P&O Study Workplan Development

Transcription

1 P&O Study Workplan Development CV SALTS Executive Committee Meeting February 21, 2019 Richard Meyerhoff, GEI Consultants Tom Grovhoug, Larry Walker Associates Joe LeClaire, LeClaire & Associates 1 KEY AREAS OF WORKPLAN Programmatic Tasks Stakeholder Process (e.g., Exec. Comm., TAC, workplan management) Governance and Funding Plans (Phase I and Phases II/III) Basin Plan Recommendations Reporting Physical Projects Development of alternatives to achieve sustainability within Salt Management Regions Selection of preferred alternative and conceptual design of selected preferred projects Non Physical Projects Special Studies (as defined in Basin Plan Amendment) 2 2 1

2 P&O STUDY WORKPLAN STATUS REPORT Previous Discussions November 15 Executive Committee Meeting January 10 Executive Committee Meeting Key issue discussed to date is the overall framework/approach for the identification of physical projects for implementation after Phase I Currently drafting physical project approach Primary focus for today is non physical projects 3 3 WORKPLAN FRAMEWORK Overall Framework for Workplan Presented at January 10 Executive Committee Meeting 4 4 2

3 ORGANIZING FRAMEWORK Salt Management Region Concept Presented at January 10 Executive Committee Meeting

4 DEFINITION OF NON-PHYSICAL PROJECTS Non Physical Projects Policies, regulations, guidelines, management practices, procedures, etc. that may have an effect on how salt and water are managed, e.g., Modified or new regulations Best Management Practices (BMPs) by sector Implementation of new salinity management practices and source control activities Long term salinity permitting approach 7 7 AGR PROTECTION CV-SALTS BACKGROUND Through May 2016 CV SALTS worked on an AGR Policy that included: Classification of groundwater basins/subbasins into default AGR classes based on existing ambient water quality in the Production Zone Policy included four AGR classes, each with a narrative water quality objective Policy included an approach, consistent with implementation of the Antidegradation Policy, for translating the narrative objective into effluent limits based on local conditions Mechanism included to potentially revise default classifications on a site specific basis 8 8 4

5 ORIGINAL PROPOSED AGR CLASSIFICATIONS AGR Class Class 1 Class 2 Class 3 Water Quality Range (EC or TDS) EC < 1,000 µs/cm (TDS < 600 mg/l) 1,000 μs/cm < EC < 3,000 μs/cm (600 mg/l < TDS < 2,000 mg/l) 3,000 μs/cm < EC < 7,500 μs/cm (2,000 mg/l < TDS < 5,000 mg/l) Quality in the Production Zone Generally suitable for irrigating all crops and all stock watering. Presumption rebuttable on a case by case basis; burden of proof falls on those claiming EC levels at or below 1,000 µs/cm do not provide reasonable protection of existing AGR uses and that a site specific EC is needed Generally acceptable for stock watering and for irrigating most salttolerant crops; not generally suitable for irrigating many salt sensitive crops, except as a temporary, short term alternative when higher quality water supplies are not readily available Generally acceptable for stock watering but is not generally suitable for irrigating all but the most salt tolerant crops, except as a temporary, short term alternative when higher water quality water supplies are not readily available. Class 4 EC > 7,500 μs/cm (TDS > 5,000 mg/l) Not suitable for either stock watering or crop irrigation uses unless blended with lower salinity water. Areas within this classification should be considered for AGR de designation. 9 9 AGR PROTECTION CV-SALTS BACKGROUND June 2016 Because of technical/policy questions, CV SALTS shifted to development of a Salt Management Strategy that included the three phased approach, beginning with the P&O Study Salt & Nitrate Management Plan still included an AGR Policy (Attachment A 5) with the following recommendation: It is recommended the proposed assignment of the default AGR threshold classes for EC/TDS be deferred at this time to provide opportunity to consider the findings from implementation of the [P&O Study]. If the recommended AGR classes and their threshold ranges remain appropriate based on Phase I findings, the inclusion of these AGR Classes and the assignment of classes to groundwater basins/subbasin will be considered through a future Basin Plan amendment process

6 AGR PROTECTION SALT MANAGEMENT STRATEGY Salt Control Program Conservative Permitting Approach relies on 700 µs/cm (monthly average) as the basis for establishing an effluent limit for the protection of AGR Only applicable to dischargers that do not participate in the P&O Study through selection of the Alternative Permitting Approach Relevant P&O Study Deliverables Basin Plan Amendment Recommendations (by Year 9): Facilitate implementation of Phase II of the Salt Control Program Consider extension of salinity variance and revision of salinity exception policies As appropriate, modify the Salinity Permitting Approaches Establish guidelines for the protection of salt sensitive crops impacts of state and federal policies and programs ALTERNATIVE APPROACH TO AGR PROTECTION LOWER SAN JOAQUIN RIVER Parallel to the development of the SNMP was the establishment of the salinity related Basin Plan Amendment in the Lower San Joaquin River (LSJR) LSJR used a watershed based approach to ensure protection of the AGR use Established salinity water quality objectives for the LSJR

7 LSJR OVERVIEW METHODOLOGY FOR SALINITY WQO DEVELOPMENT Determined Existing Baseline WQ conditions under varying water years Determined most sensitive significant crop irrigated from LSJR (almonds) Ran Hoffman Model to establish range of AGR criteria to protect almonds Developed modeling tool to predict surface water quality Developed range of management scenarios (planned, plausible, extreme) Used modeling tool to predict LSJR water quality under different scenarios Informed by above, selected preferred AGR criteria in close communication with agricultural stakeholders Adopted as site specific water quality objectives in Basin Plan LSJR APPROACH - KEY CONSIDERATIONS Balance between desired supply quality and agricultural runoff constraints Higher salinity water can be managed better than no water Developed different (less restrictive) objectives applicable during extended dry period conditions Extended dry period includes drought period plus year following

8 ADDITIONAL CONSIDERATION: EPA COMMENTS ON CV-SALTS BASIN PLAN AMENDMENT EPA requested clarification of the use of 700/900 µs/cm EC values used to establish NPDES effluent limits to protect AGR/MUN, respectively, under the "Conservative Permitting Approach Responsive argument includes: An outcome of the P&O study will be development of appropriate salinity based effluent limits, derived using a consistent and transparent process. Given the time needed to develop this translation process, the Regional Board is applying the values applicable to the Conservative Permitting Approach while appropriate methods and procedures are being developed QUESTION: WHAT SHOULD BE FOCUS OF THE P&O STUDY WORKPLAN? Options to consider for inclusion in the Workplan: Dust off the original AGR Policy work and conduct work needed to assign AGR classes to Central Valley groundwater basins/ subbasins Should we also develop classification for protection of surface water (not originally addressed in AGR Policy)? Continue development of the LSJR approach for use outside of the LSJR watershed Hybrid approach, e.g., establish the classes as a default, but develop procedures to translate the narrative objective into appropriate effluent limits

9 IMPACTS OF STATE AND FEDERAL POLICIES AND PROGRAMS Purpose: Identify conflicts or impediments to implementation of potential salt management strategies and develop recommendations to resolve where possible Information will provide input to the evaluation of alternatives/scenario planning within and between salt management regions Question: Other areas of investigation to include? Potential Areas of Investigation Federal and State law and regulations applicable to water/salt management Agency responsibilities for water and/or salt management planning (federal, state, regional, county, local, etc.), including SGMA Water rights/water management Balancing beneficial use protection, including instream flow and fisheries protection requirements Stormwater recharge targets Recycled water use Water conservation requirements Impediments to salt storage/disposal INCLUSION OF BORON PROJECTS IN THE WORKPLAN CV SALTS Staff Report states: No additional studies have been conducted to determine appropriate interim limits for boron under drought or conservation/reuse conditions. Therefore, it is inappropriate at this time to include boron in the proposed policy Question 1: What other areas should be targeted for boron evaluation? Question 2: What technical work is needed (e.g., repeat previous CV SALTS tasks completed for EC/TDS including data characterization, mapping, conceptual modeling, etc.)

10 INCLUSION OF OTHER CONSTITUENTS IN THE WORKPLAN Other Salt Related Constituents Question: Should the Workplan include studies on other salinityrelated constituents, e.g., chlorides, to provide the technical basis for their management under a Salt Control Program? SMCL related Constituents Question: Should the Workplan include studies that characterize SMCLs other than EC/TDS or salts that may be captured in the question above? TOOLS TO EVALUATE SALT MANAGEMENT SCENARIOS Planning to include in the Workplan the development of tool(s) that would be used to address valley wide strategies, identify benefits of various salt management scenarios, and evaluate the net salt balance for Salt Management Regions expected to result from implementation of proposed alternatives. Key considerations for development of scenario planning tools include: Expected benefits from implementation of physical and non physical projects Physical projects include both existing/planned projects and potential future projects Potential future projects would include both those within and between Salt Management Regions Tool should have ability to evaluate and optimize key project elements, e.g., minimization of groundwater extraction rates, numbers/location of wells, location of infrastructure, costs, energy needs, etc. Optimization focuses on minimization of anticipated salt sustainability gap Question: Any other key considerations that should be included in development of scenario planning tools?

11 DETERMINING BEST TIMING FOR NON-PHYSICAL PROJECTS & STUDIES/TOOL DEVELOPMENT Non Physical Projects Physical Projects Special Studies/Tool Development Interim Report Non Physical Projects Physical Projects Special Studies/Tool Development Basin Plan Recommendations Final Report Our goal in the Workplan is to spread the work out as evenly as possible over time to manage annual costs, e.g. no need to create tools until you need them Question Are there any non physical projects that you were expecting would be completed under the P&O Study that you anticipated would be completed earlier vs. later? NEXT STEPS Provide any additional comments on the topics/questions discussed today by COB March 8. Team has initiated preparation of draft sections of Workplan; will be developing initial cost estimates for key tasks Plan to bring back initial sections for review prior to next CV SALTS meeting in March

12 Additional Discussion?

13 AGR Protection Approach We discussed options for establishing a basis for AGR protection in the future. The range of options presented included (a) working with the original AGR Policy approach to establish default classes for groundwater basins/subbasins; (b) using the approach developed specifically for the Lower San Joaquin River watershed and apply it elsewhere in the Central Valley; and (c) a hybrid approach that could include establishing both default narrative criteria (within specified areas) and a methodology to translate the narrative criteria on a local/sub-regional basis for the purpose of establishing effluent limits. There may be other approaches. Question: Do you have any additional comments to supplement Thursday s Executive Committee discussion? Impacts of State and Federal Policies and Programs on Salt Management Workplan will include a task to identify conflicts or impediments to implementation of potential salt management strategies and develop recommendations to resolve them where possible. We provided an example list of areas to be investigated as part of this activity: (a) federal and state law and regulations applicable to water/salt management; (b) agency responsibilities for water and/or salt management planning (federal, state, regional, county, local, etc.), including SGMA; (c) water rights/water management; (d) balancing beneficial use protection, including instream flow and fisheries protection requirements; (e) stormwater recharge targets; (f) recycled water use; (g) water conservation requirements; and (h) impediments to salt storage/disposal. Question: Do you have other specific areas to recommend for investigation not covered in the above list? Request: To help frame the task, it would be helpful to have a few key examples of where conflicts currently exist. Please submit a brief description of such an example. Boron CV-SALTS Staff Report states: No additional studies have been conducted to determine appropriate interim limits for boron under drought or conservation/reuse conditions. Therefore, it is inappropriate at this time to include boron in the proposed policy. The Staff Report indicates that this issue could be considered further under the P&O Study. Question 1: Are there other areas of investigation that should be targeted for boron? Question 2: From your perspective, what technical work is needed to support management decisions for boron (e.g., data characterization, mapping, conceptual modeling)? Other Salt-Related Constituents Question: Should the Workplan include studies on other specific salinity-related constituents, e.g., chlorides, to provide the technical basis for their management under a Salt Control Program? PO Study Workplan_Information Request_ Docx