Alameda County Department of Environmental Health Land Use Program
Onsite Waste Water Treatment Systems (OWTS) Regulatory Oversight
January 5, 2015 Presentation Overview
• 2014 Land Use Program – Actions Triggering Onsite Wastewater Treatment System Oversight – Service Requests Statistics – Work Flow Changes – Administrative Changes – Fees
• Going Forward – Local Agency Management Program (LAMP) – Groundwater Sustainability Act – Program Restructuring – Fee Evaluation per Prop26 Requirements – Tools or a Solution
Actions Triggering Land Use Program Regulatory Oversight Owner Initiated Installation of New Potable Water Supply Well or Treatment of Existing Well Sewer Connection/Existing OWTS Abandonment Failing OWTS Real Estate Transactions Site Development/Improvement Projects (Additions, Remodels, New Construction) Regulatory Agency Initiated PWA Referral to ACDEH (Building, Demolition, Grading Permit Applications) CDA Referral to ACDEH (Site Development Reviews, Conditional Use Permits, Subdivisions) ACDEH Food Program Referral to ACDEH Land Use Program (Commercial Food Facility Permits) Non-Compliance with ACDEH Land Use Program Directives (Corrective Action) Complaint Investigations & Code Enforcement (Illegal & Failing OWTs) 2014 Service Request Statistics
Service Request Type In Queue Processed Residential Projects Commercial Projects Real Estate Transactions Complaint & Code Enforcement Investigations Failing OWTS Requiring Corrective Action Undocumented OWTS Project Consultation Meetings Potable Water Supply Well Source Testing OWTS Performance Evaluations OWTS Design Reviews Construction/Abandonment Permits OWTS Operating Permits Appeals & Variances 2014 Commercial Facility Statistics
Commercial Facilities No. Wineries Dog Kennels Horse Boarding/Equestrian Centers Event Centers Restaurants/Bars/Cafes Gas Stations Cemetery/Crematoriums Schools Fire Stations Industrial/Power Facilities Solid Waste Facilites No. of Projects Requiring Interagency Coordination Agency Coordination Type No. ACDEH CUPA, Commercial/Industrial Facility Regulatory LOP, OPS Oversight and Permits CDA Site Development Review, Conditional Use Permits, Subdivisions, & Code Enforcement PWA Building , Demolition, and Grading Permits Zone 7 Residential and Commercial OWTS Permits RWQCB Tier 1 Consultation Meetings, Commercial Facility OWTS Permits CDF&W OWTS Streambed Crossings, Protected Species USACE Waters of the U.S., Jurisdictional Wetlands Cities Code Enforcement 2014 Land Use Program Statistics
Location No. of Commercial Facilities No. of Residential Facilities Livermore Pleasanton Sunol Castro Valley Hayward Oakland Dublin Fremont EBRPD 2014 Land Use Program Work Flow Changes • Placing emphasis at the project scoping stage to ensure mutual understanding between stakeholders (customers, consultants, and regulatory agencies) regarding: – Permitting process – Coordination – Timeline – Customer and Consultant Responsibilities • Providing alternative project consultation meeting venues that are more central to customers
2014 Land Use Program
Work Flow Changes • Placing emphasis on the preliminary design phase in the permitting process to identify project constraints, technology options, and potential projects costs (capital , O&M, and regulatory fees) in order to provide sufficient data for stakeholders to make informed financial and risk management decisions about their projects
• Requiring greater accountability from OWTS design professionals and placing more emphasis on requisite certification, licenses and professional stamps
• Incorporating OWTS Design Plans into the Building Permit Application Plans in order to facilitate interagency coordination during plan review and permit issuance
2014 Land Use Program Administrative Changes • Staff Increases • Development of Service Request Forms • Expansion of Fee Payment Options • Development of Permitting & Approval Process Work Flow Tables • Website Redesign • Inventory Tracking • Developing tools to share site specific and regional data with other regulatory agencies
Service Request Types and Fees
Service Request Type PE Code Fees Project Consultation Meeting 2613 $145 Site Visit/Evaluation 2613 $433 OWTS Performance/Site Evaluation 2601 $433 Existing OWTS As-Built Plan Review 2604 $433 Preliminary OWTS Design Review 2602, 2603, 2604 $1,587 Final OWTS Design Review 2604 $433 OWTS Construction Permit (Standard OWTS) 2605, 2614 $866 OWTS Construction Permit (Advanced OWTS) 2605, 2613, 2614 $1,011 OWTS Abandonment Permit 2612 $433 OWTS Operating Permit (Advanced OWTS) 2606 $288 Potable Water Supply Well Source Testing 2607 $433 Deed Restriction 2613 $145 Change Creates Confusion
• The state’s OWTS requires a different approach that many in the field resist: – Is there discretion for when the policy can be implemented? – Is Section 3.1 in effect and does the State have the authority to over- ride local ordinance? – When the state rule is more restrictive, who has the authority to grant a variance? • Is DEH mandated to implement the OWTS? • Does the Business and Professions Code affect OWTS projects? • Does DEH have Administrative authority to change workflow, billing process, • What is the most effective way to keep the community informed of changes while still managing the workload? • Can the program become cost offsetting via fees?
Going Forward
• Certified Local Area Management Program (LAMP) in place by 2018 – Communication – Collaboration – Direction
• Enforce all applicable laws and regulations
• Restructure the program: annual monitoring, data sharing, staff priorities, workflow, fee evaluation per Prop 26 requirements LAMP Timeline
• Local agencies can continue to implement their existing OWTS Programs until May 13, 2018
• In the interim period, all local agencies must consult with the RWQCB prior to permitting an OWTS for which the local agency standard is less protective than the OWTS Policy Tier 1, 3, or 4 requirements.
• Local agencies must submit a written notice of its intent to regulate OWTS’s in their jurisdiction using a LAMP (Tier 2 Requirements). A proposed LAMP must accompany the notice and be submitted to the RWQCB by May 13, 2016
• The LAMP may propose differing requirements from the State OWTS Policy Tier 1, 3, and 4 requirements as long as they are deemed to protect water quality and public health
• While reviewing the proposed LAMP, the RWQCB will consider the past performance of the local program to adequately protect water quality
• Once approved, modifications to a LAMP must be approved by the RWQCB
LAMP Required Elements
• Education and Outreach Program – Regulatory oversight permitting and approval process
– Operations, maintenance and reporting requirements
– OWTS Service Provider Certification Program
– Areas of Concern
– Formation of OWTS Management Entities
LAMP Required Elements
• OWTS Service Provider Certification Educational, training, certification, and/or licensing requirements required of OWTS Service Providers: – Site Evaluators – Surveyors – Designers – Installers – Pumpers – Maintenance Contractors
LAMP Required Elements
• Septic Tank Cleaning Registration Program – Assessment of existing and proposed disposal locations for septage, the volume of septage anticipated, and whether adequate capacity is available
– Septage pumper registration requirements
– Septage pumper reporting requirements
LAMP Required Elements
• Water Quality Assessment Program – Development and maintenance of a Water Quality Assessment Program to evaluate OWTS impacts to ground and surface water
– Implementation of Salt and Nutrient Management Plan and Groundwater Sustainability Program Requirements
– Coordination with watershed management groups (Groundwater Basin Managers and Groundwater Sustainability Agencies)
– Monitoring & analysis of water quality data (nitrates and pathogens) in surface & groundwater
– Annual & 5-Year Reporting and Program Evaluation Requirements to RWQCB LAMP Required Elements
• Water Quality Assessment Program Data Evaluation
– Monitoring & analysis of water quality data (nitrates and pathogens) in surface & groundwater
• Random well samples from a domestic well sampling program
• Routine real estate transfer samples
• Review of public system sampling reports done by the local agency or another municipality responsible for the public system
• Water quality testing reports done at the time of new well development
• Receiving water sampling performed as part of an NPDES permit
• Groundwater sampling performed as part of Waste Discharge Requirements
• Groundwater data collected as part of the Groundwater Ambient Monitoring and Assessment Program and available in the State Geotracker Database
LAMP Required Elements • Identification of Areas of Concern – Requires complete inventory of OWTSs – Areas with parcels where there is insufficient area for OWTS expansion in case of failure – Areas with high domestic well usage – Areas with surface water & groundwater vulnerability to OWTS due to: • Hydrogeologic conditions • Proximity to surface water bodies • High OWTS density • High density of failing OWTSs and OWTSs predating adopted standards of design and construction • Parcel size and susceptibility to hydraulic mounding
LAMP Required Elements
• OWTS’s Requiring Corrective Action – Has affected or will affect groundwater or surface water to a degree that makes it unfit for drinking or other uses – Is causing a human health or public nuisance condition by waste water discharging to surface or backing up into plumbing fixtures – Requires repairs in substantial conformance to the greatest extent practicable – Owner unable to comply with corrective action requirements due to financial hardship – Regulatory Options
Tools for a Solution: ArcGIS
• Utilization of ArcGIS platform to aggregate data relative to OWTS permitting:
Existing commercial and residential OWTS locations Assessor Parcel Numbers Surface water body locations Groundwater basin locations Groundwater monitoring well data (elevations and water quality) Water treatment plants and supply line locations POWTs and sewer line locations Animal facilities Topography Hydrogeology Earthquake Faults Soil Maps
• Data can be input as dots/locations on a map
• Geo-Code Vs in-field GIS recording of dots on the map using Trimbles to improve accuracy Tools for a Solution: ArcGIS
ArcGIS data can be used to: • Inform development of a “living” ACDEH LAMP • Identify areas of concern : Impacted or at risk groundwater basins and surface water bodies Areas with high OWTS density Areas with animal facilities • Transition from a prescriptive code to a performance based code • Develop short, medium and long term solutions in areas of concern: Community OWTS Expansion of existing POTWs Planning of new POWTs Creation of local management entities • Inform real estate transactions • Aid in community education and outreach programs
Tools for a Solution: E-GIS & Pictometry
• ACDEH Intranet E-GIS Website • ACDEH aims to use E- GIS as a platform to share site specific, local and regional data with other Alameda County Agencies and SFRWQB during permitting process • Goal is to model OWTS E-GIS system after the Department’s map of food facility inspections, where each dot/location contains data on that location Tools for a Solution: File-Net
• A data bucket for combined Agency review and participation with features to: Store editable Pictometry shots Store CAD drawings in non- editable versions but still be able to draw lines and add bubbles, to allow CDA, PW and ACDEH to use the same set of plans Allow folders for each agency to keep their site related review comments, PDF permits, sign off sheets and allow other Agencies to view contents Tie all data to a dot/location on the E-GIS map Transparency and Client Service
• With confidentiality concerns properly addressed, RPs and their contractors should be able to monitor the progress on their sites by accessing their dot/location on the map. Psomas on contract to develop California Sustainable Groundwater Management Act of 2014 • AB 1739, SB1168 commits the state to locally controlled, sustainable groundwater management – The convergence of multiple issues: • Sustainability, Storage Capacity, Planning and Protection of a valuable resource, • Protection against “Undesired results”: Septic, well installations, assimilative capacity, cumulative impact, mitigation of contamination • Funding – De minimus (minimum users threshold): 1,785 gallons /day extraction
Sustainability Program
• Must work in concert with all applicable Area Plans • Must collaborate with impacted cities and the county • Does not over-ride the authority to issue permits for wells held by the well permitting program • Empowers the implementing agency to impose fees • Allows the creation of local ordinance to regulate the transfer of groundwater Sustainability Agencies
• A Sustainability Agency must be identified for every part of the basin by 2016 and a plan for the basin must be in place within 5 to 7 years • Alameda Water District and Zone 7 are designated Sustainability Agencies for their districts. Albany to Hayward, SF Bay to Castro Valley must be designated – The State will implement for the County if a local Sustainability Agency is not declared by 2016 Well Management Program
• Zone 7, ACWD and Alameda Public Works collectively enforce the California Water Code 13800-13806 for the construction, maintenance and destruction of ground water wells and exploratory holes • Alameda County is responsible for the area West of the hills and North of Hayward. • Title 6, chapter 6.88 of County Ordinance defines the County’s responsibilities • Separate from the new Sustainability and Protection Act Transition
• Alameda County Public Works and The Department of Environmental Health are in talks to transition authority and responsibility for the well management program as the administering agency • DEH considered this program a natural fit with other existing responsibilities such as Land Use, Site mitigation oversight, individual small water well installation Sustainability Agency
• DEH considers duties of the Sustainability Agency to be compatible with implementation of the Groundwater Well Management. • DEH works closely with the other Sustainability Agencies in the County, Zone 7 and ACWD and with the state oversight agency: SWRCB. • DEH works closely with CDA and PW Undesireable Results currently mitigated by DEH oversight • Leaking underground fuel tanks (LOP) • Surface contamination by past industrial use (SLIC) • Septic Systems (land use) • Landfill leachate (solid waste) • NPDES-Clean Water Program (CWP) • Surfacing Sewage and Overflows (SSO)
TO: Applicants for Onsite Wastewater Treatment Systems & Local Agencies
FROM: Dyan Whyte Assistant Executive Officer
DATE: December 22, 2014
SUBJECT: Clarifying which standards apply for Onsite Wastewater Treatment Systems (OWTS) before May 2018 or adoption of a Local Agency Management Program (LAMP)
The State Water Board OWTS Policy became effective on May 13, 2013, and established a 60-month compliance deadline by which local agencies would either apply the OWTS Policy standards (contained in Tiers 1, 3, or 4 of the OWTS Policy) or prepare a LAMP for Regional Water Board approval (described in Tier 2 of the OWTS Policy). This memo clarifies the Water Board’s expectations for approval of OWTS before May 2018 (the end of the 60-month period) or until the local agency has a LAMP approved by the Water Board, whichever comes first. Herein we will refer to this period of time as the “interim period”.
There has been some confusion over which standards apply to new OWTS during the interim period. Specifically, we have received questions regarding which standard applies if there is a discrepancy between a local ordinance and the State Water Board OWTS Policy Tier 1 requirements. The OWTS Policy notes that after May 2018 or LAMP approval (whichever comes first), the stricter of the two standards must be applied. It does not address the interim period.
To avoid confusion and ensure that water quality will be protected during this interim period, all local agencies must consult with the Water Board prior to permitting an OWTS for which the standard is less protective than the OWTS policy Tier 1, 3, or 4 requirements, (as applicable, depending on whether the system is located within an impaired water body and whether the system requires corrective action). If the Water Board determines that the proposed OWTS poses a threat to surface or groundwater, the Water Board may ask the OWTS applicant for a Report of Waste Discharge (ROWD) and consider permitting the OWTS using waste discharge requirements.
In the event that an interested party or the local agency believes that the an existing or proposed OWTS, as regulated by the local agency, will not sufficiently protect water quality, either party may request a consultation with Water Board staff to clarify whether a ROWD must be submitted to the Water Board. To request such a consultation, please contact
Christine Boschen, Section Leader, Watershed Management Division (510) 622-2346 or [email protected]
We respect the need for permit streamlining and clarity in what standards apply. When a consultation is requested, we will either 1) confirm that the OWTS can be permitted by the local agency consistent with its current program, or 2) require the applicant to apply for a Water Board permit. In either case, we will respond in a reasonable time frame.
Alameda County Department of Environmental Health
OWTS GIS IMPLEMENTATION PLAN
Prepared for: Alameda County Department of Environmental Health
November 21, 2014
PREPARED BY:
PSOMAS 1500 IOWA AVENUE, SUITE 210 RIVERSIDE, CALIFORNIA 92507
PREFACE ii
TITLE PAGE
Document Name: OWTS GIS Implementation Plan Publication Date: November 17, 2014 Contract Number: UR420797 Project Number: Psomas Project No. 4ALA010142 Prepared by: Brian Hoefer, Psomas Craig Gooch, Psomas
Psomas Document Contact Brian Hoefer PSOMAS 1500 Iowa Avenue, Suite 210 Riverside, CA 92507
Phone Number: 916-500-3730 email: [email protected] Web Address: www.psomas.com
Psomas Management Certification
______November 21, 2014
Brian Hoefer Date Psomas Project Manager
PSOMAS
PREFACE iii
AUTHORIZATION MEMORANDUM
The undersigned have carefully reviewed this report and note the status of report acceptance.
Department of Environmental Health Certification Please check the appropriate statement:
______The document is accepted. ______The document is accepted pending the changes noted. ______The document is not accepted.
Approval by Core Project Team
______
Dilan Rowe Date Project Manager
______
Hana Al Bariazi Date Business Analytics and Strategy Coordinator
PSOMAS
PREFACE iv
PREFACE
PROJECT BACKGROUND The Alameda County Department of Environmental Health (DEH) operates various programs to protect the public, including oversight and management responsibility for the review, approval, and performance monitoring of on-site wastewater treatment systems (OWTS) throughout the county. Initial discussions with Psomas revealed that DEH had a vision for data management and modeling to support their OWTS program that could benefit significantly from the development of a Geographical Information System (GIS).
Alameda County has a mature GIS program managed by the Information Technology Department (ITD) for which Psomas has been contracted to provide on-call technical consulting services. In September 2014, Psomas was engaged to help DEH design a GIS program, as well as provide ad hoc technical GIS implementation support. This report is the main deliverable from that first task to develop a GIS program supporting OWTS.
Psomas conducted two days of onsite workshops at DEH on September 29-30, 2014. The meeting notes became the basis for the development of this Implementation Plan for the development of GIS at DEH.
PURPOSE & SCOPE OF THE DOCUMENT The document’s purpose is to define the business needs for developing a GIS at DEH and layout a vision for what that system would include, as well as provide a recommended high-level implementation plan, schedule, and rough costs for its development. It is anticipated that each task recommended in this plan would begin with a design / scoping process that would elicit more refinement and detail as each is engaged in the recommended development.
INTENDED AUDIENCE This document is intended for internal use by DEH staff, as well as authorized key staff from other Alameda County departments and external agencies that DEH wishes to engage. This document is not intended for wide-distribution or public consumption.
DOCUMENT VERSION CONTROL It is the reader's responsibility to ensure they have the latest version of this document. Questions should be directed to the owner of this document, or the project manager.
REVISION SHEET
Release Name Date Revision Description Rough Draft 10/17/2014 1.0 Initial Draft for Internal Review First Draft 11/21/2014 1.1 First Draft for DEH Review
PSOMAS
TABLE OF CONTENTS 5
Table of Contents
Title Page ...... ii Authorization Memorandum ...... iii Project Background ...... iv Purpose & Scope of the Document ...... iv Intended Audience ...... iv Document Version Control ...... iv Revision Sheet ...... iv 1 Executive overview ...... 7 2 OWTS Business Needs ...... 7 2008 OWTS Regulation...... 7 LAMP Certification Program ...... 8 The Permit Approval Process ...... 9 Departmental Processes and Procedures...... 9 OWTS Performance Monitoring ...... 10 Program Funding Mechanisms ...... 10 3 A Vision of Future OWTS Operations ...... 10 Improved efficiency and information consistency ...... 10 Institutionalized Processess and procedures ...... 10 Integrated Information Systems ...... 11 Effective Tools and Capabilities ...... 11 Staff Training and Support ...... 11 Technology Infrastructure ...... 11 4 Users and Roles ...... 12 5 Information Technology Strategy ...... 12 6 APPLICATION Solutions and Functions ...... 13 7 GIS DATASETS ...... 15 8 Implementation plan ...... 17 TRACK 1: Collect and Manage Data ...... 18 TRACK 2: Implement Data Driven Processes ...... 23 TRACK 3: Implement Advanced Solutions...... 27 9 Implementation Schedule ...... 29 10 Organizational Impact and costs ...... 30
PSOMAS
TABLE OF CONTENTS 6
PSOMAS
Alameda County Department of Environmental Health 7 OWTS GIS Implementation Plan
1 EXECUTIVE OVERVIEW
The Department of Environmental Health (DEH) has responsibility for administrating Onsite Wastewater Treatment Systems (OWTS) to protect water quality and public health. A modest OWTS program received a significant boost in 2008 when the Alameda County Board of Supervisors adopted a new ordinance and regulation for OWTS that significantly expanded the scope of DEH to issue both construction and operating permits for septic systems. In addition, the State Water Resource Control Board (SWRCB) issued its OWTS Policy in June 2012 that introduced new state-wide requirements for OWTS classification and management. Understanding that statewide standards might be either too- restrictive or not protective enough for local conditions, the SWRCB established the Local Agency Management Program (LAMP) that would allow agencies like DEH, when they become certified, to establish and administer local OWTS standards that better meet the needs of their local community. DEH has been expanding its staff and capabilities in recent years in response to both of these needs.
Although it is the responsibility of the developer/owner/designer to ensure that the OWTS is designed, constructed, and operated in accordance with applicable ordinances and regulations, it is DEH that is responsible for verifying compliance and system performance. In order to ensure that the OWTS design is appropriate, it is essential that DEH staff understand, for example, the: soil characteristics, installation depth, groundwater level, and drainage properties of the installation site. And, in order to ensure that setback distance requirements have been met, DEH needs to maintain a full inventory and know the precise location of the local water wells and surface water intake points in the area, as well as the locations of surrounding OWTS installations. These are geospatial datasets to be constructed and spatial analysis problems that can most-readily be solved by developing a Geographical Information System (GIS), the content and planning of which this report is expected to significantly advance.
High-level strategies and implementation planning for the development of a GIS and integrating it into the appropriate land development permitting process supporting the OWTS program are included in this report. The plan calls for maximum use of internal staff and out-of-the-box technologies that DEH largely already has access to, as well as leveraging existing GIS systems and capabilities that have already been established within Alameda County. This would be supplemented with outside technical consulting, including modest as-needed custom programming and scripting, in order to help make the system sustainable over the long-term, as well as more efficient to construct.
2 OWTS BUSINESS NEEDS
This section of the report presents the business needs of the Department pertaining to the OWTS program. Identification of OWTS business needs is important as a foundational understanding of the Department’s responsibilities. In later sections of this document, methods for supporting the business needs are presented based on GIS and IT related technologies.
2008 OWTS REGULATION The onsite wastewater treatment program received a boost in 2008 when the County adopted the Alameda County Onsite Wastewater Systems Regulation along with a new ordinance. This new regulation allows the Department to not only issue construction permits for advanced systems, but also
Version 1.1 Psomas Alameda County Department of Environmental Health 8 OWTS GIS Implementation Plan
operating permits that will allow the Department to monitor their performance. It also includes the ability to apply deed restrictions that will be key to enforcing the new regulation.
LAMP CERTIFICATION PROGRAM OWTS’s are under the regulation of the State Water Resources Control Board (SWRCB, the “Board”). However, the Board has recognized that establishment of a single set of criteria for OWTS across the entire state would either be too restrictive or not be protective enough under some circumstances. Therefore, to accommodate local conditions, the SWRCB is encouraging local agencies to submit management programs “Local Agency Management Programs” (LAMP) for approval, and upon approval, then manage the installation of new and replacement OWTS under that program.
A rough summary of what is to be included in a Local Agency Management Plan is as follows: 1. What systems are installed—an inventory of OWTS in the area. 2. Where are the failed systems, poor soil conditions, and other areas of concern? 3. What is the plan to address those issues—i.e. what are recommended solutions. 4. What is the criteria that will be applied for new or upgraded OWTS?
Just some the conditions that need to be analyzed in order to determine areas of concern and determine suitable OWTS installation criteria, include: • High or low percolation rates (unsuitable soils) • Shallow soils requiring dispersal system installations closer to the ground surface than standard • Locations of high-quality waters • Areas of high OWTS density • Areas of existing OWTS that predate any adopted standards for design and construction, including cesspools • Areas of existing OWTS that violate state-mandated minimum setbacks • Areas of high domestic well usage • Areas with fractured bedrock • Areas with poorly drained soils • Surface waters that are vulnerable to pollution from OWTS • Surface waters within the watershed that are listed as impaired for nitrogen or pathogens
In addition, the local agency must maintain a water quality assessment program to determine the operational status of OWTS and evaluate the impact of discharges to groundwater and local surface water quality. The types of monitoring data is expected to include: • Well samples from domestic wells • Public water system sampling reports • Water quality testing reports done at the time of new well development • Water sampling performed as part of a NPDES permit • Data contained in the California Water Quality Assessment Database • Groundwater sampling performed as part of Waste Discharge Requirements • Groundwater data collected as part of the Groundwater Ambient Monitoring and Assessment Program (available from GeoTracker)
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• Real estate transfer samples
Unless exceptions have been granted, the local agency is expected to enforce the following minimum setbacks: • 150 feet from a public water well • 200 feet from a public water well when the effluent dispersal system exceed 10 feet in depth • 600 feet from a public water well when the effluent dispersal system exceed 20 feet in depth • 1,200 feet within the catchment basin of a public water system surface water intake point • 400 feet within the catchment basin from the high water mark of a reservoir, lake, other flowing water body that is a water source for a public water system
DEH is preparing a draft Local Agency Management Plan to submit to the Board for review and approval in the near future. Recertification would then occur every three years after initial plan approval.
THE PERMIT APPROVAL PROCESS OWTS permit approval processes are being reviewed to improve regulatory oversight and Departmental involvement at the best times during project review. In the recent past on-site wastewater treatment has not been adequately represented in the construction, re-grading, remodel, or demolition approval processes, resulting in DEH getting involved late in the process that can be disruptive to the project (as leech fields can only be constructed on undisturbed ground).
Progress has been made to alert the Department on new construction permits, but there remains work to be done on re-grading, remodeling, and demolition permits. Interdepartmental coordination with the Public Works Agency and the Community Development Agency has resulted in OWTS being included in plan sets. However, further work is needed to assure the Department is included in all plan review processes that may be impacted by OWTS policies.
DEPARTMENTAL PROCESSES AND PROCEDURES The Department is reviewing and strengthening processes and standards based on engineering-based strategies and approaches. Additionally, customer engagement procedures are being standardized and information is being prepared to communicate OWTS program information.
Processes are being designed so that only face-to-face meetings occur at the Department at key intervals (particularly early in the plan review process) with both owner and design consultant required to be in attendance. At present, owners and design consultants are taking the liberty to ask questions and send emails at any point in the process, rather than submitting at specific times during the project that would help streamline review processes.
The Department is in the process of creating new fact sheets that will detail the new processes for residents, design consultants, and also real estate professionals, e.g. “Remodeling and Your Septic System”, “Odor Complaints?”, “Failed Septic System?”, and so forth.
The Department’s website is being enhanced to represent information about the OWTS program and processes. These enhancements will improve communication with property owners and their consultants regarding the program.
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OWTS PERFORMANCE MONITORING The Department will need to establish methods and tools to help track and oversee routine performance monitoring of advanced systems. Advanced system users are now required to provide maintenance records and perform performance monitoring of effluent (versus influent). The County has only issued one operating permit, so far. However, since the performance data will ultimately need to be reported to the SWRCB, it is on Department’s critical path to establish a solid framework for performance reporting (predominantly by advanced system operators) that ensures that quality data is collected and managed appropriately.
PROGRAM FUNDING MECHANISMS A significant challenge for the Department moving forward is finding additional funding mechanisms that are fair and equitable to help support OWTS programs such as LAMP. Perhaps the majority of the funding should come from property owners that have septic systems and/or that have private water wells. However, many of those property owners simply cannot afford high fees or special taxes. Public water supplies are also being protected, so a special tax on water consumption could also be considered.
3 A VISION OF FUTURE OWTS OPERATIONS
The Department of Environmental Health is a regulatory agency responsible to see that plans and built systems comply with regulations. It is the responsibility of the property owner to hire the necessary surveyors, engineers, geologists, hydro-geologists, OWTS design specialists, and so forth, to develop and implement an OWTS design that meets current regulations. The Department’s primary role is to verify that installed OWTS is compliant with those regulations and, particularly with advanced systems, verify that the OWTS is being properly maintained and operated.
Fulfilling the OWTS business needs will require a robust information system that has authoritative information necessary to comply with the Department’s regulatory responsibilities. The information will need to be reliable, accessible, and be presented in a manner that is easy to use by those who need the information.
The following statements are presented to illustrate how the OWTS program could operate.
IMPROVED EFFICIENCY AND INFORMATION CONSISTENCY Anytime a project is contested, even without litigation, it ends upon being very time-consuming and costly for DEH. In order to avoid those bad situations, DEH needs to have clarity in what they have (inventory of systems, whether they are in compliance, areas of concern, etc.) and what they are doing (processes and procedures). Then, they need to push back on owner/developers to comply with those processes and procedures (e.g. OWTS fully integrated into plans and a set meeting schedule and agenda to be covered at key intervals). Plus, continue to work to improve upon the breadth, strength, and precision of county ordinances to better protect the public health.
INSTITUTIONALIZED PROCESSESS AND PROCEDURES DEH shall seek to establish documented, institutionalized, processes and procedures that will allow staff to interact and deliberate with outside individuals and agencies using one common mission understanding and voice. Institutionalized means living documents that are fully understood and practiced as needed by all staff, while also being continually updated and improved on a regular basis.
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INTEGRATED INFORMATION SYSTEMS DEH currently has three highly-capable information systems that it can leverage to successfully complete its mission: • Esri ArcGIS—geographical information storage, retrieval, management, and analysis • FileNet P8—document storage, retrieval, and management (workflow) • Decade EnvisionConnect—regulatory data management
The near-term goal is to have these systems working together as seamlessly as possible, with: • Documents stored in FileNet easily accessible from both EnvisionConnect and GIS • Regulatory data stored in EnvisionConnect readily available for either direct access or download (as appropriate) for spatial analysis within the GIS • Data integrity maintained in all three systems with firmly-established procedures for data and system updates
EFFECTIVE TOOLS AND CAPABILITIES A number of applications and tools would be available to help DEH staff perform their specific duties, including: • Information Retrieval—information associated with any OWTS will be readily-available at a (GIS- based) mouse click, including project plans, correspondence, permits, fees, system performance data, and so forth. • Data Analysis—data in one system (e.g. performance data from EnvisionConnect) is readily available for GIS display and analysis. • Site Review—review of development permits is done all electronically, including: plan markup, follow-up actions, and inter-departmental review workflow and sign-off. • Annual Inspections—inspection and performance data from system operators is submitted electronically. • State Reporting—reporting to the State is mostly automated through scripts/reporting from DEH databases.
STAFF TRAINING AND SUPPORT DEH staff are well-trained and empowered to develop new processes and tools (which are then documented and formally adopted as an organization) that support and enhance the OWTS program, using external consulting support (nominally) as needed for support on infrequent and/or complex tasks. Staff are also cross-trained as appropriate to help maintain system service levels, reliability and sustainability.
TECHNOLOGY INFRASTRUCTURE The technology infrastructure is based upon capable and mature software systems that are backed by well-established and reputable software companies. The focus is on procedures and processes that are able to leverage core technology with minimal reliance on customized software applications that would need to be maintained by DEH. And, where there are needed customizations, leverage previous development efforts and share responsibility for maintenance with other County departments. The overall goal is to keep the technology infrastructure as flexible (maintainable), and thereby, sustainable over the long-term.
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4 USERS AND ROLES
The implementation of LAMP by DEH affects various other regulatory bodies, as well as commercial developers, engineering firms, system design specialists, system operators, real estate agents, and property owners. The potential users of the GIS and IT based datasets, processes, and tools that DEH will be developing in support of LAMP include: • DEH—used internally in various roles to ensure OWTS systems are in compliance with the applicable ordinances and regulations • DEH, PWA, CDA—county agencies involved in permitting • SWRCB—as the ultimate authority over OWTS within the state, repository of state-wide water quality datasets, and manager of the LAMP program • Zone 7—other regulatory agencies with common interests, overlapping missions, and goals • Land developers and individual property owners—OWTS owners • Professional engineering / consulting firms—geologists, hydro-geologists, surveyors, technical specialists, and so forth, that are designing and overseeing construction of OWTS systems • Advanced System Operators—commercial firms contracted to operate and maintain advanced OWTS systems • Real estate agents—researching properties for clients
5 INFORMATION TECHNOLOGY STRATEGY
Information technology can help the Department fulfill its business needs by organizing, managing, analyzing, and presenting information. The information needs of the LAMP require a significant amount of information representing county-wide and site-specific information. The information needs are very broad and detailed including environmental, policy, OWTS systems, projects, and inspection type data. Much of this data is relevant to a specific location or area within the county, thus making Geographic Information Systems (GIS) a relevant technology supporting the Department’s needs. With the above business needs in mind, the following strategies are recommended for organizing, managing, analyzing and disseminating information related to the OWTS program:
Empower a Core Team. The types of data that are collected and analysis that will be performed are likely to change and potential grow over time in an environment of changing technology, policies, and regulations. In this dynamic situation, our general recommendation is to equip a core team with feature- rich software, capable hardware, and adequate training that will empower them to develop unique solutions to analysis problems and be flexible to the changing needs of the Department.
GIS-centric Information Inventory and Analysis. Much of DEH’s daily activities will be associated with a specific OWTS, property line, building, well, water body, community, contaminant source, area-of- concern, and so forth, which are geographically-dispersed and inter-related that would benefit greatly from GIS technology. ArcGIS technology is also very adept at integrating with external databases. So, using a GIS-centric strategy to the information technology infrastructure is warranted.
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Advanced GIS Analysis Capabilities. In its role as a regulatory agency, DEH is responsible for collecting and analyzing data on OWTS, and other sources of pollutants, as well as the public water wells and surface water intake points that are being protected. In regards to the surface water intake points, the LAMP program also requires that DEH understand their high-water characteristics and full-catchment areas in order to effectively enforce minimum required setbacks. This will require good-resolution terrain data and the use of advanced GIS software.
Sub-meter GPS for Accurate Field Data Collection. Due to the typical mapping methods and resulting inaccuracies for many GIS layers, generating setback areas for wells and water bodies would require that DEH include a significant buffer margin in order to ensure that there are limited false negatives. Creating a large buffer would, of course, also generate an increased amount of false positives (that would need to be investigated, incurring additional costs to the owner). We are recommending that DEH adopt the standard that wells, surface water intake points (and associated water bodies), and the locations of OWTS installations be mapped using sub-meter GPS to tighter accuracy standards (e.g. +- 1 m), then the buffer margin could be safely made smaller reducing both false negatives and positives.
GIS, EnvisionConnect, and FileNet System Integration. As much as possible, DEH should work to ensure that these systems work efficiently together to meet the collective data and functional needs of the OWTS program. At the minimum, there should be basic data interchange compatibility with shared key identifiers (e.g. ON number) that are properly managed to maintain their integrity. In addition, DEH should look to acquire application-level functional integration where it is cost effective so that everyday tasks are easier to accomplish for DEH staff as well as the many other potential users of this information both internal and external to the County.
Leverage Existing County Infrastructure and Applications. Alameda County has invested significantly in both ESRI ArcGIS and FileNet centralized (web) server infrastructure, now hosted by ITD, that DEH will want to leverage. There are also several projects underway that will be providing basic integration between ArcGIS Server and FileNet P8 that DEH could use as a template for its own web application(s).
Procedures, Training, and Support for Sustainability. The recommended IT staffing strategy is to employ a small group of highly-trained individuals that have the flexibility to build and develop their own procedures for building and maintaining the data, systems, and (web) applications, using ITD and outside consultants to augment their capabilities. However, with an eye for consistency and sustainability, placing an emphasis on documenting the procedures and processes that are developed and cross-training whenever practical.
6 APPLICATION SOLUTIONS AND FUNCTIONS
The following is a recommend list of application solutions and functions that would address the stated business needs of DEH, as well as notes about how they could be acquired or developed.
Internal OWTS GIS Viewer. This would be a web-based application for internal use built using the framework already established by ITD consisting of Esri ArcGIS Server and Geocortex technology. Major functions would include: • GIS layer display (including choice of parcels or ortho-photography as basemap) and navigation
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• Access to Pictometry (oblique images) • Search for address, parcel, ON Number, and so forth • Access to EnvisionConnect OWTS system record and related performance data • Integrated FileNet access to electronic project files • One-Click Property Report (regulatory and other information about the property, described in more later in this document) • Site Analysis Report (map-based setback analysis, described in more detail later in this document)
External OWTS GIS Viewer. This would be an external-facing version of the internal website that would feature datasets and functions that are a subset of the internal site, with perhaps other datasets and functions added intended only for public consumption, such as: • Extract and download contours (the immediate area around a site used for preliminary planning) • Create “D” size drawing (PDF) for preliminary planning
Data Management. Management of datasets would be accomplished primarily using out-of-the-box native application tools designed for that purpose with custom scripts to automate repetitive and/or challenging tasks as may be deemed necessary: • ArcGIS Desktop—use ArcMap, ArcCatalog, and ArcToolbox applications to maintain spatial data, using geo-processing (Python) as may be needed for automation. Includes: o One-time investigation of supplemental assessor data looking for attributes that would indicate there was improvements to the property or has a septic system o On-going creation of areas of concern (e.g. terrain, jurisdiction, concentrations of septic systems, groundwater conditions) o On-going evaluation of mitigation measures (connection to sewers, opportunities to form community systems, installation of advanced systems, etc.) o Regular GIS data exchange with other agencies (e.g. Zone 7, SWRCB, cities, special districts), including collection of sewer system infrastructure o Import of CAD data (site and OWTS design) as part of the land development permit process o Providing regular geocoding assistance to EnvisionConnect (DEH would like OWTS points to be shown at the centroid of the parcel when initially geocoding) o As needed evaluation and implementation of assessment fees (assessment district modeling, formation, and management • Trimble GPS—use Trimble hardware/software solution to gather field data and import into GIS format. • FileNet—use web-based tool to load and catalog project documents and correspondence. • EnvisionConnect—use main application to inventory OWTS (with matching GIS points), process inspections, and manually record performance data. Use scripts (SQL) or programming as needed for import of performance / monitoring data from an O&M program (possible submittals to DEH website) and for export of data for reporting to the SWRCB.
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7 GIS DATASETS
This section presents recommendations for GIS data development (or acquisition), data sources where they are known, as well as management considerations, as applicable:
OWTS Inventory Essential to the OWTS program will be a more complete inventory of systems. At present, only a portion are accounted for in the project files and EnvisionConnect. Sources of information on existing systems are likely to be few and of poor quality as many systems were installed long before there were any regulations or ordinances. Plus, researching records of individual connections to sewer systems could be labor intensive. Therefore, a presumption is that the easiest way to improve the inventory is to discover systems them through analysis of ancillary datasets, such as: • Look at possible un-sewered communities and individual parcels that are too far from any existing sewer line to possibly be connected • Look at billing/tax records to see which parcels are paying sewer connection or any special assessment fees (e.g. for community systems) • Look at septic pumping records
Attribute data that DEH would like to have on each system includes: • ON number—primary identifier and foreign key to EnvisionConnect and FileNet • Street Address • Year Installed • Standard or Advanced System • Type of system (e.g. Advantex) • Permitted_YN—whether the system was permitted or not. • Permit No. • SWRQB_Tier: o 0 = Existing OTWS o 1 = Low-Risk New or Replacement OWTS not covered by LAMP o 2 = LAMP approved OWTS o 3 = Impaired Areas o 4 = OWTS Requiring Corrective Action
OWTS Components The individual components of the OWTS are important for validating minimum setbacks: • Infiltration trenches • Seepage pits • Dispersal fields
OWTS does not need depth, dimensions, or other attributes, only the ON number.
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Moratoriums Areas were OWTS have been banned. There is only one area at present, Happy Valley. DEH would like to lift moratorium so that advanced systems can be constructed.
Containment Sources Typical sources of nitrates, such as the following that can be created from land use data: • Wineries • Golf courses / driving ranges • Parks • Horse stables / boarding • Dog kennels
Historical Farming A GIS layer of historical farming activities, such as old chicken farms. Generated by Zone 7.
Nitrate Plumes Polygons of known high concentrations of nitrates. Generated by Zone 7.
Areas of Concern Areas of concern would be generated through analysis of available data sources, including: • High seasonal ground water levels • Unsuitable soils for septic • Fractured bedrock • High density of septic systems
Management Entities A map of the jurisdiction of various management agencies that have the potential to manage a community system.
Wells Public, private, as well as monitoring wells—the preference would be that all groundwater monitoring wells be “owned” and managed by Zone 7 Water Agency (Alameda Flood Control and Water Conservation District) as a separate database that then DEH has direct access.
Water Quality Monitoring Data Water quality sampling data from wells, hopefully a dataset available from Zone 7 or SWRQB (GeoTracker).
Setbacks Polygons created by buffering well and surface water features (including wetlands) various setback distances to be used primarily to alert owner/designers (everyone) during in the permitting process, as well as real estate agents through public facing websites (with disclaimers about accuracy).
Sewer Systems Copies of sewer system data from partner agencies (development already in progress) used to evaluate possible connectivity to sewers.
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Soils Used to establish areas of poor soil suitability.
Endangered Species Used to establish wetland setbacks.
Commercial Food Facilities A polygon layer for altering to alert owner/designers during in the permitting process that DEH will need to review.
Specific Plan Areas Areas that have development potential—generated by CDA.
Conditional Use Permit Large facilities that must use port-a-potty during large events. Could be used to alert owner during permitting process.
Pumping Activities Solid waste is collecting data on what gets pumped and where it disposed. Perhaps they also have a record of who was pumped (link to parcels). This data could then be analyzed for frequency (or no record) of pumping to help detect failed systems. Concentrations of failed systems could become areas of concern.
Geology Used to find areas of concern (e.g. cracked bedrock).
Demographic Data Useful in determining economic vitality of areas potentially subject to assessment fees.
Recommended Solutions Polygons showing the recommended solutions to areas of concern used for LAMP program and public outreach, such as: • Connection to sewers • Installation of advanced systems • Formation of community treatment systems
And how those solutions might be funded: • Proposed assessment districts
8 IMPLEMENTATION PLAN
The following implementation plan is organized into three tracks and within those tracks a series of tasks that roughly represent the recommended sequence for implementation. The tracks overlay each other so that the key benefits of the one track can begin to provide a return to another track as data is collected and refined.
Each track and task is presented as a brief narrative of the activities and outcomes: • Track 1—establishes the basics of collecting, developing, and analyzing OWTS datasets using ArcGIS desktop software, FileNet, EnvisionConnect, GPS equipment, with associated user training, that will be at the heart of the OWTS program. Specific tasks to be accomplished include:
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o Update Core GIS Software o Obtain GPS Hardware and Software o Create Logical and Physical Geodatabase Design o GIS Data Development o Manage Project File Document with FileNet o Integrate EnvisionConnect with GIS Capabilities o Obtain Training and Technical Support o Establish Sustainability • Track 2—focuses on leveraging the GIS datasets developed in Track 1, along with ArcGIS web technology established by ITD, to create web applications that drive OWTS processes and have the potential to reach a wide audience of end users, including: outside regulatory agencies, developers, consulting firms, and real estate professionals. Specific tasks to be accomplished include: o Create Internal GIS Viewer o One Click Parcel Report o Create Public Assessable Website and Outreach • Track 3—addresses advanced applications that could be created along-side the more fundamental datasets and functionality developed in tracks 1 and 2. Specific tasks to be accomplished include: o Establish O&M Program o As-built Submission Requirements o Digital Plan Checks o Site Analysis Report o Implement Field Inspections
A project schedule in the next section represents a high level view of the timing and phasing recommendation for each track and task.
TRACK 1: COLLECT AND MANAGE DATA Track 1 is focused on establishing a core GIS program for OWTS, including: • Upgrading ArcGIS desktop software • Developing a conceptual geodatabase design • Developing, analyzing, and managing GIS datasets using ArcGIS desktop software • Collecting data in the field using GPS equipment • Storing documents within FileNet and preparing for linking to the GIS • Storing information within EnvisionConnect and preparing for linking with GIS • Obtaining user training • Documenting processes and procedures for long-term sustainability
Upgrade Core GIS Software GIS development at DEH has so far been centered on getting familiar with the ArcGIS Desktop software and gathering together copies of available GIS datasets from partner agencies. Approximately 2,700
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OWTS projects (perhaps less than half of the total systems in the county) that have been roughly mapped (i.e. geocoded to a street centerline based geocoding service).
Staff at DEH currently have exclusive access to the following ArcGIS desktop software licensing: • ArcGIS Desktop Basic—one stand-alone license (Hana) • ArcGIS Desktop Basic—one floating (shared) license (Natalie)
In the expansion of the GIS program as envisioned, it is probable the DEH staff could run into some limitations of using only basic licenses (e.g. inability to create feature-linked annotation, direct editing of related tables, ability to edit geometric networks, ability to edit data stored in SDE, etc.). DEH should be prepared to either arrange for shared access or upgrade an existing ArcGIS license to the following: • ArcGIS Desktop Standard—one floating (shared) license or stand-along license.
The following ArcGIS software would be useful to support terrain processing and watershed analysis required to create surface water intake setbacks: • ArcGIS 3D Analyst—one floating extension • ArcGIS Spatial Analyst—one floating extension
3D Analyst is also necessary for quality 3D rendering that might prove useful to DEH for creating better visuals of surface and subsurface terrain as part of its public outreach.
Psomas recommends DEH seek outside support in the creation of setbacks for surface water intake points (or 3D rendering), instead of investing in advanced software and training that would not be frequently utilized.
Outcomes: • Improved GIS data management and analysis capabilities supporting LAMP
Obtain GPS Hardware and Software Although the Department may not be able to afford to hire inspectors and embark on a full-fledged field inspection program at this time, we feel that existing personnel could begin collecting precise location data using GPS anytime they are in the field and could also engage in regular field trips to collect precise location data as needs arise.
We recommend that DEH acquire GPS receiver(s) and software to enable efficient and accurate collection of site specific location data (leach fields, tanks, etc.). The Geo series from Trimble has proven over time to be a highly effective tool for non-surveyor types to use to collect accurate point, line, and polygon data in the field. The Juno T41 Series provides a no frills 1 to 2 meter accuracy at a reasonable cost. The GeoExplorer 7 Series is GNSS ready (accessing many more satellites making collection much easier) and has real-time (with a cellular connection) sub-meter accuracy, which is plenty accurate enough for DEH’s purposes. The Geo 7 Series also adds Floodlight technology that helps process low- strength signals (e.g. under heavy tree cover), which can come in handy, and is capable of centimeter accuracy through software upgrades.
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Juno T41 Series - or - Geo 7 Series
With either Trimble unit, it is recommended that DEH license the Trimble GPS Pathfinder software that facilitates transferring GIS/GPS data on to and off the GPS unit. The Pathfinder software can also be used to post-process the GPS data to improve accuracy if the real-time cellular connection was not available or had issues in the field.
Outcomes: • GPS capability supporting precise measurement of OWTS, well, and water body locations • Knowledge supporting potential updates to regulations and ordinances
Create Logical and Physical Geodatabase Design At the minimum, DEH should develop a conceptual geodatabase design that depicts object and feature classes with key identifiers and relationship classes to tables within external systems (e.g. EnvisionConnect). This will help everyone either building or using the system to understand where data is to be stored and the relationships between datasets.
DEH could also create a physical design that includes definitions of all attributes, domains, and sub- classes (if needed). If a physical design is created, there are a variety of templates and tools from Esri for creating geodatabase designs and generating empty database schemas from those designs.
Descriptions of the datasets (e.g. owner, description, update frequency, etc.) could be included in the conceptual design. However, ultimately this should be entered as metadata. There are readily available built-in tools for creating and managing metadata within the ArcGIS Desktop software.
GIS Data Development GIS layers to be developed (or acquired) were identified during the needs assessment and previously described in more detail within Section 7 of this document, namely:
• OWTS Inventory • Management Entities • OWTS System Components • Moratoriums • Wells • Contaminant Sources • Water Quality Monitoring Data • Pumping Activities • Nitrate Plumes • Geology • Areas of Concern • Demographic Data Historical Farming
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• Setbacks • Commercial Food Facilities • Sewer Systems • Specific Plan Areas • Soils • Conditional Use Permits • Endangered Species
It is envisioned that these layers could be primarily developed using in-house resources and out-of-the- box GIS applications and tools with some technical implementation support from outside consultants. Additionally, some geo-processing model definition (using Model Builder) and/or Python scripting is expected to prove advantageous.
Outcomes: • Development of GIS data layers in support of LAMP requirements • Development of GIS data layers supporting permit processing (One-click Parcel Report)
Manage Project File Documentation with FileNet Whenever DEH becomes involved with a planned or existing OWTS, be it a permit process or citizen complaint, DEH staff create a paper-based project file and assign an “ON” number, as well as create a new OWTS record within EnvisionConnect. In this manner, DEH has collected information on about 2,700 OWTS in the county, which is only a portion of the systems that are installed.
DEH should strive to become fully electronic, with all reports, plans, and correspondence, whether they were received in paper or electronic form, being stored and managed within FileNet. Important original (signed) paper records should still be stored and maintained within project folders, but only accessed as- needed on a limited secondary or backup basis (helping to preserve the integrity of the hard copy files).
All OWTS document classes within FileNet should have an “ON” number that will allow the electronic file to be linked to (or searched from) GIS and EnvisionConnect.
There is a renewed effort underway to convert the paper records to digital. The project files will be cleaned-up and inventoried prior to scanning (a significant effort) with high expectations for ultimate success.
Once the project files have been cleaned-up, scanned, and loaded into FileNet, DEH will need a documented process and procedures for managing documents moving forward from that point in time.
Outcomes: • Project files loaded as electronic documents into FileNet • Electronic project files within FileNet linked to EnvisionConnect OWTS records • Documents searchable using FileNet tools (and API) – ready for website development (8.2.1) • Document management processes and procedures created supporting document integrity and system sustainability
Integrate EnvisionConnect with GIS Capabilities EnvisionConnect is designed to track and organize much of the activities an agency like DEH engages in order to manage a regulatory program like OWTS, including: compliance tracking, permitting and
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licensing, fees/charges/financials, complaint management, activity tracking, workload assignment, document management, and so forth.
DEH is currently using EnvisionConnect mostly to process service requests (complaints) and to track labor (dailies) that are invoiced against projects. There are templates setup for groundwater well monitoring and performance monitoring of systems, percolation tests, as well as some other activities, that are not being used at present. The permitting and site inspection modules are being used by other divisions, but not by OWTS division staff.
The templates not-in-use have the flavor of catch-all generic templates that have every field any client has ever asked for related to those activities. So, there many fields that are not needed or relevant to DEH. The conclusion has been that EnvisionConnect will need to be reconfigured to make those extended functions really useable.
DEH needs to re-evaluate and possible change its procedures for its use and redesign/reconfigure the data schemas to match the new requirements. Most notably, EnvisionConnect could be used in the future to store and manage advanced system performance data. Performance monitoring of advanced OWTS should be tracked by DEH (using EnvisionConnect) and tied to the project. Getting that information to the SWRQB cleanly in the future is a key (re)design consideration.
As EnvisionConnect has a central role in the management of the OWTS program, integration between GIS and EnvisionConnect will likely be a primary GIS development project activity. Integration with EnvisionConnect (performance data) should be reasonable as they have a published Application Programming Interface (API) and, if necessary to achieve the desired functionality, could be integrated through its backend data store (SQL Server 2008).
EnvisionConnect has the ability to link to electronic documents that DEH wants to utilize (loading the electronic documents into FileNet) that would be achieved in the previous task.
Outcomes: • Redesign/reconfigure of EnvisionConnect to suit OWTS needs • Ability to link GIS features of OWTS to EnvisionConnect records – ready for website development (8.2.1) • Electronic project files within FileNet linked to EnvisionConnect OWTS records
Obtain Training and Technical Support Development of most of the required GIS layers will only require fairly common GPS and GIS data processing, analysis, management skills, and techniques (described in the previous section). Esri offers a plethora of instructor-led and web-based course user training options. Typically, it takes at least a week or two of instructor led (or equivalent web-based) user training to become a proficient GIS data editor analyst. The following are some of the skills that DEH staff will want to master: • Understanding of datums and projections, including how to translate datasets • Forming and managing metadata • Designing and creating new geodatabases, feature datasets, features, and objects • Importing and exporting shapefiles and other data formats such as CAD to and from a geodatabase • Editing related tables from the GIS (requires Standard license) • Editing points, lines, and polygons • Creating and editing geometric networks (sewers, drainage, hydro – requires Standard license)
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• Forming spatial and tabular queries • Forming data relationships - joins and relates • Performing overlay analysis • Creating spatial buffers and performing spatial clips • Defining symbology and thematic mapping • Creating labels (including using label statements) • Creating and editing feature-linked annotation (requires Standard license)
In addition, user training in the use of GPS hardware and software (as recommended by the manufacturer) is highly recommended.
Training in Microsoft SQL Server and SQL based queries could prove highly beneficial in achieving integration between Esri ArcGIS Desktop and EnvisionConnect that uses SQL Server (2008) as its data store. However, this is another area that DEH should choose to outsource as the skill would not be needed daily.
It is recommend that DEH engage with GIS consulting firm for technical support on an on-call service basis to help with the initial learning curve and inevitable data issues. Once trained and after an initial boost period of readily available technical support, DEH staff should be able to build and maintain these datasets over time working closely with various partner agencies, without requiring much other outside assistance.
Outcomes: • Users adequately trained to collect, develop, and manage GIS data using Esri and GPS software • Enlist consulting firm for technical support on on-call basis during start-up (first year)
Establish Sustainability Deployment of GIS and GPS technology requires investment in the training and accumulated experience of the core team. This capability could be lost or compromised when an employee is unable to work or leaves the Department. To help mitigate this risk, DEH will want to document core procedures, perform good house-keeping and management of project files, maintain excellent metadata, and allow for cross- training of employees.
Outcomes: • Documented processes and procedures, including: data, metadata, and project file management • Regular cross-training of employees
TRACK 2: IMPLEMENT DATA DRIVEN PROCESSES Track 2 focuses on leveraging the GIS datasets developed in Track 1, along with ArcGIS web technology established by ITD, to create web applications that drive OWTS processes and have the potential to reach a wide audience of end users, including: outside regulatory agencies, developers, consulting firms, and real estate professionals.
Create Internal OWTS GIS Viewer DEH will need a readily-accessible method of retrieving available OWTS related information, including LAMP-related information and datasets, plus wells and water bodies that are being protected. The recommended strategy, and acknowledged industry best practice, is to make GIS the unifying element to the needed system integrations.
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Psomas recommends that DEH create use a web based GIS viewer to provide easy access to this information. Alameda County ITD has invested in a GIS viewer framework that DEH could easily leverage. Other county departments such as the Assessor and Public Works, have integrated GIS and FileNet functionality.
This approach to delivering data through a GIS viewer leverages previous GIS development efforts at Alameda County. Existing GIS viewer development for Public Works and Community Development may be an appropriate framework for extending functionality to address DEH business needs.
Alameda County’s GIS Viewer
Outcomes: • One platform to access various OWTS related datasets • Easier-to-use versus desktop software • Support for unrestricted numbers of users • Easy access to most recent Alameda County departmental datasets • Basis for possible public website • Basis for possible secured public web services (to be consumed by external agencies)
Integration with Land Development Process—One-click Parcel Report A pressing need of DEH is to become involved much more reliably and earlier in the land development permit processes for new construction, remodels, demolition, and grading. Since these processes are primarily owned by other departments, namely PWA and CDA, DEH needs to be integrated into those processes in a manner that is reliable, un-obtrusive, but most importantly, early and effective.
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There is an initiative with some momentum behind it already to create a website called “One-click Parcel Report” that would be based upon a similar website that Psomas developed for Riverside County and the City of Dublin.
The concept behind the website is exceedingly simple. The user clicks/selects a parcel and an on-screen (PDF format) report is generated that provides nearly every bit of publically available information about that parcel that they County has accessible from within its GIS, including: • Parcel information (APN, address, owner name, lot size, etc.) • Planning information (planning areas) • Environmental areas of concern / special planning districts • Fire zones • Development fees (assessment districts) • Transportation agreements • Hydrology (flood zone, flood district) • Geologic (faults nearby, susceptibility to subsidence, paleontological sensitivity) • Miscellaneous (school district, census tract, misc. ordinances, tax rate areas). • Permits (current and historical with status) • Planning cases (current and historical with status) • Code enforcement cases (current and historical with status)
The expectation is then that this website would then become an integral part of the land development review process for County staff, as well as key tool for owner, developers, and real estate professionals on a possible public version of the website.
All that would be needed for DEH to be integrated into a One-click Parcel Report website for Alameda County is for DEH to communicate its regulation domain, areas of concern, setbacks, and other requirements through GIS layers. This would take the form of polygon GIS layers that intersect / overlap the parcels, including: • Un-sewered parcels (i.e. the OWTS inventory) • Community systems
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• Areas of concern • Moratoriums • Setbacks (from OWTS, wells, water bodies)
Outcomes: • DEH tie-in to land development process • Basis for possible public website (and outreach to developers, owners, and real estate community)
Create Public Assessable Website and Outreach Public outreach will be very important program element moving forward. DEH needs to be communicating what are the issues that the community is facing (e.g. areas of concern, high densities of septic systems) and the type of solutions that DEH is recommending (e.g. connection to sewers, installation of advanced system, creating community systems). A primary method of accomplishing this is to make of same data and functionality available to the public.
To create a public website, DEH could create a scaled-down version (e.g. limited data) of the internal application described above. The public version can contain any functional element or data layer from the internal site that is suitable for public consumption, such as: • OWTS inventory • Areas of concern • Setbacks (wells, water bodies) • One-click parcel report
In addition, there could be functions added that are only intended for external use, such as: • Find my property • Hot topics • Extract and download contours (portions) • Create “D” size drawing for preliminary planning
There would be some limits of the types of information that was published. For instance, there would be a notice that there was a deed restriction, but no direct access to the document itself. Also, pumping records would not be published.
DEH would also like to specifically target outreach to the real estate agents. It is expected that real estate agents would want to take full advantage of any publically assessable information and tools that DEH disseminates on behalf of their clients. Then, when it is become evident that DEH will need to be involved, DEH will encourage real estate agents to do an in-person file review.
The existence of the public website could be promoted with a fact sheet. Likewise, this website could link to the fact sheets on the main DEH website.
Outcomes: • Outreach to the public • Tools for developers, owners, specialists, and real estate agents
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TRACK 3: IMPLEMENT ADVANCED SOLUTIONS Track 3—addresses advanced applications that could be created along-side the more fundamental datasets and functionality developed in tracks 1 and 2.
Establish OWTS Operations and Maintenance Program Although DEH has not yet issued an operating permit from the 2008 regulations, the approval of operating permits are imminent. Thus, DEH needs to establish the format and delivery of operations (performance) and maintenance data in short order. The data needs to be in a format that is highly useful to DEH and partner agencies.
In addition, the State has approved bills that allow cities and counties to opt-in to becoming a groundwater management district for the water under their footprint. Since this is likely to be challenging (chaotic) to implement, it is important that DEH firmly establish its procedures in the near future.
There are number of agencies (e.g. SWRQB, ACWD, ACFC Zone 7, EBRPD) that are involved in monitoring advanced system sites already. So, it is vitally important that DEH is able to readily share information. SWRQB might require that DEH submit sampling data via GeoTracker (or something equivalent).
East Bay Regional Park District (EBRPD) is one of the biggest users of septic systems in the area. Wineries are another.
DEH would like the submission to be either all or electronic with influent and effluent sampling data submitted electronically, if necessary, redundant to the paper submission. DEH would like to be able to easily graph performance data.
Some (most) operators have telemetry systems (e.g. Orenco). The possibility of collecting the data directly from these systems will also need to be investigated.
The possibility of creating a website for electronic submission of performance data was also discussed. It would be very useful that once a report has been submitted that that is automatically updated within Envision (i.e. in compliance with the regulation requirements).
Once the submission standards have been established on new systems, DEH would like to make those requirement retroactive on all advanced systems. Which means that all advanced system users will need to be notified as a group, which in turn means that DEH needs an accurate inventory of those systems.
Outcomes: • Establish tools and procedures for O&M data submission from operators • Establish tools and procedures for submission of performance data to SWRQB and other outside agencies
AS-BUILT Submission Requirements DEH should enhance current Alameda County OWTS Regulation to add as-built reporting requirements, including a specification for the capture of photo images, as well as horizontal accuracy standards for gathering OWTS component locations (including nearby OWTS), well and surface water intake locations, and setback measurements. One of the acceptable methods should be the use of an accurate (sub- meter) GPS.
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These additional requirements will put extra accountability on the owner/developer/design specialist to ensure the OWTS is installed in the correct location and in full accordance with the design. DEH will, of course, over time, be gradually gathering accurate information on OWTS locations, well locations, surface water intake points, and so forth, which could also be made available to owner/developers in the future. So, if an owner/developer is submitting inaccurate or false information, the submitted measurements will not add up or correlate with other data, and therefore, should easily detectable by DEH.
The enhanced regulation would also specify acceptable methods of reporting as-built information to DEH, which could direct them to a basic DEH-owned data submittal intake website.
An intermediate solution might be to require that the property owner (designer) provide a plan drawing that is tied by distance measurements to property boundaries. DEH staff would then later convert the plan drawing into GIS features. One downside of this approach is that the Alameda County parcels are not very accurate, particularly in the unincorporated areas that are served by septic systems, so the resulting GIS features would only really be spatially accurate enough to use for preliminary analysis and all results would still need to be field verified by the owner/designer.
In addition, DEH will also want a documented procedure on how staff will translate plan drawings into GIS features and then, as may be needed, translating those features to their as-built locations (once accepted by DEH).
In this fashion, DEH will be able to compare design versus as-built, as well as verify setbacks, using GIS techniques primarily based upon input provided by the owner/developer—without incurring the significant costs of developing and maintaining formal field-based inspection program.
Outcomes: • Accurate OWTS locations and pictures for evaluation/historical purposes and from which to analyze possible setback violations
Digital Plan Checks In cooperation with PWA and CDA, DEH should investigate the possibility of using a commercial software solution to automate the development plan check process making it entirely digital, including: • Import/capture of plans as a digital plan set with version control • Comments and red-line mark-ups • Support for concurrent review (including being able to view other department comments and mark-ups) • Tracking of check lists and action items for developer/owner follow-up • Enforcing approval process with digital sign-off
Research will be needed to find potential market solutions and evaluate their viability. There is the potential that no solution is found as the commercial options in this arena are limited.
Outcomes: • Implementation of a digital plan check review system (TBD)
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Site Analysis Report This would be an enhancement to the OWTS GIS Viewer to include a GIS-based setback analysis function for a selected OWTS site with graphical (map-based) as well as tabular format outputs. The tool would be developed and tested on the internal site before someday, perhaps, also being added to the external public-facing site.
Outcomes: • Addition of site analysis reporting tool to internal and perhaps external website
Implement Field Inspections At present, DEH does not have a field inspector. An eventual goal of DEH is to someday have a dedicated field inspector that could capture accurate as-built information (GIS layers) on OWTS, public wells, and surface water bodies that could be used for efficient setback analysis (i.e. without generating a ton of false positives and negatives that would need to be field verified).
DEH is currently relying upon the professional certification/registration accountability of the OWTS designer to follow-through construction of the OWTS to ensure it is in accordance with the design. This approach has a major short-coming in that there is a bunch of information about the installed OWTS that DEH would like to have, such as: • Precise GPS coordinates of the tank(s) and dispersal field(s) • Precise GPS coordinates of domestic wells in the immediate area (e.g. up to 1,200 feet) • Images of the completed installation for historical reference
Outcomes: • Implement field inspection program
9 IMPLEMENTATION SCHEDULE
The following is a sample implementation schedule for the proposed GIS implementation at DEH.
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There is considerable flexibility in the proposed project schedule because there are very few true dependencies between tracks or tasks. The overall project critical path would likely be as follows: • Task 1.3 Create Conceptual GIS Design should be completed prior to starting on 1.5 (FileNet) or 1.6 (EnvisionConnect). • FileNet (1.5) and EnvisionConnect (1.6) development should be well-established before starting development of the internal GIS Viewer (2.1) • The internal GIS Viewer (2.1) and One Click Parcel Report (2.2) should be completed and fully tested/vetted before embarking upon a public version (2.3).
All other tasks have only weak dependencies. Therefore, it is estimated that this project could be compressed into as little as 12 months, but 15 months (or longer) would be a more practical target project duration.
10 ORGANIZATIONAL IMPACT AND COSTS
The following is an estimate of the overall technical consulting support and other direct costs (ODC) by track and task. These costs are provided for purposes of order of magnitude costs to assist in project budgeting.
These estimates do not include internal County labor costs. Typical of most GIS development efforts, the creation of needed GIS datasets will be the biggest task that will likely require several hundred hours of effort from DEH staff. Other efforts could also be significant. However, we expect that much of that effort has already been anticipated by DEH and the proposed GIS implementation as described in this document is not expected to have any significant organizational impact.
The “Lead” column indicates whether DEH staff or a technical consultant might be tasked to lead the effort. With DEH staff leading the effort, the “Consultant Labor Est.” is for providing technical assistance to DEH. If it is recommended that a Consultant take the lead on the task, then the labor estimate is for the consultant to produce the deliverable.
TRACK 1—COLLECT AND MANAGE DATA
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Track 1 Notes: 1. $6,500 is an estimated one-time cost to convert one ArcGIS Desktop Basic to and ArcGIS Desktop Standard license. Please note that the annual maintenance cost will also increase. Please verify all costs with DEH’s Esri account representative. 2. $8,500 is an estimated cost to obtain a Geo 7 series GPS unit with 50 cm accuracy (versus decimeter or centimeter accuracy), along with companion TerraSync and Pathfinder Office software. This combination should reliably provide DEH with sub-meter horizontal accuracy for field data collection. DEH could upgrade the unit at a later point to obtain the higher rated accuracies (costs undetermined). 3. $10,000 is the recommended budget for two DEH staff to obtain up to two weeks of instructor-led course training or combination of instructor-led and on-line training.
TRACK 2—IMPLEMENT DATA DRIVEN PROCESSES
Track 2 Notes: 1. It is presumed that the One Click Parcel Report will have been previously developed by CDA and this estimate for DEH is associated with only enhancing the existing application to include DEH related datasets and functions.
TRACK 3—IMPLEMENT ADVANCED SOLUTIONS
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Track 3 Notes: 1. TBD is a placeholder for undetermined costs of what might be DEH’s portion of a joint Digital Plan Check development project with PWA and CDA. To develop a more accurate estimate will require a thorough investigation of available options and discussions / negotiations with PWA and CDA.
TOTAL PROJECT ESTIMATE (ALL TRACKS) The total estimate for technical consulting support and other direct costs (ODC) is $179,000 over a 15- month or longer project duration that would be divided into two fiscal years. ITD charges a management and system configuration fee that is a percentage of the project labor. Following good project management practices, it is recommended that DEH include a contingency budget for un-anticipated labor costs or expenses, bringing the total recommended budget estimate to $213,850.
Version 1.1 Psomas
State of California Edmund G. Brown Jr., Governor
California Environmental Protection Agency Matthew Rodriquez, Secretary
State Water Resources Control Board http://www.waterboards.ca.gov
Charles R. Hoppin, Chair Frances Spivy-Weber, Vice Chair Tam M. Doduc, Member Steven Moore, Member
Thomas Howard, Executive Director Jonathan Bishop, Chief Deputy Director Caren Trgovcich, Chief Deputy Director
Adopted by the State Water Resources Control Board on June 19, 2012 Approved by the Office of Administrative Law on November 13, 2012 Effective Date of the Policy: May 13, 2013
Preamble – Purpose and Scope – Structure of the Policy
Preamble
Onsite wastewater treatment systems (OWTS) are useful and necessary structures that allow habitation at locations that are removed from centralized wastewater treatment systems. When properly sited, designed, operated, and maintained, OWTS treat domestic wastewater to reduce its polluting impact on the environment and most importantly protect public health. Estimates for the number of installations of OWTS in California at the time of this Policy are that more than 1.2 million systems are installed and operating. The vast majority of these are functioning in a satisfactory manner and meeting their intended purpose.
However there have been occasions in California where OWTS for a varied list of reasons have not satisfactorily protected either water quality or public health. Some instances of these failures are related to the OWTS not being able to adequately treat and dispose of waste as a result of poor design or improper site conditions. Others have occurred where the systems are operating as designed but their densities are such that the combined effluent resulting from multiple systems is more than can be assimilated into the environment. From these failures we must learn how to improve our usage of OWTS and prevent such failures from happening again.
As California’s population continues to grow, and we see both increased rural housing densities and the building of residences and other structures in more varied terrain than we ever have before, we increase the risks of causing environmental damage and creating public health risks from the use of OWTS. What may have been effective in the past may not continue to be as conditions and circumstances surrounding particular locations change. So necessarily more scrutiny of our installation of OWTS is demanded of all those involved, while maintaining an appropriate balance of only the necessary requirements so that the use of OWTS remains viable.
Purpose and Scope of the Policy
The purpose of this Policy is to allow the continued use of OWTS, while protecting water quality and public health. This Policy recognizes that responsible local agencies can provide the most effective means to manage OWTS on a routine basis. Therefore as an important element, it is the intent of this policy to efficiently utilize and improve upon where necessary existing local programs through coordination between the State and local agencies. To accomplish this purpose, 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. In particular, the Policy requires actions for water bodies specifically identified as part this Policy where OWTS contribute to water quality degradation that adversely affect beneficial uses.
This Policy only authorizes subsurface disposal of domestic strength, and in limited instances high strength, wastewater and establishes minimum requirements for the permitting, monitoring, and operation of OWTS for protecting beneficial uses of waters 1 Preamble – Purpose and Scope – Structure of the Policy of the State and preventing or correcting conditions of pollution and nuisance. And finally, this Policy also conditionally waives the requirement for owners of OWTS to apply for and receive Waste Discharge Requirements in order to operate their systems when they meet the conditions set forth in the Policy. Nothing in this Policy supersedes or requires modification of Total Maximum Daily Loads or Basin Plan prohibitions of discharges from OWTS.
This Policy also applies to OWTS on federal, state, and Tribal lands to the extent authorized by law or agreement.
Structure of the Policy
This Policy is structured into ten major parts:
Definitions Definitions for all the major terms used in this Policy are provided within this part and wherever used in the Policy the definition given here overrides any other possible definition. [Section 1]
Responsibilities and Duties Implementation of this Policy involves individual OWTS owners; local agencies, be they counties, cities, or any other subdivision of state government with permitting powers over OWTS; Regional Water Quality Control Boards; and the State Water Resources Control Board. [Sections 2, 3, 4, and 5]
Tier 0 – Existing OWTS Existing OWTS that are properly functioning, and do not meet the conditions of failing systems or otherwise require corrective action (for example, to prevent groundwater impairment) as specifically described in Tier 4, and are not determined to be contributing to an impairment of surface water as specifically described in Tier 3, are automatically included in Tier 0. [Section 6]
Tier 1 – Low-Risk New or Replacement OWTS New or replacement OWTS that meet low risk siting and design requirements as specified in Tier 1, where there is not an approved Local Agency Management Program per Tier 2. [Sections 7 and 8]
Tier 2 – Local Agency Management Program for New or Replacement OWTS California is well known for its extreme range of geological and climatic conditions. As such, the establishment of a single set of criteria for OWTS would either be too restrictive so as to protect for the most sensitive case, or would have broad allowances that would not be protective enough under some circumstances. To accommodate this 2 Preamble – Purpose and Scope – Structure of the Policy extreme variance, local agencies may submit management programs (“Local Agency Management Programs”) for approval, and upon approval then manage the installation of new and replacement OWTS under that program.
Local Agency Management Programs approved under Tier 2 provide an alternate method from Tier 1 programs to achieve the same policy purpose, which is to protect water quality and public health. In order to address local conditions, Local Agency Management Programs may include standards that differ from the Tier 1 requirements for new and replacement OWTS contained in Sections 7 and 8. As examples, a Local Agency Management Program may authorize different soil characteristics, usage of seepage pits, and different densities for new developments. Once the Local Agency Management Program is approved, new and replacement OWTS that are included within the Local Agency Management Program may be approved by the Local Agency. A Local Agency, at its discretion, may include Tier 1 standards within its Tier 2 Local Agency Management Program for some or all of its jurisdiction. However, once a Local Agency Management Program is approved, it shall supersede Tier 1 and all future OWTS decisions will be governed by the Tier 2 Local Agency Management Program until it is modified, withdrawn, or revoked. [Section 9]
Tier 3 – Impaired Areas Existing, new, and replacement OWTS that are near impaired water bodies may be addressed by a TMDL and its implementation program, or special provisions contained in a Local Agency Management Program. If there is no TMDL or special provisions, new or replacement OWTS within 600 feet of impaired water bodies listed in Attachment 2 must meet the specific requirements of Tier 3. [Section 10]
Tier 4 – OWTS Requiring Corrective Action OWTS that require corrective action or are either presently failing or fail at any time while this Policy is in effect are automatically included in Tier 4 and must follow the requirements as specified. [Section 11]
Conditional Waiver of Waste Discharge Requirements The requirement to submit a report of waste discharge for discharges from OWTS that are in conformance with this policy is waived. [Section 12]
Effective Date When this Policy becomes effective. [Section 13]
Financial Assistance Procedures for local agencies to apply for funds to establish low interest loan programs for the assistance of OWTS owners in meeting the requirements of this Policy. [Section 14] 3 Preamble – Purpose and Scope – Structure of the Policy
Attachment 1 AB 885 Regulatory Program Timelines.
Attachment 2 Tables 4 and 5 specifically identify those impaired water bodies that have Tier 3 requirements and must have a completed TMDL by the date specified.
Attachment 3 Table 6 shows where one Regional Water Board has been designated to review and, if appropriate, approve new Local Agency Management Plans for a local agency that is within multiple Regional Water Boards’ jurisdiction. What Tier Applies to my OWTS?
Existing OWTS that conform to the requirements for Tier 0 will remain in Tier 0 as long as they continue to meet those requirements. An existing OWTS will temporarily move from Tier 0 to Tier 4 if it is determined that corrective action is needed. The existing OWTS will return to Tier 0 once the corrective action is completed if the repair does not qualify as major repair under Tier 4. Any major repairs conducted as corrective action must comply with Tier 1 requirements or Tier 2 requirements, whichever are in effect for that local area. An existing OWTS will move from Tier 0 to Tier 3 if it is adjacent to an impaired water body listed on Attachment 2, or is covered by a TMDL implementation plan.
In areas with no approved Local Agency Management Plan, new and replacement OWTS that conform to the requirements of Tier 1 will remain in Tier 1 as long as they continue to meet those requirements. A new or replacement OWTS will temporarily move from Tier 1 to Tier 4 if it is determined that corrective action is needed. The new or replacement OWTS will return to Tier 1 once the corrective action is completed. A new or replacement OWTS will move from Tier 1 to Tier 3 if it is adjacent to an impaired water body, or is covered by a TMDL implementation plan.
In areas with an approved Local Agency Management Plan, new and replacement OWTS that conform to the requirements of the Tier 2 Local Agency Management Plan will remain in Tier 2 as long as they continue to meet those requirements. A new or replacement OWTS will temporarily move from Tier 2 to Tier 4 if it is determined that corrective action is needed. The new or replacement OWTS will return to Tier 2 once the corrective action is completed. A new or replacement OWTS will move from Tier 2 to Tier 3 if it is adjacent to an impaired water body, or is covered by a TMDL implementation plan, or is covered by special provisions for impaired water bodies contained in a Local Agency Management Program.
4 Preamble – Purpose and Scope – Structure of the Policy
Existing, new, and replacement OWTS in specified areas adjacent to water bodies that are identified by the State Water Board as impaired for pathogens or nitrogen and listed in Attachment 2 are in Tier 3. Existing, new, and replacement OWTS covered by a TMDL implementation plan, or covered by special provisions for impaired water bodies contained in a Local Agency Management Program are also in Tier 3. These OWTS will temporarily move from Tier 3 to Tier 4 if it is determined that corrective action is needed. The new or replacement OWTS will return to Tier 3 once the corrective action is completed.
Existing, new, and replacement OWTS that do not conform with the requirements to receive coverage under any of the Tiers (e.g., existing OWTS with a projected flow of more than 10,000 gpd) do not qualify for this Policy’s conditional waiver of waste discharge requirements, and will be regulated separately by the applicable Regional Water Board.
5 Definitions
1.0 Definitions. The following definitions apply to this Policy:
“303 (d) list” means the same as "Impaired Water Bodies." “At-grade system” means an OWTS dispersal system with a discharge point located at the preconstruction grade (ground surface elevation). The discharge from an at- grade system is always subsurface. “Average annual rainfall” means the average of the annual amount of precipitation for a location over a year as measured by the nearest National Weather Service station for the preceding three decades. For example the data set used to make a determination in 2012 would be the data from 1981 to 2010. “Basin Plan” means the same as “water quality control plan” as defined in Division 7 (commencing with Section 13000) of the Water Code. Basin Plans are adopted by each Regional Water Board, approved by the State Water Board and the Office of Administrative Law, and identify surface water and groundwater bodies within each Region’s boundaries and establish, for each, its respective beneficial uses and water quality objectives. Copies are available from the Regional Water Boards, electronically at each Regional Water Boards website, or at the State Water Board’s Plans and Policies web page (http://www.waterboards.ca.gov/plans_policies/). “Bedrock” means the rock, usually solid, that underlies soil or other unconsolidated, surficial material. “CEDEN” means California Environmental Data Exchange Network and information about it is available at the State Water Boards website or http://www.ceden.org/index.shtml. “Cesspool” means an excavation in the ground receiving domestic wastewater, designed to retain the organic matter and solids, while allowing the liquids to seep into the soil. Cesspools differ from seepage pits because cesspool systems do not have septic tanks and are not authorized under this Policy. The term cesspool does not include pit-privies and out-houses which are not regulated under this Policy. “Clay” means a soil particle; the term also refers to a type of soil texture. As a soil particle, clay consists of individual rock or mineral particles in soils having diameters <0.002 mm. As a soil texture, clay is the soil material that is comprised of 40 percent or more clay particles, not more than 45 percent sand and not more than 40 percent silt particles using the USDA soil classification system. “Cobbles” means rock fragments 76 mm or larger using the USDA soil classification systems. “Dispersal system” means a leachfield, seepage pit, mound, at-grade, subsurface drip field, evapotranspiration and infiltration bed, or other type of system for final wastewater treatment and subsurface discharge.
6 Definitions
“Domestic wastewater” means wastewater with a measured strength less then high- strength wastewater and is the type of wastewater normally discharged from, or similar to, that discharged from plumbing fixtures, appliances and other household devices including, but not limited to toilets, bathtubs, showers, laundry facilities, dishwashing facilities, and garbage disposals. Domestic wastewater may include wastewater from commercial buildings such as office buildings, retail stores, and some restaurants, or from industrial facilities where the domestic wastewater is segregated from the industrial wastewater. Domestic wastewater may include incidental RV holding tank dumping but does not include wastewater consisting of a significant portion of RV holding tank wastewater such as at RV dump stations. Domestic wastewater does not include wastewater from industrial processes. “Dump Station” means a facility intended to receive the discharge of wastewater from a holding tank installed on a recreational vehicle. A dump station does not include a full hook-up sewer connection similar to those used at a recreational vehicle park. “Domestic well” means a groundwater well that provides water for human consumption and is not regulated by the California Department of Public Health. “Earthen material” means a substance composed of the earth’s crust (i.e. soil and rock). “EDF” see “electronic deliverable format.” “Effluent” means sewage, water, or other liquid, partially or completely treated or in its natural state, flowing out of a septic tank, aerobic treatment unit, dispersal system, or other OWTS component. “Electronic deliverable format” or “EDF” means the data standard adopted by the State Water Board for submittal of groundwater quality monitoring data to the State Water Board’s internet-accessible database system Geotracker (http://geotracker.waterboards.ca.gov/). “Escherichia coli” means a group of bacteria predominantly inhabiting the intestines of humans or other warm-blooded animals, but also occasionally found elsewhere. Used as an indicator of human fecal contamination. “Existing OWTS” means an OWTS that was constructed and operating prior to the effective date of this Policy, and OWTS for which a construction permit has been issued prior to the effective date of the Policy. “Flowing water body” means a body of running water flowing over the earth in a natural water course, where the movement of the water is readily discernible or if water is not present it is apparent from review of the geology that when present it does flow, such as in an ephemeral drainage, creek, stream, or river. “Groundwater” means water below the land surface that is at or above atmospheric pressure.
7 Definitions
“High-strength wastewater” means wastewater having a 30-day average concentration of biochemical oxygen demand (BOD) greater than 300 milligrams- per-liter (mg/L) or of total suspended solids (TSS) greater than 330 mg/L or a fats, oil, and grease (FOG) concentration greater than 100 mg/L prior to the septic tank or other OWTS treatment component. “IAPMO” means the International Association of Plumbing and Mechanical Officials. “Impaired Water Bodies” means those surface water bodies or segments thereof that are identified on a list approved first by the State Water Board and then approved by US EPA pursuant to Section 303(d) of the federal Clean Water Act. “Local agency” means any subdivision of state government that has responsibility for permitting the installation of and regulating OWTS within its jurisdictional boundaries; typically a county, city, or special district. “Major repair” means either: (1) for a dispersal system, repairs required for an OWTS dispersal system due to surfacing wastewater effluent from the dispersal field and/or wastewater backed up into plumbing fixtures because the dispersal system is not able to percolate the design flow of wastewater associated with the structure served, or (2) for a septic tank, repairs required to the tank for a compartment baffle failure or tank structural integrity failure such that either wastewater is exfiltrating or groundwater is infiltrating. “Mottling” means a soil condition that results from oxidizing or reducing minerals due to soil moisture changes from saturated to unsaturated over time. Mottling is characterized by spots or blotches of different colors or shades of color (grays and reds) interspersed within the dominant color as described by the USDA soil classification system. This soil condition can be indicative of historic seasonal high groundwater level, but the lack of this condition may not demonstrate the absence of groundwater. “Mound system” means an aboveground dispersal system (covered sand bed with effluent leachfield elevated above original ground surface inside) used to enhance soil treatment, dispersal, and absorption of effluent discharged from an OWTS treatment unit such as a septic tank. Mound systems have a subsurface discharge. “New OWTS” means an OWTS permitted after the effective date of this Policy. “NSF” means NSF International (a.k.a. National Sanitation Foundation), a not for profit, non-governmental organization that develops health and safety standards and performs product certification. “Oil/grease interceptor” means a passive interceptor that has a rate of flow exceeding 50 gallons-per-minute and that is located outside a building. Oil/grease interceptors are used for separating and collecting oil and grease from wastewater.
8 Definitions
“Onsite wastewater treatment system(s)” (OWTS) means individual disposal systems, community collection and disposal systems, and alternative collection and disposal systems that use subsurface disposal. The short form of the term may be singular or plural. OWTS do not include “graywater” systems pursuant to Health and Safety Code Section 17922.12. “Percolation test” means a method of testing water absorption of the soil. The test is conducted with clean water and test results can be used to establish the dispersal system design. “Permit” means a document issued by a local agency that allows the installation and use of an OWTS, or waste discharge requirements or a waiver of waste discharge requirements that authorizes discharges from an OWTS. “Person” means any individual, firm, association, organization, partnership, business trust, corporation, company, State agency or department, or unit of local government who is, or that is, subject to this Policy. “Pit-privy” (a.k.a. outhouse, pit-toilet) means self-contained waterless toilet used for disposal of non-water carried human waste; consists of a shelter built above a pit in the ground into which human waste falls. “Policy” means this Policy for Siting, Design, Operation and Management of OWTS. “Pollutant” means any substance that alters water quality of the waters of the State to a degree that it may potentially affect the beneficial uses of water, as listed in a Basin Plan. “Projected flows” means wastewater flows into the OWTS determined in accordance with any of the applicable methods for determining average daily flow in the USEPA Onsite Wastewater Treatment System Manual, 2002, or for Tier 2 in accordance with an approved Local Agency Management Program. “Public Water System” is a water system regulated by the California Department of Public Health or a Local Primacy Agency pursuant to Chapter 12, Part 4, California Safe Drinking Water Act, Section 116275 (h) of the California Health and Safety Code. “Public Water Well” is a ground water well serving a public water system. A spring which is not subject to the California Surface Water Treatment Rule (SWTR), CCR, Title 22, sections 64650 through 64666 is a public well. “Qualified professional” means an individual licensed or certified by a State of California agency to design OWTS and practice as professionals for other associated reports, as allowed under their license or registration. Depending on the work to be performed and various licensing and registration requirements, this may include an individual who possesses a registered environmental health specialist certificate or is currently licensed as a professional engineer or professional geologist. For the purposes of performing site evaluations, Soil Scientists certified by the Soil Science Society of America are considered qualified professionals. A local agency may modify this definition as part of its Local Agency Management Program.
9 Definitions
“Regional Water Board” is any of the Regional Water Quality Control Boards designated by Water Code Section 13200. Any reference to an action of the Regional Water Board in this Policy also refers to an action of its Executive Officer, including the conducting of public hearings, pursuant to any general or specific delegation under Water Code Section 13223. “Replacement OWTS” means an OWTS that has its treatment capacity expanded, or its dispersal system replaced or added onto, after the effective date of this Policy. “Sand” means a soil particle; this term also refers to a type of soil texture. As a soil particle, sand consists of individual rock or mineral particles in soils having diameters ranging from 0.05 to 2.0 millimeters. As a soil texture, sand is soil that is comprised of 85 percent or more sand particles, with the percentage of silt plus 1.5 times the percentage of clay particles comprising less than 15 percent. “Seepage pit” means a drilled or dug excavation, three to six feet in diameter, either lined or gravel filled, that receives the effluent discharge from a septic tank or other OWTS treatment unit for dispersal. “Septic tank” means a watertight, covered receptacle designed for primary treatment of wastewater and constructed to: 1. Receive wastewater discharged from a building; 2. Separate settleable and floating solids from the liquid; 3. Digest organic matter by anaerobic bacterial action; 4. Store digested solids; and 5. Clarify wastewater for further treatment with final subsurface discharge. “Service provider” means a person capable of operating, monitoring, and maintaining an OWTS in accordance to this Policy. “Silt” means a soil particle; this term also refers to a type of soil texture. As a soil particle, silt consists of individual rock or mineral particles in soils having diameters ranging from between 0.05 and 0.002 mm. As a soil texture, silt is soil that is comprised as approximately 80 percent or more silt particles and not more than 12 percent clay particles using the USDA soil classification system. “Single-family dwelling unit” means a structure that is usually occupied by just one household or family and for the purposes of this Policy is expected to generate an average of 250 gallons per day of wastewater. “Site” means the location of the OWTS and, where applicable, a reserve dispersal area capable of disposing 100 percent of the design flow from all sources the OWTS is intended to serve. “Site Evaluation” means an assessment of the characteristics of the site sufficient to determine its suitability for an OWTS to meet the requirements of this Policy.
10 Definitions
“Soil” means the naturally occurring body of porous mineral and organic materials on the land surface, which is composed of unconsolidated materials, including sand- sized, silt-sized, and clay-sized particles mixed with varying amounts of larger fragments and organic material. The various combinations of particles differentiate specific soil textures identified in the soil textural triangle developed by the United States Department of Agriculture (USDA) as found in Soil Survey Staff, USDA; Soil Survey Manual, Handbook 18, U.S. Government Printing Office, Washington, DC, 1993, p. 138. For the purposes of this Policy, soil shall contain earthen material of particles smaller than 0.08 inches (2 mm) in size. “Soil Structure” means the arrangement of primary soil particles into compound particles, peds, or clusters that are separated by natural planes of weakness from adjoining aggregates. “Soil texture” means the soil class that describes the relative amount of sand, clay, silt and combinations thereof as defined by the classes of the soil textural triangle developed by the USDA (referenced above). “State Water Board” is the State Water Resources Control Board “Supplemental treatment” means any OWTS or component of an OWTS, except a septic tank or dosing tank, that performs additional wastewater treatment so that the effluent meets a predetermined performance requirement prior to discharge of effluent into the dispersal field. “SWAMP” means Surface Water Ambient Monitoring Program and more information is available at: http://www.waterboards.ca.gov/water_issues/programs/swamp/ “Telemetric” means the ability to automatically measure and transmit OWTS data by wire, radio, or other means. “TMDL” is the acronym for "total maximum daily load." Section 303(d)(1) of the Clean Water Act requires each State to establish a TMDL for each impaired water body to address the pollutant(s) causing the impairment. In California, TMDLs are usually adopted as Basin Plan amendments and contain implementation plans detailing how water quality standards will be attained. “Total coliform” means a group of bacteria consisting of several genera belonging to the family Enterobacteriaceae, which includes Escherichia coli bacteria. “USDA” means the U.S. Department of Agriculture. “Waste discharge requirement” or “WDR” means an operation and discharge permit issued for the discharge of waste pursuant to Section 13260 of the California Water Code.
11 Responsibilities and Duties
Responsibilities and Duties
2.0 OWTS Owners Responsibilities and Duties
2.1 All new, replacement, or existing OWTS within an area that is subject to a Basin Plan prohibition of discharges from OWTS, must comply with the prohibition. If the prohibition authorizes discharges under specified conditions, the discharge must comply with those conditions and the applicable provisions of this Policy. 2.2 Owners of OWTS shall adhere to the requirements prescribed in local codes and ordinances. Owners of new and replacement OWTS covered by this Policy shall also meet the minimum standards contained in Tier 1, or an alternate standard provided by a Local Agency Management Program per Tier 2, or shall comply with the requirements of Tier 3 if near an impaired water body and subject to Tier 3, or shall provide corrective action for their OWTS if their system meets conditions that place it in Tier 4. 2.3 Owners of OWTS shall comply with any and all permitting conditions imposed by a local agency that do not directly conflict with this Policy, including any conditions that are more stringent than required by this Policy. 2.4 To receive coverage under this Policy and the included waiver of waste discharges, OWTS shall only accept and treat flows of domestic wastewater. In addition, OWTS that accept high-strength wastewater from commercial food service buildings are covered under this Policy and the waiver of waste discharge requirements if the wastewater does not exceed 900 mg/L BOD and there is a properly sized and functioning oil/grease interceptor (a.k.a grease trap). 2.5 Owners of OWTS shall maintain their OWTS in good working condition including inspections and pumping of solids as necessary, or as required by local ordinances, to maintain proper function and assure adequate treatment. 2.6 The following owners of OWTS shall notify the Regional Water Board by submitting a Report of Waste Discharge for the following: 2.6.1 a new or replacement OWTS that does not meet the conditions and requirements set forth in either a Local Agency Management Program if one is approved, an existing local program if it is less than 60 months from the effective date of the Policy and a Local Agency Management Program is not yet approved, or Tier 1 if no Local Agency Management Program has been approved and it is more than 60 months after the effective date of this Policy; 2.6.2 any OWTS, not under individual waste discharge requirements or a waiver of individual waste discharge requirements issued by a Regional Water Board, with the projected flow of over 10,000 gallons-per-day;
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2.6.3 any OWTS that receives high-strength wastewater, unless the waste stream is from a commercial food service building; 2.6.4 any OWTS that receives high-strength wastewater from a commercial food service building: (1) with a BOD higher than 900 mg/L, or (2) that does not have a properly sized and functioning oil/grease interceptor. 2.7 All Reports of Waste Discharge shall be accompanied by the required application fee pursuant to California Code of Regulations, title 23, section 2200.
3.0 Local Agency Requirements and Responsibilities 3.1 Local agencies, in addition to implementing their own local codes and ordinances, shall determine whether the requirements within their local jurisdiction will be limited to the water quality protection afforded by the statewide minimum standards in Tier 0, Tier 1, Tier 3, and Tier 4, or whether the local agency will implement a Local Agency Management Program in accordance with Tier 2. Except for Tier 3, local agencies may continue to implement their existing OWTS permitting programs in compliance with the Basin Plan in place at the effective date of the Policy until 60 months after the effective date of this Policy, or approval of a Local Agency Management Program, whichever comes first, and may make minor adjustments as necessary that are in compliance with the applicable Basin Plan and this Policy. Tier 3 requirements take effect on the effective date of this Policy. In the absence of a Tier 2 Local Agency Management Program, to the extent that there is a direct conflict between the applicable minimum standards and the local codes or ordinances (such that it is impossible to comply with both the applicable minimum standards and the local ordinances or codes), the more restrictive standards shall govern. 3.2 If preferred, the local agency may at any time provide the State Water Board and all affected Regional Water Board(s) written notice of its intent to regulate OWTS using a Local Agency Management Program with alternative standards as authorized in Tier 2 of this Policy. A proposed Local Agency Management Program that conforms to the requirements of that Section shall be included with the notice. A local agency shall not implement a program different than the minimum standards contained in Tier 1 and 3 of this Policy after 60 months from the effective date of this Policy until approval of the proposed Local Agency Management Program is granted by either the Regional Water Board or State Water Board. All initial program submittals desiring approval prior to the 60 month limit shall be received no later than 36 months from the effective date of this Policy. Once approved, the local agency shall adhere to the Local Agency Management Program, including all requirements, monitoring, and reporting. If at any time a local agency wishes to modify its Local Agency Management Program, it shall provide the State Water Board and all affected Regional Water Board(s) written notice of its intended modifications and will continue to implement its existing Local Agency Management Program until the modifications are approved.
13 Responsibilities and Duties
3.3 All local agencies permitting OWTS shall report annually to the Regional Water Board(s). If a local agency’s jurisdictional area is within the boundary of multiple Regional Water Boards, the local agency shall send a copy of the annual report to each Regional Water Board. The annual report shall include the following information (organized in a tabular spreadsheet format) and summarize whether any further actions are warranted to protect water quality or public health: 3.3.1 number and location of complaints pertaining to OWTS operation and maintenance, and identification of those which were investigated and how they were resolved; 3.3.2 shall provide the applications and registrations issued as part of the local septic tank cleaning registration program pursuant to Section 117400 et seq. of the California Health and Safety Code; 3.3.3 number, location, and description of permits issued for new and replacement OWTS and which Tier the permit is issued. 3.4 All local agencies permitting OWTS shall retain permanent records of their permitting actions and will make those records available within 10 working days upon written request for review by a Regional Water Board. The records for each permit shall reference the Tier under which the permit was issued. 3.5 A local agency shall notify the owner of a public well or water intake and the California Department of Public Health as soon as practicable, but not later than 72 hours, upon its discovery of a failing OWTS as described in sections 11.1 and 11.2 within the setbacks described in sections 7.5.6 through 7.5.10. 3.6 A local agency may implement this Policy, or a portion thereof, using its local authority to enforce the policy, as authorized by an approval from the State Water Board or by the appropriate Regional Water Board. 3.7 Nothing in the Policy shall preclude a local agency from adopting or retaining standards for OWTS in an approved Local Agency Management Program that are more protective of the public health or the environment than are contained in this Policy. 3.8 If at any time a local agency wishes to withdraw its previously submitted and approved Tier 2 Local Agency Management Program, it may do so upon 60 days written notice. The notice of withdrawal shall specify the reason for withdrawing its Tier 2 program, the effective date for cessation of the program and resumption of permitting of OWTS only under Tiers 1, 3, and 4.
4.0 Regional Water Board Functions and Duties 4.1 The Regional Water Boards have the principal responsibility for overseeing the implementation of this Policy. 4.2 Regional Water Boards shall incorporate the requirements established in this Policy by amending their Basin Plans within 12 months of the effective date of this Policy, pursuant to Water Code Section 13291(e). The Regional Water 14 Responsibilities and Duties
Boards may also consider whether it is necessary and appropriate to retain or adopt any more protective standards. To the extent that a Regional Water Board determines that it is necessary and appropriate to retain or adopt any more protective standards, it shall reconcile those region-specific standards with this Policy to the extent feasible, and shall provide a detailed basis for its determination that each of the more protective standards is necessary and appropriate. 4.2.1 Notwithstanding 4.2 above, the North Coast Regional Water Board will continue to implement its existing Basin Plan requirements pertaining to OWTS within the Russian River watershed until it adopts the Russian River TMDL, at which time it will comply with section 4.2 for the Russian River watershed. 4.3 The Regional Water Board designated in Attachment 3 shall review, and if appropriate, approve a Local Agency Management Program submitted by the local agency pursuant to Tier 2 in this Policy. Upon receipt of a proposed Local Agency Management Program, the Regional Water Board designated in Attachment 3 shall have 90 days to notify the local agency whether the submittal contains all the elements of a Tier 2 program, but may request additional information based on review of the proposed program. Approval must follow a noticed hearing with opportunity for public comment. If a Local Agency Management Program is disapproved, the Regional Water Board designated in Attachment 3 shall provide a written explanation of the reasons for the disapproval. A Regional Water Board may approve a Local Agency Management Program while disapproving any proposed special provisions for impaired water bodies contained in the Local Agency Management Program. If no action is taken by the respective Regional Water Board within 12 months of the submission date of a complete Local Agency Management Program, the program shall be forwarded to the State Water Board for review and approval pursuant to Section 5 of this Policy. 4.3.1 Where the local agency’s jurisdiction lies within more than one Regional Water Board, staff from the affected Regional Water Boards shall work cooperatively to assure that water quality protection in each region is adequately protected. If the Regional Water Board designated in Attachment 3 approves the Local Agency Management Program over the written objection of an affected Regional Water Board, that Regional Water Board may submit the dispute to the State Water Board under Section 5.3. 4.3.2 Within 30 days of receipt of a proposed Local Agency Management Program, a Regional Water Board will forward a copy to and solicit comments from the California Department of Public Health regarding a Local Agency Management Program’s proposed policies and procedures, including notification to local water purveyors prior to OWTS permitting. 4.4 Once a Local Agency Management Program has been approved, any affected Regional Water Board may require modifications or revoke authorization of a local agency to implement a Tier 2 program, in accordance with the following: 15 Responsibilities and Duties
4.4.1 The Regional Water Board shall consult with any other Regional Water Board(s) having jurisdiction over the local agency before providing the notice described in section 4.4.2. 4.4.2 Written notice shall be provided to the local agency detailing the Regional Water Board’s action, the cause for such action, remedies to prevent the action from continuing to completion, and appeal process and rights. The local agency shall have 90 days from the date of the written notice to respond with a corrective action plan to address the areas of non- compliance, or to request the Regional Water Board to reconsider its findings. 4.4.3 The Regional Water Board shall approve, approve conditionally, or deny a corrective action plan within 90 days of receipt. The local agency will have 90 days to begin implementation of a corrective action plan from the date of approval or 60 days to request reconsideration from the date of denial. If the local agency fails to submit an acceptable corrective action plan, fails to implement an approved corrective action plan, or request reconsideration, the Regional Water Board may require modifications to the Local Agency Management Program, or may revoke the local agency’s authorization to implement a Tier 2 program. 4.4.4 Requests for reconsideration by the local agency shall be decided by the Regional Water Board within 90 days and the previously approved Local Agency Management Program shall remain in effect while the reconsideration is pending. 4.4.5 If the request for reconsideration is denied, the local agency may appeal to the State Water Board and the previously approved Local Agency Management Program shall remain in effect while the appeal is under consideration. The State Water Board shall decide the appeal within 90 days. All decisions of the State Water Board are final. 4.5 The appropriate Regional Water Board shall accept and consider any requests for modification or revocation of a Local Agency Management Program submitted by any person. The Regional Water Board will notify the person making the request and the local agency implementing the Local Agency Management Program at issue by letter within 90 days whether it intends to proceed with the modification or revocation process per Section 4.4 above, or is dismissing the request. The Regional Water Board will post the request and its response letter on its website. 4.6 A Regional Water Board may issue or deny waste discharge requirements or waivers of waste discharge requirements for any new or replacement OWTS within a jurisdiction of a local agency without an approved Local Agency Management Program if that OWTS does not meet the minimum standards contained in Tier 1. 4.7 The Regional Water Boards will implement any notifications and enforcement requirements for OWTS determined to be in Tier 3 of this Policy.
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4.8 Regional Water Boards may adopt waste discharge requirements, or conditional waivers of waste discharge requirements, that exempt individual OWTS from requirements contained in this Policy.
5.0 State Water Board Functions and Duties 5.1 As the state agency charged with the development and adoption of this Policy, the State Water Board shall periodically review, amend and/or update this Policy as required. 5.2 The State Water Board may take any action assigned to the Regional Water Boards in this Policy. 5.3 The State Water Board shall resolve disputes between Regional Water Boards and local agencies as needed within 12 months of receiving such a request by a Regional Water Board or local agency, and may take action on its own motion in furtherance of this Policy. As part of this function, the State Water Board shall review and, if appropriate, approve Local Agency Management Programs in cases where the respective Regional Water Board has failed to consider for approval a Local Agency Management Program. The State Water Board shall approve Local Agency Management Programs at a regularly noticed board hearing and shall provide for public participation, including notice and opportunity for public comment. Once taken up by the State Water Board, Local Agency Management Programs shall be approved or denied within 180 days. 5.4 A member of the public may request the State Water Board to resolve any dispute regarding the Regional Water Board’s approval of a Local Agency Management Program if the member of the public timely raised the disputed issue before the Regional Water Board. Such requests shall be submitted within 30 days after the Regional Water Board’s approval of the Local Agency Management Program. The State Water Board shall notify the member of the public, the local agency, and the Regional Water Board within 90 days whether it intends to proceed with dispute resolution. 5.5 The State Water Board shall accept and consider any requests for modification or revocation of a Local Agency Management Program submitted by any person, where that person has previously submitted said request to the Regional Water Board and has received notice from the Regional Water Board of its dismissal of the request. The State Water Board will notify the person making the request and the local agency implementing the Local Agency Management Program at issue by letter within 90 days whether it intends to proceed with the modification or revocation process per Section 4.4 above, or is dismissing the request. The State Water Board will post the request and its response letter on its website. 5.6 The State Water Board or its Executive Director, after approving any Impaired Water Bodies [303 (d)] List, and for the purpose of implementing Tier 3 of this Policy, shall update Attachment 2 to identify those water bodies where: (1) it is likely that operating OWTS will subsequently be determined to be a contributing 17 Responsibilities and Duties
source of pathogens or nitrogen and therefore it is anticipated that OWTS would receive a loading reduction, and (2) it is likely that new OWTS installations discharging within 600 feet of the water body would contribute to the impairment. This identification shall be based on information available at the time of 303 (d) listing and may be further updated based on new information. Updates to Attachment 2 will be processed as amendments to this Policy. 5.7 The State Water Board will make available to local agencies funds from its Clean Water State Revolving Fund loan program for mini-loan programs to be operated by the local agencies for the making of low interest loans to assist private property owners with complying with this Policy.
18 Tier 0 – Existing OWTS
Tier 0 – Existing OWTS Existing OWTS that are properly functioning and do not meet the conditions of failing systems or otherwise require corrective action (for example, to prevent groundwater impairment) as specifically described in Tier 4, and are not determined to be contributing to an impairment of surface water as specifically described in Tier 3, are automatically included in Tier 0.
6.0 Coverage for Properly Operating Existing OWTS 6.1 Existing OWTS are automatically covered by Tier 0 and the herein included waiver of waste discharge requirements if they meet the following requirements: 6.1.1 have a projected flow of 10,000 gallons-per-day or less; 6.1.2 receive only domestic wastewater from residential or commercial buildings, or high-strength wastewater from commercial food service buildings that does not exceed 900 mg/L BOD and has a properly sized and functioning oil/grease interceptor (a.k.a. grease trap); 6.1.3 continue to comply with any previously imposed permitting conditions; 6.1.4 do not require supplemental treatment under Tier 3; 6.1.5 do not require corrective action under Tier 4; and 6.1.6 do not consist of a cesspool as a means of wastewater disposal. 6.2 A Regional Water Board or local agency may deny coverage under this Policy to any OWTS that is: 6.2.1 Not in compliance with Section 6.1; 6.2.2 Not able to adequately protect the water quality of the waters of the State, as determined by the Regional Water Board after considering any input from the local agency. A Regional Water Board may require the submission of a report of waste discharge to receive Region specific waste discharge requirements or waiver of waste discharge requirements so as to be protective. 6.3 Existing OWTS currently under waste discharge requirements or individual waiver of waste discharge requirements will remain under those orders until notified in writing by the appropriate Regional Water Board that they are covered under this Policy.
19 Tier 1 – Low Risk New or Replacement OWTS
Tier 1 – Low Risk New or Replacement OWTS New or replacement OWTS meet low risk siting and design requirements as specified in Tier 1, where there is not an approved Local Agency Management Program per Tier 2.
7.0 Minimum Site Evaluation and Siting Standards 7.1 A qualified professional shall perform all necessary soil and site evaluations for all new OWTS and for existing OWTS where the treatment or dispersal system will be replaced or expanded. 7.2 A site evaluation shall determine that adequate soil depth is present in the dispersal area. Soil depth is measured vertically to the point where bedrock, hardpan, impermeable soils, or saturated soils are encountered or an adequate depth has been determined. Soil depth shall be determined through the use of soil profile(s) in the dispersal area and the designated dispersal system replacement area, as viewed in excavations exposing the soil profiles in representative areas, unless the local agency has determined through historical or regional information that a specific site soil profile evaluation is unwarranted. 7.3 A site evaluation shall determine whether the anticipated highest level of groundwater within the dispersal field and its required minimum dispersal zone is not less than prescribed in Table 2 by estimation using one or a combination of the following methods: 7.3.1 Direct observation of the highest extent of soil mottling observed in the examination of soil profiles, recognizing that soil mottling is not always an indicator of the uppermost extent of high groundwater; or 7.3.2 Direct observation of groundwater levels during the anticipated period of high groundwater. Methods for groundwater monitoring and determinations shall be decided by the local agency; or 7.3.3 Other methods, such as historical records, acceptable to the local agency. 7.3.4 Where a conflict in the above methods of examination exists, the direct observation method indicating the highest level shall govern. 7.4 Percolation test results in the effluent disposal area shall not be faster than one minute per inch (1 MPI) or slower than one hundred twenty minutes per inch (120 MPI). All percolation test rates shall be performed by presoaking of percolation test holes and continuing the test until a stabilized rate is achieved. 7.5 Minimum horizontal setbacks from any OWTS treatment component and dispersal systems shall be as follows: 7.5.1 5 feet from parcel property lines and structures; 7.5.2 100 feet from water wells and monitoring wells, unless regulatory or legitimate data requirements necessitate that monitoring wells be located closer;
20 Tier 1 – Low Risk New or Replacement OWTS
7.5.3 100 feet from any unstable land mass or any areas subject to earth slides identified by a registered engineer or registered geologist; other setback distance are allowed, if recommended by a geotechnical report prepared by a qualified professional. 7.5.4 100 feet from springs and flowing surface water bodies where the edge of that water body is the natural or levied bank for creeks and rivers, or may be less where site conditions prevent migration of wastewater to the water body; 7.5.5 200 feet from vernal pools, wetlands, lakes, ponds, or other surface water bodies where the edge of that water body is the high water mark for lakes and reservoirs, and the mean high tide line for tidally influenced water bodies; 7.5.6 150 feet from a public water well where the depth of the effluent dispersal system does not exceed 10 feet; 7.5.7 Where the effluent dispersal system is within 1,200 feet from a public water systems’ surface water intake point, within the catchment of the drainage, and located such that it may impact water quality at the intake point such as upstream of the intake point for flowing water bodies, the dispersal system shall be no less than 400 feet from the high water mark of the reservoir, lake or flowing water body. 7.5.8 Where the effluent dispersal system is located more than 1,200 feet but less than 2,500 feet from a public water systems’ surface water intake point, within the catchment of the drainage, and located such that it may impact water quality at the intake point such as upstream of the intake point for flowing water bodies, the dispersal system shall be no less than 200 feet from the high water mark of the reservoir, lake or flowing water body. 7.6 Prior to issuing a permit to install an OWTS the permitting agency shall determine if the OWTS is within 1,200 feet of an intake point for a surface water treatment plant for drinking water, is in the drainage catchment in which the intake point is located, and located such that it may impact water quality at the intake point such as being upstream of the intake point for a flowing water body. If the OWTS is within 1,200 feet of an intake point for a surface water treatment plant for drinking water, is in the drainage catchment in which the intake point is located, and is located such that it may impact water quality at the intake point: 7.6.1 The permitting agency shall provide a copy of the permit application to the owner of the water system of their proposal to install an OWTS within 1,200 feet of an intake point for a surface water treatment. If the owner of the water system cannot be identified, then the permitting agency will notify California Department of Public Health Drinking Water Program. 7.6.2 The permit application shall include a topographical plot plan for the parcel showing the OWTS components, the property boundaries, proposed structures, physical address, and name of property owner.
21 Tier 1 – Low Risk New or Replacement OWTS
7.6.3 The permit application shall provide the estimated wastewater flows, intended use of proposed structure generating the wastewater, soil data, and estimated depth to seasonally saturated soils. 7.6.4 The public water system owner shall have 15 days from receipt of the permit application to provide recommendations and comments to the permitting agency. 7.7 Natural ground slope in all areas used for effluent disposal shall not be greater than 25 percent. 7.8 The average density for any subdivision of property made by Tentative Approval pursuant to the Subdivision Map Act occurring after the effective date of this Policy and implemented under Tier 1 shall not exceed the allowable density values in Table 1 for a single-family dwelling unit, or its equivalent, for those units that rely on OWTS.
Table 1: Allowable Average Densities per Subdivision under Tier 1. Average Annual Rainfall Allowable Density (in/yr) (acres/single family dwelling unit) 0 - 15 2.5 >15 - 20 2 >20 - 25 1.5 >25 - 35 1 >35 - 40 0.75 >40 0.5
8.0 Minimum OWTS Design and Construction Standards 8.1 OWTS Design Requirements 8.1.1 A qualified professional shall design all new OWTS and modifications to existing OWTS where the treatment or dispersal system will be replaced or expanded. A qualified professional employed by a local agency, while acting in that capacity, may design, review, and approve a design for a proposed OWTS, if authorized by the local agency. 8.1.2 OWTS shall be located, designed, and constructed in a manner to ensure that effluent does not surface at any time, and that percolation of effluent will not adversely affect beneficial uses of waters of the State. 8.1.3 The design of new and replacement OWTS shall be based on the expected influent wastewater quality with a projected flow not to exceed 3,500 gallons per day, the peak wastewater flow rates for purposes of sizing hydraulic components, the projected average daily flow for purposes of sizing the dispersal system, the characteristics of the site, and the required level of treatment for protection of water quality and public health.
22 Tier 1 – Low Risk New or Replacement OWTS
8.1.4 All dispersal systems shall have at least twelve (12) inches of soil cover, except for pressure distribution systems, which must have at least six (6) inches of soil cover. 8.1.5 The minimum depth to the anticipated highest level of groundwater below the bottom of the leaching trench, and the native soil depth immediately below the leaching trench, shall not be less than prescribed in Table 2.
Table 2: Tier 1 Minimum Depths to Groundwater and Minimum Soil Depth from the Bottom of the Dispersal System Percolation Rate Minimum Depth Percolation Rate ≤1 MPI Only as authorized in a Tier 2 Local Agency Management Program 1 MPI< Percolation Rate ≤ 5 Twenty (20) feet MPI 5 MPI< Percolation Rate ≤ 30 Eight (8) feet MPI 30 MPI< Percolation Rate ≤ Five (5) feet 120 MPI Percolation Rate > 120 MPI Only as authorized in a Tier 2 Local Agency Management Program MPI = minutes per inch
8.1.6 Dispersal systems shall be a leachfield, designed using not more than 4 square-feet of infiltrative area per linear foot of trench as the infiltrative surface, and with trench width no wider than 3 feet. Seepage pits and other dispersal systems may only be authorized for repairs where siting limitations require a variance. Maximum application rates shall be determined from stabilized percolation rate as provided in Table 3, or from soil texture and structure determination as provided in Table 4.
8.1.7 Dispersal systems shall not exceed a maximum depth of 10 feet as measured from the ground surface to the bottom of the trench.
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Table 3: Application Rates as Determined from Stabilized Percolation Rate
Percolation Application Percolation Application Percolation Application Rate Rate Rate Rate Rate Rate
(minutes (gallons (minutes (gallons (minutes (gallons per Inch) per day per per Inch) per day per per Inch) per day per square square square foot) foot) foot) <1 Requires 31 0.522 61 0.197 Local Manage- ment Program 1 1.2 32 0.511 62 0.194 2 1.2 33 0.5 63 0.19 3 1.2 34 0.489 64 0.187 4 1.2 35 0.478 65 0.184 5 1.2 36 0.467 66 0.18 6 0.8 37 0.456 67 0.177 7 0.8 38 0.445 68 0.174 8 0.8 39 0.434 69 0.17 9 0.8 40 0.422 70 0.167 10 0.8 41 0.411 71 0.164 11 0.786 42 0.4 72 0.16 12 0.771 43 0.389 73 0.157 13 0.757 44 0.378 74 0.154 14 0.743 45 0.367 75 0.15 15 0.729 46 0.356 76 0.147 16 0.714 47 0.345 77 0.144 17 0.7 48 0.334 78 0.14 18 0.686 49 0.323 79 0.137 19 0.671 50 0.311 80 0.133 20 0.657 51 0.3 81 0.13 21 0.643 52 0.289 82 0.127 22 0.629 53 0.278 83 0.123 23 0.614 54 0.267 84 0.12 24 0.6 55 0.256 85 0.117 25 0.589 56 0.245 86 0.113 26 0.578 57 0.234 87 0.11 27 0.567 58 0.223 88 0.107 28 0.556 59 0.212 89 0.103 29 0.545 60 0.2 90 0.1 30 0.533 >90 - 120 0.1
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Table 4: Design Soil Application Rates (Source: USEPA Onsite Wastewater Treatment Systems Manual, February 2002)
Soil Texture Soil Structure Shape Grade Maximum Soil Application (per the USDA soil classification Rate(gallons per system) day per square foot) 1 Coarse Sand, Sand, Loamy Coarse Single grain Structureless 0.8 Sand, Loamy Sand Fine Sand, Very Fine Sand, Loamy Single grain Structureless 0.4 Fine Sand, Loamy Very Fine Sand Coarse Sandy Loam, Sandy Loam Massive Structureless 0.2 Platy Weak 0.2 Moderate, Strong Prohibited
Prismatic, Blocky, Weak 0.4 Granular Moderate, Strong 0.6
Fine Sandy Loam, very fine Sandy Massive Structureless 0.2 Loam Platy Weak, Moderate, Strong Prohibited Prismatic, Blocky, Weak 0.2 Granular Moderate, Strong 0.4 Loam Massive Structureless 0.2 Platy Weak, Moderate, Strong Prohibited Prismatic, Blocky, Weak 0.4 Granular Moderate, Strong 0.6
Silt Loam Massive Structureless Prohibited Platy Weak, Moderate, Strong Prohibited Prismatic, Blocky, Weak 0.4 Granular Moderate, Strong 0.6 Sandy Clay Loam, Clay Loam, Silty Massive Structureless Prohibited Clay Loam Platy Weak, Moderate, Strong Prohibited Prismatic, Blocky, Weak 0.2 Granular Moderate, Strong 0.4 Sandy Clay, Clay, or Silty Clay Massive Structureless Prohibited Platy Weak, Moderate, Strong Prohibited Prismatic, Blocky, Weak Prohibited Granular Moderate, Strong 0.2
1 Soils listed as prohibited may be allowed under the authority of the Regional Water Board, or as allowed under an approved Local Agency Management Program per Tier 2.
25 Tier 1 – Low Risk New or Replacement OWTS
8.1.8 All new dispersal systems shall have 100 percent replacement area that is equivalent and separate, and available for future use. 8.1.9 No dispersal systems or replacement areas shall be covered by an impermeable surface, such as paving, building foundation slabs, plastic sheeting, or any other material that prevents oxygen transfer to the soil. 8.1.10 Rock fragment content of native soil surrounding the dispersal system shall not exceed 50 percent by volume for rock fragments sized as cobbles or larger and shall be estimated using either the point-count or line-intercept methods. 8.1.11 Increased allowance for IAPMO certified dispersal systems is not allowed under Tier 1. 8.2 OWTS Construction and Installation 8.2.1 All new or replacement septic tanks and new or replacement oil/grease interceptor tanks shall comply with the standards contained in Sections K5(b), K5(c), K5(d), K5(e), K5(k), K5(m)(1), and K5(m)(3)(ii) of Appendix K, of Part 5, Title 24 of the 2007 California Code of Regulations. 8.2.2 All new septic tanks shall comply with the following requirements: 8.2.2.1 Access openings shall have watertight risers, the tops of which shall be set at most 6 inches below finished grade; and 8.2.2.2 Access openings at grade or above shall be locked or secured to prevent unauthorized access. 8.2.3 New and replacement OWTS septic tanks shall be limited to those approved by the International Association of Plumbing and Mechanical Officials (IAPMO) or stamped and certified by a California registered civil engineer as meeting the industry standards, and their installation shall be according to the manufacturer’s instructions. 8.2.4 New and replacement OWTS septic tanks shall be designed to prevent solids in excess of three-sixteenths (3/16) of an inch in diameter from passing to the dispersal system. Septic tanks that use a National Sanitation Foundation/American National Standard Institute (NSF/ANSI) Standard 46 certified septic tank filter at the final point of effluent discharge from the OWTS and prior to the dispersal system shall be deemed in compliance with this requirement.
26 Tier 1 – Low Risk New or Replacement OWTS
8.2.5 A Licensed General Engineering Contractor (Class A), General Building Contractor (Class B), Sanitation System Contractor (Specialty Class C- 42), or Plumbing Contractor (Specialty Class C-36) shall install all new OWTS and replacement OWTS in accordance with California Business and Professions Code Sections 7056, 7057, and 7058 and Article 3, Division 8, Title 16 of the California Code of Regulations. A property owner may also install his/her own OWTS if the as-built diagram and the installation are inspected and approved by the Regional Water Board or local agency at a time when the OWTS is in an open condition (not covered by soil and exposed for inspection).
27 Tier 2 – Local Agency OWTS Management Program
Tier 2 – Local Agency OWTS Management Program Local agencies may submit management programs for approval, and upon approval then manage the installation of new and replacement OWTS under that program. Local Agency Management Programs approved under Tier 2 provide an alternate method from Tier 1 programs to achieve the same policy purpose, which is to protect water quality and public health. In order to address local conditions, Local Agency Management Programs may include standards that differ from the Tier 1 requirements for new and replacement OWTS contained in Sections 7 and 8. As examples, a Local Agency Management Program may authorize different soil characteristics, usage of seepage pits, and different densities for new developments. Once the Local Agency Management Program is approved, new and replacement OWTS that are included within the Local Agency Management Program may be approved by the Local Agency. A Local Agency, at its discretion, may include Tier 1 standards within its Tier 2 Local Agency Management Program for some or all of its jurisdiction. However, once a Local Agency Management Program is approved, it shall supersede Tier 1 and all future OWTS decisions will be governed by the Tier 2 Local Agency Management Program until it is modified, withdrawn, or revoked.
9.0 Local Agency Management Program for Minimum OWTS Standards The Local Agency Management Program for minimum OWTS Standards is a management program where local agencies can establish minimum standards that are differing requirements from those specified in Tier 1 (Section 7 and Section 8), including the areas that do not meet those minimum standards and still achieve this Policy’s purpose. Local Agency Management Programs may include any one or combination of the following to achieve this purpose: Differing system design requirements; Differing siting controls such as system density and setback requirements; Requirements for owners to enter monitoring and maintenance agreements; and/or Creation of an onsite management district or zone. 9.1 Where different and/or additional requirements are needed to protect water quality the local agency shall consider the following, as well as any other conditions deemed appropriate, when developing Local Agency Management Program requirements: 9.1.1 Degree of vulnerability to pollution from OWTS due to hydrogeological conditions. 9.1.2 High Quality waters or other environmental conditions requiring enhanced protection from the effects of OWTS. 9.1.3 Shallow soils requiring a dispersal system installation that is closer to ground surface than is standard. 9.1.4 OWTS is located in area with high domestic well usage.
28 Tier 2 – Local Agency OWTS Management Program
9.1.5 Dispersal system is located in an area with fractured bedrock. 9.1.6 Dispersal system is located in an area with poorly drained soils. 9.1.7 Surface water is vulnerable to pollution from OWTS. 9.1.8 Surface water within the watershed is listed as impaired for nitrogen or pathogens. 9.1.9 OWTS is located within an area of high OWTS density. 9.1.10 A parcel’s size and its susceptibility to hydraulic mounding, organic or nitrogen loading, and whether there is sufficient area for OWTS expansion in case of failure. 9.1.11 Geographic areas that are known to have multiple, existing OWTS predating any adopted standards of design and construction including cesspools. 9.1.12 Geographic areas that are known to have multiple, existing OWTS located within either the pertinent setbacks listed in Section 7.5 of this Policy, or a setback that the local agencies finds is appropriate for that area. 9.2 The Local Agency Management Program shall detail the scope of its coverage, such as the maximum authorized projected flows for OWTS, as well as a clear delineation of those types of OWTS included within and to be permitted by the program, and provide the local site evaluation, siting, design, and construction requirements, and in addition each of the following: 9.2.1 Any local agency requirements for onsite wastewater system inspection, monitoring, maintenance, and repairs, including procedures to ensure that replacements or repairs to failing systems are done under permit from the local governing jurisdiction. 9.2.2 Any special provisions applicable to OWTS within specified geographic areas near specific impaired water bodies listed for pathogens or nitrogen. The special provisions may be substantive and/or procedural, and may include, as examples: consultation with the Regional Water Board prior to issuing permits, supplemental treatment, development of a management district or zone, special siting requirements, additional inspection and monitoring. 9.2.3 Local Agency Management Program variances, for new installations and repairs in substantial conformance, to the greatest extent practicable. Variances are not allowed for the requirements stated in sections 9.4.1 through 9.4.9. 9.2.4 Any educational, training, certification, and/or licensing requirements that will be required of OWTS service providers, site evaluators, designers, installers, pumpers, maintenance contractors, and any other person relating to OWTS activities. 9.2.5 Education and/or outreach program including informational materials to inform OWTS owners about how to locate, operate, and maintain their
29 Tier 2 – Local Agency OWTS Management Program
OWTS as well as any Water Board order (e.g., Basin Plan prohibitions) regarding OWTS restrictions within its jurisdiction. The education and/or outreach program shall also include procedures to ensure that alternative onsite system owners are provided an informational maintenance or replacement document by the system designer or installer. This document shall cite homeowner procedures to ensure maintenance, repair, or replacement of critical items within 48 hours following failure. If volunteer well monitoring programs are available within the local agency’s jurisdiction, the outreach program shall include information on how well owners may participate. 9.2.6 An assessment of existing and proposed disposal locations for septage, the volume of septage anticipated, and whether adequate capacity is available. 9.2.7 Any consideration given to onsite maintenance districts or zones. 9.2.8 Any consideration given to the development and implementation of, or coordination with, Regional Salt and Nutrient Management Plans. 9.2.9 Any consideration given to coordination with watershed management groups. 9.2.10 Procedures for evaluating the proximity of sewer systems to new or replacement OWTS installations. 9.2.11 Procedures for notifying the owner of a public water system prior to issuing an installation or repair permit for an OWTS, if the OWTS is within 1,200 feet of an intake point for a surface water treatment plant for drinking water, is in the drainage area catchment in which the intake point is located, and is located such that it may impact water quality at the intake point such as upstream of the intake point for a flowing water body, or if the OWTS is within a horizontal sanitary setback from a public well. 9.2.12 Policies and procedures that will be followed when a proposed OWTS dispersal area is within the horizontal sanitary setback of a public well or a surface water intake point. These policies and procedures shall either indicate that supplemental treatment as specified in 10.9 and 10.10 of this policy are required for OWTS that are within a horizontal sanitary setback of a public well or surface water intake point, or will establish alternate siting and operational criteria for the proposed OWTS that would similarly mitigate the potential adverse impact to the public water source. 9.2.13 Any plans for the phase-out or discontinuance of cesspool usage. 9.3 The minimum responsibilities of the local agency for management of the Local Agency Management Program include: 9.3.1 Maintain records of the number, location, and description of permits issued for OWTS where a variance is granted.
30 Tier 2 – Local Agency OWTS Management Program
9.3.2 Maintain a water quality assessment program to determine the general operation status of OWTS and to evaluate the impact of OWTS discharges, and assess the extent to which groundwater and local surface water quality may be adversely impacted. The focus of the assessment should be areas with characteristics listed under section 9.1. The assessment program will include monitoring and analysis of water quality data, review of complaints, variances, failures, and any information resulting from inspections. The assessment may use existing water quality data from other monitoring programs and/or establish the terms, conditions, and timing for monitoring done by the local agency. At a minimum this assessment will include monitoring data for nitrates and pathogens, and may include data for other constituents which are needed to adequately characterize the impacts of OWTS on water quality. Other monitoring programs for which data may be used include but are not limited to any of the following: 9.3.2.1. Random well samples from a domestic well sampling program. 9.3.2.2. Routine real estate transfer samples if those are performed and reported. 9.3.2.3. Review of public system sampling reports done by the local agency or another municipality responsible for the public system. 9.3.2.4. Water quality testing reports done at the time of new well development if those are reported. 9.3.2.5. Beach water quality testing data performed as part of Health and Safety Code Section 115885. 9.3.2.6. Receiving water sampling performed as a part of a NPDES permit. 9.3.2.7. Data contained in the California Water Quality Assessment Database. 9.3.2.8. Groundwater sampling performed as part of Waste Discharge Requirements. 9.3.2.9. Groundwater data collected as part of the Groundwater Ambient Monitoring and Assessment Program and available in the Geotracker Database. 9.3.3 Submit an annual report by February 1 to the applicable Regional Water Board summarizing the status of items 9.3.1 through 9.3.2 above. Every fifth year, submit an evaluation of the monitoring program and an assessment of whether water quality is being impacted by OWTS, identifying any changes in the Local Agency Management Program that will be undertaken to address impacts from OWTS. The first report will commence one year after approval of the local agency’s Local Agency Management Program. In addition to summarizing monitoring data collected per 9.3.2 above, all groundwater monitoring data generated by the local agency shall be submitted in EDF format for inclusion into
31 Tier 2 – Local Agency OWTS Management Program
Geotracker, and surface water monitoring shall be submitted to CEDEN in a SWAMP comparable format. 9.4 The following are not allowed to be authorized in a Local Agency Management Program: 9.4.1 Cesspools of any kind or size. 9.4.2 OWTS receiving a projected flow over 10,000 gallons per day. 9.4.3 OWTS that utilize any form of effluent disposal that discharges on or above the post installation ground surface such as sprinklers, exposed drip lines, free-surface wetlands, or a pond. 9.4.4 Slopes greater than 30 percent without a slope stability report approved by a registered professional. 9.4.5 Decreased leaching area for IAPMO certified dispersal systems using a multiplier less than 0.70. 9.4.6 OWTS utilizing supplemental treatment without requirements for periodic monitoring or inspections. 9.4.7 OWTS dedicated to receiving significant amounts of wastes dumped from RV holding tanks. 9.4.8 Separation of the bottom of dispersal system to groundwater less than two (2) feet, except for seepage pits, which shall not be less than 10 feet. 9.4.9 Installation of new or replacement OWTS where public sewer is available. The public sewer may be considered as not available when such public sewer or any building or exterior drainage facility connected thereto is located more than 200 feet from any proposed building or exterior drainage facility on any lot or premises that abuts and is served by such public sewer. This provision does not apply to replacement OWTS where the connection fees and construction cost are greater than twice the total cost of the replacement OWTS and the local agency determines that the discharge from the OWTS will not affect groundwater or surface water to a degree that makes it unfit for drinking or other uses. 9.4.10 Except as provided for in sections 9.4.11 and 9.4.12, new or replacement OWTS with minimum horizontal setbacks less than any of the following: 9.4.10.1 150 feet from a public water well where the depth of the effluent dispersal system does not exceed 10 feet in depth. 9.4.10.2 200 feet from a public water well where the depth of the effluent dispersal system exceeds 10 feet in depth. 9.4.10.3 Where the effluent dispersal system is within 600 feet of a public water well and exceeds 20 feet in depth the horizontal setback required to achieve a two-year travel time for microbiological contaminants shall be evaluated. A qualified professional shall conduct this evaluation. However in no case shall the setback be less than 200 feet. 32 Tier 2 – Local Agency OWTS Management Program
9.4.10.4 Where the effluent dispersal system is within 1,200 feet from a public water systems’ surface water intake point, within the catchment of the drainage, and located such that it may impact water quality at the intake point such as upstream of the intake point for flowing water bodies, the dispersal system shall be no less than 400 feet from the high water mark of the reservoir, lake or flowing water body. 9.4.10.5 Where the effluent dispersal system is located more than 1,200 feet but less than 2,500 feet from a public water systems’ surface water intake point, within the catchment area of the drainage, and located such that it may impact water quality at the intake point such as upstream of the intake point for flowing water bodies, the dispersal system shall be no less than 200 feet from the high water mark of the reservoir, lake or flowing water body. 9.4.11 For replacement OWTS that do not meet the above horizontal separation requirements, the replacement OWTS shall meet the horizontal separation to the greatest extent practicable. In such case, the replacement OWTS shall utilize supplemental treatment and other mitigation measures, unless the permitting authority finds that there is no indication that the previous system is adversely affecting the public water source, and there is limited potential that the replacement system could impact the water source based on topography, soil depth, soil texture, and groundwater separation. 9.4.12 For new OWTS, installed on parcels of record existing at the time of the effective date of this Policy, that cannot meet the above horizontal separation requirements, the OWTS shall meet the horizontal separation to the greatest extent practicable and shall utilize supplemental treatment for pathogens as specified in section 10.8 and any other mitigation measures prescribed by the permitting authority. 9.5 A Local Agency Management Program for OWTS must include adequate detail, including technical information to support how all the criteria in their program work together to protect water quality and public health. 9.6 A Regional Water Board reviewing a Local Agency Management Program shall consider, among other things, the past performance of the local program to adequately protect water quality, and where this has been achieved with criteria differing from Tier 1, shall not unnecessarily require modifications to the program for purposes of uniformity, as long as the Local Agency Management Program meets the requirements of Tier 2.
33 Tier 3 – Impaired Areas
Tier 3 – Advanced Protection Management Programs for Impaired Areas
Existing, new, and replacement OWTS that are near impaired water bodies may be addressed by a TMDL and its implementation program, or special provisions contained in a Local Agency Management Program. If there is no TMDL or special provisions, new or replacement OWTS within 600 feet of impaired water bodies listed in Attachment 2 must meet the applicable specific requirements of Tier 3.
10.0 Advanced Protection Management Program An Advanced Protection Management Program is the minimum required management program for all OWTS located near a water body that has been listed as impaired due to nitrogen or pathogen indicators pursuant to Section 303(d) of the Clean Water Act. Local agencies are authorized to implement Advanced Protection Management Programs in conjunction with an approved Local Agency Management Program or, if there is no approved Local Agency Management Program, Tier 1. Local agencies are encouraged to collaborate with the Regional Water Boards by sharing any information pertaining to the impairment, provide advice on potential remedies, and regulate OWTS to the extent that their authority allows for the improvement of the impairment. 10.1 The geographic area for each water body’s Advanced Protection Management Program is defined by the applicable TMDL, if one has been approved. If there is not an approved TMDL, it is defined by an approved Local Agency Management Program, if it contains special provisions for that water body. If it is not defined in an approved TMDL or Local Agency Management Program, it shall be 600 linear feet [in the horizontal (map) direction] of a water body listed in Attachment 2 where the edge of that water body is the natural or levied bank for creeks and rivers, the high water mark for lakes and reservoirs, and the mean high tide line for tidally influenced water bodies, as appropriate. OWTS near impaired water bodies that are not listed on Attachment 2, and do not have a TMDL and are not covered by a Local Agency Management Program with special provisions, are not addressed by Tier 3. 10.2 The requirements of an Advanced Protection Management Program will be in accordance with a TMDL implementation plan, if one has been adopted to address the impairment. An adopted TMDL implementation plan supersedes all other requirements in Tier 3. All TMDL implementation plans adopted after the effective date of this Policy that contain load allocations for OWTS shall include a schedule that requires compliance with the load allocations as soon as practicable, given the watershed-specific circumstances. The schedule shall require that OWTS implementation actions for OWTS installed prior to the TMDL implementation plan’s effective date shall commence within 3 years after the TMDL implementation plan’s effective date, and that OWTS implementation actions for OWTS installed after the TMDL implementation plan’s effective date shall commence immediately. The TMDL implementation plan may use some or all of the Tier 3 requirements and shall establish the applicable area of
34 Tier 3 – Impaired Areas
implementation for OWTS requirements within the watershed. For those impaired water bodies that do have an adopted TMDL addressing the impairment, but the TMDL does not assign a load allocation to OWTS, no further action is required unless the TMDL is modified at some point in the future to include actions for OWTS. Existing, new, and replacement OWTS that are near impaired water bodies and are covered by a Basin Plan prohibition must also comply with the terms of the prohibition, as provided in Section 2.1. 10.3 In the absence of an adopted TMDL implementation plan, the requirements of an Advanced Protection Management Program will consist of any special provisions for the water body if any such provisions have been approved as part of a Local Agency Management Program. 10.4 The Regional Water Boards shall adopt TMDLs for impaired water bodies identified in Attachment 2, in accordance with the specified dates. 10.4.1 If a Regional Water Board does not complete a TMDL within two years of the time period specified in Attachment 2, coverage under this Policy’s waiver of waste discharge requirements shall expire for any OWTS that has any part of its dispersal system discharging within the geographic area of an Advanced Protection Management Program. The Regional Water Board shall issue waste discharge requirements, general waste discharge requirements, waivers of waste discharge requirements, or require corrective action for such OWTS. The Regional Water Board will consider the following when establishing the waste discharge requirements, general waste discharge requirements, waivers of waste discharge requirements, or requirement for corrective action: 10.4.1.1 Whether supplemental treatment should be required. 10.4.1.2 Whether routine inspection of the OWTS should be required. 10.4.1.3 Whether monitoring of surface and groundwater should be performed. 10.4.1.4 The collection of a fee for those OWTS covered by the order. 10.4.1.5 Whether owners of previously-constructed OWTS should file a report by a qualified professional in accordance with section 10.5. 10.4.1.6 Whether owners of new or replacement OWTS should file a report of waste discharge with additional supporting technical information as required by the Regional Water Board. 10.5 If the Regional Water Board requires owners of OWTS to submit a qualified professional’s report pursuant to Section 10.4.1.5, the report shall include a determination of whether the OWTS is functioning properly and as designed or requires corrective actions per Tier 4, and regardless of its state of function, whether it is contributing to impairment of the water body. 10.5.1 The qualified professional’s report may also include, but is not limited to:
35 Tier 3 – Impaired Areas
10.5.1.1 A general description of system components, their physical layout, and horizontal setback distances from property lines, buildings, wells, and surface waters. 10.5.1.2 A description of the type of wastewater discharged to the OWTS such as domestic, commercial, or industrial and classification of it as domestic wastewater or high-strength waste. 10.5.1.3 A determination of the systems design flow and the volume of wastewater discharged daily derived from water use, either estimated or actual if metered. 10.5.1.4 A description of the septic tank, including age, size, material of construction, internal and external condition, water level, scum layer thickness, depth of solids, and the results of a one-hour hydrostatic test. 10.5.1.5 A description of the distribution box, dosing siphon, or distribution pump, and if flow is being equally distributed throughout the dispersal system, as well as any evidence of solids carryover, clear water infiltration, or evidence of system backup. 10.5.1.6 A description of the dispersal system including signs of hydraulic failure, condition of surface vegetation over the dispersal system, level of ponding above the infiltrative surface within the dispersal system, other possible sources of hydraulic loading to the dispersal area, and depth of the seasonally high groundwater level. 10.5.1.7 A determination of whether the OWTS is discharging to the ground’s surface. 10.5.1.8 For a water body listed as an impaired water body for pathogens, a determination of the OWTS dispersal system’s separation from its deepest most infiltrative surface to the highest seasonal groundwater level or fractured bedrock. 10.5.1.9 For a water body listed as an impaired water body for nitrogen, a determination of whether the groundwater under the dispersal field is reaching the water body, and a description of the method used to make the determination. 10.6 For new, replacement, and existing OWTS in an Advanced Protection Management Program, the following are not covered by this Policy’s waiver but may be authorized by a separate Regional Water Board order: 10.6.1 Cesspools of any kind or size. 10.6.2 OWTS receiving a projected flow over 10,000 gallons per day. 10.6.3 OWTS that utilize any form of effluent disposal on or above the ground surface. 10.6.4 Slopes greater than 30 percent without a slope stability report approved by a registered professional.
36 Tier 3 – Impaired Areas
10.6.5 Decreased leaching area for IAPMO certified dispersal systems using a multiplier less than 0.70. 10.6.6 OWTS utilizing supplemental treatment without requirements for periodic monitoring or inspections. 10.6.7 OWTS dedicated to receiving significant amounts of wastes dumped from RV holding tanks. 10.6.8 Separation of the bottom of dispersal system to groundwater less than two (2) feet, except for seepage pits, which shall not be less than 10 feet. 10.6.9 Minimum horizontal setbacks less than any of the following: 10.6.9.1 150 feet from a public water well where the depth of the effluent dispersal system does not exceed 10 feet in depth; 10.6.9.2 200 feet from a public water well where the depth of the effluent dispersal system exceeds 10 feet in depth: 10.6.9.3 Where the effluent dispersal system is within 600 feet of a public water well and exceeds 20 feet in depth the horizontal setback required to achieve a two-year travel time for microbiological contaminants shall be evaluated. A qualified professional shall conduct this evaluation. However in no case shall the setback be less than 200 feet. 10.6.9.4 Where the effluent dispersal system is within 1,200 feet from a public water systems’ surface water intake point, within the catchment of the drainage, and located such that it may impact water quality at the intake point such as upstream of the intake point for flowing water bodies, the dispersal system shall be no less than 400 feet from the high water mark of the reservoir, lake or flowing water body. 10.6.9.5 Where the effluent dispersal system is located more than 1,200 feet but less than 2,500 feet from a public water systems’ surface water intake point, within the catchment of the drainage, and located such that it may impact water quality at the intake point such as upstream of the intake point for flowing water bodies, the dispersal system shall be no less than 200 feet from the high water mark of the reservoir, lake or flowing water body. 10.6.9.6 For replacement OWTS that do not meet the above horizontal separation requirements, the replacement OWTS shall meet the horizontal separation to the greatest extent practicable. In such case, the replacement OWTS shall utilize supplemental treatment and other mitigation measures. 10.6.9.7 For new OWTS, installed on parcels of record existing at the time of the effective date of this Policy, that cannot meet the above horizontal separation requirements, the OWTS shall meet the horizontal separation to the greatest extent practicable and shall
37 Tier 3 – Impaired Areas
utilize supplemental treatment for pathogens as specified in section 10.10 and any other mitigation measures as prescribed by the permitting authority. 10.7 The requirements contained in Section 10 shall not apply to owners of OWTS that are constructed and operating, or permitted, on or prior to the date that the nearby water body is added to Attachment 2 who commit by way of a legally binding document to connect to a centralized wastewater collection and treatment system regulated through WDRs as specified within the following timeframes: 10.7.1 The owner must sign the document within forty-eight months of the date that the nearby water body is initially listed on Attachment 2. 10.7.2 The specified date for the connection to the centralized community wastewater collection and treatment system shall not extend beyond nine years following the date that the nearby water body is added to Attachment 2. 10.8 In the absence of an adopted TMDL implementation plan or Local Agency Management Program containing special provisions for the water body, all new or replacement OWTS permitted after the date that the water body is initially listed in Attachment 2 that have any discharge within the geographic area of an Advanced Protection Management Program shall meet the following requirements: 10.8.1 Utilize supplemental treatment and meet performance requirements in 10.9 if impaired for nitrogen and 10.10 if impaired for pathogens, 10.8.2 Comply with the setback requirements of Section 7.5.1 to 7.5.5, and 10.8.3 Comply with any applicable Local Agency Management Program requirements. 10.9 Supplemental treatment requirements for nitrogen 10.9.1 Effluent from the supplemental treatment components designed to reduce nitrogen shall be certified by NSF, or other approved third party tester, to meet a 50 percent reduction in total nitrogen when comparing the 30-day average influent to the 30-day average effluent. 10.9.2 Where a drip-line dispersal system is used to enhance vegetative nitrogen uptake, the dispersal system shall have at least six (6) inches of soil cover.
38 Tier 3 – Impaired Areas
10.10 Supplemental treatment requirements for pathogens 10.10.1 Supplemental treatment components designed to perform disinfection shall provide sufficient pretreatment of the wastewater so that effluent from the supplemental treatment components does not exceed a 30-day average TSS of 30 mg/L and shall further achieve an effluent fecal coliform bacteria concentration less than or equal to 200 Most Probable Number (MPN) per 100 milliliters. 10.10.2 The minimum soil depth and the minimum depth to the anticipated highest level of groundwater below the bottom of the dispersal system shall not be less than three (3) feet. All dispersal systems shall have at least twelve (12) inches of soil cover. 10.11 OWTS in an Advanced Protection Management Program with supplemental treatment shall be designed to meet the applicable performance requirements above and shall be stamped or approved by a Qualified Professional. 10.12 Prior to the installation of any proprietary treatment OWTS in an Advanced Protection Management Program, all such treatment components shall be tested by an independent third party testing laboratory. 10.13 The ongoing monitoring of OWTS in an Advanced Protection Management Program with supplemental treatment components designed to meet the performance requirements in Sections 10.9 and 10.10 shall be monitored in accordance with the operation and maintenance manual for the OWTS or more frequently as required by the local agency or Regional Water Board. 10.14 OWTS in an Advanced Protection Management Program with supplemental treatment components shall be equipped with a visual or audible alarm as well as a telemetric alarm that alerts the owner and service provider in the event of system malfunction. Where telemetry is not possible, the owner or owner’s agent shall inspect the system at least monthly while the system is in use as directed and instructed by a service provider and notify the service provider not less than quarterly of the observed operating parameters of the OWTS. 10.15 OWTS in an Advanced Protection Management Program designed to meet the disinfection requirements in Section 10.10 shall be inspected for proper operation quarterly while the system is in use by a service provider unless a telemetric monitoring system is capable of continuously assessing the operation of the disinfection system. Testing of the wastewater flowing from supplemental treatment components that perform disinfection shall be sampled at a point in the system after the treatment components and prior to the dispersal system and shall be conducted quarterly based on analysis of total coliform with a minimum detection limit of 2.2 MPN. All effluent samples must include the geographic coordinates of the sample’s location. Effluent samples shall be taken by a service provider and analyzed by a California Department of Public Health certified laboratory.
39 Tier 3 – Impaired Areas
10.16 The minimum responsibilities of a local agency administering an Advanced Protection Management Program include those prescribed for the Local Agency Management Programs in Section 9.3 of this policy, as well as monitoring owner compliance with Sections 10.13, 10.14,and 10.15.
40 Tier 4 – OWTS Requiring Corrective Action
Tier 4 – OWTS Requiring Corrective Action OWTS that require corrective action or are either presently failing or fail at any time while this Policy is in effect are automatically included in Tier 4 and must follow the requirements as specified. OWTS included in Tier 4 must continue to meet applicable requirements of Tier 0, 1, 2 or 3 pending completion of corrective action.
11.0 Corrective Action for OWTS 11.1 Any OWTS that has pooling effluent, discharges wastewater to the surface, or has wastewater backed up into plumbing fixtures, because its dispersal system is no longer adequately percolating the wastewater is deemed to be failing, no longer meeting its primary purpose to protect public health, and requires major repair, and as such the dispersal system must be replaced, repaired, or modified so as to return to proper function and comply with Tier 1, 2, or 3 as appropriate. 11.2 Any OWTS septic tank failure, such as a baffle failure or tank structural integrity failure such that either wastewater is exfiltrating or groundwater is infiltrating is deemed to be failing, no longer meeting its primary purpose to protect public health, and requires major repair, and as such shall require the septic tank to be brought into compliance with the requirements of Section 8 in Tier 1 or a Local Agency Management Program per Tier 2. 11.3 Any OWTS that has a failure of one of its components other than those covered by 11.1 and 11.2 above, such as a distribution box or broken piping connection, shall have that component repaired so as to return the OWTS to a proper functioning condition and return to Tier 0, 1, 2, or 3. 11.4 Any OWTS that has affected, or will affect, groundwater or surface water to a degree that makes it unfit for drinking or other uses, or is causing a human health or other public nuisance condition shall be modified or upgraded so as to abate its impact. 11.5 If the owner of the OWTS is not able to comply with corrective action requirements of this section, the Regional Water Board may authorize repairs that are in substantial conformance, to the greatest extent practicable, with Tiers 1 or 3, or may require the owner of the OWTS to submit a report of waste discharge for evaluation on a case-by-case basis. Regional Water Board response to such reports of waste discharge may include, but is not limited to, enrollment in general waste discharge requirements, issuance of individual waste discharge requirements, or issuance of waiver of waste discharge requirements. A local agency may authorize repairs that are in substantial conformance, to the greatest extent practicable, with Tier 2 in accordance with section 9.2.3 if there is an approved Local Agency Management Program, or with an existing program if a Local Agency Management Program has not been approved and it is less than 5 years from the effective date of the Policy.
41 Tier 4 – OWTS Requiring Corrective Action
11.6 Owners of OWTS will address any corrective action requirement of Tier 4 as soon as is reasonably possible, and must comply with the time schedule of any corrective action notice received from a local agency or Regional Water Board, to retain coverage under this Policy. 11.7 Failure to meet the requirements of Tier 4 constitute a failure to meet the conditions of the waiver of waste discharge requirements contained in this Policy, and is subject to further enforcement action.
42 Waiver – Effective Date – Financial Assistance
Conditional Waiver of Waste Discharge Requirements
12.0 In accordance with Water Code section 13269, the State Water Board hereby waives the requirements to submit a report of waste discharge, obtain waste discharge requirements, and pay fees for discharges from OWTS covered by this Policy. Owners of OWTS covered by this Policy shall comply with the following conditions: 12.0.1 The OWTS shall function as designed with no surfacing effluent. 12.0.2 The OWTS shall not utilize a dispersal system that is in soil saturated with groundwater. 12.0.3 The OWTS shall not be operated while inundated by a storm or flood event. 12.0.4 The OWTS shall not cause or contribute to a condition of nuisance or pollution. 12.0.5 The OWTS shall comply with all applicable local agency codes, ordinances, and requirements. 12.0.6 The OWTS shall comply with and meet any applicable TMDL implementation requirements, special provisions for impaired water bodies, or supplemental treatment requirements imposed by Tier 3. 12.0.7 The OWTS shall comply with any corrective action requirements of Tier 4. 12.1 This waiver may be revoked by the State Water Board or the applicable Regional Water Board for any discharge from an OWTS, or from a category of OWTS.
Effective Date
13.0 This Policy becomes effective six months after its approval by the Office of Administrative Law, and all deadlines and compliance dates stated herein start at such time.
43 Waiver – Effective Date – Financial Assistance
Financial Assistance
14.0 Local Agencies may apply to the State Water Board for funds from the Clean Water State Revolving Fund for use in mini-loan programs that provide low interest loan assistance to private property owners with costs associated with complying with this Policy. 14.1 Loan interest rates for loans to local agencies will be set by the State Water Board using its policies, procedures, and strategies for implementing the Clean Water State Revolving Fund program, but will typically be one-half of the States most recent General Obligation bond sale. Historically interest rates have ranged between 2.0 and 3.0 percent. 14.2 Local agencies may add additional interest points to their loans made to private entities to cover their costs of administering the mini-loan program. 14.3 Local agencies may submit their suggested loan eligibility criteria for the min-loan program they wish to establish to the State Water Board for approval, but should consider the legislative intent stated in Water Code Section 13291.5 is that assistance is encouraged for private property owners whose cost of complying with the requirements of this policy exceeds one-half of one percent of the current assessed value of the property on which the OWTS is located.
44 Attachment 1
OWTS Policy Time Lines
E V7 6/4/2012 f f e c t i v e
D Year 5 Year 10 Year 15 a t e nd rd
P Initial Waiver 2 Waiver 3 Waiver o l i c y a n d
W a i v e r
A d o 6 p 1 yr 2 yrs 1 yr 1 yr 1 yr t e mth d W R a L R a L S n o d o B B B i d c j c t
u s h D a a r
s s
e a l l S S S P i t u s v A m A l B B B o i b p i g e u u l e m
u i n w r r r t t c n t h h e e e
i y e
B t t o o n n n a
P p a R r r e e e n i i e s r t t w w w d e i y o i r e n
s s s s
i g c c O E a o s o
o o r P p W W W
d n W l a D n m u p d l m a a a a n t e r T
p i n o o i i i o e v S v v v l s v f e n e c e e e
a i t t l o r r r n o e i l o w i p
t n s i n
a e
e ( l w
1 r p s 0 e e
. r t r End of initial period for 7
o i o )
OWTS owners to sign sewer d L
f o connection agreement (10.7) o c r
a l
A g e n c y
A n n u a l
R o F e f O A n i A i p f r s t W
s s o h 4 s t s r
t e T h y t r e s
s e S e y s s p a e
s m i o m r m a r e r t p e
n s a n t t c
t a r
t r e r s e t p
s p e o
o v r r e t
t r o
y 45 f
SB – State Water Board RB – Regional Water Board
Attachment 2
The tables below specifically identify those impaired water bodies where: (1) it is likely that operating OWTS will subsequently be determined to be a contributing source of pathogens or nitrogen and therefore it is anticipated that OWTS would receive a loading reduction, and (2) it is likely that new OWTS installations discharging within 600 feet of the water body would contribute to the impairment. Per this Policy (Tier 3, Section 10) the Regional Water Boards must adopt a TMDL by the date specified in the table. The State Water Board, at the time of approving future 303 (d) Lists, will specifically identify those impaired water bodies that are to be added or removed from the tables below. Table 5. Water Bodies impaired for pathogens that are subject to Tier 3 as of 2012.
TMDL
NO. Completion
REGION REGION NAME WATERBODY NAME COUNTIES Date 1 North Coast Clam Beach Humboldt 2020 1 North Coast Luffenholtz Beach Humboldt 2020 1 North Coast Moonstone County Park Humboldt 2020 1 North Coast Russian River HU, Lower Russian River HA, Guerneville HSA, Sonoma 2016 mainstem Russian River from Fife Creek to Dutch Bill Creek 1 North Coast Russian River HU, Lower Russian River HA, Guerneville HSA, Sonoma 2016 Green Valley Creek watershed 1 North Coast Russian River HU, Middle Russian River HA, Geyserville HSA, Sonoma 2016 mainstem Russian River at Healdsburg Memorial Beach and unnamed tributary at Fitch Mountain 1 North Coast Russian River HU, Middle Russian River HA, mainstem Sonoma 2016 Laguna de Santa Rosa 1 North Coast Russian River HU, Middle Russian River HA, mainstem Santa Sonoma 2016 Rosa Creek 1 North Coast Trinidad State Beach Humboldt 2020
2 San Francisco China Camp Beach Marin Bay 2014 2 San Francisco Lawsons Landing Marin Bay 2015 San Francisco 2 Bay Pacific Ocean at Bolinas Beach Marin 2014
46
Attachment 2
TMDL
NO. Completion
REGION REGION NAME WATERBODY NAME COUNTIES Date 2 San Francisco Pacific Ocean at Fitzgerald Marine Reserve San Mateo Bay 2016 2 San Francisco Pacific Ocean at Muir Beach Marin Bay 2015 2 San Francisco Pacific Ocean at Pillar Point Beach San Mateo Bay 2016 2 San Francisco Petaluma River Marin, Sonoma Bay 2017 2 San Francisco Petaluma River (tidal portion) Marin, Sonoma Bay 2017 2 San Francisco San Gregorio Creek San Mateo Bay 2019 3 Central Coast Pacific Ocean at Point Rincon (mouth of Rincon Cr, Santa Santa Barbara Barbara County) 2015 3 Central Coast Rincon Creek Santa Barbara, Ventura 2015 4 Los Angeles Canada Larga (Ventura River Watershed) Ventura 2017 4 Los Angeles Coyote Creek Los Angeles, Orange 2015 4 Los Angeles Rincon Beach Ventura 2017 4 Los Angeles San Antonio Creek (Tributary to Ventura River Reach 4) Ventura 2017 4 Los Angeles San Gabriel River Reach 1 (Estuary to Firestone) Los Angeles 2015 4 Los Angeles San Gabriel River Reach 2 (Firestone to Whittier Narrows Los Angeles Dam 2015 4 Los Angeles San Gabriel River Reach 3 (Whittier Narrows to Ramona) Los Angeles 2015 4 Los Angeles San Jose Creek Reach 1 (SG Confluence to Temple St.) Los Angeles 2015 4 Los Angeles San Jose Creek Reach 2 (Temple to I-10 at White Ave.) Los Angeles 2015 4 Los Angeles Sawpit Creek Los Angeles 2015 4 Los Angeles Ventura River Reach 3 (Weldon Canyon to Confl. w/ Coyote Ventura Cr) 2017 4 Los Angeles Walnut Creek Wash (Drains from Puddingstone Res) Los Angeles 2015 5 Central Valley Wolf Creek (Nevada County) Nevada, Placer 2020 5 Central Valley Woods Creek (Tuolumne County) Tuolumne 2020 7 Colorado River Alamo River Imperial 2017
47
Attachment 2
TMDL
NO. Completion
REGION REGION NAME WATERBODY NAME COUNTIES Date 7 Colorado River Palo Verde Outfall Drain and Lagoon Imperial, Riverside 2017 8 Santa Ana Canyon Lake (Railroad Canyon Reservoir) Riverside 2019 8 Santa Ana Fulmor, Lake Riverside 2019 8 Santa Ana Goldenstar Creek Riverside 2019 8 Santa Ana Los Trancos Creek (Crystal Cove Creek) Orange 2017 8 Santa Ana Lytle Creek San Bernardino 2019 8 Santa Ana Mill Creek Reach 1 San Bernardino 2015 8 Santa Ana Mill Creek Reach 2 San Bernardino 2015 8 Santa Ana Morning Canyon Creek Orange 2017 8 Santa Ana Mountain Home Creek San Bernardino 2019 8 Santa Ana Mountain Home Creek, East Fork San Bernardino 2019 8 Santa Ana Silverado Creek Orange 2017 8 Santa Ana Peters Canyon Channel Orange 2017 8 Santa Ana Santa Ana River, Reach 2 Orange, Riverside 2019 Temescal Creek, Reach 6 (Elsinore Groundwater sub basin 8 Santa Ana boundary to Lake Elsinore Outlet) Riverside 2019 8 Santa Ana Seal Beach Orange 2017 8 Santa Ana Serrano Creek Orange 2017 8 Santa Ana Huntington Harbour Orange 2017
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Attachment 2
Table 6. Water Bodies impaired for nitrogen that are subject to Tier 3.
TMDL Completion
REGION NAME WATERBODY NAME COUNTIES Date REGIONNO. Russian River HU, Middle Russian River HA, mainstem 1 North Coast Laguna de Santa Rosa Sonoma 2015 San Francisco 2 Bay Lagunitas Creek Marin 2016 San Francisco 2 Bay Napa River Napa, Solano 2014 San Francisco 2 Bay Petaluma River Marin, Sonoma 2017 San Francisco 2 Bay Petaluma River (tidal portion) Marin, Sonoma 2017 San Francisco 2 Bay Sonoma Creek Sonoma 2014 San Francisco 2 Bay Tomales Bay Marin 2019 San Francisco 2 Bay Walker Creek Marin 2016 4 Los Angeles Malibu Creek Los Angeles 2016 4 Los Angeles San Antonio Creek (Tributary to Ventura River Reach 4) Ventura 2013 8 Santa Ana East Garden Grove Wintersburg Channel Orange 2017 8 Santa Ana Grout Creek San Bernardino 2015 8 Santa Ana Rathbone (Rathbun) Creek San Bernardino 2015 8 Santa Ana Summit Creek San Bernardino 2015 8 Santa Ana Serrano Creek Orange 2017
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Attachment 3
Regional Water Boards, upon mutual agreement, may designate one Regional Water Board to regulate a person or entity that is under the jurisdiction of both (Water Code Section 13228). The following table identifies the designated Regional Water Board for all counties within the State for purposes of reviewing and, if appropriate, approving new Local Agency Management Plans.
Table 7. Regional Water Board designations by County.
Regions with Designated Regions with Designated County Jurisdiction Region County Jurisdiction Region Alameda 2,5 2 Placer 5,6 5 Alpine 5,6 6 Plumas 5 5 Amador 5 5 Riverside 7,8,9 7 Butte 5 5 Sacramento 5 5 Calaveras 5 5 San Benito 3,5 3 Colusa 5 5 San Contra Bernardino 6,7,8 6 Costa 2,5 2 San Diego 9,7 9 Del Norte 1 1 San El Dorado 5,6 5 Francisco 2 2 Fresno 5 5 San Joaquin 5 5 Glenn 5,1 5 San Luis Obispo 3,5 3 Humboldt 1 1 San Mateo 2,3 2 Imperial 7 7 Santa Inyo 6 6 Barbara 3 3 Kern 3,4,5,6 5 Santa Clara 2,3 2 Kings 5 5 Santa Cruz 3 3 Lake 5,1 5 Shasta 5 5 Lassen 5,6 6 Sierra 5,6 5 Los Angeles 4,6 4 Siskiyou 1,5 1 Madera 5 5 Solano 2,5 5 Marin 2,1 2 Sonoma 1,2 1 Mariposa 5 5 Stanislaus 5 5 Mendocino 1 1 Sutter 5 5 Merced 5 5 Tehama 5 5 Modoc 1,5,6 5 Trinity 1 1 Mono 6 6 Tulare 5 5 Monterey 3 3 Tuolumne 5 5 Napa 2,5 2 Ventura 4,3 4 Nevada 5,6 5 Yolo 5 5 Orange 8,9 8 Yuba 5 5
50 Nutrient Management Plan For the Livermore Valley Groundwater Basin
November 2014
PREPARED BYY:
ZONE 7 WATER AGENCY 100 North Canyons Parkway Livermore, CA 94551 (925) 454-5000
Nutrient Management Plan
Livermore Valley Groundwater Basin
November 2014
PREPARED BY:
ZONE 7 WATER AGENCY
100 North Canyons Parkway
Livermore, CA 94551
(925) 454-5000
PREPARED BY:
ZONE 7 WATER AGENCY STAFF
Contributors:
Kurt Arends – Assistant General Manager Jarnail Chahal, P.E. – Engineering Manager Jill Duerig, P.E. – General Manager Matt Katen, P.G. – Principal Geologist Tom Rooze, P.G. – Associate Geologist Colleen Winey, P.G. – Assistant Geologist
Table of Contents
Page
ES Executive Summary ...... i ES 1 Background ...... i ES 2 Groundwater Basin Characteristics ...... i ES 3 Basin Nutrient Evaluation ...... ii ES 4 Antidegradation Analysis ...... iii ES 5 Nutrient Management Goals and Strategies ...... iv ES 6 Plan Implementation ...... v
1 Background ...... 7 1.1 Introduction ...... 7 1.2 Purpose and Management Objectives ...... 8 1.3 Regulatory Framework ...... 9 1.3.1 Master Water Recycling Permit and Salt Management Plan ...... 9 1.3.2 State Recycled Water Policy ...... 9 1.3.3 Onsite Wastewater Treatment Systems ...... 10 1.3.4 Zone 7 Wastewater Management Plan ...... 10 1.3.5 Groundwater Management Plan and Annual Reports ...... 11 1.4 Stakeholder Involvement ...... 11 1.5 CEQA Considerations ...... 12
2 Livermore Valley Groundwater Basin Characteristics ...... 13 2.1 Groundwater Basin Overview ...... 13 2.1.1 Geology ...... 14 2.1.2 Main and Fringe Basins ...... 15 2.1.3 Aquifer Zones ...... 15 2.1.1 Land Use ...... 19 2.2 Groundwater Inventory ...... 20 2.2.1 Conjunctive Use ...... 20 2.2.2 Groundwater Storage ...... 20
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2.2.3 Groundwater Production ...... 20 2.2.4 Groundwater Sustainability ...... 21 2.3 Basin Water Quality (Nutrients) ...... 23 2.3.1 Overview ...... 23 2.3.2 Nitrate Concentrations ...... 24 2.3.3 Assimilative Capacity ...... 29 2.4 Areas of Concern ...... 29
3 Basin Nutrient Evaluation ...... 36 3.1 Historical Sources of Nitrate ...... 36 3.2 Conceptual Model ...... 37 3.2.1 Fate and Transport of Nitrate ...... 37 3.2.2 Methodology ...... 37 3.3 Nitrogen Loading Calculations ...... 41 3.3.1 Current Nitrogen Loading ...... 41 3.3.2 Future Nitrate Loading ...... 45 3.4 Projected Nitrate Concentrations ...... 49
4 Proposed Projects and Antidegradation Analysis ...... 53 4.1 Recycled Water Projects ...... 53 4.2 Stormwater Capture Projects ...... 54 4.3 SWRCB Recycled Water Policy Criteria ...... 54 4.4 Antidegradation Assessment ...... 55
5 Nutrient Management Goals and Strategies ...... 57 5.1 Introduction ...... 57 5.2 Fertilizer Application ...... 57 5.3 Recycled Water Irrigation ...... 58 5.4 Livestock Manure Management ...... 58 5.5 Onsite Wastewater Treatment Systems ...... 58 5.5.1 General Septic Tank Management ...... 58 5.5.2 Septic Tank Management in Areas of Concern ...... 59 5.5.3 Winery Process Wastewater ...... 59
6 Plan Implementation ...... 61 6.1 Implementation Measures ...... 61 6.1.1 Introduction ...... 61 6.1.2 Fertilizer BMPs ...... 61 6.1.3 Recycled Water Irrigation BMPs ...... 61 6.1.4 Livestock Manure Management ...... 62 6.1.5 Onsite Wastewater Treatment and Disposal ...... 62
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6.2 Basin Monitoring Programs ...... 72 6.2.1 Introduction ...... 72 6.2.2 Nutrient Specific Monitoring Programs ...... 73 6.3 Implementation Schedule ...... 75
7 References ...... 77
List of Figures Page
Figure ES-1: Nitrate Concentrations (Upper Aquifer) and Areas of Concern ...... ii Figure ES-2: Total Nitrogen Loading and Removal ...... iii Figure ES-3: Antidegradation Assessment ...... iv Figure 2-1: Map of Livermore Valley Groundwater Basin and Subbasins (DWR, 1974) ...... 13 Figure 2-2: Recharge Area and Confining Layer above Upper Aquifer ...... 16 Figure 2-3: Gradient in Upper Aquifer, October 2013 ...... 17 Figure 2-4: Gradient in Lower Aquifer, October 2013 ...... 18 Figure 2-5: Map of Municipal Wells ...... 21 Figure 2-6: Groundwater Supply and Demand Components ...... 22 Figure 2-7: Maximum Concentration of Nutrients in Basin Areas ...... 23 Figure 2-8: Nitrate Concentrations in Upper Aquifer ...... 24 Figure 2-9: Nitrate Concentrations in Lower Aquifer ...... 25 Figure 2-10: Nitrate Concentrations by Node ...... 26 Figure 2-11: Storage (AF), Nitrate Concentrations (as NO3 in mg/L) and Assimilative Capacity (mg/L) by Node, Subbasin, and Basin Area ...... 27 Figure 2-12: Nitrate Concentrations by Subbasin, Aquifer, and Basin Area ...... 28 Figure 2-13: Average Nitrate Concentrations and Assimilative Capacities by Basin Area ...... 29 Figure 2-14: Nitrate Areas of Concern ...... 30 Figure 2-15: Nitrate Areas of Concern and Trends...... 35 Figure 3-1: Historical and Existing Sources of Nitrate ...... 36 Figure 3-2: Existing Nitrogen Sources and Removal ...... 38 Figure 3-3: Nitrogen Loading Rates from Horse Boarding, Rural Properties, and Wineries ...... 38 Figure 3-4: Nitrogen Loading Rates from Fertilized Irrigation by Land Use ...... 39 Figure 3-5: Source Water Application Rates from Irrigation by Land Use ...... 40 Figure 3-6: Nitrate Concentrations in Irrigation Source Water ...... 40 Figure 3-7: 2013 Land Use ...... 41 Figure 3-8: 2013 Source Water Distribution ...... 42 Figure 3-9: Total Nitrate Loading (in lbs N/acre) ...... 43 Figure 3-10: Net Nitrogen Loading by Basin, Current Land Use with Average Rainfall ...... 44 Figure 3-11: Summary of Current Total Nitrogen Loading and Removal ...... 45 Figure 3-12: Land Use at Buildout ...... 46 Figure 3-13: Source Water Distribution at Buildout ...... 47 Figure 3-14: Net Nitrogen Loading by Basin, Land Use at Buildout with Average Rainfall ...... 48 Figure 3-15: Summary of Total Nitrogen Loading and Removal at Buildout ...... 49 Figure 3-16: Predicted Nitrate Concentrations in Main Basin ...... 50
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Figure 3-17: Predicted Nitrate Concentrations in Fringe Basin North ...... 51 Figure 3-18: Predicted Nitrate Concentrations in Fringe Basin Northeast ...... 51 Figure 3-19: Predicted Nitrate Concentrations in Fringe Basin East ...... 52 Figure 4-1: Existing and Future Recycled Water Use ...... 53 Figure 4-2: Antidegradation Assessment ...... 56 Figure 6-1: Special OWTS Permit Areas ...... 66 Figure 6-2: Happy Valley Areas of Concern ...... 67 Figure 6-3: May School Area of Concern ...... 68 Figure 6-4: Buena Vista/Greenville Areas of Concern ...... 69 Figure 6-5: Mines Road Areas of Concern ...... 70 Figure 6-6: Tank OWTS Permit Requirements for Areas of Concern ...... 71 Figure 6-7: Map of Program Wells ...... 74
Acronyms and Abbreviations Abbrev Description Abbrev Description AC Assimilative Capacity LWRP Livermore Water Reclamation Plant ACEH Alameda County Environmental Health MCL Maximum contaminant level AF Acre-feet mg/L Milligrams per liter AF/yr Acre-feet per year N Nitrogen bgs Below ground surface NMP Nutrient Management Plan BMO Basin Management Objective NO3 Nitrate Ion BMP Best Management Practices OWTS Onsite Wastewater Treatment System BOs Basin Objectives PO4 Phosphate Ion CASGEM CA Statewide GW Elevation Monitoring POTW Publicly owned treatment works CDA Community Development Agency ROWD Request of Waste Discharge CDPH California Department of Health Services RRE Rural Residential Equivalence CEC Constituents-of-emerging-concern RWQCB Regional Water Quality Control Board CIMIS California Irrigation Management System SBA South Bay Aqueduct CEQA California Environmental Quality Act SCVWD Santa Clara Valley Water District CWS California Water Service SCWA Sonoma County Water Agency DSRSD Dublin San Ramon Services District SMP Salt Management Plan DWR California Department of Water Resources SNMP Salt Nutrient Management Plan EIR Environmental Impact Report SWP State Water Project ft Feet SWRCB State Water Resources Control Board GIS Geographic information systems TAF Thousand acre-feet GWMP Groundwater Management Plan TDS Total dissolved solids GPQ Groundwater Pumping Quota TKN Total Kjeldahl nitrogen LAFCO Local Agency Management Program USGS U.S. Geological Survey LAMP Local Agency Management Program WDR Waste Discharge Requirements lbs Pounds WWMP Wastewater Management Plan
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1 Background 1.1 Introduction
Zone 7 Water Agency (Zone 7) has actively managed the Livermore Valley Groundwater Basin (California Department of Water Resources [DWR] Basin No. 2-10) for over 50 years. Zone 7 prepared a Salt Management Plan (SMP) in 2004 to address the increasing level of total salts in the Main Basin of the Livermore Valley Groundwater Basin. The SMP was designed to protect the long-term water quality of the Main Basin and is a permit condition of the Master Water Recycling Permit, Regional Water Quality Control Board (RWQCB) Order No. 93-159, issued jointly to Zone 7, the City of Livermore, and Dublin San Ramon Services District (DSRSD). The SMP was approved by the RWQCB in October 2004 and was incorporated into Zone 7’s Groundwater Management Plan (GWMP) in 2005. The status of salt management has been updated in Zone 7's annual GWMP reports, copies of which are submitted to the RWQCB to satisfy associated permit reporting requirements.
In February 2009, the State Water Resources Control Board (SWRCB) adopted a Recycled Water Policy (SWRCB, Resolution No. 2009-0011) to encourage and facilitate the increased use of recycled water statewide. The policy requires among other things, that Salt/Nutrient Management Plans (SNMPs) be completed for all groundwater basins using recycled water in California. Because there is already an approved SMP for the Livermore Valley Groundwater Basin, a new SNMP is not required. However, to make the existing SMP comparable to the SNMP described in the Recycled Water Policy, Zone 7 has prepared this Nutrient Management Plan (NMP) as an addendum to its 2004 SMP. This plan does not cover other groundwater basins within the Zone 7 Service Area (Sunol Valley, San Joaquin – Tracy Subbasin) because there are no recycled water projects planned in those basins.
This report is organized into the following sections:
Section 1: Introduction – provides an overview of the report. Section 2: Livermore Valley Groundwater Basin Characteristics – provides an overview of the groundwater basin including groundwater inventory and basin water quality. Section 3: Basin Nutrient Evaluation – describes how Zone 7 manages the groundwater basin for storage and water quality. Section 4: Proposed Projects and Antidegradation Analysis – describes the proposed recycled water irrigation projects and how this plan addresses the State’s antidegradation policy (SWRCB, Resolution Number 68 – 16). Section 5: Goals and Strategies – describes the nutrient management options and strategies and outlines the nutrient management goals for groundwater, wastewater, and recycled water. Section 6: Plan Implementation – describes the implementation measures and provides an overview of the basin monitoring program. Section 0: References – a list of reports and documents that were used to prepare this report.
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1- Background
1.2 Purpose and Management Objectives
This NMP summarizes Zone 7's approach to managing nutrient loading in the Livermore Valley Groundwater Basin. The main purposes of this nutrient management plan are to:
Provide an assessment of the existing and future groundwater nutrients concentrations; Address the additional nutrient loading anticipated from the planned expansion of recycled water use over the groundwater basin; and Identify specific high groundwater nitrate areas and describe the planned management actions developed to address these impacted areas. Zone 7’s primary groundwater Basin Management Objective (BMO) is to provide for the control, protection and conservation of groundwater for future beneficial uses. The RWQCB’s Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan) designates the following beneficial uses for groundwater in the Livermore Valley Groundwater Basin:
Municipal and Domestic Supply Industrial Service and Process Supply Agricultural Supply The Basin Plan also specifies Groundwater Quality Objectives for total dissolved solids (TDS) and nitrate for the Livermore Valley Groundwater Basin as follows:
Central Basin TDS: Ambient or 500 milligrams per liter (mg/L), whichever is lower Nitrate (as NO3): 45mg/L
Fringe Subbasins TDS: Ambient or 1,000 mg/L, whichever is lower Nitrate (as NO3): 45mg/L
Upland and Highland Areas California domestic water quality standards set forth in California Code of Regulations, Title 22 and current county standards.
Waters designated for use as domestic or municipal water supply shall not contain concentrations of chemicals in excess of natural concentrations or the limits specified in California Code of Regulations, Title 22, Chapter 15, particularly Tables 64431-A and 64431-B of Section 64431, Table 64444-A of Section 64444, and Table 4 of Section 64443.
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1- Background
1.3 Regulatory Framework 1.3.1 Master Water Recycling Permit and Salt Management Plan
In 1993, the RWQCB issued a joint Master Water Recycling Permit (Master Permit) (Order No. 93-159) to Zone 7, DSRSD, and the City of Livermore authorizing the three agencies to produce, distribute and manage recycled water throughout the Livermore-Amador Valley (Valley). The Master Permit required that an SMP be developed to fully offset both current salt loading from natural sources and operations and any future salt loading associated with new recycled water projects before any extensive water recycling projects could be implemented in the Valley.
Between 1994 and 1999, Zone 7 developed a draft SMP for the Livermore Valley Groundwater Basin through a collaborative process with its retail water supply customers and the public. The SMP was finalized and approved by the RWQCB in 2004, and later incorporated into Zone 7’s GWMP.
DSRSD and the City of Livermore have since filed for, and have been granted, coverage under a regional General Water Reuse Order (General Order No. 96-011) to administer their current and future landscape irrigation recycled water projects within their individual jurisdictions. As with the Master Permit, the General Order requires that an SMP be developed and approved. The Master Permit has been kept active by the RWQCB at the request of DSRSD and Livermore only to address potential future groundwater recharge projects.
The City of Pleasanton has applied for permit coverage for their planned recycled water use projects under the same general order that DSRSD and City of Livermore’s recycled water programs are operating under (General Order No. 96-011), and reference Zone 7’s approved SMP in their application to satisfy the order’s SMP requirement.
1.3.2 State Recycled Water Policy
In 2009, the SWRCB adopted a Recycled Water Policy (SWRCB, Resolution No. 2009-0011) which requires that SNMPs be completed for all groundwater basins using recycled water in California. However, since an approved SMP already exists for the Livermore Valley Groundwater Basin, a new SNMP is not required.
In June 2014, the SWRCB adopted General Water Quality Order No. 2014-0090-DWQ to promote and regulate landscape irrigation recycled water projects within the state. This general order was written to be consistent with the State’s Recycled Water Policy in that it requires an SNMP be prepared and adopted by the RWQCB. This NMP will be submitted to the RWQCB as an amendment to the previously adopted SMP.
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1- Background
1.3.3 Onsite Wastewater Treatment Systems
Alameda County Environmental Health (ACEH) regulates the operation, installation, alteration, and repair of individual onsite wastewater treatment systems (OWTS), (i.e., septic tank systems) in all of Alameda County under the authority of Chapter 15.18 of the Alameda County General Ordinance. ACEH may also, in consultation with the RWQCB and other applicable agencies, identify boundaries of areas of special concern and adopt additional or modified requirements to address special environmental concerns in those areas. ACEH’s 2007 Onsite Wastewater and Individual/Small Water Systems Regulations were developed in collaboration with Zone 7, and include special provisions for the Upper Alameda Creek Watershed, above Niles; such as a moratorium for new septic systems in unincorporated Happy Valley and a larger minimum parcel size requirement for new septic tank systems in the rest of the watershed than in other parts of the County.
In June 2012, the SWRCB adopted a new policy that establishes siting, design, operation, and maintenance criteria for OWTS, statewide. The purpose of this Policy is to allow the continued use of OWTS by providing local agencies a streamlined regulatory tool with clear criteria and a flexible alternative for protecting water quality and public health from OWTS impacts where local conditions call for special requirements to be implemented. The OWTS Policy gives the RWQCBs the principal responsibility to oversee implementation and calls for incorporating the OWTS Policy requirements into all Basin Plans. The San Francisco Bay RWQCB adopted a Basin Plan amendment in June 2014 that incorporates the State's new OWTS Policy.
The OWTS policy allows for local agencies such as counties and cities to adopt programs to manage OWTS within their jurisdictions. As such, ACEH is planning to work with RWQCB staff to develop a Local Agency Management Program (LAMP) pursuant to the policy that addresses local conditions while still protecting water quality and public health.
1.3.4 Zone 7 Wastewater Management Plan
In 1982, Zone 7 adopted its Wastewater Management Plan for the Unsewered, Unincorporated Area of Alameda Creek Watershed above Niles (WWMP) (Zone 7, 1982), which provides wastewater management policies intended to prevent further degradation of water quality from onsite wastewater disposal systems in the Livermore Valley, Sunol Valley, and Niles Cone groundwater basins. An additional policy was added in 1985 that limited the use of septic systems for new commercial development (Zone 7 Resolution 1165).
Although ACEH issues permits for OWTSs in Alameda County, Zone 7 requires special approval for any of the following septic systems located within the Valley: Any new septic system constructed, partially or fully, for a commercial or industrial use; Any conversion of a residential septic system to a commercial or industrial use; or Any new residential septic system that discharges greater than one rural residential equivalence of wastewater (i.e., greater than an annual average of 320 gallons/day) per 5 acres.
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1- Background
1.3.5 Groundwater Management Plan and Annual Reports
In 2005, Zone 7 compiled and documented all of its groundwater management policies, objectives, and programs, including its WWMP and SMP, into its comprehensive GWMP for the Livermore Valley Groundwater Basin, which the DWR recognizes as a SB1938-compliant GWMP. Zone 7’s GWMP provides a detailed description of the groundwater management goals and practices used for the Livermore Valley Groundwater Basin, as well as detailed descriptions of the subbasin boundaries; hydrologic settings; historical groundwater use and overdraft; practices and measures used to prevent future overdraft and groundwater quality degradation; and stakeholder involvement during the development of the GWMP. Another significant portion of the GWMP addresses the numerous monitoring programs and protocols employed by Zone 7 to quantify, manage and protect the basin’s groundwater supplies.
The GWMP itself is intended to be a “living document,” and as such, undergoes periodic reevaluations and updates as conditions and management goals may change. Periodic adjustments to the GWMP are noted in the Annual Reports for the Groundwater Management Program (years 2005 to 2013), available online at www.zone7water.com. Major revisions are handled through a formal revision or addendum process that involves collaboration between Zone 7, the RWQCB, Zone 7’s retailers, and other stakeholders in an open public process.
In 2014, California passed three new bills (Senate Bills 1168 and 1319, Assembly Bill 1739) designed to achieve sustainable groundwater management in the state within the next 20 years. In SB 1168, Zone 7 was deemed the exclusive local agency within its statutory boundaries with powers to comply with this new part of the Water Code. 1.4 Stakeholder Involvement
This NMP was developed with cooperation and input from regulatory agencies (e.g., RWQCB, ACEH, Alameda County Community Development Agency [Alameda CDA]), property owners, Zone 7’s Retailers (City of Livermore, DSRSD, City of Pleasanton, California Water Service), and other interested parties. The following meetings took place from June 2013 to November 2014 to discuss the calculation methods, results, and proposed actions:
June 2013: Meeting at RWQCB with Sonoma County Water Agency (SCWA), RMC, Santa Clara Valley Water District (SCVWD) also in attendance. July 2013: Status meetings with Zone 7 Retailers. October 2013: Status meeting with Zone 7 Retailers October 2013: Public meeting with presentation to Zone 7’s Board Water Resources Committee discussing preliminary results.
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1- Background
January 2014: Follow-up public meeting and presentation to Zone 7’s Board Water Resources Committee. March 2014: Progress meeting with RWQCB, SCVWD, SCWA. April 2014: Public stakeholder meeting with property owners and residents in May School, Buena Vista and Greenville Areas of Concern. Staff from ACEH and Alameda CDA were also in attendance. July 2014: Progress meeting with RWQCB, ACEH and Alameda CDA October 2014: Progress meeting with Zone 7 Retailers to discuss final results. October 2014: Progress meeting with RWQCB, ACEH, and Alameda CDA to discuss final results. November 2014: Public meeting with presentation to Zone 7’s Board Water Resources Committee to discuss final results. November 2014: Public meeting with presentation to Zone 7’s Board to present final report. 1.5 CEQA Considerations
This NMP is exempt from California Environmental Quality Act (CEQA) under Section 15061.b.3, covered by the general rule that CEQA only applies to projects with the potential for significant effects on the environment. A notice of exemption was filed with the Alameda County Clerk-Recorder. This Plan is an addendum to the existing GWMP, which was also found to be exempt from CEQA in 2005.
The NMP provides a focused assessment of current and anticipated issues and concerns relating to nitrate concentrations in the groundwater basin. Best management practices (BMPs) are identified – focused primarily on minimizing nitrogen loading over the groundwater basin. The BMPs are inherently protective measures for the environment, and therefore no significant impacts will occur as a result of implementation of the Plan.
The plan does not identify the need for new or modified infrastructure. Should Zone 7 wish to undertake such a project in the future to help meet NMP related goals, it would require project-specific analysis under CEQA.
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2 Livermore Valley Groundwater Basin Characteristics 2.1 Groundwater Basin Overview
This section provides a brief summary of the hydrogeologic setting of the Livermore Valley Groundwater Basin. A more detailed description can be found in Zone 7’s GWMP (Zone 7, 2005a). The Livermore Valley Groundwater Basin (Figure 2-1) is an inland alluvial basin underlying the east-west trending Livermore-Amador Valley (Valley) in northeastern Alameda County.
Figure 2-1: Map of Livermore Valley Groundwater Basin and Subbasins (DWR, 1974)
The Main Basin is a portion of the Livermore Valley Groundwater Basin that contains the highest yielding aquifers and generally the best quality groundwater. The Fringe Basins consist primarily of shallow, lower-yielding alluvium containing relatively poor quality groundwater. The upland area
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3 - Basin Nutrient Evaluation
portions of the groundwater basin consist primarily of lower-yielding bedrock of the Livermore, Tassajara, and Green Valley Formations.
Six principal streams flow into and/or through the Main Basin and join in the southeast where the Arroyo de la Laguna flows out of the valley. The five arroyos shown in Figure 2-1 and listed below are essentially tributaries to the Arroyo de la Laguna:
Arroyo Valle, Arroyo Mocho, Arroyo Las Positas, South San Ramon Creek, Tassajara Creek, and Alamo Creek/Canal.
Average precipitation ranges from 14 inches per year at the eastern edge of the Valley to over 20 inches per year in the western portion.
2.1.1 Geology
The Valley and portions of the surrounding uplands overlie groundwater-bearing materials. These materials consist of deposits from alluvial fans, streams, and lakes (of Pleistocene-Holocene age; less than about 1.6 million years old) that range in thickness from a few feet along the margins to nearly 800 feet (ft) in the west-central portion. The alluvium consists of unconsolidated gravel, sand, silt, and clay. The southeastern region of the Valley is the most important groundwater recharge area and consists mainly of sand and gravel that was deposited by the ancestral and present Arroyo Valle and Arroyo Mocho.
The Livermore Formation (Pleistocene age; 11,000 to 1.6 million years old), found below the majority of the alluvium in the groundwater basin, consists of beds of clayey gravels and sands, silts, and clays that are unconsolidated to semi-consolidated. However, the contact between the overlying alluvium and the Livermore Formation is nearly impossible to discern from drill cuttings and electrical logs. This formation is estimated to be 4,000 ft thick in the southern and western portion of the basin. These sediments tend to have low-yielding groundwater in the upland areas.
The Tassajara and Green Valley Formations, located in the Tassajara Uplands north of the Valley, are roughly Pliocene in age (1.6 to 5.3 million years old). They basically consist of sandstone, tuffaceous sandstone/siltstone, conglomerate, shale, and limestone. Water movement from these formations to the alluvium of the fringe and Main Basins is minimized by faults and angular unconformities or by stratigraphic disconformities along the formation-alluvium contacts.
The lateral movement of groundwater is restricted by the presence of geologic structures which create boundaries. These include the Parks Boundary (which was initially considered to be fault-related, but may be a depositional boundary between recent alluvium and older material), as well as the Livermore, Pleasanton, Calaveras, and Greenville faults.
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3 - Basin Nutrient Evaluation
2.1.2 Main and Fringe Basins
The Main Basin and Fringe Basins (shown on Figure 2-1) are comprised of the subbasins listed below:
Main Basin Fringe Basin North Fringe Basin Northeast Fringe Basin East Castle Bishop Altamont Mocho I Bernal Camp Cayetano (southern portion) Amador Dublin May Mocho II Spring Vasco Mocho I (northern portion)
All of the Valley’s municipal supply wells are completed in the Main Basin aquifers, which have the highest transmissivity in the Valley. Figure 2-2 (from Zone 7, 2014) shows the recharge area for the Main Basin. The most relevant of the Fringe Basins to the NMP is the Fringe Basin North due to its connectivity with the Main Basin (Section 2.1.3.1) and because of the amount of recycled water use, both existing and proposed, in that portion of the basin.
2.1.3 Aquifer Zones 2.1.3.1 Overview
Water levels in the Main Basin typically vary with seasonal recharge and extraction. The highest water levels usually are found at the end of the rainy season and lowest water levels at the end of the high demand summer/fall seasons; however, this trend can change during periods of extended drought or multi-year storage replenishment (Section 2.2.1). Zone 7 maintains a system of Key Wells that is used to monitor general conditions in each of the Main Basin’s Subbasins.
Although multiple aquifers have been identified in the Main Basin alluvium, wells have been classified generally as being in one of two aquifer zones (upper or lower), separated by a relatively continuous silty- clay aquitard up to about 50 ft thick. Groundwater in both the upper and lower aquifer zones generally follows a westerly flow pattern, similar to the surface water streams, along the structural central axis of the valley toward municipal pumping centers.
The Main Basin is connected primarily to the fringe areas through the shallow alluvium, especially across the northern boundaries of the Main Basin. Subsurface inflow into the deeper portions of the Main Basin from the fringe subbasins is considered to be minor. The deeper aquifers of the Main Basin are primarily recharged through vertical migration of groundwater within the Main Basin itself.
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Legend Approximate Limit of Confining Layer Confining Layer Groundwater Basin Main Basin Recharge Area
GROUNDWATER BASIN BOUNDARY . 7,000 3,500 0 7,000 Sources: Esri, HERE, DeLorme, TomTom, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), Feet swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GIS User Community
DRAWN: TR/CW Scale: 1 " = 7,000 ft ZONE 7 WATER AGENCY Figure 2-2 REVIEWED: MK 100 North Canyons Parkway, Livermore, CA Date: Oct 3, 2014 Recharge Area and Confining Layer File: E:\PROJECTS\SNMP Update\Report\Figures\NMPFig2-02-RechargeMap.mxd Above Upper Aquifer
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2.1.3.2 Upper Aquifer Zone
The upper aquifer zone consists of alluvial materials, including primarily sandy gravel and sandy clayey gravels. These gravels are usually encountered underneath a confining surficial clay layer typically 5 to 70 ft below ground surface [bgs] in the west and exposed at the surface in the east. The base of the upper aquifer zone ranges from 80 to 150 ft bgs. Groundwater in this zone is generally unconfined; however, when water levels are high, portions of the Upper Aquifer Zone in the western portion of the Main Basin can become confined.
Figure 2-3: Gradient in Upper Aquifer, October 2013
The groundwater gradient in the Upper Aquifer is generally from east to west towards the Bernal Subbasin, then to the south where groundwater flows out of the Main Basin (see Figure 2-3). The
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gradient typically ranges from 0.005 to 0.025 with isolated areas of flatter or steeper gradients, especially near subbasin boundaries.
2.1.3.3 Lower Aquifer Zone
All sediments encountered below the clay aquitard in the center portion of the basin have been known collectively as the Lower Aquifer Zone. The aquifer materials consist of semi-confined to confined, coarse-grained, water-bearing units interbedded with relatively low permeability, fine-grained units. It is believed that the Lower Aquifer Zone derives most of its water from the Upper Aquifer Zone through the leaky aquitard(s) when groundwater heads in the upper zone are greater than those in the lower zone.
Figure 2-4: Gradient in Lower Aquifer, October 2013
In the Lower Aquifer, the groundwater gradient within the Mocho II and Amador Subbasins ranges from 0.001 to 0.05 with groundwater flowing generally westward along the longitudinal axis of the Livermore- Amador Valley (see Figure 2-4). In the Bernal Subbasin, the gradient (typically less than 0.006) is
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slightly to the north and east towards the Hopyard and Mocho Wellfields. Typically, the lowest elevations correspond to the municipal pumping wellfields within each subbasin.
There are two major subsurface structural features that act as partial barriers to the lateral movement of groundwater in the Lower Aquifer. These features define the sub-basin boundaries between the Mocho II and Amador Subbasins, and between the Dublin and Camp fringe basins and the Main Basin. Groundwater levels are significantly higher on the up-gradient sides of these partial barriers, but it is believed that groundwater cascades across these linear features providing some subsurface recharge for the adjacent subbasin.
2.1.1 Land Use
The majority of the land use over the Main and Fringe Basins is considered urban (60%), 7% is dedicated to gravel mining, 6% is used for irrigated agriculture, and the remaining areas are open space (27%).
Zone 7 has an established Land Use Monitoring Program that identifies changes in land use with an emphasis on changes in impervious areas and the volume and quality of irrigation water that could impact the volume or quality of water recharging the Main Basin. Land use data are derived from aerial photography, permit applications, field observations, and City and County planning documents. The current land use categories are:
Residential (rural) Public (Irrigated Park) Residential (low density) Agriculture (vineyard) Residential (medium density) Agriculture (non-vineyard) Residential (high density) Mining Area – Pit Commercial and Business Water Body Industrial Golf Course Public Open Space
The source of the water that supplies each of the land use polygons is also catalogued. The sources of water are identified as:
Delivered (municipal) water Groundwater Recycled water
Land use and source water information are used to calculate rainfall and applied water recharge and salt and nutrient loading. Current and future land uses and their associated loading contributions are discussed in more detail in Section 3.
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2.2 Groundwater Inventory 2.2.1 Conjunctive Use
Zone 7 imports extra surface water from the State Water Project’s (SWP) South Bay Aqueduct (SBA) and artificially recharges it in the Main Basin (currently using stream percolation in losing reaches). This recharged SWP water is then available to Zone 7 for pumping during dry years. In normal years, Zone 7 operates its wells to augment production during demand peaks and whenever a shortage or interruption occurs in surface water supply or treatment. However, Zone 7 has also pumped groundwater as a salt management strategy. The decision of which well(s) to pump first is based on pumping costs, pressure zone needs, delivered aesthetic water quality issues, operational status, and demineralization facility capacity. Although reduced groundwater pumping may have a positive impact on groundwater storage and delivered water quality, increased groundwater pumping has a beneficial impact on the basin’s salt loading because much of the salt in the pumped groundwater eventually leaves the basin as wastewater export.
2.2.2 Groundwater Storage
The Main Basin is estimated to hold up to 254 thousand acre-feet (TAF) whereas the fringe basins are estimated to hold 243 TAF. Zone 7 quantifies the total groundwater storage of the Main Basin by averaging the values computed by two independent methods: a groundwater elevation method and a hydrologic inventory method. Additional information on these two methods can be found in Zone 7’s annual GWMP reports.
One of Zone 7’s groundwater basin management objectives is to maintain water levels above historical lows to minimize the risk of inducing land subsidence. Therefore, not all of the total groundwater storage is considered accessible. “Operational” or “Available” Storage is the approximate amount of storage available above the historical low groundwater surface (about 126 TAF). The remainder (approximately 128 TAF) is estimated reserves stored below historical lows.
2.2.3 Groundwater Production
Zone 7 provides water resources management services to about 220,000 residents of the Valley. Zone 7 integrates management of both surface and groundwater supplies for conjunctive use and reliability of water supplies. Groundwater typically makes up 15-25% of the water supplied by Zone 7 to its retail water supply agencies; however, higher groundwater use can occur during droughts and surface water outages. In addition, two of the four retailers independently operate supply wells, as do other domestic and agricultural users, so the total amount of groundwater makes up a higher percentage of the total regional supply (typically 20-40%). All of the Valley’s municipal supply wells are completed in Main Basin aquifers (Figure 2-5).
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Figure 2-5: Map of Municipal Wells
2.2.4 Groundwater Sustainability
Zone 7 strives to manage the basin’s groundwater sustainability. To assure sustainability, Zone 7 quantifies the supply and demand components (Figure 2-6) and their calculated annual volumes each year and makes sure that the long-term averages do not indicate overdraft conditions. The results are presented in Zone 7’s Annual Reports for the GWMP (see Zone 7, 2014 for the most recent example).
The Main Basin’s “natural,” sustainable, groundwater yield is defined as the amount of water that can be pumped from the groundwater basin and replenished by long-term average, natural supply. The long- term, natural sustainable yield is calculated based on local precipitation and natural recharge over a century of hydrologic records and projections of future recharge conditions. Applied water recharge has been historically included in the “natural” sustainable yield because of its sustainable contribution to groundwater recharge.
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Figure 2-6: Groundwater Supply and Demand Components Inflow and Outflow Components Normal Water Year (AF/yr) Natural Sustainable Yield Supply Natural Stream Recharge 5,700 Arroyo Valle Prior Rights 900 Rainfall Recharge 4,300 Applied (Irrigation) Water Recharge 1,600 Subsurface Inflow 1,000 Basin Overflow -100 Inflow Total 13,400 Natural Sustainable Yield Demand Municipal pumping by Retailers 7,214* Other groundwater pumping 1,186 Agricultural pumping 400 Mining Area Losses 4,600 Outflow Total 13,400 Managed Supply Artificial Stream Recharge Inflow Total Varies† Managed Demand Municipal Pumping by Zone 7 Outflow Total Varies† *Retailer Groundwater Pumping Quota (GPQ) for a Calendar Year †Artificial stream recharge and Zone 7 pumping amounts are determined by the availability of surface water
The long-term, natural sustainable yield in the Main Basin was estimated to be about 13,400 acre-feet (AF) annually (Zone 7, 1992). While the natural sustainable yield approximates long-term-average natural recharge, the actual amount of natural recharge varies from year to year depending on the amount of local precipitation and irrigation during the year.
Zone 7’s artificial recharge operations allow the groundwater basin to yield additional water, which is as sustainable as the supply of imported surface water. Zone 7 contracts with the SWP to import water that is released from the SBA or from Lake Del Valle (a SWP reservoir also operated by the California Department of Water Resources) into the arroyos for the purpose of augmenting the natural stream recharge.
Historically, Zone 7’s annual groundwater pumping has varied with the availability of imported surface water and the capacity to treat that surface water. However, Zone 7 also operates its wells for salt management, to supply short-term demand peaks, and to compensate for treatment and conveyance system interruptions. The decision of which well(s) to pump is based on groundwater elevations, pumping costs, pressure zone needs, delivered aesthetic water quality issues, salt management needs, operational status, and groundwater demineralization facility capacity. Although reduced groundwater pumping may have a positive impact on groundwater storage and delivered water quality, increased groundwater pumping has a beneficial impact on the basin’s salt loading because much of the salt in the pumped groundwater eventually leaves the basin as wastewater export. Annual variability can be accommodated as long as the long-term average groundwater demands don’t exceed the sustainable average recharge.
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2.3 Basin Water Quality (Nutrients) 2.3.1 Overview
In addition to managing the basin for supply sustainability, Zone 7 manages the basin for groundwater quality. In general, groundwater quality throughout most of the Main Basin is suitable for most types of urban and agriculture uses with some minor localized water quality degradation. Zone 7’s annual GWMP reports (see Zone 7, 2014 for the 2013 report) present more details of the groundwater quality monitoring and management programs for the basin.
The nutrient constituent of concern for this plan is nitrate since it is the only nutrient that has had a significant impact on groundwater quality. The Basin Objective (BO) for nitrate is 45 mg/L (measured as NO3) for both the Main and Fringe Basins (California RWQCB, 2011). Phosphate is also monitored as part of the GWMP, but is encountered in concentrations well below the water quality standards and is not considered a significant nutrient of concern for the Livermore Valley Groundwater Basin. Figure 2-7 below shows the maximum concentrations encountered in each of the basin areas.
Figure 2-7: Maximum Concentration of Nutrients in Basin Areas
Concentration Max (2001-2014) Main Fringe Fringe Fringe Standard Basin North Northeast East Nutrient mg/L mg/L mg/L mg/L mg/L (1) (2) Nitrate (as NO3) 45 95 340 190 163 (3) Phosphate (as PO4) 5 2.85 3.65 1.93 0.34 (1) MCL from CDPH and BO from RWQCB (2) Only 2 sample results above 100 mg/L (3) Recommended limit from World Health Organization
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2.3.2 Nitrate Concentrations
The results from Zone 7’s annual groundwater sampling are used to prepare nitrate concentrations maps each year for Zone 7’s Groundwater Management Program annual reports. The 2013 nitrate concentration contours from the upper and lower aquifers are shown in Figure 2-8 and Figure 2-9 below:
Figure 2-8: Nitrate Concentrations in Upper Aquifer
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Figure 2-9: Nitrate Concentrations in Lower Aquifer
Average nitrate concentrations are resolved by first using ArcGIS’s Spatial Analyst to calculate the volume-weighted average nitrate concentration (measured as NO3) for each groundwater storage node from the nitrate concentration maps. The groundwater storage nodes are the same polygonal areas referred to in Zone 7’s Groundwater Management Plan (Zone 7, 2005a) and used to calculate groundwater storage at the end each water year. Figure 2-10 shows the layout of the nodes, and the average upper and lower aquifer nitrate concentrations for each node from the 2013 monitoring well sampling results (Zone 7, 2014).
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Figure 2-10: Nitrate Concentrations by Node
Figure 2-11 below shows the storage volume, average nitrate concentrations, and assimilative capacity (AC) by node, aquifer, subbasin, and basin areas (see Section 2.3.3 for discussion on how assimilative capacity is calculated).
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Figure 2-11: Storage (AF), Nitrate Concentrations (as NO3 in mg/L) and Assimilative Capacity (mg/L) by Node, Subbasin, and Basin Area Upper Lower Total Basin NODE Basin Subbasin Storage NO3 AC Storage NO3 AC Storage NO3 AC NODE 1 FBN 28,888 1 44 - - - 28,888 1 44 NODE 2 FBN 3,363 3 42 - - - 3,363 3 42 NODE 3 FBN 6,303 6 39 - - - 6,303 6 39 NODE 4 FBN 6,236 14 31 - - - 6,236 14 31 NODE 5 FBN 5,914 14 31 - - - 5,914 14 31 NODE 6 FBN 7,349 11 34 - - - 7,349 11 34 NODE 7 FBN 6,825 11 34 - - - 6,825 11 34 NODE 8 FBN 4,263 2 43 - - - 4,263 2 43 NODE 9 FBN 5,119 5 40 - - - 5,119 5 40 NODE 10 FBN 7,219 11 34 - - - 7,219 11 34 NODE 11 FBN 4,918 6 39 - - - 4,918 6 39 NODE 12 FBN 10,142 3 42 - - - 10,142 3 42 NODE 13 FBN 8,035 3 42 - - - 8,035 3 42 NODE 14 FBN 5,495 5 40 - - - 5,495 5 40 NODE 15A FBN 106 1 44 - - - 106 1 44 NODE 16A FBN 96 2 43 - - - 96 2 43 NODE 15 MB Bernal 535 11 34 1,771 12 33 2,306 12 33 NODE 16 MB Bernal 600 4 41 2,654 13 32 3,253 11 34 NODE 17 MB Bernal 1,499 12 33 1,602 9 36 3,100 11 34 NODE 18 MB Bernal 2,649 10 35 5,457 12 33 8,106 12 33 NODE 19 MB Bernal 3,784 14 31 5,579 12 33 9,363 13 32 NODE 20 MB Bernal 913 1 44 3,656 7 38 4,569 6 39 NODE 21 FBN 17,445 10 35 - - - 17,445 10 35 NODE 22 FBN 11,837 20 25 - - - 11,837 20 25 NODE 23 MB Amador 2,129 11 34 2,812 15 30 4,942 13 32 NODE 24 MB Amador 2,660 15 30 2,993 17 28 5,653 16 29 NODE 25 MB Amador 7,483 12 33 6,979 11 34 14,462 12 33 NODE 26 MB Amador 8,884 7 38 8,923 17 28 17,807 12 33 NODE 27 FBN 17,655 27 18 - - - 17,655 27 18 NODE 28 FBN 7,814 31 14 - - - 7,814 31 14 NODE 29 MB Amador 4,620 27 18 1 26 19 4,621 27 18 NODE 30 MB Amador 7,216 18 27 5,735 21 24 12,951 19 26 NODE 31 MB Amador 8,402 3 42 15,010 8 37 23,412 6 39 NODE 32 FBN 1,024 22 23 - - - 1,024 22 23 NODE 33 MB Amador 639 18 27 479 19 26 1,118 19 26 NODE 34 MB Amador 2,755 25 20 5,618 13 32 8,373 17 28 NODE 35 MB Amador 8,831 7 38 22,775 11 34 31,607 9 36 NODE 36 MB Amador 10,863 1 44 1 7 38 10,865 1 44 NODE 37 MB Amador 209 6 39 0 12 33 209 6 39 NODE 38 MB Mocho II 4,915 37 8 1,629 30 15 6,544 35 10 NODE 39 MB Mocho II 10,011 19 26 4,251 24 21 14,263 21 24 NODE 40 MB Mocho II 10,930 27 18 2,267 10 35 13,197 24 21 NODE 41 MB Mocho II 10,889 4 41 1 2 43 10,890 4 41 NODE 42 MB Mocho II 7,647 36 9 1,759 33 12 9,406 35 10 NODE 43 FBNE 8,622 27 18 - - - 8,622 27 18 NODE 44 FBE 6,830 15 30 - - - 6,830 15 30 NODE 45 FBNE 62,141 14 31 - - - 62,141 14 31 NODE 46 FBNE - 11 34 - - - - 11 34 NODE 47 FBNE - 7 38 - - - - 7 38 Bernal 9,981 11 34 20,717 11 34 30,698 11 34 Amador 64,692 10 35 71,326 12 33 136,018 11 34 Mocho II 44,392 22 23 9,908 24 21 54,299 22 23 Main Basin 119,064 15 30 101,951 13 32 221,015 14 31 FB-North 166,046 11 34 166,046 11 34 FB-Northeast* 70,762 15 30 70,762 15 30 FB-East 6,830 15 30 6,830 15 30 TOTAL* 362,702 13 32 101,951 13 32 464,653 13 32 * not including Nodes 46 and 47 (no storage info available) Storage in AF, NO3 Concentration in mg/L, AC = Assimilative Capacity
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The average volume-weighted concentrations were then calculated for each subbasin, aquifer, and basin area; and the results are as shown in Figure 2-12 below.
Figure 2-12: Nitrate Concentrations by Subbasin, Aquifer, and Basin Area
The 2013total average nitrate concentration in the upper aquifer is 15 mg/L, with all subbasins between 9 mg/L and 27 mg/L. The average nitrate concentration in the lower aquifer is 13 mg/L, with all subbasins between 11 mg/L and 24 mg/L. The overall concentration for the Main Basin is 14 mg/L. The average concentrations in the Fringe Basins (which only consist of an upper aquifer) ranged between 11 mg/L and 15 mg/L. All average basin concentrations are well below the BO (45 mg/L); however, there are Areas of Concern (described in Section 2.4) where local nitrate concentrations do exceed the BO.
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2.3.3 Assimilative Capacity
Assimilative Capacity, the natural capacity of the groundwater basin to absorb pollutants, is the difference between the BO (45 mg/L) and the average concentration of the basin with a relatively conservative contaminant like nitrate. The assimilative capacity for each of the nodes and basins are shown in Figure 2-13 and are summarized below by basin area.
Figure 2-13: Average Nitrate Concentrations and Assimilative Capacities by Basin Area
Basin Assimilative BASIN AREA Average NO3 Objective Capacity (mg/L) (mg/L) (mg/L) Main Basin 14 45 31 Fringe Basin - North 11 45 34 Fringe Basin – Northeast 15 45 30 Fringe Basin – East 15 45 30
2.4 Areas of Concern
Average nitrate concentrations are well below the BO (45 mg/L) in all four groundwater basin areas in the Livermore Valley Groundwater Basin, however there are ten local Areas of Concern where nitrate concentrations are above the BO. These areas are shown in Figure 2-14 and Figure 2-15 and are described below, roughly from West to East. Five of the ten Areas of Concern have a higher-than average density of septic tanks in use, which has led to the development of special requirements for new septic tank applications in these areas. The septic tank management goals and strategies and associated implementation plan for these five Areas of Concern are discussed in detail in Sections 5.5.2 and 6.1.5.2.
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Figure 2-14: Nitrate Areas of Concern
1. Happy Valley – The County adopted a moratorium on new septic tanks for the Happy Valley area in the 1970’s when several domestic wells tested high for nitrate. There were, and still are, over 100 septic tanks in this unincorporated part of Pleasanton. There are no dedicated monitoring wells in Happy Valley; however, many of the domestic wells have been tested for nitrate since 1973. In 2012, Zone 7 and ACEH conducted voluntary testing of water samples domestic wells in Happy Valley. Seven of the 31 wells had nitrate concentrations that exceeded the maximum contaminant level (MCL) of 45 mg/L, with one reaching 124 mg/L. Most of the high nitrate occurrences were detected in the central portion of this enclosed sub- basin.
2. Staples Ranch – This elongated Area of Concern runs from west to east in the southern portion of the Camp Subbasin in the eastern portion of Dublin. Concentrations have been slowly rising (see graph below) to a maximum concentration 66.43 mg/L in the 2013 Water Year (October 2012 to September 2013). No active nitrogen sources have been identified;
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however, this may be a remnant of past dairy operations in the area that were discontinued long ago but are slowly migrating toward the monitoring well. 100 Staples Ranch (3S/1E 2M 3) 80 60 40
(mg/L) Maximum Contaminant Level = 45 mg/L 20
Nitrate (as NO3) (as NO3) Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
3. Bernal – The long-term trend of nitrate concentrations in 3S/1E 22D 2 (in the southern portion of the Amador West Subbasin, see graph below) has been slowly declining, however, recently concentrations have been fluctuating around the MCL. The source of high nitrate and the reason for the fluctuating concentrations has not been identified, but it is speculated that the nitrate may have been entering the Main Basin as hill-front recharge and/or subsurface inflow from the neighboring Livermore Uplands to the south but its source(s) are diminishing as urban development spreads into the Upland area.
100 Bernal (3S/1E 22D 2) 80 60
(mg/L) 40 Maximum Contaminant Level = 45 mg/L 20 Nitrate (as NO3) Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
4. Jack London – This Area of Concern extends from the eastern portion of the Mocho II Subbasins to the northeastern portion of the Amador Subbasin. Portions of this nitrate plume date back to at least the 1960s. Nitrate concentrations appear to have stabilized at just above the MCL (58 mg/L in 3S/1E 7H 2, see graph below). The sources are believed to be historical municipal wastewater disposal, historical and existing agricultural practices, and historical and current recycled water use.
100 Jack London (3S/1E 7H 2) 80 60 40
(mg/L) Maximum Contaminant Level = 45 mg/L 20
Nitrate (as NO3) (as NO3) Nitrate 0 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
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5. Constitution – This Area of Concern exists near the boundary of the Mocho II, Camp, and Amador Sub-basins and is up-gradient from the Las Positas Golf Course in Livermore. Nitrate concentrations in 3S/1E 1F 2 (see graph below) show an upward trend; however, concentrations in 3S/1E 2R 1 (see Figure 2-15), down-gradient from 3S/1E 1F 2, are relatively stable. The source of the nitrate is unconfirmed but may possibly be from historical septic tanks and agricultural practices, current landscape fertilizer, and/or recycled water use.
200 Constitution (3S/1E 1F 2) 150
100 Maximum Contaminant Level = 45 mg/L (mg/L) 50
Nitrate (as NO3) (as NO3) Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
6. May School - The highest nitrate concentration detected in the basin is located in the May Subbasin near May School Rd (maximum concentration of 189.54 mg/L in 2013, see graph below). In the 2008 Water Year (October 2007 to September 2008), as part of a one-time water quality study in this area, Zone 7 sampled and analyzed several domestic wells in the area to determine the extent of nitrate contamination. These results (presented in the 2008 Annual Report for the Groundwater Management Program, Zone 7, 2009) suggested that the nitrate appeared to be relatively localized with the highest concentration in the vicinity of 2S/2E 28D 2. The source of high nitrate was not identified; however, it likely comes from agricultural land use in that area.
200 May School (2S/2E 28D 2) 150
100
(mg/L) 50 Maximum Contaminant Level = 45 mg/L Nitrate (as NO3) (as Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
7. Buena Vista - This nitrate plume exists in the central and eastern portion of the Mocho II Subbasin. The concentration in 3S/2E 22B 1 (see graph below), near the proximal end of the plume, fluctuates above and below the MCL, but has been above the MCL for the last few years (61.56 mg/L in the 2013 Water Year). The potential sources of the nitrate are existing septic tanks and historical agricultural practices, livestock manure, and composting vegetation. There are over 100 septic tanks still in use near the proximal end of the plume, and documented historical poultry ranching, and crop and floral farming along Buena Vista Avenue. There are also an abundant amount of wineries in the area, although viticulturists use very little nitrate-based fertilizer.
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100 Buena Vista (3S/2E 22B 1) 80 60 40
(mg/L) 20 Maximum Contaminant Level = 45 mg/L 0 Nitrate (as NO3) (as NO3) Nitrate
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
8. Charlotte Way- This plume exists in the western portion of the Mocho I Subbasin and may commingle with the Buena Vista Area of Concern in the eastern portion of the Mocho II Subbasin. Nitrate concentrations in 3S/2E 14A 3 (see graph below) have fluctuated above and below the MCL, most recently dropping below the MCL to 38.31 mg/L in the 2013 Water Year. The cause is believed to be historical septic tanks, fertilizer applications, and other agricultural impacts in the Buena Vista area that have migrated down-gradient.
200 Charlotte Way (3S/2E 14A 3) 150
100 Maximum Contaminant Level = 45 mg/L (mg/L) 50
Nitrate (as NO3) (as NO3) Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
9. Greenville – This Area of Concern is represented by a single well located near the corner of Tesla and Greenville Roads. The maximum concentration of nitrate was 163.90 mg/L in 2001 Water Year (October 2000 to September 2001), with a concentration of 156.33 mg/L in the 2013 Water Year (see graph below). The source of nitrate in this well is unconfirmed, but may be from historical chicken farming, and other agricultural land uses located up-gradient of the monitoring well. There is concern for the potential increase in onsite wastewater disposal from future commercial development planned for this area.
200 Greenville (3S/2E 24A 1) 150
100
(mg/L) 50 Maximum Contaminant Level = 45 mg/L
Nitrate (as NO3) (as NO3) Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
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10. Mines Road – This Area of Concern, which is also represented by a single well (3S/2E 26J 2, see graph below), is located along Mines Road. Nitrate concentrations in this well have fluctuated widely ranging from non-detect to a maximum of 94.77 mg/L in October 2011. The reason for the fluctuations are unknown, but may be related to agriculture and changes in precipitation.
200 Mines Rd (3S/2E 26J 2) 150
100 Maximum Contaminant Level = 45 mg/L (mg/L) 50
Nitrate (as NO3) (as NO3) Nitrate 0
1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
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NITRATE AREAS OF CONCERN AND TRENDS
Constitution May School National Labs
Staples Ranch
May School
Buena Vista
Constitution
Staples Ranch
J. London Charlotte Way
Buena Vista Greenville
Bernal
Bernal Mines Rd.
Greenville
Jack London Mines Road
FIGURE 2-15
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3 Basin Nutrient Evaluation 3.1 Historical Sources of Nitrate
The most significant historical sources of nitrate in the basin (shown in Figure 3-1) are from:
Composting vegetation (buried and surficial) Municipal wastewater and sludge disposal Septic tanks Concentrated animal boarding/ranching (horse boarding, chicken and/or cattle ranching) Applied fertilizers (crops and landscape)
Figure 3-1: Historical and Existing Sources of Nitrate
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Many of the contributing activities are still active today, however in much smaller quantities. Fertilizer application areas are not shown in Figure 3-1 because records of fertilizer applications were not available for this plan and therefore are assumed. 3.2 Conceptual Model 3.2.1 Fate and Transport of Nitrate
To determine if groundwater nitrate concentrations will rise or drop over the long-term, one must calculate the net nitrate loading on the groundwater basin. However, net nitrate loading is difficult to calculate because nitrate readily converts to and from other nitrogen compounds (e.g., nitrite, ammonia, elemental nitrogen) in the unsaturated soil zone. Therefore, it is common to use total nitrogen as the metric for determining potential net nitrate loading.
The fate and transport of nitrogen compounds in the unsaturated zone is complex, with transformation, attenuation, uptake, and leaching in various environments. The following excerpt is from Moran, et al, 2011.
Nitrogen may be applied to crops in various forms such as animal manure, anhydrous ammonia, urea, ammonium sulfate, calcium nitrate, or ammonium nitrate, but all forms may eventually be converted to nitrate and transported away from the shallow soil zone to streams or groundwater. Denitrification, which converts nitrate to nitrogen or nitrous oxide gas, can mitigate nitrate loading to streams and groundwater, and can occur in any zone where certain geochemical conditions are met, viz. low oxygen, the presence of an electron donor such as organic carbon or reduced sulfur, and a population of denitrifying bacteria. The hyporheic zone of streams, riparian buffer zones, poorly drained soils, and saturated zones with low dissolved oxygen are all environments where bacteria are generally present and conditions favorable for denitrification may exist.
However, once in the saturated groundwater zone, nitrogen is relatively stable, and primarily exists as nitrate. Some denitrification can occur in the saturated zone, but not readily in the oxygen-rich conditions that are so common in the shallow aquifers of the Livermore Valley Groundwater Basin. Since nitrate is soluble in water, it is transported with the groundwater through the aquifers.
3.2.2 Methodology 3.2.2.1 Introduction
To calculate the net nitrogen loading, Zone 7 sums the current nitrogen loading from all the sources and removal components, which are shown in Figure 3-2 below.
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Figure 3-2: Existing Nitrogen Sources and Removal
NITROGEN SOURCES NITROGEN REMOVAL Stream Recharge Soil Processes Rainfall Recharge Denitrification Pipe Leakage Soil texture (absorption) Subsurface Inflow Plant Uptake Horse Boarding (manure) Groundwater Pumping (wastewater export) Rural (septic and livestock manure) Mining Export Winery (septic and process water) Subsurface Outflow Applied water (well water and recycled) Fertilizers (agriculture and turf)
In most cases, nitrogen loading from each component above (e.g., stream recharge, rainfall recharge, pipe leakage, etc.) can be quantified by multiplying water volume, which Zone 7 calculates annually as part of its groundwater inventory, by the concentration of nitrogen compounds in the water. For example, to calculate the nitrogen loading from stream recharge, the volume of stream recharge is multiplied by the average nitrate concentration in the stream water.
3.2.2.2 Manure, Septic, and Wastewater
To calculate the nitrogen loading from horse boarding facilities, rural properties with septic systems, and wineries; Zone 7 calculated the number of facilities or properties from aerial photographs and land use data and then applied a nitrogen loading rate per facility/property, obtained from literature review and shown on Figure 3-3 below.
Figure 3-3: Nitrogen Loading Rates from Horse Boarding, Rural Properties, and Wineries
Nitrogen Loading LAND USE CATEGORY lbs/acre-yr Horse Boarding (Manure) 75 Rural (Septic and Manure) 49 Wineries (septic & process water) Small (per facility/yr) 54 Medium (per facility/yr) 200 Large (per facility/yr) 355
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3.2.2.3 Irrigation and Fertilizer Application
Nitrogen loading from fertilized irrigation (fertigation) and the corresponding removal from soil processes (evapotranspiration, denitrification, soil absorption, and plant uptake) was estimated by using the following formula (where N = nitrogen):
Leached N to Groundwater = N from Applied Fertilizer + N in Source Water – N lost in Soil
N from Applied Fertilizer is calculated by using land use estimates for irrigated acreage, irrigation season, and fertilizer application rates:
N from Applied Fertilizer = Percentage Irrigated Area x Time Irrigated x N Application Rate
The land use values for irrigation are listed below in Figure 3-4:
Figure 3-4: Nitrogen Loading Rates from Fertilized Irrigation by Land Use
Applied Irrigation Constants Nitrogen Irrigated Irrigation Fertilizer LAND USE CATEGORY Area1 Season Application lbs N/irr % Months acre Agriculture - Other 72% Apr - Sep 133 Agriculture - Vineyard 48% Apr - Sep 29 Golf Course 60% Oct - Sep 91 Mining Area Other 0% NA 0 Mining Area Pit 0% NA 0 Mining Area Pond 0% NA 0 Open Space 0% NA 0 Public (Schools, Government Bldgs, etc.) 10% Oct - Sep 91 Roads 0% NA 0 Rural Residential 1% Oct - Sep 91 Urban Commercial and Industrial 10% Oct - Sep 91 Urban Park 49% Oct - Sep 91 Urban Residential High Density 27% Oct - Sep 91 Urban Residential Low Density 8% Oct - Sep 91 Urban Residential Medium Density 32% Oct - Sep 91 Water 0% NA 0
N from Source Water is calculated using estimated water application rates by land use and source water concentration. Zone 7 calculated average water application rates by land use (see Figure 3-5 below, in units per acre of land use and per acre of irrigated area) using its areal recharge spreadsheet model which
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calculates applied water recharge (along with rainfall recharge and unmetered groundwater pumping) for the Main Basin and Fringe Basin North. The model uses rainfall, evaporation, soil type, irrigation efficiency, pervious area, pervious area irrigated, and irrigation season to calculate applied water rates for 500 ft by 500 ft cells that correspond to those used in Zone 7’s groundwater model.
Figure 3-5: Source Water Application Rates from Irrigation by Land Use
Water Water LAND USE CATEGORY Application Application Rate Rate AF/acre AF/irr acre Agriculture - Other 0.7 1.0 Agriculture - Vineyard 0.6 1.3 Golf Course 1.1 1.8 Public (Schools, Government Bldgs, etc.) 0.5 5 Rural Residential 0.6 6 Urban Commercial and Industrial 0.3 3 Urban Park 1.1 2.2 Urban Residential High Density 0.7 2.6 Urban Residential Low Density 0.4 5 Urban Residential Medium Density 1.0 3.1
The concentration of the source water was calculated using data collected as part of Zone 7’s groundwater annual monitoring programs. The concentration ranges for the last ten years and the average used in the calculations is presented below in Figure 3-6.
Figure 3-6: Nitrate Concentrations in Irrigation Source Water
Water Type NO3 Range NO3 Average mg/L mg/L Delivered (municipal) ND-19.8 3.6 Groundwater (supply wells) ND-147 23.3 Recycled water* 108-196 152 *All nitrogen from NO3, NO2, and TKN assumed to convert to nitrate. ND = Not Detected above the Detection Limit
Nitrate concentrations for recycled water in the Valley are usually below detection limits, however other compounds (nitrite, ammonia, and organic nitrogen) contain nitrogen and can be converted to nitrate in the subsurface. Zone 7 assumed that all the nitrogen from these compounds has the potential to convert to nitrate. This is likely not the case, but provides a conservative upper limit of possible nitrate accumulation in the groundwater basin. Also, for this evaluation, it was assumed that for certain land uses (e.g., commercial, agriculture), professional landscapers will reduce the volume of applied fertilizer to account for the nitrogen in the source water.
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For this study, the N Lost in Soil from evapotranspiration, denitrification, soil absorption, and plant uptake is assumed to be 90% of the nitrogen applied (Horsley Witten Group, 2009). 3.3 Nitrogen Loading Calculations 3.3.1 Current Nitrogen Loading
To calculate current nitrogen loading, Zone 7 applied the methodology described in Section 3.2.2 using the following data sets:
Daily precipitation for an average year Daily evaporation for an average year 2013 Land-Use (shown in Figure 3-7) 2013 Source Water Distribution (shown in Figure 3-8)
Figure 3-7: 2013 Land Use
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Figure 3-8: 2013 Source Water Distribution
The resulting total current nitrogen loading from all sources is shown on the map in Figure 3-9 below.
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Figure 3-9: Total Nitrate Loading (in lbs N/acre)
The net nitrogen loading from each component (loading and removal) is shown by basin area in Figure 3-10 and is summarized in Figure 3-11 below:
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FIGURE 3-10 NET NITROGEN LOADING BY BASIN CURRENT LAND USE WITH AVERAGE RAINFALL
MAIN BASIN FRINGE BASIN (NORTH) FRINGE BASIN (NORTHEAST) FRINGE BASIN (EAST) Concentration N Loading Concentration N Loading Concentration N Loading Concentration N Loading COMPONENTS Units or Ratelbs N/yr Units or Ratelbs N/yr Units or Rate lbs N/yr Units or Rate lbs N/yr LOADING 18,795 AF 6 mg/L 74,216 3,300 AF 11 mg/L 23,471 3,105 AF 5 mg/L 10,379 517 AF 23 mg/L 7,477 Stream Recharge 10,895 AF 1 mg/L 8,398 150 AF 4 mg/L 326 1,049 AF 1 mg/L 668 100 AF 1 mg/L 62 Nat Stream Recharge 5,700 AF 0.94 mg/L 3,315 150 AF 3.50 mg/L 326 999 AF 1.00 mg/L 619 100 AF 1.00 mg/L 62 AV Prior Rights 900 AF 1.58 mg/L 881 Art Stream Recharge 4,295 AF 1.58 mg/L 4,202 50 1.58 mg/L 49 Rainfall Recharge 4,300 AF 0.50 mg/L 1,333 1,486 AF 0.50 mg/L 461 960 AF 0.50 mg/L 298 276 AF 0.50 mg/L 86 Leakage 1,000 AF 21 mg/L 13,020 485 AF 21 mg/L 6,309 50 AF 21 mg/L 651 10 AF 21 mg/L 130 Applied Water 1,600 AF 39 mg/L 38,431 1,180 AF 22 mg/L 16,375 1,046 AF 14 mg/L 8,762 130 AF 89 mg/L 7,199 Irrigation (fertilizer) 23,452 15,836 5,964 864 Horse Boarding 52 acre 75 lbs/acre 3,914 0 acre 75 lbs/acre 0 0 acre 75 lbs/acre 0 40 acre 75 lbs/acre 2,978 Rural Septic/Manure 186 properties 49 lbs/prop 9,114 11 properties 49 lbs/prop 539 56 properties 49 lbs/prop 2,744 63 properties 49 lbs/prop 3,087 Winery Large 3 wineries 355 lbs/winery 1,065 0 wineries 355 lbs/winery 0 0 wineries 355 lbs/winery 0 0 wineries 355 lbs/winery 0 Winery Medium 2 wineries 200 lbs/winery 400 0 wineries 200 lbs/winery 0 0 wineries 200 lbs/winery 0 0 wineries 200 lbs/winery 0 Winery Small 9 wineries 54 lbs/winery 486 0 wineries 54 lbs/winery 0 1 wineries 54 lbs/winery 54 5 wineries 54 lbs/winery 270 Subsurface Inflow 1,000 AF 21.02 mg/L 13,034 0 AF 0.44 mg/L 0 0 AF 0.44 mg/L 0 0 AF 0.44 mg/L 0 REMOVAL ‐18,795 AF 10 mg/L ‐122,235 ‐3,300 AF 8 mg/L ‐17,236 ‐3,105 AF 14 mg/L ‐26,777 ‐517 AF 15 mg/L ‐4,804 Zone 7 Pumping ‐5,940 AF 18.30 mg/L ‐67,390 Retailer Pumping ‐6,570 AF 10.78 mg/L ‐43,921 Ag Pumping ‐400 AF 9.32 mg/L ‐2,310 ‐133 AF 0.44 mg/L ‐36 ‐53 AF 15.00 mg/L ‐493 ‐21 AF 15.00 mg/L ‐195 Other Pumping ‐1,185 AF 11.17 mg/L ‐8,205 Mining Losses ‐4,600 AF 0.13 mg/L ‐382 Subsurface Outflow ‐100 AF 0.44 mg/L ‐27 ‐3,166 AF 8.76 mg/L ‐17,200 ‐3,052 AF 13.89 mg/L ‐26,284 ‐496 AF 15.00 mg/L ‐4,608 Subsurface to Streams ‐2,166 AF 3.10 mg/L ‐4,166 ‐3,052 AF 13.89 mg/L ‐26,284 ‐496 AF 15.00 mg/L ‐4,608 Subsurface to MB ‐1,000 AF 21.02 mg/L ‐13,034 NET NITROGEN LOADING ‐48,019 6,234 ‐16,398 2,674
10/3/2014 E:\PROJECTS\SNMP Update\Report\Figures\NMPFig3-10-2013NLoadingCalcs.xlsx Figure 3-10
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Figure 3-11: Summary of Current Total Nitrogen Loading and Removal
BASIN AREA N LOADING N REMOVAL lbs NET N lbs N/yr N/yr LOADING lbs N/yr Main Basin 74,216 - 122,235 - 48,019 Fringe Basin North 23,471 -17,236 6,234 Fringe Basin Northeast 10,379 - 26,777 - 16,398 Fringe Basin East 7,477 - 4,804 2,674
The largest source of nitrogen for the basin areas is irrigation (32% to 67% of total loading), with the exception of the Fringe Basin East, where nitrogen loading from irrigation is only 12% of total loading. In the Fringe Basin East, nitrogen loading is predominantly from horse boarding facilities (40%) and septic tanks (41%). Septic tanks also contribute a significant source of nitrogen (26%) in the Fringe Basin Northeast.
The largest removal of nitrogen in the Main Basin is from groundwater pumping (99.7%). In the Fringe Basin areas, where there is little groundwater pumping, the majority of nitrogen removal is from subsurface outflow (95% to 99.8%). However, because there are no wells down-gradient of the Fringe Basin East, the nitrate concentration of the subsurface outflow is unknown. For the calculations presented in Figure 3-10, Zone 7 used the average concentration of the basin.
In the Main Basin the net nitrogen loading is negative because of nitrogen removal by groundwater pumping. In the Fringe Basin Northeast the net nitrogen loading is also negative primarily because of high nitrate concentrations in the subsurface outflow. However, the net annual nitrogen loading is increasing in the Fringe Basin North and Fringe Basin East because there is little groundwater pumping or subsurface outflow and no other major nitrogen removal mechanisms.
3.3.2 Future Nitrate Loading
The planning horizon for this study is 2050, which is close to when “buildout” of the cities is currently projected. At “buildout,” the following land use changes are expected to be completed:
Aggregate mining activities, converting to other uses. Urban development per Municipal General Plans South Livermore Plan development Recycled water project expansions
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To calculate nitrogen loading at “buildout,” Zone 7 applied the methodology described in Section 3.2.2 using the following data sets:
Daily precipitation for an average year Daily evaporation for an average year Land-Use at Buildout (shown in Figure 3-12 below) Source Water Distribution at Buildout (shown in Figure 3-13 below)
Figure 3-12: Land Use at Buildout
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Figure 3-13: Source Water Distribution at Buildout
The net nitrogen loading from each component (loading and removal) is shown by basin area in Figure 3-14 and is summarized in Figure 3-15 below:
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FIGURE 3-14 NET NITROGEN LOADING BY BASIN LAND USE AT BUILDOUT WITH AVERAGE RAINFALL
MAIN BASIN FRINGE BASIN (NORTH) FRINGE BASIN (NORTHEAST) FRINGE BASIN (EAST) Concentration N Loading Concentration N Loading Concentration N Loading Concentration N Loading COMPONENTS Units or Ratelbs N/yr Units or Rate lbs N/yr Units or Ratelbs N/yr Units or Rate lbs N/yr LOADING 17,395 AF 7 mg/L 78,595 3,300 AF 13 mg/L 26,430 3,105 AF 6 mg/L 11,814 517 AF 27 mg/L 8,628 Stream Recharge 9,495 AF 1 mg/L 7,028 150 AF 4 mg/L 326 1,049 AF 1 mg/L 668 100 AF 1 mg/L 62 Nat Stream Recharge 5,700 AF 0.94 mg/L 3,315 150 AF 3.50 mg/L 326 999 AF 1.00 mg/L 619 100 AF 1.00 mg/L 62 AV Prior Rights 900 AF 1.58 mg/L 881 Art Stream Recharge 2,895 AF 1.58 mg/L 2,833 50 1.58 mg/L 49 Rainfall Recharge 4,300 AF 0.50 mg/L 1,333 1,486 AF 0.50 mg/L 461 960 AF 0.50 mg/L 298 276 AF 0.50 mg/L 86 Leakage 1,000 AF 21 mg/L 13,020 485 AF 21 mg/L 6,309 50 AF 21 mg/L 651 10 AF 21 mg/L 130 Applied Water 1,600 AF 45 mg/L 44,180 1,180 AF 26 mg/L 19,335 1,046 AF 16 mg/L 10,197 130 AF 103 mg/L 8,350 Irrigation (fertilizer) 29,201 18,796 6,369 985 Horse Boarding 52 acre 75 lbs/acre 3,914 0 acre 75 lbs/acre 0 0 acre 75 lbs/acre 0 40 acre 75 lbs/acre 2,978 Rural Septic/Manure 186 properties 49 lbs/prop 9,114 11 properties 49 lbs/prop 539 66 properties 49 lbs/prop 3,234 73 properties 49 lbs/prop 3,577 Winery Large 3 wineries 355 lbs/winery 1,065 0 wineries 355 lbs/winery 0 0 wineries 355 lbs/winery 0 0 wineries 355 lbs/winery 0 Winery Medium 2 wineries 200 lbs/winery 400 0 wineries 200 lbs/winery 0 0 wineries 200 lbs/winery 0 0 wineries 200 lbs/winery 0 Winery Small 9 wineries 54 lbs/winery 486 0 wineries 54 lbs/winery 0 11 wineries 54 lbs/winery 594 15 wineries 54 lbs/winery 810 Subsurface Inflow 1,000 AF 21.02 mg/L 13,034 0 AF 0.44 mg/L 0 0 AF 0.44 mg/L 0 REMOVAL ‐17,395 AF 8 mg/L ‐81,224 ‐3,300 AF 8 mg/L ‐17,236 ‐3,105 AF 14 mg/L ‐26,777 ‐517 AF 16 mg/L ‐5,202 Zone 7 Pumping ‐5,940 AF 12.19 mg/L ‐44,905 Retailer Pumping ‐6,570 AF 7.18 mg/L ‐29,267 Ag Calculated ‐400 AF 6.21 mg/L ‐1,539 ‐133 AF 0.44 mg/L ‐36 ‐53 AF 15.00 mg/L ‐493 ‐21 AF 16.25 mg/L ‐212 Other Pumping ‐1,185 AF 7.47 mg/L ‐5,486 Mining Losses ‐3,200 AF 0.00 mg/L 0 Subsurface Outflow ‐100 AF 0.44 mg/L ‐27 ‐3,166 AF 8.76 mg/L ‐17,200 ‐3,052 AF 13.89 mg/L ‐26,284 ‐496 AF 16.25 mg/L ‐4,991 Subsurface to Streams ‐2,166 AF 3.10 mg/L ‐4,166 ‐3,052 AF 13.89 mg/L ‐26,284 ‐496 AF 16.25 mg/L ‐4,991 Subsurface to MB ‐1,000 AF 21.02 mg/L ‐13,034 NET NITROGEN LOADING ‐2,629 9,194 ‐14,963 3,426
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Figure 3-15: Summary of Total Nitrogen Loading and Removal at Buildout
BASIN N LOADING N REMOVAL NET N LOADING (lbs N/yr) (lbs N/yr) (lbs N/yr) Main Basin 78,595 - 81,224 - 2,629 Fringe Basin North 26,430 -17,236 9,194 Fringe Basin Northeast 11,814 -26,777 -14,963 Fringe Basin East 8,628 -5,202 3,426
At “buildout,” the largest components of loading and removal of nitrogen are the same as those currently, with only slight percentage changes. The largest source of nitrogen loading for the basin areas is irrigation (37% to 71% of total loading, a slight increase over the current 32% to 67%), with the exception of the Fringe Basin East, where nitrogen loading from irrigation is only 11% of total loading (12% currently). In the Fringe Basin East, nitrogen loading is predominantly from horse boarding facilities (34%, compared to 40% currently) and septic tanks (42%, compared to 41% currently). Septic tanks also contribute a significant source of nitrogen (28%, compared to 26% currently) in the Fringe Basin Northeast.
The largest removal of nitrogen in the Main Basin is predicted to be from groundwater pumping (99.98%, currently 99.7%). In the Fringe Basin areas, where there is little groundwater pumping, the majority of nitrogen removal will be from subsurface outflow (95% to 99.8%, same as current). However, because there are no wells down-gradient of the Fringe Basin East, the nitrate concentration of the subsurface outflow is unknown. For the calculations presented in Figure 3-14, Zone 7 used the average concentration of the basin.
At “buildout,” the net nitrogen loading in the Main Basin will continue to be negative because of nitrogen removal by groundwater pumping. In the Fringe Basin Northeast the net nitrogen loading will continue to be negative primarily because of high nitrate concentrations in the subsurface outflow. However, the net annual nitrogen loading will continue to be positive in the Fringe Basin North and Fringe Basin East because there is little groundwater pumping or subsurface outflow and no other major nitrogen removal mechanisms. 3.4 Projected Nitrate Concentrations
Zone 7 created a spreadsheet model to estimate future nitrogen concentrations for the four basin areas. These are presented and discussed by basin area below. Also shown on the graphs for the Main Basin and Fringe Basin North, where the recycled water irrigation projects are planned, are the predicted concentrations if there were no additional recycled water irrigation projects. According to the Recycled Water Policy, a recycled water irrigation project must use less than 10% of the available assimilative capacity or multiple projects must use less than 20% of available assimilative capacity. Since there are
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three planned recycled water projects in the Valley (by DSRSD, Livermore, and Pleasanton), the results are assessed relative to 20% of the available assimilative capacity.
Nitrate concentrations in the Main Basin are expected to drop (see Figure 3-16 below) primarily because of the removal of nitrates by groundwater pumping. The graph below also shows that there is only a minor expected increase in concentrations (<1 mg/L) from future planned recycled water, primarily because it is assumed that for the majority of land uses, nitrogen loading from the recycled water irrigation projects will be offset by reduced fertilizer application (Section 3.2.2).
Figure 3-16: Predicted Nitrate Concentrations in Main Basin
25.0 Main Basin
20.0 (mg/L)
Predicted Nitrate Concentration 15.0 Concentration With No Additional Recycled Water 20% of Assimilative Capacity Cocentration
10.0 Nitrate
5.0
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050
While net nitrate loading is positive in the Fringe Basin North, the total nitrogen loading increase is small relative to the overall volume of water in the basin. Therefore concentrations are only expected to rise slightly (about 2 mg/L) and are not expected to approach the limit of 20% of the assimilative capacity (see Figure 3-17 below). Also, there is only a minor expected increase in concentrations (<1 mg/L) from future planned recycled water, primarily because the nitrogen loading from the recycled water irrigation projects will be offset by reduced fertilizer application.
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Figure 3-17: Predicted Nitrate Concentrations in Fringe Basin North
20.0 Fringe Basin North
15.0 (mg/L)
10.0 Cocentration Predicted Nitrate Concentration Concentration With No Additional Recycled Water
Nitrate 20% of Assimilative Capacity 5.0
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050
Nitrate concentrations in the Fringe Basin Northeast are expected to drop (see Figure 3-18 below) because of the net negative nitrogen loading, primarily because of nitrate losses due to subsurface overflow from the basin. No recycled water irrigation projects are planned over this basin.
Figure 3-18: Predicted Nitrate Concentrations in Fringe Basin Northeast
25 Fringe Basin Northeast
20 (mg/L)
Predicted Nitrate Concentration 15 20% of Assimilative Capacity Cocentration
10 Nitrate
5
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050
Due to the positive net nitrogen loading primarily from anticipated increases in rural residential and agri- commercial land uses (livestock manure and septic system leachate), nitrate concentrations are expected to rise only slightly (about 1 mg/L) in the Fringe Basin East (see Figure 3-19 below), and are anticipated to remain below the 20% of the assimilative capacity limit. No recycled water irrigation projects are planned over this basin.
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Figure 3-19: Predicted Nitrate Concentrations in Fringe Basin East
25 Fringe Basin East 20 Predicted Nitrate Concentration 20% of Assimilative Capacity (mg/L) 15
10 Cocentration
5 Nitrate 0
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050
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4 Proposed Projects and Antidegradation Analysis
4.1 Recycled Water Projects
The Recycled Water Policy and other state-wide planning documents recognize the tremendous need for and benefits of increased recycled water use in California. As stated in the Recycled Water Policy “The collapse of the Bay-Delta ecosystem, climate change, and continuing population growth have combined with a severe drought on the Colorado River and failing levees in the Delta to create a new reality that challenges California’s ability to provide the clean water needed for a healthy environment, a healthy population and a healthy economy, both now and in the future. …….We strongly encourage local and regional water agencies to move toward clean, abundant, local water for California by emphasizing appropriate water recycling, water conservation, and maintenance of supply infrastructure and the use of stormwater (including dry-weather urban runoff) in these plans; these sources of supply are drought- proof, reliable, and minimize our carbon footprint and can be sustained over the long-term.” Clearly, the benefits in terms of sustainability and reliability of recycled water use cannot be overstated (quoted from RMC, 2013).
Recycled water represents a significant potential resource for the Valley. Livermore, Pleasanton, and DSRSD plan to expand the use of recycled water for turf and landscape irrigation projects over the next few years. The location of existing and future recycled water use is shown in Figure 3-13. The estimated volumes of future planned recycled water use are shown in the figure below:
Figure 4-1: Existing and Future Recycled Water Use Volume Inside Main Basin Location AF % Existing Livermore 1,700 59% DSRSD 2,800 0% Future East Pleasanton Plan 300 100% Pleasanton Phase 1 1,700 41% Staples Ranch 200 50% DSRSD – planned 300 0% Livermore - planned 300 100%
Mitigation of the water quality concerns related to salt loading from recycled water use is addressed in Zone 7’s SMP (Zone 7, 2004, Chapter 3, Section 3.3.1.1) and in Zone 7 Annual Reports for the GWMP (most recent is Zone 7, 2014 for the 2013 Water Year, October 2012 to September 2013). Zone 7 is collaborating with Livermore, DSRSD, and Pleasanton to incorporate future planned recycled water use
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expansions, and to plan for future groundwater demineralization facilities to mitigate for the potential impact to groundwater and delivered water quality. 4.2 Stormwater Capture Projects
Zone 7 supports low impact development projects with pervious surfaces that allow for improved management of stormwater and enhanced groundwater recharge, particularly in developed areas (Zone 7, 2011). As stated in the Recycled Water Policy, 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, the inclusion of a significant stormwater use and recharge component within the salt/nutrient management plans is critical to the long-term sustainable use of water in California. While there are currently no proposed large-scale plans for stormwater capture and recharge in the Valley, the County and Cities have required stormwater capture and recharge for various small-scale projects. Zone 7 encourages the continuation of this concept into future land development.
Zone 7 does include stormwater recharge as part of its areal recharge and stream flow recharge calculations, however the effect of individual, small-scale stormwater capture and recharge projects is not included at this time due to the uncertainties in the projected quantity and volumes. The current calculations represent a conservative approach since storm water capture and recharge would likely decrease nitrate concentrations in the groundwater basin. Future updates to this plan may re-evaluate this approach as future projects are proposed. 4.3 SWRCB Recycled Water Policy Criteria
Section 9 Anti-Degradation of the SWRCB’s Recycled Water Policy states, in part:
a. The State Water Board adopted Resolution No. 68-16 as a policy statement to implement the Legislature’s intent that waters of the state shall be regulated to achieve the highest water quality consistent with the maximum benefit to the people of the state.
b. Activities involving the disposal of waste that could impact high quality waters are required to implement best practicable treatment or control of the discharge necessary to ensure that pollution or nuisance will not occur, and the highest water quality consistent with the maximum benefit to the people of the state will be maintained…..
d. Landscape irrigation with recycled water in accordance with this Policy is to the benefit of the people of the State of California. Nonetheless, the State Water Board finds that the use of water for irrigation may, regardless of its source, collectively affect groundwater quality over time. The State Water Board intends to address these impacts in part through the development of salt/nutrient management plans described in paragraph 6.
(1) A project that meets the criteria for a streamlined irrigation permit and is within a basin where a salt/nutrient management plan satisfying the provisions of paragraph 6(b) is in place
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may be approved without further antidegradation analysis, provided that the project is consistent with that plan.
(2) A project that meets the criteria for a streamlined irrigation permit and is within a basin where a salt/nutrient management plan satisfying the provisions of paragraph 6(b) is being prepared may be approved by the Regional Water Board by demonstrating through a salt/nutrient mass balance or similar analysis that the project uses less than 10 percent of the available assimilative capacity as estimated by the project proponent in a basin/sub-basin (or multiple projects using less than 20 percent of the available assimilative capacity as estimated by the project proponent in a basin/sub-basin). 4.4 Antidegradation Assessment
Section 3.4 includes graphs of future average nitrate concentrations for scenarios with and without the proposed recycled water irrigation projects in the Main Basin and Fringe Basin North. The graphs show that irrigation with recycled water contributes very minor nutrient loading in the basins (<1%), and that the recycled water projects do not use more than 20% of the available assimilative capacity. Nitrogen loading from recycled water can be minimized even further by employing recycled water irrigation BMPs (Section 5.3), and fertilizer BMPs (Section 5.2) when turf or landscape fertilizers (or fertigation) are applied along with recycled water.
The NMP analysis finds that recycled water use can be increased while still protecting and improving groundwater quality for beneficial uses. Figure 4-2 addresses how the proposed recycled water irrigation projects comply with each of the components of SWRCB’s Anti Degradation Policy (Resolution No. 68- 16).
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Figure 4-2: Antidegradation Assessment
SWRCB Resolution No. 68-16 Component Antidegradation Assessment
Water quality changes associated with The irrigation projects will proposed recycled water project(s) are consistent with the maximum benefit of the contribute only a minimal increase (<1 mg/L) people of the State. in groundwater nitrate concentrations at urban buildout. The water quality changes associated with proposed recycled water project(s) will not will not use more than 20% of the available unreasonably affect present and anticipated Assimilative Capacity beneficial uses. will not cause groundwater quality to exceed The water quality changes will not result in Basin Plan Objectives water quality less than prescribed in the Basin Plan.
The projects are consistent with the use of best Because all planned recycled water projects over practicable treatment or control to avoid the groundwater basin are landscape irrigation pollution or nuisance and maintain the highest projects, most of the nitrogen from these water quality consistent with maximum benefit projects will be removed by plant uptake and to the people of the State. volatilization (and some by bacterial denitrification under certain conditions). Additional nitrogen loading will be avoided with the use of recycled water and fertilizer use BMPs (see Section 6.1)
The proposed project(s) is necessary to The recycled water projects are crucial for accommodate important economic or social continued sustainability of the Valley’s water development. supply and are part of the urban growth plans for Cities of Dublin, Livermore, and Pleasanton.
Implementation measures are being or will be Both, the SMP and the NMP contain measures implemented to help achieve Basin Plan that have been or will be implemented to Objectives in the future. address current and future salt and nutrient loading of the Groundwater Basin.
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5 Nutrient Management Goals and Strategies
5.1 Introduction
As shown in Section 3.4 above, basin-wide nitrogen concentrations are expected to drop or stay relatively constant over the long-term; however, there are some existing high nitrate concentrations in local areas of concern (Section 2.4). This chapter presents the goals and strategies for mitigating nitrate concentrations in the groundwater basin primarily by focusing on minimizing nitrogen loading over the groundwater basin.
The primary sources of nitrogen loading over the groundwater basin are from fertilizer application, recycled water irrigation, leaching of livestock manure, and onsite wastewater treatment systems (OWTS). Best Management Practices (BMPs) are the best tools for minimizing nitrogen loading from irrigation (fertigation), turf and crop fertilization practices, and penned livestock facilities such as horse boarding facilities. And while the additional nitrogen loading from future recycled water project expansions is expected to be small (Section 3.4), it would be prudent to employ the fertilizer application BMPs as well as the recycled water irrigation BMPs for all recycled water irrigation projects.
OWTS use in the Valley involves domestic and commercial septic tanks and systems to treat and dispose of winery process wastewater. OWTS management, especially in the Areas of Concern, requires long- term goals and strategies for ensuring impacts from new onsite wastewater disposal systems are not going to create a new nitrate problem or exacerbate an existing one. Eventually, the conventional septic tank systems in the Areas of Concern should be converted to alternative systems having nitrogen reduction treatment, or the affected homes and businesses should be connected to a municipal or community sewer system. Management of onsite treatment and disposal of wastewater from wine making and bottling processes is under the RWQCB’s jurisdiction, and is currently provided for through the RWQCB’s waste discharge requirement (WDR) permit program. Although WDRs are an effective means for managing nutrient loading from this land use, improvements are needed in stakeholder guidance and permit compliance. 5.2 Fertilizer Application
Goal 5.2: Minimize nitrogen loading from fertilizer application
Strategy 5.2a: Promote the use of fertilizer BMPs (Section 6.1.2) to avoid over-application of fertilizers. Using results of soil and irrigation water chemical testing to determine the appropriate amount of additional fertilizer to apply is a good way to lessen excess leachable nitrogen in the soil.
Strategy 5.2b: Limiting irrigation water application to the crop and landscape plants’ agronomic rate will reduce the amount of nutrient-rich leachate that migrates below the vegetation root zone and into the underlying aquifer(s).
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5.3 Recycled Water Irrigation
Goal 5.3: Minimize nitrogen loading from recycled water irrigation projects
Strategy 5.3a: Follow Recycled Water Policy guidance for landscape irrigation projects. Minimize recharge of nitrogen by irrigating landscapes to the prescribed agronomic rates. Account for the nitrogen content of the recycled water when determining how much fertilizer to apply.
Strategy 5.3b: Maintain low levels of nitrogen in the produced recycled water by keeping the nitrogen concentrations in the source water low and/or by utilizing a nitrogen removal process during the production of recycled water. 5.4 Livestock Manure Management
Goal 5.4: Minimize nitrogen loading from concentrated livestock facilities such as horse boarding, training, and breeding facilities
Strategy 5.4: Promote the use of BMPs (Section 6.1.4) such as manure management and controlling site drainage to prevent nutrient contamination of rainfall runoff and irrigation return flows that may percolate to groundwater and/or flow into surface water bodies. 5.5 Onsite Wastewater Treatment Systems 5.5.1 General Septic Tank Management
Goal 5.5.1: Minimize nitrogen loading from new onsite wastewater treatment systems (OWTS), e.g., septic tank systems.
Strategy 5.5.1a: Continue applying Zone 7 policies and County Ordinance and Regulation provisions, e.g., 1 Rural Residential Equivalence (RRE)/5 Ac max.
Strategy 5.5.1b: Continue to work with ACEH to ensure that: 1) they are aware of groundwater nitrate issues in the Livermore Valley Groundwater Basin; 2) that variance requests are given the appropriate scrutiny; and 3) their OWTS approvals are consistent with adopted NMP goals and objectives.
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5.5.2 Septic Tank Management in Areas of Concern
Goal 5.5.2: Reduce nitrogen loading from septic tanks in Areas of Concern.
Strategy 5.5.2a: Increase understanding of existing conditions and causes, and set realistic management goals and apply adaptive management as necessary.
Strategy 5.5.2b: Require new development projects utilizing OWTS in the Areas of Concern to reduce the overall nitrogen loading to the property.
Strategy 5.5.2c: On at least an annual basis, assess performance of wastewater treatment systems, estimate area-wide nitrogen loading and monitor groundwater quality beneath the Areas of Concern.
5.5.3 Winery Process Wastewater
Goal 5.6: Minimize nitrogen loading from onsite disposal practices of winery process wastewater.
Strategy 5.6a: Require local wine producers and bottlers to apply for and comply with RWQCB WDRs for the proper treatment and disposal of winery process waste streams.
Strategy 5.6b: Develop guidance document(s) to assist both project proponents and RWQCB staff with Report of Waste Discharge (ROWD) and WDR development and evaluations.
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6 Plan Implementation
6.1 Implementation Measures 6.1.1 Introduction
Nitrate concentrations are expected to remain well below 20% of the assimilative capacity limit for all four groundwater areas in the Livermore Valley Groundwater Basin; however there are local Areas of Concern where nitrate concentrations are above the Basin Objective (BO, 45 mg/L as NO3). The main sources of nitrogen loading throughout the groundwater basin include fertilizer application, recycled water irrigation, livestock facilities, and onsite wastewater treatment systems. The implementation measures presented below are designed to minimize loading from these main sources, particularly in the Areas of Concern shown on Figure 2-14 and described in Section 2.4.
6.1.2 Fertilizer BMPs
Fertilizer application should be adjusted to the needs of the plants/crops to which it is being applied and take into account the nutrients already present in soil and irrigation water to avoid over-fertilization. Fertilizer BMPs include the following:
Targeted application of fertilizer and soil amendments – limit the application of salts and nutrients to the area at the point of the irrigation drip emitter, rather than broadcast across a large area.
Adjust fertilizer amounts to account for nutrients already present in irrigation water and soil. Nutrient levels can be assessed by testing soil and water.
Apply irrigation at agronomic rates to prevent nutrients in fertilizer from leaching into the groundwater.
Effective vineyard management includes regular soil and petiole testing to help understand what, and how much, nutrients need to be added to the soil to produce the desired grape production and flavor. When the soil and petiole testing includes nitrogen as a test parameter, the results can be used to ensure that the amount of additional nitrogen applied is limited to that amount needed by the vines.
6.1.3 Recycled Water Irrigation BMPs
The use of recycled water for irrigation is controlled by California Code of Regulations, Title 22 (Title 22). In addition to adhering to the Title 22 regulations related to recycled water, recycled water BMPs include the following:
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Reduce application of fertilizer to account for nitrogen in the recycled water.
Irrigate during evening and early morning hours to reduce evaporation and human exposure.
An effective irrigation system should be used that applies recycled water at agronomic rates. Infiltration of recycled water past the active root zone should be limited to only what is needed to remove salts from the root zone.
6.1.4 Livestock Manure Management
Livestock and Equestrian Facilities are another source of nitrates due to concentrated amounts of manure where animals are kept. Equestrian Facilities include horse boarding, training, and breeding facilities. Livestock manure management BMPs include the following:
Manure management – remove manure regularly. If manure can’t be removed daily then it should be covered and stockpiled on an impervious surface. Surface water should be prevented from reaching the storage area.
Building and site design – should keep animal areas, such as paddocks and corrals, as dry as possible during the rainy season.
Wash rack design – should not allow water to flow into storm drains, creeks, ponds, or recharge areas. Wash racks should be connected to the sanitary sewer, if possible.
Site referral and review process – a process is in place for new sites and modifications of existing sites to be reviewed by Zone 7. This process can be used to encourage facilities that support BMPs. It is also an opportunity to educate the public on nitrate BMPs.
Additional guidance for manure management can be found in existing documents such as Horse Manure Management – A Guide for Bay Area Horse Keepers (Buchanan et al., 2003).
6.1.5 Onsite Wastewater Treatment and Disposal
Limitations for the expansion of municipal sewer coverage in the Livermore-Amador Valley associated with the establishment of urban growth boundaries has resulted in the continued reliance of OWTS for development in the unincorporated areas. In particular, the continued growth of winery-related commercial development in or near the south Livermore high nitrate areas is a concern for maintaining or improving groundwater quality. Septic systems that may have been allowed in the past may not be appropriate in the future as conditions and circumstances surrounding particular locations change or become known.
As provided for in the RWQCB Basin Plan, ACEH has committed to developing a Local Agency Management Program (LAMP) for RWQCB approval that will address their management of OWTS in
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unincorporated Alameda County. A LAMP is a management program where local agencies establish minimum standards that are different from those specified in the State OWTS Policy, but are necessary to protect water quality and public health. Requirements for different minimum lot size for new development using OWTS and the addition of nitrogen-removing treatment equipment on OWTS for certain conditions are examples of special provisions that ACEH will likely include in its LAMP.
6.1.5.1 General Septic Tank Program
One of the purposes of the Alameda County Onsite Wastewater and Individual/Small Water Systems Ordinance and Regulations is to prevent environmental degradation of surface water and groundwater from onsite disposal of private sewage to the greatest extent possible. Included in the regulations are special provisions for the Upper Alameda Creek Watershed, above Niles; namely:
a. a minimum parcel size requirement of 5 acres for new single-family septic tank systems; and b. a maximum discharge of 320 gallons per day per 5 acres for commercial septic tank systems.
Continued application of the general provisions of the County OWTS Ordinance and Regulation and these special provisions should minimize the groundwater nitrate impact from septic tank use in the majority of the unincorporated areas of the Livermore Valley Groundwater Basin except in the Areas of Concern. Additionally, the following measures should be accomplished:
Zone 7 and ACEH should continue working together to ensure that both agencies are aware of groundwater issues in the Livermore Valley Groundwater Basin and that any OWTS approvals are consistent with the adopted NMP goals and objectives.
Zone 7 and ACEH should continue to collaborate on the decisions surrounding approval of new septic tank use for commercial facilities’ domestic wastewater disposal on a case-by-case basis and to evaluate the potential risks and make proper decisions as additional information becomes available.
Zone 7 and ACEH should continue to collaborate on assessing the potential risks and impact(s) associated with granting OWTS regulation variances and on developing any special requirements necessary to ensure groundwater quality protection.
6.1.5.2 Septic Tank Management in Areas of Concern
Zone 7 has identified ten Areas of Concern with elevated nitrate concentrations in groundwater. Current and past onsite wastewater disposal practices are thought to be an important contributor to the high nitrate concentrations found in these areas. As such, ongoing and future wastewater disposal projects in the Areas of Concern should be managed with a bias towards reduction of the current loading. It is also important to increase the understanding of the extent of the nitrate impacts in many of these areas and to monitor the concentration trends as projects add and subtract wastewater loading in these areas. Towards these goals the following measures should be performed:
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Zone 7 will coordinate further characterization and monitoring of the local nitrate plumes by working with ACEH, RWQCB and various property owners and consultants on the development of plans for the construction and operation of additional monitoring wells.
Zone 7 should continue its effort to inform ACEH and Alameda CDA of the nitrate issues in the Livermore Valley Groundwater Basin and to collaborate on development plans, permit reviews, and CEQA analyses for projects involving onsite wastewater disposal in Areas of Concern to assure approvals are consistent with adopted NMP goals and objectives.
Local Agency Formation Commission (LAFCO), developers and County and City planning agencies should continue to work together to create opportunities for discontinuing onsite disposal of nutrient-rich wastewater within the Areas of Concern; such as connecting dwellings and businesses to municipal or community sewage treatment works when feasible.
ACEH, Zone 7, and RWQCB should work together on the development, approval, and implementation of the LAMP with Zone 7 identifying the special need areas, contributing local groundwater and geologic expertise, and providing ongoing regional groundwater monitoring.
In five of the ten Areas of Concern, septic tank use is the predominant method of wastewater disposal, but unlike the other five Areas of Concern, there are no current plans for extending the municipal sewer service to these five OWTS areas. The five areas are:
Happy Valley (Figure 6-2) May School (Figure 6-3) Buena Vista (Figure 6-4) Greenville (Figure 6-4) Mines Road (Figure 6-5)
Accordingly, special OWTS permit requirements have been developed for new septic tank applications received for these five Areas of Concern for use during the interim between NMP adoption and LAMP approval. These five special OWTS permit requirement areas are shown in Figure 6-1 to Figure 6-5, and the recommended permit requirements are summarized below and presented in a table in Figure 6-6.
These special permit requirements are designed to reduce the amount of nitrogen loading from OWTS in the five Areas of Concern over time by requiring replacement of old conventional septic tank systems with new treatment systems when the opportunity arises. For example, in order to add an additional single-family dwelling with a new septic system to a parcel that already has an existing single-family dwelling with a conventional septic tank, the project must include installation of pre-treatment equipment, capable of removing 65% of the nitrogen content from the wastewater stream, on both OWTS (new and existing systems). As a consequence, the net result would be an onsite loading reduction from a pre- project total of one rural residential equivalence (1.0 RRE) to a post- project total of 0.7 RRE. (0.35 + 0.35 RRE).
Where a new OWTS is proposed for a single-family dwelling on an existing vacant parcel (i.e., historic lot-of-record) in a special permit requirement area, the project is automatically required to install
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nitrogen-removing pre-treatment equipment capable of removing either a minimum of 50% or 65% of the nitrogen from the residential wastewater depending whether the vacant lot is 5 acres or greater or less than 5 acres.
Because wastewater generated by commercial operations can result in higher loading rates than residential flows, the permitting of OWTS for new commercial projects within the special permit requirement areas require higher level of scrutiny. At a minimum, projects must include a nitrogen- removing system, but also must demonstrate by analysis that the project will result in an improved nitrate condition beneath the site and not cause the offsite condition to worsen. Many of the commercial use OWTS will fall under the RWQCB’s jurisdiction and thus be subject to their Report of Waste Discharge (ROWD) requirements.
These same permit criteria may also be incorporated into the County’s LAMP and used by the RWQCB while developing Waste Discharge Requirements (WDR) for commercial projects within their purview if they prove to be effective at improving or halting groundwater quality degradation in these Areas of Concern. The following are measures specific to the special permit requirement areas:
Until ACEH’s LAMP has been finalized and approved by the RWQCB, ACEH should incorporate and implement an interim permit approval policy such as the one recommended in Figure 6-6.
Zone 7 should continue to refine the special permit area boundaries as more groundwater quality data becomes available in the future.
Zone 7 and ACEH will continue to support RWQCB in its WDR decisions and specific requirements.
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Figure 6-1: Special OWTS Permit Areas
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Figure 6-2: Happy Valley Areas of Concern
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Figure 6-3: May School Area of Concern
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Figure 6-4: Buena Vista/Greenville Areas of Concern
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Figure 6-5: Mines Road Areas of Concern
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FIGURE 6‐6 PROPOSED SEPTIC TANK PERMIT REQUIREMENTS INSIDE AREAS OF CONCERN
Development Type Septic Tank Permit Type Requirement Remodel/add-on with no new septic system Grandfathered required Must install nitrogen reducing engineered system w/ min Remodel/add-on with new septic system required Existing Residential Dwelling 50% nitrogen removal. Must install nitrogen reducing engineered systems for both Adding a secondary dwelling unit on a historic lot- dwellings w/ min 65% nitrogen removal. OK to combine into of-record (pre-1982) one system. New septic on vacant historic lot-of-record less Must install nitrogen reducing engineered system w/ min than 5 acre (pre-1982) 65% nitrogen removal. New Residential Dwelling New septic on vacant new lot (must be 5 acre or Must install nitrogen reducing engineered system w/ min greater) or vacant historic lot-of-record 5 acre or 50% nitrogen removal. greater Self-contained (porta-potties or holding tank) Maintain records of offsite disposal.
New Retail, Commercial or Submit a hydrogeologic study demonstrating that the new Industrial Use (including development (including the proposed wastewater disposal and any on-site remediation) will reduce the existing onsite wineries, event centers, New onsite treatment and disposal system nitrogen loading and improve groundwater quality beneath restaurants, and B&Bs) the site. Water Board may require Report of Waste Discharge for these new wastewater systems.
10/27/2014 E:\PROJECTS\SNMP Update\Report\Figures\NMPFig6‐06‐SepticRequirement.xlsx Figure 6‐6
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6.1.5.3 Winery Process Wastewater
There are currently over 50 wineries located over the Livermore Valley Groundwater Basin, however, many of them do not produce or bottle wine onsite. The ones that do produce or bottle wine, also produce a wastewater stream during the wine production and bottling operations. This winery process water, which contains nutrients, is often disposed in evaporation ponds, on the surface as irrigation or dust control water, or in the subsurface using OWTS and leachfields. Regardless of which of these disposal methods are used, the RWQCB has authority to regulate the discharge; thus a Report of Waste Discharge is required to be submitted to the RWQCB for the discharge of wastewater to the surface or subsurface. The RWQCB will then approve the discharge by issuing Waste Discharge Requirements, waive the need of a WDR, or deny approval of the discharge.
To assist applicants with their ROWD preparation and the RWQCB with their evaluation of ROWDs and WDR decisions, Zone 7 and ACEH will continue to provide relevant information on groundwater occurrence, use, quality and vulnerability to the RWQCB and applicants.
The preparation of a guidance document on the proper treatment and disposal of wastewater and organic wastes generated from the wine making and wine bottling processes would be beneficial for the development of plans that are effective at minimizing nutrient loading to the groundwater basin. 6.2 Basin Monitoring Programs 6.2.1 Introduction
Zone 7 currently monitors the following as part of its GWMP:
groundwater (levels and quality), climatological (precipitation and evaporation), surface water (streamflow and quality), mining area (mining activities and water export volumes), land use (area), groundwater production (volume and quality), land surface subsidence (inelastic and elastic), and wastewater/recycled water (use and quality).
The monitoring programs focus on the Main Basin where groundwater is pumped for municipal uses, but monitoring stations are located throughout the groundwater basin to assess conditions in the fringe and upland basins. The programs are designed to assess the sustainability and quality of the groundwater basin, and the results are used in water resources management planning and decision making. Complete
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descriptions of the monitoring programs are provided in Zone 7’s GWMP and SMP. The components of the programs that address nutrient monitoring are outlined below. These programs are evaluated annually and revised as necessary as part of Zone 7’s Annual Reports for the GWMP.
Zone 7’s existing monitoring programs already address nutrient monitoring, and no changes are proposed at this time. However, Zone 7 will continue to work with property owners and developers to fully characterize nitrate concentrations and nitrogen loading for projects inside the Areas of Concern. This might include the installation and monitoring of additional wells up-gradient and down-gradient of areas with high nitrate concentrations.
State policy does not require monitoring for Constituents of Emerging Concern (CECs) for basins where recycled water use is limited to irrigation projects. Since the recycled water use in the Valley is currently limited to irrigation projects, Zone 7 does not monitor for CECs at this time; however Zone 7 will continue to review the regulations and Valley conditions to assess whether future CEC monitoring is appropriate.
6.2.2 Nutrient Specific Monitoring Programs
Climatological Monitoring – Zone 7’s network of seven rainfall stations, two pan evaporation stations, and one California Irrigation Management Information System (CIMIS) station provide daily rainfall and evaporation data for basin recharge calculations. This information is used to calculate the volume of recharge, evaporation, and nitrogen loading from rainfall.
Surface Water Monitoring – This program focuses on the four main gaining and losing streams that impact the groundwater basin (i.e., Arroyo Valle, Arroyo Mocho, Arroyo Las Positas, and Arroyo De La Laguna), and the diversions and accretions that affect the flows into or from each of them. Zone 7 measures the inflow and outflow from the streams to quantify the volume of water recharging or discharging from the groundwater basin’s aquifers. Zone 7 also samples and analyzes water from the streams to provide a record of water quality for the basin’s recharge and discharge waters from which the groundwater basin’s annual nitrate loading is calculated.
Zone 7’s Water Level Monitoring – Zone 7 measures groundwater levels in over 230 monitoring and production wells (see Zone 7’s Water Quality Sampling –Zone 7 samples groundwater at least annually from all accessible groundwater wells in the program. Samples are analyzed by Zone 7’s laboratory for metals and general minerals (including Nitrate as NO3 and Phosphate as PO4).
Figure 6-7 below) twice per year during seasonal extremes (i.e., spring highs and fall lows) for storage tracking. Water level measurements are also measured monthly in some wells to monitor subsidence, adjust recharge operations, and identify when semi-annual water level measurements should be scheduled.
Zone 7’s Water Quality Sampling –Zone 7 samples groundwater at least annually from all accessible groundwater wells in the program. Samples are analyzed by Zone 7’s laboratory for metals and general minerals (including Nitrate as NO3 and Phosphate as PO4).
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Figure 6-7: Map of Program Wells
Land Use Monitoring – Zone 7 maps and quantifies Valley land use (see Figure 3-7 for the 2013 land use map) for areal recharge calculations (e.g., rainfall recharge, applied water recharge, and unmetered groundwater pumping for agriculture) and salt/nutrient loading (e.g., from irrigation, horse boarding facilities, and properties with septic tanks). The program identifies changes in land use with an emphasis on changes in impervious areas and the volume and quality of irrigation water that could impact the volume or quality of water recharging the Main Basin. Land use data are derived from aerial photography, permit applications, field observations, and City and County planning documents.
Wastewater and Recycled Water Monitoring - Zone 7 compiles and reviews data on the volume and quality of wastewater collected and recycled water used within the watershed from the Livermore Water Reclamation Plant (LWRP), DSRSD Water Reclamation plant, and the Veterans Hospital sewage treatment plant. Zone 7 also reviews Septic Tank Use Applications located within the Valley for compliance with Zone 7’s Wastewater Management Plan. Zone 7 must approve all onsite disposal systems for new commercial developments or any residential system that will potentially exceed the loading allowed for the site.
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6.3 Implementation Schedule
The Implementation Measure BMPs for Fertilizers, Irrigation, and Livestock Manure Management are already in place throughout the Valley.
Zone 7’s groundwater monitoring programs are also already in place; just the new monitoring wells discussed in Section 6.1.5.3 could be constructed and added to the existing programs.
The special OWTS permit approval requirements are currently being applied by ACEH.
ACEH, Zone 7, and RWQCB staff will begin to work on the LAMP before the end of 2014 and anticipate completing the effort in 2015.
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7 References
Buchanan, Marc et al. 2003, Horse Manure Management: A Guide for Bay Area Horse Keepers.
California Department of Public Health. 2014. Titles 22 and 17 California Code of Regulations, California Department of Public Health’s Recycled Water Regulations.
California Department of Water Resources.1974. California’s Groundwater, Bulletin 118-2, Evaluation of Ground Water Resources: Livermore and Sunol Valleys.
_____. 2003. California’s Groundwater, Bulletin 118—Update 2003.
California Regional Water Quality Control Board, San Francisco Bay Region, 2013, San Francisco Bay Basin (Region 2) Water Quality Control Plan (Basin Plan).
Camp Dresser and McKee Inc. 1982. Wastewater Management Plan for the Unsewered, Unincorporated area of Alameda Creek Watershed above Niles. Prepared for Zone 7 of Alameda County Flood Control and Water Conservation District.
Horsley Witten Group, 2009, Evaluation of Trufgrass Nitrogen Fertilizer Leaching Rates in soils on Cape Cod, Massachusetts, June 29, 2009.
Moran, Jean; Esser, Bradley; Hillegonds, Darren; Holtz, Marianne; Roberts, Sarah; Singleton, Michael; and Visser, Ate. 2011, California GAMA Special Study: Nitrate Fate and Transport in the Salinas Valley.
RMC, 2002, Groundwater Nitrate Sources in the Buena Vista Area, May 2002
———. 2012, Santa Rosa Plain Subbasin Salt and Nutrient Management Plan, Draft Report prepared for the City of Santa Rosa, July 13, 2012.
———. 2013, Sonoma Valley Salt and Nutrient Management Plan, Prepared for the Sonoma Valley county Sanitation District, September 2013.
Solley, W. B., R. R. Pierce, H. A. Perlman (USGS). 1998. Estimated use of water in the United States in 1995. US Geological Survey circular; 1200. Denver, CO: US Geological Survey. Report nr 06079007X. ix, 71p.
Zone 7 (Alameda Flood Control and Water Conservation District, Zone 7). 1987. Statement On Zone 7 Groundwater Management. August. Prepared by Zone 7 Board Committee.
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References
———. 1992. Main Groundwater Basin Natural Safe Yield, Internal Memo prepared by Zone 7 Water Agency.
———. 2003. Draft Report, Well Master Plan, Prepared by CH2MHill for Zone 7 Water Agency.
———. 2004. Salt Management Plan. Prepared by Zone 7 Water Agency.
———. 2005a. Groundwater Management Plan. Prepared by Jones & Stokes and Zone 7 Water Agency.
———. 2005b. Well Master Plan Conformed EIR, Prepared by ESA for Zone 7 Water Agency.
———. 2007. Annual Report for the Groundwater Management Program—2006 Water Year. Prepared by Zone 7, June 2007.
———. 2011. 2011 Water Supply Evaluation. Prepared by Zone 7, July 2011.
———. 2012. Toxic Sites Surveillance Annual Report 2011. Prepared by Zone 7, April 2012.
———. 2014. Annual Report for the Groundwater Management Program—2013 Water Year. Prepared by Zone 7, August 2014.
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Roe, Dilan, Env. Health
From: Jeff Morlan
To: Dilan Roe PE
Dilan, here are my brief preliminary comments regarding your presentation at the above referenced meeting in regards to code and plan production:
1) List septic tank manufacturer only or equal on plans; no tank dimensions needed, Cal State Engineering format is consistent with this and works well.
2) Do not make construction item take-offs mandatory; make licensed contractor responsible w/ consultant answering questions. This keeps Engineer out of legal jeopardy for disagreements (we don’t give estimates except for County permit fee reasons-and then only with a major disclaimer).
3) Show all calculations; produce topography by land surveying methods for all designs.
4) Per Business and Professions code, only P.E.’s and maybe Geologists can produce topography survey or hydraulic calculations. Need P.E. to duplicate “wet Stamp” plans with these features. Counties have been breaking the law for years! (I know there are consultants that will “howl” over this…but it’s the law!).
5) Prefer to hold pre-design meeting during profile stage (at site) or after; this allows more data to be talked abut and maybe save money for client.
6) See attachments which indicate that current County regs. can stay in use till LAMP is finished.
These are just a few preliminary comments, please feel free to contact me anytime with questions or proposals.
Very Truly Yours,
Jeff Morlan PE
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