Proposed SNMP Implementation Measures Framework

Transcription

1 Nitrate Implementation Measures Study (NIMS) Strategic Salt Accumulation Land and Transport Study (SSALTS) Proposed SNMP Implementation Measures Framework Joe LeClaire, PhD Richard Meyerhoff, PhD Don Schroeder, PE November 8, 205 Executive Committee Policy Meeting Wednesday Afternoon Goals Present a proposed framework for nitrate and TDS implementation measures section of the Central Valley SNMP Reach a general consensus on elements of the proposed framework Discuss policy related questions related to nitrate and TDS implementation measures This is a Strawman Proposal Examples are Hypothetical 2

2 Central Valley SNMP Implementation Measures Must be consistent with Basin Plan requirements for a Program of Implementation: Description of the nature of actions which are necessary to achieve the objectives, including recommendations for appropriate action by any entity, public or private; A time schedule for the actions to be taken A description of surveillance to be undertaken to determine compliance with the objectives 3 Implementation Measures Framework Relevance to SNMP SNMP Section 8 addresses programmatic implementation Key elements Salt and nitrate management goals thresholds & milestones Outcome of Executive Committee policy discussions Implementation measures for salt and nitrate, e.g., menu of management options (technical outcomes of SSALTS & NIMS) Implementation framework today s discussion 4 2

3 Central Valley SNMP Implementation Mechanisms Framework requires a mechanism of implementation it has been assumed that WDRs will be used to trigger implementation If you have a WDR, determine whether you want to meet programmatic SNMP requirements collectively with other permit holders through establishment of a Management Zone or individually through your own WDR Either strategy (individual or collective) requires development of a Local SNMP that meets minimum programmatic level Central Valley SNMP requirements 5 Nitrate and TDS Management Goals Framework assumes that nitrate and TDS management goals for local SNMP will address three key elements Ensure User Protection ensure safe drinking water supply in zone of influence Minimum Requirement Implement activities to resolve user protection concerns within first 3 to 5 years of the Program of Implementation established in each local SNMP Achieve Sustainability balance of inputs/outputs Timeline and deliverables will be site specific, but with vadose zone contributions and ongoing irrigated agriculture, the timeframe to meet the goal is likely to be greater than 50 years Local SNMP to include both short term (< 20 years) and long term (50+ years) implementation measures Implement Managed Aquifer Restoration Program Considers long term implementation measures (50+ years) Phased program recommended first priority is attainment of nitrate or TDS water quality objectives or attainment goals 6 3

4 Content of a Management Zone Proposal Proposal to Establish Management Zone Chapter ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation 7 Content of a Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation A local SNMP for an individual discharger would have similar content except that: Delineation would focus on zone of influence of the discharge Governance section would not be needed 8 4

5 Conceptual Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation Delineation Establish MZ boundary Identify participating dischargers and other stakeholders 9 Hypothetical Management Zone 0 5

6 Conceptual Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation Governance Organization Legal Commitments Budget Plan Funding Commitments Dispute Resolution Outreach Plan Conceptual Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation Characterization Inventory of water supply wells Existing conditions nitrate and TDS Groundwater flow characteristics Nitrate & TDS trends Estimated available assimilative capacity 2 6

7 Management Zones Every management zone will have an SNMP specific to local conditions: Land use Hydrogeology Groundwater production TDS and nitrate distributions and concentrations, etc. Estimated Assimilative Capacity Source control measures and treatment options will be designed according to local conditions, e.g., Permeable reactive barriers to be considered for shallow groundwater with high nitrate concentrations Reverse osmosis vs. ion exchange based on co existence of TDS and nitrate Conceptual Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation Prioritization Based on findings of characterization, delineate Priority Areas for nitrate and/or TDS implementation activities Rank Priority Areas: Risk to water supply (user protection) Existing nitrate/tds concentrations Water quality trends 4 7

8 Priority Areas Priority areas will be identified during the delineation and characterization studies Priority areas will be defined for both nitrate and TDS In this hypothetical management zone, 3 percent of wells exceed 0 mg/l for nitrate N, 44 percent exceed 000 mg/l for TDS, and 4 percent exceed both 000 mg/l for TDS and 0 mg/l for nitrate N Priority Area 3 (PS3) high salinity Priority Area (PN) high nitrate Priority Area 2 (PN2) high nitrate, localized issue, e.g., POTW Priority Areas Priority Area is a hypothetical, unsewered small community. Priority Area 2 is a hypothetical POTW discharge pond. Priority Area 3 is a hypothetical area of high salinity. Priority Area 3 (PS3) high salinity Priority Area (PN) high nitrate Priority Area 2 (PN2) high nitrate, localized issue, e.g., POTW 8

9 Conceptual Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation Program of Implementation For each Priority Area Phased POI to meet nitrate or TDS goals, e.g., proposed BMPs or alternative compliance programs Proposed implementation timeline Progress towards attainment demonstration to show that proposed POI results in progress towards attainment of WQOs within proposed timeline Base POI for areas outside of Priority Areas, e.g., source control, BMPs, etc. Proposed surveillance and monitoring program 7 Progress Towards Attainment Illustration of Uncertainty Hurricane Joaquin 8 9

10 Hurricane Joaquin Actual Path 9 POI for a Nitrate Priority Area POI will address the three goals of the local SNMP User protection, progress towards sustainability, pathway to aquifer restoration Local SNMP will select from a portfolio of source control measures, treatment options, and brine management Local SNMP specifies specific actions required to achieve the goals over a specified timeframe Priority Area (PN) high nitrate Priority Area 2 (PN2) high nitrate, localized issue, e.g., POTW 0

11 PN High Nitrate Priority Area. User Protection: Provide alternative drinking water sources Whole water tanks New production wells Package treatment system including brine management Priority Area (PN) high nitrate PN High Nitrate Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone nitrate mitigation 2a. Design/preconstruction activities Management zone nitrate plan Conceptual Design Environmental/permitting Brine Management Landfill Evaporation ponds Deep well injection Salt accumulation areas Priority Area (PN) high nitrate 2a

12 PN High Nitrate Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone nitrate mitigation 2a. Design/preconstruction activities 2b. Construction Treatment Goals pump, treat, serve Extractions wells Pipelines Other infrastructure In situ nitrate treatment Brine management Priority Area (PN) high nitrate 2a 2b PN High Nitrate Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone nitrate mitigation 2a. Design/preconstruction activities 2b. Construction 2c. Operation, including brine management Wells Pipelines Other infrastructure Priority Area (PN) high nitrate 2a 2b 2c 2

13 PN High Nitrate Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone nitrate mitigation 3. Additional projects/new technology, as needed Priority Area (PN) high nitrate 2a 2a 2b 3 2c POI for a TDS Priority Area POI will address the three goals of the local SNMP User protection, progress towards sustainability, pathway to aquifer restoration Local SNMP will select from a portfolio of source control measures, treatment options, and brine management Local SNMP specifies specific actions required to achieve the goals over a specified timeframe MZ scale SNMPs may include a commitment by certain stakeholders to participate in the Central Valley Brine Line funding plan, conceptual design, environmental and permitting, etc. Priority Area 3 (PS3) high salinity 3

14 PS3 High TDS Priority Area. User Protection: Provide alternative drinking water sources Whole water tanks New production wells Priority Area 3 (PS3) high salinity PS3 High TDS Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone salt mitigation 2a. Design brine management plan Identify areas for desalination Site specific evaporation ponds Site specific deep well injection Truck/rail to landfill Truck/rail/pipeline to subregional evaporation ponds Truck/rail/pipeline to salt accumulation areas Priority Area 3 (PS3) high salinity 2a 4

15 PS3 High TDS Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone salt mitigation 2a. Design brine management plan 2b. Construction Extraction wells, drainage system, pumps Treatment facilities Subregional pipelines Subregional evaporations ponds Salt accumulation areas Priority Area 3 (PS3) high salinity 2a 2b PS3 High TDS Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone salt mitigation 2a. Design brine management plan 2b. Construction 2c. Operation Extraction wells, drainage system, pumps Treatment facilities Subregional pipelines Subregional evaporations ponds Salt accumulation areas Priority Area 3 (PS3) high salinity 2a 2b 2c 5

16 PS3 High TDS Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone salt mitigation 3. Aquifer Restoration: Determine commitment to the design, construction, operations and maintenance of the CV Brine Line (certain management zones) Environmental/permitting Design Brine line construction: interceptor and laterals Pump stations Priority Area 3 (PS3) high salinity 2a 2b 3 2c PS3 High TDS Priority Area. User Protection: Provide alternative drinking water sources 2. Sustainability: Management zone salt mitigation 3. Restoration: Commitment to the design, construction, operations and maintenance of the CV Brine Line (certain management zones) 4. Additional projects/new technology, as needed. Priority Area 3 (PS3) high salinity 2a 2b 3 4 2c 6

17 POI Outside of Priority Areas Elements may include: Irrigated Lands Regulatory Program Best Management Practices (BMPs) and Outreach and Education Livestock Operations BMPs and Outreach and Education POTWs and Food Processing Facilities Reductions in effluent concentrations through WDRs Onsite Wastewater Treatment Systems Implementation of 203 OWTS policy Leaking Sewer Pipes Infrastructure rehabilitation. Strategic Land Retirement Field Tile Drains Priority Area 3 (PS3) high salinity Priority Area (PN) high nitrate Priority Area 2 (PN2) high nitrate, localized issue, e.g., POTW 33 Conceptual Management Zone Proposal Chapter Proposal to Establish Management Zone ) Delineation 2) Governance 3) Characterization 4) Prioritization 5) Program of Implementation (Local SNMP) including monitoring & renewal 6) Supplemental Documentation Supporting Documentation Antidegradation analysis CEQA checklist and SED Alternatives analysis Economic analysis 34 7

18 Example of an Overall Phased Program of Implementation Phase First 0 years of implementation Establish Local SNMP Meet user protection goal within first 3 to 5 years Establish and implement first iteration of a POI that addresses sustainability and managed restoration goals Phase 2 Second 0 years Update Local SNMP Evaluate progress towards attainment of WQOs Adaptive management revise POI as needed to address sustainability and managed restoration goals Phase 3 and following Phase 3 and following: Increased focus on long term strategy achieve sustainability and restoration 35 Cascading Deliverables within Phases Phase Example Phase First 0 years of implementation Establish Local SNMP for MZ or individually Meet user protection goal within first 3 years of local SNMP implementation Establish first iteration of a POI that addresses sustainability and managed aquifer restoration goals Potential Phase Deliverables MZ Delineation and Governance Plan by Year 2 Characterization of findings and outcome of prioritization analysis by Year 3 Local SNMP with POI and progress towards attainment demonstration by Year 4 POI deliverables, as defined by Local SNMP, e.g., meet user protection goal (if applicable) through Year 0 to be implemented upon CV Water Board approval 36 8

19 Policy Questions for Discussion. What should the trigger be to determine an implementation approach (individual vs. MZ) and initiate Phase to develop the local SNMP? (a) Approved Basin Plan Amendment (b) WDR renewal 2. Is there a general consensus on the basic illustrated steps to develop a local SNMP delineation, governance, prioritization, POI 3. When developing a POI and demonstrating that the POI will make progress towards attainment of objectives, should our focus be: (a) Solely on meeting the water quality objective, e.g., < 0 mg/l nitrate (b) Achieving better than the WQO, e.g., to create assimilative capacity (c) Both, e.g., establishment of primary and secondary goals 4. Is there consensus to use 000 mg/l as the attainment goal for TDS? 37 Policy Questions for Discussion 5. What is reasonable timeframe for completion of the (a) initial phase; (b) subsequent phases? 0 years, other? 6. Is there general consensus on framing the POI around these three goals considering both short and long term strategies: (a) User protection safe water supply (b) Sustainability achieve mass balance of inputs and outputs (c) Managed aquifer restoration 38 9

20 Next Steps Take your comments from today Receive any additional written comments on framework by December 4 Prepare draft SSALTS and NIMS implementation sections Write in format and style that can be inserted into SNMP Bring framework back to you in a written form NIMS Report Phase 3 SSALTS Report Portion of SNMP Section 8 39 Questions? 40 20

21 SQ Mile 2 SQ Mile 4 SQ Mile 6 SQ Mile 8 SQ Mile 9 SQ Mile 0 SQ Mile 2 SQ Mile 4 SQ Mile 6 SQ Mile SQ Mile 2 SQ Mile 4 SQ Mile 6 SQ Mile 8 SQ Mile 9 SQ Mile 0 SQ Mile 2 SQ Mile 4 SQ Mile 6 SQ Mile 2

22 43 WDR Implementation Language Example of WDR language from MS4 Permit regarding preparation of a TMDL Implementation Plan: The Permittees may submit the plan individually, jointly or through a collaborative effort with other urban dischargers such as the existing MSAR TMDL Task Force (San Bernardino County MS4 Permit) Potential use of similar language to implement SNMP through WDRs: The Permittee may submit a Local SNMP individually or through a collaborative effort with other dischargers such as through the establishment of a Management Zone