11615 Sterling Ave., Riverside, CA 92503 951.354.4220 Fax 951.785.7076 www.sawpa.org

S A W P A SANTA ANA WATERSHED PROJECT AUTHORITY

BASIN MONITORING PROGRAM TASK

FORCE

Tuesday, February 9, 2016

9:30 a.m. – 11:30 a.m.

AGENDA

1. Introductions

2. Public Comments

3. Approval of December 1, 2015 Meeting Summary

4. Status of BMP Task Force Agreement Amendment approval – SAWPA

5. Draft FY 2016-2017 Basin Monitoring Program Task Force Budget - SAWPA

6. Regional Board Triennial Review List, Drought Response Policy, Outline ofSuggested Actions– Risk Sciences

7. Basin Plan Amendment for SAR Wasteload Allocation Status- Risk Sciences

8. Schedule Future Meeting

9. Adjournment

a. Scoping Committee Meeting, Feb. 9th 11:45 am – 12:45 pm

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M E E T I N G S U M M A R Y

Basin Monitoring Program Task Force

December 1, 2015

ATTENDEES:

Andy Campbell, IEUA Jennifer Torres, City of Corona

Andy Malone, WEI representing CBWM Keith Person, Regional Board

Anthony Budicin, SBMWD Lynn Merrill, City of Rialto

Bob Tincher, SBVMWD Marsha Westropp, OCWD

Cindy Li, Regional Board Marissa Flores-Acosta, SBMWD

Ed Filadelfia, City of Riverside RWQCP Robert Eland, City of Riverside RWQCP

Fakhri Manghi, WMWD Tim Moore, Risk Sciences

Greg Herzog, City of Riverside PU Bobby Gustafson, EVMWD (Phone)

Lyndy Lewis, IRWD Mark Norton, SAWPA

Jayne Joy, EMWD Zyanya Blancas, SAWPA

Jennifer Shepardson, SBMWD

Call to Order/Introductions The Basin Monitoring Program Task Force (Task Force) meeting was called to order at 1:30 p.m. at the Santa

Ana Watershed Project Authority (SAWPA) office located at 11615 Sterling Avenue, Riverside, California.

Brief introductions were made.

Approval of October 27, 2015 Meeting Summary Meeting notes were approved as presented.

MOVED, to approve October 27, 2015 meeting summary.

Result: Adopted (Unanimously)

Motion/Second: Joy/Merrill

Status of BMP Task Force Agreement Amendment approval - SAWPA The Basin Monitoring Program Task Force Amendment (Amendment) was distributed to the agencies for

signatures on July 13, 2015. Mark Norton stated that there are still a few agencies that have not submitted their

Amendment. Those agencies are the Inland Empire Utilities Agency, Lee Lake, City of Redlands, City of Rialto,

City of Riverside and Yucaipa Valley Water District.

Regional Board Triennial Review List, Drought Response Policy – Regional Board At the previous meeting, Jayne Joy, EMWD, provided a PowerPoint presentation on Regional Board’s

consideration of a need for a policy regarding TDS compliance during drought conditions. The Task Force

requested Tim Moore, Risk Sciences, provide an outline of suggested action items to move forward on a drought

policy. First draft of the outline is complete and is currently being reviewed before presented the Task Force for

comments.

The petition to the State Water Board is structure for short term immediate action to begin taking steps to

mitigate the next drought. Fortunately, the State Board has already initiated the review process for their anti-

degradation policy; this will be tied to the drought policy.

DRAFT

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Basin Plan Amendment for SAR Wasteload Allocation status – Risk Sciences 8:21 Tim Moore provided copies of the 48 page Petition to Revise Water Quality Objective for Nitrate-Nitrogen in

Chino-South Management Zone (Petition). Moore began his presentation by giving a brief background to the

issues found in the Chino-South groundwater management zone (CSMZ).

It was stated that the City of Ontario had sent a letter to the Regional Board in 2010, opposing the rise of the

Nitrate-N objective and recently attached it as a comment to the Petition. They claimed that CDA pumps/treats

groundwater from Chino-South; a higher objective will allow more nitrogen loading to Chino-South, which will

increase treatment costs for the CDA; therefore, a higher objective essentially transfers treatment costs from the

POTWs to the CDA and its rate payers; and that it would not be compliant with CWC 13241. Discussion ensued

on the misinterpretation of the letter. Curtis Paxton, CDA General Manager, stated the letter was attached only

as a form of discussion and not as a submittal. He asked for more time to review the Petition. CDA will be

meeting with their technical committee next week. The Task Force agreed to allow CDA another month for

comments.

Regional Board said that Riverside’s permit will be expiring in 2018; therefore there is a rush for the next WLA.

It was agreed by the Task Force that the WLA Basin Plan Amendment should be completed in 2017.

Consultant Services Support for next Ambient Water Quality Update and SAR Wasteload Allocation Update for FY 2016-17 The Task Force agreed to move forward with a competitive bid process for both the Ambient Water Quality

Update and the Santa Ana River Wasteload Allocation Update for FY 2016-17. A Scoping Committee was

formed; Tim Moore (Risk Sciences), Greg Woodside (Orange County Water District), Jennifer Shepardson

(City of San Bernardino Water Department), and Jayne Joy (Eastern Municipal Water District). Discussion

ensued on the scope of work for the RFPs. It was suggested that the RFP for the WLAM update request the

model’s user manual. In the past, the Task Force received a cost estimate of $16,000 to $17,000 for the

development of a user manual and documentation of the process, which is essentially a deliverable version of it

so anyone could make adjustments to the model. Task Force member recommended investigating the option of

having an in-house modeler. There was discussion regarding the possibility of turning the model into a

spreadsheet. Question arose whether certain detailed data is necessary (e.g. daily time stamps); Task Force

agreed that they will need to ask a consultant to determine that. It was noted that the model needs to be updated

as it does not reflect the current land use data.

Scheduled Future Meeting The next Task Force meeting was scheduled for Tuesday, February 9, 2016 at 9:30 am.

Future items

Elsinore Valley Municipal Water District Maximum Benefit Report

Review of Western Municipal Water District groundwater model for Riverside A

Adjournment 3:31 pm

DRAFT

FY 16-17 CostProjected Expenses SAWPA TF Admin & Contract Adm $50,000

SAR Annual Report $30,000Risk Sciences Regulatory & Documentation Support $74,000Ambient Water Quality w/ Interpretive tools (FY 2016-2017)1 $350,000 $116,667SAR Wasteload Allocation (FY 2016-2017)2 $250,000 $125,000

$395,667

Projected Revenue

SAWPA Admin SAR ReportRisk Sciences Reg Support

Ambient Water Quality & Tools

SAR Wasteload Allocation Total

IEUA $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180EMWD $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180OCWD $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

SBVMWD5 $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180CORONA $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180EVMWD $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

REDLANDS $2,631.58 $3,700.00 $5,833.35 $6,250.00 $18,415RIALTO $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

RIVERSIDE $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180RIX JPA $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180YVWD $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

WRCRWA $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180JCSD $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

LEE LAKE WD6 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $17,548BEAUMONT $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

CBWM $2,631.58 $3,700.00 $5,833.35 $6,250.00 $18,415BANNING5 $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180SGPWA5 $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180BCVWD5 $2,631.58 $1,764.71 $3,700.00 $5,833.35 $6,250.00 $20,180

IRWD $2,631.58 $3,700.00 $5,833.35 $6,250.00 $18,415$50,000 $30,000 $74,000 $116,667 $125,000 $395,667

1. Triennial Ambient Water Quality (AWQ) Update w/Interpretive Tools (FY16-17) - funding collected annually over 3 years2. SAR Wasteload Allocation (FY 16-17) - funding collected over 2 years3. WE Inc. Study - SAR salinity influences of POTWs - to be conducted in FY 14-15 and funded using carryover reserves4. Task Force Carryover Reserves resulting from reduced FY 2012-2014 adm costs than originally budgeted5. SBVMWD, SGPWA, BCVWD and Banning are included as forthcoming new task force agencies and funding partners6. A discount was provided for POTWs producing under 1 mgd of wastewater flow - No SAWPA Admin cost per TF direction

Draft FY 16-17 Basin Monitoring Program Task Force Budget (Effective 2-9-16)

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Principles to Govern Development of a Drought Policy in the SAR Watershed

Background 1) In the Recycled Water Policy (Res. No. 2009-0011), the State Water Resources Control

Board ("State Water Board") found that severe drought was "challenging California's ability to provide the clean water needed to support a healthy population, a healthy environment and a healthy economy now and in the future."

2) In adopting the Recycled Water Policy the State Water Board declared their

"independence from relying on the vagaries of annual precipitation and move towards sustainable management of surface water and groundwater, together with enhanced water conservation, water reuse and the use of stormwater."

3) The Recycled Water Policy directs the State Board and the Regional Water Quality

Control Boards ("Regional Board") to "exercise the authority granted to them by the Legislature to the fullest extent possible to encourage the use of recycled water, consistent with state and federal water quality laws."

4) "When used in compliance with this [Recycled Water] Policy, Title 22 and all applicable

state and federal water quality laws, the State Water Board finds that recycled water is safe for approved uses, and strongly supports recycled water as a safe alternative to potable water for such approved uses… The State Water Board [also] finds that the use of recycled water in accordance with this Policy, that is, which supports the sustainable use of groundwater and/or surface water, which is sufficiently treated so as not to adversely impact public health or the environment and which ideally substitutes for use of potable water, is presumed to have a beneficial impact." [RWP, §1 & §3, pgs. 2 & 3]

5) The Recycled Water Policy requires the Regional Board to develop and implement

regional and sub-regional salt and nutrient management plans to encourage greater use of recycled water while assuring compliance with applicable water quality standards. The degree of specificity within these plans will vary with a number of site-specific factors including stormwater recharge. "It is also the intent of the State Water Board that because stormwater is typically lower in nutrients and salts and can augment local water supplies, inclusion of significant stormwater use and recharge component within the salt/nutrient management plans is critical to the long-term sustainable use of water in California." [RWP, §6(b)(2), pg. 5]

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Regulatory Issues 6) Permit limitations governing the discharge of treated municipal wastewater (aka

"recycled water") may include restrictions on the salt concentration in the final effluent. The limits themselves may be derived based on the applicable narrative or numeric water quality objective, or based on high quality receiving water, or based on a maximum allowable increase in Total Dissolved Solids (TDS) compared to the average salinity concentration in the municipal water supply source, or based on the best demonstrated performance of the treatment plant using representative prior discharge data.

7) Historically, NPDES limits and waste discharge requirements (WDRs) rarely included any

special provision or consideration for variations in effluent quality that may be directly or indirectly related to recurrent drought conditions.

8) Extended periods of below normal precipitation (aka "droughts") can create conditions

that may make it more difficult to comply with some WDRs governing salinity.

a) First, during droughts, there is generally less high quality (low TDS) surface water available and water agencies commonly increase their reliance on lower quality (higher TDS) groundwater sources to augment their water supply. Most wastewater treatment plants are not designed to remove TDS. Consequently, higher salinity in the water supply tends to result in higher salinity in recycled water.

b) Second, mandatory conservation measures undertaken in response to prolonged

drought may significantly alter the behavior of residential and commercial water users. The cumulative effect of shorter showers, larger laundry loads, less frequent flushing, etc. combine to reduce water waste which previously helped dilute the average TDS concentration of raw sewage and, eventually, recycled water.

c) These drought-related changes in water quality temporarily aggravate a long-

term trend toward increasing TDS that is caused by widespread adoption of high efficiency, low-flow fixtures and appliances that reduce water waste and subsequent dilution, and by greater use of in-home water softening technologies that increase TDS discharged to the sewer system.

d) The net result is that, even where wastewater treatment plants have been able

to cope with the long-term trend of rising TDS in the sewage influent, drought-related conditions may temporarily eliminate the small but critical buffer needed to assure consistent compliance.

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Regulatory Issues (continued)

9) Inability to assure consistent compliance with WDRs governing salinity makes it more difficult to increase the use of recycled water for landscape or crop irrigation. In addition, these requirements may inadvertently disincentivize greater implementation of more efficient irrigation systems.

10) This problem is compounded by the fact that compliance with WDRs for TDS is often

evaluated using relatively short-term averaging periods (e.g. daily, weekly, monthly means). Since droughts typically persist for several years, even WDRs expressed as an annual average may be practically impossible to meet given the elevated salinity concentrations in the best available water supplies during such times.

Recommendations

11) For discharges to groundwater, calculate compliance with the applicable narrative or numeric salinity objectives using a flow-weighted annual average while simultaneously taking into consideration the annual recharge from natural precipitation (median value of the last 100 years).

Such an approach would be consistent with the Recycled Water Policy in that it accounts for the influence of stormwater recharge over the long-term and is also consistent with the State Board's previous precedential orders deeming it appropriate to consider "system mixing." [SWRCB Order No. 81-5; Lompoc] Many of the short-term averaging periods most commonly used originated in EPA

regulations intended to protect surface waters [see, for example, 40 CFR 122.45(d)]. These averaging periods are unnecessarily restrictive where surface recharges routinely take several years to reach the groundwater after passing through the vadose zone. Most important, this approach would continue to protect water quality by assuring that compliance with a receiving water limitation for salinity is evaluated, holistically, based on the cumulative net effects on the receiving water.

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Recommendations (continued)

12) Authorize the use of "Offset Projects," particularly increased stormwater 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. Recognize that the credits needed to achieve compliance during periods of drought must be acquired and accumulated during the years of above normal precipitation (esp. El Niño winters) and, as such, must remain valid for at least 10 years.

13) Consider amending the Basin Plan to establish a temporary variance/exception from

salinity-related standards when the Governor or State Water Board has declared a drought emergency or when some other pre-defined trigger condition has been met. At such times, alternate interim WDRs or effluent limits would apply. In general, the purpose of this approach is to exempt dischargers from temporary non-compliance for exceedances/violations caused by the loss of high quality (lower TDS) water supplies and/or salinity increases directly related to mandatory conservation measures.

14) Consider amending the Basin Plan to establish a temporary variance/exception from

salinity-related standards where the TDS concentration in the permitted discharge is significantly better (lower) than the TDS concentration in the receiving water and is expected to provide progress toward re-attaining said standards by improving receiving water quality while promoting maximum use/reuse of available water supplies.

Feb. 9, 2016 1

Water Quality Objective for Nitrate in the Chino-South GMZ: A summary of regulatory alternatives considered by the BMPTF (2009 - 2015)

1) Make a finding that the projected degradation caused by streambed recharge is

temporally-limited because the long-term projections from the WLAM show the 63-year average is actually estimated to be less than the nitrate objective of 4.2 mg/L.

Summary of WLAM for CSGMZ – Scenario #8 for 2020*

TIN Recharge Quality (WQO = 4.2 mg/L nitrate-nitrogen)

Scenario 8d: Max. Recycle

Scenario 8e: Intermediate

Scenario 8f: Max. Discharge

Long-term Average (63 years) 4.03 mg/L 4.10 mg/L 4.14 mg/L Highest Running 10-year Avg. 4.25 mg/L 4.31 mg/L 4.34 mg/L

Maximum Est. Exceedance 0.05 mg/L (1.1%) 0.11 mg/L (2.6%) 0.14 mg/L (3.3%) *WEI; Addendum to the 2008 Santa Ana River Wasteload Allocation Model Report: Scenario 8; Jan. 5, 2015.

2) Make a finding that the actual degradation is likely to be less than the projected

degradation because the WLAM (by necessity) must employ a series of concurrent worst case assumptions about the volume and quality of discharge simultaneously by the POTWs that is very unlikely to actually occur. In addition, by law, the POTWs must begin planning for treatment upgrades and improvements when they reach 75-80% of their rated capacity.

3) Make a finding that the nitrate objective is no actually being exceeded because the NPDES permit limits are expressed as Total Inorganic Nitrogen (TIN). Nitrate usually makes up only about 85% of TIN. Thus, there is a 15% safety factor built into the WLA system and the maximum projected temporary TIN exceedance is only about 3% higher than the nitrate objective.

4) Revise the site-specific nitrogen loss coefficient for Reach 3 of the SAR overlying the

Chino-South GMZ from 50% up to 55-60%. This is well within the N-loss range previously documented in site-specific studies and would be sufficient to eliminate the nominal temporary exceedance that is projected to occasionally occur under worst case assumptions.

Feb. 9, 2016 2

5) Revise the nitrate objective for the Chino-South GMZ by raising it from 4.2 mg/L to 5.0

mg/L. This would retroactively authorize a small portion of the degradation that has already occurred and would simplify current NPDES permitting for the POTWs without exacerbating current poor groundwater quality (avg. nitrate > 28 mg/L). Given the existing 50% N-loss coefficient, effluent discharges limited to 10 mg/L will recharge the CSGMZ at no more than 5 mg/L even if there is zero dilution from high quality stormwater runoff.

6) Reduce the maximum volume of recycled water that is discharged to Reach 3 and 4 of

the Santa Ana River overlying the CSGMZ. 7) Reduce the effluent limit for TIN from 10 mg/L to approximately 9.5 mg/L for discharges

of recycled water to Reach 3 and 4 of the Santa Ana River overlying the CSGMZ.