ATTACHMENT 5. ATTACHMENT C-2 ECONOMIC ANALYSIS...TABLE OF CONTENTS Central Valley Salt and Nitrate Management Plan Central Valley Regional Water Quality Control Board Larry Walker

ATTACHMENT 5. ATTACHMENT C-2 ECONOMIC ANALYSIS

O C T O B E R 2 0 1 6

Central Valley Salt and Nitrate Management

Plan Economic Analysis

submitted by

TABLE OF CONTENTS

Central Valley Salt and Nitrate Management Plan Central Valley Regional Water Quality Control Board

Larry Walker Associates Economic Analysis i

1 INTRODUCTION ................................................................................................................................................. 1

1.1 Background .............................................................................................................................. 1 1.2 Purpose and Need for this Document....................................................................................... 2 1.3 Scope of Assessment ............................................................................................................... 3

2 REGULATORY REQUIREMENTS ..................................................................................................................... 4

2.1 Introduction............................................................................................................................... 4 2.2 Federal Laws, Plans, Policies, and Regulations ....................................................................... 4

2.2.1 Federal Antidegradation Policy ............................................................................................... 4 2.2.2 Federal Antidegradation Guidance ......................................................................................... 5

2.3 State Laws, Plans, Policies, and Regulations........................................................................... 6 2.3.1 State Antidegradation Policy and Guidance ........................................................................... 6 2.3.2 State Laws, Regulations, Plans, and Policies for Economic Analyses ................................... 8

3 REGULATORY SETTING/BASELINE CONDITION ........................................................................................ 13

3.1 Regional Board Programs of Implementation ......................................................................... 13 3.2 Regulation of Waste Discharges in the Central Valley ........................................................... 21 3.3 Surface water ......................................................................................................................... 22

3.3.1 Wastewater........................................................................................................................... 22 3.3.2 Stormwater ........................................................................................................................... 25 3.3.3 Agriculture............................................................................................................................. 31

3.4 Groundwater........................................................................................................................... 31 3.4.1 Wastewater........................................................................................................................... 31 3.4.2 Stormwater ........................................................................................................................... 35 3.4.3 Agriculture............................................................................................................................. 35

4 WATER QUALITY SETTING ............................................................................................................................ 40

4.1 Introduction............................................................................................................................. 40 4.2 Existing Surface Water Quality ............................................................................................... 44

4.2.1 Surface Water Body Impairments ......................................................................................... 44 4.2.2 Ambient Surface Water Quality Conditions........................................................................... 48

4.3 Existing Groundwater Quality ................................................................................................. 62 4.3.1 Basin and Subbasin Boundaries........................................................................................... 62 4.3.2 High Resolution Mapping for the Central Valley SNMP ........................................................ 63

5 PROPOSED PROJECT AND NO PROJECT ALTERNATIVE ......................................................................... 67

5.1 Proposed Project .................................................................................................................... 67 5.1.1 Groundwater Management Areas......................................................................................... 68 5.1.2 Permitting and Management Strategies................................................................................ 70 5.1.3 Policies and Guidance .......................................................................................................... 75

5.2 No Project Alternative............................................................................................................. 84 6 ECONOMIC ANALYSIS ................................................................................................................................... 86

6.1 Introduction............................................................................................................................. 86 6.2 No Project............................................................................................................................... 87

6.2.1 Future Regulatory Environment ............................................................................................ 87 6.2.2 Projected Future Economic Impacts of Not Controlling Salinity ............................................ 89

6.3 Proposed Project .................................................................................................................... 93

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Larry Walker Associates Economic Analysis 2

6.3.1 Drinking Water Solutions – Assessment Assumptions and Methodology ............................. 98 6.3.2 Short-Term Drinking Water Solutions ................................................................................. 101 6.3.3 Long-Term Drinking Water Solutions .................................................................................. 102 6.3.4 Long-Term Nitrate Management......................................................................................... 105 6.3.5 Long-Term Salt Management: Regional Brine Line ............................................................ 122 6.3.6 Description of Economic Costs Attributable to Individual CV-SALTS Policies, Strategies, and

Guida ce ............................................................................................................................................ 129 6.4 SNM P Valley-Wide Surveillance and Monitoring Program ................................................... 161

n

7 REFERENCES ................................................................................................................................................ 163

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TABLES

Table 1: Tulare Lake Basin Groundwater Quality Objectives for Salinity. ................................................... 21

Table 2: 303(d) Listed Water Bodies for Select Pollutants in Region 5....................................................... 46

Table 3: Selected Monitoring Sites used to Characterize Surface Water Quality in Region 5. ................... 52

Table 4: Summary of Watershed Sanitary Survey Information for Select Parameters................................ 54

Table 5: Summary of Surface Water Quality Data available through the California Environmental Data Exchange Network (CEDEN) for Constituents with Secondary MCL Standards. ................................ 60

Table 6: Aggregate (Volume-Weighted) Ambient Conditions for Nitrate and TDS in Groundwater. ........... 65

Table 7: Direct Annual Economic Impacts by the Year 2030 (Howitt et al., 2009). ..................................... 92

Table 8: Total Cumulative Economic Impacts by the Year 2030 (Howitt et al., 2009)................................. 93

Table 9: CV-SALTS Polices, Strategies, and Guidance and their Associated Actions that Produce Economic Impacts............................................................................................................................... 96

Table 10: Bottled Water Supply Estimated Costs for the Alta Irrigation District. ....................................... 101

Table 11: Bottled Water Supply Estimated Costs for Areas of the Central Valley with Elevated Nitrate Concentrations in Groundwater. ....................................................................................................... 102

Table 12: Community Water System Estimated Costs for the Alta Irrigation District Using Different Treatment Technologies for Nitrate Removal.................................................................................... 103

Table 13: Community Water System Estimated Costs for Areas in the Central Valley with Elevated Nitrate Concentrations in Groundwater. ....................................................................................................... 104

Table 14: Point-of-Use Treatment System Estimated Costs for the Alta Irrigation District........................ 105

Table 15: Point-of-Use Treatment System Estimated Costs for Areas in the Central Valley with Elevated Nitrate Concentrations in Groundwater. ............................................................................................ 105

Table 16: Number of Extraction and Injection Wells Assumed for Long-Term Nitrate Management in the Dinuba and Cutler-Orosi Areas (LSCE, 2016b)................................................................................. 109

Table 17: Dinuba Area Daily Treated Volumes under Different Management Plans (LSCE, 2016b). ....... 111

Table 18: Summary of Dinuba Pump-Treat-Reinject Simulation Results (LSCE, 2016b). ........................ 111

Table 19: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Dinuba Area (Restoration Plan B).......................................................................................................................... 114

Table 20: Cutler-Orosi Daily Treated Volumes under Different Management Plans (LSCE, 2016b) ........ 114

Table 21: Summary of Cutler-Orosi Pump-Treat-Reinject Simulation Results (LSCE, 2016b). ................ 116

Table 22: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Cutler-Orosi Area (Restoration Plan B).......................................................................................................................... 116

Table 23: Number of Extraction Wells and Injection Wells Assumed for Long-Term Nitrate Management in the Entire Alta Irrigation District (LSCE, 2016b). ............................................................................... 117

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Table 24: Alta Irrigation District Daily Treated Volumes under Different Management Plans (LSCE, 2016b). .......................................................................................................................................................... 117

Table 25: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Entire Alta Irrigation District (Restoration Plan B). .............................................................................................. 118

Table 26: Estimates for Number of Wells and Treated Volumes Required for Long-Term Nitrate Management in the Alta Irrigation District and Projections for the Central Valley.............................. 120

Table 27: Central Valley Daily Treated Volumes under Different Management Plans. ............................. 121

Table 28: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Central Valley (Restoration Plan B).......................................................................................................................... 121

Table 29: Long-Term Salinity Management Plan – Summary of Estimated Costs.................................... 128

Table 30: Estimated Costs to Meet Groundwater Management Zone Policy Requirements and Options. 132

Table 31: Estimated Costs to Meet Nitrate Permitting Strategy Requirements and Options..................... 137

Table 32: Estimated Costs to Meet Salinity Management Strategy Requirements. .................................. 141

Table 33: Estimated Costs to Meet Exceptions Policy Revision Requirements and Options.................... 146

Table 34: Estimated Costs to Meet AGR Policy Requirements for Development of a Site-Specific Objective. .......................................................................................................................................... 148

Table 35: Estimated Costs to Meet Salinity Variance Program Revision Requirements for Surface Water Dischargers. ...................................................................................................................................... 151

Table 36: Example Estimated Costs to Meet Offsets Policy Requirements. ............................................. 154

Table 37: Estimated Costs to Meet Drought Policy Requirements for Surface Water Dischargers. ......... 157

Table 38: Estimated Costs to Meet Secondary MCLs Guidance Requirements and Options................... 160

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FIGURES

Figure 1: Main Central Valley Hydrologic Regions and Surrounding Geography........................................ 42

Figure 2: Central Valley Surface Water Flows. ........................................................................................... 43

Figure 3: Central Valley Groundwater Basins (DWR Bulletin 118; DWR, 2015a). ...................................... 44

Figure 4: 303(d) Listed Water Bodies for Select Pollutants. ....................................................................... 47

Figure 5: CEDEN and USGS Monitoring Locations in Region 5 Where Data are collected for Salts, Nitrate, and Constituents with Secondary MCLs. ............................................................................................ 50

Figure 6: Selected CEDEN and USGS Monitoring Sites used to Characterize Surface Water Quality in Region 5.............................................................................................................................................. 51

Figure 7: DWR Bulletin 118 Groundwater Basins/Subbasins in the Central Valley Floor. .......................... 64

Figure 8: Areas in Alta Irrigation District with Groundwater Nitrate Concentrations ≥ 10.1 (red areas) and ≥ 7.5 mg/L as N (orange plus red areas) in the Upper or Lower Zones (excludes cities with populations > 5,000 (groundwater nitrate concentration data taken from CV-SALTS, 2016c). .............................. 99

Figure 9: Areas in the Central Valley with Groundwater Nitrate Concentrations ≥ 10.0 (red areas) and ≥ 7.5 mg/L as N (orange plus red areas) in the Upper or Lower Zones (excludes cities with populations > 5,000 (groundwater nitrate concentration data taken from CV-SALTS, 2016c). ............................ 100

Figure 10: Alta Irrigation District Pilot Study Area (CV-SALTS, 2016b) .................................................... 107

Figure 11: Pump-Treat-Reinject and Recharge Subareas in the Alta Irrigation District (LSCE, 2016b).... 108

Figure 12: Extraction and Injection Wells in the Dinuba and Cutler-Orosi Areas for the Aggressive Restoration Modeling Scenario (LSCE, 2016b)................................................................................. 110

Figure 13: Dinuba Area Time-Series Plots of Simulated Nitrate Concentrations under Different Restoration Plans (LSCE, 2016b) ....................................................................................................................... 112

Figure 14: Cutler-Orosi Area Time-Series Plots of Simulated Nitrate Concentrations under Different Restoration Plans (LSCE, 2016b). .................................................................................................... 115

Figure 15: On-Farm Recharge Time-Series Plots of Simulated Nitrate Concentrations under Different Restoration Plans (LSCE, 2016b). .................................................................................................... 119

Figure 16: Potential Alignment for the Central Valley Brine Line (CV-SALTS, 2014)................................ 126

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APPENDICES

APPENDIX A. Impaired Surface Water Bodies in Region 5

APPENDIX B. Surface Water Quality Characterization

APPENDIX C. San Joaquin River Average EC by Water Year Type (CV-SALTS, 2015)

APPENDIX D. Summary of High Resolution Groundwater Quality for the Central Valley SNMP (CV-SALTS, 2016c)

APPENDIX E. Estimated Costs for Bottled Water

APPENDIX F. Estimated Costs for Community Water Systems

APPENDIX G. Estimated Costs for Point-of-Use Systems

APPENDIX H. Estimated Costs for Long-Term Nitrate Management

APPENDIX I. Estimated Costs for Long-Term Salinity Management

APPENDIX J. Estimated Hours to Complete Regulatory Documents and Technical Studies Required Under the SNMP

APPENDIX K. Estimated Annual Sampling and Analysis Costs for Secondary MCL Monitoring in the Central Valley


Larry Walker Associates Economic Analysis v

Acronyms and Abbreviations

µg/L microgram per liter

ACP Alternative Compliance Plan

AGR agricultural supply

AID Alta Irrigation District

BAT Best Available Technology Economically Acheivable

BCT Best Conventional Pollutant Control Technology

Board Central Valley Regional Water Quality Control Board (CVRWQCB)

BOD Biochemical oxygen demand

BMPs best management practices

BPA Basin Plan Amendment

CCR California Code of Regulations

CEDEN California Environmental Data Exchange Network

Central Valley Water Board

Central Valley Regional Water Quality Control Board (CVRWQCB)

CEQA California Environmental Quality Act

CTR California Toxics Rule

CV-SALTS Central Valley Salinity Alternatives for Long-term Sustainability Initiative

CWA Clean Water Act

Delta Sacramento-San Joaquin Delta

diam diameter

DWR Department of Water Resources

EC electrical conductivity

EIR environmental impact report

ELGs Effluent Limitation Guidelines

ft/sec feet per second

gpd gallons per day

gpm gallons per minute

GQMP grounwater quality management plan

GSAs Groundwater Sustainable Agencies

IAZ Intial Analysis Zone

IGP Industrial General Permit

ILRP Irrigated Lands Regulatory Program



IX ion exchange

LAAs land application areas

LSCE Luhdorff & Scalmanini Consulting Engineers

LWA Larry Walker Associates

LSJR Lower San Joaquin River

MBAs foaming agents

MCL maximum contaminant level

MEP maximum extent practicable

MGD million gallons per day

mg/L milligram per liter

MTBE Methyl-tert-butyl ether

MUN municipal and domestic supply

N nitrogen

NALs numeric action levels

NIMS Nitrate Implemenation Measures Study

NPDES National Pollutant Discharge Elimination System

NTU Nephelometric turbidity units

NWIS National Water Information System

O&M operations and maintenance

OWTS onsite wastewater treatment systems

P&O prioritization and optimization

POU point-of-use

PTS pump, treat, and serve

Regional Water Board Central Valley Regional Water Quality Control Board (CVRWQCB)

RMP Rrpresentative monitoring program

RO reverse osmisis

SAMP surveillance and monitoring program

SED substitute environmental document

SGMA Sustainable Groundwater Management Act

SIP State Implementation Policy

SMCL secondary maximum contaminant level

SNMP Salt and Nitrate Management Plan

sq mi square mile

SQMP surface water quality management plan

SRSJB Sacramento River and San Joaquin Basin



SRSJR Basin Plan Water Quality Control Plan for the Sacramento River and San Joaquin River Basins

SRWP Sacramento River Watershed Program

SSALTS Strategic Salt Accumulation Land and Transportation Study

SSOs site specific objectives

State Board State Water Resources Control Board

State Water Board State Water Resources Control Board

STORET EPA STOrage and RETreival

SWMP storm water management plan

SWPPP storm water pollution prevention plan

SWRCB State Water Resources Control Board

TBELs Technology-based effluent limitations

TDS total dissolved solids

TLB Basin Plan Water Quality Control Plan for the Tulare Lake Basin

TMDL total maximum daily load

T & O taste and odor

TSD Technical Support Document for Water Quality-Based Toxics Control

TSS total suspended solids

U.S. EPA United States Environmental Protection Agency

USGS United States Geological Survey

UTS under-the-sink

UV ultra violet

WDRs waste discharge requirements

WLA waste load allocations

WQBEL water quality-based effluent limitation

WQP Water Quality Portal

WQLS water quality limited segment

WQO water quality objective

WWTP wastewater treatment plant

yrs years

Central Valley Salt and Nitrate Management Plan Central Valley RegionalWater Quality ControlBoard


1 INTRODUCTION

1.1 BACKGROUND

Elevated salt and nitrate concentrations in portions of California’s Central Valley impair, or threaten to impair, the region’s water and soil quality. Such impairment, in turn, threatens agricultural productivity and/or the region’s drinking water supplies. The Central Valley Salinity Alternatives for Long-Term Sustainability initiative (CV-SALTS), began in 2006 as a coalition of representatives from agriculture, cities, industry, water supply, environmental justice, state and federal regulatory agencies and the public to develop an environmentally and economically sustainable plan for the management of salt and nitrate in the Central Valley.

As a part of this overarching effort, CV-SALTS is assisting with the development of a Salt and Nitrate Management Plan (SNMP) for the entirety of the Central Valley Regional Water Quality Control Board’s (Central Valley Water Board) jurisdictional area (referred to herein as “Central Valley” or “Region 5”) (CV-SALTS, 2016a). The SNMP builds on a range of water quality management policies and mechanisms already in existence and proposes additional policies and tools needed to provide the Central Valley Water Board with flexibility in addressing legacy and ongoing loading of salt and nitrate in the diverse region. The SNMP presents a comprehensive regulatory and programmatic approach for the sustainable management of salt and nitrate in ground and surface water (CV-SALTS, 2016a).

Although broader in overall scope, the SNMP also was developed to meet requirements set forth in the State Water Resources Control Board (State Board) Recycled Water Policy (CV-SALTS, 2016a). The purpose of the Recycled Water Policy is to increase the use of recycled water from municipal wastewater sources in a manner that implements state and federal water quality laws. Policy implementation is intended to encourage the use of recycled water, stormwater, water conservation, conjunctive use of surface and groundwater, and improve the use of local water supplies. The Recycled Water Policy also requires the development of salt and nutrient management plans for each groundwater basin in California.

In order to achieve the goals established by CV-SALTS for the Central Valley, the SNMP must not only address the requirements of the Recycled Water Policy but also address legacy and ongoing salt and nitrate accumulation concerns. To address these concerns, implementation of this SNMP is built on achieving the following prioritized Central Valley Region management goals for salt and nitrate:

Goal 1: Ensuring a safe drinking water supply for all residents in the valley;

Goal 2: Balancing salt and nitrate loading to eliminate further degradation where reasonable and feasible; and

Goal 3: Implementing management restoration where reasonable and feasible

These management goals recognize the need to focus limited resources first on health risks associated with unsafe drinking water. Subsequent but important goals that will require longer

Commented [A1]: Provides no justification or explanation as to why non‐salinity secondary MCLs are needed to be included.

Commented [A2]: Why is this limited to the valley and not the entire Central Valley region where it will be applied?



implementation timelines include balancing salt and nitrate loading and restoring water quality where reasonable and feasible.

1.2 PURPOSE AND NEED FOR THIS DOCUMENT

In order to facilitate implementation of the SNMP, CV-SALTS is recommending a number of new policies, regulatory tools, and clarifications to the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins and the Water Quality Control Plan for the Tulare Lake Basin (Basin Plans). The SNMP and related policies (included as attachments A1- A11 to the SNMP) will be adopted, by the Central Valley Water Board, as references within and/or amendments to the Basin Plans (BPAs). The Central Valley Water Board amends its Basin Plans through a structured process involving peer review (as necessary), public participation, and environmental and regulatory reviews.

There are four requirements related to economic considerations that the Central Valley Water Board must consider when adopting a BPA. Each of these requirements are discussed in additional detail in Section 2.3.2.

The first legal requirement is stated in Water Code section 13141, which requires that, prior to implementation of any agricultural water quality control program, the Central Valley Water Board must include an estimated cost of such a program, together with an identification of potential sources of funding, in the Basin Plan.

The second requirement is stated in Water Code section 13241(d), which requires that the Central Valley Water Board consider economics when establishing water quality objectives.

The third requirement is stated in Water Code section 13242 which requires the Central Valley Water Board to develop a program of implementation for achieving water quality objectives. The costs of some of the actions that will be required of regulated dischargers with implementation of the new policies, strategies, and guidance can be estimated, along with the cost of the surveillance and monitoring program necessary to determine compliance with objectives.

The fourth requirement is stated in Public Resources Code section 21159, which requires the Central Valley Water Board, when adopting an amendment that will require the installation of pollution control equipment or is a performance standard or treatment requirement, to include an environmental analysis of the reasonably foreseeable methods of compliance. This environmental analysis is required to take into account a reasonable range of environmental, economic, and technical factors, population and geographic areas, and specific sites.

This document presents the results of the economic analysis of the proposed SNMP and related policies. Given the geographic extent of the area in which the SNMP will be implemented, this analysis is a programmatic assessment of potential costs. Subsequent project‐level analyses will

Commented [A3]: As these policies would be applied over time, how will the Regional Board identify the economic impacts?



need to be performed by the local agencies that will implement projects resulting from the SNMP. This analysis is for the reasonably foreseeable cost impacts associated with the reasonably foreseeable actions to be implemented, based on information developed for the SNMP. The analysis ensures that the fiscal impacts associated with implementing the SNMP and related policies within the Central Valley are consistent with the Federal and state requirements.

1.3 SCOPE OF ASSESSMENT

Based on the requirements listed above for considering economics when adopting a Basin Plan Amendment, an evaluation was performed with regard to the economic costs that likely are to occur with adoption of the proposed SNMP and supporting policies, strategies, and guidance. As a preface to the economic analysis, it was necessary to document the federal and state regulatory requirements with respect to economic considerations that the Central Valley Water Board is obliged to follow. It was also necessary to document the baseline regulatory setting under which dischargers in the Central Valley are currently regulated. It is this baseline regulatory setting upon which any new requirements included in the proposed Basin Plan Amendment would either be added or substituted. A baseline water quality setting was prepared to provide a summary level understanding of ambient water quality in the Central Valley for salts, nitrate, and constituents with a secondary maximum contaminant level (SMCL) objective. A summary of the SNMP’s policies, strategies, and guidance, along with various options contained therein, was developed to describe the Proposed Project that would be implemented with adoption of the Basin Plan Amendment for the Sacramento River and San Joaquin River Basins and the Tulare Lake Basin. A description of the No Project Alternative was also developed; it describes the future regulatory setting under which dischargers will be regulated if the SNMP and related policies, strategies, and guidance are not adopted.

Using the various summaries described above as background, an economic analysis was conducted to provide planning level cost estimates for short- and long-term actions to address nitrate contamination of groundwater, long-term actions to address salinity management, and a collection of discharge-specific technical studies, regulatory documents, and monitoring programs required by the SNMP and its related policies, strategies, and guidance. Where supporting information was not available to develop a quantitative cost estimate, a qualitative estimate is provided. This report also contains a summary of future changes in the Central Valley’s regional economy that are anticipated to could occur under increasing salinity loading to surface and groundwater absent the adoption of the proposed SNMP.

Commented [A4]: Insufficient analysis was provided for SMCLs.



2 REGULATORY REQUIREMENTS

2.1 INTRODUCTION

This section summarizes the current federal and state laws, plans, policies, and regulations that relate to the economic analyses that will be conducted for the development, adoption, and implementation of the proposed Central Valley SNMP and associated Basin Plan Amendment. Federal and state antidegradation policies are discussed to the extent that their implementation requires consideration of economic and social impacts.

2.2 FEDERAL LAWS, PLANS, POLICIES, AND REGULATIONS

The following section discusses federal laws, plans, policies, and regulations relevant to the antidegradation analyses that will be conducted for the proposed Central Valley SNMP and associated Basin Plan amendment. The federal policy and guidance is applicable to the waters of the United States in the Central Valley.

2.2.1 Federal Antidegradation Policy

The federal Clean Water Act (CWA) requires states to adopt, with United States Environmental Protection Agency (U.S. EPA) approval, water quality standards applicable to all intrastate waters (33 U.S.C. § 1313). U.S. EPA regulations also require state water quality standard submittals to include an antidegradation policy to protect beneficial uses and prevent further degradation of high quality waters (33 U.S.C. § 1313(d)(4)(B); 40 C.F.R. § 131.12). In general, the Federal Antidegradation Policy emphasizes the maintenance of existing ambient conditions. The Federal Antidegradation Policy considers lowering of water quality to be allowable in some cases, including those where the costs of control would cause widespread and substantial economic and social impacts.

The Federal Antidegradation Policy is designed to protect existing uses and the level of water quality necessary to protect existing uses, and provide protection for higher quality and outstanding national resource waters. The federal policy directs states to develop and adopt a statewide Antidegradation Policy that is consistent with the following:

(1) Existing in-stream water uses and the level of water quality necessary to protect the existing uses shall be maintained and protected.

(2) Where the quality of the waters exceeds levels necessary to support the protection and propagation of fish, shellfish, and wildlife and recreation in and on the water, that quality shall be maintained and protected unless the State finds, after full satisfaction of the intergovernmental coordination and public participation provisions of the State's continuing planning process, that allowing lower water quality is necessary to accommodate important economic or social development in the area in which the waters are located. In allowing such degradation or lower water quality, the State shall assure water quality adequate to protect existing uses fully. Further, the State shall assure that there shall be achieved the highest statutory and regulatory requirements for all new and



existing point sources and all cost-effective and reasonable best management practices for nonpoint source control.

(i) The State may identify waters for the protections described in paragraph (a)(2) of this section on a parameter-by-parameter basis or on a water body-by-water body basis. Where the State identifies waters for antidegradation protection on a water body-by-water body basis, the State shall provide an opportunity for public involvement in any decisions about whether the protections described in paragraph (a)(2) of this section will be afforded to a water body, and the factors considered when making those decisions. Further, the State shall not exclude a water body from the protections described in paragraph (a)(2) of this section solely because water quality does not exceed levels necessary to support all of the uses specified in section 101(a)(2) of the Act.

(ii) Before allowing any lowering of high water quality, pursuant to paragraph (a)(2) of this section, the State shall find, after an analysis of alternatives, that such a lowering is necessary to accommodate important economic or social development in the area in which the waters are located. The analysis of alternatives shall evaluate a range of practicable alternatives that would prevent or lessen the degradation associated with the proposed activity. When the analysis of alternatives identifies one or more practicable alternatives, the State shall only find that a lowering is necessary if one such alternative is selected for implementation.

(3) Where high quality waters constitute an outstanding National resource, such as waters of National and State parks and wildlife refuges and waters of exceptional recreational or ecological significance, that water quality shall be maintained and protected.

(4) In those cases where potential water quality impairment associated with a thermal discharge is involved, the Antidegradation Policy and implementing method shall be consistent with Section 316 of the Act. (40 C.F.R. § 131.12)

2.2.2 Federal Antidegradation Guidance

In 1985, U.S. EPA issued guidance for antidegradation (Questions and Answers on: Antidegradation, U.S. EPA, 1985)1,2. This document provides guidance on the Antidegradation Policy component of water quality standards and its application, including a question and answer format to present information about the origin of the policy, the meaning of various terms, and its application in both general terms and in specific examples. While nonpoint source activities are not exempt from the provisions of the Antidegradation Policy, the document notes “additional

1 https://nepis.epa.gov/Exe/ZyPDF.cgi/200137AI.PDF?Dockey=200137AI.PDF 2 This document was designated as Appendix A to Chapter 2 – General Program Guidance (antidegradation) of the Water Quality Standards Handbook, December 1983.



guidance will be developed concerning the application of the Antidegradation Policy as it affects pollution from nonpoint sources”3.

Based on guidance developed by U.S. EPA, Region 9 (Guidance on Implementing the Antidegradation Provisions of 40 C.F.R. § 131.12 (U.S. EPA, 1987) and guidance issued by the State Water Resources Control Board (State Water Board) with regard to application of the Federal Antidegradation Policy (Memorandum from William R. Attwater to Regional Board Executive Officers Federal Antidegradation Policy (Attwater, 1987)) application of the Federal Antidegradation Policy is triggered by a lowering, or potential lowering, of surface water quality.

The Sacramento River, the San Joaquin River, Tulare Lake, and the San Francisco Bay/Sacramento-San Joaquin Delta Estuary are not designated outstanding national resource waters; therefore, the receiving waters are not subject to that portion of the federal policy. The application to other portions of the policy is determined on a case-by-case and constituent-by- constituent basis. For water bodies that do not presently attain water quality standards, permitted discharges must maintain existing water quality.

For waters with quality that is better than necessary to support beneficial uses, a permitted discharge may not lower water quality unless such lowering is necessary to accommodate important economic or social development. In August 2005, U.S. EPA issued a memorandum discussing antidegradation reviews and significance thresholds (Memorandum from Ephraim S. King, Director, Office of Science and Technology, U.S. EPA, Office of Water to Water Management Division Directors, Regions 1-10 (King, 2005). As discussed in the memorandum, an intent of the policy “is to maintain and protect high quality waters and not to allow for any degradation beyond a de minimis level without having made a demonstration, with opportunity for public input, that such lowering is necessary and important” (King, 2005). U.S. EPA and key stakeholders reached consensus on a significance threshold value of a 10% reduction in available assimilative capacity, coupled with a cumulative cap. USEPA further noted that this approach is “workable and protective in identifying those significant lowerings of water quality that should receive a full . . . antidegradation review, including public participation” (King, 2005). This determination by U.S. EPA is helpful in establishing the magnitude of water quality change that is considered to be of significant interest in the antidegradation analysis.

2.3 STATE LAWS, PLANS, POLICIES, AND REGULATIONS

The following sections discuss state laws, plans, policies, and regulations relevant to the economic analyses that will be conducted for the proposed Central Valley SNMP and associated Basin Plan amendment. Again, the implementation of State Antidegradation Policy is discussed to the extent that it requires consideration of economic and social impacts.

2.3.1 State Antidegradation Policy and Guidance

The State’s Antidegradation Policy is embodied in State Water Board Resolution 68-16 (Statement of Policy with Respect to Maintaining High Quality Waters in California). In

3 Response to question #14 (page 6)



general, the policy emphasizes the protection of high quality waters. Such protection is bounded by actions that are consistent with maximum benefit to the people of the State and best practicable treatment or control (BPTC) of the discharge. Unlike the Federal Antidegradation Policy, which applies only to surface waters that are waters of the U.S., the state policy applies to waters of the state, which is defined to mean, “any surface water or groundwater, including saline waters, within the boundaries of the state.” (Wat. Code, § 13050(e).)

Resolution No. 68-16

The State issued its Antidegradation Policy in 1968 to protect and maintain existing water quality in California4. The State’s Resolution 68-16 predates the Federal Antidegradation Policy and satisfies the federal regulation requiring states to adopt their own antidegradation policies. It states, in part:

(1) Whenever the existing quality of water is better than the quality established in policies as of the date on which such policies become effective, such existing high quality will be maintained until it has been demonstrated to the State that any change will be consistent with maximum benefit to the people of the State, will not unreasonably affect present and anticipated beneficial uses of such water and will not result in water quality less than that prescribed in the policies.

(2) Any activity which produces or may produce a waste or increased volume or concentration of waste and which discharges or proposes to discharge to existing high quality water will be required to meet waste discharge requirements which will result in the best practicable treatment or control of the discharge necessary to assure that (a) a pollution or nuisance will not occur and (b) the highest water quality consistent with maximum benefit to the people of the State will be maintained.

Administrative Procedures Update 90-004

The State Water Board issued guidance (APU 90-004) to all Regional Water Boards in 1990 regarding the implementation of State and federal antidegradation policies in NPDES permits5

(SWRCB, 1990). Using this guidance, Regional Water Boards are to determine if an NPDES discharge is consistent with the intent and purpose of the policies.

APU 90-004 provides guidance on the appropriate level of analysis that may be necessary, distinguishing between the need for a “simple” antidegradation analysis and a “complete” antidegradation analysis. If it is determined that a simple analysis is not appropriate based on the estimated level of impact of a discharge, then a more rigorous analysis – a complete analysis – is appropriate. A primary focus of an antidegradation analysis is the determination of whether and the degree to which water quality is lowered. This determination greatly influences the level of

4 The State Water Board is reviewing Resolution No. 68-16 to improve the usefulness of the Antidegradation Policy as a tool for making informed decisions regarding discharges that affect groundwater in California. Once the review is complete, State Board staff will consider what additional guidance or regulatory action is recommended. 5 Administrative Procedures Update 90-004 applies to discharges regulated under the federal Clean Water Act’s NPDES program. Asociacion de Gente Unida por el Agua v. Central Valley Water Board, supra, 210 Cal.App.4th at 1270.



analysis required and the level of scrutiny applied to the “balancing test” – that is, whether the discharge is necessary to accommodate important economic and social development, and whether a water quality change is consistent with maximum benefit to the people of the State.

An antidegradation analysis must address the following questions stated in State Water Board APU 90-004 to maintain consistency with State and federal antidegradation policies6.

Whether a reduction in water quality will be spatially localized or limited with respect to

the water body; e.g., confined to the mixing zone;

Whether a discharge of treated effluent will produce minor effects which will not result in a significant reduction of water quality;

Whether a discharge of treated effluent has been approved in a General Plan, or similar growth and development policy document, and has been adequately subjected to the environmental analysis required in an environmental impact report (EIR) or substitute environmental document (SED) required under CEQA; and

Whether the Proposed Project is consistent with maximum benefit to the people of the

State.

2.3.2 State Laws, Regulations, Plans, and Policies for Economic Analyses

California Water Code

The (Wat. Code § 7 and related sections) is California’s statutory authority for the protection of water quality.

The Water Code (Wat. Code § 13000) requires the Regional Water Board to adopt water quality policies, plans, and objectives that ensure beneficial uses of the State are reasonably protected, considering the various demands. The language states (in part):

……The Legislature further finds and declares that activities and factors which may affect the quality of the waters of the state shall be regulated to attain the highest water quality which is reasonable, considering all demands being made and to be made on those waters and the total values involved, beneficial and detrimental, economic and social, tangible and intangible…….

The Water Code also requires that the Regional Water Board consider economics when adopting new water quality objectives, developing a program of implementation for achieving water quality objectives, or requiring the implementation of any agricultural water quality program. In considering economics, the Regional Water Board is required to examine three statutory

6 Once a permit is adopted with specific effluent limitations and maximum permitted flow, antidegradation is satisfied for discharge at those effluent limitations and maximum permitted flow.



provisions as they relate to actions contained within a proposed Basin Plan Amendment (BPA). These statutory provisions include the following:

Wat. Code § 13141 requires that, prior to the implementation of any agricultural water

quality control program, the Regional Water Board must have an estimated cost of such a program. The language states:

State policy for water quality control adopted or revised in accordance with the provisions of this article, and regional water quality control plans approved or revised in accordance with Section 13245, shall become a part of the California Water Plan effective when such state policy for water quality control, and such regional water quality control plans have been reported to the Legislature at any session thereof.

However, prior to implementation of any agricultural water quality control program, an estimate of the total cost of such a program, together with an identification of potential sources of financing, shall be indicated in any regional water quality control plan.

Wat. Code §13241(d) requires that the Regional Water Board consider economics when

establishing water quality objectives. The language of section 13241 in its entirety states:

Each regional board shall establish such water quality objectives in water quality control plans as in its judgment will ensure the reasonable protection of beneficial uses and the prevention of nuisance; however, it is recognized that it may be possible for the quality of water to be changed to some degree without unreasonably affecting beneficial uses. Factors to be considered by a regional board in establishing water quality objectives shall include, but not necessarily be limited to, all of the following:

a) Past, present, and probable future beneficial uses of water. b) Environmental characteristics of the hydrographic unit under

consideration, including the quality of water available thereto. c) Water quality conditions that could reasonably be achieved through the

coordinated control of all factors which affect water quality in the area. d) Economic considerations. e) The need for developing housing within the region. f) The need to develop and use recycled water.

In addition, Wat. Code §13263 recognizes that “(a) The regional board, after any necessary hearing, shall prescribe requirements as to the nature of any proposed discharge, existing discharge, or material change in an existing discharge, except discharges into a community sewer system, with relation to the conditions existing in the disposal area or receiving waters upon, or into which, the discharge is made or proposed. The requirements shall implement any relevant water quality control plans that have been adopted, and shall take into consideration the beneficial uses to be protected, the water



quality objectives reasonably required for that purpose, other waste discharges, the need to prevent nuisance, and the provisions of Section 13241”.

Wat. Code §13242 requires that the Regional Water Board develop a program of

implementation for achieving water quality objectives. The language states:

The program of implementation for achieving water quality objectives shall include, but not be limited to:

(a) A description of the nature of actions which are necessary to achieve the objectives, including recommendations for appropriate action by any entity, public or private.

(b) A time schedule for the actions to be taken.

(c) A description of surveillance to be undertaken to determine compliance with objectives.

Public Resources Code

The Public Resources Code §21159 requires that the Regional Water Board when adopting a BPA that includes installation of pollution control equipment, or a performance standard or treatment requirement, including a rule or regulation that requires the installation of pollution control equipment or a performance standard or treatment requirement pursuant to the California Global Warming Solutions Act of 2006 (Division 25.5 (commencing with Section 38500) of the Health and Safety Code), to conduct an environmental analysis of the reasonably foreseeable methods of compliance. This environmental analysis is required to take into account a reasonable range of environmental, economic, and technical factors, population and geographical areas, and specific sites. The language states:

a) An agency listed in Section 21159.4 shall perform, at the time of the adoption of a rule or

regulation requiring the installation of pollution control equipment, or a performance standard or treatment requirement, including a rule or regulation that requires the installation of pollution control equipment or a performance standard or treatment requirement pursuant to the California Global Warming Solutions Act of 2006 (Division 25.5 (commencing with Section 38500) of the Health and Safety Code), an environmental analysis of the reasonably foreseeable methods of compliance. In the preparation of this analysis, the agency may utilize numerical ranges or averages where specific data is not available; however, the agency shall not be required to engage in speculation or conjecture. The environmental analysis shall, at minimum, include all of the following [emphasis added]:

1) An analysis of the reasonably foreseeable environmental impacts of the methods of compliance.

2) An analysis of reasonably foreseeable feasible mitigation measures. 3) An analysis of reasonably foreseeable alternative means of compliance with the

rule or regulation.



4) For a rule or regulation that requires the installation of pollution control equipment adopted pursuant to the California Global Warming Solutions Act of 2006 (Division 25.5 (commencing with Section 38500) of the Health and Safety Code), the analysis shall also include reasonably foreseeable greenhouse gas emission impacts of compliance with the rule or regulation.

b) The preparation of an environmental impact report at the time of adopting a rule or regulation pursuant to this division shall be deemed to satisfy the requirements of this section.

c) The environmental analysis shall take into account a reasonable range of environmental, economic, and technical factors, population and geographic areas, and specific sites.

d) This section does not require the agency to conduct a project-level analysis. e) For purposes of this article, the term "performance standard" includes process or raw

material changes or product reformulation. f) This section is not intended, and may not be used, to delay the adoption of any rule or

regulation for which an analysis is required to be performed pursuant to this section.

State Water Resources Control Board and Regional Water Board Resolutions and Guidance

In September 2012, the California Legislature adopted Assembly Bill 685, which added section 106.3 to the Water Code (effective January 1, 2013), declaring that every human has the right to clean, affordable, and accessible water for consumption, cooking and sanitary purposes (generally referred to as the human right to water). The section states:

(a) It is hereby declared to be the established policy of the state that every human being has the right to safe, clean, affordable, and accessible water adequate for human consumption, cooking, and sanitary purposes.

(b) All relevant state agencies, including the department, the state board, and the State Department of Public Health, shall consider this state policy when revising, adopting, or establishing policies, regulations, and grant criteria when those policies, regulations, and criteria are pertinent to the uses of water described in this section.

(c) This section does not expand any obligation of the state to provide water or to require the expenditure of additional resources to develop water infrastructure beyond the obligations that may exist pursuant to subdivision (b).

(d) This section shall not apply to water supplies for new development.

(e) The implementation of this section shall not infringe on the rights or responsibilities of any public water system.

Consistent with Wat. Code section 106.3, in February 2016, the State Water Board adopted Resolution No. 2016-0010, which established the human right to water as a core value and provided direction and guidance to the Water Boards to ensure consistency in the manner in which the right is considered in certain board actions. This guidance included [emphasis added]:



10. Encourages Water Board staff to consider existing law and policies that may be relevant to assessing water safety, cleanliness, affordability, accessibility, adequacy, and sustainability, such as those referred to in recitals 7-14, when considering the human right to water.

In addition and, consistent with Wat. Code § 106.3, the Regional Water Board adopted Resolution No. R5-2016-0018 in April 2016, which established the human right to water as a core value and top priority within the region. The Resolution also provided direction to Regional Water Board Staff to ensure consistency in the manner in which the right is considered in certain board actions. This direction included [emphasis added]:

10. Encourages Central Valley Water Board staff to consider existing law and policies that may be relevant to assessing water safety, cleanliness, affordability, accessibility, adequacy, and sustainability, such as those referred to in recitals 7-11, when considering the human right to water.

11. Directs Central Valley Water Board staff to develop policies that allow for and incentivize local and regional efforts for providing replacement water where appropriate while long-term water quality solutions are developed and implemented.

Based on guidance issued by the State Water Board with regard to application of the Federal Antidegradation Policy (Attwater, 1987) the policy requires that reductions in water quality be justified as necessary to accommodate important social and economic development. Although USEPA has provided relatively little guidance on how this part of the test should be applies, this part of the Federal Antidegradation Policy may best be viewed as a balancing test. The greater the impact on water quality, the greater the justification in terms of economic or social development necessary to justify the change. In fact, the State has some flexibility to determine what kinds of impacts constitute “important economic or social development” that may justify changes in water quality.

Commented [A5]: The approach of the Attachment A‐9 SMCL guidance does not provide consistency with this Resolution.

Commented [A6]: It is important to include all of these considerations in the evaluations to fully address the value of preventing impacts to MUN.



3 REGULATORY SETTING/BASELINE CONDITION

3.1 REGIONAL BOARD PROGRAMS OF IMPLEMENTATION

The Porter-Cologne Water Quality Control Act requires that every basin plan consist of beneficial uses, water quality objectives, and a program of implementation for achieving water quality objectives {Wat. Code § 13050(j)}. According to the Act, the implementation program for a basin plan must include:

1. A description of the nature of actions which are necessary to achieve the objectives,

including recommendations for appropriate action by any entity, public or private;

2. A time schedule for the actions to be taken; and,

3. A description of surveillance to be undertaken to determine compliance with the objectives. {Wat. Code § 13242}

The actions taken by the Regional Water Board to achieve water quality objectives (see item 1 above) include all of the following:

1. Identifying potential water quality problems;

2. Confirming and characterizing water quality problems through assessments of source,

frequency, duration, extent, fate, and severity;

3. Remedying water quality problems through imposing or enforcing appropriate measures;

4. Monitoring problem areas to assess effectiveness of the remedial measures.

Whatever actions that the Regional Water Board implements must be consistent with the Basin Plan’s beneficial uses and water quality objectives, as well as polices, plans, agreements, prohibitions, guidance, and other restrictions and requirements adopted by the State and Regional Water Board.

The most common means of preventing or limiting water quality degradation and thus, protecting water quality and beneficial uses, is through the issuance of NPDES permits pursuant to the requirements of the Federal Clean Water Act (Section 402) for which California has implementing responsibility and waste discharge requirements (WDRs pursuant to the California Water Code (Section 13260). The national permit system applies to certain surface water discharges, whereas WDRs allow for control of discharges to land, groundwaters or surface waters. When issuing WDRs the Central Valley Water Board considers existing receiving water quality; historical, present, and future beneficial uses and the rates of use; nature and character of the discharge and possible impacts on beneficial uses and receiving water quality, particularly in the immediate vicinity of the discharge; and water quality objectives.



Section 303(d) of the Clean Water Act requires states to develop lists of water bodies (or segments of water bodies) that will not attain water quality standards (“objectives”, in California) after implementation of minimum required levels of treatment by point-source dischargers (i.e., municipalities and industries). A portion of a waterbody identified as impaired (i.e., not attaining water quality standards) is described as a water quality limited segment (WQLS). Section 303(d) requires states to develop a Total Maximum Daily Load (TMDL) for each of the listed pollutant and water body combinations for which there is impairment. A TMDL is the amount of loading of a given constituent that the water body can receive and still meet water quality standards for that constituent. The TMDL must include an allocation of allowable loadings for both point and non-point sources, with consideration of background loadings and a margin of safety. NPDES permit limitations for listed pollutants must be consistent with allocations identified in adopted TMDLs. Once all or a segment of a waterbody is identified as impairment for a particular pollutant and added to the 303(d) List, the Regional Water Board begins a process to perform and implement a TMDL.

Additionally, state law requires that every new water quality control program for agriculture estimate the total cost and identify potential sources of funding as part of its implementation {Wat. Code § 13241}. The following sections describe the control actions taken by the Central Valley Water Board, as they pertain to antidegradation, which result in the achievement of most of the water quality objectives contained in the Basin Plans for the Sacramento River Basin and San Joaquin River Basin and Tulare Lake Basin. The following sections highlight existing Central Valley Water Board actions that are implemented to control salts, nitrate, and other pollutants of concern (pesticides, trace elements, and sediments) in point and nonpoint discharges.

Control Actions Common to Both Basin Plans

Basin Plans for the Sacramento River Basin and San Joaquin River Basin and the Tulare Lake Basin include descriptions of how the Central Valley Water Board implements State and federal antidegradation policies and applies water quality objectives, among other actions. The following subsections describe those actions that are common to both Basin Plans, as well as those that are unique to each of them, with an emphasis on antidegradation and the application of water quality objectives.

Antidegradation

The Central Valley Water Board’s Basin Plans implement, and incorporate by reference, both the State and federal antidegradation policies. In its implementation of the State Antidegradation Policy, Statement of Policy with Respect to Maintaining High Quality of Waters in California (Resolution No. 68-16), the Central Valley Water Board is charged with preventing or minimizing surface and groundwater degradation so that high quality waters of the State are maintained “consistent with maximum benefit to the people of the State” when issuing WDRs or determining an acceptable level of degradation in an equivalent process. Resolution No. 68-16 predates the Federal Antidegradation Policy and requires that existing quality of waters be maintained unless degradation is justified based on specific findings.



Implementation of the State Antidegradation Policy by Regional Water Boards is guided by an Administrative Procedures Update (APU 90-004) issued by the State Water Resources Control Board (SWRCB) in 1990 that provides Regional Water Boards with guidance on the appropriate level of analysis that may be necessary, distinguishing between the need for a ‘simple’ antidegradation analysis and a ‘complete’ antidegradation analysis (SWRCB, 1990). If it is determined that a simple analysis is not appropriate based on the estimated level of impact of the new discharge, then a more rigorous analysis – a complete analysis – is appropriate. A primary focus of the complete analysis is the determination of whether, and the degree to which, water quality is lowered. This determination greatly influences the level of analysis required and the level of scrutiny applied to the “balancing test” – that is, whether the discharge is necessary to accommodate important economic and social development, and whether a water quality change is consistent with maximum benefit to the people of the State.

A simple antidegradation analysis addresses the following questions stated in SWRCB APU 90- 004 to maintain consistency with state and federal antidegradation policies:

Whether a reduction in water quality will be spatially localized or limited with respect to the water body; e.g., confined to the mixing zone;

Whether the proposed discharge of treated effluent will produce minor effects which will not results in a significant reduction in water quality;

Whether the proposed discharge of treated effluent has been approved in a General Plan, or similar growth and development policy document, and has been adequately subjected to the environmental analysis required in an environmental impact report (EIR) or substitute environmental document (SED) required under the California Environmental Quality Act (CEQA); and

Whether the Proposed Project is consistent with maximum benefit to the people of the State.

In addition, the following items are to be addressed in a complete antidegradation analysis:

A comparison of the projected receiving water quality to the water quality objectives and/or criteria used to protect designated beneficial uses, and

A socioeconomic analysis to establish a balance between the proposed action and the public interest.

Similar to the considerations made by a Regional Water Board when issuing WDRs, factors to be considered in determining whether a proposed discharge is necessary to accommodate important economic and social development and is consistent with maximum benefit to the people of the State include:

Economic costs to maintain water quality compared to the benefits.



Environmental aspects of the proposed discharge.

Consideration of alternative control measures which might reduce, eliminate, or compensate for negative impacts of the proposed discharge.

NPDES permits, WDRs, and Basin Plan Amendments must all include findings that describe how a specific action (e.g., the determination of an effluent or receiving water limitation, discharge prohibition, or the setting of a new water quality objective) to be authorized by the Central Valley Water Board is consistent with the antidegradation provisions of 40 C.F.R. § 131.12 and State Water Board Resolution No. 68-16.

Application of Water Quality Objectives

Water quality objectives are used to protect beneficial uses that require a certain level of water quality for the uses to be attained. The Porter-Cologne Water Quality Control Act defines water quality objectives as “…the limits or levels of water quality constituents or characteristics which are established for the reasonable protection of beneficial uses of water or the prevention of nuisance within a specific area” [Water Code Section 13050(h)]. Water quality objectives may be stated in either numerical or narrative form. Water quality objectives may be applied on a geographic basis or applied to all waters within a surface water or groundwater resource for which beneficial uses have been designated.

The Central Valley Water Board may designate a mixing zone within a surface water for discharges controlled by NPDES and stormwater permits. A mixing zone provides a small zone of initial dilution in the immediate vicinity of a discharge. A mixing zone comprises a limited volume of water in which the concentration of a specific constituent may exceed its relevant water quality objective provided that the mixing zone is small compared to the total area of the water body, does not impact beneficial uses outside the mixing zone, and the relevant water quality objective for the constituent in question is met at the edge of the mixing zone. The Regional Water Board can assign individual mixing zones for specific constituents, and follows guidance provided in the Technical Support Document for Water Quality-Based Toxics Control (TSD) (U.S. EPA, 1991) or the Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays and Estuaries of California (known as the State Implementation Policy (SIP) (SWRCB, 2005) when determining the appropriate dimensions of a mixing zone. Mixing zones have not been authorized for discharges to groundwater; rather compliance with relevant water quality objectives is determined at first encountered groundwater without dilution.

The Regional Water Board also may establish a compliance schedule for a NPDES permit or a time schedule for a WDR when it determines that a discharger will not be able to immediately meet specific water quality objectives or criteria, or effluent limitations for the discharge that are derived from these objectives or criteria. The Regional Water Board will set a compliance schedule or time schedule that includes dates by which a discharger must perform specific actions intended to lead the discharge to compliance with objectives, criteria, or effluent limitations by a date certain. Compliance schedules for NPDES permits are limited to no more than 10 years. The Regional Water Board will establish compliance schedules in NPDES permits consistent with the provisions of the State Water Board’s Compliance Schedule Policy



(Resolution No. 2008-0025). Time schedules for WDRs are established consistent with Wat. Code § 13263.

The numerical and narrative water quality objectives included or referenced in the Basin Plans constitute the least stringent standards that the Central Valley Water Board will apply in order to protect beneficial uses. The Regional Water Board can impose effluent limitations on a discharge, with or without the granting of an associated mixing zone that may be more stringent than water quality objectives. The Board also establishes receiving water limitations (for surface water or groundwater) which must meet applicable water quality objectives. These limitations, effluent and receiving water, must ensure that water quality objectives are met in in the receiving water and that effluent does not cause or contribute to an exceedance of a water quality objective in the receiving water. However, receiving water limitations are not set to improve receiving water quality where existing ambient concentrations exceed water quality objectives. In instances where natural background concentrations exceeds an objective, the natural background concentration will be considered to comply with the objective. The Regional Water Board will establish the most stringent numerical limitations or prohibitions where natural background concentrations are close to or exceed water quality objectives. More stringent numerical limitations (or prohibitions) will be enacted by the Regional Water Board in order to maintain existing water quality and protect beneficial uses unless the Board finds that some amount of degradation is permissible pursuant to Resolution No. 68-16. In these cases, beneficial uses must still be protected.

With regard to compliance with a narrative objective (e.g., for bacteria, chemical constituents, taste and odor, and toxicity), the Board will, on a case-by-case basis, evaluate compliance using a numerical limitation as an interpretation of a narrative objective. When determining an appropriate numerical limitation for the purpose of evaluating compliance with a narrative objective, the Regional Water Board considers direct evidence of impacts to beneficial uses, information submitted by a permitted entity or stakeholder, and relevant numerical criteria and guidelines developed and/or published by other state, federal, and international agencies and organizations. The Board evaluates the information received with regard to its relevance to the particular narrative objective and the beneficial use(s) it is to protect when determining an appropriate numerical value to use to evaluate compliance with the narrative objective.

Short- and Long-term Salt Management

The Central Valley Water Board recognizes that long-term salt management is becoming increasingly important, primarily in the San Joaquin Valley and the Tulare Lake Basin, as a means to allow agriculture to continue at its current level. If the discharge of salts to surface water and groundwater is not controlled and salts continue to build up in soils and groundwater, agriculture could be severely limited to only those areas possessing adequate soils and water supplies that would allow continued operations. Evaporation basins are used as an acceptable interim disposal method for agricultural subsurface drainage and may be an acceptable permanent disposal method provided that water quality and wildlife beneficial uses are adequately protected through the application of WDRs. As a method for permanently moving salts out of the Central Valley, the Central Valley Water Board and CV-SALTS are evaluating



the feasibility of construction and operation of a valley-wide drain to carry salts out of the San Joaquin Valley and the Tulare Lake Basin. The drain would carry wastewater generated by municipal, industrial, and agricultural activities that is high in salt and inadequate for reuse. Furthermore, all discharges (emanating from irrigated agriculture, confined animal activities, municipal, industrial, and oil field wastewaters, storm water, etc.) to surface water and groundwater throughout the Central Valley are currently controlled by various WDRs that minimize impacts to water quality and beneficial uses by salts through the limiting of their loadings to receiving waters. However, the loading of salts to groundwater basins in the Central Valley currently outpaces their export from the Central Valley in many areas of the valley floor (CV-SALTS, 2013).

Variances and Exceptions

In March 2015, the State Water Board approved a Central Valley Water Board Resolution (Resolution R5-2014-0074) that amended the Basin Plans for the Sacramento River and San Joaquin River Basins and the Tulare Lake Basin to add policies for variances from surface water quality standards for point source dischargers, a variance program for salinity, and an exception from implementation of water quality objectives for salinity (State Water Board Resolution No. 2015-0010). The Variance Policy allows the Central Valley Water Board the authority to grant short-term exceptions from meeting water quality based effluent limitations for non-priority pollutants, including salinity constituents and nitrate, to dischargers subject to National Pollutant Discharge Elimination System (NPDES) permits. An individual discharger seeking a variance is required to perform environmental and antidegradation analyses of its discharge and the application for the variance must be reviewed and approved by the US Environmental Protection Agency (USEPA) before provisions may be included in the discharger’s NPDES permit.

The Salinity Variance Program allows the Regional Board the authority to grant multiple discharger variances from meeting water quality-based effluent limitations for salinity constituents to municipal wastewater dischargers. The multiple discharger variance provides a streamlined approach for approving an individual discharger variance application. The purpose of establishing the Salinity Variance Program was to support development of the SNMP. Variances granted under the Salinity Variance Program are not subject to USEPA review and approval before provisions may be included in NPDES permits. The Salinity Variance Program has a sunset date of June 30, 2019. This means that the Central Valley Water Board cannot approve new or renew existing variances after that date. Variance provisions that have been included in NPDES permits by June 30, 2019, will continue to be in effect until the expiration date of the provisions or the Regional Board modifies the conditions.

The Variance Policy and Salinity Variance Program apply to surface water discharges. Under the policy and program, a surface water discharger that demonstrates it is unable to meet an existing or proposed water quality-based effluent limitation (WQBEL) based on a surface water quality standard, and/or an adopted wasteload allocation, can be granted an interim effluent limitation at a level higher than the current level of the constituent in the effluent if the granting of such an interim limit is consistent with maximum benefit to the people of the state. The Salinity Variance Program applies to electrical conductivity (EC), total dissolved solids (TDS),



chloride, sulfate, and sodium, and is specifically for wastewater dischargers that have or will implement local pretreatment, source control, and pollution prevention efforts to reduce the effluent concentrations of salinity constituents and are still faced with obtaining a higher quality municipal source supply or implementing costly treatment plant upgrades to remove salts.

The Salinity Exception Program establishes procedures for dischargers (municipal wastewater, industrial wastewater, and dairies) that are subject to WDRs and conditional waivers to obtain a short-term exception from meeting effluent or groundwater limitations for EC, TDS, chloride, sulfate, and sodium. This program is applicable to point and nonpoint discharges to groundwater, and is applicable to those dischargers subject to WDRs that face acquisition of a new source water supply or costly treatment to comply with effluent limitations and groundwater limitations for salinity constituents. The purpose of establishing the Salinity Exception Program was to support development of the SNMP. Irrigated agriculture is regulated under Surface Water (non-NPDES) and Groundwater WDRs. Irrigated lands dischargers may also apply for salinity exceptions from meeting receiving water limitations in surface or groundwater for salinity constituents. The Salinity Exception Program has a sunset date of June 30, 2019. After that date, the Regional Board cannot adopt or renew exceptions under this program. However, provisions that were adopted and in effect before that date will continue to be in effect until they expire or the Regional Board decides to modify the provisions. The Salinity Variance Program and Salinity Exception Program were designed to support the development and initial implementation of the comprehensive salt and nitrate management plan(s) (SNMPs) for the Central Valley by requiring applicants to participate in CV-SALTS efforts (CVRWQCB, 2014).

Onsite Wastewater Treatment Systems

Onsite wastewater treatment systems (OWTS) are potential sources of nitrogen and pathogens to surface water and groundwater if not properly maintained. As a result, the State Board adopted Resolution No. 2012-0032, adopting the Water Quality Control Policy for Siting, Design, Operation, and Maintenance of Onsite Wastewater Treatment Systems (OWTS Policy). This Policy establishes a statewide, risk-based, tiered approach for the regulation and management of OWTS installations and replacements and sets the level of performance and protection expected from OWTS.

The OWTS Policy sets standards for OWTS that are constructed or replaced, that are subject to a major repair, that pool or discharge waste to the surface of the ground, and that have affected, or will affect, groundwater or surface water to a degree that makes it unfit for drinking water or other uses, or cause a health or other public nuisance condition. The OWTS Policy also includes minimum operating requirements for OWTS that may include siting, construction, and performance requirements; requirements for OWTS near impaired water bodies; requirements authorizing local agency implementation of the requirements; corrective action requirements; minimum monitoring requirements; exemption criteria; requirements for determining when an existing OWTS is subject to major repair, and a Conditional Waiver of waste discharge requirements.



Control Actions Unique to the San Joaquin River Basin

Water quality in the San Joaquin River Basin has been significantly degraded in the past several decades due to anthropogenic activities and natural processes. Salinity increases in surface water and groundwater have prompted the Regional Water Board to implement controls on salt concentrations in the Lower San Joaquin River (LSJR) upstream of Vernalis in order to meet salinity objectives at this long-term monitoring location at the edge of the Sacramento-San Joaquin Delta. In addition to salts, concentrations of boron, selenium, molybdenum, and other trace elements have also increased. Nonpoint discharges have been identified as being the largest contributors to salts and other constituents to the LSJR. Based on the recognition in 1975 when the Basin Plan was first drafted that the LSJR would require salinity management, the Central Valley Water Board began development of a salt management program for the impaired segment of the river that resulted in approval of a Basin Plan Amendment (State Water Board Resolution No. 96-078) to regulate agricultural subsurface drainage discharges to Grassland Watershed surface waters and the LSJR (Central Valley Water Board Resolution No. 96-147). While the focus of the water quality control program was selenium load reduction to the LSJR, it resulted in decreased loadings of salts and other trace elements to the river. To further control selenium discharges to the river, the Central Valley Water Board adopted a Total Maximum Daily Load (TMDL) for selenium for the LSJR in 2001.

In an effort to explicitly manage salt and boron in the LSJR (specifically, Reach 83, defined as the segment of the LSJR between the Merced River confluence and Vernalis), the Central Valley Water Board developed a control program for these constituents with goal of achieving compliance with salt and boron water quality objectives and providing dischargers with the ability to move salt out of the San Joaquin River Basin into the Delta and eventually to the Pacific Ocean. The salt and boron control program was embodied in a Salt and Boron TMDL for the LSJR that was completed in 2004 (Resolution No. R5-2004-0108), approved by the State Water Board in 2005 (Resolution No. 2005-0087), and approved by the Office of Administrative Law in 2006 (CVRWQCB, 2004). The TMDL established load allocations for nonpoint sources and waste load allocations for point sources, provides dischargers with a schedule for compliance based on the priority assigned to the discharge. The TMDL encourages entities discharging to and upstream of Reach 83 of the LSJR to participate in the San Joaquin River Real-Time Water Quality Program that has as its main objective the facilitation of the control and timing of wetland and agricultural drainages to coincide with periods when dilution flow in the LSJR is sufficient to meet Vernalis salinity objectives. Periods of high flow produce assimilative capacity in the river that allows additional salt loadings to the river while still meeting downstream salinity objectives.

Control Actions Unique to the Tulare Lake Basin

A significant water quality problem in the Tulare Lake Basin is the continued increase of salinity in soils and groundwater. While an increase in the salinity of groundwater in a closed basin is a natural phenomenon, the salinity increase of groundwater in the Tulare Lake Basin has been hastened by anthropogenic activities; especially, through the large amount of irrigated agriculture that occurs within the Basin. The major problem in the Basin is the salts brought in with irrigation water and leached out of soils. Due to elevated salinities, groundwater quality in some



portions of the Basin no longer supports Municipal and Domestic Supply (MUN) and Agricultural Supply (AGR) beneficial uses above certain depths where salts have concentrated over time in a shallow perched groundwater.

The Central Valley Water Board has implemented specific controls for limiting the addition of salts to surface water and groundwater in the Tulare Lake Basin. The Board has imposed an EC limit on discharges to surface waters of either the source water plus 500 µmhos/cm or 1,000 µmhos/cm, whichever is more stringent. An exception to the source water plus 500 µmhos/cm limit can be made for industrial discharges to surface waters when a discharger technically demonstrates that allowing a greater net incremental increase in EC will result in lower mass emissions of salt and in conservation of water, provided that beneficial uses are protected. Similarly, an exception for discharges to land of industrial food processing wastes can be made when the discharger demonstrates that best available technology and best management practices are used to control inorganic dissolved solids to the maximum extend feasible, while still protecting beneficial uses.

The Regional Board has also implemented controlled groundwater degradation for salinity as a feasible and practical short-term management alternative for the accumulation of salts. The controlled degradation of groundwater by salts takes the form of a maximum average annual increase in salinity (measured as electrical conductivity) allowed for specific hydrographic units, as shown in Table 1. In addition, the Central Valley Water Board encourages application or disposal of consolidated treated effluents in the western portion of the Basin, toward the drainage trough of the valley.

Table 1: Tulare Lake Basin Groundwater Quality Objectives for Salinity.

Hydrographic Unit

Maximum Average Annual Increase in Electrical Conductivity (µmhos/cm)

Westside (North and South) 1

Kings River 4

Tulare Lake and Kaweah River 3

Tule River and Poso 6

Kern River 5

Taken from Table III-4, Tulare Lake Basin Plan.

3.2 REGULATION OF WASTE DISCHARGES IN THE CENTRAL VALLEY

Based on the definitions and requirements of the California Water Code and the CWA, discharges can be generally divided into the discharge of pollutants to surface waters or other types of discharges (i.e. waste discharges to land or discharges that affect groundwater). As described above, discharges to surface waters are regulated by permits issued under the National Pollutant Discharge Elimination System (NPDES) program while discharges of other types are



permitted through Waste Discharge Requirements (WDR) or waivers to WDRs under the Porter- Cologne Act.

In the Central Valley, as in other regions of California, regulated waste discharges include

Municipal and Industrial Wastewater

Municipal and Industrial Stormwater

Agricultural runoff from irrigated lands and from dairies/confined animal feeding operations (CAFOs)

The elements of the regulatory programs associated with these waste discharges to surface water and to land/groundwater were evaluated based on a review of recent permits to assess practices that result in the current conditions in receiving water as discussed below.

3.3 SURFACE WATER

For surface waters considered to be Waters of the US, point source discharges to surface waters are controlled through regulations described in both WDRs and federal NPDES permits. The requirements of Section 402 of the Clean Water Act apply in addition to requirements under the California Water Code Section 13260 and Section 13263. Current quality of surface water in the Central Valley is the result of dischargers generally complying with the effluent limitations established in NPDES permits.

The current approach to implementation of state and federal requirements for wastewater, stormwater and agricultural discharges is discussed below.

3.3.1 Wastewater

Wastewater discharges are regulated to control the impacts to receiving waters from domestic and industrial wastewater. Wastewater from municipalities is primarily domestic wastewater with some commercial/industrial discharges. Industrial wastewater discharges will vary depending on the industry. The focus for this analysis is on industrial activities with the potential to discharge salts and nutrients.

Municipal

Municipal wastewater NPDES permits are used to regulate discharges to protect beneficial uses by including discharge prohibitions, effluent limitations, receiving water limitations, monitoring and reporting requirements, and special provisions. NPDES permits are subject to disapproval by USEPA and are subject to renewal every 5 years. The Central Valley uses a standardized NPDES template to organize and describe the requirements that are applicable to each permitted

Commented [A7]: *Please see comments in Antidegradation Analysis document, which also apply here. We incorporate those comments by reference.



discharger as described below. A subset of recently adopted permits was reviewed to determine typical current permit provisions7.

Discharge Prohibitions

Discharge prohibitions that are common to all NPDES permits include prohibiting by-pass of treatment operations, creation of a nuisance, discharge of pollutant-free wastewater (e.g., rainwater, groundwater, etc.) or any discharge in a manner different than described in the permit. In addition, site-specific prohibitions may include restrictions on discharging under conditions of low receiving water flow or discharges that may not meet other regulatory requirements.

Effluent Limitations

Effluent limitations are the primary mechanism used to protect water quality and beneficial uses. Constituents requiring effluent limitations may be technology based or water quality based. Technology based effluent limitations ensure that treatment processes are operating properly and include biochemical oxygen demand (BOD), Total Suspended Solids (TSS), bacteria, and pH. Standard values for BOD and TSS are established based on the type of treatment that is required by the permit (i.e., secondary or tertiary treatment standards). Technology based effluent limitations also include flow, chlorine residual and percent removal. Water Quality Based Effluent Limitations are established to provide reasonable protection of beneficial uses. Water Quality standards are established in the California Toxics Rule (CTR) and the Central Valley Basin Plans, as described previously. Effluent limitations are assigned for constituents that are determined to have a reasonable potential to cause or contribute to an exceedance of an applicable water quality standard in the receiving water.

In cases where a discharger shows that they cannot consistently comply with a water quality based effluent limit, the discharger can be granted a compliance schedule with interim performance based limitations along with a plan and schedule to come into compliance with final effluent limitations. Site specific objectives that consider conditions unique to the receiving water may also be developed.

Receiving Water Limitations

In addition to meeting effluent limitations, dischargers must also meet receiving water limitations established to protect beneficial uses. The permit requires that the discharge does not cause or contribute to an exceedance of a water quality objective.

Monitoring and Reporting Requirements

To verify that effluent and receiving water limits are being met, every NPDES permit includes a monitoring and reporting program that outlines constituents to be monitored in effluent and receiving water and describes the frequency, location and analytical methods to be used. In

7 The permits that were reviewed for this summary include the following: City of Lodi (R5-2013-0125-1), City of Manteca (R5-2015-0026), City of Stockton (R5-2014-0070-02), Mountain House Community Services District (R5- 2013-0004-01), Cities of Turlock/Modesto (R5-2016-0010), and Sacramento Regional County Sanitation District (R5-2016-0020).

Commented [A8]: If limits are based only on dissolved fractions, then they may be removed from reasonable potential and effluent limits would no longer exist, nor monitoring or targeted treatment or pretreatment. How would downstream MUN be protected from cumulative and long‐term impacts?



addition to monitoring for constituents with effluent limitations, monitoring of priority pollutants and other parameters are required to more completely characterize the discharge. Characterization monitoring is required one or more times during each permit term. For dischargers to the Delta, receiving water monitoring requirements may be met by participating in the Central Valley Water Board’s Regional Monitoring Program.

Special Provisions

Special studies and other provisions are included for topics that may include the development of management practices or plans, specialized monitoring, or special studies to evaluate site- specific conditions (e.g., mixing zone/dilution, translators or water effects ratios).

Specific Requirements regarding salinity, nitrates and secondary MCL parameters

Most Central Valley wastewater NPDES permits include an effluent limit for Electrical Conductivity. The EC limit is typically an annual average based on current performance. Water conservation and the drought have led to reduced flows to municipal wastewater treatment plants which has resulted in increasing salts concentrations. However, in many cases, the total load of salts discharged remains relatively constant. Therefore, performance based effluent limitations may be given to a discharger that result in negligible degradation to the receiving water.

Municipalities also have a provision in their permit to develop and implement a Salinity Minimization and Evaluation Plan or Salinity Source Control Program to minimize salinity in effluent discharges.

Effluent limitations are also included for nitrate in some permits (set equal to the Maximum Contaminant Level (MCL) of 10 mg/L). Discharges found to have reasonable potential to cause or contribute to the exceedance of the Primary MCL for nitrate in a receiving water designated as supporting the MUN beneficial use will be given an effluent limitation for nitrate, particularly in regions of the Central Valley where water bodies are considered impaired for nutrients.

In addition, non-salinity secondary MCL parameters (e.g., manganese, iron, and aluminum) that may be found at levels of concern in municipal wastewater also will be assigned effluent limitations. Turbidity is usually controlled through operational specifications or through a receiving water limit.

As discussed above (Control Actions Unique to the San Joaquin River Basin), there are TMDLs for selenium, boron and salts in the LSJR region that also contain requirements for managing salts.

Industrial

Industrial discharges to surface water are regulated in much the same way as municipal discharges with the same permit elements and requirements. The specific effluent limitations assigned will depend on the nature of the discharge. The industrial activities most likely to discharge significant levels of nutrients and salts are food processors and wineries. Regulation and impacts to receiving waters of these activities are discussed in the next section

Commented [A9]: These could be removed based on RPA using dissolved fractions. Filtered turbidity would no longer scientifically represent risk of discharged water since the samples are proposed to be filtered.



(Groundwater). A subset of recently adopted permits was reviewed to determine typical current permit provisions8.

Wineries and food processors are the industrial categories that are considered most likely to be significant sources of salts and nitrogen. However, hatcheries were also reviewed as dischargers to surface water. Hatcheries are regulated for discharges to surface water and groundwater by a General Order for Cold Water Concentrated Aquatic Animal Production (R5-2014-0161) with effluent limitations for formaldehyde, copper and chlorine. Surface water limitations are included for EC and TDS based on each Basin Plan and groundwater limitations are specified for nitrate (10 mg/L) and TDS (500 mg/L).

3.3.2 Stormwater

Municipal (Phase I and Phase II)

The Municipal Storm Water Permitting Program regulates storm water discharges from municipal separate storm sewer systems (MS4s). MS4 permits were issued in two phases9.

Under Phase I (starting in 1990), the Regional Water Board adopted NPDES storm water permits for medium (population between 100,000 and 250,000) and large (population greater than 250,000) municipalities. Most of these permits are issued to groups of Co- permittees encompassing large metropolitan areas (examples include East Contra Costa County MS4 permit, Sacramento County MS4 permit, and City of Stockton/County of San Joaquin permit).

On April 30, 2003, as part of Phase II, the State Water Board issued a General Permit for the Discharge of Storm Water from Small MS4s (Order No. 2003-0005-DWQ) to provide permit coverage for smaller municipalities (population less than 100,000), including non- traditional Small MS4s (facilities such as military bases, public campuses, prisons and hospital complexes). The Phase II Small MS4 General Permit covers Phase II Permittees statewide. On February 5, 2013, the Phase II Small MS4 General Permit was renewed and became effective on July 1, 201310.

It should be noted the Regional Water Board adopted a Region-wide MS4 Permit (Order No. R5- 2016-004011) in June 2016 (effective October 1, 2016). While the primary focus will be on enrolling Phase I MS4 permittees as their current permits expire, Phase II MS4 permittees have the option to enroll under this General Permit and terminate coverage under the Phase II Small MS4 General Permit.

The Phase I and Phase II permits are structured very similarly and are used to regulate discharges to protect beneficial uses by including discharge prohibitions, effluent limitations, receiving

8 The permit reviewed for this summary was the following: Fish Hatcheries (R5-2014-0161). 9 http://www.waterboards.ca.gov/centralvalley/water_issues/storm_water/municipal_permits/ 10 http://www.waterboards.ca.gov/water_issues/programs/stormwater/phase_ii_municipal.shtml 11 http://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/general_orders/r5-2016- 0040_ms4.pdf



water limitations, monitoring and reporting requirements, and special provisions. The Regional Water Board and State Water Board use a similar approach to organize and describe the requirements that are applicable to each permitted discharger. These requirements, as included within the Regional Water Board General Permit (Order No. R5-2016-0040) and State Water Board Phase II Permit (Order No. 2013-0001-DWQ), are briefly described below.


The permits include storm water and non-storm water discharge prohibitions.

The storm water discharge prohibitions incorporate applicable Statewide Water Quality Control Plan or Basin Plan prohibitions as well as a prohibition on creating a condition of pollution, contamination or nuisance.

Non-storm water discharges into the MS4 must be effectively prohibited, where such

discharges are not authorized by a separate NPDES permit or conditionally authorized within the MS4 permit.12

The primary compliance approach (pollutant prioritization) allows the Permittee to develop a customized Storm Water Management Plan (SWMP)13. The objective of the SWMP is to describe a Storm Water Management Program that identifies and addresses MS4 discharge impacts so that such discharges do not cause or contribute to exceedances of water quality standards in waters of the United States (as defined in 40 C.F.R. § 230.3). The SWMP describes the Permittee’s Storm Water Management Program including milestones, strategies and activities, and their corresponding schedules for implementation.

In general, the Permittee’s full compliance with the requirements in the Permit, including timely implementation of the Storm Water Management Program, constitutes compliance with the discharge prohibitions.


Within the context of MS4 permits, the CWA does not explicitly reference a requirement to meeting Technology Based Effluent Limitations (TBELs) or water quality standards. MS4 discharges must effectively prohibit non-storm water discharges and reduce pollutants in the discharge to the Maximum Extent Practicable (MEP), however requiring strict compliance with water quality standards by imposing numeric effluent limitations is at the discretion of the permitting agency. The permits include TBELs and water quality based effluent limitations (while the Regional Water Board permit uses these terms, the Phase II General Permit does not).

12 Conditionally authorized pursuant to 40 CFR section 122.26(d)(2)(iv)(B)(1), require the implementation of BMPs, or is a discharge associated with emergency containment or cleanup. 13 The secondary compliance approach (Prescriptive) is reserved for Permittees that are unsuccessful in complying with the requirements under the Pollutant Prioritization approach.



MEP is the technology based standard.14 Meeting MEP requires the continual assessment and modification of the Storm Water Management Program to ensure that the program is effectively addressing the pollutants of concern.

NPDES permits must incorporate water quality based effluent limitations (WQBELs) that

are consistent with the assumptions and requirements of applicable waste load allocations (WLA).15 In the context of MS4 discharges, WQBELs may be expressed in the form of either numeric limitations or, where authorized by the Basin Plan, best management practices (BMPs).16 With the exception of certain WQBELs based on applicable TMDLs, the permits do not contain numeric effluent limitations and, instead, include requirements to reduce pollutants in storm water discharges to the MEP17.

In general, the Permittee’s full compliance with the requirements in the Permit, including timely implementation of the Storm Water Management Program, constitutes compliance with the effluent limitations.


The permits include receiving water limitations, which provide that the storm water discharges from the MS4 shall not cause or contribute to exceedances of water quality standards in the receiving waters. The permits incorporate/refer to applicable Statewide Water Quality Control Plan or Basin Plan water quality standards. If exceedances persist, notwithstanding implementation of the Storm Water Management Program, the Permittee must follow a process to identify if any modifications to the SWMP are necessary.

In general, the Permittee’s full compliance with the requirements in the Permit, including timely implementation of the Storm Water Management Program, constitutes compliance with the receiving water limitations. Final attainment of a water quality standard is demonstrated when the Permittee’s MS4 discharges are no longer causing or contributing to exceedances of that water quality standard within the applicable receiving water or that receiving water is meeting water quality standards. Final attainment is verified through monitoring and reporting results.


The Regional Water Board General Permit requires the development and implementation of a monitoring program. 18 The goal of the monitoring program is to inform the Permittee, to the extent feasible, about the nexus between the implementation of the storm water program, the quality of the discharges from the MS4, and the resulting impact, if any, on the receiving water. The monitoring program may include receiving water monitoring, source characterization, urban discharge monitoring, special studies, and/or TMDL monitoring. If approved by the Regional

14 CWA section 402(p)(3)(B)(iii) 15 40 CFR 122.44(d)(1)(vii)(B) 16 40 CFR 122.44(k) 17 The applicable WQBELs and TMDL requirements are contained within Attachment G of both permits. 18 Under the Phase II General Permit some Permittees may be exempt from the requirement to develop a monitoring program.



Water Board, the Permittee may participate in a regional monitoring program to address all or part of the local water quality monitoring requirements.

As applicable, the Phase II General Permit requires Permittees to develop and implement monitoring programs for discharges to Areas of Special Biological Significance, to support TMDLs, for discharges to 303(d) listed water bodies, to evaluate receiving water quality, or to evaluate the effectiveness of water quality projects or the storm water program. In addition, Permittees are encouraged to participate in a regional monitoring program in order to cost- effectively combine resources and water quality information.

Special Provisions

While the permits don’t include any requirements to conduct special studies, they recognize the use of these types of studies as a part of:

A monitoring program;

A receiving water assessment; or

Effectiveness assessments.

Specific Requirements for Salinity (EC, TDS), Nitrates and Secondary MCL Parameters

The primary location for parameter specific requirements is within the TMDL portion of the permits. The permits include TMDLs that have been adopted by the Regional Water Board or US EPA for pollutant specific issues within water bodies or segments of water bodies in Region 5. All Permittees that are assigned a WLA or identified as a responsible party where urban runoff is listed as the source, must comply with the requirements as specified within the permit.

Currently, there are no adopted TMDLs for salinity, nitrates or secondary MCL parameters that are applicable to MS4s in the Central Valley. The Lower San Joaquin Salt and Boron TMDL concluded that stormwater contributes negligible salinity loads to the Lower San Joaquin River; less than one quarter of one percent of the river’s total salt load as measured at the Airport Way Bridge near Vernalis (CVRWQCB, 2004).

Industrial

On November 16, 1990, US EPA promulgated Phase I storm water regulations, which require operators of facilities that discharge storm water associated with industrial activity (industrial storm water dischargers) to obtain an NPDES permit. The State Water Board first issued an NPDES Industrial General Permit (IGP) in 1997 and subsequently reissued it 2014. 19 The IGP regulates industrial storm water discharges and authorized non-storm water discharges from specific categories of industrial facilities. The IGP requires the development of a site-specific

19

http://www.swrcb.ca.gov/board_decisions/adopted_orders/water_quality/2014/wqo2014_0057_dwq_rev_mar2015.p df



Storm Water Pollution Prevention Plan (SWPPP), which must include the information necessary to demonstrate compliance with permit requirements.

The IGP is used to regulate discharges to protect beneficial uses by including discharge prohibitions, effluent limitations, receiving water limitations, monitoring and reporting requirements, and special requirements and provisions. These requirements, as included within the IGP, are briefly described below.


The IGP includes storm water and non-storm water discharge prohibitions.

Storm water discharges to waters of the US are prohibited, except as explicitly authorized by the IGP or another NPDES permit. The storm water discharge prohibitions also incorporate applicable Statewide Water Quality Control Plan or Basin Plan prohibitions as well as a prohibition on creating a condition of pollution, contamination or nuisance.

Non-storm water discharges are prohibited, where such discharges are not authorized by the IGP (as being de minimis), a separate NPDES permit or WDRs.


In the 2014 update of the IGP, the State Water Board determined that it is not feasible to establish numeric TBELs. However, the IGP requires dischargers to implement BMPs that comply with Best Available Technology Economically Achievable (BAT) and Best Conventional Pollutant Control Technology (BCT) requirements to reduce or prevent pollutants in storm water discharges and authorized non-storm water discharges. The IGP’s requirements constitute BCT for discharges of industrial storm water and authorized non-storm water discharges.

US EPA established Effluent Limitation Guidelines and New Source Performance Standards (ELGs) for storm water discharges from facilities in 11 industrial categories. Storm water discharges from facilities subject to ELGs shall not exceed those storm water ELGs. For facilities where ELGs have been developed, compliance with the BAT/BCT and ELG requirements constitutes compliance with the IGP technology-based requirements.

The IGP includes annual and instantaneous maximum Numeric Action Levels (NALs). The NALs are not intended to serve as TBELs or WQBELs and are not considered violations of the IGP.

The Dischargers must comply with TMDL-specific requirements, which may not be limited by the BAT/BCT technology-based standards. The TMDL requirements are coordinated by the Regional Water Board. (The State Water Board is in the process of amending the IGP to incorporate TMDL specific requirements.)

In general, the Discharger must implement minimum and advanced BMPs as necessary to achieve compliance with the effluent limitations.




The IGP includes receiving water limitations, which require that the storm water discharges and authorized non-storm water discharges do not cause or contribute to exceedances of applicable water quality standards in the receiving waters, adversely affect human health or the environment, or contain pollutants in quantities that threaten to cause pollution or a public nuisance.

If a discharge causes or contributes to an exceedance of a water quality standard, the Discharger must implement additional BMPs or other control measures in order to attain compliance with the receiving water limitations. Compliance with water quality standards may, in some cases, require Dischargers to implement controls that are more protective than controls implemented solely to comply with the technology-based requirements within the IGP.

In general, the Discharger must implement minimum and advanced BMPs as necessary to achieve compliance with the receiving water limitations.


The IGP contains monitoring requirements that are necessary to determine whether pollutants are being discharged and whether response actions are necessary. Data and information resulting from the monitoring assist in the Dischargers’ evaluations of BMP effectiveness, ability to meet NALs and ELGs, and compliance with the Permit.

Special Requirements and Provisions

While the IGP does not include any requirements to conduct special studies, it does have special requirements for plastic materials.

Specific Requirements for Salinity (EC, TDS), Nitrates and Secondary MCL Parameters

While the monitoring program includes some salinity, nitrate, or secondary MCL related analytical parameters based on the type of industrial facility, the IGP does not contain specific programs or studies directed at these parameters. The following IGP requirements would trigger monitoring for salinity, nitrate, or secondary MCL related analytical parameters:

Facilities subject to “additional analytical parameters identified in IGP Table 1;

Facilities that identify these parameters on a facility-specific basis that serve as indicators of the presence of all industrial pollutants identified in the pollutant source assessment;

Facilities that identify these parameters associated with the industrial source assessment related to receiving waters with 303(d) listed impairments or approved TMDLs; and

Additional parameters required by the Regional Water Board

These parameters may also be identified within the TMDL portion of the Permit. The IGP includes TMDLs that have been adopted by the applicable Regional Water Board or US EPA for



pollutant specific issues within water bodies or segments of water bodies throughout the state that are applicable to industrial dischargers. Currently, there are no TMDLs listed for Region 5. As noted, the State Water Board is in the process of amending the IGP to incorporate TMDL specific requirements.

3.3.3 Agriculture

Agriculture is not regulated through the NPDES program but the WDRs do have requirements associated with surface water as described below.

Irrigated Agriculture

Irrigated Agriculture is not regulated through the NPDES program and the specific elements of the Irrigated Agriculture WDRs are described in Section 3.4.3. However, the WDRs contain surface water limitations to address potential impacts to surface waters from irrigated agriculture. In addition, the WDRs require that Erosion and Sediment Control Plans be developed and implemented to address potential impacts to surface water.

Receiving water limitations are applied to surface water as narrative objectives stating that wastes discharged from Member operations shall not cause or contribute to an exceedance of a water quality objective. Trigger limits are established for constituents of concern. If the trigger is exceeded two or more times in a three-year period at a given sampling location, then a surface water quality management plan (SQMP) must be developed and implemented. A time schedule for addressing the water quality problem is required to be included in the SQMP and may not exceed 10 years.

Dairies

Dairies are regulated by a General Order Waste Discharge Requirements and discharges to surface waters are generally prohibited. The General Order prohibits discharges of wastes or wastewater to surface waters unless authorized separately by an NPDES permit. However, irrigation supply water for cropland associated with a dairy may not be covered by this prohibition. Control of discharges to groundwater are discussed in Section 3.4.3.

3.4 GROUNDWATER

Current quality of groundwater in the Central Valley is influenced by discharges that generally comply with effluent limitations and other requirements established in WDRs. The elements of WDRs and how they are designed to maintain and protect beneficial uses are described below.

3.4.1 Wastewater

Waste Discharge Requirements for domestic and industrial wastewater follow the same general framework with certain differences associated with aspects that are unique to either municipal or industrial systems.

Commented [A10]: Please clarify that this these are not required for the rice order.

Commented [A11]: This includes a limited number of constituents.



Municipal

Municipal wastewater WDRs are used to regulate discharges to protect beneficial uses of groundwater by including discharge prohibitions, effluent limitations, groundwater limitations, monitoring and reporting requirements, and other provisions. A subset of recently adopted permits was reviewed to determine typical current permit provisions20.


Discharge prohibitions that are common to Central Valley WDRs include prohibiting discharge to surface water, by-pass of treatment operations, discharge of hazardous waste, toxic substances that would disrupt the treatment process, discharge of pollutant-free wastewater, or any discharge in a manner different than described in the permit.


Effluent limitations are the primary mechanism used to protect water quality and beneficial uses and are established for flow and specific constituents. Flow limitations are established for average dry weather flow. The need for effluent limitations is discussed in the anti-degradation findings in most WDRs.

In cases where a discharger shows that they cannot consistently comply with a water quality based effluent limit, interim performance based limits are established along with a plan and schedule for the discharger to come into compliance with final effluent limitations.

Groundwater Limitations

In addition to meeting effluent limitations, groundwater limitations are established to protect beneficial uses. Limitations are established for salts and nitrates. The permits requires that the discharge does not cause an exceedance of an applicable water quality objective.


To verify that effluent and receiving water limits are being met, each set of WDRs includes a monitoring and reporting program that outlines constituents to be monitored in effluent and receiving water and describes the frequency, location and analytical methods to be used. In addition to monitoring for constituents with effluent limitations, monitoring of priority pollutants and other parameters are required to more completely characterize the discharge. Characterization monitoring is required one or more times during each permit term.

Provisions

Provisions may include compliance schedules and operational requirements. For WDRs for facilities that produce recycled water, provisions related to operation of the UV disinfection system or other elements of the Recycled Water Program may be included in the provisions.

20 The permits that were reviewed for this summary include the following: City of Lathrop (R5-2016-0028), Tesoro Viejo Mutual Water Company (R5-2016-0057), City of Fresno WRF (R5-2014-0162), City of Sanger (R5-2014- 0004), and City of Tulare WRF (R5-2013-0019).



Other provisions or discharge specifications may be related to storage pond management or solids disposal.


Central Valley WDRs may include effluent limitations for TDS or EC, and nitrates. In addition, if necessary, effluent limitations are established for other secondary MCLs. Groundwater limitations are also established such that effluent will not cause an exceedance of a Water Quality Objective or MCL in the groundwater. If the constituent concentration in the groundwater is greater than the WQO, then the groundwater limitation may be set equal to the ‘current groundwater quality’. In addition, specific wells may be designated for determining compliance with groundwater limitations.

Effluent limitations are also included for nitrate or total nitrogen and are set equal to the MCL of 10 mg/L. In the Tulare Lake Basin, effluent limitations for EC are set equal to 1000 µmhos/cm or set equal to source water EC concentration + 500 µmhos/cm, whichever is more stringent.

Effluent limitations may also be set for secondary MCLs to support the MUN beneficial use. In addition, effluent limitations for salts (e.g., sodium, chloride, boron) may be established to protect the AGR beneficial use. In these cases, the SNMP is referred to as being used to set effluent limitations for these constituents in the future.

Industrial Wastewater

Industrial wastewater WDRs for food processors and wineries, similar to municipal wastewater WDRs, are used to regulate discharges to protect beneficial of groundwater by including discharge prohibitions, effluent limitations, groundwater limitations, monitoring and reporting requirements, and other provisions. These permit elements highlighting differences from the municipal WDRs are described below based on a review of WDRs adopted in 2014-201521.

In addition to the food processors and wineries, WDRs for oil fields and mines were also reviewed as potential sources of salts discharges. The permits that were reviewed were primarily associated with requirements to close these facilities and cease wastewater discharges. Oil field permits included limits for EC, chloride and boron based on the Basin Plan Objectives.


Discharge prohibitions that are common to Central Valley WDRs include prohibiting discharge to surface water, by-pass of treatment operations, discharge of hazardous waste, toxic substances that would disrupt the treatment process, discharge of pollutant-free wastewater, or any discharge in a manner different than described in the permit. In addition, food processors and wineries discharge to land application areas (LAAs). As a result discharge prohibitions are established for residual solids and other wastes that may be produced that cannot be disposed of to the LAAs to

21 The permits that were reviewed for this summary include the following: Edison Grape Processing (R5-2015- XXXX), Sutter Home Winery (R5-2015-0085), Del Monte Foods (R5-2014-0116), Reedley Winery (R5-2014- 0045), Morning Star Tomato Packing (R5-2013-0144), ConAgra Tomato Processing (R5-2014-0106), Oil Fields (R5-2013-0061), and Zenda Mine (R5-2014-0138).



prevent odors and/or nuisance. Many industrial WDRs also contain prohibitions against discharging domestic wastewater to the industrial disposal sites.


Effluent limitations are the primary mechanism used to protect water quality and beneficial uses and area established for flow and specific constituents. Flow limitations are established for average dry weather flow. Constituents requiring effluent limitations include biochemical oxygen demand (BOD), and, depending on the discharger, TDS or FDS and nitrates or total nitrogen. The need for effluent limitations is discussed in the anti-degradation findings. In general, effluent limitations are expressed as mass loading to the LAAs.

Discharge specifications

In addition to effluent limitations, discharge specifications for the LAAs and for handling of solids are included in industrial WDRs. These specifications are associated with applying wastewater at agronomic rates and managing solids to minimizing leaching.


In addition to meeting effluent limitations, groundwater limitations are established to protect beneficial uses. Limitations are established for salts (EC or TDS), nitrates, and other constituents identified in Title 22. The permit requires that the discharge does not cause an exceedance of an applicable water quality objective. In cases where the groundwater exceeds the objective, the groundwater limit states that the discharge cannot cause a ‘statistically significant increase.’ It is stated that compliance with these effluent limitations is determined at specific wells identified in the monitoring and reporting plan.


To verify that effluent and receiving water limits are being met, every WDR includes a monitoring and reporting program that outlines constituents to be monitored in effluent and groundwater and describes the frequency, location and analytical methods to be used. Monitoring is required for constituents with effluent or groundwater limitations, general minerals and other constituents identified in Title 22. Monitoring of source water is also required in many industrial WDRs.

Provisions

Provisions may include time schedule orders and operational requirements. Workplans to develop or modify a groundwater monitoring network may be included in the provisions. In addition, requirements to develop Solids, Salinity and/or Nitrogen Management Plans may be included.

Effluent limitations for TDS are established as performance based annual average limits. For dischargers with levels of nitrogen that are a concern, nitrogen limits are expressed as the nitrogen mass loadings that will not exceed the agronomic rate when applied to Land Application Areas. Groundwater limitations are set depending on the ambient groundwater quality for



nitrogen, secondary MCLs, and TDS or FDS. Solids, Salinity or Nitrogen management plans may be required. Other forms of requiring assessments of salts and nitrates include BOD and Nitrogen Application and Irrigation Management Reports and/or a Groundwater Limitation Compliance Assessment Plans. Monitoring for TDS, nitrate, MCLs and standard minerals in effluent and groundwater is also required.

3.4.2 Stormwater

Municipal (Phase I and Phase II)

The Regional Water Board General Permit and Phase II Permit are both NPDES Permits and WDRs. While they are primarily focused on surface water, they do include a requirement to protect groundwater quality when implementing infiltration BMPs so that the pollutants of concern are not transferred to groundwater. The permits also support improved groundwater recharge.

Industrial

While the IGP is an NPDES permit and not a WDR, it does include requirements to protect groundwater quality when implementing infiltration BMPs so that the industrial pollutants are not transferred to groundwater.

3.4.3 Agriculture

Regulation of irrigated agriculture and dairies is implemented through WDRs as described below. WDRs for the Sacramento River Watershed, East San Joaquin and Tulare Lake Basin were reviewed to assess requirements for irrigated agriculture that contribute to current receiving water quality conditions. The General Order for Milk Cow Dairies was reviewed to assess requirements for dairies that contribute to current receiving water conditions.

Irrigated Agriculture

The Regional Water Board has adopted WDRs for discharges from irrigated lands to protect both surface water and groundwater throughout the Central Valley. The Irrigated Lands Regulatory Program (ILRP) implements the WDRs which have been adopted for discrete regions within the Central Valley, a commodity coalition (such as rice growers), or individual growers. The WDRs allow for a third party or coalition group to coordinate efforts by growers within a discrete region to comply with the regulatory requirements. WDRs have been adopted for growers within the following Coalition Groups:

Eastern San Joaquin Watershed Grassland Drainage Area Rice Growers within the Sacramento Valley Sacramento River Watershed San Joaquin County and Delta Area Tulare Lake Basin Area Western San Joaquin River Western Tulare Lake Basin Area

Commented [A12]: See below for suggested specific edits.

Commented [A13]: This description needs to be expanded to better represent surface water impacts or added to Section 3.3.3.



Each of the WDRs include discharge prohibitions, receiving water limitations, provisions, and monitoring and reporting as described below. The WDRs specify the responsibilities of both the Coalition and the individual growers. The WDRs for the Sacramento River Watershed (R5- 2014-0030-R1), Tulare Lake Basin (R5-2013-0120) and the East San Joaquin Watershed (R5- 2012-0116-R3) were specifically reviewed. The East San Joaquin Watershed WDR is currently under review by the State Board and the action taken may change the impacts from irrigated agriculture in this part of the Central Valley in the future. However, the current WDRs were assumed to be representative of current practices and used to evaluate baseline conditions.


Discharges of hazardous waste are prohibited and discharges of wastes (e.g., fertilizers, fumigants, pesticides) to groundwater via backflow into a water supply well or down a groundwater well casing are prohibited.


Receiving water limitations are applied to surface water and groundwater and are narrative stating that wastes discharged from Member operations shall not cause or contribute to an exceedance of a water quality objective. Triggers are established for constituents of concern. If the trigger is exceeded two or more times in a three-year period at a given sampling location, then a surface water quality management plan (SQMP) or groundwater quality management plan (GQMP) must be developed and implemented. A time schedule for addressing the water quality problem is included in the SQMP or GQMP and may not exceed 10 years. The proposed time schedule must be supported with appropriate technical or economic justification as to why the proposed schedule is as short as practicable.

Provisions

General provisions outline the responsibilities of the third party group (i.e., Coalition) and the members (i.e., growers). Provisions require individual growers to participate in Coalition outreach events, implement water quality management practices, develop and implement a Sediment and Erosion Control Plan, a Management Practice Evaluation Program, a Farm Evaluation Plan, and a Nitrogen Management Plan. The Coalition develops and implements a plan to track and evaluate the effectiveness of water quality management practices, conducts water quality monitoring and assessment, and prepares and submits annual reports on these activities. The Coalition is required to conduct education and outreach to inform growers of program requirements and water quality problems.

Monitoring and Reporting

The WDRs require both surface water and groundwater monitoring. Surface water monitoring sites in the Sacramento Valley are categorized as representative sites, integration sites and special studies sites. Representative monitoring sites are representative of all areas and all types of irrigated agricultural waste discharge within the Coalition’s area. Surface water monitoring sites are selected to allow characterization of water flow, quality, and irrigated agricultural waste

Commented [A14]: The Rice Growers Order is quite different from these and should have been included.

Commented [A15]: Does not represent variability in agricultural operations in the future.

Commented [A16]: There are very limited triggers in existing WDRs in the Sacramento Valley.

Commented [A17]: Does not apply to rice growers, which represents approximately one half million acres of agriculture in the Sacramento Valley.



discharges. Integration sites are used for identifying cumulative effects and long-term trends in water quality. Sites may also be designated for special studies, if needed, for a SQMP to evaluate commodity or management practice-specific effects on identified water quality problems, to evaluate sources, and to track the status of the identified water quality problems. Constituents that are required to be monitored include E. coli, conductivity, nitrogen compounds, TSS, turbidity, and hardness.

In East San Joaquin, surface water monitoring is linked to exceedances of trigger limits. Core monitoring sites are monitored on a rotating schedule and, if a trigger limit is exceeded, then representative site monitoring and/or special studies sites are added. Constituents to be monitored are similar to those in the Sacramento Valley.

Groundwater monitoring requirements include preparing a Groundwater Quality Assessment Report, implementing a Management Practice Evaluation Program and conducting Groundwater Quality Trend Monitoring. Annual monitoring is conducted for conductivity, pH, dissolved oxygen, temperature and nitrate. In addition, monitoring wells are sampled once every five years for TDS and general mineral.


The WDRs require each Member to develop a farm specific nitrogen management plan. There are no specific requirements for Salts or other secondary MCLs. Triggers have been established for TDS (450 mg/L in East San Joaquin and 125 mg/L in the Sacramento Valley) and nitrates (10 mg/L in East San Joaquin) as stated in the monitoring and reporting program. If the trigger is exceeded a SQMP or GQMP must be developed. Depending on the location/region, triggers are also established for other secondary MCLs. Triggers are included for boron, copper, EC, and turbidity in the East San Joaquin area and for arsenic, boron, and lead in Sacramento Valley, for example.

The WDRs also note that actions associated with achieving compliance with water quality objectives for salts and nitrates should be coordinated with the policies and actions of CV- SALTS.

Dairies

Dairies in the Central Valley are regulatory by General Order WDRs that include requirements for testing wells, applying fertilizer and manure to crops at agronomic rates, and meeting standards for properly storing and handling manure to minimize leaching and runoff. Requirements cover the facilities where animals are housed, waste facilities, and associated croplands.


Discharge prohibitions include the following:

• Discharge to surface water unless NPDES permit • Hazardous waste

Commented [A18]: It should be noted that this does not include most of the secondary MCLs, even though high levels of aluminum, iron, and manganese are found in the major agricultural drainages in the Sacramento Valley.



• Pollution, nuisance • Dead animals to ponds • Stormwater to surface water • Land application of wastes if not for nutrient recycling


The General Order does not include a section on Effluent Limitations. Groundwater limitations are narrative and state that the discharge of waste at existing milk cow dairies shall not cause the underlying groundwater to exceed water quality objectives, unreasonably affect beneficial uses, or cause a condition of pollution or nuisance. This section refers generally to the Basin Plan water quality objectives.

Provisions

Provisions include requirements associated with management of wastewater retention ponds, production areas, and land application areas. Provisions specify practices to minimize leaching from solids disposal and to apply fertilizers at agronomic rates. In addition, nutrient and waste management plans and a salinity report are required.

Monitoring and Reporting

Monitoring of groundwater is required and may be conducted on an individual basis or through a Representative Monitoring Program (RMP). Most dairies perform this monitoring through membership in an RMP. All supply wells (irrigation wells and domestic wells) must be tested annually and results reported to the Regional Board. In addition, dairies are further required to install dedicated monitoring wells to sample “first-encountered” (shallowest) groundwater.

About 1,143 Central Valley dairies are members (95 percent plus of Central Valley dairies) of the representative monitoring program, paying monthly fees to support ongoing monitoring and research into improved management practices. The RMP includes 443 wells on 42 dairies from Orland to Bakersfield, representing the range of soil, climate and cropping conditions of Central Valley dairies. Wells are monitored monthly, including quarterly water quality analysis for nine constituents (including nitrate), annual testing for 22 constituents, providing 16,000 raw data points annually. The RMP evaluates all aspects of dairies that have potential to impact groundwater, including ponds, croplands and animal housing areas, with management practices for all of these areas being evaluated.


As noted above, the General Order contains requirements associated with the management of nutrients, solids and salinity.

Nutrient management plan. All dairies of any size must follow a nutrient management plan prepared by a certified agronomist. The plan requires sampling of manure, irrigation water and harvested plant tissue so that an Application/Removal Ratio can be calculated field by field. Any



manure exported from the dairy must be recorded and accounted for. Complete records must be kept on farm and an annual report submitted to the Regional Board.

Waste management plan. All dairies must have a waste management plan prepared by a licensed engineer. The plan must affirm that animal housing and manure storage areas are designed to prevent flooding and runoff, drain properly during normal operation and rain events, and are designed with sufficient capacity to safely handle and manage the manure generated until it can be safely applied to crops at the dairy or exported off site.

Salinity Report. A report must be prepared that identifies sources of salt in waste generated at the dairy, evaluates measures that can be taken to minimize salt in the dairy waste, and certifies that they will implement the approved measures identified to minimize salt in the dairy waste.



4 WATER QUALITY SETTING

4.1 INTRODUCTION

Of California’s nine Regional Water Quality Control Boards (Regional Water Boards), the geographical area under the jurisdiction of the Central Valley Regional Water Quality Control Board (Central Valley Water Board) is the largest and most diverse; stretching from the Oregon border to the northern tip of Los Angeles County. The area contains about 60,000 square miles or almost 40% of the state (CVRWQCB, 2010) and is comprised of three distinct Hydrologic Regions, as defined by the California Department of Water Resources (DWR) (DWR, 2015a), as well as a fourth region within those boundaries that is hydrologically unique (DWR, 2014):

The northern third of the valley falls within the “Sacramento River Hydrologic Region” and is referred to as the Sacramento Valley.

The southern two-thirds of the valley is referred to as the San Joaquin Valley, which contains two Hydrologic Regions:

o The “San Joaquin River Hydrologic Region” in the north.

o The “Tulare Lake Hydrologic Region” in the south.

The fourth region is the Sacramento-San Joaquin River Delta, which is contained in and receives flows from both the Sacramento River and San Joaquin River Hydrologic Regions, and its waters are redistributed throughout the state via federal and state water projects.

The Water Quality Control Plan (Basin Plan) developed by a Regional Water Board designates the beneficial uses for the surface and groundwater within a specified area, the water quality objectives to protect those uses, and a program of implementation needed for achieving the objectives. Two Basin Plans have been developed for the Central Valley region22 (Region 5) and cover the Hydrologic Regions mentioned above:

The Water Quality Control Plan for the Sacramento River and San Joaquin River Basins; and

The Water Quality Control Plan for the Tulare Lake Basin.

A separate document, the Water Quality Control Plan for the San Francisco Bay/ Sacramento- San Joaquin Delta Estuary, covers the San Francisco Bay and Sacramento-San Joaquin Delta and was developed by the State Water Board since it covers areas within the jurisdiction of two Regional Water Boards (Region 5 and Region 2, the San Francisco Bay Regional Water Quality Control Board). The Central Valley Water Board implements the components related to water quality within the Delta. Additional plans applicable within Region 5 include the Water Quality

22 http://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/




Control Plan for Control of Temperature in the Coastal and Interstate Waters and Enclosed Bays and Estuaries of California and the Water Quality Control Plan for Enclosed Bays and Estuaries of California.

As shown in Figure 1 and Figure 2, surface waters from the Sacramento and San Joaquin River Valleys connect in the Delta and drain to the San Francisco Bay and onward to the Pacific Ocean, or are diverted into the state and federal water projects. Surface water from the Tulare Lake Hydrologic Region, on the contrary, only drains north into the San Joaquin River in years of extreme rainfall, essentially making this region a closed basin without natural surface water outlets.

Most of the groundwater in the Central Valley moves from the edges (foothills) toward the center trough of the Central Valley floor, then toward the Delta. As defined by DWR’s Bulletin 118 (DWR B118) and shown in Figure 3, there are 86 groundwater basins and 126 groundwater subbasins within the borders of the Central Valley Region.

The two main basins within the region are the Sacramento Valley Groundwater Basin and the San Joaquin Valley Groundwater Basin. The San Joaquin Valley Groundwater Basin includes subbasins that lie within the Tulare Lake Hydrologic Region (Figure 3). The main source of groundwater in the Central Valley is typically located within the upper 1,000 feet of deposits, which contain the groundwater that is a main focus of the Central Valley Salt and Nitrate Management Plan (CV-SALTS, 2016a). In some places, saline water is found at shallow depths in continental deposits, which can result from upward migration of connate water, evaporative concentration, or estuarine water trapped during sedimentation (Page, 1986).

Each of the regions face their own challenges. For example, the Delta is the largest estuarine ecosystem on the Pacific Coast and serves as the distribution point to move water throughout the state and supply over 25-million people (CV-SALTS, 2013). For the purposes of the SNMP and the characterization of the Central Valley, the primary focus will be on the three Hydrologic Regions: the Sacramento River Hydrologic Region, the San Joaquin River Hydrologic Region, and the Tulare Lake Hydrologic Region.



Source: [SNMP Figure 2-1; CV-SALTS, 2016a]

Figure 1: Main Central Valley Hydrologic Regions and Surrounding Geography. Commented [A20]: Note: please ignore modifications to this page. Changes were made to make file smaller for the purpose of providing comments.



Source: [SNMP Figure 2-2; CV-SALTS, 2016a]

Figure 2: Central Valley Surface Water Flows. Commented [A21]: Same note as above.



Figure 3: Central Valley Groundwater Basins (DWR Bulletin 118; DWR, 2015a).

4.2 EXISTING SURFACE WATER QUALITY

4.2.1 Surface Water Body Impairments

Section 303(d) of the Clean Water Act requires states to identify water bodies (or segments of water bodies) within its boundaries that do not meet water quality standards for specific water quality parameters. Section 303(d) further requires states to develop a Total Maximum Daily

Commented [A22]: Same note as above



Load (TMDL), a plan to attain standards, for each of the listed water bodies for which there is impairment. The U.S. EPA finalized approval of California’s 2012 Section 303(d) List on July 30, 201523, which is the current listing of impaired water bodies in the Central Valley (SWRCB, 2012).

The SNMP and CV-SALTS Basin Plan Amendment proposes new policies for the regulation of salt and nitrate and a suite of secondary MCL parameters (CV-SALTS, 2016a). Parameters of interest under these new policies include the following:

Electrical conductivity (EC) and total dissolved solids (TDS)

Iron

Nitrate Manganese

Chloride Methyl-tert-butyl ether (MTBE)

Sulfate Odor-Threshold

Aluminum Silver

Color Thiobencarb

Copper Turbidity

Foaming agents (MBAS) Zinc

Water bodies located within Region 5 that are identified in the 2012 303(d) list as impaired for the above listed parameters of interest are summarized in Table 2 (SWRCB, 2012). Only listings for metals for which the Municipal and Domestic Supply (MUN) beneficial use is specified as not being supported due to the impairment are included. Additional details for each listing, such as TMDL completion date, number of exceedances, and references are included in Appendix A. The majority of the listings summarized for the parameters of interest are for electrical conductivity and total dissolved solids, followed by two listings for chloride. Only a single listing each is included for aluminum, iron, manganese, and zinc. No water bodies are listed as impaired specifically for nitrate, although one is listed for "Nutrients." A map showing the locations of the impaired 303(d)-listed water bodies for the select pollutants is provided in Figure 4.

23 The list and supporting documentation are available on the State Water Board’s website: http://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2012.shtml



Table 2: 303(d) Listed Water Bodies for Select Pollutants in Region 5.

Sacramento River Hydrologic Region Pollutant

Delta Waterways (western portion) EC

Delta Waterways (northwestern portion) EC

Knights Landing Ridge Cut (Yolo County) Salinity

Pit River (from confluence of N and S forks to Shasta Lake) Nutrients

Pit River, South Fork Salinity

Spring Creek (Colusa County) Salinity

Tule Canal (Yolo County) Salinity

San Joaquin River Hydrologic Region Pollutant

Camanche Reservoir Zinc

Carson Creek (from WWTP to Deer Creek) Aluminum

Carson Creek (from WWTP to Deer Creek) Manganese

Deer Creek (Sacramento County) Iron

Del Puerto Creek Salinity

Delta Waterways (export area) EC

Delta Waterways (southern portion) EC

Delta Waterways (western portion) EC

Grasslands Marshes EC

Ingram Creek (from confluence with San Joaquin River to confluence with Hospital Creek) Salinity

Kellogg Creek (Los Vaqueros Reservoir to Discovery Bay; Delta Waterways, west portion) Salinity Mountain House Creek (from Altamont Pass to Old River, Alameda and San Joaquin Counties; partly in Delta Waterways, southern portion)

Salinity

Mountain House Creek (from Altamont Pass to Old River, Alameda and San Joaquin Counties; partly in Delta Waterways, southern portion)

Chloride

Mud Slough, North (downstream of San Luis Drain) EC

Mud Slough, North (upstream of San Luis Drain) EC

Newman Wasteway Salinity

Old River (San Joaquin River to Delta-Mendota Canal; in Delta Waterways, south portion) EC

Old River (San Joaquin River to Delta-Mendota Canal; in Delta Waterways, south portion) TDS

Ramona Lake (Fresno County) Salinity

Salado Creek (Stanislaus County) Salinity

Salt Slough (upstream from confluence with San Joaquin River) EC

San Joaquin River (Bear Creek to Mud Slough) EC

San Joaquin River ( Mud Slough to Merced River) EC

San Joaquin River ( Merced River to Tuolumne River) EC

San Joaquin River ( Tuolumne River to Stanislaus River) EC

San Joaquin River (Stanislaus River to Delta Boundary) EC

Sand Creek (tributary Marsh Creek, Contra Costa County; Delta Waterways, west portion) Salinity

Temple Creek EC

Tom Paine Slough (in Delta Waterways, southern portion) Salinity

Tom Paine Slough (in Delta Waterways, southern portion) Chloride

Tulare Lake Hydrologic Region Pollutant Kings River, Lower (Island Weir to Stinson and Empire Weirs) EC



303(d) Listings in Region 5 for Selected Analytes

Legend

Pollutant

- Aluminum

-= Chloride

- ElectricalConductivti y

- Iron

= Manganese

- Nutrients

- Salinity

- TotalDissolved Solids

- Zlnc

N

A 0 37.5 75 --- :::====::::Miles

Figure 4: 303(d) Listed Water Bodies for Select Pollutarts.



4.2.2 Ambient Surface Water Quality Conditions

Waters quality within Region 5 is variable. Streams flowing from the igneous rocks of the Cascade Range and/or the Sierra Nevada Range to the Sacramento River Hydrologic Region and eastern portions of the San Joaquin River and Tulare Lake Hydrologic Regions provide water with low concentrations salts and nitrates (DWR, 2015b). However, flows from the marine sedimentary rocks of the Coast Ranges to the western portions of the San Joaquin River and Tulare Lake Hydrologic Regions provide water of poorer quality and higher concentrations of dissolved solids.

Sacramento River Hydrologic Region – When compared to other areas within the Central Valley, surface waters in the Sacramento River Hydrologic Region generally have low salt and nitrate levels. The northern reaches of the Sacramento River have very low salt concentrations. As the water travels south through the valley, contact with natural salts in the soil, as well as agricultural and anthropogenic activities, elevate salt and nitrate concentrations. Surface waters within the Sacramento Valley consistently have total nitrate (as N) concentrations less than 10 mg/L as N and EC concentrations less than 1,000 µS/cm (Appendix B).

San Joaquin River Hydrologic Region – The surface water quality of the San Joaquin River Hydrologic Region is primarily dependent upon the source of the water, geologic influence, and land use, and reservoir operations. Streams in the western portion of the basin are mainly ephemeral, with the downstream channels mainly being used to transport high salinity agricultural return flows to the main channel of the San Joaquin River. The eastern portion of the region is generally characterized by higher quality and higher volume of surface water derived from Sierra Nevada snowmelt. Nitrate and EC concentrations in surface waters east of the San Joaquin River are generally of better quality compared to west of the San Joaquin River (Appendix B)(CV-SALTS, 2013 – Appendix G). West and southwest of the San Joaquin River, high salinity soils, low flows and agricultural return flows contribute to EC concentrations far above 1,000 µS/cm, while east of the San Joaquin River concentrations are typically less than 500 µS/cm (Appendix B). Despite high quality surface water inputs from the east side of the region, due to the diversions of the natural headwaters as part of the federal Central Valley Project and higher salinity content water being imported to the basin from the Delta, the San Joaquin River continues to experience increased salt concentrations. This caused the river to become the focus of the development of a Basin Plan Amendment for salt and boron in the Lower San Joaquin River, a special case study through CV-SALTS to identify appropriate salt and boron water quality objectives and a program of implementation to protect the most sensitive beneficial use, agricultural supply (AGR) (CV-SALTS, 2015).

Tulare Lake Hydrologic Region – The Tulare Lake Hydrologic Region has few natural surface water sources, most of which originate from Sierra Nevada snowmelt and are concentrated in the eastern portion of the region. Where measured, nitrate concentrations in natural source waters are generally below 10 mg/L as N. EC concentrations in natural



source waters are variable, but are typically below 1,000 µS/cm. However, irrigation drainage and canals can experiences EC concentrations above 1,000 µS/cm (Appendix B).

Surface water from the Sacramento River Hydrologic Region and the San Joaquin River Hydrologic Region meet in the Delta, which ultimately drains to San Francisco Bay. The primary sources of salinity in the Delta are from tidal seawater intrusion from the Pacific Ocean through the San Francisco Bay, and to a lesser extent, from agricultural and other discharges in the Central Valley. Salinity affects Delta agricultural, municipal, and environmental beneficial uses. The timing and distribution of salinity is primarily affected by flow, which is largely determined by water management in the Delta and watersheds upstream of the Delta (DWR, 2014).

To characterize surface water for salt, nitrate, and secondary MCLs, major water bodies within each of the three Hydrologic Regions were identified and monitoring stations were selected based on data availability and period of record. Available data were obtained through the California Environmental Data Exchange Network (CEDEN)24 and United States Geological Survey (USGS) Water Quality Portal (WQP)25 (Figure 5). To best represent current surface water quality and to capture a good representation of different water year types26, only data from 1990 to present were obtained for inclusion in the current analysis. Sites selected for the analysis needed to meet the following criteria:

For EC, a monitoring station needed to have greater than 50 measurements;

For Nitrate, a monitoring station needed to have greater than 20 measurements;

For aluminum, iron, or manganese, a monitoring station needed to have greater than 10 measurements; and

The date range for the measurements at a monitoring station had to be greater than 2 years.

For each monitoring location selected (Table 3, Figure 6), time series plots over the period of record were developed for each constituent and basic summary statistics calculated to generate box and whisker plots for each site-constituent combination. Concentrations of metals with drinking water secondary MCL standards (i.e., aluminum, copper, iron, manganese, silver, and zinc) are of particular interest due to clarifications to current secondary MCL standards

24 http://www.ceden.org/ 25 The Water Quality Portal is a cooperative service sponsored by USGS, U.S. Environmental Protection Agency (EPA), and National Water Quality Monitoring Council that integrates publicly available water-quality data from the USGS National Water Information System (NWIS) database and the EPA STOrage and RETrieval (STORET) data warehouse. http://www.waterqualitydata.us 26 http://cdec.water.ca.gov/cgi-progs/iodir/WSIHIST – San Joaquin Valley or Sacramento Valley Water Year Hydrologic Classification (e.g., critical, dry, below normal, above normal, wet). The method for determining the Water Year Hydrologic Classification is defined in the SWRCB Revised Water Right Decision 1641, March 2000, Figure 2, page 189.



0 12.525 50 75 100 • • Miles

implementation contained in the proposed Central Valley SNMP Basin Plan Amendment (CV- SALTS, 2016a). In addition, several watershed sanitary sUIVeys were reviewed to supplement the information developed under the current ambient surface water data assessment (Table 4).

Legend

CEDEN si tes

• USGS sites

-- Rivers

DCentral Valley

l._iDelta

ASSOCIATES

D Sacramento River HR

DSan Joaquin River HR

:=J Tulare Lake HR

N

A

Figure 5: CEDEN and USGS Monitoring Locations in Region 5 Where Data are collected for Salts,Nitrate,and Constituents with Secondary MCLs.

Commented [A23]: Please ignore change to map. These were made to make file smaller for purpose of providing comments.



WALKE R

ASSOCIATES

Legend

• Selected Site Locations

-- Rivers

c:::J Central Valley

L_] Delta

c=J Sacramento River HR

San Joaquin River HR

t=J Tulare Lake HR

N

A 0 12.525

50 75 100

•-=:II•ICII--c====--•Miles

Figure 6: Selected CEDEN and USGS Monitoring Sites used to Characterize Surface Water Quality in Region 5. Commented [A24]: Same note as above



Table 3: Selected Monitoring Sites used to Characterize Surface Water Quality in Region 5.

Site Designation

Monitoring Location Name1

EC

Nitrate2

Aluminum2

Iron2

Manganese2

Tulare Lake Hydrologic Region

Kaweah above Tokopah Falls

MARBLE FORK KAWEAH R AB TOKOPAH FALLS NR KAWEAH CA

X

Main Drain Canal near Hwy 46

Main Drain Canal near Highway 46 X

Kings River at Manning Avenue

Kings River at Manning Avenue X T

Gould Canal at Riverbend Ave

Gould Canal at Riverbend Ave X T

San Joaquin River Hydrologic Region

Cosumnes River at Michigan Bar

COSUMNES R A MICHIGAN BAR CA

X D D

Cosumnes River @ Michigan Bar X

Merced River near Newman

MERCED R A RIVER ROAD BRIDGE NR NEWMAN CA

X D D D

Merced River @ River Road X

Mud Slough Near Gustine

MUD SLOUGH NR GUSTINE CA X D D D

Mud Slough downstream of San Luis Drain

X

Orestimba Creek at Hwy 33

Orestimba Creek @ Hwy 33 X

Salt Slough at Lander Avenue

SALT SLOUGH A HWY 165 NR STEVINSON CA

X D D D

Salt Slough @ Lander Avenue X

San Joaquin River above Maze Blvd

SAN JOAQUIN R AT MAZE RD BRIDGE NR MODESTO CA

X D

San Joaquin River above Maze Boulevard

X

San Joaquin River at Crows Landing

SAN JOAQUIN R NR CROWS LANDING CA

X D

SJR @ Crows Landing X

San Joaquin River at Vernalis

SAN JOAQUIN R NR VERNALIS CA X D D D D

San Joaquin River at Airport Way near Vernalis

X



Site Designation

Monitoring Location Name1

EC

Nitrate2

Aluminum2

Iron2

Manganese2

San Joaquin River (BG30)

San Joaquin River (BG30) D D, T D, T

Stanislaus River at Ripon

STANISLAUS R A RIPON CA X D D D

Tuolumne River at Modesto

TUOLUMNE R A MODESTO CA X D D D

Sacramento River Hydrologic Region

American River at Discovery Park

AMERICAN R A SACRAMENTO CA X D D D D

American R @ Discovery Park X T

Colusa Basin Drain above Knights Landing

COLUSA BASIN DR A RD 99E NR KNIGHTS LANDING CA

X D D D

Colusa Basin Drain above Knights Landing (SVWQC)

X D, T

Feather River at Nicolaus

FEATHER R NR NICOLAUS X D D D D

Feather River at Nicolaus- 515ST0472

X

Sacramento River at Colusa

SACRAMENTO R A COLUSA CA X D D D D

Sacramento River at Colusa (SVWQC)

X

Sacramento River at Colusa near Bridge Street

X

Sacramento River at Freeport

SACRAMENTO R A FREEPORT CA X D D D D

Sacramento River at Freeport (SVWQC)

X

Sacramento River Below Keswick

SACRAMENTO R A KESWICK CA X D, T D D D

Sacramento River Below Keswick (SVWQC)

X

SACRAMENTO R BL KESWICK DAM

T T

Sacramento River below Verona

SACRAMENTO R A VERONA CA X D D D D

Sacramento River below Verona X

Sacramento River (BG20)

Sacramento River (BG20) D D, T D, T

Yuba River at Marysville

YUBA R A MARYSVILLE CA X D D D D

Yuba River at Marysville X

[1] Italics – CEDEN site name; CAPITOLIZED – USGS site name

[2] D – dissolved fraction; T – total fraction



Table 4: Summary of Watershed Sanitary Survey Information for Select Parameters.

Watershed Sanitary Survey Parameters of Interest

California State Water Project (2011 Update)[a]

Salinity, turbidity, nutrients, taste and odor incidents, as well as trace elements and organic chemicals are specifically addressed in the survey as water quality constituents having the capacity to cause drinking water standards to be violated or to reduce the quality of drinking water supplies conveyed through the State Water Project. All available water quality data at a number of locations in the watersheds, the Delta, and along the State Water Project facilities were evaluated for the update. An evaluation of the data indicate the following: ● EC levels are considerably lower in the American, Sacramento, and Mokelumne (at Wimpys) Rivers than in the San Joaquin River (at Vernalis) and Calaveras River (at Brookside Road). Data presented for Vernalis and several State Water Project facilities (such as the Delta Mendota Canal at McCabe and the O'Neill Pump-Generating Plant Intake, the O'Neill Forebay Outlet, and Check 41) are shown to exceed the recommended secondary MCL. ● Turbidity levels are observed to be higher in the Sacramento and San Joaquin (at Vernalis) Rivers than the American and Calaveras Rivers. ● Nutrient concentrations reported as total Nitrogen are considerably below 10 mg/L at all monitoring locations presented. ● Taste and odor (T&O) incidents are common in the Delta and State Water Project. Problematic levels of two compounds most often responsible for problems have been observed in the Delta, along the California Aqueduct, and in southern California reservoirs. ● Within the discussions for trace elements and organic chemicals, none of the specific parameters of interest for the project are indicated to be of concern.

State Water Project Volume 1 of 5: The San Joaquin River (2013/2014 Update)[b]

This recent State Water Project sanitary survey update focuses on the San Joaquin River watershed upstream of the Vernalis water quality station, the legal boundary for the Sacramento-San Joaquin River Delta. Potential contaminants of concern include salinity (i.e., electrical conductivity and total dissolved solids), nutrients (including nitrate), turbidity, as well as trace elements and pesticides. ● EC levels and TDS concentrations in the San Joaquin River Watershed are shown to exceed the recommended secondary MCLs. ● Exceedances of the MCL of 10 mg/L as N for nitrate are shown to occur in multiple counties within the survey area. ● Turbidity levels are reported to be highest within Fresno and Mariposa Counties, while typically lowest in Madera County. ● Within the discussions for trace elements and pesticides, none of the specific parameters of interest for the project are indicated to be of concern.

American River (2013 Update)[c] The survey focuses on constituents of interest for drinking water purposes including turbidity and other detected constituents that have a primary or secondary drinking water standard. ● The American River is generally low in solids, with monthly average peak daily turbidity levels (observed along the river from the North Fork at Placer County Water Agency's American River Pump Station to the Lower American River at Discovery Park) below 75 Nephelometric turbidity units (NTU); typically, peak daily turbidity is stated to be less than 10 NTU. ● A review of monitoring program data in urban creeks (Willow Creek) and from urban runoff discharge points show that total iron has been detected above the secondary MCLs. ● No other specific parameters of interest for the project are addressed as concerns.




Watershed Sanitary Survey Parameters of Interest

Sacramento River (2015 Update)[d] Key findings were developed for constituents of interest including turbidity, volatile and synthetic organic compounds, aluminum, iron, and manganese. ● Generally, turbidity levels range between 10 to 100 NTU. It is typical for turbidity levels in the Lower American River to be lower than those in the Sacramento River. ● Levels of iron, aluminum, and manganese can be well above their respective secondary MCLs in the Sacramento River. ● Thiobencarb has been historically detected in the Sacramento River and is a focus of the Sacramento River Source Water Protection Program. ● No other specific parameters of interest for the project are addressed as concerns.

Jenkinson Lake and Middle Fork Cosumnes River[e]

El Dorado Irrigation District (2013 Update)

Of the specific parameters of interest for the project, only water quality of turbidity within the Jenkinson Lake and Middle Fork Cosumnes River Watersheds is discussed. In general, turbidity levels are generally under 10 NTU.

Stanislaus River (2006 Update)[f] Of the specific parameters of interest for the project, only water quality of turbidity is a focus; no significant concerns are identified. In general, water in the Stanislaus River watershed has low turbidity; historical data indicates annual averages of less than 10.0 NTU.

Santa Clara River (2011 Update)[g]

United Water Conservation District Nitrate is included as a constituent of concern for the Oxnard-Hueneme Water System, although it is stated that the Santa Clara River exhibits relatively low concentrations of nitrate. No concerns are addressed for the Lake Piru Recreation Area Water System, for which water quality reflects that of the quality imported from the State Water Project. No other specific parameters of interest for the project are addressed as significant concerns.

References:

[a] Archibald Consulting, Palencia Consulting Engineers, and Starr Consulting. 2012.

[b] DWR, MWQI. 2015.

[c] Starr Consulting and Palencia Consulting Engineers. 2013.

[d] Starr Consulting, Palencia Consulting Engineers, and Rincon Consultants, Inc. 2015.

[e] El Dorado Irrigation District. 2014.

[f] Black & Veatch. 2006.

[g] Morgan, Craig and Linda Purpus. 2011.

Electrical Conductivity

Among the CEDEN and USGS the databases, electrical conductivity (EC) is the most frequently measured and recorded parameter. A summary of EC findings for each Hydrologic Region is provided below.

EC data were available at eight of the selected monitoring locations throughout the Sacramento River Hydrologic Region (Figures B-1 through B-3; Appendix B). Overall, water quality for EC is considered to be good, with median and 1st through 3rd quartile values at all monitoring locations falling below the recommended secondary MCL of 900 µS/cm. EC levels between stations typically vary by about 100s µS/cm, with the exception of the Colusa Basin Drain.



EC data were available at ten of the selected monitoring locations in the San Joaquin River Hydrologic Region (Figures B-4 through B-6; Appendix B). East side tributaries to the San Joaquin River (Cosumnes, Merced, Stanislaus, and Tuolumne Rivers) show EC values lower than the recommended secondary MCL of 900 µS/cm. Tributaries to the west and southwest of the San Joaquin River (Mud Slough, Salt Slough, and Orestimba Creek) have EC values between the 1st and 3rd quartiles which fall at or above the recommended secondary MCL objective. EC measurements in the main stem of the San Joaquin River show a wide range of values. The median EC value at Crows Landing is 910 µS/cm, which is slightly above the recommended secondary MCL. EC values then decrease between Crows Landing and Maze Road Bridge and again between Maze Road Bridge and Vernalis. The improvement in water quality is likely due to east side tributary contributions. EC in the main stem of the San Joaquin River is also highly variable and dependent on water year type and the water quality and flows of the east side tributaries. High EC levels seen at Crows Landing during dry years are shown to decrease substantially by the time water reaches Maze Road Bridge (Appendix C) (CV-SALTS, 2015).

Sacramento River site BG20 and Harvey O. Banks Pumping Plan Headworks are both located within the Delta. Although these sites experience higher levels in the mid-upper hundreds, EC levels rarely exceed the recommended secondary MCL for EC (Figures B-7 and B-8; Appendix B).

EC data were available at four of the selected monitoring locations in the Tulare Lake Hydrologic Region (Figures B-9 and B-10; Appendix B). Medians and calculated values within the 1st and 3rd quartiles are lower than the recommended secondary MCL with the exception of the Main Drain Canal monitoring site, which experiences high EC levels during irrigation events.

Nitrate as N

Nitrate concentrations measured as N were available at eight of the selected monitoring locations in the Sacramento River Hydrologic Region (Figures B-11 and B-12; Appendix B). Overall, water quality for nitrate is considered to be good, with median and 1st through 3rd quartile values at all monitoring locations falling below the Primary MCL of 10 mg/L as N. Nitrate levels for the various stations are typically below 0.5 mg/L with the exception of the Colusa Basin Drain which can periodically show concentrations up to 4 mg/L as N.

Nitrate concentrations measured as N were available at nine of the selected monitoring locations in the San Joaquin River Hydrologic Region (Figures B-13 and B-14; Appendix B). All nitrate values for tributaries to the east of the San Joaquin River (Cosumnes, Merced, Stanislaus, and Tuolumne Rivers) were lower than the Primary MCL of 10 mg/L as N. Nitrate values were higher in tributaries to the west and southwest of the San Joaquin River (Mud Slough, and Salt Slough), but with a median still below the Primary MCL. The highest median was recorded in the San Joaquin River at the Maze Road Bridge monitoring site; however, this calculated median was based on a limited data set.

Three monitoring locations located in the Delta had a small amount of nitrate as N data which all fell below the primary MCL (Figures B-15 and B-16; Appendix B).



Nitrate as N data were available at three of the selected monitoring locations in the Tulare Lake Hydrologic Region (Figures B-17 and B-18; Appendix B). All values fell below the primary MCL of 10 mg/L as N.

Aluminum

Among the two databases examined, aluminum is most frequently measured and recorded in the Sacramento River Hydrologic Region as a dissolved fraction and rarely as total aluminum. There are few data for aluminum in the other Hydrologic Regions. Averages and medians of dissolved aluminum at all monitoring locations where sufficient data are available fall below the secondary MCL of 200 µg/L. However, total aluminum is frequently measured at or above the secondary MCL. A summary of findings for each Hydrologic Region is provided below.

Dissolved aluminum data were available at eight of the selected monitoring locations throughout the Sacramento River Hydrologic Region and total Aluminum data were available at one location (Figures B-19 through B-21; Appendix B). Average and median dissolved aluminum data are lower than the secondary MCL objective at all monitoring locations. Total aluminum data at the Sacramento River below Keswick reservoir were found to be at or frequently above the secondary MCL objective.

Information presented within relevant sanitary surveys indicate that surface water levels of aluminum can be well above the secondary MCL in the Sacramento River. Average and median values were near to or greater than the secondary MCL for aluminum at all sanitary sewer monitoring locations, except for Discovery Park on the Lower American River. Levels increase between Hamilton City to Colusa, and then again between Colusa and Verona. Agricultural drains have higher levels than the main stem. Butte Slough, Colusa Basin Drain, and Sutter Bypass all enter downstream of Colusa and have recorded very high levels of aluminum. Butte Slough has a median of 329.5 µg/L and Sutter Bypass has a median of 316 µg/L. Colusa Basin Drain records the highest aluminum levels of the three drains with a median of 892 µg/L. Aluminum decreases at Verona, likely due to low levels of aluminum in the Feather River (Starr Consulting, Palencia Consulting Engineers, and Rincon Consultants, Inc., 2015).

Dissolved aluminum data were available at one of the selected monitoring locations in the San Joaquin River Hydrologic Region (Figures B-22 and B-23; Appendix B). All measured values fell below the secondary MCL objective for aluminum of 200 µg/L.

The monitoring location at Banks Pumping Plant Headworks within the Delta collects both dissolved and total aluminum data (Figures B-24 and B-25; Appendix B). Dissolved aluminum values fell below the secondary MCL objective while total aluminum values frequently exceeded the objective.

Aluminum data were not available at any of the selected monitoring locations in the Tulare Lake Hydrologic Region.




Iron

As contained in the two databases relied upon in the present analysis, iron is most frequently measured as a dissolved fraction and rarely as total iron. Averages and medians of dissolved iron at all monitoring locations fall below the secondary MCL. However, total iron is frequently measured at or above the secondary MCL of 300 µg/L. A summary of findings for each Hydrologic Region is provided below.

Dissolved iron measurements were available at eight of the selected monitoring sites in the Sacramento River Hydrologic Region and total iron data were available at one of the selected monitoring locations (Figures B-26 through B-28; Appendix B). Average and median dissolved iron were lower than the secondary MCL objective at all of the monitoring locations. Total iron is frequently at or above the secondary MCL at all of the monitoring locations.

Information presented within relevant sanitary surveys indicates that raw water levels of iron can be well above the secondary MCL in the Sacramento River. Average and median values were near to or greater than the secondary MCL for iron at all sanitary survey monitoring locations, except for Discovery Park on the Lower American River. Levels increase between Hamilton City to Colusa, and then again between Colusa and Verona. Agricultural drains have higher levels than the main stem Sacramento River. Butte Slough, Colusa Basin Drain, and Sutter Bypass all enter downstream of Colusa and have recorded very high levels of iron. Butte Slough has a median of 728 µg/L and Sutter Bypass has a median of 637.5 µg/L. Colusa Basin Drain records the highest iron levels of the three drains with a median of 1,330 µg/L. Iron decreases at Verona, likely due to low levels of iron in the Feather River (Starr Consulting, Palencia Consulting Engineers, and Rincon Consultants, Inc., 2015).

Dissolved iron was available at eight of the selected monitoring locations in the San Joaquin River Hydrologic Region (Figures B-29 and B-30; Appendix B). Average and median dissolved iron data were lower than the secondary MCL objective for iron of 300 µg/L at all of the monitoring locations. The Stanislaus, Tuolumne, Merced, and Cosumnes Rivers show higher concentrations relative to those seen in the San Joaquin River.

Total and dissolved iron was available at three delta monitoring locations (Figure B-31 and B- 32; Appendix B). All dissolved iron values fell below the secondary MCL objective; however, total iron data are found to at or frequently above the secondary MCL objective.

Iron data were not available at any of the selected monitoring locations in the Tulare Lake Hydrologic Region.

Manganese

As contained in the two databases relied upon in the present analysis, manganese is most frequently measured and recorded as a dissolved fraction and rarely as total manganese. Available data were compared to the secondary MCL for manganese of 50 µg/L. A summary of finding for each Hydrologic Region is provided below.

Commented [A27]: **Please see comments in Antidegradation Analysis document, which also apply here. We incorporate those comments by reference.

Commented [A28]: **Please see comments in Antidegradation Analysis document, which also apply here. We incorporate those comments by reference.



Within the Sacramento River Hydrologic Region, dissolved manganese was available at eight of the selected monitoring site locations and total manganese was available at one of the selected monitoring locations (Figure B-33 through B-35; Appendix B). Average and median dissolved manganese were lower than the secondary MCL objective at all of the monitoring locations. Total manganese was found to be above the secondary MCL in the Colusa Basin Drain, the one site where it was measured.

As reported in relevant sanitary surveys, the raw water levels of manganese can be above the secondary MCL in the Sacramento River. For the sanitary survey monitoring stations, the manganese levels in the Sacramento River are higher upstream than those observed downstream. Monitoring performed within the watershed in other receiving waters observed the same trend (Starr Consulting, Palencia Consulting Engineers, and Rincon Consultants, Inc., 2015).

Dissolved manganese concentration data were available at seven of the selected monitoring locations in the San Joaquin River Hydrologic Region (Figure B-36 and B-37; Appendix B). Average and median dissolved manganese, were greater than the secondary MCL objective of 50 µg/L in Mud Slough and Salt Slough. At other locations within the region, the average and median were found to be lower than the secondary MCL with occasional values that exceed the secondary MCL.

Total and dissolved manganese data were available at three delta monitoring locations (Figures B-38 and B-39; Appendix B). Dissolved manganese concentrations were below the secondary MCL objective at all three locations. Total Manganese concentrations were below the secondary MCL at the Banks Pumping Plant Headworks and at Sacramento River location BG 20. Total manganese data on the San Joaquin River at site BG 30 were below the secondary MCL objective.

Manganese data were not available at any of the selected monitoring locations in the Tulare Lake Hydrologic Region and, as such, there were no data available to characterize or draw conclusions with respect to manganese for the region.

Other Secondary MCLs

Basic statistics were conducted on the other secondary MCL’s and parameters of interest. The median values calculated from all of the available surface water monitoring data in CEDEN are summarized for each of the Hydrologic Regions in Table 5.




Table 5: Summary of Surface Water Quality Data available through the California Environmental Data Exchange Network (CEDEN) for Constituents with Secondary MCL Standards.

Analyte

Secondary MCL

(µg/L)*

Sacramento River

San Joaquin River

Tulare Lake

n Median (µg/L)*

n Median (µg/L)*

n Median (µg/L)

Aluminum, Dissolved 27 12.9 4 9.48 --- ---

Aluminum, Total 200 45 130.7 --- --- --- ---

Chloride, Dissolved* (mg/L)

300

1.87

177

3.3

167

1.7

Chloride, Not Recordeda* (mg/L)

40

4.02

1,321

64.7

49

4.17

Chloride, Total* (mg/L)

Recommended 250

28

0.05b

33

0.13

4

32.2

Copper, Dissolved 422 2.11 2,372 1.38 476 1.5

Copper, Total 1,000 632 3.54 3,851 3.44 368 5.33

Iron, Dissolved 16 55.7 15 47 139 18.6

Iron, Total 300 143 415.5 14 572 49 145

Manganese, Dissolved

27

4.3

25

4.03

139

1.7

Manganese, Total 50 155 32.5 25 24.9 44 14.2

MBAs, Total 500 50 10.7 10 40.4 --- ---

Silver, Dissolved 95 0.001 59 0.0013 --- ---

Silver, Total 100 180 0.004 58 0.0034 --- ---

Sulfate, Dissolved* (mg/L)

296

1.98

126

2.38

167

2.74

Sulfate, Not Recordeda* (mg/L)

40

3.07

1,323

74.89

49

5.64

Sulfate, Total* (mg/L) Recommended

250

198

6.62

11

0.99b

---

---

Thiobencarb, Total 1 306 0.00044 957 NDc 177 NDc

Turbidity* (NTU) 5 5,717 5.55 7,305 13.49 1,124 3.01

Zinc, Dissolved 241 2.12 2,097 0.99 279 1.82

Zinc, Total 5,000 484 4.86 3,510 4.95 392 7.14 [*] data are shown in units of µg/L, except when noted [a] Values indicate probable representation of "total" fraction for analyte.

[b] Limited amount of data compared to dissolved, resulting in lower "total" fraction value.

[c] Less than 10% detected data.

Turbidity

Turbidity levels vary greatly depending on season and location. The Sacramento River has high turbidity during the winter months and low turbidity during the summer, while the San Joaquin



River shows an opposite pattern with high turbidity during the summer (Archibald Consulting, Palencia Consulting Engineers, and Starr Consulting, 2012).

Turbidity related to suspended particulate matter is correlated with total iron, manganese, and aluminum measurements. Particularly in the Sacramento River, a significant proportion of the metals transported in the waterbody occurs in colloidal form which represents the dominant form of aluminum and iron in the water column (Alpers, 2000). Total iron, manganese, and aluminum go up and down with winter spikes in turbidity. However, dissolved fractions of these constituents remain low as the metals are present in the suspended sediment in the river that causes high turbidity readings. Likewise, in the San Joaquin River, agricultural drainage with suspended sediment during the growing season contributes to elevated turbidity and increased total fractions of metal ions.

On the Sacramento River, turbidity levels are seasonally variable, with the highest levels occurring during the wet season, typically in January and February. Turbidity is directly related to flow in the river; when flows increase, turbidity increases. Turbidity levels decline during the spring and summer months and reach the lowest levels in the fall when flows on the river are lowest. Turbidity levels rise when storm events result in increasing flows during the winter months (Archibald Consulting, Palencia Consulting Engineers, and Starr Consulting, 2012).

The San Joaquin River has a pattern of rapidly increasing turbidity when flows first increase in the winter months due to storm events; however, during prolonged periods of high flows, turbidity drops. This could be due to high quality water being released from upstream reservoirs rather than storm-generated flows. During the summer months, turbidity is inversely proportional to flow. As the river flow decreases in the summer, a larger percent of the water in the river is agricultural drainage, which could be one source of the high turbidity levels measured in summer. Another possible source is increased algal production during the summer months. Turbidity levels are highest in the summer, but the variability in turbidity is greatest during the winter months due to storm events (Archibald Consulting, Palencia Consulting Engineers, and Starr Consulting, 2012).

The seasonal turbidity pattern at Banks Pumping Plant is similar to that in the San Joaquin River. Turbidity is quite high at Mendota with a median of 10.85 Nephelometric turbidity units (NTU). Between Mendota and Lander Avenue, turbidity increases with a median of 23.0 NTU. Salt Slough’s turbidity contribution to the San Joaquin River is greater than that of Mud Slough, with a median of 21.0 NTU for Mud Slough and 30.0 NTU for Salt Slough. Both sloughs and Crows Landings have relatively high turbidity levels, indicating limited dilution effects from the Merced River on the Lower San Joaquin River. Further downstream at the Patterson Irrigation District Pumps, the effect the Merced River has on water quality in the San Joaquin River can be seen as the median turbidity at the Patterson Irrigation District Pumps decreases to 17.0 NTU. The decrease in turbidity at Vernalis could be attributed to the influences of the Tuolumne and Stanislaus Rivers on the Lower San Joaquin River (DWR, 2015b).



4.3 EXISTING GROUNDWATER QUALITY

4.3.1 Basin and Subbasin Boundaries

Groundwater basins and subbasins are defined by the DWR B118. There are 126 groundwater basins/subbasins located within Region 5. Of these, 41 groundwater basins/subbasins overlay the Central Valley Floor (defined in the SNMP as the extent of the Central Valley Hydrologic Model (CVHM) model boundary; CV-SALTS, 2016a) and 85 of the basins/subbasins are located outside the Central Valley Floor. The entire Region 5 area covered by groundwater basins is approximately 24,100 square miles; the area of the 41 basins/subbasins in the Valley Floor is approximately 20,500 square miles, or about 85% of the total groundwater basins/subbasins within Region 5. These basins and subbasins are shown in Figure 7. Detailed information about each basin can be found in DWR B11827. Key groundwater basins and subbasins within each of the DWR-defined Hydrologic Regions are described below (CV-SALTS, 2016c).

Sacramento River Hydrologic Region – The Sacramento Valley Groundwater Basin is the main groundwater basin located in the Sacramento River Hydrologic Region and is divided into 18 groundwater subbasins, based on hydrologic, geologic, and political boundaries, covering 6,057 square miles of the Central Valley Floor. Other groundwater basins outside the Valley Floor within the Sacramento River Hydrologic Region are shown in Figure 3, with the majority of these basins occurring in the northeastern portion of the Hydrologic Region.

San Joaquin River Hydrologic Region – The San Joaquin Valley Groundwater Basin is the main groundwater basin that covers the San Joaquin River Hydrologic Region. The Basin is further divided into 9 groundwater subbasins, based on hydrologic, geologic, political boundaries, covering 10,591 square miles of the Central Valley Floor.

Tulare Lake Hydrologic Region – The San Joaquin Valley Groundwater Basin is the main groundwater basin that covers the Tule Lake Hydrologic Region. Within this region, the Basin is further divided into 7 groundwater subbasins. Together, the Tulare Lake, Kings, Westside, Tule, Kern County, and Kaweah Groundwater Subbasins of the San Joaquin Valley Groundwater Basin cover 4,783 square miles.

Throughout the Central Valley, water is utilized for a wide range of uses including agriculture, municipal/domestic use, recreation, managed wetlands, etc. High quality water is of importance for the economy related to agriculture and for drinking water. However, groundwater quality in the Central Valley Floor is very regionally dependent and in various regions can exceed drinking water standards (Table 3).

27 http://www.water.ca.gov/ground water/bulletin118/index.cfm



4.3.2 High Resolution Mapping for the Central Valley SNMP

Within the Central Valley Floor

Groundwater quality analyses and mapping using high resolution techniques were recently prepared as described in the Updated Groundwater Quality Analysis and High Resolution Mapping for Central Valley Salt and Nitrate Management Plan (CV-SALTS, 2016c). The high resolution work provides a detailed look at groundwater quality conditions throughout the Central Valley Floor and groundwater basins/subbasins within Region 5, including those located outside of the Central Valley Floor (Table 6).

High resolution groundwater quality maps for three defined groundwater zones (Upper, Lower, and Production Zones ) within the Central Valley Floor provide a highly refined and accurate characterization of the ambient groundwater quality and assimilative capacity at the groundwater basin/subbasin scale as well as at the Initial Analysis Zone (IAZ) scale . The Upper Zone includes the depth from the bottom of the vadose zone to the top of the Lower Zone and where the Corcoran Clay is present, the Upper Zone does not extend below the Corcoran Clay. The Lower Zone includes the depth from the bottom of the Upper Zone to the depth of the bottom of the Lower Zone and within the Corcoran Clay area, the Lower Zone is bounded at the bottom by the top of the Corcoran Clay layer. The Production Zone combines the Upper Zone and the Lower Zone and is defined as the portion of the aquifer system where the majority of groundwater production occurs.

The high resolution detail provides preliminary local information for identifying future assessment of local and regional data gaps and monitoring needs. The evaluation also facilitates regional salt and nitrate management for the entirety of Region 5's jurisdiction, including the planning and implementation of long-term strategies and assessment of interim measures.



Source: [NIMS Figure 2-1; CV-SALTS, 2016b]

Figure 7: DWR Bulletin 118 Groundwater Basins/Subbasins in the Central Valley Floor. Commented [A30]: Same note as above.

CentralValley Salt and Nitrate Management Plan CentralValley RegionalWater Quality ControlBoard

larry Walker Associates Economic Analysis 65

Nitrate (mg/ as N)

TDS (mg/L)

DWR 8118 Groundwater Basin Code

Upper zone

Lower Zone*

Production Zone

Upper Zone

Lower Zone*

Production zone

> ..!!! iij > i.i.. .... c: u

C1l

c..:. C1l

..t.:.:. ... z0

5-6.01 1.04 1.05 1.05 164 178 172 5-6.02 0.95 1.36 1.16 149 202 176

5-6.03 1.03 1.21 1.12 190 147 168 5-6.04 0.99 1.45 1.22 258 159 198 5-6.05 0.92 1.76 1.28 148 160 154 5-6.06 0.85 0.89 0.87 162 192 176

5-21.50 1.37 1.88 1.67 238 238 238 5-21.51 1.78 2.34 2.16 289 264 272 5-21.52 3.29 2.87 3.06 613 472 533 5-21.53 1.23 2.20 1.77 234 262 250 5-21.54 1.92 3.06 2.66 361 297 320 5-21.55 1.59 1.91 1.80 226 223 224

5-21.56 2.42 1.36 1.67 200 181 186 5-21.57 2.83 2.08 2.28 204 192 195 5-21.58 2.62 1.38 1.80 403 313 343 5-21.59 1.93 0.99 1.31 338 310 320 5-21.60 2.19 2.35 2.28 349 295 317 5-21.61 2.91 1.90 2.30 430 365 391 5-21.62 2.37 1.15 1.67 992 918 950 5-21.64 3.67 1.58 2.37 446 298 353 5-21.67 12.27 3.59 7.63 790 523 647

5-21.68 2.66 6.03 4.58 1069 635 823

> ..!!! iij

-> .l..t.l.

uC1l

..!!! "0 "0

2-3 3.48 3.47 3.47 1400 564 900 2-4 4.82 1.07 2.68 2896 671 1628

5-21.65 2.13 1.55 1.78 343 222 270 5-21.66 4.46 2.68 3.36 935 504 669 5-22.01 6.07 3.69 4.72. 506 293 385

5-22.02 7.58 3.74 5.53 352 217 280

5-22.03 10.97 4.63 7.74 439 211 322 5-22.04 6.48 3.46 4.85 418 261 334 5-22.05 8.88 6.64 8.21 874 540 774

5-22.06 4.65 3.78 4.09 417 275 325

5-22.07 5.84 3.32 5.01 1307 928 1184 5-22.15 3.64 2.30 3.04 1255 890 1091 5-22.16 2.65 1.48 1.87 206 227 220

> c..:.-

C1l

C1l ltl

O..S..:. >

::I .l..t.l. 0

V) c: u

C1l

5-22.08 7.12 6.62 6.84 560 391 464 5-22.09 1.26 2.86 1.80 2038 1165 1744

5-22.10 2.32 0.43 1.37 3218 846 2025 5-22.11 11.88 13.38 12.64 514 419 465 5-22.12 5.33 1.36 3.23 1659 740 1173

5-22.13 8.31 8.29 8.30 588 382 465

5-22.14 5.54 3.29 3.76 2313 561 1177

Table 6: Aggregate (Volume-Weighted) Ambient Conditions for Nitrate and TDS in Groundwater.

Aggregate (Volume Weighted) Ambient Conditions

c:

•Above Corcoran Clay wh ere present.



The high resolution work includes the following analysis at the basin/subbasin and IAZ scale:

Basic statistical analyses, including minimum, maximum, average, and median values for nitrate and TDS, for the 41 groundwater basins/subbasins overlying the Central Valley Floor and for the other 85 basins/subbasins in Region 5 that are located or partially located outside the Central Valley Floor. Results of the analyses are included in Appendix C.

High resolution ambient groundwater quality maps (nitrate and TDS) for the Central Valley Floor (for three defined zones: Upper, Lower, and Production Zones) and for basins/subbasins outside the Central Valley where sufficient data are available;

High resolution assimilative capacity maps (nitrate and TDS) for the Central Valley Floor (Upper, Lower, and Production Zones) and for basins/subbasins outside the Central Valley where sufficient data are available;

Groundwater quality trends for the Central Valley Floor in the upper, lower, and production zones for both nitrate and TDS; and

Maps featuring predicted future groundwater quality conditions for the 10, 20, and 50 year time frame.

Outside of the Central Valley Floor

There are 85 basins/subbasins in Region 5 that are located or partially located outside the Central Valley Floor. These basins/subbasins were analyzed where there were sufficient data as part of the groundwater quality analyses and high resolution mapping effort (CV-SALTS, 2016c). Wells outside of the Central Valley Floor were not categorized into aquifer zones. However, summary statistics for wells outside the Central Valley Floor within DWR B118 groundwater subbasins and Region 5 are included in the summary tables (Appendix C). For 16 of the 85 DWR B118 subbasins outside of the Central Valley Floor that had sufficient data for interpolation, results for ambient conditions and assimilative capacity are provided as part of the groundwater quality analyses and high resolution mapping effort (CV-SALTS, 2016c) in Figures 51 through 66 and Figures 80 through 95, respectively.



5 PROPOSED PROJECT AND NO PROJECT ALTERNATIVE

5.1 PROPOSED PROJECT

The Central Valley SNMP is built on the following three management goals (CV-SALTS, 2016a):

Goal 1: Ensure a Safe Drinking Water Supply. The most important management goal for the Central Valley Region is to ensure that a safe, reliable drinking water supply is available to all residents of the region. The need to ensure a safe, reliable drinking water supply is the highest priority for the management of nitrate under the SNMP and is to be complied with as quickly as possible in all areas in the Central Valley Region.

Goal 2: Achieve Balanced Salt and Nitrate Loadings. This goal seeks to establish a balance of the mass of salt and nitrate in groundwater underlying each permitted or managed area, where reasonable and feasible. With regard to salt, balance is defined as achieving a state where inputs of salt (salt flux in) into a managed area are equal to outputs (salt flux out) from the same area. Similarly, nitrate balance means a balance of nitrate flux in and nitrate flux out of the permitted managed area. The nitrate mass balance will need to account for nitrate taken up by crops and losses of nitrate from the nitrogen cycle in soil, including denitrification in the root zone by soil microbial activity and volatilization to the atmosphere.

Goal 3: Implement Managed Aquifer Restoration Program. This goal seeks, where reasonable and feasible, to restore salt and nitrate levels within groundwater basins and subbasins or locally managed areas to concentrations that are below the applicable water quality objectives established for each constituent. Accordingly, SNMP implementation not only focuses on restoring the beneficial use where reasonable and feasible, but it also seeks to minimize or prevent further degradation of ground waters that are currently meeting water quality objectives so that they do not become impaired.

The foundation for implementation of the Central Valley SNMP is the Basin Plans, which establish the Central Valley Water Board’s existing regulatory authority to manage salt and nitrate in the region. However, the existing regulatory framework in the Basin Plans currently limits the Central Valley Water Board’s ability to consider innovative salt or nitrate management strategies, including strategies that are consistent with the intent and purpose of the Recycled Water Policy and goals of CV-SALTS28. To address these regulatory limitations, CV-SALTS developed recommendations for modifications or clarifications to the Basin Plans to facilitate implementation of innovative salt and nitrate management strategies to improve water quality. These recommendations are designed to facilitate implementation of the SNMP and efforts to achieve the salt and nitrate management goals. For the most part, the recommendations are not

28 The goals adopted by CV-SALTS include: sustain the Valley’s lifestyle, support regional economic growth, retain a world-class agricultural economy, maintain a reliable, high-quality water supply, protect and enhance the environment.

Commented [A31]: We agree and appreciate this important goal of the SNMP. However, important aspects of a safe, reliable drinking water supply include water that is aesthetically pleasing and at a reasonable cost. We are concerned that the proposed revisions to the secondary MCLs in Table 64449‐A will degrade source water quality and result in either reduced aesthetics of the treated water supply or increased water treatment and residual costs. The implications of the Attachment A‐9 SMCL guidance should be included in the evaluation of this goal.



self-implementing and require adoption of amendments to the Basin Plans. The recommended Basin Plan amendments address the following topic areas.

Groundwater Management Areas o Default Groundwater Management Areas o Groundwater Management Zone Policy

Permitting and Management Strategies o Nitrate Permitting Strategy o Salinity Management Strategy

Policies and Guidance o Revision of the Exceptions Policy for Waste Discharges to Groundwater

(Exceptions Policy) o Salinity Management to Provide Reasonable Protection of AGR Beneficial Uses

in Groundwater (AGR Policy) o Revision of the Salinity Variance Program o Offsets Policy o Drought and Water Conservation Policy o Guidance to Implement Secondary Maximum Contaminant Levels (Secondary

MCL Guidance) o Guidelines for Developing Alternative Compliance Projects for Nitrate

Discharges o Factors to Support a Maximum Benefit Finding

The following sections provide a description of the key elements of these recommended management strategies, policies, and guidance. These descriptions are based on the CV-SALTS draft policy documents dated September 12, 2016. For some policies, the CV-SALTS Executive Committee has identified optional approaches to certain elements, based on input from stakeholders, to undergo CEQA evaluation. These optional approaches are identified in the descriptions below and are considered part of the Proposed Project.

5.1.1 Groundwater Management Areas

Default Groundwater Management Areas

The California Department of Water Resources (DWR) Bulletin 118 defines, delineates, and describes the groundwater basins and subbasins in the Central Valley Region (DWR, 2015a). These basins/subbasins will serve as default groundwater management areas unless a group of dischargers elects to establish a management zone (see Section 0 for discussion of management zones), which may establish an alternative area for the management of nitrate in groundwater.

The Basin Plans for the Central Valley include requirements for the protection of groundwater quality through the establishment of water quality objectives and programs of implementation to achieve the water quality objectives. Currently, the TLB Basin Plan identifies groundwater basins and subbasins in Table II-2 that, for the most part, match those shown in DWR Bulletin 118. However, when DWR Bulletin 118 was last updated, several of the subbasins were deleted. TLB Basin Plan Table II-2 has not been similarly revised to reflect these changes. The SRSJB



Basin Plan does not currently identify or enumerate specific groundwater basins or subbasins, as identified by DWR Bulletin 118.

Because the default level of salt and nitrate management established by the SNMP is at the groundwater basin/subbasin, it is recommended that the Basin Plans be amended to include the current DWR Bulletin 118 list of groundwater basins/subbasins in the Central Valley Region. This would require (a) minor changes to Table II-2 in the TLB Basin Plan; and (b) addition of a new table in Basin Plan Chapter II (Existing and Potential Beneficial Uses) to list the groundwater basins/subbasins for the SRSJB Basin.

Groundwater Management Zone Policy

The Groundwater Management Zone Policy recommends the Basin Plans be amended to include criteria for establishment and regulation of management zones for the purposes of groundwater quality management and control of nitrate. The Groundwater Management Zone Policy elements are summarized below.

a) Management zones would be a discrete regulatory compliance unit for the purposes of

complying with WDRs for nitrate. Dischargers have the discretion to join a management zone or continue to be permitted as an individual (or group under general WDRs).

Option: Management zones would not be available for evaluating compliance with WDRs; only as a means for collaborative groundwater basin monitoring, modeling, and other related assessment activities.

b) A minimum requirement of a management zone implementation plan is to be consistent

with the management goals of the SNMP, including,(1) addressing short-term and long- term drinking water needs affected by nitrates, (2) plan for achieving balanced nitrate loadings within the management zone (to the extend feasible and reasonable), and (3) plan for establishing a managed aquifer restoration program to restore nitrate levels to concentrations at or below the water quality objectives to the extent it is feasible and reasonable to do so.

Option: Include a goal to achieve balance and restore aquifer, where feasible, within 50 years.

c) Management zones would only be applied for the regulation and control of nitrate.

Option: Management zones would be allowed to address other constituents of concern to MUN uses (e.g., arsenic).

d) A management zone can be larger than one groundwater basin/subbasin for administrative

purposes, including providing drinking water within the area covered by the entire management zone. However, when developing implementation plans within a management zone, these plans should be developed only for areas that are hydrologically



connected. In addition, assimilative capacity may only be allocated within hydrologically connected areas.

e) Fixed timelines are established for participation in a management zone: (1) a 270-day

timeline for dischargers who decide to work collaboratively to develop a Preliminary Management Zone Proposal, and (b) an additional 60 days for dischargers to submit their Notice of Intent with respect to which path for compliance they will choose—participate in the proposed management zone that encompasses their discharge or continue to be permitted as an individual discharger.

Option: Timelines are not fixed, but at the discretion of the Central Valley Water Board.

f) Management zones would be required to develop and implement an Early Action Plan,

which outlines the approach to provide drinking water to communities with nitrate- impaired wells.

g) Assimilative capacity within a management zone is determined on a volume-weighted

average basis in the production zone of the delineated management zone boundary and within hydrologically connected areas.

Option: Limit determination of available assimilative capacity based on a volume weighted average in the first encountered groundwater] (same as baseline/existing conditions).

5.1.2 Permitting and Management Strategies

Nitrate Permitting Strategy

The Nitrate Permitting Strategy proposes to amend the Basin Plan to establish pathways for compliance with nitrate groundwater quality objectives. The specific elements of the Nitrate Permitting Strategy are:

a) There would be two compliance pathways: (1) pathway for dischargers that want to be

permitted individually (Path A); and (2) dischargers permitted within a management zone (Path B).

b) For individual pathway (Path A), the proposed policy provides for five categories of

discharges to determine appropriate WDRs: 1) no degradation; 2) de minimis; 3) degradation below 75 percent of the water quality objective; 4) degradation above 75 percent of the water quality objective, or receiving water quality is 50 percent of the objective and the discharge is causing an annual increase in nitrate greater than 0.1 mg/L as N using cumulative average; and 5) discharge above objective and no available assimilative capacity. Categories 3 and 4 include trigger language regarding trending of water quality upwards toward water quality objective.



For category 3 – Trends are based on causing concentrations to increase by more than 0.1 mg/L-N per year using cumulative average annual increase over a five- year period.

For category 4 – Discharges are in category 4 if receiving water is above 75 percent of the objective, or if the receiving water is at 50 percent of the objective and the discharge causes groundwater to increase by more than 0.1 mg/L-N as an annual increase using cumulative average annual increase over five-year period. To allow assimilative capacity here, discharger would need to submit an alternative compliance plan.

c) Proposed strategy provides the basis for determining whether a discharger must seek an

alternative compliance pathway. It depends on the categorization of the discharge, and the discharge’s impact on water quality. If there is an initial finding that the 0.1 mg/L nitrate trend has been exceeded, the discharger would be allowed to collect additional data and/or conduct additional analyses prior to requiring an alternative compliance plan be submitted.

d) The alternative compliance pathway would likely include participation in projects to

deliver drinking water to communities with nitrate-impaired wells and to participate in projects to improve ambient groundwater quality in the long term.

e) Timeline for submittal of Notice of Intent regarding participation in a management zone

(or not) is directly related to timing of the need to indicate if the discharger is going to follow nitrate permitting strategy Path A or Path B, and is required 60-days after submittal of Preliminary Management Zone Proposal. Timeline for amending WDRs is left to the Board.

f) When allocating assimilative capacity, a simple antidegradation analysis is required for

category 1 and 2 discharges, and a complete antidegradation analysis is required for the other categories.

g) Allocation of assimilative capacity to individual dischargers is determined at First

Encountered Usable Groundwater. For dischargers within a management zone will receive an allocation of assimilative capacity which is determined based on the water quality in the production zone.

h) When allocating assimilative capacity to an individual discharger and the individual

discharger is within a Management Zone, the Central Valley Water Board will need to consider impact to available assimilative capacity in the Management Zone.

i) As part of the Notice of Intent for an individual discharger under Path A that falls within

categories 3, 4, or 5, the individual discharger would need to conduct an initial assessment to determine if the discharge (or collective discharges if under a General Order) is impacting any nearby public water supply or domestic wells for nitrate.



An optional approach to the Nitrate Permitting Strategy is provided below.

1) Compliance with SNMP to be determined on a permit-by-permit basis. Management zone compliance with SNMP would not be an option.

2) All dischargers should be required to characterize their loading and impact of their

loading on nitrate water quality in the immediate area of the discharge. This characterization would need to be conducted as part of a permit renewal application, or be ordered via section 13267 of the Water Code. In priority areas and upon notice by the Central Valley Water Board, individual dischargers should provide this information the Central Valley Water Board within 90 days. The Executive Officer shall have the discretion to extend the 90 days on a case-by-case basis due to special circumstances, but in no event should the extension be for more than an additional 90 days.

3) As part of the permit, dischargers shall then be required to assess their loading impact on

the subbasin area (as defined by DWR Bulletin 118). Dischargers will have the option to characterize loading and impact on the subbasin through individual efforts or as part of a cooperative-type program.

4) Permittees selecting the individual pathway for meeting item 3 would have one-year from

permit adoption to conduct the subbasin assessment, and permittees selecting to conduct the subbasin assessment on a management zone/subbasin basis in conjunction/cooperation with others would have one-year to develop the cooperative effort, and then one-year to conduct the assessment.

5) Based on the results of the individual characterization of loading as described in

paragraph 2 above, permittees would then need to determine their compliance pathway (i.e., use of assimilative capacity in shallow groundwater or through granting of an exception).

6) Assimilative capacity could only be granted if the discharge (or collective discharges if

the permit covered more than one permittee) would not cause or contribute shallow groundwater in a reasonably defined area to exceed 7.5 mg/L of N. Reasonably defined area means a local area and not on a subbasin basis. Any allocation of assimilative capacity would need to participate in local, regional and/or statewide efforts that ensure safe drinking water where nitrate contamination is of issue for the area in question.

7) If assimilative capacity was not available under the terms specified above in paragraph 6,

the permittee(s) would need to apply for an exception, and granting of an exception would be subject to the conditions in the exception option as set forth by the additional conditions within the Exceptions Policy options. In particular, any permittee(s) receiving an exception would need to be part of local, regional and/or statewide efforts that ensure safe drinking water where nitrate contamination is of issue for the area in question.



Salinity Management Strategy

The Salinity Management Strategy involves a phased approach of study and implementation to control salt accumulation in the Central Valley. Phase I consists of developing a Prioritization and Optimization Study (CDM Smith, 2016b) to further define the conceptual design of the Strategic Salt Accumulation Land and Transportation Study (SSALTS; CV-SALTS, 2014) into a feasibility study that identifies appropriate regional and sub-regional projects, including location, routing and implementation/operation of specific projects. Completion of the study is anticipated to take approximately 10-years, though the strategy recommends that the Executive Officer of the Central Valley Water Board be given the direct authority to extend this time frame if compelling reasons or adequate justification is provided for an extension. Once the Prioritization and Optimization Study is completed, Phase II of the Salinity Management Plan will be implemented. Implementation of Phase II, in whole or part, will occur as indicated in the Prioritization and Optimization Study, and after approval of any necessary Basin Plan amendments. Phase II will generally consist of environmental permitting, obtaining funding, and engineering and design, which is anticipated take approximately 10 years. Phase III would consist of actual construction of the physical projects identified in the Prioritization and Optimization Study, in particular a regulated brine line. Implementation of Phase III construction of a regulated brine line is highly dependent on obtaining the necessary public funding.

While the Prioritization and Optimization Study is being implemented, CV-SALTS recommends that the Basin Plans be amended to include an interim salinity permitting approach for discharges of salinity. This approach allows the Central Valley Water Board to manage degradation while the long-term salinity efforts are being implemented. Because this approach is intended to be interim in nature, at the outset, CV-SALTS recommends that the interim permitting approach be set in place for 15 years to allow for implementation of Phase I of the Salinity Management Strategy. At the end of Phase I, it may be necessary to extend the Interim Salinity Permitting approach to allow for implementation of Phase II, or to adjust the approach as deemed appropriate to implement Phase II. Any such change may require a Basin Plan amendment.

To implement the Interim Salinity Permitting approach in WDRs/conditional waivers, the Central Valley Water Board will need to revise existing WDRs/conditional waivers and NPDES Permits. Further, during this interim period, there will be new dischargers, or existing dischargers seeking facility modifications, that will have salinity discharges. CV-SALTS recommends that the Central Valley Water Board, in cooperation with stakeholders, develop a series of resolutions/orders that amend applicable WDRs/conditional waivers. In general, the resolutions/orders would require dischargers to continue current reasonable, feasible and practicable efforts to implement salinity management practices and/or source control efforts, including implementation of any pollution prevention plans, watershed plans, and/or salt reduction plans. Monitoring for salinity in surface and groundwater would also continue as part of applicable monitoring programs, or through regional monitoring programs as appropriate. Monitoring should also be coordinated with the CV-SALTS Surveillance and Monitoring Program (SAMP). Discharge levels of salinity would need to remain fairly consistent with current levels, accounting for conservation and some appropriate increment of growth. Most importantly, discharges being permitted under this interim approach would be required to



participate in efforts related to the Prioritization and Optimization Study, and subsequent Phases II and III as applicable. The level of participation would vary based on salinity in the discharge as well as local conditions, and the needed level of participation would be established by the lead entity that is overseeing the Prioritization and Optimization Study. The resolutions/orders would establish the time-frame for application of the interim permitting approach, which could not exceed 15 years in length. For NPDES dischargers, which are subject to federal regulatory requirements, CV-SALTS recommends that as NPDES permits are renewed on their normal five-year cycle, that the Central Valley Water Board consider approval of a salinity variance per the Salinity Variance Policy, which would include a requirement to participate in the Prioritization and Optimization Study in order to receive the variance for meeting applicable surface water quality objectives for salinity. Or, in the alternative, the Central Valley Water Board could consider a NPDES watershed-based permit for salinity as it deems appropriate.

The resolutions/orders would need to include provisions that allow dischargers the discretion to opt out of participation in efforts to prepare the Prioritization and Optimization Study. However, CV-SALTS recommends that dischargers wishing to opt out be permitted under current traditional and conservative permitting approaches.

For groundwater dischargers wishing to opt out, this would mean that they would need to show that they do not cause or contribute to exceedances of groundwater limitations for salinity constituents in first encountered groundwater, and that selection of applicable salinity water quality objectives would be conservative (e.g., most restrictive criteria for protection of AGR and MUN beneficial uses). Further, no new allocation (or expansion of an allocation) of assimilative capacity could be granted to a groundwater discharger that wishes to opt out of the Prioritization and Optimization Study. However, if a discharger has previously received allocation of assimilative capacity, and such allocation was granted with the support of an antidegradation study/analysis, then a discharger may opt out using previously approved allocations. Further, CV-SALTS recommends that the Central Valley Water Board use its discretion to issue time schedules for meeting salinity limitations for those opting out sparingly and in a limited manner. In other words, a discharger opting out should not be allowed a long-term time schedule for meeting a restrictive salinity limitation. However, the Central Valley Water Board maintains the discretion to determine if a short time schedule is appropriate in certain circumstances.

For non-NPDES surface water dischargers wishing to opt out, the same principles would apply in that they would need to show that the discharge(s) do not cause or contribute to exceedances of salinity limitations, and that the selection of applicable salinity water quality objectives would be conservative and be based on the most restrictive criteria for the AGR and MUN beneficial uses, as applicable. Like with groundwater dischargers, no new allocation (or expansion) of assimilative capacity (i.e., dilution credit) could be granted but that previously approved allocations that were supported by an antidegradation study/analysis could be maintained. Use of time schedules should also be limited as discussed above.



For NPDES surface water dischargers wishing to opt out, the same principles would apply as those for non-NPDES surface water dischargers. In addition, salinity variances and long-term compliance schedules would not be an available option for those seeking to opt out of the Prioritization and Optimization Study.

It is recommended that such resolutions be prepared and ready for Central Valley Water Board consideration within one (1) year of the Basin Plan amendments becoming effective. In the meantime, while such resolutions are being developed, CV-SALTS recommends that the Central Valley Water Board permit salinity discharges in a reasonable manner that looks to implementing the Salinity Management Strategy as set forth in the SNMP.

At the close of Phase I, or potentially at the end of Phase II, the Central Valley Water Board may determine that it is necessary to revise the Interim Salinity Permitting approach. This approach would be added to the Basin Plan at the end of Phase I, as determined appropriate and applicable at that time.

5.1.3 Policies and Guidance

Exceptions Policy

The Exceptions Policy recommends modifications to the existing Salinity Exception Program in the Basin Plans, which authorizes the Central Valley Water Board to grant exceptions for salinity constituents in non-NPDES program WDRs where it concludes that it is infeasible, impracticable or unreasonable to prohibit an otherwise non-compliant discharge to groundwater. The proposed modifications are summarized below.

a) The June 30, 2019, sunset date would be eliminated from the Salinity Exception Program

so that the Central Valley Water Board would be able to authorize new exceptions or reauthorize previously approved exceptions after this date.

b) The Salinity Exception Program would be expanded to authorize exceptions nitrate; the

current program allows for exceptions only for EC, TDS, chloride, sulfate, and sodium.

Option: Expand program to also include boron.

c) The existing Salinity Exception Program limits term of an exception to 10 years. The exception has a 5-year check-in requirement (the Central Valley Water Board can rescind exception if requirements not met) and can be reauthorized at the end of the exception. The proposed policy recommends:

i. No 10-year limit on an exception term; instead the Board has the discretion to

decide actual term.

ii. 5-yr check-ins still required regardless of length of approved exception and Board can still intervene to terminate exception at check-ins if conditions not met.



As a condition for reauthorizing/renewing an exception, dischargers will be required to periodically reassess Best Management Practices (BMPs) and survey available treatment technologies to determine if feasible, practicable and reasonable compliance options have become available.

Option: Retain existing 10-year limit for exception term; exceptions can be renewed at 10-year intervals with no end date.

d) Add a new provision requiring dischargers to assure an adequate supply of safe, reliable

and affordable drinking water, as a condition of authorizing an exception for nitrate in those areas of the groundwater basin or subbasin adversely affected by the non-compliant discharge (or discharges). The assurance must consist of a plan for providing safe drinking water, which may include plans developed by more than just the discharger but others in the community as well.

Option: Also add in the following new conditions for obtaining an exception:

“Best Efforts” are to be provided29. Participation in a mitigation fund or other mitigation program that fully mitigates

impacts to drinking water. Participation in a program that restores the aquifer to meet water quality

objectives.

Option: In addition to above, the following specific performance measures are a condition for obtaining and renewing exceptions.

For obtaining an initial exception:

Long-term management plans show improved water quality trends over a 10 and 20 year horizon.

Long-term management plans show salt/nitrate balance and restoration of aquifer to meet water quality objectives in a short a time as practicable, but not to exceed 50 years.

For obtaining renewal of exceptions:

Demonstration that short-term drinking water solutions were effectively implemented.

Demonstration that mitigation fund / alternative drinking water projects have been effective and identification of additional actions, if needed.

29 The “best efforts” approach involves the Central Valley Water Board establishing limitations expected to be achieved using reasonable control measures. Factors which should be analyzed under the “best efforts” approach include the effluent quality achieved by other similarly situated dischargers, the good faith efforts of the discharger to limit the discharge of the constituent, and the measures necessary to achieve compliance. SWRCB Order WQ 81- 5, at p. 7. The State Water Board has applied the “best efforts” factors in interpreting BPTC. (See SWRCB Order Nos. WQ 79-14, and WQ 2000-07).



Demonstration that aquifer restoration / mitigation projects have been effective and identification of additional actions, if needed.

Long-term management plans show improved water quality trends over: 1) a 10 and 20 year horizon at first and second renewal; 2) a 20 year horizon at third and fourth renewals.

Long-term management plans show salt/nitrate balance and restoration of aquifer to meet water quality objectives in as short a time as practicable, but not to exceed: 1) 40 years at first renewal, 2) 30 years at second renewal, 3) 20 years at third renewal, and 4) 10 years at fourth renewal.

e) Retain the following justification within the Salinity Exception Program under a list of

conditions where the Board may conclude that it is infeasible, impracticable, or unreasonable to prohibit a non-compliant discharge: “Situations where compelling the discharge to comply with the applicable WDR (and assuming it was possible to do so) would not significantly improve water quality or assure attainment of the related standards in the foreseeable future (≈20 years).”

Option: Delete this justification from the Salinity Exception Program.

f) The proposed Exceptions Policy is silent with respect to timeframes for achieving salt

and nitrate balance, and restoration of aquifers (i.e., goals 2 and 3 of SNMP).

Option: Establish a 50-year timeframe for achieving balance and restoration for both salt and nitrate. “Restoration” nitrate is defined by either: 1) 50% of MCL; 2) 75% of MCL; or 3) 100% of MCL.

g) Exceptions may be granted to Management Zones.

Option: Exceptions may only be applied on a permit-by-permit basis.

AGR Policy

The AGR Policy proposes to amend the Basin Plan to assign AGR classes to groundwater basins or subbasins based on existing TDS concentrations and EC levels for purposes of interpreting the narrative Chemical Constituents objective for groundwater. Once a groundwater basin or subbasin is given an AGR classification, TDS concentrations (and EC levels) within the basin/subbasin would be managed within the range established for that class. The AGR classes are defined below.

AGR Class 1: TDS < 600 mg/L (EC < 1,000 μS/cm). Groundwater quality in the production zone that may be used as an agricultural water supply is generally suitable for irrigating all crops and all stock watering. This presumption is rebuttable on a case-by- case basis with the burden of proof falling on those claiming that EC levels at or below 1,000 μS/cm do not provide reasonable protection of existing AGR uses and that a site- specific EC value should be established.



AGR Class 2: 600 mg/L < TDS < 2,000 mg/L (1,000 μS/cm < EC < 3,000 μS/cm). Groundwater quality in the production zone that may be used as an agricultural water supply is generally acceptable for stock watering and for irrigating most salt-tolerant crops; it is not generally suitable for irrigating many salt-sensitive crops, except as a temporary, short-term alternative when higher quality water supplies are not readily available.

AGR Class 3: 2,000 mg/L < TDS < 5,000 mg/L (3,000 μS/cm < EC < 7,500 μS/cm). Groundwater quality in the production zone that may be used as an agricultural water supply is generally acceptable for stock watering but is not generally suitable for irrigating all but the most salt-tolerant crops, except as a temporary, short-term alternative when higher water quality water supplies are not readily available.

AGR Class 4: TDS > 5,000 mg/L (EC > 7,500 μS/cm). Groundwater quality in the production zone that is not suitable for either stock watering or crop irrigation AGR uses unless blended with lower salinity water. Areas within this classification should be considered for AGR de-designation.

The assignment of a groundwater basin or subbasin to an AGR class is based on the existing volume-weighted average of TDS concentrations in the production zone. When issuing WDRs/conditional waivers, localized areas with TDS concentrations higher or lower than the thresholds of the class assigned to the basin will be managed through application of State Antidegradation Policy and requirements of the SNMP or potentially through development of site-specific objectives.

Each AGR classification described above is rebuttable on a case-by-case basis, with the burden of proof falling on the discharger claiming that the specified EC/TDS ranges do not provide reasonable protection of existing AGR uses or, ranges are unnecessarily stringent and higher values should be applied to all or some groundwaters in the area, and that site-specific EC/TDS ranges should be established. Where such analyses are performed by groups representing water users in a defined area are found to be sound and approved by the Central Valley Water Board, the resulting ranges would take precedence over the default classification assigned to that area.

Salinity Variance Program

The Salinity Variance Policy proposes modifications to the existing Salinity Variance Program to align it with the SNMP and Salinity Management Strategy. The Salinity Variance Policy recommends that the current Salinity Variance Program be amended in the following ways.

1) Extend the provision prohibiting the Central Valley Water Board from authorizing new

salinity variances or reauthorizing previously approved salinity variances from June 30, 2019, to 15 years from the effective date of Basin Plan amendments that revise the Salinity Variance Program.



2) Extend application of the Salinity Variance Program to water quality-based effluent limitations for salinity water quality standards that are related to the MUN beneficial use, and not just the AGR beneficial use.

3) Revise the current Salinity Variance Program to require participation in the Salinity

Management Strategy Prioritization and Optimization Study. The requirement to participate in CV-SALTS may also be appropriate, depending on if CV-SALTS is still intact for this purpose.

4) Make clear that salinity variances are intended to facilitate implementation of the phased

Salinity Management Strategy, and that salinity variances are not available to individuals/permittees that wish to opt out of participating in implementation of Phase I of the Salinity Management Strategy.

The conditions for authorizing the salinity variance would remain the same, except as revised based on the above.

Authorization for salinity variances may be granted by the Central Valley Water Board for individual dischargers or for multiple dischargers under a watershed based NPDES permit for salinity discharges. Terms and conditions associated with the granting of a salinity variance would be incorporated into relevant NPDES permits, and failure to comply with such terms and conditions may result in the termination of the variance and/or an enforcement action.

Offsets Policy

The Offsets Policy proposes to amend the Basin Plans to allow the use of offsets for discharges to groundwater. Offsets would provide an indirect approach to partial or complete compliance with a WDR/Conditional Waiver requirement for a given pollutant by managing other sources and loads so that the net effect on receiving water quality from all known sources is functionally- equivalent to or better than that which would have occurred through direct compliance with the WDR at the point-of-discharge. Authorization to allow use of offsets would provide:

A mechanism to re-target the resources required to achieve compliance in order to produce greater public benefits (e.g., better net water quality, lower cost, less risk).

A mechanism whereby diverse dischargers within the same management zone can pool available resources to implement alternative compliance projects, in phases, on a risk- priority basis.

A mechanism to develop and fund large-scale, long-term regional water quality improvement projects (e.g., as described by the SSALTS or the Nitrate Implementation Measures Study (NIMS)), by recognizing participation in such efforts as partial credit toward compliance.

Market-based incentive to establish “mitigation banks” designed to develop and implement water quality improvement projects, which are useful for pooling resources of



relatively small dischargers into a critical funding mass to support projects that would normally be beyond their individual means.

An offset allows for the management of other sources and loads (not directly associated with the regulated discharge) so that the combined net effect on receiving water quality from the discharge and the offset is functionally-equivalent to (and potentially better) than that which would have occurred by requiring the discharger to comply with its WDR at the point-of- discharge. In this regard, an offset project must be located within the same groundwater basin/subbasin or management zone as the regulated discharge. However, the Offsets Policy is also intended to incentivize implementation of some large-scale projects such as a regional regulated brine line or a mitigation bank established to provide safe drinking water. Key aspects of the Offsets Policy include:

Where there is no assimilative capacity available in the receiving water, the offset must result in a net improvement in existing water quality (e.g., the offset ratio must be > 1:1) compared to baseline regulatory requirements. Offset ratios < 1:1 may be authorized only in accordance with the State's Antidegradation Policy unless an exception is granted or time schedule order or compliance schedule order allows a less stringent interim ratio to apply.

Offsets must be for substantially the same pollutant. Cross-pollutant trading (e.g., TDS for nitrate, nitrate for arsenic) should not be construed as true “offsets.” Such a cross pollutant offset may be more appropriate for a short-term effort with long-term efforts focused on the original pollutant of concern.

The proposed package (discharge + offset project) cannot result in unmitigated localized impairments (e.g., “hotspots”) to sensitive areas (especially drinking water supply wells) or have a disproportionate impact on a disadvantaged community. This situation can best be addressed, although not required, by implementing offsets within management zones that provide other mechanisms to assure water users remain protected. Downgradient well owners must be notified and encouraged to participate in the offset approval process.

Offsets apply to a specific discharge for a defined period. Offsets can be renewed but must be periodically reviewed and reauthorized by the Central Valley Water Board. The length of that period will be specified by the Central Valley Water Board when the offset is approved.

The terms and conditions governing an approved offset should specify the remedial actions that must be undertaken by the discharger, and the metric(s) used to trigger such obligations, in the event that the offset project fails for some reason.

The offset project must include a monitoring and reporting program sufficient to verify that the pollution reduction credits are actually being generated as projected and that these credits are adequate to offset the discharge loads in the ratio approved by the Central Valley Water Board. Pollutant removal, reduction, neutralization, transformation



and dilution may all be acceptable means of generating offset credits (subject to appropriate verification).

In addition to the proposed policy, there are two options for how offsets can be used and the water quality to be attained:

Option 1: (a) Offsets could be used across groundwater subbasins and basins, and management zones; and (b) offset projects do not require attainment of water quality objectives in the underlying water, only progress toward attainment.

Option 2: (a) Allow use of offsets only in the specific area to which a discharge impacts; and (b) limit definition of an offset to only projects that result in water quality objectives being attained.

Drought and Water Conservation Policy

The Drought Policy applies to both surface water and groundwater discharges, and proposes to eliminate barriers to the use of recycled water where compliance with WDRs for salinity (expressed as EC and TDS) during drought periods may be challenging. The Drought Policy proposes to amend the Basin Plans as follows:

a) For discharges to groundwater, calculate compliance with applicable narrative/numeric

salinity objectives using long-term (10+ year) flow-weighted average while simultaneously considering expected recharge and potential dilution from natural precipitation and streambed percolation to the same basin/subbasin.

b) Authorize the use of “Offset Projects,” particularly increased storm water capture and

recharge, to demonstrate compliance with WDRs governing salinity discharges. Allow offset credits to be created and banked by constructing and operating such projects or by discharging well below the WDR threshold in non-drought years. Recognize that the credits needed to achieve compliance during periods of drought must be generated at times of above normal precipitation (especially El Niño winters) and, as such, must remain valid for at least 10 years.

c) Establish a temporary variance/exception from salinity-related water quality objectives

during certain drought conditions. A variance/exception would be triggered by:

Governor declared drought emergency (statewide – affects any hydrologic region),



An “Extended Dry Period,”30 or

Local state of emergency declaration.

At such times, more appropriate interim WDRs or effluent limitations would apply.

d) Establish a temporary variance/exception from salinity-related water quality objectives where the TDS concentration in the permitted discharge is significantly better (lower) than the TDS concentration in the receiving water and will improve receiving water quality while promoting maximum use/reuse of available water supplies. Potential impacts to downstream/downgradient water quality must also be evaluated as part of this demonstration.

Option: In lieu of authorizing a temporary variance/exception, consider pre- authorizing an automatic allocation of assimilative capacity (where it exists) to accommodate higher TDS concentrations in the discharge/recharge during drought conditions.

Secondary MCL Guidance

The Secondary MCL Guidance proposes the Basin Plans be amended as follows:

a) Incorporate text from 22 CCR section 64449 section 64449.2 into the Basin Plans that provides guidance on the application of “Recommended”, “Upper”, and “Short Term” consumer acceptance levels for TDS, EC, chloride, and sulfate in WDRs and NPDES permits.

Option: Only “Recommended” secondary MCL values may be used as the basis for WDRs.

b) Constituents concentrations ranging to the “Short Term” level in 22 CCR Table 64449-B

may be authorized in WDRs on a temporary basis in those situations where construction of new facilities or connection to new water sources is pending as specified in 22 CCR section 64449(d)(3). Further, constituents ranging to the “Short Term” level in Table 64449-B may be authorized on a temporary basis due drought conditions when normal water supplies are not available.

30 An Extended Dry Period is defined using the State Water Resources Control Board’s San Joaquin Valley “60-20- 20” Water Year Hydrologic Classification included in the Bay-Delta Water Quality Control Plan to assign a numeric indicator to a water year type as follows (State Water Resources Control Board 2006): Wet – 5; Above Normal – 4; Below Normal – 3; Dry – 2; Critically Dry – 1. The indicator values will be used to determine when an Extended Dry Period is in effect: • An Extended Dry Period shall begin when the sum of the current year 60-20-20 indicator value and the previous two years’ 60-20-20 indicator values total six (6) or less. • An Extended Dry Period shall be deemed to exist for one water year (12 months) following a period with an indicator value total of six (6) or less.

Commented [A32]: *Please see comments in Antidegradation Analysis, which apply here. We incorporate those comments by reference.



c) Allow compliance with WDRs based on secondary MCLs in 22 CCR Table 64449-A for

metals, color, and turbidity and in CCR Table 64449-B for TDS, EC, chloride, sulfate to be determined from a filtered water sample (water passed through a 0.45 micron filter). For discharges to receiving waters that have been legally exempted from filtration requirements in the Enhanced Surface Water Treatment Rule, compliance is to be evaluated using an unfiltered sample.

Option: Compliance with WDRs based on secondary MCLs in 22 CCR Table 64449-A for metals, color, and turbidity and in CCR Table 64449-B for TDS, EC, chloride, sulfate is based only on a non-filtered water sample.

d) Modify the Chemical Constituents objective for surface waters and groundwater in the

Basin Plans to be consistent and account for natural background conditions. Specifically, in cases where the natural background concentration is greater than secondary MCLs in 22 CCR Table 64449-A or the “Upper” level in 22 CCR Table 64449-B, the water body shall not exceed the natural background concentration due to controllable anthropogenic sources.

e) Allow the Board to take into consideration any dilution or other attenuation that may

occur between the point of discharge and any intake to a downstream (surface water) or down-gradient (groundwater) water supply system.

Options:

(1) Compliance with secondary MCLs must be achieved at the point of discharge. (This is more restrictive than baseline/existing conditions for surface water discharges, in which the Board has the authority to grant a mixing zone and adopt WDRs with dilution credit where there is assimilative capacity.)

(2) Compliance with secondary MCLs must be achieved at edge of a mixing

zone. (This is the same as baseline/existing conditions for surface water discharges.)

f) Where waste discharges have the potential to affect source water quality in water supply

intakes or wells located downstream (surface water) or downgradient (groundwater) of a discharge, the Board may require the discharger, or dischargers collectively if in an approved management zone or as part of general order, to develop a detailed fate and transport analysis prior to issuing WDRs. The purpose of this analysis is to determine how the discharge affects the concentration of constituents identified in 22 CCR Tables 64449-A and 64449-B at water supply intakes or water supply wells to ensure a safe drinking water supply for users.

Option: Additional requirement that if concentrations within a water body or groundwater basin reach 80% of the secondary MCL at the point of a water



supply intake or well, a study will be conducted to evaluate actions to reduce the

concentration of the constituent.

Option: Additional requirement that establishes a monitoring program for surface waters to characterize natural background and existing conditions with respect to secondary MCLs where available data is deemed to be insufficient.

g) Specify that compliance with WDRs based on secondary MCLs in 22 CCR Tables

64449-A and 64449-B shall be determined from an annual average of water samples.

Alternative Compliance Project Guidelines

When an individual or group of dischargers is unable to demonstrate that their discharge is not causing or contributing to nitrate degradation above the triggers identified in the SNMP, they have an opportunity to request either allocation of available assimilative capacity or an exception. In most cases, the request for the granting of assimilative capacity or an exception in these circumstances will trigger the need for submittal of a proposed Alternative Compliance Project. The Alternative Compliance Project Guidelines define the components that must be included in an alternative compliance project in order to be considered and approved by the Central Valley Water Board. The guidelines specify a number of requirements for a proposed Alternative Compliance Project, including: 1) be consistent with the management goals of the SNMP; 2) prioritize assurance that drinking water that meets drinking water standards is available to all drinking water users within the zone of influence where there are significant nitrate water quality concerns in groundwater; 3) identify short and long-term projects or planning activities that will be implemented to make progress toward the SNMP water quality management goals; and 4) include a short- and long-term schedule for implementation of nitrate management activities.

Maximum Benefit Guidance

The SNMP includes factors to consider when making a finding that a proposed project meets the test that its approval and implementation would be “consistent with the maximum benefit to the people of the state” test, as stated in the State Antidegradation Policy, with examples provided. These examples address situations where lowering water quality is necessary to accommodate important social and economic growth in the region particularly where more stringent WDRs or prohibiting the discharge would result in widespread and substantial adverse socioeconomic impacts in the area. Such situations addressed in the guidance include increasing recycled water use, increasing groundwater recharge, dewatering discharges necessary to protect infrastructure deemed vital to public safety, and lowering water quality would produce significantly less adverse environmental impact than imposing more stringent effluent limitations or discharge prohibitions.

5.2 NO PROJECT ALTERNATIVE

Under the No Project Alternative, there would be no amendment to the Basin Plans to incorporate the changes recommended by the Central Valley SNMP policies, as described for the



Proposed Project. The result would be regulation of waste discharges in the Central Valley according to the regulatory framework described in Section 3. Continued regulation of salt and nitrate discharges according to the existing regulatory framework has significant implications relative to permit limitations and time schedules that must be met to achieve water quality objectives for salt and nitrate.

Municipal and Industrial Wastewater. Municipal and industrial wastewater dischargers that currently have an interim effluent limitation for EC, TDS, chloride, sulfate, and/or sodium based on a variance issued under the Salinity Variance Program or exception issued under the Salinity Exception Program would not be able to have that variance/exception renewed after June 30, 2019 via the program. The Central Valley Water Board could still grant variances for EC, TDS, chloride, sulfate, and/or sodium after June 30, 2019; these variances would be issued consistent with the Central Valley Water Board’s Variance Policy and subject to USEPA approval before implementation in NPDES permits. Inclusion of performance-based effluent limitations in current NPDES permits or WDRs tied to participation in CV-SALTS that are higher than AGR- or MUN-based water quality objectives would no longer to be allowed. Rather, those NPDES permits and WDRs would include final water quality-based effluent limitations. Further, discharges to groundwater would be required to comply with EC and nitrate limitations based on applying EC and nitrate water quality objectives at the first encountered groundwater.

Irrigated Agriculture. Irrigated agriculture discharges to surface waters and groundwater would need to come into compliance with water quality standards for EC, TDS, and nitrate in receiving water within 10 years from triggering of surface water or groundwater quality management plan for these constituents. Further, discharges to groundwater would be required to comply with EC and nitrate limitations based on applying EC and nitrate water quality objectives at the first encountered groundwater.

Dairies. If the monitoring data indicate violation of a groundwater limitation requiring specifying that the discharge shall not cause or contribute to exceedance of water quality objectives, unreasonably affect beneficial uses, or cause a condition of pollution or nuisance, dairy dischargers are required to implement management practices/activities (BPTC for high quality waters or best efforts for waters that are not high quality) that will bring the facility into compliance with on a time schedule that is as short as practicable. All discharges must be in compliance with the groundwater limitation no later than 10 years after submittal date of a summary representative monitoring report, which must be submitted by July 1, 2020. Also, permittees would need to comply with EC and nitrate limits based on water quality objectives in first encountered groundwater.

Storm Water. Regulation of storm water discharges would continue as described in Section 3, with compliance achieved through implementation of storm water management plans and implementation of BMPs.

Commented [A33]: This section only addresses continued problems associated with the salt and nitrate compliance issues. There is no discussion of impacts caused by the other secondary MCLs, especially those in Table 64449‐A. Full evaluation of SMCLs should be included, including information on the water quality programs that support the need for the Attachment A‐9 SMCL guidance.



6 ECONOMIC ANALYSIS

6.1 INTRODUCTION

If the proposed Basin Plan Amendment for a Central Valley SNMP is adopted, it will result in the implementation of new policies, strategies, and guidance, along with a Central Valley SNMP and program of implementation that will enable the Central Valley Water Board to address legacy and ongoing loading of salt and nitrate to the receiving waters in the diverse region (CV- SALTS, 2016a). To varying degrees, these new policies, strategies, and guidance require a suite of actions to be taken by various parties, including the Regional Board and the regulated entities that currently discharge salt and nitrate to Central Valley receiving waters, as well as those that propose to discharge in the future. The proposed Central Valley SNMP presents a comprehensive regulatory and programmatic approach for the sustainable management of salt and nitrate. The programmatic nature of the SNMP sets the stage for a host of future compliance strategies and associated projects to be implemented by individuals, as well as groups of individuals operating together in newly defined management zones. However, the future, unknown nature of such individual and group actions limits the ability to precisely define these actions and therefore, estimate the costs of such individual and group actions that will be undertaken in the future. The three overarching goals of the Central Valley SNMP Implementation Program are (CV-SALTS, 2016a):

Ensuring a safe drinking water supply for all residents in the valley;

Balancing salt and nitrate loading to eliminate further degradation where reasonable and feasible; and

Implementing management restoration where reasonable and feasible

In the absence of details regarding specific individual and group actions related to salt and nitrate management that will take place in the future, the current analysis offers planning level cost estimates for short- and long-term actions to address nitrate contamination of groundwater, long- term actions to address salinity management, and a collection of discharge-specific technical studies, regulatory documents, and monitoring programs required by the SNMP and related policies, strategies, and guidance.

As described in Section 2.3.2 of this document, there are four legal requirements related to economic considerations that the Central Valley Water Board must consider when adopting a Basin Plan Amendment. The first legal requirement is stated in Water Code section 13141 which requires that prior to implementation of any agricultural water quality control program, the Board must include an estimated cost of such a program, together with an identification of potential sources of funding, in the Basin Plan. The second requirement is stated in Water Code section 13241(d) which requires that the Board consider economics when establishing water quality objectives. The third requirement is stated in Water Code section 13242 which requires the Board to develop a program of implementation for achieving water quality objectives. The program of implementation must include (a) a description of the nature of actions which are

Commented [A34]: Why limited to the Valley? The SNMP will apply to the entire Central Valley region.



necessary to achieve the objectives, including recommendations for appropriate action by any entity, public or private; (b) a time schedule for the actions to be taken; and (c) a description of surveillance to be undertaken to determine compliance with objectives. The costs of some of the actions that will be required of regulated dischargers with implementation of the new policies, strategies, and guidance can be estimated, along with the cost of the monitoring and surveillance program necessary to determine compliance with objectives. The fourth requirement is stated in Public Resources Code section 21159 which requires the Board, when adopting an amendment that will require the installation of pollution control equipment or is a performance standard or treatment requirement, to include an environmental analysis of the reasonably foreseeable methods of compliance. This environmental analysis is required to take into account a reasonable range of environmental, economic, and technical factors, population and geographic areas, and specific sites.

The planning level cost estimates presented in this analysis are those associated with the No Project Alternative and the Proposed Project, and have been developed with consideration of various cost estimates already developed under earlier CV-SALTS efforts. Additionally, the current analysis provides an estimated cost for implementation of the CV-SALTS’s recommended Surveillance and Monitoring Program (SAMP) for the SNMP (CDM Smith, 2016a), as well as a discussion of the limitations of the various planning level costs presented herein.

6.2 NO PROJECT

The No Project Alternative represents a future scenario where there would be no amendment to the Basin Plans to incorporate the changes recommended by the Central Valley SNMP policies, strategies, and guidance as described for the Proposed Project. The result would be regulation of waste discharges in the Central Valley according to the regulatory framework described in Section 3 and discussed further in this section as it relates to potential economic impacts to dischargers.

6.2.1 Future Regulatory Environment

As described in Section 3, municipal and industrial wastewater dischargers that currently have an interim effluent limitation for EC, TDS, chloride, sulfate, and/or sodium based on a variance issued under the Salinity Variance Program or exception issued under the Salinity Exception Program would not be able to have that variance/exception renewed after June 30, 2019, via the program. The Central Valley Water Board can still grant variances applicable to surface water discharges for EC, TDS, chloride, sulfate, and/or sodium after June 30, 2019, subject to USEPA approval. IfOnce existing variances and exceptions expire, dischargers will be faced with meeting water quality objectives for salts that likely will require the implementation of additional treatment or control of their discharges, or other actions (e.g., new source water supply) that result in reduced loads for salinity. The inclusion of performance-based effluent limitations in current NPDES permits or WDRs tied to participation in CV-SALTS that are higher than AGR- or MUN-based water quality objectives would no longer to be allowed. In the absence of the Central Valley SNMP, these NPDES permits and WDRs would be amended to include final

Commented [A35]: See edit suggestion below.

Commented [A36]: Wouldn’t this be better stated as “If” since there is the potential to extend the variances indefinitely?



water-quality based effluent limitations. Additionally, discharges to groundwater would be required to comply with EC and nitrate limitations based on applying EC and nitrate water quality objectives at the first encountered groundwater. The future compliance costs for these dischargers cannot be quantified because these costs will be case-specific and information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available.

Discharges from irrigated agriculture to surface waters and groundwater would need to come into compliance with water quality objectives for EC, TDS, and nitrate in receiving water within 10 years from the triggering of a surface water or groundwater quality management plan for these constituents. Further, discharges to groundwater would be required to comply with EC and nitrate limitations based on applying EC and nitrate water quality objectives at the first encountered groundwater. Irrigated agriculture would have 10 years to reduce its loads of salt and nitrate to the point that discharges were compliant with water quality objectives for these parameters. Because existing WDRs and Conditional Waivers for irrigated agriculture have been written to describe CV-SALTS as providing future guidance on how and to what degree salt and nitrate loads will be controlled by agriculture, growers in the Central Valley have focused their attention on preventing the discharge of pesticides to surface waters. Salt and nitrate management for agricultural discharges are in the initial stages of development. The future compliance costs for these dischargers cannot be quantified because these costs will be case-specific and information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available. It is unknown if future compliance costs will drive growers to fallow or retire land as a means to balance the cost of compliance with maintaining viable agricultural operations.

Discharges from dairies that are determined to cause or contribute to an exceedance of a water quality objective, unreasonably affect beneficial uses, or cause a condition of pollution or nuisance require the discharger to bring its discharge in compliance with groundwater limitations no later than 10 years after the submittal date of a summary representative monitoring report, which must be submitted by July 1, 2020. Dairies are required to implement management practices/activities (BPTC for high quality waters or best efforts for waters that are not high quality) that will bring the facilities into compliance on a time schedule that is as short as practicable. Also, dairies would need to comply with EC and nitrate limits based on water quality objectives in first encountered groundwater. Similar to irrigated agriculture, existing WDRs for dairies have been written to include language that CV-SALTS will provide future guidance on how and to what degree salt and nitrate loads will be controlled. Without the regulatory flexibility afforded by the SNMP’s policies, strategies, and guidance, dairies will be faced with meeting water quality objectives for salts that likely will require the implementation of additional treatment or control of their discharges. The future compliance costs for these dischargers are difficult to quantify because these costs will be case-specific and information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available. However, a 2013 cost estimate for retrofitting existing and constructing new lagoons

Commented [A37]: The ILRP generally focuses on a broader suite of constituents than just salt, nitrate, and pesticides, such as sediment and pathogens.



for select dairy sizes ranged from $180,00031 to $1,400,00032 per lagoon (Provost & Pritchard, 2013).

Finally, stormwater dischargers would continue to be required to implement stormwater management plans and BMPs, as necessary, to achieve compliance with water quality objectives. Stormwater is not a large contributor of nitrate, but does observe seasonally high EC/TDS concentrations during storm runoff events. Increased costs to this discharge sector could occur as a result of being required to implement additional BMPs (e.g., education and outreach) to reduce TDS. Although future cost increases to stormwater programs would not be expected to be significant.

6.2.2 Projected Future Economic Impacts of Not Controlling Salinity

In March 2009, a group of researchers at the University of California at Davis released a report describing future economic impacts that could occur in the Central Valley if salinity discharges to groundwater continue at their current pace in the absence of new regulation aimed to control the groundwater degradation caused by salts (Howitt et al., 2009). The study team was charged with measuring the economic impacts of increasing salinity in the Central Valley to the year 2030. The study was conducted assuming that there is no change in current policy and, as such, represents the economic impacts associated with taking no action. However, the researchers assumed that the most important program in determining future salinity conditions in the Central Valley would be the WDRs for irrigated agriculture. It should be noted that at the time this report was released in 2009, agriculture in the Central Valley was still being regulated under Conditional Waivers.

Projected increases in salinity in the Central Valley were based on two factors. The first factor was the growth of the areas of shallow saline groundwater based on 30 years of historical records. The second factor was increased levels of salts that result indirectly from imported water. Based on increasing salinity stemming from these factors, the direct economic effects on industry, residential, food processing, confined animal operations, and irrigated agricultural production in the Central Valley were measured. The study assessed the economic and social impacts of increasing salinity in the Central Valley. It was assumed that economic and social impacts will occur in the Central Valley as salinity levels increase, creating changes in water quality, water supply, production of goods and services, income, and employment. A major component of the study was to determine the direct (initial changes) and indirect (inter-business commerce) effects of increasing salinity on water demand and usage in various economic sectors in the Sacramento, San Joaquin, and Tulare basins. These sectors include municipal and industrial water treatment, food processing, confined animal feeding operations, and agriculture.

Direct impacts are usually measured as direct physical costs on water users including industry, urban users and agriculture. Urban users are directly affected through water taste and degradation of water appliances resulting from increased salinity. Industry is affected by accelerated degradation of pipes and other water infrastructure. Animal feeding operations and food

31 New single liner lagoon construction for a 300 cow dairy. 32 Retrofitting of existing lagoon with double liner for a 3,000 cow dairy.



processing facilities are forced to meet new regulations in effluent discharge. Thus, since regulations increase as salinity increases, these sectors realize higher costs with salinity increases. Finally, salinity has a direct impact on agriculture in the Central Valley through reduced crop yields. Reduced yields force farmers to change rotations to lower value salt tolerant varieties and/or change input application (e.g. water application). All of these sectors are both impacted by and creators of salinity and, consequently, the interaction between each sector and salinity must be considered.

The economic impacts of not implementing a salinity management program, similar to the Central Valley SNMP, were empirically estimated by assuming that salinity continues to accumulate at its current rate (in mg/L per year of TDS): 2.63 mg/L/year for the San Joaquin and Tulare basins, and 0 – 1.53 mg/L per year for the Sacramento Basin. The analysis looked at three salinity accumulation scenarios: baseline, medium, and high. The 2.63 mg/L per year rate was used for the Tulare and San Joaquin basin in all three scenarios, while the rate was varied for the Sacramento Basin: 0 mg/L per year (baseline), 0.64 mg/L per year (medium), and 1.53 mg/L per year (high) (Howitt et al., 2009).

The study projected economic activity and social conditions to 2030 using the Regional Economic Modeling, Inc. (REMI) model (http://remi.com/). The model estimated direct economic effects (those due to loss of production in the various sectors) and indirect effects (loss of income, output, employment, and population). Table 7 shows estimates of direct annual economic losses for the three scenarios in each of the three basins. The total of all direct losses across all three basins ranges from $988 million to $1.543 billion for the year 2030 depending on the salinity scenario (Howitt et al., 2009). The San Joaquin Basin is estimated to experience the greatest impacts for most sectors except for concentrated animal feeding operations (CAFOs) and irrigated agriculture, where the Tulare Basin is estimated to experience the largest economic impacts. Note that household and industrial production costs are shown as increases in cost, while economic impacts to all other sectors are expressed as decreases in production or processing. It should also be noted that for some sectors (i.e., wine production and food processing) salinity effects and economic impacts were averaged across all three basins, resulting in each basin showing the same level of impact.

The total economic impacts (indirect effects) presented in Table 8 represent the sum of impacts estimated by the REMI model for the time period 2008 through 2030 for the three salinity scenarios in five areas: Sacramento Basin, San Joaquin Basin, Tulare Basin, the rest of California, and all of California. Under the medium set of assumptions regarding salinity accumulations, annual California income is expected to decline by $2.251 billion, output by $6.485 billion, employment by 46,299, and population by 65,013 in the year 2030. Under the low or base salinity assumptions, impact estimates are reduced by approximately 25 percent and under the high assumptions, increased by approximately 35 percent (Howitt et al., 2009).

The authors of the study acknowledged that a detailed understanding of salinity levels, distribution, and rates of accumulation in the Central Valley was lacking at the time the modeling was conducted and therefore, the results of the study should not be used to develop regional policies for the control of salt. The researchers note that the principal uncertainties associated



with the results were caused by a lack of information on the physical parameters of salinity accumulation rather than the economic parameters and future efforts should be targeted on improving the hydrological knowledge of salinity accumulation (Howitt et al., 2009).



Table 7: Direct Annual Economic Impacts by the Year 2030 (Howitt et al., 2009).

Basin

Scenario(1)

Baseline Medium High

Impacts Shown in Millions of Dollars(2)

Increased Household Cost

Sacramento $0.000 $4.862 $11.624

San Joaquin $15.622 $15.622 $15.622

Tulare $11.959 $11.959 $11.959

Total $27.581 $32.443 $39.205

Increased Industrial Production Cost

Sacramento $0.000 $96.558 $230.834

San Joaquin $299.751 $299.751 $299.751

Tulare $208.341 $208.341 $208.341

Total $508.093 $604.651 $738.927

Decreases in Wine Production

Sacramento -$7.322 -$7.322 -$7.322

San Joaquin -$7.908 -$7.908 -$7.908

Tulare -$2.440 -$2.440 -$2.440

Total -$17.670 -$17.670 -$17.670

Decreases in Food Processing

Sacramento -$23.760 -$23.760 -$23.760

San Joaquin -$57.132 -$57.132 -$57.132

Tulare -$52.447 -$52.447 -$52.447

Total -$133.340 -$133.340 -$133.340

Decreases in CAFO Production

Sacramento $0.000 $0.000 $0.000

San Joaquin -$9.709 -$19.018 -$26.862

Tulare -$107.017 -$140.033 -$228.265

Total -$116.726 -$159.051 -$255.127

Decreases in Irrigated Agricultural Production

Sacramento $0.000 $0.000 $0.000

San Joaquin $0.000 $0.000 $0.000

Tulare -$184.714 -$272.091 -$359.467

Total -$184.714 -$272.091 -$359.467

Total Impacts -$988.123 -$1,219.245 -$1,543.736

1. A 2.63 mg/L per year increase in TDS was assumed for the Tulare and San Joaquin basins under all three scenarios. The following TDS per year rates of increase were assumed for the Sacramento Basin: 0 mg/L (Baseline), 0.64 mg/L (Medium), and 1.53 mg/L (High). 2. Positive dollars represent costs to impacted sectors and negative dollars represent loss of revenue to impacted

sectors.



Table 8: Total Cumulative Economic Impacts by the Year 2030 (Howitt et al., 2009).

Sacramento

San Joaquin

Tulare

Rest of California

All of California

Income (Billion 2008$)

Baseline -$0.075 -$0.201 -$0.875 -$0.533 -$1.685

Medium -$0.160 -$0.242 -$1.177 -$0.673 -$2.251

High -$0.278 -$0.289 -$1.620 -$0.859 -$3.047

Output (Billion 2008$)

Baseline -$0.226 -$1.014 -$1.580 -$2.085 -$4.905

Medium -$0.766 -$1.099 -$1.968 -$2.652 -$6.485

High -$1.513 -$1.206 -$2.538 -$3.447 -$8.704

Employment (thousand)

Baseline -1.057 -3.087 -22.680 -6.861 -33.685

Medium -2.378 -3.931 -31.160 -8.830 -46.299

High -4.210 -4.795 -43.600 -11.580 -64.185

Population (thousand)

Baseline -1.610 -4.066 -33.530 -8.352 -47.558

Medium -3.375 -5.178 -45.920 -10.540 -65.013

High -5.830 -6.372 -64.110 -13.530 -89.842

6.3 PROPOSED PROJECT

The proposed Basin Plan Amendment (BPA) for a Central Valley SNMP encompasses new policies, strategies, and guidance that the Central Valley Water Board will implement and follow to provide short- and long-term solutions to salt and nitrate legacy problems in the Central Valley (CV-SALTS, 2016a). The proposed BPA will create new flexibility and leverage for the Regional Water Board in the way that is regulates dischargers contributing salt and nitrate loads to Central Valley receiving waters and groundwater basins. Furthermore, in its regulation of current and future discharges of salt and nitrate to Central Valley receiving waters and groundwater basins, the Board will prioritize its actions to meet the three overarching goals of the SNMP.

A description of the Proposed Project and its policies, strategies, and guidance is presented in Section 5.1. These descriptions are based on the CV-SALTS draft policy documents dated September 12, 2016. For some policies, the CV-SALTS Executive Committee has identified optional approaches to certain elements, based on input from stakeholders, to undergo economic evaluation. These optional approaches are identified in the descriptions below and are considered part of the Proposed Project. The policies, strategies, and guidance and their associated actions and economic impacts are included in Table 9. As described in Section 6.1,



the proposed SNMP provides a framework and guidelines for dischargers to individually, or in partnership, control their current loadings of salt and nitrate, and provides recommendations to address legacy contamination of these pollutants in the Central Valley.

The Proposed Project includes a number of recommendations for which planning level cost estimates may be derived; for example: supply of replacement drinking water to affected communities, long-term actions to address salt and nitrate contamination of groundwater, and numerous studies and investigations required under the proposed policies and strategies. Proposed policies, strategies, and guidance collectively identify various discharge-specific studies, and in some cases monitoring and surveillance efforts, that will need to be performed as a means to characterize current impacts of a discharge on the receiving water, establish current ambient water quality, and monitor future ambient water quality resulting from the implementation of control measures.

For other aspects of the Proposed Project, cost estimates are not possible because future actions or projects to control salt and nitrate are too speculative; for example, future actions will be dependent upon the concentrations of these pollutants in the discharges and the available assimilative capacity of the receiving water or groundwater basin to which these discharges occur.

Using available information derived from existing analyses and cost estimates completed for other CV-SALTS efforts, the current economic analysis further develops planning level cost estimates for short-term drinking water solutions (Section 6.3.1), long-term drinking water solutions (Section 6.3.2), long-term nitrate management (Section 6.3.3), and long-term salinity management (Section 6.3.4) that support the three overarching goals of the SNMP Implementation Program. In this evaluation, “short-term” is defined as the period prior to implementation of long-term salt or nitrate management actions (on the order of two or more decades). “Long-term” is defined as the period after implementation of salt and nitrate actions to address the SNMP goals (on the order of 20 to 50 years). Cost estimates based on site-specific conceptual projects are scaled to the regional level, where possible.

With regard to discharge-specific studies required under the SNMP, the completion of an antidegradation analysis (including an estimation of available assimilative capacity in the receiving water) for most discharges to surface waters and groundwater in the Central Valley will become a common practice. The Groundwater Management Zone Policy and Nitrate Permitting Strategy33, in particular, require various levels of studies and submittal of policy- and strategy-based documentation depending on the estimated impacts of a discharge and the available assimilative capacity of the groundwater basin. The costs of certain studies are

33 The Nitrate Permitting Strategy applies to discharges to groundwater. In some limited instances, the principles identified in the Nitrate Permitting Strategy may also be appropriate for consideration by the Central Valley Water Board to discharges to surface waters where the municipal and domestic (MUN) beneficial use is the most sensitive beneficial use. In such cases, the Central Valley Water Board will determine if assimilative capacity exists under current applicable mixing zone policies for NPDES dischargers, or consider application of a variance as currently set forth in the Variance Policy for Surface Waters that is contained in the Basin Plans. The Nitrate Permitting Strategy provided here is not intended to revise existing policies that apply to NPDES surface water dischargers.



estimated and provided in Section 6.3.5 on a policy-by-policy basis, where adequate information is available to enable formulation of an estimate.



Table 9: CV-SALTS Polices, Strategies, and Guidance and their Associated Actions that Produce Economic Impacts.

CV-SALTS Policy/Strategy/Guidance

Policy/Strategy/Guidance-Driven Actions with Associated Economic Impacts

Discharge- Specific

Studies(1); Monitoring and

Reporting

Conservative Permitting Approach to Dischargers that

“Opt Out” of Regional Solutions

(i.e., not part of Management Zone)

Short-Term Actions to Address Nitrate Contamination of

Groundwater (i.e., supply

replacement water)

Long-Term Actions to Address Nitrate Contamination of

Groundwater

Long-Term Actions to

Address Salinity Management(2)

Groundwater Management Zone Policy(3)

---

Nitrate Permitting Strategy(4)

---


---

---

Exceptions Policy(5) ---

AGR Salinity Policy --- --- --- ---

Salinity Variance Policy

No Variances for Dischargers that Opt

Out of Phase I of Salinity Management

Strategy

---

---

Offsets Policy --- Drought and Water Conservation Policy

---

---

---

---

Secondary MCL Guidance(6)

---

---

---

---

Alternative Compliance Project Guidelines

---

---

---

1. Discharge-specific studies vary by individual policy requirements. However, completion of an antidegradation analysis (including estimation of available assimilative capacity) for a discharge will be a common required practice.

2. Long-term salinity management will require the development of a Prioritization and Optimization Study as a first phase in the process.

Commented [A38]: How will SMCL economic analysis address long ‐term and cumulative impacts if analysis is only conducted during permit renewals and updates?



3. Participation in a Groundwater Management Zone requires the following studies/documents to be prepared: Preliminary Management Zone Proposal, Early Action Plan, Initial Assessment, Notice of Intent, Final Management Zone Plan, Management Zone Implementation Plan, monitoring and surveillance program, antidegradation analysis (including estimation of available assimilative capacity), and additional studies, as necessary.

4. Under the proposed Nitrate Permitting Strategy, dischargers may be required to prepare one or more of the following studies/documents: Notice of Intent, Early Action Plan, antidegradation analysis (including estimation of available assimilative capacity), monitoring and trend evaluation, SNMP Implementation Plan, and additional studies as necessary.

5. Salinity and Nitrate Minimization Studies (NPDES permittees) and Management Plans (irrigated agriculture) (i.e., BPTC/best efforts demonstration). 6. Monitoring and Surveillance related to Secondary MCL Guidance is an option of the guidance.



6.3.1 Drinking Water Solutions – Assessment Assumptions and Methodology

Legacy nitrate pollution in the Central Valley has caused significant and widespread problems in drinking water supplies. The first of the three overarching goals of the Central Valley SNMP Implementation Program is to ensure a safe drinking water supply for all residents of the valley (CV-SALTS, 2016a). A long-term permanent solution to supply drinking water to individuals and households in the Central Valley that have nitrate-contaminated groundwater likely consists of a combination of community water systems and point-of-use (POU) devices. As a short-term solution, before and during the implementation of these long-term solutions, drinking water in the form of bottled water provides a temporary solution to communities and households whose drinking water fails to meet nitrate standards.

For the purpose of this economic assessment, areas in the Central Valley that have nitrate concentrations greater than or equal to the Primary MCL of 10 mg/L (as N) in either the upper or lower groundwater zones have been grouped together. A second grouping consists of areas with well nitrate concentrations of 7.5 mg/L (as N) or greater in either the upper or lower zones. This second grouping does not represent areas where all groundwater exceeds the Primary MCL of 10 mg/L (as N) for nitrate. In fact, only the red areas (see Figure 8 and Figure 9) that make up the combined red plus orange area have groundwater that exceeds the Primary MCL for nitrate. The inclusion of the orange areas (7.5 mg/L (as N) nitrate concentration < 10 mg/L (as N)) in the combined coverage is meant to represent those areas where impacts to groundwater quality is a threat if nitrate loading is not controlled. Cities with populations greater than 5,000 inhabitants have been excluded from both of these areas, because, for this analysis, it is assumed that these cities have existing community water systems and would not be candidates for user protection under the Central Valley SNMP. The combined area represents those drinking water wells that are currently impaired or are at risk of becoming impaired by nitrate in the future. These two study areas are shown in Figure 8 for the Alta Irrigation District (AID) and Figure 9 for the entire Central Valley.

Cities34, towns, and individual households35 that would require short-term and long-term drinking water solutions were identified for the two (≥ 10 mg/L as N and ≥ 7.5 mg/L as N) study areas. Cities and towns with populations less than 5,000 were used to calculate the cost of providing drinking water to inhabitants via community water systems (blue and green areas in Figure 8 and Figure 9). The number of households that exist outside of cities and towns was used to calculate the cost of providing drinking water to these residents via POU devices (red and orange areas in Figure 8 and Figure 9). The cost to provide bottled water was calculated by summing the number of households identified to receive drinking water from a community water system and the number of households identified for installation of a POU device.

34 Identification and enumeration of cities and towns taken from 2010 U.S. Census data. 35 Enumeration of households based on census block data taken from 2010 U.S. Census data. A census block is the smallest geographic unit used by the U.S. Census Bureau for tabulation of 100-percent (data collected from all houses, rather than a sample of houses). See U.S. Census Bureau Geographic Areas Reference Manual: Chapter 11, available at: https://www.census.gov/geo/reference/garm.html



N

0

Groundwater Well Concentration 7.5 mgfl

2.5 5 10 Miles A

-L-- -- --4--4--

Figure 8: Areas in Alta Irrigation District with Groundwater Nitrate Concentrations::: 10.1(red areas) and::: 7.5 mgllas N (orange plus red areas) in the Upper or lower Zones (excludes cities with populations > 5,000 (groundwater nitrate



concentration data taken from CV-SAllS,2016c). Commented [A39]: Note: please ignore changes to figure, which were made for the purpose of having a smaller file for providing comments.



,

Legend

.•. •

. Communities with Nitrate Impacted Wells ( 10.0 mg/L)

. Communities with Nitrate Impacted Wells ( 7.5 mg/L)

. Groundwater Well Concentration 10.0 mg/L

Groundwater Well Concentration7.5 mg/L N

25 50 100 Miles



Figure 9: Areas in the CentralValley with Groundwater Nitrate Concentrations::10.0 (red areas) and:: 7.5 mgllas N (orange plus red areas) in the Upper or Lower Zones (excludes cities with populations :. 5,000 (groundwater nitrate

concentration data taken from CV.SALTS,2016c). Commented [A40]: Same note as above.



6.3.2 Short-Term Drinking Water Solutions

Bottled Water

As a short-term solution to supplying drinking water that meets drinking water standards to those living in areas impacted by nitrate in groundwater, it was assumed that bottled water would be provided to individuals and households that reside in areas that have drinking water well concentrations of nitrate equal to or greater than 10 mg/L (as N). It was assumed that cities with populations greater than 5,000 would not require bottled water to be provided and were excluded from the analysis area. Figure 8 shows the extent of this analysis layer for the Alta Irrigation District (located within the Kings Subbasin; DWR B118 Code: 5-22.08) and Figure 9 shows the extent the analysis area for the Central Valley. The following assumptions were used to calculate the annual cost to provide bottled water to individuals and households:

Drinking water consumption per household is 2.25 gallons per day (gpd).

Drinking water cost is $1.63 per gallon.

Cities with populations greater than 5,000 were assumed to currently provide their residents with drinking water in community systems that met the primary MCL for nitrate of 10 mg/L (as N) and therefore, were excluded from the analysis.

Alta Irrigation District

The populations and number of households36 in the AID area within each of the analysis areas (nitrate concentrations ≥ 10 mg/L and ≥ 7.5 mg/L as N) and the estimated annual costs to provide bottle water to these households are provided in Table 10. Refer to Appendix E for details of cost calculations.

Table 10: Bottled Water Supply Estimated Costs for the Alta Irrigation District.

Bottled Water Service Area

Population1

Number of

Households1

Daily Gallons per Household2

Price per

Gallon2

Annual Cost

AID (Upper or Lower Zone Nitrate ≥10 mg/L as N)

11,365

2,895

2.25

$1.63

$3.9 million

AID (Upper or Lower Zone Nitrate ≥7.5 mg/L as N)

19,988

4,949

2.25

$1.63

$6.6 million

[1] Population and number of households data taken from U.S. Census Bureau 2010.

[2] Daily household water consumption and price per gallon taken from Alternative Water Supply Options for Nitrate

Contamination, University of California, Davis. Harter, Thomas. July 2012.

36 The U.S. Census Bureau definition of a household includes a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied as separate living quarters by one or more persons.



Valley-Wide

The populations and number of households in the Central Valley within each of the analysis areas (nitrate concentrations ≥ 10 mg/L and ≥ 7.5 mg/L as N) and the estimated annual costs to provide bottle water to these households are provided in Table 11. Refer to Appendix E for details of cost calculations.

Table 11: Bottled Water Supply Estimated Costs for Areas of the Central Valley with Elevated Nitrate Concentrations in Groundwater.

Bottled Water Service Area

Population1

Number of Households1

Gallons Consumed per Household per

Day2

Price per Gallon2

Annual Cost

Central Valley (Upper or Lower Zone Nitrate ≥10 mg/L as N)

208,668

59,758

2.25

$1.63

$80 million

Central Valley (Upper or Lower Zone Nitrate ≥7.5 mg/L as N)

302,416

87,462

2.25

$1.63

$117 million

[1] Population and number of households data taken from U.S. Census Bureau 2010.

[2] Daily household water consumption and price per gallon are from the Alternative Water Supply Options for Nitrate

Contamination, University of California, Davis. Harter, Thomas. July 2012.

6.3.3 Long-Term Drinking Water Solutions

Community Water Systems

Connecting households impacted by nitrate levels in groundwater to either existing community water systems or new community systems was described in the Nitrate Implementation Measures Study (NIMS) as a viable solution for providing drinking water that meets drinking water standards to affected households (CV-SALTS, 2016b). The current economic analysis uses the pump, treat and serve (PTS) model of a community water system presented in the NIMS Report [NIMS Figure 5-17] to develop an approximate cost basis for the AID area and then extrapolate that to nitrate-impacted areas in the Central Valley. The NIMS Report developed costs for three different treatment processes to significantly reduce nitrate concentrations (1 mg/L as N or lower) in groundwater before providing as finished drinking water to consumers (CV-SALTS, 2016b). The three nitrate removal processes evaluated in the NIMS Report were reverse osmosis, ion-exchange, and biological denitrification.


The NIMS PTS community water system designed for AID consists of two water treatment plants that would provide treated groundwater to the smaller communities37 in the District. The

37 Cutler, Delft Colony, Dinuba, East Orosi, London, Monson, Orosi, Seville, Sultana, Traver, and Yettem.



NIMS PTS costs for the three different types of treatment technologies are provided in Table 12. Refer to Appendix F for details of cost calculations.

Table 12: Community Water System Estimated Costs for the Alta Irrigation District Using Different Treatment Technologies for Nitrate Removal.

Treatment Technologies

for Nitrate Removal

Capital Costs

(Millions)1

Operations and Maintenance

(Millions/Year)1

Annualized Cost

(Millions)1,2

AID Reverse Osmosis $71.25 $6.92 $9.42

AID Ion Exchange $47.28 $3.35 $6.08

AID Biological Denitrification $42.97 $1.32 $3.80

[1] NIMS Report (CV-SALTS, 2016b)

[2] Annualized costs were based on annual operations and maintenance (O&M) costs plus annualized capital

costs at a 4% annual interest rate.

Valley-Wide

The AID area serves as an archetype that can be used to develop very approximate costs in other areas of the Central Valley that have nitrate-impacted groundwater. Using the PTS costs developed for the AID area, a PTS cost per capita was developed. The following assumptions were made to extrapolate the PTS model from the AID study area to other similar nitrate- impacted areas of the Central Valley:

The AID area’s per capita treatment costs is representative of other areas that have communities that require a PTS.

Cities with populations greater than 5,000 were assumed to currently provide their residents with drinking water from community water systems that meet the primary MCL of 10 mg/L (as N) for nitrate and therefore, were excluded from the analysis.

For costing purposes, it was assumed that all community water systems will fall between production rates of 0.5 and 5 million gallons per day (MGD). This assumption is based on the two water treatment plants for AID in the NIMS study area and is supported by the exclusion of cities >5000 from the current study area.

Either ion exchange or biological denitrification provide the most cost-effective means to remove elevated nitrate concentrations; the exception would be areas that also have wells with total dissolved solids (TDS). For this analysis, for areas with TDS concentrations greater than 1,500 mg/L, it is assumed that reverse osmosis treatment would be used for removal of both salts and nitrates. An analysis of groundwater areas with high nitrates and TDS found that 30% of the area in the Central Valley with nitrate concentrations ≥ 10 mg/L (as N) and 27% of areas with nitrate concentrations ≥ 7.5 mg/L (as N) also have TDS levels at or above 1500 mg/l TDS. In these areas, a reverse osmosis system was assumed. In the remaining areas in the Central Valley, biological denitrification treatment was assumed.



The results of the extrapolation are presented in Table 13. Refer to Appendix F for details of cost calculations.

Table 13: Community Water System Estimated Costs for Areas in the Central Valley with Elevated Nitrate Concentrations in Groundwater.

Pump, Treat and

Serve Area

Population1

Capital Cost (Millions)2

Operations and Maintenance Cost

(Millions/Year)2

Annualized Cost

(Millions)2

Central Valley (Upper or Lower Zone Nitrate ≥ 10 mg/L as N)

85,250

$108.50

$6.00

$11.57

Central Valley (Upper or Lower Zone Nitrate ≥ 7.5 mg/L as N)

117,728

$147.64

$8.29

$15.98

[1] Population data taken from U.S. Census Bureau 2010.

[2] Costs per capita were calculated from the NIMS Report (CV-SALTS, 2016b).

Point-of-Use Treatment

Areas of dispersed population with elevated nitrate concentrations in groundwater that will not be serviced by a community water system will require installation of POU treatment systems in each household. POU treatment systems for nitrate consist of whole house nitrate ion exchange (IX) systems, whole house reverse osmosis (RO) systems, and under-the-sink (UTS) RO systems. For this cost estimate, UTS RO systems were assumed to be the most practical device for servicing nitrate-impacted households, with the other two systems both having drawbacks. Whole house RO systems are cost prohibitive and would require additional and extensive plumbing modifications in many households to ensure that the treated water does not leach metals from existing plumbing. Nitrate IX systems treat all of the household’s water, but they do so by adding salt, which can cause taste issues in the drinking water as well as add salt load to the household’s wastewater.

The cost basis for UTS RO systems assumes that they are leased (at a monthly rate) and will require RO membrane replacement every three to five years. Multiple lease quotes were obtained throughout the Central Valley for this system and the highest quote was used for the cost estimate.


The number of households in the AID area that would not be connected to the community water system was calculated through geolocated census data (2010) and the nitrate analysis areas shown in Figure 8. Table 14 lists the two different areas that were considered for this analysis and the annual cost for leasing UTS RO systems for each household within those areas. Refer to Appendix G for details of cost calculations.



Table 14: Point-of-Use Treatment System Estimated Costs for the Alta Irrigation District.

Point-of-Use Treatment Area

Population1

Number of

Households1

Monthly

Unit Cost2

Total Annual Cost(3)

AID (Upper or Lower Zone Nitrate ≥10 mg/L as N)

6,483

1,752

$40

$0.9 million

AID (Upper or Lower Zone Nitrate ≥7.5 mg/L as N)

12,103

3,162

$40

$1.6 million

[1] U.S. Census Bureau 2010.

[2] Based on conservative quote for monthly lease of a RO system.

[3] Total Annual Cost includes the cost of membrane replacement for POU treatment system every three years.

Valley-Wide

The costs of POU devices for the entire Central Valley were calculated from the number of households located within the two nitrate analysis areas (see Figure 9) that were not considered to be served by community water systems. These annual cost estimates are shown in Table 15. Refer to Appendix G for details of cost calculations.

Table 15: Point-of-Use Treatment System Estimated Costs for Areas in the Central Valley with Elevated Nitrate Concentrations in Groundwater.

Point-of-Use Treatment Area

Population1

Number of

Households1

Monthly

Unit Cost2

Total Annual Cost(3)

Central Valley (Upper or Lower Zone Nitrate ≥10 mg/L as N)

123,418

36,906

$40

$19 million

Central Valley (Upper or Lower Zone Nitrate ≥7.5 mg/L as N)

184,688

55,747

$40

$29 million

[1] U.S. Census Bureau 2010.

[2] Based on conservative quote for monthly lease of a RO system.

[3] Total Annual Cost includes the cost of membrane replacement for POU treatment system every three years.

6.3.4 Long-Term Nitrate Management

The goals of Long-Term Nitrate Management as described in the Central Valley SNMP are as follows:






For the purposes of developing cost estimates for management measures intended to address the second and third goals, the approach described in this section was followed. As a first step, cost estimates for aggressive restoration actions were developed for the Dinuba and Cutler-Orosi areas, two subareas of the Alta Irrigation District (AID). Based on the information developed for the Cutler-Orosi and Dinuba subareas, costs were estimated for the entire AID study area and, subsequently, costs were estimated for the Central Valley in areas impacted by elevated nitrate levels in groundwater.


AID is located in the eastern portion of the San Joaquin Valley (see Figure 10) and comprises about 238 square miles (CV-SALTS, 2016b). Groundwater modeling for two AID subareas, Dinuba and Cutler-Orosi, was conducted by Luhdorff & Scalmanini Consulting Engineers (LSCE), as a member of the Larry Walker Associates (LWA) project team. The modeling covered a range of Aggressive Restoration Alternative Modeling Scenarios38 that were vetted with CV-SALTS stakeholders (LSCE, 2016b). Modeling assumptions and results from that work were used in the development of cost estimates in this section.

Cost estimates provided below are also partially based on assumptions, findings, and unit costs developed for the Nitrate Implementation Measures Study (NIMS) (CV-SALTS, 2016b). Section 5.5.4 of NIMS describes and provides cost estimates for various management scenarios for reducing nitrate concentrations in the groundwater basin underlying the AID study area.

In order to change the ambient nitrate concentration in groundwater in the AID study area, aggressive measures were modeled. Removing nitrate mass is accomplished by pumping groundwater out of the aquifer system. That water can either be treated and served, treated and reinjected, or applied directly to agricultural lands. Another possible aggressive measure to reduce nitrate concentrations in the groundwater basin is through artificial winter season recharge on agricultural fields (on-farm winter recharge), where, in the AID example, excess Kings River water would be applied during winter months (November through March) to a particular agricultural area where the potential for accepting recharge is high. These two concepts (pumping and recharge) were examined in the Aggressive Restoration Alternative Modeling Scenario effort (LSCE, 2016b).

Two AID subareas, Dinuba and Cutler-Orosi, were prioritized for pump, treat, and reinject based on their status as economically disadvantaged communities, ambient nitrate levels, land uses, and mass loadings. A third area located north of Dinuba and east of Reedley was selected for examination of the on-farm winter recharge scenario based on its high recharge potential (soil type, depth to water, etc.). The recharge area considered is about 12 square miles or 7,600 acres. Based on previous studies, on average, there are 47,000 ac-ft of Kings River floodwater available annually (LSCE, 2016b). The location of the pump, treat, and reinject and recharge areas that were considered in the modeling effort are shown in Figure 11.

38 The Aggressive Restoration Alternative Modeling Scenario merges an AID Archetype MZ modeling scenario with select NIMS controls and on-farm winter recharge (LSCE, 2016b).



Figure 10: Alta Irrigation District Pilot Study Area (CV-SALTS, 2016b) Commented [A41]: Same note as above regarding map.



Figure 11: Pump-Treat-Reinject and Recharge Subareas in the Alta Irrigation District (LSCE, 2016b).

For the pump, treat, and reinject case studies, injection wells were assumed upgradient of the study areas, and extraction wells were assumed at locations down gradient of injection wells. The density of extraction and injection wells was determined based on estimates of the mass needed to be removed to achieve target concentrations within a specified target time frame using

Commented [A42]: Same note as above regarding map



wells that can pump at an assumed rate (LSCE, 2016b). The LSCE modeling results indicated that 26 extraction and 41 injection wells would be needed in the Dinuba area and 4 extraction and 7 injection wells would be needed in the Cutler-Orosi area (see Figure 12).

The breakdown for the number of wells needed in the lower and upper zones is shown in Table 16. For the upper zone aquifer the wells are assumed to be 300 feet deep. For the lower zone aquifer, the wells are assumed to be 752 feet deep (LSCE, 2016b).

Table 16: Number of Extraction and Injection Wells Assumed for Long-Term Nitrate Management in the Dinuba and Cutler-Orosi Areas (LSCE, 2016b).

Area

Extraction Wells

Injection Wells

Total Number of Wells

Dinuba

Upper 10 16 26

Lower 16 25 41

Total 26 41 67

Cutler-Orosi

Upper 3 5 8

Lower 1 2 3

Total 4 7 11

Given the number of wells noted in Table 16, different scenarios were modeled for several different well pumping rates:

No project, known as Scenario 3, represents a scenario where water is pumped and applied to agricultural land with no treatment. This does not necessarily improve the groundwater quality, but it removes some nitrate mass through crop utilization. It was described as “Scenario 3” in a previous CV-SALTS modeling effort performed by LSCE (CV-SALTS, 2016e).

Plan A assumes the same conditions as Scenario 3 with the added on-farm winter recharge in the area north of Dinuba.

Plan B represents a pump, treat, and reinject scenario using 500 gpm extraction wells. The flowrate for the injection wells is optimized by the model, and ranges from 250 gpm to 320 gpm. On-farm winter recharge from Plan A is also incorporated.

Plan C increases the pumping and injection rates from Plan B by a factor of 1.5 for each well (e.g., extraction wells pumping at 500 gpm in Plan B pump at 750 gpm in Plan C). On-farm winter recharge from Plan A is also incorporated.

Plan D increases the pumping and injection rates from Plan B by a factor of 2 for each well (e.g., extraction wells pumping at 500 gpm in Plan B pump at 1,000 gpm in Plan C). On-farm winter recharge from Plan A is also incorporated.



The modeling results and respective cost estimates for the three subareas of treatment are detailed below, where possible.

Figure 12: Extraction and Injection Wells in the Dinuba and Cutler-Orosi Areas for the Aggressive Restoration Modeling Scenario (LSCE, 2016b). Commented [A43]: Same note as above regarding map



Pump, Treat, and Reinject: Dinuba

Twenty-six (26) extraction wells were assumed for the pump, treat, and reinject nitrate management approach in the Dinuba area (see Table 16). The total volumes treated daily under Plans B through D are shown in Table 17.

Table 17: Dinuba Area Daily Treated Volumes under Different Management Plans (LSCE, 2016b).

Plan B

Plan C

Plan D

Flowrate

Total Volume

Flowrate

Total Volume

Flowrate

Total Volume

Extraction per Well Treated per Well Treated per Well Treated Area Wells (gpm) (MGD) (gpm) (MGD) (gpm) (MGD)

Upper 10 500 7.2 750 10.8 1000 16.4

Lower 16 500 11.5 750 17.3 1000 23.0

Total 26 500 18.7 750 28.1 1000 37.4

Time series plots of average nitrate concentration under the different management plans are provided in Figure 13. As shown in the graphs, Plans B, C, and D show significant improvements in ambient groundwater nitrate concentrations compared to Plan A. The upper zone did not achieve a target of 5 mg/L (as N) during the entire 100-year simulation. The lowest concentration attained in the upper zone occurred in Plan D, with a value of 10.5 mg/L (as N) after 40 years. The lower zone reached a target of 5 mg/L (as N) with Plan C and Plan D after 60 years and 34 years, respectively. As shown in the figure, all of the aquifer zones reach an equilibrium condition over time, meaning that the amount of nitrate mass entering the area equals the amount of mass leaving the area. In all cases, it takes decades for the Dinuba area to reach a state of equilibrium. A summary of the simulation results is provided in Table 18.

Table 18: Summary of Dinuba Pump-Treat-Reinject Simulation Results (LSCE, 2016b).

Number of years to reach:

Aquifer Initial

Concentration

5 mg/L as N 7.5 mg/L as N

Zone (mg/L) Plan A Plan B Plan C Plan D Plan A Plan B Plan C Plan D

Upper 19.9 - - - - - - - -

Lower 9.0 - - 60 34 37 20 12 9

Production 11.9 - - - - - 95 29 21

“-“ indicates concentration target is unattainable by the selected restoration plan. Equilibrium conditions are attained before reaching target level.



45

z 42

39 O:IJ ,§. 36

33

3"..0 27 0

24

!": 21

z: ";"! 18

15 5 r;; 12

Dinuba, Upper Zone -

Scenario3

- PlanA

- PlanB

- Plane

10 20 30 40 50 60 70 80 90 100

Simulated Time (Years)

Dinuba, Lower Zone 12

z 11

,§. 10

=0

'£ 9 =..

8

- PlanO

8 7

E

.s 6

]" 5

r;; 4 L 0 10 20 30 40 50 60 70 80 90


100

21

£ 20

19 1), 18 ,§. 17

.=!? 16

15 14

g 13 u e 12

E l J z: 10 "9" :; 8 5 r;; 7

6

Dinuba, Production Zone

0 10 20 30 40 50 60 70 80 90


100

Figure 13: Dinuba Area lime-Series Plots of Simulated Nitrate Concentrations under Different Restoration Plans



(LSCE,201Gb)



The estimated costs for the pump, treat, and reinject systems can be broken down into two main components: extraction and injection wells and treatment facilities. For cost estimating purposes, it was assumed that regional treatment facilities with ion exchange technologies and evaporation ponds would meet the treatment needs (CV-SALTS, 2016b). For each area needing treatment, a network of pipes was assumed to connect the upper zone extraction wells and transport the water to a regional treatment facility where nitrate would be removed and the treated water pumped to upper zone reinjection wells. Similarly, a network of pipes was assumed to connect the lower zone extraction wells and transport the water to a regional treatment facility and from there to lower zone reinjection wells. Evaporation ponds would be needed for brine; it was estimated that an evaporation pond area of approximately 0.15 acres (assuming 5-ft depth) would be needed for a 1 MGD treatment facility (CV-SALTS, 2016b). It is important to note that, while the LSCE evaluation locates the wells in each study area, the exact location of the wells, treatment facilities, and evaporation ponds have not been evaluated in this concept-level analysis. The following costs are based on a pump, treat, and reinject system composed of a certain number of wells, pumps, pipelines, and treatment facilities. These planning level costs are intended to be inclusive of all project implementation costs including planning, engineering and contingencies (CV-SALTS, 2014).

The capital cost for each extraction and injection facility is estimated at $1.4M and it accounts for the construction and installation of each well, as well as the appurtenant engineering and conveyance facilities (pumps, pipelines, etc.) to take the extracted water to/from the facility to the centralized treatment facilities. The estimated concept-level operation and maintenance (O&M) costs are approximated as 10% of the total capital costs (CV-SALTS, 2014).

The capital and O&M costs for the ion exchange treatment facilities are based on studies reported in An Assessment of the State of Nitrate Treatment Alternatives Final Report to the American Water Works Association (AWWA, 2012). This report was used by CDM Smith in its derivation of cost estimates in the NIMS Report (CV-SALTS, 2016b). Based on the assumptions used in this report, estimated costs for ion exchange facilities with a capacity between 0.5 and 5 MGD (as needed in the Cutler-Orosi area) have annualized capital costs ranging from $0.28 to $0.94 per 1,000 gallons of treated water. Operating costs are estimated to range from $0.46 to $1.25 per 1,000 gallons of treated water. Estimated costs for ion exchange facilities with over 5 MGD capacity (as needed in the Dinuba area) have annualized capital costs ranging from $0.28 to $0.61 per 1,000 gallons of treated water. Operating costs are estimated to range from $0.37 to $0.87 per 1,000 gallons of treated water. In addition, evaporation ponds are estimated to cost approximately $500,000 per acre (CV-SALTS, 2016b).

Based on the assumptions described above, the costs for each element of the proposed long-term nitrate management plan for the Dinuba area under modeling Plan B are shown in Table 19. Separate cost estimates for Plans C and D scenarios were not developed. However, capital costs would be marginally higher to account for increased horsepower of pumps required and incremental increases in piping and valves. Energy costs would be significantly higher, increased by 50% for Plan C and 100% for Plan D.



Table 19: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Dinuba Area (Restoration Plan B).

Capital Costs ($ Millions) Annual O&M Costs ($ Millions)

Treatment Total Treatment Total

Zones Wells Low High Low High Wells Low High Low High

Upper $36 $8 $17 $ 44 $ 53 $3.6 $1.0 $2.3 $ 4.6 $ 5.9

Lower $57 $14 $28 $ 71 $ 85 $5.7 $1.7 $3.8 $ 7.4 $ 9.5

Project Total $93 $22 $45 $115 $138 $9.3 $2.7 $6.1 $12.0 $15.4

Contingency (30%) $ 35 $ 41 $ 3.6 $ 4.6

Total, with contingency $150 $179 $ 16 $ 20

Annualized capital cost (20 yrs, 3% interest) $ 10 $ 12

Low High

Total annual cost (annualized capital & O&M) $ 26 $ 32

Pump, Treat, and Reinject: Cutler-Orosi

Four extraction wells were assumed for the pump, treat, and reinject nitrate management approach in the Cutler-Orosi subarea (see Table 16). The total volumes treated daily under Plans B through D are shown in Table 17.

Table 20: Cutler-Orosi Daily Treated Volumes under Different Management Plans (LSCE, 2016b)

Plan B Plan C Plan D

Total Total Total Flowrate Volume Flowrate Volume Flowrate Volume


Upper 3 500 0.7 750 1.1 1000 1.4

Lower 1 500 2.2 750 3.2 1000 4.3

Total 4 500 2.9 750 4.3 1000 5.8

Time series plots of average nitrate concentration under the different management plans are provided in Figure 14. As shown in the graphs, Plans B, C, and D showed improvements compared to Plan A. The upper and production zones did not achieve the target of 5 mg/L (as N) during the entire 100-year simulation. In the upper zone, the lowest concentration achieved was 6.6 mg/L (as N) under Plan D. In the production zone, the lowest concentration achieved was 5.2 mg/L (as N), also under Plan D. The lower zone reached its target of 5 mg/L (as N) in 23 years, 14 years, and 11 years, with Plans B, C, D respectively. All of the aquifer zones reach an equilibrium condition over time, meaning that the amount of nitrate mass entering the area equals the amount of mass leaving the area. In the upper zone, it takes two decades for the Cutler-Orosi area to reach a state of equilibrium at a future improved level. In the lower zone and production zone, it takes 50 years or more to reach equilibrium. A summary of the simulation results is provided in Table 21.



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Figure 14: Cutler-OrosiArea Time-Series Plots of Simulated Nitrate Concentrations under Different Restoration Plans

(LSCE,201Gb).



Table 21: Summary of Cutler-Orosi Pump-Treat-Reinject Simulation Results (LSCE, 2016b).

Number of years to reach:

Aquifer Initial

Concentration

5 mg/L as N 7.5 mg/L as N

Zone (mg/L) Plan A Plan B Plan C Plan D Plan A Plan B Plan C Plan D

Upper 11.4 - - - - - 12 7 5

Lower 6.0 - 23 14 11 0 0 0 0

Production 8.6 - - - - - 3 2 2

“-“ indicates concentration target is unattainable by the selected restoration plan. Equilibrium conditions are attained before reaching target level.

Based on the same assumptions described for the cost derivations for the Dinuba subarea, and based on the treated volumes shown in Table 20, the costs for each element of the pump, treat, and reinject nitrate management approach in the Cutler-Orosi area under Restoration Plan B are shown in Table 22. As mentioned earlier, separate cost estimates for Plans C and D scenarios were not developed. However, capital costs would be marginally higher to account for increased horsepower of pumps required and incremental increases in piping and valves. Energy costs would be significantly higher, increased by 50% for Plan C and 100% for Plan D.

Table 22: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Cutler-Orosi Area (Restoration Plan B).



Zone Wells Low High Low High Wells Low High Low High

Upper $11.2 $2.4 $ 8.0 $13.6 $19.2 $1.1 $0.4 $1.0 $1.5 $2.1

Lower $ 4.2 $0.8 $ 2.6 $ 5.0 $ 6.8 $0.4 $0.1 $0.3 $0.5 $0.7

Project Total $15.4 $3.2 $10.6 $18.6 $26.0 $1.5 $0.5 $1.3 $2.0 $2.8

Contingency (30%) $ 5.6 $ 7.8 $0.6 $0.8

Total, with contingency $24.2 $33.8 $2.6 $3.6

Annualized capital cost (20 yrs, 3% interest) $ 1.6 $ 2.3

Low High

Total annual cost (annualized capital & O&M) $ 4.2 $ 5.9

Pump, Treat, and Reinject: Entire Alta Irrigation District

Based on modeling results for the two subareas in AID, LSCE estimated the number of wells that would be needed to aggressively restore the entire AID study area (LSCE, 2016b). The number of wells estimated for the lower and upper zones is shown in Table 23. The total volume treated daily under Plan B is derived from the number of wells and flowrates and is shown in Table 24. Similar to the Dinuba and Cutler-Orosi subareas, the simulation assumed that areas in AID with existing nitrate concentrations above 7.5 mg/L (as N) (see Figure 8) would be restored through the pump, treat, and reinject approach. Modeling for the entire AID study area was not within the scope of work performed by LSCE. Therefore, it is unknown how long it would take to



reach target concentration goals (or whether they are attainable at all) under Plans A, B, C, and D.

Table 23: Number of Extraction Wells and Injection Wells Assumed for Long-Term Nitrate Management in the Entire Alta Irrigation District (LSCE, 2016b).

Area

Extraction Wells

Injection Wells

Total Number of Wells

Upper 238 381 619

Lower 377 604 981

Total 615 985 1600

Table 24: Alta Irrigation District Daily Treated Volumes under Different Management Plans (LSCE, 2016b).

Plan B

Plan C

Plan D

Flowrate

Total Volume

Flowrate

Total Volume

Flowrate

Total Volume


Upper 238 500 171 750 257 1000 343

Lower 377 500 271 750 407 1000 543

Total 615 500 443 750 664 1000 886

Similar to the two AID subareas, for estimating costs for the entire AID, it was assumed that regional treatment facilities with ion exchange technologies and evaporation ponds would be used to reduce nitrate prior to reinjection. The following costs are based on a pump, treat, and reinject system composed of extraction and injection wells and treatment facilities. For cost estimating purposes, the standard capacity of a treatment facility is assumed to be 25 MGD. Based on the flows shown in Table 23 for the overall AID archetype study area, seven treatment facilities of this size would be needed to handle extracted water from the upper zone, and eleven treatment facilities would be needed to meet the treatment needs for the lower zone. Evaporation ponds would be needed for residuals; it is estimated that an evaporation pond area of approximately 3.5 acres (assuming 5-ft depth) would be needed for each 25 MGD treatment facility.

Based on the assumptions described above, and the unit costs previously described for the Dinuba and Cutler-Orosi subareas, the estimated costs for long-term nitrate management in the AID area under Restoration Plan B are shown in Table 25. As stated previously, separate cost estimates for Plans C and D scenarios were not developed. However, capital costs would be marginally higher to account for increased horsepower of pumps required and incremental increases in piping and valves. Energy costs would be significantly higher, increased by 50% for Plan C and 100% for Plan D.



Table 25: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Entire Alta Irrigation District (Restoration Plan B).


AID Zone

Wells

Treatment Total

Low High Low High

Wells

Treatment Total

Low High Low High

Upper $ 867 $202 $ 427 $1,069 $1,294 $ 87 $25 $ 57 $112 $143

Lower $1,373 $318 $ 670 $1,691 $2,043 $137 $39 $ 89 $176 $227

Project Total $2,240 $520 $1,097 $2,760 $3,377 $224 $64 $146 $288 $370

Contingency (30%) $ 828 $1,001 $ 86 $111

Total, with contingency $3,588 $4,338 $374 $481

Annualized capital cost (20 yrs, 3% interest) $ 241 $ 292

Low High

Total annual cost (annualized capital & O&M) $ 615 $ 773

On-Farm Recharge

The On-Farm Winter Recharge modeling scenario was assumed to apply excess Kings River surface water during a five-month period in the winter (November to March). The increased recharge volume would cause vertical movement of water downward through the aquifer system in the vicinity of the on-farm recharge area. Figure 15 shows the time-series plots of simulated nitrate concentrations in the recharge area over the 100-year simulation period for the various restoration plans. On-farm recharge activities reduced the simulated nitrate concentrations in the upper zone and in the production zone compared to the “no project” Scenario 3 simulation. One of the negative side effects of flushing an increased amount of water downward is that poor shallow water quality migrates downward deeper into the aquifer. As seen in the lower zone time series plot, the presence of on-farm recharge slightly increased the average nitrate concentration for the lower zone (LSCE, 2016b).

Information is not available to allow the development of a cost estimate for the on-farm recharge scenario. On-farm recharge was considered to be a conceptual scenario, but its feasibility has yet to be demonstrated. At this conceptual stage, it is not possible to develop a meaningful cost estimate.



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Figure 15: On-Farm Recharge lime-Series Plots of Simulated Nitrate Concentrations under Different Restoration Plans



(LSCE,201Gb).



Valley-Wide

Pump, Treat, and Reinject for Long-Term Nitrate Management in the Central Valley

The findings from the LSCE analysis for Alta Irrigation District were scaled up to the Central Valley based on the information derived in the AID modeling effort and the surface area of nitrate-impacted areas in the Central Valley (see Figure 9 for map showing nitrate impacted areas in the Central Valley). However, these findings have to be strongly qualified. Applying pump, treat, and reinject designs to large regional areas may not be practicable. Localized efforts in areas that are of high priority (based on proximity to communities and existing ambient conditions) may be more feasible for restoration activities (LSCE, 2016b).

For the purpose of obtaining a planning-level understanding of the potential costs of a valley- wide restoration effort, the number of wells and treatment facilities needed were projected and shown in Table 26. The total volumes to be treated daily under Plans B through D were derived based on the number of wells and flowrates shown in Table 27. Similarly to AID, this estimate assumed that areas with existing nitrate concentrations above 7.5 mg/L (as N) would be aggressively restored. However, modeling under the various restoration plans was not conducted at the valley-wide level. It is unknown how long it would take to reach target concentration goals (or whether they are attainable at all) under Plans A, B, C, and D.

Table 26: Estimates for Number of Wells and Treated Volumes Required for Long-Term Nitrate Management in the Alta Irrigation District and Projections for the Central Valley.

Area needing

Area


treatment (sq mi)

Extraction Wells

Injection Wells

Upper Zone 208 238 381

Lower Zone 254 377 604

Total 462 615 985

Valley-wide

Upper Zone 6,154 7,053 11,291

Lower Zone 4,324 6,418 10,283

Total 10,478 13,471 21,574



Table 27: Central Valley Daily Treated Volumes under Different Management Plans.

Plan B Plan C Plan D

Total Total Total Flowrate Volume Flowrate Volume Flowrate Volume


Upper 6,154 500 4,431 750 6,646 1000 8,862

Lower 4,324 500 3,113 750 4,670 1000 6,227

Total 10,478 500 7,544 750 11,316 1000 15,088

Similar to AID, for cost estimation purposes, it was again assumed that regional treatment facilities with ion exchange technologies and evaporation ponds would be built for treating the pumped groundwater valley-wide. At a proposed 25 MGD capacity per facility and using the total volumes to be treated shown in Table 27, 204 treatment facilities were projected to be needed for the upper zone and 185 for the lower zone under Restoration Plan B. Evaporation ponds of approximately 3.5 acres (assuming 5-ft depth) would be needed for each 25 MGD treatment facility.

Based on the assumptions described above and the unit costs previously described, the estimated costs for each element of the pump, treat, and reinject approach under Plan B for the Central Valley are shown in Table 28. As stated previously, these estimates are strongly qualified and intended only to present a planning-level understanding of the financial effort involved in aggressively restoring such a large basin. Because of all of the generalizations, estimations, and ‘scaling up’ factors involved, actual costs could easily be plus or minus 50% of estimated costs.

Table 28: Estimated Capital and O&M Costs for Long-Term Nitrate Management in the Central Valley (Restoration Plan B).

Capital Costs ($ Billions) Annual O&M Costs ($ Billions)


Zone Wells Low High Low High Wells Low High Low High

Upper $26 $6 $12 $32 $38 $2.6 $0.7 $1.7 $3.3 $4.3

Lower $23 $5 $11 $28 $34 $2.3 $0.7 $1.5 $3.0 $3.8

Project Total $60 $72 $6.3 $8.1

Contingency (30%) $18 $22 $1.9 $2.4

Total, with contingency $78 $94 $8.2 $10.5

Annual cost (20 years, 3% interest) $5.2 $6.3

Low High

Total annual cost (annualized capital & O&M) $13.4 $16.8

On-Farm Recharge for Long-Term Nitrate Management in the Central Valley

Projecting on-farm recharge needs and cost estimates valley-wide is not practical at this time. This type of long-term management strategy is highly site-specific and greatly dependent on the



ability of the aquifer materials to accept additional water. Factors such as soil and subsurface texture, the presence of deep ripping, and the depth to the water table, are all factors that determine the ability of a particular area to transmit excess water vertically downward into the aquifer. Locations for on-farm recharge or any increased recharge efforts must be considered and selected according to their hydrogeologic setting, local site conditions, and availability of excess winter waters. Determining suitable on-farm recharge and flood water availability for locations valley-wide is outside of the scope of this study.

Refer to Appendix H for details of cost calculations presented herein for long-term nitrate management.

6.3.5 Long-Term Salt Management: Regional Brine Line

The proposed Central Valley SNMP presents a comprehensive regulatory and programmatic approach for the sustainable long-term management of salt and nitrate in the Central Valley. The three overarching goals of the Central Valley SNMP Implementation Program are:




In this section, cost estimates are described for one of the four Long-Term Salt Management alternatives (Alternative #1) proposed in the Strategic Salt Accumulation Land and Transport Study (SSALTS) Phase 2 Report (CV-SALTS, 2014). The mass balance analysis that was used to develop the SSALTS Phase 2 Report alternative is based on findings in the Initial Conceptual Model (ICM) Technical Services: Tasks 7 and 8 – Salt and Nitrate Analysis for the Central Valley Floor and a Focused Analysis of Modesto and Kings Sub-regions (CV-SALTS, 2013). The ICM effort found that the current net salt accumulation in the entire Central Valley is about 7 million tons annually. Nevertheless, there are areas with good ambient groundwater quality where, although salt is accumulating, it is doing so at low rates. The SSALTS Phase 2 Report proposes pump-and-treat solutions in 8 of the 22 initial analysis zones (IAZs) modeled in the ICM, for a net salt removal of approximately 5 million tons annually. Seven of the IAZs (9, 10, 14, 15, 19, 21, and 22) are located in the San Joaquin, Tulare, and Kern County areas and one IAZ (6) represents the Cache-Putah area.

The SSALTS Phase 2 Report discusses four long-term salt management alternatives, all of them involving regional desalter facilities and brine disposal. In all of these scenarios, brine disposal relies on deep well injection in the Cache-Putah area (IAZ 6), and transportation of all or a portion of the brine from the remaining seven IAZs to the San Francisco Bay Area via a regional brine line. Brine would be discharge via either the East Bay Municipal Utility District (EBMUD) outfall or an alternative outfall location in saline waters.



A regional brine line is a favored choice for exporting the brine from the Central Valley due to capacity and cost limitations of other transportation options (truck and rail). Other in-valley management alternatives, such as the San Joaquin River Real-Time Management Program, brine reuse in local hydraulic fracturing projects, disposal in designated salt accumulation areas, or a combination of these, were also considered in the SSALTS Phase 2 Report (CV-SALTS, 2014). Nevertheless, unlike the other salt management options, the Bay Area disposal option potentially has the capacity to manage all of the current salt accumulation in the Central Valley. In terms of which Bay Area location is proposed, the EBMUD location is a viable candidate. Substantial engineering, land acquisition, CEQA, and permitting would be required for constructing an additional Bay Area outfall (CV-SALTS, 2014).

In terms of treatment, regional desalters with reverse osmosis (RO) are considered in this economic analysis because of proven performance and known costs associated with RO treatment. Emerging technologies, while potentially promising, cannot be evaluated at this time due to a lack of essential information. The analysis assumes that treatment facilities would be located near the brine line, so there would be minimal conveyance facilities to transport the brine from the desalters to the brine line. This pump-treat-reinject scenario is modified from the original SSALTS Alternative #1, in that the current analysis assumes that the water recovered post-RO treatment is transported and returned to the ground in an area upgradient of its extraction point as a means of achieving restoration of Central Valley groundwater quality and to maintain sustainable groundwater levels.

The following sections provide a description and cost for each element of this proposed salt management alternative. These planning level costs are intended to be inclusive of all project implementation costs including planning, engineering and contingencies (CV-SALTS, 2014).

Extraction Facilities

Extraction of salts would occur from shallow groundwater, perched water, and agricultural drain water. The total estimated volume of water to be treated from the seven affected IAZs in the San Joaquin and Tulare areas is 825 MGD; 167.5 MGD is expected to be treated in IAZ 6 (CV- SALTS, 2014). An assumed average extraction rate of 750 gpm was used to estimate the number of extraction facilities (extraction wells, drain water sump pumps, etc.). About 693 facilities would be required for the seven affected IAZs in the San Joaquin and Tulare basins and another 155 facilities for IAZ 6 to move the necessary volume of water through treatment and reinjection.

The capital cost for each extraction facility is estimated at $1.4M and it accounts for the installation of the extraction facility, as well as the appurtenant engineering and conveyance facilities (pumps, pipelines, etc.) to take the extracted water from the facility to the desalter facilities. The estimated concept-level operation and maintenance (O&M) costs are approximated as 10% of the capital costs (CV-SALTS, 2014).



Desalter Facilities

Thirty-three 25-MGD desalter facilities would be required to treat the water in the San Joaquin and Tulare basins and another seven 25 MGD desalters would be required for IAZ 6. The basis for design includes an assumption of high TDS concentration (above 1,000 mg/L) and 90% recovery of treated water.

The capital cost for each treatment facility is estimated at $150M based on a treatment cost of $6/gal per day. The estimate includes an allowance of up to 5 miles of 12-in diameter pipeline for each desalter to tie into the brine line. The estimated concept-level O&M costs are approximated as 10% of the capital costs (CV-SALTS, 2014).

Post-RO Treatment for Trace Constituents

The existence of inorganic trace constituents in the brine concentrate has the potential to be problematic in terms of NPDES permit compliance for discharges from EBMUD or another wastewater treatment plant (WWTP). Some areas with subsurface agricultural drainage have elevated concentrations of one or more trace elements; e.g., selenium, molybdenum, arsenic, uranium, and vanadium. The specific treatment technology to remove trace constituents at any given location will depend on the specific constituents. For the purposes of providing a concept- level cost estimate, it was assumed that half of the desalter facilities will need such additional treatment facilities (CV-SALTS, 2014).

In general, several processes can be considered for treatment of trace constituents in the brine, such as ion exchange, lime softening, and coagulation/co-precipitation. The post-treatment process to remove the inorganic trace constituents can be constructed at the local desalter facilities and operated and maintained by local plant staff. These treatment facilities are relatively complex, requiring well trained staff and frequent maintenance. The estimated cost to add treatment for trace constituents (ion exchange) at each desalination facility ranges from $3/gpd to $4/gpd (CV-SALTS, 2014).

Reinjection Facilities for Treated Water

As mentioned regarding this pump-treat-reinject scenario, the treated water is assumed to be transported and returned to the ground in an area upgradient of its extraction point. At a recovery rate of 90%, approximately 90% of the number of wells needed for extraction would be needed for reinjection of the treated water. The unit cost for the injection facilities is assumed to be similar to the extraction cost, $1.4M. This cost accounts for the installation of the injection well, as well as the appurtenant engineering and conveyance facilities (pumps, pipelines, etc.) to take the treated water from the desalter facilities to injection wells. The estimated concept-level O&M costs are again approximated as 10% of the capital costs.

Regional Pipeline for Brine Disposal

It is assumed that a regional brine line would transport concentrated brine from desalters from the seven IAZs in the San Joaquin and Tulare areas to the Bay Area for disposal at EBMUD. The SSALTS Phase 2 Report presents two alignments for this pipeline (see Figure 16).



Alternative 1 follows a gas pipeline alignment (roughly paralleling the Interstate 5 Freeway) along the western side of the valley, turning west near Tracy and then north near Fremont. Alternative 2 crosses the coastal mountains further to the south near Panoche Junction. According to the SSALTS report, this alternative is not preferred, because it would not be able to collect brine concentrate from IAZs 22, 12, and 9. Also, the lift over the coastal range is greater than in Alternative 1 (CV-SALTS, 2014).

Brine line pipe material would be corrosion-resistant, such as high-density polyethylene (HDPE). Flows in the upper reaches can be accommodated by a single pipe (maximum HDPE pipe diameter is 63 inches). In the lower reaches, it is assumed that two pipelines would be placed side-by-side in a trench. The total length of the proposed pipeline is 281 miles; the diameter varies through the various reaches, based on the brine volume collected at different locations along the alignment. Based on estimates of volumes and flow rates for each IAZ, and a target of maintaining velocities of approximately 6 feet per second (ft/sec) in the brine line, it was assumed that a 24-inch diameter pipeline would be sufficient for the first 50 miles of the Central Valley Brine Line (through IAZs 21 and 19), a 36-inch pipeline would be sufficient for IAZ 15 (through mile 72), and a 48-inch pipeline would be required for miles 72 through 135. It was assumed that two 48-inch pipelines would be required for the remainder of the pipeline – miles 135 to 281 (CV-SALTS, 2014).

In estimating costs for the brine line installation, a unit cost of $6/linear foot/diameter-inch was used for rural areas (up to mile 135). A unit cost of $15/linear foot/diameter inch was assumed for miles 225 to 281 because the pipeline crosses the coastal range and because of the urbanization in the East Bay. The estimated concept-level O&M costs are approximated as 10% of the capital costs (CV-SALTS, 2014).

Central Valley Salt and Nitrate M:magement PIan Central Valley Regional Water Quality Control Board

Lany Walker .Associates Economic Analysis 126

••

Legend

lO mile markers (Alternative1)

lO·mlle markers (Alternative 2)

lO mile markers (Alternatives 1& 2)

N

A. .o.12.=s.===2s........s.0

Miles

Figure 16: Potential Alignment for the Central Valley Brine Line (CV-SATLS, 2014). Commented [A44]: Same note as above regarding map



It is assumed that a series of pump stations would also be required along the brine line, with each pump station functioning essentially as an in-line booster pump station. For the purposes of developing the cost estimates included in the SSALTS Phase 2 report, it was assumed seven pump stations would be required at strategic locations, ranging from 20 to 60 miles apart. The capital costs for all pump stations would be $260M. Annual power costs would be about $60M, and maintenance would be $13M, based on 5 percent of capital costs (CV-SALTS, 2014).

Brine Disposal at EBMUD

Based on discussions CDM Smith had with EBMUD in 2014, it was assumed that a tipping fee of $0.04/gallon would be charged for brine disposal (CV-SALTS, 2014).

Deep Well Injection for IAZ 6 Brine

Under this salinity management approach, brine from RO treatment in IAZ 6, a zone that is far removed from the brine line alignment, would be injected and stored in deeper aquifers isolated from primary drinking water aquifers for disposal or storage and future recovery. It is assumed that each deep well would pump 0.5 MGD to a depth of 4,000 ft (CV-SALTS, 2014). If each desalter facility in IAZ 6 produces 2.5 MGD of brine, then five of these wells would be needed to dispose of brine from each of the seven IAZ 6 desalters.

The unit cost of each deep injection well was estimated at $2.5M; of this cost approximately 60% is for drilling the well and the remainder is for well head facilities, approximately two miles of piping, pumping, and a pump station. Operating costs would include the delivery pump station power and maintenance and replacement costs, injection pumps power, and well operation and maintenance costs. Assuming that the annual O&M costs would be approximately 10% of the capital cost, the annual operating cost of each well was assumed to be approximately $250,000 (CV-SALTS, 2014).

Summary of Costs

Based on the assumptions described above, the estimated costs for each element of the proposed long-term salinity management plan are shown in Table 29. Refer to Appendix I for details of cost calculations for long-term salinity management.



Table 29: Long-Term Salinity Management Plan – Summary of Estimated Costs.

IAZs 9, 10, 14, 15, 19, 21, and 22 IAZ 6 Entire Project

Capital Cost

O&M

Capital Cost

O&M

Total Capital

Total O&M

Component

Number of Units Unit Cost

Total ($M)

Cost ($M)

Number of Units

Unit Cost

Total ($M)

Cost ($M)

Cost ($B)

Cost ($B)

Extraction wells 693 $1.4M $970 $97 155 $1.4M $217 $22

Desalter facilities 33 $150M $4,950 $495 7 $150M $1,050 $105

Post-RO brine treatment 37.25MGD $4/gal $149 $15

Reinjection wells 624 $1.4M $874 $87 16 $1.4M $22 $2

Brine line (1) 24” diam, 50mi 36” diam, 22 mi 48” diam, 63 mi 2 x 48” diam, 90 mi 2 x 48” diam, 56 mi

$6/ LF diam in $6/ LF diam in $6/ LF diam in $6/ LF diam in $15/ LF diam in

$38 $25 $96

$239 $373

Subtotal brine line: $771 $77

Brine line pump stations 7 $36.85M $258 $72

Brine disposal at EBMUD 74.5MGD $0.04/gal $1,088

Deep well brine disposal 35 $2.53M $89 $9

Total costs $7,972 $1,938 $1,378 $138 $9.3 $2.1

Contingency (30%) $2.8 $0.6

Total plus contingency $12.1 $2.7

Estimated annual cost (over 30 years at 3% interest rate) $0.6 $2.7



Total estimated annual cost $3.3

(1) A 1.75 multiplier (instead of 2) is applied for segments where two parallel pipes are used (to account for cost savings from using the same alignment).



Salinity Prioritization and Optimization Study

As a means to further develop the work produced under SSALTS, CV-SALTS stakeholders have identified the need for completion of a Salinity Prioritization and Optimization Study (P&O) Study that would take place during the first 10 years of the SNMP implementation. The Salinity P&O Study would determine optimal areas to locate regional/sub-regional treatment and transportation facilities for salinity, while accounting for nitrate issues in groundwater. The study would, in phases, evaluate the location, routing, and implementation and operational feasibility of facilities including the regional regulated brine line described in the previous section. Implementation of the Salinity Management Strategy described in Section 5.1 would occur in three phases, each lasting 10 years and each including technical tasks that support the portion of the salinity management plan executed in that and subsequent phases. During the first 10 years (Phase 1), Salinity P&O studies would be conducted that lead to a concept design for the proposed regulated brine line. Phase 1 would also include development of a Governance Options Plan and Funding Plan. The estimated annual cost of implementation for Phase 1 of the Salinity P&O Study ranges from $700K to $1.3M (CDM Smith, 2016b).

6.3.6 Description of Economic Costs Attributable to Individual CV-SALTS Policies, Strategies,

and Guidance

As seen by the various policy/strategy/guidance-driven actions presented in Table 9 that will produce economic impacts, different elements of the policies, strategies, and guidance will require resources to implement short- and long-term actions. As described in the preceding sections, the costs of these local, sub-regional, and regional actions are planned to be supported by those entities that discharge concentrations of nitrate and/or salts in excess of standards that discharge to waters with little or no available assimilative capacity. All dischargers of salt and nitrate will be required to characterize their discharges and the impacts of those discharges on receiving waters as a means to assess compliance with the requirements of a given policy or strategy.

All of the policies, strategies, and guidance included in Table 9 require some level of discharge and ambient water quality characterization, whether performed by an individual discharger or by a group of dischargers within an approved management zone. As stated earlier, the proposed SNMP provides a framework and guidelines for dischargers to control their current loadings of salt and nitrate. Beyond the cost of some discharge and receiving water characterization studies that can be estimated, the proposed SNMP does not specify the salt and nitrate control methods or projects that individual dischargers or groups of dischargers will implement in the future to meet water quality objectives (WQOs) and satisfy the requirements of a given policy or strategy. To this end, the following sections focus on studies, and in some cases monitoring and surveillance programs, that will be required of the regulated community with adoption of the proposed SNMP. Costs were developed as “per study” costs where possible. Cost estimates were prepared based on a range of hours projected to complete a study, and assumed an average consultant billing rate of $200/hour.

Commented [A45]: Insufficient analysis is provided for non‐salt related SMCLs.



Groundwater Management Zone Policy

Policy Actions

The Groundwater Management Zone Policy recommends the Basin Plans be amended to include criteria for establishment and regulation of management zones for the purposes of groundwater quality management and control of nitrate. The Groundwater Management Zone Policy proposes that management zones would be a discrete regulatory compliance unit for the purposes of complying with WDRs for nitrate. Assimilative capacity within a management zone is determined on a volume-weighted average basis in the production zone of the delineated management zone boundary and within hydrologically connected areas. An option included in the policy is to limit determination of available assimilative capacity based on a volume- weighted average in the first encountered groundwater; this is consistent with current regulatory policy regarding groundwater.

Dischargers have the discretion to join a management zone or continue to be permitted as an individual (or group under general WDRs). A management zone can be larger than one groundwater basin/subbasin for administrative purposes, including providing drinking water within the area covered by the entire management zone. However, when developing implementation plans within a management zone, these plans should be developed only for areas that are hydrologically connected.

An option included in the policy is that management zones would not be available for evaluating compliance with WDRs; only as a means for collaborative groundwater basin monitoring, modeling, and other related assessment activities. Management zones would be required to have implementation plans that are consistent with the three overarching goals of the SNMP, with an option for achieving the third goal – restoration of nitrate levels to concentrations at or below the water quality objectives to the extent it is feasible and reasonable to do so – within 50 years. Outside of this option, the policy does not set a timeframe for achieving restoration of an aquifer. There also exists an option to allow management zones to be applied for the regulation and control of constituents in addition to nitrate; for example, arsenic.

The policy includes requirements to prepare multiple documents in a step-wise fashion that describe the proposed management zone, characterize the discharges to and water quality of the zone, describe the governance and funding structures to be implemented, describe the actions and water quality improvements to be taken to achieve the three overarching goals of the SNMP, and propose a monitoring and surveillance program to track water quality within the management zone. These regulatory compliance documents and associated technical studies include: Preliminary Management Zone Proposal, Initial Assessment, Notice of Intent, Final Management Zone Plan, Management Zone Implementation Plan, monitoring and surveillance program, antidegradation analysis (including estimation of available assimilative capacity), and additional technical studies, as necessary. A management zone also would be required to develop and implement an Early Action Plan, which outlines the approach to provide drinking water to communities with nitrate-impaired wells.



Economic Considerations

The management zone construct was designed to allow regulatory flexibility in areas where the interactions among land use, water quality and water users are complex and significant concerns exist with meeting the nitrate water quality objective established to protect the MUN beneficial use in groundwater. The collaborative nature of the management zone concept facilitates the pooling of resources among dischargers in an area to leverage actions for the improvement of water quality that otherwise would be outside the means of an individual discharger. Participation in a management zone supports distribution of resources toward meeting the three overarching goals of the SNMP, while allowing an appropriate timeframe for directing resources to improve local and sub-regional groundwater quality.

A cornerstone feature of a management zone as a discrete regulatory compliance unit is the determination of available assimilative capacity based on a volume-weighted average in the production zone. The use of the larger area encompassed by the production zone allows for greater dilution of a discharge and less stringent treatment and control as compared to assessing compliance with WQOs in first encountered groundwater. The policy option to regulate discharges based on available assimilative capacity in first encountered groundwater would act as a strong disincentive to the formation of management zones, and would result in implementation of additional treatment and control by some dischargers.

Similarly, the policy option to not allow management zones to be used for the purpose of evaluating compliance with WDRs would act as a disincentive to the formation of management zones, as non-acknowledgment of a management zone for compliance purposes would be no different than regulating an individual discharge at first encountered groundwater. Again, evaluating compliance at first encountered groundwater would result in implementation of additional treatment and control by some dischargers.

The requirement to implement Management Zone Plans that are consistent with the three overarching goals of the SNMP will have economic impacts on dischargers participating in a management zone. It should be noted that dischargers not participating in a management zone will have similar requirements to fund actions that are consistent with the three overarching goals. Methods and cost estimates for providing an adequate supply of safe drinking water to affected communities are presented in Section 6.3.1 (Short-Term Drinking Water Solutions) and Section 6.3.2 (Long-Term Drinking Water Solutions) of this report. Methods and cost estimates for providing long-term nitrate management to groundwater basins that exceed the Primary MCL of 10 mg/L for nitrate are presented in Section 6.3.3. The establishment of a 50-year time frame to achieve balance and restoration potentially could significantly increase the spending of discharger resources, but its ultimate effect on achieving balance and restoration of a groundwater basin is case-specific and indeterminate.

The process to establish and operate a management zone consistent with the three overarching goals of the SNMP requires the preparation of a number of documents (Preliminary Management Zone Proposal, Early Action Plan, Initial Assessment, Notice of Intent, Final Management Zone Plan, Management Zone Implementation Plan), associated technical studies (antidegradation



analysis including groundwater modeling to estimate available assimilative capacity), and development of a monitoring and surveillance program or commitment to participate in a regional groundwater monitoring program. Quantitative and qualitative cost assessments of the various Groundwater Management Zone Policy elements and their options are presented in Table 30.

Table 30: Estimated Costs to Meet Groundwater Management Zone Policy Requirements and Options.

Policy Task/Option

Estimated Cost

Notes

Source

Establishment of a

Management Zone

---

Costs to establish a

management zone are

case-specific, not

quantifiable at this time;

A management zone

leverages water quality

improvements that could

be made through the

pooling of resources

Preliminary Management

Zone Proposal, Early

Action Plan, Initial

Assessment, Notice of

Intent, Final Management

Zone Plan, Management

Zone Implementation Plan

$100,000 – $300,000

Initial studies and

submittals required to

inform management zone

formation decision

LWA

Simple or Complete

Antidegradation Analysis

$25,000 – $100,000

LWA

Groundwater Modeling for

Management Zone(1)

$300,000 – $800,000

LSCE

Surveillance and

Monitoring Program

---

Future monitoring costs to

dischargers – case-

specific, not quantifiable at

this time

Short-Term Drinking

Water Solutions

---

See Section 6.3.1

Long-Term Drinking

Water Solutions

---

See Section 6.3.2

Restoration of Aquifer to

Meet Nitrate Water

Quality Objectives (option)

---

See Section 6.3.3

Determination of available

assimilative capacity

---

Future treatment costs for

some dischargers – case-



Policy Task/Option

Estimated Cost

Notes

Source

based on a volume-

weighted average in the

first encountered

groundwater (option)


this time;

Disincentive to the

formation of management

zones

Management zone not

used to evaluate

compliance with WDR

(option)

---




this time;

Disincentive to the


zones

Establishment of a 50-

year timeframe for

achieving balance and

restoration for nitrate

(option)

---

Potentially significant

increase in spending of

discharger resources –

case-specific, not

quantifiable at this time –

see Section 6.3.3

See Appendix J for basis of estimated costs.

1. Costs exceeding the upper range could be incurred if significant hydrological analyses are required for an area

lacking any such previous analyses.

Nitrate Permitting Strategy

Strategy Actions

The Nitrate Permitting Strategy proposes to amend the Basin Plan to establish two pathways, Path A and Path B, for compliance with nitrate groundwater quality objectives. Path A is for dischargers that choose to be permitted individually, and Path B is for dischargers that choose to be permitted within a management zone. A discharger selecting Path A will be required to determine which of five categories most accurately describes its discharge: 1) no degradation; 2) de minimis; 3) degradation below 75 percent of the water quality objective; 4) degradation above 75 percent of the water quality objective, or receiving water quality is 50 percent of the objective and the discharge is causing an annual increase in nitrate greater than 0.1 mg/L as N using cumulative average; and 5) discharge above objective and no available assimilative capacity. Categories 3 and 4 include trigger language regarding trending of water quality upwards toward water quality objective. A discharger in either Category 3 or Category 4 that determines the 0.1 mg/L nitrate trend has been exceeded (based on an annual increase using cumulative average annual increases over a five-year period) would be required to submit an alternative compliance plan (ACP) in order to be granted assimilative capacity for the discharge.

The need for development of an ACP is prompted when an individual or group of dischargers is unable to demonstrate that their discharge is not causing or contributing to nitrate degradation



above the triggers identified in the Central Valley SNMP. The alternative compliance pathway likely would include participation in projects to deliver drinking water to communities with nitrate-impaired wells and to participate in projects to improve ambient groundwater quality in the long-term.

An initial assessment is required to characterize a discharger’s loading and impact of their loading on nitrate water quality in the immediate area of the discharge. As part of the Notice of Intent for an individual discharger under Path A that falls within categories 3, 4, or 5, the individual discharger would need to conduct an initial assessment to determine if the discharge (or collective discharges if under a General Order) is impacting any nearby public water supply or domestic wells for nitrate. Dischargers determined to be impacting wells used for potable supply would need to prepare an Early Action Plan to outline the approach that will be used to provide drinking water to communities with nitrate-impaired wells.

When the Regional Water Board allocates assimilative capacity, a simple antidegradation analysis must be prepared for category 1 and 2 discharges, and a complete antidegradation analysis (including socioeconomic considerations) prepared for the other categories. Allocation of assimilative capacity to individual dischargers is determined at First Encountered Usable Groundwater. Dischargers within a management zone will receive an allocation of assimilative capacity which is determined based on the water quality in the production zone. When allocating assimilative capacity to an individual discharger and the individual discharger is within a management zone, the Central Valley Water Board will need to consider impact to available assimilative capacity in the management zone.

Dischargers selecting Path B and choosing to work collaboratively within a management zone must follow the requirements set forth in the Groundwater Management Zone Policy described in the previous section. In addition to the tasks performed by a discharger following Path A, dischargers participating in a management zone would need to develop a Preliminary Management Zone Proposal, Final Management Zone Plan, Management Zone Implementation Plan, and monitoring and surveillance program.

Several options to the Nitrate Permitting Strategy are described in Section 5.1. Only those options that will have an economic impact on dischargers are included below and discussed under Economic Considerations.

1. Compliance with SNMP to be determined on a permit-by-permit basis. Management

zone compliance with SNMP would not be an option.

2. All dischargers should be required to characterize their loading and impact of their loading on nitrate water quality in the immediate area of the discharge. This characterization would need to be conducted are part of a permit renewal application, or be ordered via section 13267 of the Water Code. In priorities areas and upon notice by the Central Valley Water Board, individual should provide this information to the Central Valley Water Board within 90 days. The Executive Officer shall have the discretion to



extend the 90 days on a case-by-case basis due to special circumstances, but in no event should the extension be for more than an additional 90 days.

3. As part of the permit, dischargers shall then be required to assess their loading impact on

the subbasin area (as defined by DWR Bulletin 118). Dischargers will have the option to characterize loading and impact on the subbasin through individual efforts or as part of a cooperative-type program.

4. Based on the results of the individual characterization of loading as described in

paragraph 2 above, permittees would then need to determine their compliance pathway (i.e., use of assimilative capacity in shallow groundwater or through granting of an exception).

5. Assimilative capacity could only be granted if the discharge (or collective discharges if

the permit covered more than one permittee) would not cause or contribute shallow groundwater in a reasonably defined area to exceed 7.5 mg/L of N. Reasonably defined area means a local area and not on a subbasin basis. Any discharger receiving an allocation of assimilative capacity would need to participate in local, regional and/or statewide efforts that ensure safe drinking water where nitrate contamination is of issue for the area in question.

6. If assimilative capacity was not available under the terms specified above in paragraph 5,

the permittee(s) would need to apply for an exception, and granting of an exception would be subject to the conditions in the exception option as set forth by the additional conditions within the Exceptions Policy options. In particular, any permittee(s) receiving an exception would need to be part of local, regional and/or statewide efforts that ensure safe drinking water where nitrate contamination is of issue for the area in question.


The Nitrate Permitting Strategy was developed to apply current traditional and conservative permitting approaches to individual dischargers not participating in a management zone. As a means to assure that individual dischargers are implementing treatment and control of their discharges consistent with the requirements of the SNMP and its three overarching goals, a detailed compliance pathway (Path A) was developed. Categorization of the impacts of individual discharges on nitrate concentrations in groundwater is required to determine which discharges represent de minimis to no impact and which ones threaten to or currently impact the receiving water. Discharges determined to be in Categories 3, 4, and 5 will require dischargers to implement successive levels of treatment or control of their discharges and/or apply for an exception where treatment and control is not reasonable, feasible or practicable to bring the discharge into compliance with the 10 mg/L (as N) objective for nitrate. These dischargers will also be required to prepare various regulatory documents (Early Action Plan, Initial Assessment, and Notice of Intent) and conduct technical studies (antidegradation analysis) and monitoring.

Additionally, these dischargers will be required to participate in actions that mitigate the impacts of their nitrate discharges, including short-term and long-term drinking water solutions and long-



term nitrate management. The net effect of all the requirement of the Nitrate Permitting Strategy on these dischargers will be to increase the cost of compliance with their future WDRs or Conditional Waivers. The number of dischargers that decide not to participate in a management zone cannot be quantified because information supporting such an inquiry has not been developed by CV-SALTS and is not otherwise available. Furthermore, the cost of compliance for individual dischargers selecting Path A also cannot be quantified because these costs will be case-specific (highly dependent on the Category to which a discharge is assigned) and information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available.

The groundwater management zone pathway (Path B) available to those dischargers that elect to work collaboratively was designed to allow multiple discharges in a defined area to be consistent with the requirements of the SNMP and its three overarching goals, while allowing regulatory flexibility in areas where the interactions among land use, water quality and water users are complex and significant concerns exist with meeting the nitrate water quality objective established to protect the MUN beneficial use in groundwater. As stated earlier, the collaborative nature of a management zone facilitates the pooling of resources among dischargers in an area to leverage actions for the improvement of water quality that otherwise would be outside the means of an individual discharger. The regulatory documents (Preliminary Management Zone Proposal, Early Action Plan, Initial Assessment, Notice of Intent, Final Management Zone Plan, Management Zone Implementation Plan), technical studies (antidegradation analysis), and monitoring and surveillance program that must be developed to establish a management zone, along with participation in short-term and long-term drinking water solutions and long-term nitrate management, will increase the cost of compliance for these dischargers in future WDRs or Conditional Waivers. However, the ability to share the costs of regulatory documents, studies, and monitoring has the potential to result in a less financially burdensome outcome for a discharger as compared to Path A. Again, because these increased costs of compliance will be unique to a given future management zone, costs cannot be quantified at this time.

All six optional actions listed above would increase the economic burden of dischargers for compliance with the requirements of the Nitrate Permitting Strategy. The strategy option (1) to not allow management zones to be used for the purpose of evaluating compliance with the SNMP would act as a disincentive to the formation of management zones, as non- acknowledgment of a management zone for compliance purposes would be no different than regulating an individual discharge at first encountered usable groundwater. Again, evaluating compliance at first encountered usable groundwater would result in implementation of additional treatment and control by some dischargers. Strategy option (2) would require all dischargers within a management zone to characterize the impacts of their own discharges with respect to nitrate and would prevent dischargers from sharing the cost to determine their collective nitrate impacts on groundwater within the management zone. To this end, per discharger compliance costs would be increased.

The option (3) to require dischargers to assess their loading impact on the subbasin area (as defined by DWR Bulletin 118) will require additional groundwater modeling of each discharge



and result in increases to each dischargers overall compliance cost. Dischargers within a management would have the ability to share the cost of subbasin groundwater modeling. Strategy option (4) requires a discharger to use water quality impacts information developed under option (2) to select a compliance pathway (Path A or Path B) considering only assimilative capacity available in the shallow groundwater (considered to be comparable to first encountered usable groundwater) or through the granting of an exception. This option prevents the use of assimilative capacity that may be available in the production zone and hence, nullifies the management zone as a discrete regulatory compliance unit for the purposes of complying with WDRs for nitrate. This option would result in the need to implement additional treatment and control by some dischargers, thereby increasing compliance costs.

Strategy option (5) proposes to limit the granting of assimilative capacity in shallow groundwater to only those dischargers that can demonstrate that their discharges do not cause ambient nitrate concentrations in a reasonably defined area (smaller than a subbasin) of shallow groundwater to exceed 7.5 mg/L (as N). Additionally, any discharger receiving an allocation of assimilative capacity would need to participate in local, regional and/or statewide efforts that ensure safe drinking water where nitrate contamination is of issue for the area in question. The use of a 7.5 mg/L (as N) cap on ambient nitrate concentrations for all dischargers to reasonably defined area to determine if assimilative capacity can be granted acts as an ad hoc water quality objective for which no supporting analysis has been performed. Additionally, the limiting of impacts only to shallow groundwater under this option again negates the use of a management zone as a compliance unit. Adoption of this option would result in the need to implement additional treatment and control by some dischargers, thereby increasing compliance costs.

Under option (6), those dischargers not granted assimilative capacity under option (5) would be required to apply for an exception. The setting of a 7.5 mg/L (as N) cap on ambient nitrate concentrations will result in either additional treatment or control of some discharges or more applications for exceptions, as compared to what would occur under use of the Primary MCL of 10 mg/L for nitrate to determine available assimilative capacity. The economic impacts associated with applying for and receiving an exception for nitrate discharges to groundwater are discussed in the Exceptions Policy Revision section.

Quantitative and qualitative cost assessments of the various Nitrate Permitting Strategy elements and their options are presented in Table 31.

Table 31: Estimated Costs to Meet Nitrate Permitting Strategy Requirements and Options

Strategy Task/Option

Estimated Cost

Notes

Source

Establishment of a

Management Zone

---

Costs to establish a

management zone are

case-specific, not


A management zone

leverages water quality

improvements that could




Estimated Cost

Notes

Source

be made through the

pooling of resources

Preliminary Management

Zone Proposal, Early

Action Plan, Initial

Assessment, Notice of

Intent, Final Management

Zone Plan, SNMP

Implementation Plan

$100,000 – $300,000

Initial studies and

submittals required to

inform management zone

formation decision;

Range of costs considered

to cover both Path A and

Path B dischargers.

LWA

Simple Antidegradation

Analysis (Categories 1

and 2)

$25,000 – $50,000

LWA

Complete Antidegradation

Analysis (Categories 3, 4

and 5)

$50,000 – $100,000

LWA


Individual Discharger

---

Case specific – may

approximate cost required

for management zone

LSCE


Management Zone(1)

$300,000 – $800,000

LSCE

Monitoring and Trend

Analysis

---

Future monitoring costs to

dischargers -- case-


this time

Short-Term Drinking

Water Solutions

---

See Section 6.3.1

Long-Term Drinking

Water Solutions

---

See Section 6.3.2


Meet Nitrate Water


---

See Section 6.3.3

Determination of available

assimilative capacity

based on a volume-

weighted average in the

first encountered

groundwater (option)

---




this time;

Disincentive to the


zones




Estimated Cost

Notes

Source

Management zone not

used to evaluate

compliance with WDR

(option)

---




this time;

Disincentive to the


zones


year timeframe for


restoration for nitrate

(option)

---




case-specific, not


see Section 6.3.3





Strategy Actions

The Salinity Management Strategy involves a phased approach of study and implementation to control salt accumulation in the Central Valley. Phase I consists of developing a Salinity Prioritization and Optimization Study (P&O Study) to further define the conceptual design of SSALTS into a feasibility study that identifies appropriate regional and sub-regional projects, including location, routing and implementation/operation of specific projects. Once the P&O Study is completed, Phase II of the Salinity Management Plan will be implemented. Phase II will generally consist of environmental permitting, obtaining funding, and engineering and design, which is anticipated to take approximately 10 years. Phase III would consist of actual construction of the physical projects identified in the P&O Study, in particular a regulated brine line.

While the P&O Study is being implemented (10 – 15 years), CV-SALTS recommends that the Basin Plans be amended to include an interim salinity permitting approach for discharges of salinity. This approach allows the Central Valley Water Board to manage degradation while the long-term salinity efforts are being implemented. Because this approach is intended to be interim in nature, CV-SALTS recommends that the interim permitting approach be set in place for 15 years to allow for implementation of Phase I of the Salinity Management Strategy.

To implement the Interim Salinity Permitting approach in WDRs/conditional waivers, the Central Valley Water Board will need to revise existing WDRs/conditional waivers and NPDES Permits. CV-SALTS recommends that the Central Valley Water Board, in cooperation with stakeholders, develop a series of resolutions/orders that amend applicable WDRs/conditional



waivers. In general, the resolutions/orders would require dischargers to continue current reasonable, feasible and practicable efforts to implement salinity management practices and/or source control efforts, including implementation of any pollution prevention plans, watershed plans, and/or salt reduction plans. Monitoring for salinity in surface and groundwater would also continue as part of applicable monitoring programs, or through regional monitoring programs as appropriate, such as the CV-SALTS Surveillance and Monitoring Program (SAMP).

Discharge levels of salinity would need to remain fairly consistent with current levels, accounting for conservation and some appropriate increment of growth. Most importantly, discharges being permitted under this interim approach would be required to participate in efforts related to the P&O Study, and subsequent Phases II and III as applicable. The level of participation would vary based on salinity in the discharge as well as local conditions, and the needed level of participation would be established by the lead entity that is overseeing the P&O Study. The resolutions/orders would establish the time-frame for application of the interim permitting approach, which could not exceed 15 years in length. For NPDES dischargers, CV- SALTS recommends that the Central Valley Water Board consider approval of a salinity variance per the Salinity Variance Policy, which would include a requirement to participate in the P&O Study.

The resolutions/orders would need to include provisions that allow dischargers the discretion to opt out of participation in efforts to prepare the P&O Study. Dischargers wishing to opt out would be permitted under the following current traditional and conservative permitting approaches:

For groundwater dischargers wishing to opt out, a reasonable potential analysis (RPA) would need to be performed that showed the discharge does not cause or contribute to exceedances of groundwater limitations for salinity constituents in first encountered groundwater, with the most restrictive criteria for protection of AGR and MUN beneficial uses considered in the analysis. Further, no new allocation (or expansion of an allocation) of assimilative capacity could be granted to a groundwater discharger wishing to opt out.

For non-NPDES surface water dischargers wishing to opt out, the same principles would apply as those describe above.

For NPDES surface water dischargers wishing to opt out, the same principles would apply as those for non-NPDES surface water dischargers. In addition, salinity variances and long-term compliance schedules would not be an available option for those seeking to opt out of the P&O Study.


The Salinity Management Strategy supports the focusing of resources toward meeting the long- term salinity management goals of the SNMP, while maintaining the discharge of salts more or less consistent with allowances for water conservation and growth over a period not to exceed 15 years. The series of resolutions/orders required under the policy would be drafted within one (1)



year of the Basin Plan amendments becoming effective, and used to revise existing WDRs/conditional waivers and NPDES Permits. Until such resolutions/orders are drafted and adopted, it is unknown what additional levels of treatment or control will be required of dischargers of salinity to achieve managed degradation of salts in the Central Valley. Future increased costs would be discharger-specific, and cannot be quantified at this time. Additionally, until a lead entity is identified to carry out the P&O Study and determines the level of participation of dischargers, the individual costs to dischargers of participating in the study is unknown. The estimated annual cost of implementation of the Salinity P&O Study ranges from $700K to $1.3M for a period of 10 years (CDM Smith, 2016b).

For those dischargers that opt out of participating in the P&O Study, the Salinity Management Strategy proposes to regulate their discharges following current traditional and conservative permitting approaches. Additionally, surface water dischargers possessing a NPDES permit that opt out will not be granted a salinity variance for meeting salinity water quality objectives in their discharge. The net effect for a discharger that declines to participate in the P&O Study will be a requirement to implement additional treatment or control of its discharge. Because such future, additional treatment requirements for these dischargers will be case-specific, costs cannot be quantified at this time. Qualitative cost assessments of the various Salinity Management Strategy elements and are presented in Table 32.

Table 32: Estimated Costs to Meet Salinity Management Strategy Requirements.

Strategy Element

Estimated Cost

Notes

Source

Resolutions/Orders

Adopting Interim Salinity

Permitting Approach

---




this time

Participation in the

Phase I Salinity

Management Strategy

Prioritization and

Optimization Study

---

Participation requirements

and costs not yet

developed by lead entity

overseeing P&O Study;

Participation based on

salinity in discharge and

local conditions;

P&O Study cost estimated

at $700K – $1.3M per year

(CDM Smith, 2016b)

Regulation of Salinity

Discharges Following

Current Traditional and

Conservative Permitting

Approaches

---




this time



Exceptions Policy Revision

Policy Actions

The Exceptions Policy recommends modifications to the existing Salinity Exception Program in the Basin Plans, which authorizes the Central Valley Water Board to grant exceptions for salinity constituents in non-NPDES program WDRs where it concludes that it is infeasible, impracticable or unreasonable to prohibit an otherwise non-compliant discharge to groundwater. All proposed revisions to the existing Exceptions Policy are described in Section 5.1. The proposed modifications to the existing policy that likely will produce economic impacts to a discharger applying for an exception are summarized below.

a) The existing Salinity Exception Program limits term of an exception to 10 years. The

exception has a 5-year check-in requirement (the Central Valley Water Board can rescind exception if requirements are not met) and can be reauthorized at the end of the exception. The proposed policy recommends:

i. No 10-year limit on an exception term; instead the Board has the discretion to

decide actual term.

ii. 5-yr check-ins are still required regardless of length of approved exception and Board can still intervene to terminate an exception at check-ins if conditions not met.

As a condition for reauthorizing/renewing an exception, dischargers will be required to periodically reassess Best Management Practices (BMPs) and survey available treatment technologies to determine if feasible, practicable and reasonable compliance options have become available.

Option: Retain existing 10-year limit for exception term; exceptions can be renewed at 10-year intervals with no end date.

b) Add a new provision requiring dischargers to assure an adequate supply of safe, reliable

and affordable drinking water, as a condition of authorizing an exception for nitrate in those areas of the groundwater basin or subbasin adversely affected by the non-compliant discharge (or discharges). The assurance must consist of a plan for providing safe drinking water, which may include plans developed by either the discharger or others in the community as well.

Option: Also add in the following new conditions for obtaining an exception:



“Best Efforts” are to be provided39. Participation in a program that restores the aquifer to meet water quality

objectives.

Option: In addition to the above, the following specific performance measures would be a condition for obtaining and renewing exceptions.

For obtaining an initial exception:

Long-term management plans show improved water quality trends over a 10 and 20 year horizon.

Long-term management plans show salt/nitrate balance (inputs equal removals) and restoration (attain water quality standards in the groundwater) of an aquifer to meet water quality objectives in as short a time as practicable, but not to exceed 50 years.

For obtaining renewal of exceptions:

Demonstration that short-term drinking water solutions were effectively implemented.

Demonstration that mitigation fund / alternative drinking water projects have been effective and identification of additional actions, if needed.

Demonstration that aquifer restoration / mitigation projects have been effective and identification of additional actions, if needed.

Long-term management plans show improved water quality trends over: 1) a 10 and 20 year horizon at first and second renewal; 2) a 20 year horizon at third and fourth renewals.

Long-term management plans show salt/nitrate balance and restoration of aquifer to meet water quality objectives in as short a time as practicable, but not to exceed: 1) 40 years at first renewal, 2) 30 years at second renewal, 3) 20 years at third renewal, and 4) 10 years at fourth renewal.

c) Retain the following justification within the Salinity Exception Program under a list of

conditions where the Board may conclude that it is infeasible, impracticable, or unreasonable to prohibit a non-compliant discharge: “Situations where compelling the discharge to comply with the applicable WDR (and assuming it was possible to do so) would not significantly improve water quality or assure attainment of the related standards in the foreseeable future (≈20 years).”

39 The “best efforts” approach involves the Central Valley Water Board establishing limitations expected to be achieved using reasonable control measures. Factors which should be analyzed under the “best efforts” approach include the effluent quality achieved by other similarly situated dischargers, the good faith efforts of the discharger to limit the discharge of the constituent, and the measures necessary to achieve compliance. SWRCB Order WQ 81- 5, at p. 7. The State Water Board has applied the “best efforts” factors in interpreting BPTC. (See SWRCB Order Nos. WQ 79-14, and WQ 2000-07).



Option: Delete this justification from the Salinity Exception Program.

d) The proposed Exceptions Policy is silent with respect to timeframes for achieving salt and nitrate balance, and restoration of aquifers (i.e., goals 2 and 3 of SNMP).

Option: Establish a 50-year timeframe for achieving balance and restoration for both salt and nitrate. “Restoration” for nitrate is defined by either: 1) 50% of MCL; 2) 75% of MCL; or 3) 100% of MCL.

e) Exceptions may be granted to management zones.

Option: Exceptions may only be applied on a permit-by-permit basis.


When a discharger applies for an exception to meet a WQO for a constituent of salinity (EC, TDS, chloride, sulfate, and sodium) under the existing Salinity Exception Program, the discharger must document current and anticipated future compliance issues for salinity, summarize source control efforts, and characterize water quality impacts by conducting an antidegradation analysis that assesses the effects of an exception on the local groundwater basin. Assessing the impacts of the discharge on the local groundwater basin, or at larger scales (i.e., DWR basin scale), requires modeling of the discharge-groundwater interactions. The level of effort and therefore, cost to model a given discharge is discharge-specific, and can only be estimated in terms of a broad range. Including nitrate and boron as constituents for which an exception could be granted, as included in the proposed policy, would not significantly change the costs of the technical studies/modeling described above as they pertain to a discharger requesting an exception for a single constituent. Requesting an exception for multiple constituents would necessarily increase the total costs of all studies.

In addition to the studies mentioned above, the proposed modifications to the existing Salinity Exception Program will result in additional economic impacts to those dischargers that seek a renewal of an exception. While the proposed policy does not discuss all requirements that must be met to obtain a renewed exception, a renewal would require the discharger to at least document existing BMPs implemented to reduce pollutant loadings and determine if feasible, practicable and reasonable compliance options have become available. Currently, exceptions are limited to 10 years. Any exception renewal costs would be offset by avoided costs for additional treatment or other control measures that were not incurred by the discharger as a result of being granted the initial and renewed exception.

The more significant economic impacts that will be incurred by those dischargers that are granted an exception for nitrate discharges to groundwater will result from the requirement to assure an adequate supply of safe, reliable and affordable drinking water to those affected by nitrate contamination in the basin or subbasin in which the discharge occurs. Methods and cost estimates for providing an adequate supply of safe drinking water to affected communities are presented in Section 6.3.1 (Short-Term Drinking Water Solutions) and Section 6.3.2 (Long- Term Drinking Water Solutions) of this report.



The proposed policy includes options related to nitrate discharges and their impacts on drinking water. One option is the requirement for a discharger to implement “best efforts” as determined by the Regional Water Board which will be considered when establishing effluent limitations for the discharge. Depending on the difference between a discharger’s current practices and what the Board defines as “best efforts”, a discharger could be required to implement additional treatment or control of its discharge. A requirement to implement additional treatment or control of a discharge would be case-specific and the cost of such implementation cannot be determined at this time.

Another option included in the policy is a requirement for a discharger to participate in a program that restores the aquifer to meet or exceed water quality objectives. Methods and cost estimates for providing long-term nitrate management to groundwater basins that equal or exceed the Primary MCL of 10 mg/L for nitrate are presented in Section 6.3.3.

Optional requirements for obtaining an initial exception include development of long-term management plans that (1) show improved water quality trends over a 10 and 20 year horizon, and (2) show salt/nitrate balance and restoration of an aquifer to meet water quality objectives in as short a time as practicable, but not to exceed 50 years. There also exists an optional requirement for renewal of an exception that requires demonstration that short-term drinking water solutions have been achieved, long-term drinking water solutions have been implemented and made progress, and under the initial and subsequent exceptions water quality has improved. These optional requirements will require additional studies and report preparation at an increased cost to the discharger.

Finally, options to the proposed policy exist to (1) prevent the Board from concluding that it is infeasible, impracticable, or unreasonable to prohibit a non-compliant discharge; (2) establish a 50-year timeframe for achieving balance and restoration for both salt and nitrate; and (3) not allow an exception for an approved management zone; exceptions would only be granted on a permit-by-permit basis; however, groundwater basin monitoring, modeling, and other related assessment activities could be undertaken on a collaborative basis. The first option specified would require that a non-compliant discharge undergo additional treatment or control at unknown cost to the discharger. Establishment of a 50-year time frame to achieve balance and restoration could accelerate the spending of resources, but its ultimate effect on achieving balance and restoration of a groundwater basin is case-specific and would depend on the magnitude of expenditure, as shown in Section 6.3.3. Not allowing a management zone to be granted an exception would require any discharger within the management zone that wanted an exception to individually bear the cost of an exception request, rather than allowing the cost to be shared among multiple dischargers. This option would likely increase the cost of participating in a management zone due to duplication of effort. Quantitative and qualitative cost assessments of the various Exceptions Policy Revision elements and their options are presented in Table 33.



Table 33: Estimated Costs to Meet Exceptions Policy Revision Requirements and Options.

Policy Task/Option

Estimated Cost

Notes

Source

Exceptions Analysis and

Application (not including

groundwater modeling)

$50,000 – $100,000

Costs for a management

zone exception – individual

discharger costs are case-

specific, but may approach

management zone cost

LWA


Management Zone(1)

$300,000 – $800,000

Costs for a management

zone exception – individual

discharger costs are case-

specific, but may approach

management zone cost

LSCE

Exceptions Renewal

Application

---

Precise requirements of

exceptions renewal not

developed by CV-SALTS.

Renewal expected to cost

less than initial exceptions

request

Short-Term Drinking

Water Solutions

---

See Section 6.3.1

Long-Term Drinking

Water Solutions

---

See Section 6.3.2

Implementation of “Best

Efforts” (option)

---

Potential increase in future

treatment costs for some



this time


Meet Nitrate Water


---

See Section 6.3.3

Development of

Management Plans to

Address Short-Term (10 –

20 years) and Long-Term

(20 – 50 years) Water

Quality (option)

$35,000 – $60,000

LWA

Exceptions Renewal –

Demonstration of Initial

Exceptions Milestone

Achieved and

$20,000 – $30,000

LWA



Policy Task/Option

Estimated Cost

Notes

Source

Improvement in Water

Quality (option)

Prevent the Board from

concluding that it is

infeasible, impracticable,

or unreasonable to

prohibit a non-compliant

discharge (option)

---

Potential increase in future

treatment costs for some



this time


year timeframe for


restoration for both salt

and nitrate

---




case-specific, not


see Section 6.3.3

Exceptions Not Applicable

to Management Zones

(option)

---

Reduced cost-sharing

available to dischargers;

Increased discharger costs,

not quantifiable at this time




AGR Policy

Policy Actions

The AGR Policy includes a default approach to assign one of four AGR threshold classes to groundwater basins or subbasins based on existing TDS concentrations and EC levels for purposes of interpreting the narrative Chemical Constituents objective for groundwater. The establishment of AGR classes is intended to provide a default basis for translating the existing narrative water quality objective to support management of salt through WDRs/Conditional Waivers. The policy also recommends to defer such an assignment of AGR classes to groundwater basins and subbasins to provided opportunity to consider the findings from implementation of the Phase I of the Salinity Management Strategy. However, if AGR classes are assigned in the future, TDS concentrations (and EC levels) within the basin/subbasin would be managed within the range established for that class (see Section 5.1.8 for additional detail). The assignment of a groundwater basin or subbasin to an AGR class is based on the volume- weighted average of TDS concentrations in the production zone. When issuing WDRs/Conditional Waivers, localized areas with TDS concentrations higher or lower than the thresholds of the class assigned to the basin will be managed through application of the State Antidegradation Policy and requirements of the SNMP.



The AGR Policy also allows for the development of site-specific objectives (SSOs) for TDS and EC for protection of the AGR beneficial use in groundwater. A site-specific objective (SSO) would be based on an assessment of the crops grown in a particular area that rely on the local groundwater aquifer to which a discharge is occurring. A soil water salinity model, such as the steady-state Hoffman Model, may be used to determine the level of groundwater salinity that would be protective of the most salt-sensitive, commercially important crop grown in the area, taking into account modeling parameters such as precipitation, leaching fraction, crop yield protection, and drought considerations.


With assignment of AGR classes to groundwater basins and subbasins there may be a need for specific agricultural operations to reduce their loadings of salts to groundwater that will result in additional costs to dischargers to implement new or enhanced salinity management plans and/or salinity control measures. Because future, necessary salinity reductions and methods to achieve them for a specific discharge are unknown at this time, it is not possible to estimate costs that a discharger will incur due to assignment of AGR classes to groundwater basins or subbasins under the AGR policy. Information supporting such an analysis has not been developed by CV- SALTS and is not otherwise available.

The estimated cost to meet the AGR Policy requirements when developing a site-specific objective is presented in Table 34. Such an effort would require a beneficial use evaluation, crop sensitivity analysis, soil salinity modeling, development of the site-specific objective, and meetings/communications between the project proponent(s) and Regional Water Board staff. The establishment of a site-specific objective for groundwater salinity could result in the need for area dischargers to implement additional salinity control measures. However, the cost to provide necessary salinity reductions under some future discharge scenario cannot be estimated because information supporting such an analysis would be site-specific, has not been developed by CV- SALTS, and is not otherwise available.

Table 34: Estimated Costs to Meet AGR Policy Requirements for Development of a Site-Specific Objective.

Task

Estimated Cost

Notes

Source

Compliance with AGR

Class

---




this time

Development of SSO $75,000 – $125,000(1) LWA


(1) Cost per study; findings may or may not be applicable to more than one discharge.



Salinity Variance Program Revision

Policy Revision Actions

The Salinity Variance Program Revision proposes modifications to the existing Salinity Variance Program for discharges to surface waters to align it with elements of the SNMP and Salinity Management Strategy. The Salinity Variance Program Revision recommends that the current Salinity Variance Program be amended to:

1) Extend the provision prohibiting the Central Valley Water Board from authorizing

new salinity variances or reauthorizing previously approved salinity variances from June 30, 2019, to 15 years from the effective date of Basin Plan amendments that revise the Salinity Variance Program.

2) Extend application of the Salinity Variance Program to water quality-based effluent

limitations for salinity water quality standards that are related to the MUN beneficial use, and not just the AGR beneficial use.

3) Revise the current Salinity Variance Program to require participation in the Phase I

Salinity Management Strategy P&O Study. The requirement to participate in CV- SALTS may also be appropriate, depending on if CV-SALTS is still intact for this purpose.

4) Make clear that salinity variances are intended to facilitate implementation of the

phased Salinity Management Strategy, and that salinity variances are not available to individuals/permittees that wish to opt out of participating in implementation of Phase I of the Salinity Management Strategy.

Authorization for salinity variances may be granted by the Central Valley Water Board for individual dischargers or for multiple dischargers under a watershed based NPDES permit for salinity discharges. Terms and conditions associated with the granting of a salinity variance would be incorporated into relevant NPDES permits, and failure to comply with such terms and conditions may result in the termination of the variance and/or an enforcement action.


The proposed amendments to the existing Salinity Variance Program described above would have some economic impacts to a surface water discharger seeking a temporary variance to a salinity objective. Beyond the baseline costs of the studies necessary to apply for a variance, dischargers would be required to participate in the Phase 1 Salinity Management Strategy P&O Study. Participation in the study would require funds from the discharger to support the study. The estimated range in total costs for the 10-year P&O Study is $7 – $13M (CDM Smith, 2016b). CV-SALTS has yet to develop a funding allocation schedule for the study that indicates required contributions from dischargers. To this end, the cost of participating in the study represents an indeterminate case-specific future cost.



Individual dischargers that do not participate in the implementation of Phase I of the Salinity Management Strategy will not be granted a salinity variance. Dischargers that opt out would be required to implement other strategies for meeting salinity objectives, including additional treatment or control, alternate source water supply, and/or other actions that would bring a discharge into compliance with salinity objectives. The number of dischargers that decide not to participate in the Phase I Salinity Management Strategy P&O Study and thus, need to implement additional treatment or control of their discharges cannot be quantified because information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available. Therefore, compliance costs for individuals not eligible to be granted a salinity variance cannot be estimated.

To apply for a salinity variance a discharger must document current and anticipated future compliance issues for salinity, summarize source control efforts, and characterize water quality impacts by conducting a ‘complete’ antidegradation analysis that assesses the effects of a variance on the receiving water. A complete antidegradation analysis (which includes a socioeconomic analysis) is required because to gain approval for a water quality standards variance for a discharge to surface waters, USEPA guidance states that a showing should be made that the variance is consistent with 40 CFR 131.10(g). One of six factors included in Section 131.10(g) that must be considered is substantial and widespread economic and social impact resulting from the cost of implementing additional treatment.

The contents of a variance application is described in detail in the policy document (Revision of the Salinity Variance Program, Final Draft September 12, 2016). The applicant of a salinity variance is also required to develop a Salinity Reduction Work Plan, and a detailed plan of how the applicant will continue to participate in CV-SALTS and how the applicant will contribute to the development and implementation of the SNMPs. The estimated costs to meet the Salinity Variance Policy requirements for surface water dischargers are presented in Table 35. It should be noted that the requirements and their associated costs for applying for a salinity variance under the proposed revisions to the Salinity Variance Program are the same as the costs that would be incurred by a discharger under the existing program.



Table 35: Estimated Costs to Meet Salinity Variance Program Revision Requirements for Surface Water Dischargers.

Task/Project

Estimated Cost

Notes

Source

Discharge-Specific

Salinity Variance Analysis

and Application

$50,000 – $100,000

LWA

Participation in the

Phase I Salinity

Management Strategy

Prioritization and

Optimization Study

---

Participation requirements

and costs not yet

developed by lead entity

overseeing P&O Study;

Participation based on

salinity in discharge and

local conditions;

P&O Study cost estimated

at $700K – $1.3M per year

(CDM Smith, 2016b)


Offsets Policy

Policy Actions

The Offsets Policy proposes to allow the use of offsets for discharges to groundwater. Offsets would provide an indirect approach to partial or complete compliance with a WDR/Conditional Waiver requirement for a given pollutant by managing other sources and loads so that the net effect on receiving water quality from all known sources is functionally-equivalent to or better than that which would have occurred through direct compliance with the WDR at the point-of- discharge. Regional Board authorization to allow the use of offsets would provide the following:

A mechanism to re-target the resources required to achieve compliance in order to produce greater public benefits (e.g., better net water quality, earlier improvements, lower cost, less risk).

A mechanism whereby diverse dischargers within the same management zone could pool available resources to implement alternative compliance projects, in phases, on a risk- priority basis.

A mechanism to develop and fund large-scale, long-term regional water quality improvement projects, e.g., as described by SSALTS or NIMS, by recognizing participation in such efforts as partial credit toward compliance.

Market-based incentive to establish “Mitigation Banks” designed to develop and implement water quality improvement projects, which are useful for pooling resources of relatively small dischargers into a critical funding mass to support projects that would normally be beyond their individual means.



An offset allows for the management of other sources and loads (not directly associated with the regulated discharge) so that the combined net effect on receiving water quality from the discharge and the offset is functionally-equivalent to (and potentially better) than that which would have occurred by requiring the discharger to comply with its WDR at the point-of- discharge. In this regard, an offset project must be located within the same groundwater basin/subbasin or management zone as the regulated discharge. However, the Offsets Policy is also intended to incentivize implementation of some large-scale projects such as a regional regulated brine line or a mitigation bank established to provide safe drinking water. Key aspects of the Offsets Policy as they relate to potential economic impacts include:

The offset project must include a monitoring and reporting program sufficient to verify that the pollution reduction credits are actually being generated as projected and that these credits are adequate to offset the discharge loads in the ratio approved by the Central Valley Water Board. Pollutant removal, reduction, neutralization, transformation and dilution may all be acceptable means of generating offset credits (subject to appropriate verification).

In addition to the proposed policy, there are two options for how offsets can be used and the water quality to be attained:

Option 1: (a) Offsets could be used across groundwater subbasins and basins, and management zones; and (b) offset projects do not require attainment of water quality objectives in the underlying water, only progress toward attainment.

Option 2: (a) Allow use of offsets only in the specific area to which a discharge impacts; and (b) limit definition of an offset to only projects that result in water quality objectives being attained.


CV-SALTS intends to develop regional guidance in the future that describes how offset credits are to be applied to surface water and groundwater discharges that would enable a discharger to track its compliance with WQOs. Until such guidance is developed for dischargers, increased costs to dischargers are unquantifiable. However, it should be noted that some level of increased costs to dischargers would be incurred through additional monitoring, data analysis, evaluation of assimilative capacity, and the reporting of this information to the Regional Board.

The policy option (1a) to allow offsets to be used across groundwater subbasins, basins, and management zones would support the allocation of resources to areas outside of the subject subbasin/basin/management zone that have greater water quality impairments than exist at the point-of-discharge, or could result in the implementation of an offsets project showing greater protection of beneficial uses or providing greater maximum benefit to the people of the state. Although the economic impacts to individual dischargers, or groups of dischargers in an approved management zone, may be no different when funding an offsets project that is local as compared to one that is sub-regional or regional. The policy option (2a) to only allow an offsets project in the specific area that a discharge impacts may act as a disincentive to the



implementation of potential offsets projects because dischargers could decide that their resources are better spent bringing their own discharges into compliance.

The policy option (1b) to not require attainment of WQOs in the underlying groundwater, only progress towards attainment, will act to incentivize the implementation of offset projects, as dischargers won’t be expending resources to meet WQOs in the immediate vicinity of their discharge. The policy option (2b) to require attainment of WQOs in the underlying groundwater will act as a disincentive to the implementation of potential offsets projects because dischargers will be required to direct their resources to implement additional treatment or control of their own discharges in order to meet WQOs.

CV-SALTS developed several conceptual offset projects that were included in the Offsets Policy as example projects. Conceptual offset projects considered by CV-SALTS include those that would result in equivalent discharge concentration, equivalent mass reduction, elimination of septic systems, large regional projects, development of alternate water supplies, nitrate mitigation bank (to fund interim supply of safe drinking water prior and during construction of small drinking water supply systems, and fund the construction and operation of such systems), and retiring of cropland. Additionally, groundwater recharge projects may be components of some of these conceptual offset projects or could be implemented as separate offset projects. The planning level costs of short-term and long-term drinking water solutions are presented in Sections 6.3.1 and 6.3.2, respectively. These are efforts that could be supported by resources managed by a nitrate mitigation bank or other coordinated funding effort. The estimated costs of large regional projects to address legacy nitrate and salt contamination issues are presented in Section 6.3.3 (Long-Term Nitrate Management) and Section 6.3.4 (Long-Term Salt Management).

Groundwater recharge implemented either as a stand-alone project or as a component of a larger offsets project provides a potential opportunity to offset salt or nitrate loadings to groundwater, potentially resulting in lower ambient groundwater concentrations and increased assimilative capacity. How cost-effective a groundwater recharge project is compared to other types of offset projects depends on the cost, availability, source, and proximity of the water to be used for recharge and the cost and availability of land having suitable characteristics for recharge. In the absence of such information for a specific groundwater recharge project, a range of costs developed by Perrone and Rohde (2016) for California groundwater recharge projects proposed under Propositions 1E, 84, 50, and 13 is provided for comparison. Perrone and Rohde (2016) found that the cost of managed aquifer recharge is highly dependent on the cost and availability of source water for recharge, with surface water being the least expensive (median cost $330 per acre-foot per year (AFY)) followed by blended water (median cost $400 AFY), wastewater (median cost $870 AFT), and stormwater (median cost $1,550 AFY).

The retirement of agricultural land is a conceptual offset project included in the Offsets Policy whereby load reductions resulting from the fallowing of farmland are determined to be functionally-equivalent to the load that could have been removed by building a new wastewater treatment plant, for example. The cost of retiring agricultural land is tightly coupled to the value of the land, which is dependent upon its location and its ability to be used for other purposes.



Because the land would be taken out of agricultural production, consideration of the loss of crop revenue over an extended period is essential. It should be noted that such an action is potentially inconsistent with one of the primary goals of the CV-SALTS effort, which is to maintain a viable agricultural economy in the Central Valley. While it is outside of the scope of this analysis, the loss of agricultural revenue in an area would have an impact on the local or regional economy, with the magnitude depending on the acreage of land retired and the use of the land post- retirement. The case-specific nature of the economic costs of retiring agricultural land for transition to other purposes prevents the development of cost estimates in the present analysis. Quantitative and qualitative cost estimates to meet the Offsets Policy requirements are presented in Table 36.

Table 36: Example Estimated Costs to Meet Offsets Policy Requirements.

Policy Option/Potential Offset Project

Estimated Cost

Notes

Source

Tracking Offset Credits

and Assessing

Compliance with WQOs

---

Costs cannot be

estimated until

necessary guidance is

developed

Offsets project allowed to

be used across

groundwater subbasins,

basins, and management

zones (Policy Option 1a)

---

Offsets project cost is

case-specific, not


Option will incentivize

the implementation of

offsets projects

Offsets project only

allowed in the specific

area that a discharge

impacts (Policy Option 2a)

---


case-specific, not


Option will act as a

disincentive to the

implementation of

offsets projects

Attainment of water

quality objectives in

underlying groundwater is

not required (Policy

Option 1b)

---


case-specific, not


Option will incentivize

the implementation of

offsets projects

Attainment of water

quality objectives in

underlying groundwater is

required (Policy Option

2b)

---


case-specific, not


Option will act as a

disincentive to the



Policy Option/Potential

Offset Project

Estimated Cost

Notes

Source

implementation of

offsets projects

Short-Term Drinking

Water Solutions

---

See Section 6.3.1

Long-Term Drinking

Water Solutions

---

See Section 6.3.2

Long-Term Nitrate

Management

---

See Section 6.3.3

Long-Term Salt

Management

---

See Section 6.3.4

Groundwater Recharge

$90 – $890 per AFY

(surface water)

$410 – $2,650 AFY

(stormwater)

$180 – $2,050

(wastewater)

$210 – $1,080

(blend)

The cost ranges

provided represent the

25th and 75th percentile

of costs by water type;

Site-specific cost

estimates cannot be

developed at this time

Perrone and

Rohde, 2016

Drought and Water Conservation Policy

Policy Actions

The Drought Policy applies to both surface water and groundwater dischargers, and proposes to eliminate barriers to the use of recycled water during drought periods where compliance with WDRs for salinity (expressed as EC and TDS) may be challenging. For discharges to groundwater, the policy supports the calculation of compliance with applicable narrative/numeric salinity objectives using long-term (10+ year) flow-weighted average values, while simultaneously considering expected recharge and potential dilution from natural precipitation and streambed percolation to the same basin/subbasin. CV-SALTS has determined that this approach would continue to protect water quality by assuring that compliance with a receiving water limitation for salinity is evaluated holistically and long-term, based on the cumulative net effects of all sources of recharge to the groundwater basin.

The policy also authorizes the use of “Offset Projects”; e.g., increased stormwater capture and recharge, to demonstrate compliance with WDRs governing salinity discharges. The policy allows offset credits to be created and banked by constructing and operating such projects or by discharging well below the WDR threshold in non-drought years. Offset credits needed to achieve compliance during periods of drought would need to be generated at times of above normal precipitation (especially El Niño winters) and, as such, must remain valid for at least 10 years. The policy also includes the establishment of a temporary variance/exception from



salinity-related WQOs during specifically-defined periods of drought (see Section 5.1.6 for more details). Once a drought condition is identified, interim WDRs or interim discharge limits would apply.

Finally, the policy allows a temporary variance/exception from salinity-related WQOs where TDS concentration in the permitted discharge are significantly better (lower) than the TDS concentration in the water to which the discharge occurs. Allowing such a discharge would act to improve ambient water quality, but would require an evaluation of downstream/downgradient impacts before such a temporary variance/exception would be granted. Alternately, the Drought Policy includes an option that would consider pre-authorization of an automatic allocation of assimilative capacity (where it exists) to accommodate higher TDS concentrations in the discharge/recharge during drought conditions.


CV-SALTS intends to develop regional guidance in the future that describes how offset credits are to be applied to surface water and groundwater discharges that would enable a discharger to track its compliance with WQOs. Until such guidance is developed for discharges to groundwater, increased costs to groundwater dischargers are unquantifiable. However, it should be noted that some level of increased costs to groundwater dischargers would be incurred through additional monitoring, data analysis, evaluation of assimilative capacity, and the reporting of this information to the Regional Board.

The protection of the MUN beneficial use during drought periods would require consideration of the full range of secondary MCLs for salinity. Additionally, protection of the AGR beneficial use likely would require a crop sensitivity analysis and soil salinity modeling to determine an appropriate salinity level of the water used to irrigate the most salt-sensitive commercially important crop in the area. These costs would be borne by both individual dischargers and those participating in an approved management zone, with the latter presumably benefitting from the ability to share these costs.

The estimated costs to meet the Drought Policy requirements for surface water dischargers are presented in Table 37. It was assumed that the discharger will conduct an initial ‘simple’ antidegradation analysis to establish baseline water quality and characterize the salinity impacts on the receiving water during drought and non-drought periods. If the surface water has a designated AGR beneficial use and is used to irrigate crops downstream of the discharge, then a crop sensitivity analysis and soil salinity modeling would be required to determine the appropriate salinity of the surface water necessary to protect the most salt-sensitive commercially important crop grown in the area. To set an interim effluent limit, consideration of the full range of secondary MCLs for TDS or EC would also be required.

The implementation of groundwater recharge projects (which would occur as an offset project) are envisioned to incrementally dilute ambient groundwater concentrations and potentially improve assimilative capacity. However, as discussed in the Offsets Policy section, development of costs for a groundwater recharge project require knowledge of the cost, availability, source (surface water, stormwater, wastewater, blend), and proximity of the water to be used for



recharge and the cost and availability of land having suitable soil for recharge. In the absence of such information for a specific groundwater recharge project, a range of costs developed by Perrone and Rohde (2016) for California groundwater recharge projects proposed under Propositions 1E, 84, 50, and 13 is provided for comparison. In the cost estimates provided in Table 37, it was assumed that a discharger’s existing monitoring and surveillance program would be sufficient to provide data necessary to characterize ambient water quality and calculate assimilative capacity in the receiving water.

Table 37: Estimated Costs to Meet Drought Policy Requirements for Surface Water Dischargers.

Task/Project

Estimated Cost

Notes

Source

Simple Antidegradation

Analysis

$12,000 – $20,000(1)

LWA

Crop Sensitivity Analysis

and Soil Salinity Modeling

$45,000 – $75,000(1)

Not necessary when

discharge is improving

existing receiving water

quality for salinity

LWA

Tracking Offset Credits

and Assessing

Compliance with WQOs

---

Costs cannot be estimated

until necessary guidance is

developed

Groundwater Recharge

$90 – $890 per AFY

(surface water)

$410 – $2,650 AFY

(stormwater)

$180 – $2,050

(wastewater)

$210 – $1,080

(blend)

The cost ranges provided

represent the 25th and 75th

percentile of costs by water

type;

Site-specific cost estimates

cannot be developed at this

time

Perrone and

Rohde, 2016


(1) Cost per study; estimates may or may not be applicable to a group of dischargers.

Secondary Maximum Contaminant Levels Guidance

Guidance Actions

The Secondary Maximum Contaminant Levels Guidance clarifies the implementation of these drinking water criteria for the MUN beneficial use. The SMCLs Guidance proposes to incorporate into the Basin Plans text from 22 CCR §64449 et seq. that provides guidance on the application of “Recommended”, “Upper”, and “Short Term” consumer acceptance levels for TDS, EC, chloride, and sulfate in WDRs and NPDES permits. Constituents concentrations ranging between the “Upper” and the “Short Term” level in 22 CCR Table 64449-B may be authorized in WDRs on a temporary basis consistent with provisions of 22 CCR §64449(d)(3). A guidance option to only use “Recommended” SMCL values as the basis for use in WDRs has also been identified.

Commented [A46]: The Attachment A‐9 SMCL Guidance and summaries in the related SNMP documents continue to lack justification for need. In this Economic Analysis document, this would include a baseline of economic impacts existing that warrant revision. Then the guidance and its options could be compared for relative economic impact and benefit.



The guidance also allows compliance with SMCLs to be determined from a filtered water sample (water passed through a 0.45 micron filter). A filtered water sample is commonly described as containing the dissolved fraction of these constituents. An option included in the guidance is to assess compliance with SMCLs based on a non-filtered water sample.

The Proposed SMCL Guidance would allow the Regional Board to take into consideration any dilution or other attenuation that may occur between the point of discharge and any intake to a downstream (surface water) or downgradient (groundwater) water supply system. Options to the guidance with respect to consideration of dilution include (1) requiring compliance with SMCLs at the point of discharge (also known as end-of-pipe compliance), (2) requiring compliance with SMCLs at the edge of an approved mixing zone, and (3) requiring compliance at point of use (downstream water treatment plant intake (surface water) or downgradient drinking water supply well (groundwater)).

Where a downstream compliance point is specified, the guidance allows the Board the discretion to require a discharger or dischargers to develop a detailed fate and transport analysis between the point of discharge and the downstream compliance point. The purpose of this analysis would be to determine how the discharge affects the concentration of SMCL constituents at downstream water supply intakes or at downgradient water supply wells.

A further option included in the guidance related to downstream or downgradient impacts at drinking water intakes or wells is to require a study to evaluate actions that can be taken to reduce concentrations of SMCL constituents if downstream or downgradient concentrations are measured to reach 80% of the SMCL.

The guidance also includes an option to require the establishment of a surface water monitoring program to characterize natural background and existing conditions with respect to SMCLs where available data are deemed to be insufficient.


The proposed guidance element to allow compliance with SMCLs to be evaluated using filtered water samples may avoid future wastewater treatment costs. Measuring the filtered concentrations of metals, color, turbidity, TDS, EC, chloride, and sulfate prior to comparing them to SMCLs would not cause a change in existing NPDES or WDR permit requirements. Therefore, the clarification would not result in a change in current surface water or groundwater concentrations of these constituents, since dischargers would not be making changes to their treatment operations that would change the existing quality of their discharges or impact water quality.

A determination of compliance with SMCLs using non-filtered water samples would result in some dischargers needing to implement additional treatment or control to comply with such SMCLs. Under implementation of this guidance option, the number of dischargers needing to implement additional treatment or control of their discharges, and the levels of such actions cannot be quantified because information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available. Therefore, increased compliance costs cannot be

Commented [A47]: We continue to disagree with the use of a filtered water sample for constituents on Table 64449‐A.

Commented [A48]: The Regional Board should protect the entire MUN designated water body to provide source water protection for current and future use. This would include consideration of mixing zones, as appropriate.

Commented [A49]: This is more stringent than current regulatory requirements and has not been requested by any parties or stakeholders that we’re aware of. Why is this being included?

Commented [A50]: We appreciate inclusion of this feature in the Attachment A‐9 SMCL guidance. It should be noted that this is an allowance at the discretion of staff and does not assure any evaluation or protection.

Commented [A51]: This section is insufficient as it provides no cost information for drinking water treatment and residual management.

Commented [A52]: This is not supported. By using filtered samples the levels would be much lower and then could be removed from permit effluent limits based on the Reasonable Potential Analysis. CWA Antibacksliding requirements could be excepted, further eliminating the need to keep these constituents in the permit for monitoring, treatment, or pretreatment.

Commented [A53]: If no effluent limits, then monitoring not required and pretreatment not required either, which could both result in long‐term degradation.

Commented [A54]: If current regulations are based on non‐filtered samples, how would additional treatment be required if it is already being met?

Commented [A55]: If no quantification of the need for such regulatory relief has been conducted, then what is the basis or need of this proposed change?



estimated. Furthermore, the strict use of non-filtered receiving water samples for comparison to SMCLs would likely trigger the development and implementation of Total Maximum Daily Loads (TMDLs) for EC and metals in multiple Central Valley surface waters based on the data provided in the Water Quality Setting (see Section 4) included in this report.

The proposed guidance element to clarify that SMCLs can be established over the range of Recommended, Upper and Short term values does not represent a significant change in NPDES or WDR permitting. The clarification will however promote procedural consistency and case- specific flexibility in permitting and may avoid future treatment costs associated with decisions to set discharge limits based only on the Recommended values in the SMCL tables. The cost of compliance for dischargers held to the Recommended SMCL criteria for TDS, EC, chloride, and sulfate cannot be quantified because case-specific information regarding dischargers that would need to implement additional treatment or control of their discharge has not been developed by CV-SALTS and is not otherwise available.

Guidance options related to point of compliance of SMCLs could have significant economic impacts for dischargers depending on how the Regional Board considers any dilution or other attenuation that may occur between the point of discharge and downstream water treatment plant intakes (surface water) or downgradient drinking water supply wells (groundwater). Implementation of the end-of-pipe compliance option may require implementation of additional treatment or other controls by some dischargers. Under implementation of this guidance option, the number of dischargers needing to implement additional treatment or control of their discharges, and the levels of such actions cannot be quantified because information supporting such an analysis has not been developed by CV-SALTS and is not otherwise available.

Implementation of the end-of-mixing zone compliance option, where a mixing zone can be granted for a discharge, may result in avoided costs of treatment for some dischargers. Implementation of this compliance option for discharges to groundwater may result in avoided treatment costs for some dischargers due to the physical distance separating a groundwater discharge and a downgradient groundwater supply system and the attenuation available in the groundwater basin or subbasin.

The cost of a detailed fate and transport study that could be required by the Regional Board to assess the impact at water supply intakes or water supply wells cannot be quantified because information supporting such a study has not been developed by CV-SALTS and is not otherwise available. Similarly, the cost of an optional study to evaluate actions that can be taken to reduce concentrations of SMCL constituents if downstream or downgradient concentrations at drinking water intakes or wells are measured to reach 80% of the SMCL cannot be estimated due to a lack of information developed to support such an estimation.

A cost associated with the optional requirement to establish a surface water monitoring program to characterize existing ambient conditions with respect to SMCLs where available data are deemed to be insufficient can be estimated. Based on the paucity of available data for most constituents with SMCLs that was identified when compiling data for the current Water Quality Setting (see Section 4), a cost estimate for an ambient monitoring program collecting quarterly

Commented [A56]: This is more stringent than current regulatory requirements and has not been requested by any parties or stakeholders that we are aware of. Why is this being included?

Commented [A57]: In addition, this is at the discretion of the Regional Board so it is not possible to determine when it will be applied/required.

Commented [A58]: This setting did not include a significant DWR Sacramento River Watershed Coordinated Monitoring Program that conducts quarterly monitoring for some of these constituents. This cost could be optimized by coordinating with DWR on this program.



samples at the 24 surface water monitoring sites considered for the baseline water quality characterization can be developed (see Appendix K). The estimated cost of such a monitoring program and the qualitative cost assessments of the other SMCLs Guidance elements and their options are presented in Table 38.

Table 38: Estimated Costs to Meet Secondary MCLs Guidance Requirements and Options.

Guidance Task/Option

Estimated Cost

Notes

Source

Evaluate compliance with

SMCLs for identified

constituents using filtered

water quality samples

---

Avoided future treatment

costs for some dischargers

– case-specific, not

quantifiable at this time

Evaluate compliance with

SMCLs for all constituents

using non-filtered water

quality samples (option)

---


some dischargers -- case-


this time;

Future costs to develop

and implement TMDLs for

SMCLs in multiple water

bodies (see Water Quality

Setting Section); costs not


Use of Recommended,

Upper, and Short-Term

consumer acceptance

levels for TDS, EC,

chloride, and sulfate

---





Exclusive use of

Recommended consumer

acceptance level for TDS,

EC, chloride, and sulfate

(option)

---




this time

SMCL compliance at end-

of-pipe (option)

---




this time

SMCL compliance at

edge-of-mixing zone

(option)

---





SMCL compliance at point

of use (option)

---

No cost to surface water

dischargers

Commented [A59]: No justification of this avoidance.

Commented [A60]: No justification of this impact.



Guidance Task/Option

Estimated Cost

Notes

Source


costs for some

groundwater dischargers –

case-specific, not


Fate and Transport Study

(option)

---

Potential future cost in

cases where compliance

determined at point of use



Study to evaluate actions

when concentrations near

drinking water intakes or

wells reach 80% of SMCL

(option)

---

Potential future cost in

cases where compliance

determined at point of use



Ambient Monitoring

Program to Assess SMCL

Constituents at 24 sites

(option)

$150,000 – $250,000

LWA

See Appendix K for basis of estimated costs.

Alternative Compliance Projects for Nitrate Discharges Guidelines

The Alternative Compliance Projects for Nitrate Discharge Guidelines specifies the technical requirements that must be included in a proposed Alternative Compliance Project (ACP). The need for an ACP may be prompted when an individual or group of dischargers is unable to demonstrate that their discharge is not causing or contributing to nitrate degradation above the triggers identified in the Central Valley SNMP. Under this circumstance, the individual or group would have an opportunity to request either allocation of available assimilative capacity or an exception. Either of these requests likely will result in a requirement to submit a proposal for an ACP as a means to offset the impacts of the discharge. The estimated costs of preparation of an ACP proposal are discussed in the Nitrate Permitting Strategy section.

6.4 SNMP VALLEY-WIDE SURVEILLANCE AND MONITORING PROGRAM

The CV-SALTS Strategy and Framework document states that the strategy to fulfill the requirements of the State Recycled Water Policy is to adopt a Central Valley SNMP and revise the Basin Plans applicable to facilitate implementation of the SNMP. Among other things, the SRWP requires that development of the SNMP include a basin/subbasin wide monitoring plan that included an appropriate network of monitoring locations to determine whether the concentrations of salts, nutrients, and other constituents of concern as identified in the Central Valley SNMP and future regional and sub-regional SNMPs are consistent with applicable water

Commented [A61]: What assurance is provided that there will be sufficient surface water monitoring? Existing programs are stated to be sufficient, however there may be changes to those programs in response to the SNMP and its related policies and guidances as well as the regionwide MUN de‐/re‐designation process BPA that the Regional Board will be considering.

Commented [A62]: How will these be determined?



quality objectives. CV-SALTS has developed a Surveillance and Monitoring Program (SAMP) to meet the monitoring requirements of the SRWP (CV-SALTS, 2016d).

The CV-SALTS SAMP was designed to meet the following board objectives:

Develop a monitoring program that will allow for statistically-defensible ambient water

quality determinations and trend analyses.

Develop a monitoring program that is cost-effective by utilizing existing monitoring programs and existing monitoring stations in order to be cost-effective and consistent.

The SAMP domain is the Central Valley as a whole, but local monitoring programs associated with individual WDRs or the execution of Management Zone Implementation Plans established for newly defined management zones could be linked with the SAMP. SAMP stakeholders will likely include overlying cities and counties, water districts, irrigation districts, drainage districts, POTWs, food processors, other industries, agriculture, nongovernmental organizations, environmental groups, and regulatory agencies. SAMP stakeholders may include, coordinate with, or be Sustainable Groundwater Management Act (SGMA) Groundwater Sustainable Agencies (GSAs). The SAMP can be implemented through the Central Valley Water Board as a valley‐wide program. Alternatively, the governance structure for each groundwater basin or management zone – agency(ies), joint powers authority, or coalition(s) or other entities – can implement the SAMP at that scale and report back to the Central Valley Water Board.

The SAMP is comprised of a number of tasks, both to start-up and implement the program. The program is estimated to take 10 years to implement. It is anticipated that a project budget between $2.7M and $5.0M would be needed to fund the initial 10 years of the SAMP. Additional administration and contracting costs likely would bring the annual cost between $300K and $550K (CDM Smith, 2016a).



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APPENDICES – ECONOMIC ANALYSIS Developed by Larry Walker Associates, September 2016.

Commented [A63]: Note: appendices removed for a smaller file to provide comments on. Any appendices that comments apply to are incorporated by reference.