average as an end -of -pipe concentration -based effluent limit. The TMDL may also result in permanent mass emission caps (i.e. pounds per year) on the WRPs. Regional Board staff will likely recommend a 7 or 8 -year compliance schedule for meeting these new requirements. Other discharges in the watershed are not expected to be regulated at this time, although they may contribute up to 40% of total chloride loadings. Under current law, the only way for the WRPs to reliably meet the expected new limits would be to install advanced wastewater treatment facilities and construct a brine line at a cost of approximately $370 million in capital costs' and approximately $6 million per year in annual O&M costs to upgrade treatment at the Valencia and Saugus WRPs. These upgrades include the use of reverse osmosis treatment (including a 45 -mile brine line and 3 -mile outfall for brine disposal) to remove chlorides in order to meet anticipated permit requirements. As a result of the upgrades current service rates for Santa Clarita residents would have to be increased by almost 5 -fold. The environmental consequences of reverse osmosis treatment, including the impacts of increased energy consumption and of building a brine line (the magnitude of which is considered a major public works project) along one of the last natural rivers in Southern California, which is home to a number of endangered species, have not been fully ' This cost estimate includes the $76 million in capital costs of plant construction, $247 million needed to construct a 45 -mile brine line, and $48 million to construct a 3 -mile ocean outfall to dispose of the treatment by-products. See Letter from Districts to Dennis Dickerson, Regional Board re: Comments on the June 26, 2000 Addendum to the Staff Report for the Basin Plan Amendment for the Santa Clara River Chloride Objectives at pg. 2 (July 14, 2000). -2- considered by the Regional Board. Chloride Concentrations and Sources Long-term (1990-1999) average effluent chloride concentrations at the Saugus and Valencia WRPs are 121 and 146 mg/I, respectively. However, recently average effluent chloride concentrations have risen to 147 and 163 mg/I for the Saugus and Valencia WRPs, respectively. WRP chloride levels are monitored on a monthly basis, and historically, the WRPs have experienced chloride levels as high as 178 and 198 mg/1 at the Saugus and Valencia WRPs, respectively, within the last 12 years (see Figure 3). Over time, approximately 20% of final effluent chlorides are estimated to be associated with industrial/commercial wastes and the disinfection/coagulation processes used during tertiary treatment of wastewater. Approximately 40% of final effluent chlorides are associated with the potable water supply. However, potable water supply chloride levels can rise significantly during drought periods, such as during the last drought period between 1987 and 1991, when chloride levels in imported water from the Bay -Delta tripled over non - drought conditions to reach 120 mg/I. Approximately 40% of final effluent chlorides are estimated to be associated with residential uses, which include the use of detergents and self -regenerating water softeners. The majority of the residential contribution is believed to be associated with self - regenerating water softeners. Self -regenerating water softeners, to which residents add their own salt on a regular basis so that the resins can regenerate on-site, are the type that cause the chloride loading problem. Prior to 1997, most people in the Santa Clarita Valley that had water softeners used canister -type water softeners that are regenerated at centralized off-site facilities (which are regulated through discharge permits). This is because LACSD adopted Resolutions in the early 1960s banning the discharge of brines to the sewers from water softeners, in anticipation of the long-term problems that can be caused by these highly saline discharges if released in areas where salts could build up in groundwater basins. However, in 1997, two appellate courts in California ruled that local agency bans on self -regenerating water softeners are pre-empted by a late 1970s state law regarding the operation of water softeners, and therefore such bans are invalid. LACSD has been conducting studies to try to document the contribution of these water softeners. For instance, continuous sampling for chloride in influent demonstrates a strong diurnal trend in concentrations (peak between 2 am and 6 am) which are likely to be caused by timer -controlled water softener releases. (See Figure 4) In addition, recent residential sampling within Districts 26 and 32 indicates that market penetration of self -regenerating water softeners is as high as 50-60% in neighborhoods built since 1999, which, along with increasing chloride levels in the water supply, may explain the recent increases in chloride loadings experienced by LACSD=s treatment plants. LACSD Activities To Reduce Chloride Loadings Over the past 10 years, LACSD has taken a number of steps to control industrial and commercial discharges of chloride to the sewer, including the imposition of chloride or total dissolved solids (TDS) limits in discharge permits. Many industries are also required.to monitor chloride levels on an on-going basis. In addition, LACSD routinely samples for chloride as part of our ongoing surveillance program. LACSD also has developed a brine softener inspection and outreach program for commercial entities, such as restaurants, car -3- washes, Laundromats, and hotels, which are considered likely to use self -regenerating water softeners. If discovered, on-site regenerating water softeners must be removed in accordance with LACSD , s historic brine discharge prohibition. In October 2000, LACSD modified chemical usage at the Valencia WRP to eliminate all chloride loadings from the plant except for those associated with disinfection. Chloride loadings from the Saugus WRP were modified similarly in May 2000. Chloride loadings due to disinfection at each WRP now average between 5 and 7 mg/l. As noted above, imported water supplies contribute substantially to chloride levels, especially during dry years. California has experienced drier than average conditions during 1999 - 2001, and chloride levels in imported water served in the Santa Clarita Valley have increased accordingly from about 40 mg/I to over 60 mg/l, on average. During extended drought conditions, imported water supply levels can rise as high as 120 mg/l. Additionally, residential water softeners are also a major contributor to chloride levels in wastewater. In 1999, the state law was modified to allow local agency bans to begin in 2003, but only after stringent conditions are met and only for residential water softeners added after the local agency enacts the ban. Without the option to greatly reduce or eliminate discharges of chloride from these water softeners, the very expensive reverse osmosis treatment mentioned earlier is likely to be the only viable compliance option. Proposed Solution The Regional Board should adopt a phased approach to the TMDL, in order to allow studies to be conducted that will result in a more refined water quality target, a hydrologic model for the watershed, and developing a pollution prevention approach to addressing the chloride issue, rather than mandating very expensive and environmentally unfriendly end -of - pipe treatment, that may turn out not to be necessary. Specifically, the first phase of the TMDL should focus on conducting these studies, including: a study to determine what the water quality objective should be to protect avocado crops, based on new information, a study on surface water/groundwater interactions to define the mixing that occurs, particularly in Reach 7, and public education on the availability of alternative detergents and water softeners. As part of this effort, LACSD would also consider options for regulating new residential water softeners in accordance with the California Health and Safety Code. Not until these efforts have been completed and evaluated should a final TMDL target be set and a full implementation plan be established. Draft 4, January 11, 2002 -4- WATER SOFTENERS AND CHLORIDE IN THE SANTA CLARA RIVER WATERSHED ISSUE PAPER _Why is Chloride a Problem and Where Does It Come From? The Los Angeles Regional Water Quality Control Board is responsible for setting water quality objectives to protect various uses of the waters in the region, such as aquatic life, recreation, drinking water, and agriculture. Among other things, the Regional Board set a water quality objective for chloride in the Santa Clara River from Bouquet Canyon Road down to the Los Angeles/Ventura County line of 100 milligrams per liter (mg/1) in the late 1970s. This level has been set to protect agricultural crops such as avocados. Chloride is a component of salt, and is found in source water (both local groundwater and water imported from the Sacramento Bay -Delta). Some chloride is also added or concentrated locally through municipal and industrial use of water. It then makes its way to wastewater via the sewer. Unfortunately, without extraordinarily expensive advanced treatment, normal wastewater treatment processes do not remove or reduce the level of chloride. To meet the chloride water quality objectives set to protect the Santa Clara River Watershed, the Regional Board is expected to adopt a Total Maximum Daily Load for chloride in early 2002, which is expected to result in very low discharge limits for the Sanitation Districts Saugus and Valencia Water Reclamation Plants. One of the major sources of chloride in wastewater is self -regenerating water softeners used by individual homeowners to lessen the impacts of hard water. Water that is referred to as hard has a high level of minerals, particularly calcium and magnesium carbonate, compared to softer water, the softest of which is natural rain before it hits the ground. There are a number of products available on the market today that soften hard water by reducing the high mineral levels found in hard water. These products operate on the principle of ion -exchange. There are two types of ion -exchange softeners: $ Exchange -tank water softeners: Spent resin canisters are exchanged with regenerated ones, and the spent resin canisters are taken to central locations that can treat the chlorides from the regeneration process. $ Self -regenerating water softeners: Resins are regenerated at your residence and the concentrated brine waste (containing high levels of chloride) is then discharged into the sanitary sewer system. In the mid-1990s, California courts found that local agencies were restricted from banning or imposing regulations on self -regenerating water softeners stricter than those found in state law, which allows virtually unrestricted installation of these appliances. Unfortunately, these court decisions tied the hands of local agencies, even where there are adverse water quality impacts or if the salt levels contributed -1- by water softeners posed an impediment to water recycling efforts. As a result, SB 1006 was enacted in 1999 that will take effect on January 1, 2003, which establishes conditions under which a local agency may regulate new self -regenerating water softeners. SB 1006 enacted Section 116786 of the California Health and Safety Code. This section authorizes a local agency to limit the availability, or prohibit the installation, of residential water softening or conditioning appliances that discharge to the sewer system through adoption of an ordinance, if three findings are made, substantiated by an independent study, and included in the ordinance. The findings must include the following: 1) The local agency is not in compliance with either their NPDES permit or their water reclamation requirements; 2) Limiting the availability, or prohibiting the installation, of the appliances is the only available means of achieving compliance with the permit or reclamation requirements; and 3) The local agency has adopted, and is enforcing, regulatory requirements that limit the volumes and concentrations of saline discharges from nonresidential sources to the sewer system to the extent technologically and economically feasible. The independent study must include a quantification of all sources of salinity, including residential water softening, residential consumptive use, industrial and commercial discharges, and seawater or brackish water infiltration and inflow into the sewer collection system. The study must also identify remedial actions taken to reduce the discharge of salinity into the sewer system from each sources, to the extent technologically and economically feasible, to bring the local agency into compliance with their permit requirements. The law does not specify who may conduct the independent study, nor does it require that anybody review or approve the independent study. Limitations on Public Agency Implementation of SB 1006 There are at least 4 major issues with respect to SB 1006. First, the new law requires a local agency to be out of compliance with a water quality discharge or water recycling permit in order to gain the authority to limit the availability of, or prohibit, water softeners. Local agencies with discharge or water recycling permits strive to be in compliance at all times, and are obligated to take steps to avoid Under SB 1006 (Statutes of 1999, Ch. 969), residential water softening devices installed before the effective date of the ordinance are grandfathered in. -2- noncompliance, rather than waiting until they are in noncompliance to address known problems. Furthermore, chronic noncompliance can trigger mandatory minimum penalties, as well as substantial discretionary penalties under the California Porter -Cologne Act and federal Clean Water Act. Second, only the local agency that is the permit -holder would be authorized to limit or prohibit the water softeners, and not neighboring or co -terminus agencies that might be better able to enforce a water softener ordinance (such as the City of Santa Clarita and County of Los Angeles, which overlap with Sanitation Districts 26 and 32). Third, the condition stating that limiting the availability, or prohibiting the installation, of the appliances is the only available means of achieving compliance (emphasis added) with discharge or water recycling permits is overly restrictive. This condition might require the local agency to pursue end -of -pipe treatment before being able to restrict the use of self -regenerating water softeners, even if this were clearly not cost- effective compared with a source control approach. Finally, because the law grandfathers in all water softeners installed before the effective date of the local ordinance, the problem (i.e. chloride discharge level) already created by these devices will be with us forever. Draft 4; January 24, 2002 (5:22PM) -3- c CL CL R C N To M A 7 7 R •7 H 13 O t E O U U. e 7 W C M d I aT ii Deo -01 Jun -01 Deo -00 Jun -00 Dec -99 Jun -99 Dec -98 Jun -98 Deo -97 Jun -97 Dec -96 Jun -96 Deo -95 Jun -95 Dec -94 Jun -94 Deo -93 Jun -93 Dec -92 Jun -92 Dec -91 Jun -91 Deo -90 Jun -90 Dec -89 Jun -89 Dec -88 Jun -88 Deo -87 Jun -87 Deo -86 Jun -86 Deo -85 Jun -85 Dec -84 Jun -84 Deo -83 Jun -83 Dec -82 Jun -82 Dec -81 Jun -81 Deo -80 Jun -80 Deo -79 Jun -79 Dec -78 Jun -78 Dec -77 Jun -77 Dec -76 Jun -76 Deo -75 Jul -75 Dec -74 Jul -74 Dec -73 Jul -73 Deo -72 Jul -72 Jan -72 Jul -71 Jan -71 Jul -70 0 o O p Jan -70 N N N ' ^ O 0 N ID'1/6w it x•93 ❑ ❑�❑ d • • •7 ❑ • ❑ EpE3 A 000 • c0 N CD i • �• 9 ®❑ • > v� •• ❑• 1`6 N c N v N o N 0 • • • QP M = • U 0 U W c W c ❑ ❑A : > c > 0 U 0 U LU N d a C LL L U t U d a 0 ••• E aIL c c o U 0 0 a. c r j•� •� Q p c fn � m m p� ❑ • • ❑ O + �❑ • • • • ❑ ❑• ip ❑❑ • • ❑� 8 r� go Deo -01 Jun -01 Deo -00 Jun -00 Dec -99 Jun -99 Dec -98 Jun -98 Deo -97 Jun -97 Dec -96 Jun -96 Deo -95 Jun -95 Dec -94 Jun -94 Deo -93 Jun -93 Dec -92 Jun -92 Dec -91 Jun -91 Deo -90 Jun -90 Dec -89 Jun -89 Dec -88 Jun -88 Deo -87 Jun -87 Deo -86 Jun -86 Deo -85 Jun -85 Dec -84 Jun -84 Deo -83 Jun -83 Dec -82 Jun -82 Dec -81 Jun -81 Deo -80 Jun -80 Deo -79 Jun -79 Dec -78 Jun -78 Dec -77 Jun -77 Dec -76 Jun -76 Deo -75 Jul -75 Dec -74 Jul -74 Dec -73 Jul -73 Deo -72 Jul -72 Jan -72 Jul -71 Jan -71 Jul -70 0 o O p Jan -70 N N N ' ^ O 0 N ID'1/6w LL 0 0 0 I*IAU po N O P� m h O M N 1 O WOy POPSAJNW SJVM �0& 10 SUOJJ W46A dOA3 m WNA 2001 2000 1999 1998 1997 1996 1995 1994 1993 1992 1991 1990 } 1989 1988 1987 1986 1985 1984 1983 1982 1981 1980 1 1 1 1 1 1 1 1 1 U 4 1 U 1 QU �b � 1� 1 a a s U= 1 I 1 1 1� P� m h O M N 1 O WOy POPSAJNW SJVM �0& 10 SUOJJ W46A dOA3 m WNA 2001 2000 1999 1998 1997 1996 1995 1994 1993 1992 1991 1990 } 1989 1988 1987 1986 1985 1984 1983 1982 1981 1980 .i, California Regional Water Quality Control Board Los Angeles Region Winston H. Hickox Over 50 Years Serving Coastal Los Angeles and Ventura Counties Recipient of the 2001 Environmental Leadership Award from Kee California Beautiful Gray Davis Environmental p p F Governor Environmental Protection 320 W. 4th Street,S Suite 200, Los Angeles, Californiaali90013 Phone (213) 576-6600 FAX (213) 576-6640 - Interne[ Address: hdp://www.swrcb.ca.gov/rwgcb4 January 18, 2002 Mayor Frank Ferry City of Santa Clarita 23920 Valencia Blvd. Santa Clarita, CA 91355-2196 SUBJECT: SANTA CLARA RIVER CHLORIDE TOTAL MAXIMUM DAILY LOAD; CITY COUNCIL MEETING ON FEBRUARY 12, 2002 Dear Mayor Ferry: On behalf of Chairman Nahai and members of the California Regional Water Quality Control Board, Los Angeles Region (Regional Board), I would like to thank you for your invitation to meet with the City Council of the City of Santa Clarita to discuss the forthcoming Chloride Total Maximum Daily Load (TMDL) for the Santa Clara River at the February 12, 2002 City Council Meeting. The Regional Board agrees with the Council's objectives to promote dialog between the Council and the Regional Board so that the Council gains a better understanding of the TMDL. The TMDL is now scheduled for consideration by the Regional Board on March 28, 2002 and Regional Board staff are planning extensive public outreach activities prior to the Regional Board hearing date, including a workshop to be held in Santa Clarita. The Regional Board views the planned workshops as the most appropriate forum for the City to gain a more detailed understanding of the TMDL and Regional Board staff will work with your staff to arrange a date and venue for the outreach meeting in Santa Clarita. Additionally, members of the Regional Board staff are available to appear at your convenience at the upcoming City Council meeting to provide the Council with an overview of the technical elements of the TMDL. I am confident the Regional Board staff can provide the Council with the information you are seeking. In the meantime, specific questions that you raised in your letter of January 2, 2002 are addressed in a separate letter to you. California Environmental Protection Agency **"The energy challenge facing Catlfornia is real Every CoWarnian needs to take immediate action to reduce energy consumption• ***Fora list of simple ways to reduce demand and cut your energy cosa, tee the tips m: kap://www.swmb.ca gov/news/echa/4nguhtml *** Qd Recycled Paper Our mission is to preserve and enhance the quality of California's water resources for the benefit of present and future generations. .. _... Mayor Frank Ferry - 2 - January 18, 2002 City of Santa Clarita As you note in your letter, the Santa Clara River is one of the last natural rivers in southern California. The Regional Board appreciates the City's support of endeavors to protect and enhance water quality and looks forward to a full dialog with the City on the chloride TMDL. If you wish to schedule Regional Board staff to attend the City Council meeting on February 12, 2002, or if there are any other questions, please call Jonathan Bishop at (213) 576-6622. Sincerely, Dennis A. Dickerson Executive Officer cc: Congressman Howard P. "Buck" McKeon State Senator William J. "Pete" Knight State Senator Tom McClintock Assemblyman George Runner Assemblyman Keith Richman Supervisor Zev Yarovslaysky, Chair, Los Angeles County Board of Supervisors Supervisor Michael Antonovich, Los Angeles County Board of Supervisors City of Santa Clarita City Council George Caravlho, City Manager, City of Santa Clarita James F. Stahl, Chief Engineer, Sanitation Districts of Los Angeles County California Environmental Protection Agency .".Theenergy challenge facing Catlfornia is real Every Californian needs to take immediate action to reduce energy consumption*** •-*For a list of simple ways to reduce demand and cut your energy costs, seethe Nps at. hap://www.swrcb.ca.gov/newslechallenge.html **• Qd Recycled Pope, Our mission is to preserve and enhance the quality of California's water resources for the benefit ofpresent and future generations. .` California Regional Water Quality Control Board vLos Angeles Region Winston H. Hickox Over 50 Years Serving Coastal Los Angeles and Ventura Counties Recipient of the 2001 Environmental Leadership Award from Keep California Beautiful Gray Davis Secretaryfor Governor Environmental 320 W. 4th Street, Suite 200, Los Angeles, California 90013 Protection Phone (213) 576-6600 FAX (213) 576-6640 - Internet Address: http://www.swrcb.ca.gov/mgcb4 January 18, 2002 Mayor Frank Ferry City of Santa Clarita 23920 Valencia Blvd. Santa Clarita, CA 91355-2196 SUBJECT: SANTA CLARA RIVER CHLORIDE TOTAL MAXIMUM DAILY LOAD Dear Mayor Ferry: On behalf of Chairman Nahai and the members of the California Regional Water Quality Control .Board, Los Angeles Region (Regional Board) we with to thank you for your letter of January 2, 2002 regarding the forthcoming Chloride Total Maximum Daily Load (TMDL) for the Santa Clara River at the February 12, 2002 City Council Meeting. In an accompanying letter, the Regional Board's efforts to promote dialog between the Council and the Regional Board is described, including our plans to hold an outreach meeting on the TMDL in Santa Clarita and the availability of Regional Board staff to attend the City Council meeting on February 12, 2002. The purpose of this letter is to address the specific issues that your letter of January 2, 2002 raised: Why a TMDL is necessary, and if there are alternatives, why they were reiected in favor or a TMDL. Section 303 of the Clean Water Act requires states to survey their waters and determine which waters are not meeting water quality standards. States are then required to establish the total maximum daily load of each pollutant of the water body. The Regional Board has determined that some of the upper reaches of the Santa Clara River are impaired by chloride. Consequently, both federal and state laws mandate a chloride TMDL for the Santa Clara River. As an alternative to the TMDL, the Regional Board considered raising the water quality objective for chloride in the upper reaches of the Santa Clara River. In order to raise a water quality objective, the Clean Water Act and the Porter Cologne Water Quality Control Act requires sufficient evidence that the beneficial uses of a water body will not be impaired by the water quality objective (WQO) increase. At the public hearing on December 7, 2000, the Regional Board found there was not sufficient evidence on record to ensure that the agricultural supply uses would be adequately protected by increasing the WQO for chloride in the upper reaches of the Santa Clara River. Consequently, the Regional Board ordered staff to prepare a TMDL. Prior to the hearing, there were several workshops on the issue that the City's staff and other stakeholders attended. The California Environmental Protection Agency ***The energy challenge facing California G real. Every Californian needs to take immediate action to reduce energy consumption*** **"For a list of simple ways to reduce demand and cut your energy costs, see the tips at. kup✓/www.swrcb.cmgov/new✓echallenge.html*** Recycled Paper Our mission is to preserve and enhance the quality of California's water resources for the benefit ofpresent andfumre generations. Mayor Frank Ferry - 2 - January 18, 2002 City of Santa Clarita Regional Board considered the information provided by these parties in its decision to develop a TMDL. What the proposed TMDL seeks to achieve from a public policy, public health and water quality perspectives. The proposed TMDL seeks to restore the upper Santa Clara River to its full beneficial uses, including agricultural supply. Downstream of the upper reaches of the Santa Clara River and the City of Santa Clarita, water from the River is diverted for direct irrigation of avocados. Avocado production is highly sensitive to the levels of chloride in the irrigation supply water and the proposed TMDL will restore the chloride levels in the Santa Clara River so it can be used for irrigation of salt sensitive crops. What range of costs may be expected from the implementation of the proposed TMDL The TMDL considers a range of remedies to restore and prevent further impairment of the upper reaches of the Santa Clara River, including source reduction measures and advanced treatment of the Saugus and Valencia Water Reclamation Plants effluent. Regional Board staff studies show that the cost to existing residents in Santa Clarita for the most expensive treatment options, should they be selected, are within the range of current wastewater treatment costs in California. Please note that the Regional Board will not mandate the method of compliance to achieve the TMDL requirements. As you note in your letter of January 2, 2002, the Santa Clara River is one of the last natural rivers in southern California. The Regional Board appreciates the City's support of endeavors to protect and enhance water quality and looks forward to working with the City on the chloride TMDL. If there are any questions, please call Jonathan Bishop at (213) 576-6622. Sincerely, / Dennis A. Dickerson Executive Officer cc: Congressman Howard P. "Buck" McKeon State Senator William J. "Pete" Knight State Senator Tom McClintock Assemblyman George Runner Assemblyman Keith Richman Supervisor Zev Yarovslaysky, Chair, Los Angeles County Board of Supervisors Supervisor Michael Antonovich, Los Angeles County Board of Supervisors City of Santa Clarita City Council George Caravlho, City Manager, City of Santa Clarita James F. Stahl, Chief Engineer, Sanitation Districts of Los Angeles County California Environmental Protection Agency ***The energy chattenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption *** ***For a list ofsimple ways to reduce demand and cut your energy costs, seethe tips at: hitpVlwww.swrcb.cmgov/news/echallenge.html*** 4 Recycled Paper Our mission is to preserve and enhance the quality of California's water resources for the benefit ofpresent and future generations.