Draft Quagga Mussel Monitoring and Control Plan Lake Piru, California October United Water Conservation District

Transcription

1 Draft Quagga Mussel Monitoring and Control Plan Lake Piru, California October 2017 United Water Conservation District

2 Table of Contents Table of Contents Executive Summary Introduction and Background Geographic Setting Overview of Lake Piru, Santa Felicia Dam, and Associated Infrastructure and Operations Lake Piru, Santa Felicia Dam, and Associated Infrastructure Water Releases and Spill Events Recreation Overview of Quagga Mussel Infestation Future Colonization Potential Overview of Containment and Control Measures to Date Systematic Monitoring Program Monitoring Methods Water Quality Dive Surveys Veliger Sampling Natural Substrate Sampling Artificial Substrate Sampling Data Management, Analysis, and Reporting Containment Measures Containment Goals Water Vessels, Equipment, and Vehicles Recreational Vessels Shoreline Fishing United Equipment and Vehicles Firefighting Equipment and Vehicles Quagga Mussel Transference to Lower Piru Creek Water Release and Mechanism Analyses Surface Water Deliveries Control Measures Mechanical and Physical Control Water Level Management Mechanical Scraping Chemical Control Adaptive Management and Reporting Constraints on Changing Containment and Control Actions Technical Advisory Committee and Regional Working Group...40 Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page i

3 Table of Contents 5.3 Decision-Making Process References...42 Appendices Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K Applicable Federal, State, and Local Regulatory, Planning, and Permitting Requirements Plankton Tow Monitoring Protocol Alternative Containment and Control Measures Considered Infeasible Examples of Education Materials Lake Piru Recreation Area Vessel Inspection Checklist Standard Operating Procedures - Invasive Species Boat Inspection and Equipment Decontamination Memorandum of Understanding Between United and Ventura County Fire Protection District United Request for Concurrence for Temporary Suspension of Migration Releases from Lake Piru dated December 2, 2016 NMFS Response to United Request for Concurrence for Temporary Suspension of Migration Releases from Lake Piru dated December 2, 2016 Lake Piru Hydrodynamic Model for a Lake Level Management Strategy Molluscicide Treatment Study Tables Table 1. Goals, Objectives, and Management Actions...5 Table 2. Dreissenid Infestation Thresholds and Conditions in Lake Piru...16 Table 3. Summary of Monitoring Activities, Frequency, and Location...22 Table 4. Summary of Points of Transference to Lower Piru Creek and Operations to Maximize Shear Stress...34 Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page ii

4 Figures Table of Contents Figure 1. Geographic Setting...8 Figure 2. Santa Felicia Dam...9 Figure 3. United Water Conservation District Boundary, Infrastructure, Facilities, and Relevant Groundwater Basins...10 Figure 4. Water Exiting the Tailrace of the Hydroelectric Plant into the Release Pool...11 Figure 5. Water Releases through the West Low-Flow Valve into the Release Pool...11 Figure 6. Quagga Mussel Infestation Delineation Map as of October Figure 7. IPM Pyramid...18 Figure 8. Monitoring and Control Locations in Lake Piru Figure 9. Monitoring and Control Locations Downstream of Lake Piru...21 Figure 10. Population Assessment Sampling...23 Figure 11 Plankton Tow...24 Figure 12. United Vessel Tags...29 Figure 12. Lake Level Management Conceptual Framework...37 Figure 13. Percent Mortality over Time at Three Concentrations of Copper and Three Treatment Temperatures 39 Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page iii

5 Executive Summary Executive Summary Quagga mussels (Dreissena rostriformis bugensis) were discovered in Lake Piru, Ventura County, California on December 18, The mussels were found in the Cow Cove area of the lake. Following discovery, United Water Conservation District (United) staff collected samples of the quagga mussels and contacted the California Department of Fish and Wildlife (CDFW). The collected samples were sent for analysis to the CDFW Shellfish Health Laboratory, Bodega Marine Lab. Testing confirmed that the samples were quagga mussels; and, subsequently, United notified CDFW, the California Department of Water Resources (DWR), and operators of nearby surface water reservoirs. This Quagga Mussel Monitoring and Control Plan (Plan) has been prepared by United to comply with State of California requirements under California Fish and Game Code (FGC) The Plan has been developed in consultation and coordination with CDFW, the Federal Energy Regulatory Commission (FERC), the National Marine Fisheries Service (NMFS), and other relevant stakeholders. Specifically, FGC 2301(d)(1) requires that the Plan address: A. Methods for delineation of infestation, including both adult quagga mussels and veligers (the larval form of quagga mussels) B. Methods for control or eradication of adult quagga mussels and decontamination of water containing larval mussels C. A systematic monitoring program to determine any changes in conditions D. The operator of the water supply system permits inspections by CDFW as well as cooperates with CDFW to update or revise control or eradication measures in the approved plan to address scientific advances in the methods of controlling or eradicating quagga mussels and veligers To address these elements, United has established the following goals as outlined in this Plan: 1. Implement a systematic monitoring program to delineate the quagga mussel infestation and measure the spread of the infestation within Lake Piru and downstream areas to address FGC 2301(d)(1)(A) and (C) 2. Implement containment measures to minimize the spread of quagga mussels to other water bodies outside of Lake Piru to address FGC 2301(d)(1)(B) 3. Control the quagga mussel population within Lake Piru and lower Piru Creek to minimize environmental and operational effects to address FGC 2301(d)(1)(B) 4. Work with CDFW and other relevant parties to adaptively manage the quagga mussel infestation and modify the Plan when appropriate to address FGC 2301 (d)(1)(d) Since the discovery of quagga mussels in 2013, United has researched, developed, tested, and implemented various monitoring, containment, and control measures to delineate, characterize, and address the infestation. The monitoring activities have included water quality sampling, dive surveys, the use of settling substrates, veliger sampling, and streambed surveys to assess the current extent of the infestation and better understand the potential for quagga mussels to spread to other parts of the Piru Creek and Santa Clara River watersheds. Currently, adult mussels and veligers have been observed throughout Lake Piru with hotspots in the northeast and southeast parts of the lake Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 1

6 Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 2 Executive Summary and on human-made infrastructure (i.e., the floating docks, the intake barge for potable water, and the intake structure for the dam), and along lower Piru Creek in the reach situated between the dam release pool downstream to United s property boundary with Rancho Temescal. In addition, adult quagga mussels have been detected along the United-owned reach of lower Piru Creek 0.25 miles upstream of the confluence with Santa Clara River. Along the Santa Clara River, a single adult quagga mussel was detected on a vertical abutment of the Torrey Road Bridge in Fillmore, California on August 23, 2017, and no other mussels have been detected at this location since. Similarly adult quagga mussels were detected on vertical abutments of the 12 th Street Bridge in Santa Paula, California. A summary of the monitoring activities conducted to date is provided in Section 1.3, and a detailed discussion of the monitoring measures including methods, frequency, and reporting is provided in Section 2. United's approach consists of using the integrated pest management (IPM) framework to guide monitoring, containment and control efforts. Containment and control measures consist of cultural, mechanical, physical, and chemical measures. United s cultural containment measures involve inspection, tracking, and tagging of recreational vessels in cooperation with other water management entities; public education; and, law enforcement. Mechanical and physical containment measures include United recommissioning Turbine Unit 1 in December 2016 to exert lethal shear stress on veligers during the release of water from Lake Piru to Piru Creek through the dam. United also conducted a study to evaluate the shear stresses associated with the water release infrastructure for various release scenarios and will be implementing releases to maximize lethal shear stress on veligers as much as possible to minimize transfer of viable veligers downstream. In addition, United has worked with stakeholders that receive surface water deliveries from the Freeman Diversion to develop an approach to ensure that quagga mussels are not transferred to stakeholder infrastructure. The approach involves infiltrating surface water deliveries through the Saticoy groundwater recharge basins which will effectively serve as sand filters to remove quagga mussel veligers as the water percolates through the basins. The water will then be pumped out of the groundwater basins using an expanded Saticoy well field. A summary of the containment activities conducted to date is provided in Section 1.5, and a detailed discussion of the ongoing and planned containment measures is provided in Section 3. Mechanical and physical control measures include contracting professional divers to perform mechanical scraping of human-made infrastructure in Lake Piru at least four times a year. United is currently developing a Lake Piru Hydrodynamic and Quagga Population Model to optimize release scenarios and develop a lake level management strategy with the objective of maximizing the mortality of quagga mussels. The model is scheduled to be completed by April Chemical containment and control measures include decontaminating equipment that has come into contact with infested water as well as treatment with a molluscicide to control the population. Following a successful pilot study, United is proceeding with the planning and permitting process to treat Lake Piru with a copper sulfate pentahydrate formulation registered under EarthTecQZ to broadly address the current quagga mussel population in Lake Piru. A summary of the control activities conducted to date is provided in Section 1.5, and a detailed discussion of the ongoing and planned control measures is provided in Section 4. United will implement adaptive management as a decision-making process to identify appropriate changes in control, containment, and monitoring actions. Information collected during implementation of this Plan will be assessed annually and used to inform and guide appropriate

7 Executive Summary changes to the Plan, if necessary, to ensure achievement of the goals. Existing monitoring, containment, and control actions will be modified as needed based on collected data and/or incidents involving the potential transfer of mussels out of the area. In addition to the data collected as part of this Plan, any contemplated changes to the Plan will also consider factors associated with the overall purpose and need of the Santa Felicia Project and its operations. To support the adaptive management process, United has formed a Technical Advisory Committee comprised of representatives from CDFW, NMFS, the U.S. Fish and Wildlife Service (USFWS), U.S. Department of Agriculture Forest Service, County of Ventura Agricultural Commissioner, and California Sea Grant. The Committee is assisting United in reviewing collected data, evaluating the effectiveness of the proposed containment, control, and monitoring measures, and, if warranted, developing alternative strategies for addressing the infestation. As part of the annual reporting process, United will submit any proposed modifications to the Plan for CDFW review and approval prior to implementation. The adaptive management process is discussed further in Section 5. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 3

8 1 Introduction and Background Section 1 Introduction and Background Quagga mussels (Dreissena rostriformis bugensis) were discovered in Lake Piru, Ventura County, California on December 18, Accordingly, this Quagga Mussel Monitoring and Control Plan (Plan) has been prepared by United Water Conservation District (United) to comply with State of California requirements under California Fish and Game Code (FGC) The Plan has been developed in consultation and coordination with the California Department of Fish and Wildlife (CDFW), the Federal Energy Regulatory Commission (FERC), the National Marine Fisheries Service (NMFS), and other relevant stakeholders. In addition to FGC 2301, various federal, state, and local laws/ordinances pertain to monitoring, containing, and controlling quagga mussels, and a summary of these additional requirements is provided in Appendix A. Specifically, FGC 2301 (d)(1) requires that the Plan address the following four elements: A. Methods for delineation of infestation, including both adult quagga mussels and veligers B. Methods for control or eradication of adult quagga mussels and decontamination of water containing larval mussels C. A systematic monitoring program to determine any changes in conditions D. The operator of the water supply system permits inspections by CDFW as well as cooperates with CDFW to update or revise control or eradication measures in the approved plan to address scientific advances in the methods of controlling or eradicating mussels and veligers These elements and United s associated goals are discussed below as well as background information on the geographic setting for Lake Piru, United s infrastructure and operations, the quagga mussel infestation, and the monitoring and control activities that have been conducted to date. To address the four elements required by FGC 2301 (d)(1), United has established the following goals: 1. Implement a systematic monitoring program to delineate the quagga mussel infestation and determine any changes in conditions to address FGC 2301(d)(1)(A) and (C) 2. Implement containment measures to minimize the spread of quagga mussels to other water bodies outside of Lake Piru to address FGC 2301(d)(1)(B) 3. Control the quagga mussel population within Lake Piru and lower Piru Creek to minimize environmental and operational effects to address FGC 2301(d)(1)(B) 4. Work with CDFW and other relevant parties to adaptively manage the quagga mussel infestation and modify the Plan when appropriate to address FGC 2301 (d)(1)(d) These goals, supporting objectives, and a summary of the management actions that have been or will be implemented to achieve these goals are summarized in Table 1. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 4

9 Table 1. Goals, Objectives, and Management Actions Goal Supporting Objective Management Actions Section 1 Introduction and Background 1. Implement a systematic monitoring program to delineate the quagga mussel infestation and determine any changes in conditions 1.1 Delineate the infestation in Lake Piru, lower Piru Creek, the spillway pool, and the Santa Clara River 1.2 Track the environmental factors that trigger and support spawning events in relation to the spread of the infestation Dive surveys to quantify adult abundance in Lake Piru Streambed surveys to quantify adult abundance in lower Piru Creek and the Santa Clara River Veliger sampling to quantify veliger abundance in Lake Piru, the spillway pool, and lower Piru Creek Monitoring of settling substrates to quantify pediveliger settling rates in Lake Piru, the spillway pool, and lower Piru Creek Water quality monitoring in Lake Piru, the spillway pool, and lower Piru Creek Veliger sampling to quantify how veliger abundance changes over time with respect to season and water quality in Lake Piru, the spillway pool, and lower Piru Creek Monitoring of settling substrates to quantify how pediveliger settling rate changes over time with respect to season and water quality in Lake Piru, the spillway pool, and lower Piru Creek 1.3 Evaluate and improve monitoring methods Continuous improvement of monitoring methods by reviewing and analyzing collected data and through consultation and coordination with various regulatory agencies, water resource agencies, and technical experts 2. Implement containment measures to minimize the spread of quagga mussels to other water bodies outside of Lake Piru 3. Control the quagga mussel population within Lake Piru and lower Piru Creek to minimize environmental and operational effects 4. Work with CDFW and other relevant parties to adaptively manage the quagga mussel infestation and modify the Plan when appropriate 1.4 Streamline data management and reporting to inform other water resource managers 2.1 Minimize/eliminate transfer of mussels through water vessels, equipment, of vehicles 2.2 Minimize transfer of mussels from Lake Piru to lower Piru Creek through water releases or spills 3.1 Remove quagga mussels from the lake and from infrastructure 4.1 Update the technical advisory committee, CDFW, FERC, NMFS, stakeholders, and other relevant parties Maintain and update database with collected data, analyze data in a timely manner, and provide data to other interested and relevant water resource managers Public education program Vessel inspection and decontamination program Tracking vessels using the Quagga Inspection Database (QID) Vessel tagging (voluntary) Vessel, vehicle, and equipment decontamination Law enforcement Memorandums of understanding with firefighting entities Infrastructure enhancement to maximize veliger mortality from shear stress Strategic water release planning Mechanical scraping Lake level management Molluscicide treatment Annual report and consultation under an adaptive management framework Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 5

10 1.1 Geographic Setting Section 1 Introduction and Background Piru Creek is a tributary to the Santa Clara River (Figure 1). The Piru Creek watershed encompasses approximately 500 square miles. The majority of the watershed is situated within Ventura County with smaller portions in Los Angeles and Kern Counties. The watershed has a Mediterranean climate, with variable wet winters and hot, dry summers. The majority of precipitation falls during the winter months, generally between October and April. The average annual precipitation at Lake Piru is 19.8 inches (in) per year. Steep-sided canyons provide the watershed with substantial topographic relief. Elevations within the watershed range from 8,831 feet (ft) mean sea level (msl) at the summit of Mount Pinos to approximately 647 ft msl at the confluence with the Santa Clara River near the town of Piru, California. Land use within the watershed consists of urban, agricultural, and open space. The lower portion of Piru Creek is downstream of Lake Piru and consists of a relatively low gradient, broad alluvial valley surrounded by agricultural land use. Lower Piru Creek has been altered from an intermittent drainage to a perennial drainage by sustained base flows from Lake Piru through Santa Felicia Dam (see Section 1.3.2). Major tributaries below Lake Piru include Modelo Canyon, Holser Canyon, Lime Canyon, Blanchard Canyon, and five unnamed tributaries. The hydrology of the Santa Clara River is characterized as flashy with infrequent, high-flow events during the wet season that increase, peak, and subside rapidly in response to high intensity rainfall. During the dry summer season, flows are intermittent or non-existent, depending primarily on areas of rising groundwater or inflows from dam releases or other anthropogenic sources. Groundwater discharges to the mainstem river occur when groundwater levels are high and the water table is close to the surface. Three geologic features are important to surface water groundwater interactions along the Santa Clara River: 1) Soledad Canyon; 2) the Piru narrows; and, 3) the Fillmore narrows. In these locations, constrictions in the width of unconsolidated deposits combined with subsurface bedrock controls cause groundwater to rise and discharge to the river, depending on groundwater levels and surface flow conditions (URS 2005, Kennedy/Jenks 2008). In areas outside of these bedrock controls, surface flow is lost through the highly permeable bed materials to groundwater. 1.2 Overview of Lake Piru, Santa Felicia Dam, and Associated Infrastructure and Operations Lake Piru, Santa Felicia Dam, and Associated Infrastructure The Lake Piru reservoir is formed by Santa Felicia Dam (Figure 2) which was built as part of the Santa Felicia Project (Project) in The earth-filled dam was constructed on lower Piru Creek approximately 6.2 miles upstream of the confluence with the Santa Clara River. The dam measures 200 ft high and 1,260 ft long. Lake Piru had an original maximum capacity of 101,225 acre-feet (AF). However, in 2015, the maximum capacity was estimated to be 81,986 AF. The primary purpose and need for the Project is the recharge of the collective groundwater basins below Lake Piru and Santa Felicia Dam and within United s boundary (Figure 3). As such, the Project is a critical component in maintaining sustainable water resources for the Santa Clara River Valley and coastal areas of Ventura County. These water resources contribute to support a relatively prosperous and diverse economy with a population of over 350,000 and agricultural production upwards of $2 billion per year (Ventura County 2016). The Project also provides power generation, recreational benefits, and wildlife conservation. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 6

11 Section 1 Introduction and Background United manages Lake Piru and the Santa Felicia Dam in conjunction with other facilities (Figure 3), including United s Freeman Diversion, to recharge groundwater basins along the Santa Clara River. United also supplies surface water to offset groundwater pumping. Groundwater replenishment through surface infiltration and surface water delivery aid ground water dependent municipalities and farmers by preventing overdraft of groundwater basins, minimizing saltwater intrusion, and enhancing groundwater quality. United owns and operates the Freeman Diversion facility on the Santa Clara River. The Freeman Diversion is located approximately 40 miles downstream of the confluence of Piru Creek and the Santa Clara River (Figure 3). At the Freeman Diversion, United diverts surface water flow from the Santa Clara River. United delivers this diverted water to its various spreading grounds (Saticoy, El Rio, Noble, and Rose) (Figure 3) to replenish aquifers that support residential communities and agricultural operations along the Santa Clara River and the Oxnard Plain. The communities United serves are home to farms that produce a significant portion of America s fruits and vegetables. The agricultural industry alone represents $3.5 billion of Ventura County s economy and employs nearly 43,000 people. In addition, United can deliver this diverted water through its various pipelines (Pumping Trough, Pleasant Valley, Oxnard-Hueneme) to agricultural operations and municipalities as an alternative water supply to reduce groundwater pumping 1. Historically, United has made annual water releases, referred to as conservation releases, from Santa Felicia Dam so that the released water would recharge groundwater basins as it flows downstream and the remaining released water would be diverted at the Freeman Diversion for surface delivery or basin recharge. In addition to water storage and conveyance, Santa Felicia Dam provides hydroelectric power generation, and is, therefore, regulated by a license issued by FERC under the Federal Powers Act (FERC License No. P ). The hydroelectric generation facility consists of two, Francis-type turbines with 218 kilowatt (kw) (Unit 1) and 1,216 kw (Unit 2) generating capacity. The FERC license incorporates requirements contained in a biological opinion (BO) from the National Marine Fisheries Service (NMFS) that United must implement to minimize the effects of the Project on the endangered southern California steelhead (Oncorhynchus mykiss) population and its designated critical habitat in Piru Creek. Among these requirements is the development and implementation of a water release plan that ensures the magnitude, timing, frequency, duration, and rate-of-change of water releases accomplish the following biological goals: Provide unimpeded migration of adult and juvenile steelhead in Piru Creek downstream of Santa Felicia Dam and in the Santa Clara River from the confluence of Piru Creek downstream to the Freeman Diversion structure. Form and preserve freshwater rearing sites for steelhead throughout Piru Creek downstream of Santa Felicia Dam. Create and maintain freshwater spawning sites (including incubation and emergence life stages of steelhead) for steelhead throughout Piru Creek downstream of Santa Felicia Dam. In compliance with this requirement, United developed the Santa Felicia Water Release Plan which was approved by FERC and NMFS in 2012 (UWCD 2012). 1 United is the managing agency for the Saticoy, El Rio, Noble, Rose, and Ferro spreading grounds; the Santa Clara River Pumping Trough Pipeline; the Pleasant Valley Pipeline; and the Oxnard-Hueneme Pipeline. 2 A copy of the license can be found at: Dam/FERC/FERC_license.pdf Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 7

12 Section 1 Introduction and Background Figure 1. Geographic Setting Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 8

13 Section 1 Introduction and Background Figure 2. Santa Felicia Dam Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 9

14 Section 1 Introduction and Background Figure 3. United Water Conservation District Boundary, Infrastructure, Facilities, and Relevant Groundwater Basins Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 10

15 1.2.2 Water Releases and Spill Events Section 1 Introduction and Background Water releases from Santa Felicia Dam have the potential to transfer quagga mussels from Lake Piru to lower Piru Creek. These releases consist of controlled releases through the dam outlet works system and uncontrolled releases through the spillway channel during spill events (Figure 2). Controlled Water Releases through the Santa Felicia Dam Outlet Works Controlled water releases are conveyed through the outlet works system which consists of an intake tower in Lake Piru, a conduit to convey flows from the lake through Santa Felicia Dam, downstream control facilities, and the hydroelectric powerhouse. The outlet conduit is split into two sections: 1) a 66-inch diameter reinforced concrete pressure conduit; and, 2) a 60-inch diameter steel penstock within a reinforced concrete tunnel. The two sections are connected by a 72-inch diameter butterfly valve housed within a valve chamber. Controlled water releases through the Santa Felicia Dam outlet works are discharged to the release pool on lower Piru Creek. The downstream release points consist of: Two Hydroelectric Turbine Units that can be operated to convey water and generate electricity. The water is subsequently released into lower Piru Creek through the tailrace (Figure 4), which flows into the release pool. Turbine Unit 1 was recommissioned in December 2016 and can operate between 7 cubic feet per second (cfs) and 20 cfs when there is sufficient head pressure in the lake (i.e., when the surface water elevation in Lake Piru is between 980 and 1,028 feet above mean sea level). Turbine Unit 2 was recommissioned in March 2016 and can operate between 40 cfs and 87 cfs when there is sufficient head pressure in the lake (i.e., when the surface elevation in Lake Piru is between 980 and 1,055 feet above mean sea level), Two cone valves that can be operated independently or together. Each cone valve can release between 20 cfs and 500 cfs (the maximum release of 500 cfs is limited by flow through the penstock and the surface water elevation in Lake Piru which needs to be 1,055 feet above mean sea level or greater), and Two low-flow valves that have the capacity to discharge between 1 cfs and 10 cfs each and are primarily used during habitat water releases (between 7 and 20 cfs) and alternative water releases (5 cfs) during maintenance and inspection activities to ensure safe access to dam infrastructure. Figure 4. Water Exiting the Tailrace of the Hydroelectric Plant into the Release Pool Figure 5. Water Releases through the West Low-Flow Valve into the Release Pool Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 11

16 Section 1 Introduction and Background The controlled water releases consist of water releases for water resource management purposes (conservation releases) and minimum water releases required under United s FERC license (steelhead habitat and migration releases). The conservation releases are used for water supply and to recharge aquifers in the Santa Clara River Valley and the Oxnard Plain. Water is retained and stored in Lake Piru during the winter and spring months when downstream aquifers are at their fullest level. When the aquifers are at their lowest levels, typically in the late summer or fall, conservation releases are used to recharge the groundwater. These releases typically involve releasing 200 to 500 cfs of water through the cone valves to maximize the amount of water that reaches the Freeman Diversion for groundwater replenishment and some deliveries to coastal irrigators to minimize their groundwater pumping. United s highest priority for water diverted at the Freeman Diversion is for replenishment of nitrate-contaminated drinking water aquifers at United s El Rio Recharge Facility. United s El Rio Wellfield provides approximately 25% of the drinking water for the City of Oxnard, 80% of the drinking water for the Port Hueneme Water Agency, and 100% for the unincorporated El Rio community. During times of drought, when United is not able to provide recharge water to its El Rio Recharge Facility, nitrate levels in the drinking water aquifers rise to several times the maximum contaminant level. For this reason, United s Board of Directors has directed staff to maximize recharge to the El Rio Recharge Facility. The most recent standard conservation release was conducted in the fall of 2012, prior to the discovery of quagga mussels in Lake Piru. From 2013 to 2016, drought conditions resulted in low lake levels, precluding United from making conservation releases. However, with climate change resulting in more extreme and prolonged dry periods in southern California, United must consider alternative operations in the future for recharging groundwater when water quality threatens human health. In 2017, United took advantage of supplemental California State Water Project water under the Article 21 Program of the State Water Project contract to combat unsafe nitrate levels in the drinking water aquifers of the Oxnard Plain. The Article 21 supplemental water was available in spring 2017 only, due to State Water Project reservoirs being full. Consequently, United released stored State Water Project water from Lake Piru and the California Department of Water Resources released Article 21 water from Castaic Lake in spring 2017, in order to maximize the amount of water that would reach the El Rio Recharge Facility, in order to reduce high nitrate levels in the groundwater. United is also working with local agencies to maximize the use of recycled water within its service area, and to develop storm water capture and recharge projects, as well as exploring other options to decrease overdraft and combat salt water intrusion. The FERC license for the Santa Felicia Hydroelectric Project stipulates that United maintain certain minimum releases to lower Piru Creek to support endangered southern California steelhead. In compliance with the FERC license requirements, United developed the Santa Felicia Water Release Plan with the following minimum required water releases: A. Minimum habitat water releases between 7 cfs and 20 cfs based on cumulative rainfall, B. Minimum migration water releases of 200 cfs triggered by certain Santa Clara River flow criteria intended to provide steelhead migration opportunities, and C. Alternative operations water releases of 5 cfs to allow for periodic dam safety activities that require closure of the penstock for inspections, maintenance, and repairs. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 12

17 Uncontrolled Water Releases Spill Events Section 1 Introduction and Background The other mechanism for the potential transport of quagga mussels into lower Piru Creek is through uncontrolled spill events. The infrastructure of the lake and the manner in which United operates the facility are to provide for water resources and not flood control. Therefore, United does not control spill events. The spillway channel was constructed at 1,055 ft msl, and once the water surface elevation in the lake reaches the spillway elevation, water spills into lower Piru Creek. Spills continue until the water surface elevation recedes below the spillway elevation, mimicking the natural recession of flows entering the lake. United does not have control over these spill events. Historically, spills occur infrequently (approximately every 5 to 7 years on average) Recreation The FERC license for the Santa Felicia Project also requires that United provide recreational opportunities both in Lake Piru and lower Piru Creek as discussed below. Lake Piru Recreational activities at the lake include fishing, swimming, boating, waterskiing, wakeboarding, tubing, kayaking, and other activities common to inland waterways. Lake Piru is the only lake in Ventura County where body contact with the water is permitted. Lake Piru also hosts a number of bass fishing tournaments and special boating events each year. Depending on the water level, the lake has as many as four available boat launches; however, only two launches are typically in use at any given time. For safety purposes, all motorized vessels visiting the lake must meet the minimum size requirements of 12-feet in length and 42-inches in width with the exception of personal watercraft (PWC) such as jet-skis which are also allowed on the waters of Lake Piru. The only mechanism for maintaining a boat on the water for more than 24- hours is to rent one of the 66 available storage slips at the marina. Boats are not allowed to moor in the lake. All boats entering and exiting the marina are logged in and out by the concession service that manages the marina. Rental boats are also available at the marina and they are solely dedicated for use at Lake Piru. However, if a boat needs to leave the Lake Piru recreational area for maintenance or another unforeseen reason, then the vessel would be decontaminated using a highpressure, hot water decontamination procedure conducted by United staff using a trailer-mounted thermal pressure washing unit in accordance with CDFW Aquatic Invasive Species Decontamination Protocols (CDFW 2009). Lower Piru Creek In lower Piru Creek, United provides access for whitewater boating when flows are greater than 200 cfs. All parties intending to participate in whitewater activities in lower Piru Creek must pre-register with Lake Piru Recreation staff, and all vessels are required to undergo the pre- and post-launch protocol outlined in Section 3.2. United does not provide any equipment for whitewater rafting activities. Lake Piru Recreation staff are responsible for the registration and coordination of whitewater rafting activities. Fishing is prohibited in lower Piru Creek as it is designated critical habitat for southern California steelhead. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 13

18 1.3 Overview of Quagga Mussel Infestation Section 1 Introduction and Background Quagga mussels were first discovered by United staff in the Cow Cove area of Lake Piru on December 18, The mussels were observed approximately 200 feet west of the floating restroom on the 5-mile per hour (mph) buoy and three adjacent artificial mussel substrate monitoring lines. Following discovery, United staff collected samples of the quagga mussels and contacted CDFW. The collected samples were sent for analysis to the CDFW Shellfish Health Laboratory, Bodega Marine Lab. Testing confirmed that the samples were quagga mussels; and United notified CDFW, the DWR, and operators of nearby surface water reservoirs. Following discovery, United implemented a systematic monitoring program to delineate the infestation and to better understand the potential for mussels to spread to other parts of the watershed (see Section 2 Monitoring Program). United maintains an infestation delineation map that is updated in real time as new monitoring data become available (Figure 6). Water quality data suggest that Lake Piru can support the colonization of quagga mussels throughout all seasons (Table 2)(UWCD 2016 and UWCD 2017). Veligers, settled juveniles, and adult quagga mussels have been observed throughout Lake Piru. The highest concentrations of adult quagga mussels have been detected on rocks, debris, and human-made infrastructure (i.e. the floating docks, the intake barge for potable water, and the intake structure for the dam). Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 14

19 Section 1 Introduction and Background Figure 6. Quagga Mussel Infestation Delineation Map as of October 2017 Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 15

20 Section 1 Introduction and Background In the spillway pool, adult mussels have been detected on the vertical rock wall within the spillway pool and one adult quagga mussel has been detected on an artificial substrate plate, but veligers have not been detected in the spillway pool. The most likely explanation for these findings is that quagga mussels were introduced to the spillway pool from the outlet works release pool in a one-time event in October 2015 when water was bypassed to the spillway pool during an inspection of the intake tower. It is possible that veligers are not observed in the spillway pool because mussels are not successfully reproducing in the spillway pool; reproduction is too low to detect; and/or veligers are being consumed by predator species that are prevalent in the spillway pool (e.g., largemouth bass and bullfrogs). Table 2. Dreissenid Infestation Thresholds and Conditions in Lake Piru Parameter Dreissenid Infestation Thresholds Lake Piru Conditions Measured in 2015 and 2016 Are Lake Piru Conditions within Thresholds? Salinity <5 ng/l <5 ng/l Yes Calcium >25 mg/l mg/l 2 Yes ph Yes Substrates Prefer hard substrates but may be found on soft substrates Rock habitat & infrastructure (docks, buoy lines, anchors, floating barge) & silt Yes Depth in lake Surface to >120 m; Prefer depths <30 m 19.5 m currently 41 m maximum Yes Temperature-range for survival 5-30 C 1 Range: C Average: 18 C Yes Temperature- optimal for reproduction and growth Temperature-minimum for reproduction 16 C Range: C Average: 18 C 9 C 1 Range: C Average: 18 C Yes Yes (the majority of the year) Lethal Temperature C Range: C Average: 18 C Yes DO- minimum required for survival >2 mg/l mg/l 3 Yes (the majority of the time at most depths) Notes 1 Exact number is not known 2 Calcium range is from water quality testing done at Lake Piru Marina from 2005 to Range from thermocline monitoring at Lake Piru in Sources: Mills et al. 1996, Wright et al. 1996, Claxton and Mackie 1998, Cohen 2007, Culver et al. 2009, IRWD and SWD 2009, CNRA 2010, Culver et al. 2014, UWCD 2016, and UWCD Adult mussels, veligers, and settled juveniles have also been detected in lower Piru Creek in the reach situated between the dam release pool and United s property boundary with Rancho Temescal (Release Reach)(Figure 2). The data collected to date indicate that quagga mussel abundance decreases from upstream to downstream within this reach. Monitoring activities to date have not detected veligers along the United-owned reach of lower Piru Creek that is situated between the Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 16

21 Section 1 Introduction and Background confluence of the Santa Clara River to approximately 0.25 miles upstream (confluence). However, eighteen small (4-6 mm), adult quagga mussels were detected on cobbles (20 cobbles surveyed) at this location during United s monthly streambed survey on October 17, On August 23, 2017, adult quagga mussels were detected on vertical, concrete abutments of Torrey Road Bridge in Fillmore and on the 12 th Street Bridge in Santa Paula, California. However, veligers have not been detected anywhere along the main stem of the Santa Clara River. Also, adult quagga mussels have not been detected on any other substrate (e.g., cobbles, debris, trash, and fencing material) in the main stem of the Santa Clara River. Adult quagga mussels have not been detected on the concrete structures of the Freeman Diversion nor the settling plates deployed at the Freeman Diversion or the desilting basin. Veligers have also not been detected at the Freeman Diversion. United will contact CDFW Los Alamitos Field Office within 24 hours if there are new areas of infestation detected below the dam. Annual summaries of monitoring results are provided in the Quagga Mussel Monitoring and Control Annual Reports (UWCD 2016 and UWCD 2017). 1.4 Future Colonization Potential To date, quagga mussels have not been observed in the Santa Clara River downstream of the confluence year-round. Although a few mussels have grown to adults on the bridge abutments, the flashy hydrology characterized by infrequent, brief high-flow events during the wet season and low to no flows during the dry season are expected to limit the potential distribution of quagga mussels due to the potential of veliger mortality associated with turbulent flow (Horvath and Lamberti, 1999; Rehmann et., al., 2003; and, Horvath and Crane 2010); desiccation during periods when the majority of the river channel is dry; scouring events during high flows; and limited yearround freshwater habitat in the lower Santa Clara River. In addition, the region experiences periodic drought conditions that result in year-round dry conditions in much of the Santa Clara River, which would significantly limit potential quagga mussel populations due to desiccation. However, areas that remain wetted due to rising groundwater will remain a focus of future monitoring efforts to better understand to what extent these wetted areas can or cannot consistently support quagga mussel populations in the Santa Clara River. The colonization potential in the Santa Clara River estuary is anticipated to be low due to the water quality conditions. Specifically, quagga mussels do not survive in salinity greater than 6 ppt, and the estuary consists of brackish water year-round with salinity levels ranging between 1 and 37 ppt depending on location and season (City of Ventura 2011). Given the presence of quagga mussels in lower Piru Creek and the Santa Clara River, United will continue to monitor areas downstream of Lake Piru as outlined in Section 2 and will use this information to inform and guide appropriate changes to the Plan as described in Section 5. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 17

22 1.5 Overview of Containment and Control Measures to Date Section 1 Introduction and Background Since discovery of quagga mussels in December 2013, United has implemented monitoring, containment, and control measures under an integrated pest management (IPM) framework with the objective of effectively managing the quagga mussels in compliance with all relevant regulations (Appendix A) and in an economically feasible manner. The IPM framework consists of the selection and use of pest control actions that ensure acceptable economic, ecological and social consequences. The IPM process starts with monitoring, followed by the implementation of cultural, mechanical/physical, biological, and chemical containment and control measures (Figure 7). Under an IPM framework, more benign strategies (cultural and Figure 7. IPM Pyramid Source: Culver et al mechanical/physical measures) are preferentially employed first, because they do not pose substantial risk to the ecosystem and non-target organisms. Biological and chemical measures are also used in IPM but must be considered with more caution given potential impacts to human health and to non-target organisms, particularly special-status species protected under the federal endangered species act (ESA) and the California Endangered Species Act (CESA). United has implemented cultural, mechanical, physical, and mild chemical measures that are summarized below and are explained in more detail in the specific survey and control reports (Culver et. al. 2014; Ecomarine 2015a through 2015c; and, Ecomarine 2016a through 2016d) as well as the annual quagga mussel monitoring and control reports for 2015 and 2016 (UWCD 2016 and UWCD 2017). United s cultural containment measures involve inspection, tracking, and tagging of recreational vessels in cooperation with other water management entities; public education; and, law enforcement. United s mechanical containment and control measures include contracting professional divers to perform mechanical scraping of infrastructure in Lake Piru at least four times a year and recommissioning Turbine Unit 1 in December 2016 to exert lethal shear stress on veligers moving from Lake Piru to Piru Creek (discussed further in Section 3.3.1). Finally, United has implemented mild chemical control measures when decontaminating vehicles and equipment that have come into contact with infested waters (see Section United Equipment and Vehicles). United has not yet attempted chemical treatment in Lake Piru, water management and conveyance infrastructure, or lower Piru Creek given the presence of southern California steelhead critical habitat and other potentially sensitive species (see Section 4.1.1). However, United has completed a pilot study of molluscicide treatment options and determined that copper sulfate pentahydrate is the most viable option (see Section 4 for more details). Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 18

23 2 Systematic Monitoring Program Section 2 Systematic Monitoring Program United s Quagga Mussel Monitoring Program (monitoring program) was designed to delineate the extent of the quagga mussel infestation; study potential effects of the infestation; monitor the dynamics of the infestation over time; and evaluate the effectiveness of any containment or control measures for Lake Piru, lower Piru Creek, and the Santa Clara River. Under the current monitoring program, United conducts and will continue to conduct the following monitoring activities: 1. Water quality monitoring 2. Dive surveys 3. Veliger sampling 4. Natural substrate sampling 5. Artificial substrate sampling The monitoring methods, locations, frequency, and information management are described in further detail below. The monitoring locations in Lake Piru are shown in Figure 8; the monitoring locations downstream of Lake Piru are shown in Figure 9; and, Table 3 summarizes the monitoring measures and their frequency. United has already implemented these monitoring efforts. The monitoring results from 2015 and 2016 are provided in the annual quagga mussel monitoring and control reports (UWCD 2016 and UWCD 2017). United is working with stakeholders in the watershed to expand the current monitoring network to additional locations. In particular, United is working with other entities that divert water downstream of Lake Piru to ensure that monitoring is taking place. For example, while United does not have access to private property downstream, United has provided artificial substrates to Rancho Temescal and Piru Mutual Water Company and has trained their staff to setup and sample the substrates. United processes the samples when supplied by these entities. In moving forward, United will continue to work with downstream landowners to collect data outside of United s property. However, these monitoring activities are not described in this Plan because they are contingent on the cooperation of other entities and will occur on land outside of United s control. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 19

24 Section 2 Systematic Monitoring Program Figure 8. Monitoring and Control Locations in Lake Piru. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 20

25 Section 2 Systematic Monitoring Program Figure 9. Monitoring and Control Locations Downstream of Lake Piru Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 21

26 Table 3. Summary of Monitoring Activities, Frequency, and Location Monitoring Method Frequency Location Section 2 Systematic Monitoring Program Water Quality Monitoring Biweekly Lake Piru (LP-1, LP-2, LP-3, LP-4, LP-5), Lower Piru Creek between the dam and the property line between United and Rancho Temescal Monthly Confluence Veliger sampling Monthly Cow Cove/Sugarloaf, Marina and courtesy docks, intake tower, pump barge, Santa Felicia Cove, 2 sites on lower Piru Creek, and 2 sites on the Santa Clara River downstream of Piru Creek when a hydrologic connection is present with Piru Creek and conditions are safe for field staff to conduct sampling Natural Substrate Sampling Monthly Lower Piru Creek between the dam and property line with Rancho Temescal, lower Piru Creek 0.25 miles upstream of the confluence with Santa Clara River, and the Freeman Diversion when conditions are safe for field staff to conduct sampling Artificial Substrate Sampling Dive Surveys Monthly Four times per year depending on visibility and diver safety 2.1 Monitoring Methods Water Quality Juan Fernandez (QM1), Cow Cove (QM2), Santa Felicia Cove (QM3 and QM4), Dam East (QM5) and West (QM6), Pump Barge (QM7), Marina (QM9), and Piru Spillway pool (PS-1) Marina and courtesy docks, water system pump barge, floating restrooms, launch ramp, Cow Cove/Sugarloaf, riprap at the dam, and rock walls abutting the dam Water quality monitoring is used to assess the environmental parameters that correlate with spawning events, recruitment, and persistence of quagga mussels in Lake Piru, Piru Creek, and the Santa Clara River. Monitoring is also used to assess any changes in water quality associated with the presence of quagga mussels. Vertical water column profiles of temperature, DO, turbidity, and ph are measured biweekly (every two weeks) at five monitoring locations within the lake (Figure 8) as lake water levels permit and in lower Piru Creek near the USGS Gaging Station (No ). Downstream, in lower Piru Creek near its confluence with the Santa Clara River, water temperature, DO, turbidity, and ph are measured concurrently with veliger sampling once per month. Additional parameters and locations may be added in the future. Depending on the results of the initial water quality monitoring, United may add additional parameters to further assess water quality such as calcium, chlorophyll a, orthophosphate and total phosphorus, phytoplankton (concentration and bio-volume), total organic carbon, zooplankton, and nitrates Dive Surveys Underwater dive surveys are used to assess the distribution and density of quagga mussels in Lake Piru and assess the effectiveness of control methods. United aims to have scientific divers sample a minimum of four times per year in the spring, summer, and fall in Lake Piru in conjunction with dives for mussel removal and cleaning of critical infrastructure (see Section 4.2.2). However, the divers can only perform surveys when visibility permits and conditions are safe for the divers. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 22

27 Section 2 Systematic Monitoring Program The population assessments are conducted by collecting samples of quagga mussels along man-made structures (the marina docks, the launch ramp, floating restroom, and pump barge) and natural substrate throughout the lake (Cow Cove, Sugarloaf, the southeast rock wall, and the dam ripap) as shown in Figure 8). At each of these locations, mussels are sampled using a quadrat (1.3 square-feet) which is placed over the surface. All of the mussels within the quadrat are removed using a spackle tool (Figure 10) and manually scraped into a mesh bag lined with a paint strainer (0.5-millimeter mesh). Given the large size of the marina docks, a representative population is determined from an average compilation of samples collected from each of the four finger docks. The collected samples are transferred to labeled resealable plastic bags and then stored in a freezer at the lake for a minimum of 24-hours. Once frozen, the samples are transported to a lab for processing which involves enumerating and measuring the collected mussels. The data are then used to calculate the total density and mussel size distribution for each sample site. In addition to the population assessments, permanent photo plots were established in November 2015 at six locations throughout the lake (see Figure 7) to monitor mussel colonies that have established on soft bottom substrate. Each photo plot locations are marked with a 5-foot long rebar stake and a subsurface buoy suspended 2 feet above the top of the stake. During each monitoring event, a 2.7 square-foot quadrat is placed at three adjacent locations to the rebar stake and photos are taken to document the populations within each quadrat. The results of the surveys are provided in the annual quagga mussel monitoring and control reports (UWCD 2016 and UWCD 2017), and all dive survey methods and locations are included in reports that are available upon request (Culver et. al. 2014; Ecomarine 2015a through 2015c; and, Ecomarine 2016a through 2016d) Veliger Sampling Figure 10. Population Assessment Sampling Source: Ecomarine 2016d Monthly veliger sampling is conducted to assess the timing and frequency of reproductive activity; determine the occurrence and magnitude of potential pathways for downstream spread (e.g., during high-volume releases); and assess the effectiveness of containment and control measures. Plankton tows are performed on a monthly basis at a minimum of four locations in Lake Piru as shown in Figure 8 and summarized in Table 3. Plankton samples in Lake Piru are collected using the CDFW standard protocol (CDFW 2015) for veliger sampling, provided in Appendix B. Sufficient vertical tows are performed using 8- or 12-inch diameter, 64-micron plankton nets at each location to filter a minimum of 1000 liters (L)(Figure 11). Samples are kept in cold storage until laboratory analysis. Since the time from spawning to mussel settlement is approximately one month, monthly surveys are adequate to characterize the annual spawning periodicity of quagga mussels. Veliger sampling is also conducted directly downstream of Lake Piru near the Santa Felicia Dam outlet works and at two additional locations within lower Piru Creek using a modified lake sampling protocol. In locations with sufficient water depth and flow, the plankton net is deployed perpendicular to flow and fully submerged, but without contact with the bottom of the stream. Water velocity at the orifice of the net is measured using a velocity meter and the net is deployed for a Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 23

28 Section 2 Systematic Monitoring Program sufficient duration to sample a minimum of 1000 L. In locations where the water depth or flow are not sufficient, water is pumped or poured via graduated bucket into the net. In addition to regularly scheduled monitoring, veliger sampling will be performed in the future during or after storm flows or high-flow releases from the dam (e.g., migration or conservation releases) to determine the risk of spread during high flow events. United will conduct this sampling only when conditions are safe for employees. During these monitoring events, veliger sampling will be conducted at two locations in the Santa Clara River, downstream of the confluence of Piru Creek when possible. Moving forward, veliger sampling will also be conducted to assess the effectiveness of control measures, such as the recommissioning Turbine Unit 1, in decreasing or eliminating veliger transfer to lower Piru Creek from Lake Piru. The location and frequency of veliger sampling in the watershed will be adapted as data become available to assess the variability and occurrence of veligers. The plankton tow samples are currently submitted to the Burton lab, 8759 Biological Grade Hubbs Hall, La Jolla, California However, United will have an in-house lab up and running within the next year and lab analyses will be conducted in-house once the lab is complete. Figure 11 Plankton Tow Source: United staff photo Natural Substrate Sampling Streambed surveys are conducted to assess recruitment and distribution of adult mussels within lower Piru Creek and the Santa Clara River. Streambed surveys are conducted on a monthly basis to provide density and recruitment estimates that can be compared with environmental factors and spawning events occurring in Lake Piru and to assess the effectiveness of containment and control measures. Monitoring surveys are conducted in lower Piru Creek within the Release Reach immediately downstream of Santa Felicia Dam; lower Piru Creek at the confluence with the Santa Clara River; and the Santa Clara River at the Freeman Division (when conditions are safe for employees to conduct the surveys). Surveyors pick up between 10 and 20 randomly selected cobble-sized substrates, record cobble size, indicate presence/absence of quagga mussels, and, if present, record the number of quagga mussels in three size classes (<5 mm, 5-10 mm, >10 mm) Artificial Substrate Sampling Artificial settling substrates are used to assess spatial and temporal variation in recruitment rates and growth; determine variation in recruitment location and timing; and, evaluate effectiveness of control measures. Sampling using settling substrates is conducted following the CDFW Quagga/Zebra Mussel Artificial Substrate Monitoring Protocol (CDFW 2015). Artificial settling substrates are composed of three 20-centimeter (cm) x 20 cm polyvinyl chloride (PVC) plates (Plates 1 through 3) that are suspended on a rope or threaded rod. Vertically, the substrates are set 1-2 meters (m) from the lake Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 24

29 Section 2 Systematic Monitoring Program bottom at sites that are shallower than 6-8 m in total depth, and at approximately 8 m below the water surface in areas of deeper water. These substrates are monitored monthly to assess growth and recruitment. During the duration of settling substrate monitoring, there will always be a minimum of 4 locations within the lake. Plates are also deployed in the spillway plunge pool, the fish bay at the Freeman Diversion, and adjacent to the desilting basin at United s spreading grounds in Saticoy (unincorporated Ventura County). After two years of monitoring artificial substrate plates in lower Piru Creek, United staff have determined that the plates are not effective at quantifying recruitment in these locations. This may be because the settlers do not easily find the plates or they do not prefer the plates in moving water. Streambed surveys have shown that mussels are definitely recruiting in the Release Reach despite not observing settlers on the plates. Therefore, streambed surveys will be used to quantify recruitment in the creek instead of artificial plate samplers. During sample collection, mussels are removed from the bottom side of the plate being sampled using a spatula, putty knife, or similar tool making sure not to crush new recruits. The top sides of the plates are not used for analysis but are scraped clean during each sampling event to minimize weight on the plates. To assess monthly recruitment, all mussels are scraped from the upper most plate (Plate 1) and collected in a pre-labeled Ziploc-bag. To assess growth over a one-year period, mussels are removed monthly from approximately 1/6 of the surface area of Plate 2 during month one through six and from Plate 3 during months seven through twelve. The collected mussels are frozen until lab analysis. United staff process these samples and then use dissecting scopes to quantify the number of recruits and measure the size of the mussels in the growth sample using calipers. At the Freeman Diversion on the Santa Clara River, surveyors employ visual and tactile surveys to inspect the concrete walls, floor, and fish screens for the presence/absence of quagga mussels when conditions are safe to conduct the surveys. To date, quagga mussels have not been detected. However, if detected in the future, then the surveyors will record observations and develop an appropriate protocol to monitor distribution and density. 2.2 Data Management, Analysis, and Reporting The collected monitoring data will be recorded and stored in Microsoft Excel or Access databases including the associated metadata. The data will be analyzed to delineate the extent of the quagga mussel infestation; quantify the effects of the infestation; quantify the dynamics of the infestation over time; and evaluate the effectiveness of any containment or control measures for Lake Piru, lower Piru Creek, and the Santa Clara River. If adult quagga mussels are observed at a previously undetected location, United will notify CDFW within 24 hours per FGC Otherwise, the monitoring data will be maintained and compiled into an annual report with an updated infestation delineation that United will provide to CDFW and will be available to other entities upon request. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 25

30 3 Containment Measures Section 3 Containment Measures 3.1 Containment Goals The containment goals described in this section are to: 1) minimize the transfer of quagga mussels from Lake Piru via water vessels, equipment, and vehicles; and, 2) minimize the transference of live veligers from Lake Piru into lower Piru Creek via water releases from the Santa Felicia Dam. This section discusses the containment measures that have already been implemented by United. Containment measures that have been analyzed and are considered infeasible are discussed in Appendix C. 3.2 Water Vessels, Equipment, and Vehicles Recreational Vessels Education and Outreach United s public education and outreach program aims to prevent the transfer of quagga mussels to other water bodies via recreational vectors. Public education focuses on the following messages: Quagga mussel infestation is a serious issue that has significant environmental and economic consequences. Every boater and person entering the Lake Piru Recreation Area has a personal responsibility to prevent the spread of quagga mussels. The awareness campaign focuses on informing the public of the quagga infestation at Lake Piru before they arrive at the recreation area. The campaign includes a Don t Move a Mussel awareness program that is posted on United s website. United provides quagga mussel information to promote awareness and educate the public through regular website updates, proactive social media campaigns, and outreach via community groups such as the Piru Neighborhood Council and the Santa Paula Chamber of Commerce. Accordingly, United has implemented measures to regularly update their website and social media platforms and has representatives involved in community groups to provide regular updates. In addition to elevating awareness and educating the public before they visit the Lake Piru Recreation Area, educational materials including a Boaters Advisory handout are distributed to visitors upon entry. Signage is placed at the entrance to the Lake Piru Recreation Area, in a prominent area within the recreation area, and at the exit. These signs include an advisory notice sign which advises the public about the infestation, a Notice of Exit Inspection sign which advises the public of the need to undergo a mandatory exit inspection and informational posters at five information kiosks which inform the public about the biology of the quagga mussel, its impacts, and the need for Clean, Drain, Dry efforts upon departure. All personnel onsite will be informed of the importance of preventing the spread of quagga mussels from Lake Piru to other water bodies. Materials have been provided to all current employees and will be provided to new employees so that they can answer basic questions and will know where to refer guests that request additional information. Copies of the education materials are provided in Appendix D. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 26

31 Vessel Tracking Section 3 Containment Measures United uses vessel tracking as a containment measure aimed at preventing the transfer of quagga mussels to other water bodies via recreational vectors. United uses the Quagga Inspection Data (QID) system that uses registration numbers to track all vessels that enter and exit Lake Piru Recreation Area. All recreational boaters entering the Lake Piru Recreation Area are advised that their vessel will be registered in the QID system, which may result in their vessel being subjected to quarantine procedures by other recreational facility managers prior to entering other water bodies. Any vessel that enters Lake Piru is also placed on a mandatory 10-day watch list, which provides other agencies with advanced warning that the vessel has launched at Lake Piru. Data entered into the QID system are available to all other agencies and managers that employ the system. Currently, QID is used at several regional reservoirs including Pyramid Lake, Castaic Lake, Casitas Lake, and Cachuma Lake. In addition, United provides the data recorded in QID to other regional reservoirs that are not using the QID system such as Lake Nacimiento and Lopez Lake when United receives a public records request. Vessel information and dates are shared via an with an attached excel spreadsheet upon request. Vessel Screening, Inspection, and Decontamination The standard operating procedures for vessel screening, inspection, and decontamination that have been implemented by United are described below. These procedures were adapted from the Equipment Inspection and Cleaning Manual prepared by the U.S. Bureau of Reclamation (USBR 2012), A Guide to Cleaning Boats developed by CDFW (CDFW 2009), and the Aquatic Nuisance Species Watercraft Decontamination Manual developed by the Colorado Division of Wildlife (CDW 2011). Pre-Launch Screening Protocol All boaters entering the lake are provided information on the vessel screening and inspection program, and educated on the best practices to prevent the spread of quagga mussels and other invasive species. All vessels including personal watercraft (e.g., jet skis) entering the lake are entered into the QID system, and the vessel operators are asked where and when the vessel was last launched. If the vessel was last used at and/or has a tag from a water body that has no known quagga mussel impacts, then the vessel is allowed to move forward with launching. However, if the vessel was last used at a location with known invasive species, then a visual inspection is conducted to ensure that the vessel is clean, drained, and dry, to reduce the risk of introducing other invasive species into the lake. If a vessel from a contaminated source does not pass the visual inspection, United delays the launch of the vessel until it meets the clean, drained, and dry requirement to ensure that no invasive species are present. Lastly, all boaters are required to sign an affidavit inspection form consenting to a post-launch vessel inspection and informing them that their vessels are required to be clean, drained, and dry upon departure from the lake and failure to do so results in the issuance of a citation. In conjunction with the pre-launch protocol, United has adopted Section 5.6(o) of Water Ordinance 15 3, which states that It shall be unlawful for any person within the Park to launch any boat on the 3 A copy of the ordinance can be found at: %20(Most%20Current)%20Amended%20and%20Restated% pdf Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 27

32 Section 3 Containment Measures water of Lake Piru that has not successfully passed an invasive species (including but not limited to quagga mussels) vessel inspection at the Park s entry area. The Park service officers at Lake Piru are authorized to enforce this section of the ordinance by means of issuing an administrative citation to those in violation. A copy of the Lake Piru Recreation Area Vessel Inspection Checklist is provided in Appendix E. The inspection procedures are the same as those outlined in Appendix F, for equipment used in conducting United s operations and projects. Post-Launch Inspection Protocol The objective of the post-launch inspections and decontamination of recreational vessels is to minimize the transfer of quagga mussels from Lake Piru to other water bodies. All vessels undergo a post-launch inspection procedure conducted by an authorized inspector who has received formal watercraft inspection and decontamination training for zebra/quagga mussels and follow the Lake Piru Recreation Area Vessel Inspection Checklist (Appendix E). Similar to the Arizona Game and Fish Aquatic Invasive Species Program 4, the post-launch protocol categorizes boats based on the number of consecutive days on the water with short-term boaters being in the water less than 96 hours and long-term boaters being in the water 96 hours or more. As specified in Arizona Game and Fish information materials 5, a watercraft that has been in quagga mussel infested waters for more than 96 hours has a higher chance of having live mussels attached. Following the post-launch inspection, boaters may request for their boat to be tagged with the Vessel Inspection Tag (VIT) as described below (see Vessel Tagging ). United staff oversee short-term boaters exiting Lake Piru and ensure the boaters are conducting the proper procedures for cleaning, draining, and drying their vessels. The boaters are responsible for cleaning their vessels of all visible quagga mussels or attached vegetation, dirt, debris, or surface deposits including mussel shells, or residue on the vessel, trailer, outdrive, or equipment that could mask the presence of attached mussels. The vessels are required to be drained, to the extent practicable, so that all water is drained from any live-well, bait-well, storage compartment, bilge area, engine compartment, deck, ballast tank, water storage and delivery system, cooler or other water storage area on the vessel, trailer, engine, or equipment. The vessels are also required to be dried so there is no visible sign of standing water, or in the case of equipment, wetness on or in the watercraft, trailer, engine or equipment. Additionally, operators of personal water craft (e.g., jet skis) are required to start their engines and run for 15 seconds, in order to ensure that water is flushed out of the personal water craft s jet drive. The vessel owners are also instructed on the amount of drying time the vessel or equipment will need before entering another water body based on the 100 th Meridian Quarantine Estimator for Zebra-Mussel Contaminated Boats, and review of other decontamination protocols (AGFD 2014, CPW 2014). The dry time calculator is found at: Long-term boaters are considered high risk for transfer of quagga mussels into other water bodies; therefore, long-term boaters leaving Lake Piru are required to undergo a high-pressure, hot water decontamination procedure conducted by United s staff using a trailer-mounted thermal pressure washing unit. Methods for decontamination follow CDFW Aquatic Invasive Species Decontamination Protocols (CDFW 2009). The decontamination procedures are the same as those Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 28

33 Section 3 Containment Measures outlined in Appendix F for decontamination of equipment used in conducting United s operations and projects. Boaters that refuse to submit to a post-launch inspection and, if necessary, decontamination will be issued a citation in violation of Section 5.6(p) of Water Ordinance 15, which states that It shall be unlawful for any person within the Park to leave the Recreation Area with any boat, personal watercraft, aquaplane or float tube which has not been cleaned, drained and dried, in a manner specified by the District, and successfully passed an invasive species (including but not limited to quagga mussels) vessel inspection, at the Park s entry area. During fishing tournaments on Lake Piru, the participants use their own boats and are subject to the same pre- and post-launch protocols discussed above. Vessel Tagging United employs a vessel security tagging system for boaters leaving Lake Piru to alert other recreational facilities of the vessel s entry into quagga mussel infested waters at Lake Piru. The tagging adds a second security measure for recreational areas that employ QID as well as alerting recreational facilities that do not use QID. Upon departure from the recreation area, recreational boaters have the option to have a VIT placed on their vessels. If requested, the VIT will be securely attached to both the vessel and trailer after inspection. An intact VIT will indicate that the vessel has not been removed from the trailer since the last visit to the Lake Piru Recreation Area (i.e., has not launched in another water body). This process involves attachment of a stainless-steel cable from the eyelet of the vessel to the vessel trailer. A security device (plastic seal) is installed to prevent tampering (see Figure 11). Figure 12. United Vessel Tags Since the vessel tagging program is voluntary and relies on the honesty and integrity of the boaters, United is exploring the legality of requiring VITs on all vessels exiting Lake Piru. However, at this time, this issue has not been resolved. Accordingly, United will continue to encourage all vessel operators to obtain a VIT. United will continue to allow returning vessels with intact VITs issued by Lake Piru to launch without an inspection. In the future, if it is determined that United has the legal authority to require all vessels to obtain a VIT prior to exiting the lake, then United will notify CDFW and revise the Plan accordingly. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 29

34 Whitewater Recreational Vessels Section 3 Containment Measures Most whitewater vessels are undocumented and do not possess a CF number. However, United does enter whitewater vessels into QID by vessel type, a description of the vessel, the owner s information, and the date of launch. All parties intending to participate in whitewater activities in middle or lower Piru Creek must pre-register with Lake Piru Recreation staff, and all vessels are required to undergo the pre- and post-launch protocols outlined above. United does not provide any equipment for whitewater rafting activities. Lake Piru Recreation staff are responsible for the registration and coordination of whitewater rafting activities Shoreline Fishing Efforts to contain the spread of mussels by fisherman are primarily focused on public education to increase awareness and elevate the accountability of visitors to the lake (see Section Education and Outreach). Illegal fishing occasionally occurs in areas outside of the Lake Piru Recreation Area (between the main entrance and the dam). This restricted area is patrolled during daytime hours to prevent access, and, while fishing after hours is prohibited as outlined in United Ordinance 15:5.6(j). The ordinance has been posted in the area often used for illegal access to the shoreline. United has also added after-hours patrols on Friday and Saturday nights during the peak season with assistance from the Ventura County sheriff s department when possible. Fishing is prohibited in lower Piru Creek due to the presence of endangered steelhead. In addition, a sign is posted at the release pool stating that fishing is prohibited in lower Piru Creek United Equipment and Vehicles United has developed Standard Operating Procedures (provided in Appendix F) to prevent the transfer of quagga mussels through its equipment and vehicles. Appendix F presents the standard operating procedures (SOPs) developed to prevent the spread of quagga mussels during performance of activities by United personnel and parties under contract with United. The objective of the SOPs is to ensure that all equipment exposed to contamination in the course of conducting activities associated with United s operations or projects be cleaned, decontaminated, and inspected prior to leaving the facilities, as well as be required to undergo an appropriate drying period prior to use at other locations Firefighting Equipment and Vehicles United has established a Memorandum of Understanding (MOU) with the Ventura County Fire Protection District (see Appendix G) and is working to establish similar MOUs with the Los Angeles County and Los Padres National Forest Fire Departments to prevent the transfer of quagga mussels during training and fire-fighting activities. The MOU with Los Padres National Forest Fire Department is currently under review. United has not received a response regarding the MOU with Los Angeles County. 3.3 Quagga Mussel Transference to Lower Piru Creek As previously discussed, water releases from Santa Felicia Dam have the potential to transfer quagga mussels from Lake Piru to lower Piru Creek. These releases consist of controlled releases through the dam outlet works system and uncontrolled releases through the spillway channel during spill events. Some of the controlled releases are required by the FERC license for the Santa Felicia Hydroelectric Project. Cessation of these releases would require a waiver or amendment to United s Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 30

35 Section 3 Containment Measures FERC license. A temporary waiver of required water releases would require agreement by multiple resource agencies. An amendment to United s FERC license would require a formal section 7 consultation under the federal Endangered Species Act (FESA). United is consulting with FERC and NMFS to determine what options are feasible, but no option is forthcoming to halt or modify these releases while still complying with the FESA. In order to identify potential containment measures, United has evaluated the potential of the existing water release infrastructure to exert lethal shear forces on quagga mussel veligers to minimize the transfer of viable veligers downstream, while United works on an extreme population control plan aimed at eradication of quagga mussels from Lake Piru and the portions of Piru Creek that United owns (see Section 4 Control Measures) Water Release and Mechanism Analyses United is limited in its actions on modifying the infrastructure to provide 100% containment of veligers. The biggest challenge is that contact time in the existing infrastructure is relatively short e.g., approximately 58-minutes at a discharge of 7 cfs and approximately 20-minutes at a discharge of 20 cfs), which would necessitate a continuous, highly toxic treatment to provide 100% containment. Given the critical habitat in lower Piru Creek, continuous, highly toxic treatments are not possible. Therefore, United is taking the short-term approach of maximizing shear stress on veligers as much as possible to minimize transfer of viable veligers downstream, while United pursues an extreme population control option aimed at eradication (see Section 4 Control Measures). United contracted GEI Consultants to conduct two studies to evaluate quagga mussel veliger mortality through the various water release mechanisms at Santa Felicia Dam (GEI 2016a and GEI 2017) and is herein referred to as the shear stress studies. Quagga mussel veligers are highly susceptible to damage and mortality by physical forces such as shear stress associated with turbulent flow (Horvath and Lamberti, 1999; Rehmann et., al., 2003; and, Horvath and Crane 2010). Accordingly, the study evaluated shear and pressure forces related to the release of water through the outlet works, and the spillway channel to determine the potential mortality of the veligers through these release points. The results of the study indicate that: quagga mussel veligers likely survive conveyance through the penstock, cone valves, butterfly valve; and low-flow release valves; flow through the turbine units results in the mortality of certain size classes of veligers depending on the flow rate; and, veligers are unlikely to survive discharge through the spillway over the range of modeled flows (10 to 150,000 cfs) due to the significant turbulence that occurs in the downstream rock channel. Based on this study, United has identified and analyzed every possible point of transference of veligers through the water release infrastructure. This analysis is discussed below and summarized in Table 4. Steelhead habitat water releases of 5 cfs are conveyed through one of the low-flow release valves and occur rarely (10 days or less per year as restricted by the FERC license) primarily during maintenance and dam safety inspections. The shear stress study results for these flows indicate no Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 31

36 Section 3 Containment Measures mortality of veligers. Currently, the low-flow valves are the only mechanism for these releases which, while infrequent, are required to safely conduct maintenance and inspection activities. Steelhead habitat releases between 7-20 cfs currently make up the majority of the water releases that United conducts. Prior to recommissioning Turbine Unit 1 in December 2016, all of these releases were conveyed through the low-flow cone valves in which most veligers survive. However, as of January 2017, both hydroelectric units are functioning and United is running habitat releases through the hydroelectric units. The shear stress calculations indicate that running 7 cfs releases through Turbine Unit 1 should result in the mortality of all veligers greater than 115 micrometers (µm); running 14 cfs releases through Unit 1 should result in the mortality of all veligers greater than 89 µm; and, running cfs through Unit 1 should result in the mortality of all size classes of veligers. Intermediate releases between cfs occur when United is ramping up for a migration release. In regards to water release points, several options are available to meet these flow release requirements. Specifically, these releases could pass through the turbine units up to 107 cfs at which time both turbines will reach their maximum capacity, and the remaining releases (anything above 107 cfs) would be released through the cone valves. Veligers are expected to survive passing through the cone valves and United has not identified an immediate action that can address this method of veliger transference. On December 2, 2016, United submitted a Request for Concurrence (Appendix H) to NMFS for the temporary suspension of migration releases between January 1 and May 31, 2017 in order to minimize the potential for conveying quagga mussels into the Santa Clara River as the migration releases occur when surface flows are present in the Santa Clara River which provides a transport pathway to areas downstream of the Piru Creek watershed. On January 19, 2016, NMFS provided a letter stating that they do not concur (Appendix I) with the request. Therefore, United is currently required to conduct the migration releases when triggered to remain in compliance with its FERC license. NMFS states that FERC would need to conduct formal section 7 consultation for this action and requested that it be combined into a consultation for a comprehensive project that includes all actions contained in this Plan that may affect steelhead and critical habitat. United is currently continuing to consult with FERC and NMFS to evaluate options for how to proceed in light of this guidance from NMFS. Migration releases at a minimum of 200 cfs are triggered based on surface flows in Santa Clara River and weather forecast criteria outlined in the Santa Felicia Water Release Plan (UWCD 2012). As discussed above, releases above 107 cfs are conveyed through the cone valves which likely results in the transfer of viable veligers downstream. The actions for addressing migration releases are the same as discussed above for Intermediate releases between cfs. Conservation releases between cfs have historically been conveyed through the cone valves which likely results in the transfer of viable veligers downstream. The conservation releases are controlled and conducted by United to meet water resource management goals, with primary emphasis on meeting the human health water quality standards for water in drinking water aquifers and to combat seawater intrusion in the coastal aquifers. During periods of drought while aquifers are in critical overdraft, United will need to continue releasing water from Lake Piru for water management purposes to combat potential impacts to human health from degraded water quality. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 32

37 Section 3 Containment Measures Emergency releases up to 500 cfs are not anticipated but could occur in the event of a natural or human caused disaster and emergency safety situation of the dam. If emergency releases are needed, then they would be conveyed through the cone valves, which likely results in the transfer of veligers downstream. Given that these releases occur during emergency situations, United cannot predict or control their occurrence and will need to take necessary actions to protect the integrity of Santa Felicia Dam and public safety. Spill Events occur when inflows are greater than outflows to the extent that the lake fills up and spills over the spillway channel of the dam. United does not have control over the occurrence of spill events or flows during the events. During extreme rain events, the lake can fill up and spill within days and inflows can equal up to approximately three-times the capacity of the lake, making it extremely difficult to prevent spill events even if the capacity of Lake Piru is maintained at the lowest possible level (~400 AF). The shear stress study evaluated flows between 10 and 150,000 cfs in the spillway, and the results indicated 100% mortality of veligers over this range in flows due to the significant turbulence that occurs in the downstream rock channel. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 33

38 Table 4. Summary of Points of Transference to Lower Piru Creek and Modeled Veliger Mortality Section 3 Containment Measures Release Type Habitat Releases Transitional Flows High-Volume Releases (Migration/Conservation Releases) (~0-6 per year) Spill Events (average ~every 5-6 years) Release Range (cfs) ,000* Release Mechanism Low- Flow Valves Turbine Unit 1 * not always feasible at low end of range because of inefficient head pressure Low- Flow Valves Cone Valves Turbine Unit 1 + Turbine United 2 + Cone Valves Santa Felicia Dam Spillway and Spillway Channel 100% Veliger Mortality? Yes for sizes 235 µm and larger Yes for sizes 200 µm and larger Yes for sizes 115 µm and larger Yes for sizes 89 µm and larger Yes for sizes 200 µm and larger No Yes 107 cfs through turbines for sizes 89 µm and larger Yes No for sizes 200 µm and smaller No for sizes 115 µm and smaller No for sizes 89 µm and smaller No for sizes 57 µm and smaller No for sizes 115 µm and smaller No extra cfs would have to go through the cone valves where most survive up to 200 cfs Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 34

39 3.4 Surface Water Deliveries Section 3 Containment Measures United is engaged with downstream stakeholders that receive surface water deliveries from the Freeman Diversion. United held a meeting with these stakeholders on December 8, The stakeholders were briefed on the potential issues related to quagga mussel infestations and were presented with a number of alternatives for treatment and removal of quagga mussels to prevent them from reaching downstream stakeholder infrastructure (AECOM 2016). The current recommendation is similar to a conjunctive-use type of operation in which surface water is infiltrated through the Saticoy groundwater recharge basins. The recharge basins will effectively serve as sand filters to remove quagga mussel veligers as the water percolates through the basins. The water will then be pumped out of the groundwater basins using an expanded Saticoy well field. This alternative is the only cost-effective alternative that guarantees complete veliger removal before reaching downstream stakeholder infrastructure. In addition to the proposed capital improvements, United has been in the process of developing a Lower River System Quagga Control Operations Manual that includes monitoring and control procedures for infrastructure downstream of the Freeman Diversion. At this time, no surface water is being delivered to United s agricultural irrigation customers which include United s Pumping Trough Pipeline (PTP) and the Pleasant Valley County Water District (PVCWD). Surface water deliveries have been prioritized for drinking water supplies (Oxnard- Hueneme Pipeline) and groundwater recharge until groundwater levels in the aquifers of the Oxnard Plain recover to sufficient levels. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 35

40 4 Control Measures Section 4 Control Measures The objectives of each control measure are to minimize attachment to key infrastructure in order to minimize infrastructure effects and maintenance costs; and to control population density to minimize negative impacts to the environment and infrastructure. This section discusses the control measures that have already been implemented by United and the measures that United is currently pursuing. Control measure alternatives that have been previously analyzed are considered infeasible are discussed in Appendix C. The success and applicability of the control measures depends on the level of infestation, the mussel life stages that are present, the possibility of continued importation of mussels from outside sources, accessibility to vulnerable areas, and presence of highly sensitive non-target species within and downstream of the infested waters. The success of these control measures will be evaluated with data collected through monitoring actions as outlined in Section 2. The effectiveness of these measures is assessed annually and used to inform and guide appropriate changes to the Plan, if necessary, as part of the adaptive management approach outlined in Section Mechanical and Physical Control Water Level Management Lake Piru was created to temporarily store winter runoff from the Piru Creek watershed until it could be released at a later time to replenish downstream groundwater aquifers. Because Lake Piru is not used for flood control or drinking water production, United has some flexibility regarding the timing and volume of water releases, providing United with the opportunity to utilize lake level management as a quagga mussel population control strategy. It has been shown that quagga mussels desiccate and die when exposed to air for given amount of time dependent on humidity and temperature (Ricciardi, et. al. 1995). Quagga mussel mortality can also be affected by prolonged exposure to low dissolved oxygen concentrations in the water (Fagan 2011, Wong and Gerstenberger 2015). It is anticipated that the lake level management strategy with the maximum quagga mortality will consist of releasing lake water near the end of a lake stratification episode (late summer), when mussels in the hypoxic zone have died, and let lake levels decrease below the hypoxic zone boundary elevation (Figure 12). Mussels exposed to air would desiccate after an appropriate time given heat and humidity, and no or low numbers of live quagga mussels will remain in the lake. Lower concentrations of veligers will likely persist due to lake mixing during a release. The lake level management strategy will be most effective when repeated over the years or combined with a molluscicide treatment (see Section 4.1.3), so that any remaining quagga mussels and/or veligers do not fully recolonize the lake. The effectiveness of United s lake level management strategy will depend on a number of factors which are currently not well understood, including: 1. Timing, frequency and depth of stratification in Lake Piru 2. Dissolved oxygen concentrations in hypoxic zone during stratification in Lake Piru 3. Quagga mussel and veliger mortality rate in hypoxic zone Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 36

41 Section 4 Control Measures 4. United s ability to lower lake levels during lake stratification, considering operational, water resources, environmental and regulatory constraints Figure 12. Lake Level Management Conceptual Framework Therefore, United is currently developing a linked Lake Piru Hydrodynamic and Quagga Population Model to test the effectiveness of Lake Level Management under various assumptions and determine an optimal release strategy considering all constraints. The model will simulate conditions for the period, which includes wet and dry periods, high and low lake levels (including spill events), and multiple conservation releases. The Lake Piru Hydrodynamic Model uses the open-source General Lake Model for simulating lake dynamics, coupled with the Aquatic EcoDynamics library (AED2) for simulations of water quality (Hipsey et al., 2014). The model is available at The model is currently being calibrated. More detailed information regarding the model and United s model calibration results is available in Appendix J. The Quagga Population model is currently under development. The model will use time series outputs from the Hydrodynamic Model (lake area, lake volume, dissolved oxygen profiles) to determine mortality and population dynamics of quagga mussels and veligers in Lake Piru. Existing quagga monitoring data will be used to determine quagga concentrations and growth parameters. United plans to have a functional Lake Piru Hydrodynamic and Quagga Population Model available by April 2018, so that different release scenarios can be analyzed to determine the optimal lake level management strategy before the summer of 2018 when stratification would occur if the lake has enough water. Note that the hydrodynamic and Quagga population models may continue to be finetuned as new monitoring data becomes available in the future, and the lake level management strategy may be adjusted accordingly under the adaptive management framework. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 37

42 4.1.2 Mechanical Scraping Section 4 Control Measures Mechanical scraping of human-made structures is conducted at a minimum of four times per year during the height of reproduction (spring, summer, and fall) to minimize the number of newly settled mussels growing to reproductive maturity. Mechanical removal involves the removal of attached juvenile and adult mussels via mechanical scraping/raking. This method is considered fairly benign giving it a low position on the IPM pyramid. With mechanical removal, mussels are detached using tools such as paint scrapers, screwdrivers, chisels, and dull knives. Manual removal has been implemented as a control measure, because it can be conducted during quarterly dive surveys and is a relatively effective tool for reducing small populations with limited effect to non-target organisms. There is a potential for other sessile organisms to be removed off of the substrate during the removal process. Due to the varying substrates and accessibility of areas within Lake Piru, such as Cow Cove which has numerous rocky crevices, manual removal has only been implemented in those areas that are suitable such as the infrastructure associated with the dam and recreation facilities. After removal, dead mussel shells are retrieved to prevent additional substrate availability to new populations of cohorts. These techniques and tools are conducted underwater by a dive team trained in mussel detection and removal techniques. Removed mussels are buried within United s property at a location that is sufficiently away from and above the high-water level of the lake to prevent potential impacts. All mussels removed from Lake Piru are air dried and then placed in 30-gallon drums. Dead mussels are transferred to an onsite location and then crushed and buried in pits located on United s property within the Lake Piru Recreation Area. The pits are located above Lake Piru s high water mark at least 1,000 feet away from the water line and a minimum of 200 feet away from any source of runoff. The pits are approximately 5 feet in depth. The success of this method is assessed by the dive surveys presented in the Monitoring Program. Density estimates are compared to previous estimates at each location and to densities on natural substrates to assess the effectiveness of mechanical scraping at these locations Chemical Control United recently completed a pilot study that tested four molluscicide options (Appendix K) The copper sulfate pentahydrate formulation registered under EarthTecQZ proved to be the most costeffective option that could effectively treat for quagga mussels while minimizing potential impacts to O. mykiss. Copper performs best at higher temperatures, however the highest concentration resulted in 100% mortality at all temperatures tested (10, 17, and 22 )(Figure 13). The number of days to 100% mortality increased with decreasing temperature. Although 22 was the maximum temperature tested, Lake Piru regularly exceeds 22 in the summer months, therefore the results are likely conservative at the maximum temperatures observed in Lake Piru. United consulted with the federal Environmental Protection Agency and currently EarthTecQZ is not considered labeled for lake-wide use against quagga mussels in a reservoir that releases to a natural system; therefore, United received guidance to pursue a special local need registration (SLN) issued through California Department of Pesticide Regulation and United will be issuing a request for proposals. As a general approach, United will be using the lake level management model and previous water quality data to optimize the treatment strategy to maximize the effectiveness in Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 38

43 Section 4 Control Measures treating the quagga mussel population. United will then treat the entire lake with up to 200 µg/l elemental copper and continue releases during this time to also treat Piru Creek. Discharge of a molluscicide to surface waters of the United States requires a National Pollution Discharge Elimination System (NPDES) permit under the federal Clean Water Act. NPDES permits are issued by SWRCB. United submitted an application for an NPDES permit to authorize the application of a copper-based molluscicide on October 21, The SWRCB issued a Notice of Applicability for the Statewide Aquatic Animal Invasive Species Control Permit on December 8, Figure 13. Percent Mortality over Time at Three Concentrations of Copper and Three Treatment Temperatures Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 39

44 5 Adaptive Management and Reporting Section 5 Adaptive Management and Reporting The purpose of the Adaptive Management Plan (AMP) is to provide a protocol in which the information collected during implementation of this Plan is assessed and used to inform and guide necessary modifications to the Plan to ensure that United is meeting the goals and objectives in compliance with FGC 2301 (d)(1). 5.1 Constraints on Changing Containment and Control Actions The decision-making process associated with the AMP will consider various constraints associated with the Santa Felicia Project. The most significant constraint is related to the purpose of the Project and its operations. United operates various facilities for the management of water resources in central Ventura County. These water resources are an important source for a relatively prosperous and diverse economy with a population of over 350,000 and agricultural production upwards of $2 billion per year. The vast majority of the water for uses in United s boundary area is extracted from wells supplied by groundwater. These extractions exceed the groundwater recharge supplies by over 20,000 AF per year. This condition is known as overdraft, which results in decreasing groundwater quality and in seawater intrusion into the coastal aquifers. The Project is an important component of United s operations intended to counter overdraft and is used to recharge depleted groundwater supplies within the Santa Clara River basin downstream of the Project. In addition, the water stored in Lake Piru is used to support endangered southern California steelhead in lower Piru Creek, and United is required to provide year-round water releases as prescribed in the Santa Felicia Water Release Plan (UWCD 2012). Lastly, the decision-making process will also consider the secondary purposes of the Project which include power generation and recreational benefits at Lake Piru. 5.2 Technical Advisory Committee and Regional Working Group United has formed a Technical Advisory Committee to support the adaptive management process. The Committee will assist United in reviewing collected data, evaluating the effectiveness of the proposed containment, control, and monitoring measures; and, if warranted, developing alternate strategies for addressing the infestation. The Committee is comprised of representatives from CDFW, USFWS, NMFS, U.S. Department of Agriculture Forest Service (Forest Service), Ventura County, and the California Sea Grant. In addition, United will continue to participate in the Regional Working Group comprised of lake managers from Ventura, Santa Barbara, and Los Angeles Counties. 5.3 Decision-Making Process The decision-making framework for modifications to the Plan is outlined below: Step 1 Annual Report: United will prepare an annual report that will be submitted to CDFW for review by March 31 of each year. The report will document Monitoring efforts Any changes in infestation delineation Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 40

45 Section 6 Adaptive Management and Reporting Containment measures including an analysis of ordinance violations and citations by recreational uses. United will also include an analysis of water releases that did or did not pass viable veligers throughout the year based on the shear stress calculations Control measures including a quantification of mussel mortality per control measure implemented Recommendations for modifications to the Plan under the Adaptive Management protocol The annual report will document the findings and activities for the previous year (January 1 to December 31) as well as cumulative data. Annual reports will be distributed to the CDFW, the Technical Advisory Committee, the regional working group, and other stakeholders. Step 2 Annual Consultation with CDFW: By May 15 of each year, United will consult with CDFW and the Technical Advisory Committee on the findings and recommendations in the annual report. The consultation may be through meetings, conference calls, workshops, or written correspondence. Step 3 Adoption of Recommendations: United will modify the monitoring, containment, and control activities to reflect the findings and recommendations in the annual report and the outcome of the annual consultation with CDFW. If modifications are significant enough to necessitate revising the Plan, then United will revise the Plan and submit the new draft Plan to CDFW for approval. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 41

46 6 References Section 6 References AECOM Freeman Diversion Facilities Invasive Species Control Options Assessment and Engineering Feasibility Study. September 7, Arizona Game and Fish Department. Aquatic Invasive Species Decontamination Protocols (McMahon-Dahlberg)%20Feb2014.pdf Bobeldyk, A. M., J. M. Bossenbroek, M. A. Evans-White, D. M. Lodge, and G. A. Lamberti Secondary spread of zebra mussels (Dreissena polymorpha) in coupled lake-stream systems. Ecoscience 12: California Department of Fish and Wildlife A Guide to Cleaning Boats and Preventing Mussel Damage. California Department of Fish and Wildlife Quagga/Zebra Mussel Artificial Substrate Protocol. Downloaded from: Mussels California Natural Resources Agency (CNRA) Invasive Mussel Guidebook for Recreational Water Managers and Users. Strategies for Local Involvement. City of Ventura Estuary Subwatershed Study Assessment of the Physical and Biological Condition of the Santa Clara River Estuary, Ventura County, California. City of Ventura Special Studies. September Claudi, R.M., and K.M. Prescott Examination of Calcium and ph as Predictors of Dreissenid Mussel Survival in the California State Water Project. RNT Consulting, Inc. March 11, Claxton, W. T., and G. L Mackie Seasonal and depth variations in gametogenesis and spawning of Dreissena polymorpha and Dreissena bugensis in eastern Lake Eerie. Canadian Journal of Zoology. 76: Cohen, A. N Potential Distribution of Zebra Mussels (Dreissena polymorpha) and Quagga Mussels (Dreissena bugensis) in California. Phase 1 Report. A report for the California Department of Fish and Game. Colorado Parks and Wildlife Aquatic Nuisance Species (ANS) Watercraft Decontamination Manual. Colorado Parks & Wildlife Official Colorado Watercraft Inspection and Decontamination (WID) Procedures. Culver, C.S., A.K. Morris, and M.A. Anghera Dive Assessment of the Quagga Mussel Infestation at Lake Piru. Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 42

47 Section 6 References Culver, C.S., S.L. Drill, M.R. Meyers, and V.T. Borel Early Detection Monitoring Manual for Quagga and Zebra Mussels. California Sea Grant Extension Program University of California Cooperative Extension. January. Ecomarine Consulting LLC. 2015a. Quagga Mussel (Dreissena Bugensis) Control Activities at Lake Piru, April 17-20, July Ecomarine Consulting LLC. 2015b. Quagga Mussel (Dreissena Bugensis) Control Activities at Lake Piru, July 14-17, September Ecomarine Consulting LLC. 2015c. Quagga Mussel (Dreissena Bugensis) Control Activities at Lake Piru, September 11-13, November Ecomarine Consulting LLC. 2016a. Quagga Mussel (Dreissena Bugensis) Control Activities at Lake Piru, November 13-15, February Ecomarine Consulting LLC. 2016b. Quagga Mussel (Dreissena Bugensis) Control Activities at Lake Piru, January and March 11-13, May Ecomarine Consulting LLC and Anghera Environmental. 2016c. Quagga Mussel (Dreissena Bugensis) Density Measurements at Lake Piru, May 22 and June 7, June Ecomarine Consulting LLC and Anghera Environmental. 2016d. Quagga Mussel (Dreissena Bugensis) Control Activities at Lake Piru, September 30 to October 2, November GEI Consultants. 2016a. Santa Felicia Dam - Quagga Mussel Veliger Transport Study. Technical Memorandum. May 9. Fagan, T Dissolved Oxygen Tolerances of Post-Veliger Dreissenids, Master of Science Thesis, Bowling Green State University. August GEI Consultants. 2016a. Santa Felicia Dam - Quagga Mussel Veliger Transport Study. Technical Memorandum. May 9. GEI Consultants. 2016b. Santa Felicia Quagga Mussel Treatment and Filtration Evaluation. Technical Memorandum. June 6. GEI Consultants Santa Felicia Dam Preliminary Quagga Mussel Veliger Transport Study. Technical Memorandum. March 22. Hipsey, M.R., Bruce, L.C., and Hamilton, D.P. (2014). GLM - General Lake Model. Model overview and user information. AED Report #26. The University of Western Australia, Perth, Australia. 42pp. Horvath, T.G and G.A. Lamberti Hydrodynamic forces affect larval zebra mussel (Dreissena polymorpha) mortality in a laboratory setting. Aquat. Invasions 5: Horvath, T. G., G. A. Lamberti, D. M. Lodge, and W. L. Perry Zebra mussel dispersal in lakestream systems: source-sink dynamics? Journal of the North American Benthological Society 15: Hosler, D Personal communication on May 11, Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 43

48 Horvath, Thomas G. and Gary A. Lamberti Mortality of Zebra Mussel, Dreissena polymorpha, Veligers during Downstream Transport. Freshwater Biology. 42: Section 6 References Irvine Ranch Water District (IRWD) and Serrano Water District (SWD) Invasive Mussel Monitoring and Control Plan Irvine Lake, California. Kennedy/Jenks (Kennedy/Jenks Consultants) Upper Santa Clara River Integrated Regional Water Management Plan (IRWMP). Mills, E.L., G. Rosenberg, A.P. Spidle, M. Ludyanskiy, Y. Pligin, and B. May A Review of the Biology and Ecology of the Quagga Mussel (Dreissena bugensis), a Second Species of Freshwater Dreissenid Introduced to North America. American Zoologist 36: Minchin, D., Boelens, R From lakes to rivers: downstream larval dispersal of Dreissena polymorpha in Irish river basins. Aquatic Invasions 3(3): Rehmann CR, Stoeckel JA, Schneider DW Effect of turbulence on the mortality of zebra mussel veligers. Canadian Journal of Zoology 81: , doi: /z Ricciardi, A., Serrouya R., Whoriskey F Aerial exposure tolerance of zebra and quagga mussels (Bivalvia: Dreissenidae): implications for overland dispersal. Canadian Journal of Fisheries and Aquatic Sciences Vol. 52. Spidle, A. P., E. L. Mills, and B. May Limits to tolerance of temperature and salinity in the quagga mussel (Dreissena bugensis) and the zebra mussel (Dreissena polymorpha). Canadian Journal of Fisheries and Aquatic Sciences 52: Stoeckel, J. A., C. R. Rehmann, D. W. Schneider, and D. K. Padilla Retention and supply of zebra mussel larvae in a large river system: importance of an upstream lake. Freshwater Biology 49: Stoeckel, J. A., D. W. Schneider, L. A. Soeken, K. D. Blodgett, and R. E. Sparks Larval dynamics of a riverine metapopulation: implications for zebra mussel recruitment, dispersal, and control in a large-river system. Journal of the North American Benthological Society 16: U.S. Bureau of Reclamation (Reclamation) Inspection and Cleaning Manual for Equipment and Vehicles to Prevent the Spread of Invasive Species. Technical Memo No pdf United Water Conservation District (UWCD) Santa Felicia Water Release Plan. June United Water Conservation District Memorandum - Piru Creek Snorkel Survey Results. August 4, United Water Conservation District Annual Report, Quagga Mussel Monitoring and Control Plan. February Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 44

49 Section 6 References United Water Conservation District Annual Report, Quagga Mussel Monitoring and Control. May URS (URS Corporation) Santa Clara River Parkway Floodplain Restoration Feasibility Study Water Resources Investigations. Prepared for the California Coastal Conservancy. April. Ventura County Ventura County s 2015 Crop & Livestock Report. Ventura County Office of the Agricultural Commissioner. Wong, WH, Gerstenberger, S Biology and Management of Invasive Quagga and Zebra Mussels in the Western United States. CRC Press. May Wright, D. A., E. M. Setzler-Hamilton, J. A. Magee, V. S. Kennedy, and S. P. McIninch Effect of Salinity and Temperature on Survival and Development of Young Zebra (Dreissena polymorpha) and Quagga (Dreissena bugensis) Mussels. Estuaries. 19(3): Quagga Mussel Monitoring and Control Plan United Water Conservation District, October 2017 Page 45

50 APPENDIX A Applicable Federal, State, and Local Regulatory, Planning, and Permitting Requirements

51 Applicable Federal, State, and Local Regulatory, Planning, and Permitting Requirements The following provides a summary of key federal, state, and local acts, regulations, plans, and permitting requirements applicable to the monitoring, management, control, and eradication of dreissenid mussels. Federal Requirements Clean Water Act Sections 401, 402, and 404 The federal Clean Water Act (CWA) is applicable to the implementation of control measures that could result in a discharge to navigable waters of the United States, as that term is defined in CWA 502(7) and corresponding case law, such as Lake Piru. CWA 401 requires that every applicant for a federal permit or license for any activity that may result in a discharge to a navigable water body, obtain a State Water Quality Certification. The certification declares that the discharge will comply with applicable provisions of the CWA, including water quality standards. These water quality standards specify the designated use of a stream or lake, pollutant limits necessary to protect the designated use, and policies to ensure that existing water uses will not be degraded by pollutant discharges. In the state of California, 401 of the CWA is administered by the California Water Resources Control Board. CWA 402 establishes the National Pollutant Discharge Elimination System (NPDES) permit program to regulate point source discharges of pollutants into waters of the United States. The NPDES permit sets specific discharge limits for point sources discharging pollutants into waters of the United States and establishes monitoring and reporting requirements, as well as special conditions. In the state of California, 402 of the CWA is administered by the California Water Resources Control Board. CWA 404 provides programmatic regulations for the discharge of dredged and fill material into waters of the United States, including wetlands or water bodies. Responsibility for administering and enforcing 404 is shared by the U.S. Army Corps of Engineers and U.S. Environmental Protection Agency (EPA). Endangered Species Act The federal Endangered Species Act (ESA) provides for the conservation of species that are endangered or threatened throughout all or a significant portion of their range, and the conservation of the ecosystems on which they depend. It is administered by the U.S. Fish and Wildlife Service (USFWS) and the NMFS. If United undertakes control measures that could affect species or critical habitat listed under the ESA, then United will need to comply with the ESA.

52 Federal Energy Regulatory Commission United was issued a license by FERC for operation of the Santa Felicia Project. The terms of this license dictate the minimum water releases for the project. Control measures must comply with the terms of the FERC license. Forest Service Lake Piru is partially within the Los Padres National Forest. The U.S. Department of Agriculture Forest Service (Forest Service) has developed a national strategic framework for invasive species management (Forest Service 2013), which includes provisions for addressing dreissenid mussels. Among the provisions of this plan are that the Forest Service collaborate and coordinate with external partners, including other federal, state, and local government agencies. Monitoring and control measures that would affect the national forest lands should be developed in coordination with the Forest Service. State of California Requirements Assembly Bill 1683 This bill was signed into law in 2007 and is intended to control the spread of dreissenid mussels within California. It authorizes the CDFW to inspect and quarantine infected boats, close recreational facilities, and restrict access to lakes. This bill exempts public or private agencies that operate a water supply system from such enforcement activities if the operator of the facilities has prepared and implemented a prescribed plan to control or eradicate dreissenid mussels. These requirements have been incorporated into the FGC beginning with This bill established FGC 2301, which applies to infested waterbodies, see details below. Assembly Bill 2065 This 2008 bill requires a water district that owns or manages a waterway to develop and implement a monitoring and control program to prevent the introduction of nonnative mussel species, thereby imposing a state-mandated local program. This bill established FGC 2302, which applies to uninfested waterbodies as discussed below. California Fish and Game Code Sections 2301 and 2302 FGC 2301 provides CDFW with the authority to protect the state from invasive mussels. FGC 2301 relates to containment plans and applies to bodies of water infested with dreissenid mussels. It allows CDFW and other designated officials to inspect any conveyance (e.g., vehicles, boats and other watercraft, containers, and trailers) that may contain dreissenid mussels; order areas within conveyances that contain water to be drained, dried, or decontaminated; and quarantine conveyances for the time needed to ensure all mussels on the conveyance have died. CDFW can also conduct inspections of surface waters and facilities located within an area that may contain mussels and, in some cases, restrict access to waters or facilities that are or may be infested with mussels. No closure, quarantine, or restriction shall be authorized without the concurrence of the Secretary of the Natural Resources Agency. If a closure lasts longer than 7 days, CDFW shall update the operator of the affected facility every 10

53 days on efforts to address the dreissenid infestation. Methods for notifying affected federal, state, and local agencies of a decision to close, quarantine, or restrict a facility also are specified. FGC 2301 specifies that a public or private agency that operates a water supply system shall cooperate with CDFW to implement measures to avoid infestation of dreissenid mussels and to control or eradicate any infestation that may occur in a water supply system. If dreissenid mussels are detected, the operator of the water supply system, in cooperation with CDFW, shall prepare and implement a plan to control or eradicate dreissenid mussels within the system. The approved plan must contain the following minimum elements: > Methods for delineation of infestation, including both adult mussels and veligers. > Methods for control or eradication of adult mussels and decontamination of water containing larval mussels. > A systematic monitoring program to determine any changes in conditions. > The requirement that the operator of the water supply system permit inspections by CDFW as well as cooperate with CDFW to update or revise control or eradication measures in the approved plan to address scientific advances in the methods of controlling or eradicating mussels and veligers. If the operator of the water delivery and storage facilities for public water supply purposes has prepared, initiated, and is in compliance with all the elements of an approved plan to control or eradicate dreissenid mussels, the requirements outlined above do not apply to the operation of those water delivery and storage facilities, and the operator is not subject to any civil or criminal liability for the introduction of dreissenid mussels as a result of those operations. CDFW may not close the water delivery facilities operated to provide water supply if an operator has prepared and implemented a control/eradication plan for mussels. The Quagga Mussel Monitoring and Control Plan for Lake Piru complies with the requirements for a plan established by FGC 2301.FGC 2302 relates to prevention programs and defines the responsibilities of reservoir owners or managers in uninfested waters. Owners and managers must assess the reservoir vulnerability to mussel infestation and develop a prevention program that includes monitoring, public education, and management of recreational activities. United had a prevention program per FGC 2302 prior to mussels being detected at Lake Piru. California Code of Regulations, Title 14, Sections California Code of Regulations, Title 14, Section 672 took effect on April 1, 2016 and was developed under the authority of FGC Sections 702, 2301, and 2302 to address the overall possession, importation, and transportation of quagga mussels. Section covers quagga mussel control and prevention and includes requirements for a control plan, prevention program, and the inspection of conveyances. Section 672.1(a) specifies the timeline for preparation and submittal of a control plan, the required content for the plan, and annual reporting requirements. Section 672.1(b) requires the development and submittal of a prevention program that addresses three key elements: 1) an assessment of vulnerability for the introduction of both adult and veliger quagga mussels; 2) a monitoring program to detect the presence of adult and/or veliger

54 quagga mussels; and, 3) management of recreational activities to prevent the introduction of quagga mussels. Section 672.1(b) also requires the submittal of annual reports to demonstrate program implementation. Lastly, Section discusses the penalties for violating the regulation and the associated appeal procedures. California Lake and Streambed Alteration Program (FGC 1600 et seq.) This program requires any person, state, or local government agency, or public utility proposing a project that could divert, obstruct, or change the natural flow of any bed, channel, or bank of a river, stream, or lake to notify CDFW before beginning the project. If CDFW determines that the project could adversely affect existing fish and wildlife resources, a Lake or Streambed Alteration Agreement is required. Such an agreement would be required if the control measures caused the effects listed above. California Endangered Species Act (FGC ) The California Endangered Species Act (CESA) prohibits the take of listed species without authorization from CDFW. CDFW may authorize the take of listed species if certain conditions are met. If United undertakes control measures that could result in the take of species listed under CESA, then United will need to comply with the CESA. California Environmental Quality Act California Environmental Quality Act (CEQA) requires state and local agencies to identify the significant environmental impacts of their actions and to avoid or mitigate those impacts, if feasible. Implementation of the control measures identified in this plan would require discretionary approval by United s Board of Directors and would have impacts on the environment; thus, compliance with CEQA will be required. United will comply with CEQA requirements associated with any proposed management action that would trigger CEQA review. Department of Pesticide Regulation (DPR) The California Department of Pesticide Regulation (DPR) regulations must be considered relative to any chemical used to control quagga and zebra mussels in waterways such as Lake Piru. DPR should be consulted prior to the use of any chemical control measures. If the product is registered with DPR, a NPDES permit for Residual Pesticide Discharges to the Waters of the United States is required. If the product is not registered with DPR, the product must undergo the DPR registration process, a NPDES permit from the Regional Water Quality Control Board will be required, or an emergency exemption may be obtained based on circumstances. County of Ventura Requirements The Piru Area Plan of the Ventura County General Plan (Ventura County Planning Division 2011) specifies that Lake Piru should be managed by United for multiple purposes, where appropriate (e.g., water conservation, recreation, and hydroelectric generation). Thus, control measures intended to protect water supplies and recreational uses would be consistent with the management purposes of the lake. Control measures, such as drawdown of the lake, may not be consistent with these purposes.

55 A Watercourse Permit is required by the Ventura County Watershed Protection District for any work or project affecting the bed, banks, and overflow areas of District jurisdictional red line channels. An Encroachment Permit is required when the work or project encroaches into the real estate holdings of the District. Specifically, a written District permit is required prior to any act that would: > Impair, divert, impede, or alter the characteristics of the flow of water running in a watercourse. > Deposit any material of any kind in a watercourse so as to obstruct it, or to impair, divert, impede, or alter the characteristics of flow of water therein. > Construct or place any structure in, upon, or across a watercourse. > Commit any act on or in any easement dedicated, granted, or reserved for flood control, storm water drainage, or water conservation purposes that will impair the use of such easement for such purposes. Permits also may be required for control measures that resulted in altered stream flows. Permits may be required for control measures that result in altered stream flows. Permits also may be required should control measures be implemented in lower Piru Creek and the Santa Clara River in the future. United will evaluate options for control measures and consult with state/federal agencies on possible measures and their effects on listed species in lower Piru Creek. If the consultation determines that measures are feasible, and these measures require a Watercourse Permit from Ventura County, United will engage the County at that time.

56 APPENDIX B Plankton Tow Monitoring Protocol

57 California Department of Fish and Wildlife Quagga/Zebra Mussel Plankton Tow Sampling Protocol Purpose of Sampling: Plankton tow sampling is a form of early detection monitoring for quagga and/or zebra mussel veligers, the planktonic larval life stage, whereby small organisms (plankton) are collected by pulling a fine-mesh net through the water column (referred to as a tow ). The plankton collected is then analyzed in a laboratory for the presence of veligers using cross-polarized light microscopy (CLPM) and/or DNA using PCR analysis. To optimize the potential for detecting veligers, if present, plankton tows should follow a standardized sampling method, sample a large volume of water, and target the times and locations where veligers are most likely to occur. Of equal importance, samples must be preserved and handled properly in order to maintain their integrity so analysis yields accurate results. To enhance early detection, monitoring for adult mussels should be conducted along with plankton tow sampling. Monitoring for adult mussels can be achieved by conducting monthly inspections of artificial substrate samplers and by surveying surfaces of shoreline, multiple habitat types and structures located in high use areas. Separate protocols for these methods are available at When and Where to Sample: Water Temperature Plankton monitoring is typically conducted when water temperatures are between 9 C - 18 C (48 F - 64 F), when spawning is occurring. In warmer regions, where water temperatures remain within this range throughout the year, mussels can spawn year round. It is recommended tows be conducted monthly when temperatures are conducive to spawning. Locations Veliger distribution can be highly localized; therefore sampling should occur throughout the waterbody at multiple sites to increase the potential for detection. Sampling sites should include areas of high use and likely sites of mussel introductions such as around docks, boat launch ramps, floating restrooms, marinas, at inlets and outlets of the 1 CDFW Quagga/Zebra Mussel Plankton Tow Sampling Procedure. October 2015

58 waterbody (mouth of tributaries; dams), and in downwind areas and eddies (which can be identified by the accumulation of leaves, pollen, and debris on the surface of the water). Depth To increase the probability of capturing veligers if they are present, tow depths of 15 meters are recommended. Number of Sites and Number of Tows The number of sites within a waterbody should be based on the size of the waterbody. A minimum of three sites is recommended. The number of tows at each site should be based on the net diameter and the depth of each tow. A minimum total volume of 1000 liters per site should be filtered through the net. Based on the diameter of the net and the depth of each tow, the number of tows per site to filter 1000 liters can be calculated (Appendix B). Summary of Sampling Recommendations Parameter Water temperature Locations Depth Number of sampling sites per waterbody Number of tows per sampling site Total volume sampled Recommendation 9 C - 18 C (48 F - 64 F) Around floating structures, marinas, inlets and outlets, coves, down-wind areas and eddies 0 15 m (0 50') Variable; based on size of waterbody, minimum of 3 Variable; based on depth and net size Minimum 1000 liters (264 gallons) per site Disclaimer: recommendations of equipment and supplies by brand or vendor are made only for the convenience of the user. Recommendations are not an endorsement and equipment or supply items of other brands that are offered by vendors may work just as well. 2 CDFW Quagga/Zebra Mussel Plankton Tow Sampling Procedure. October 2014

59 Equipment and Supplies: Plankton tow net 63 or 64 micron mesh size - 8 inch diameter (WildCo part number 426-A28 recommended) - 12 inch diameter (Aquatic Research Instruments simple plankton net recommended) Tow rope 100 foot minimum with 1 or 5 meter graduation marks Ballast weight optional, use if needed Collection/sample bottles plastic wide mouth 250 or 500 ml capacity Sample labels Environmental Sampling Supply 2 X 3 inches, part no recommended (labels are sometimes provided with a bottle order) Ink pen/pencil Plankton Tow field data sheets Lab sample submission/ chain of custody (COC) form Notebook/ notepad Sharpie-type marker Hand calculator Spool for tow rope Carabineer Eighteen (18) gallon Rubbermaid tote with lid 23.9 X 15.9 X 16.5 inch White vinegar (approximately 5% acetic acid) Household bleach (approximately 6% hypochloride) Spray bottle 32 oz. (grey Spraymaster type recommended) Measuring cup with graduations for milliliters or ounces Zip lock bags 1 gallon Ruler with 1 mm graduations Non-denatured ethanol (200 proof) Baking soda, 4% solution in distilled water (W/V) ph paper (Whatman type CF ph range recommended) Blue ice or gel packs Cooler large enough to retain all samples Boat 3 CDFW Quagga/Zebra Mussel Plankton Tow Sampling Procedure. October 2014

60 Optional Equipment and Supplies: Bucket, 1-5 gallons Tools and tool box Camera Depth finder Multi-parameter water quality meter GPS unit Write-in-the-rain paper Clip board Cell phone Personal floatation devices First aid kit Fire extinguisher Batteries, all size Equipment Preparation Prior to Collection 1. Decontaminate nets and related equipment before use. The decontamination protocol is provided in Appendix A. 2. If necessary affix a ballast weight to the net assembly. 3. Options for marking the tow rope: A. Measure the tow rope in 1 or 5 meter intervals B. Using a Sharpie type marker or labeling tape mark the rope at 1 or 5 meter intervals (markers can bleed or run during the decontamination process). C. Or, electrical shrink wrap can be used to mark the rope at 1 or 5 meter intervals. a. To do this obtain electrical shrink wrap slightly larger than the rope s diameter b. Cut the shrink wrap in inch segments c. Measure and mark the rope with a pen at 1 or 5 meter intervals d. Slide the appropriate number of shrink wrap segments on the rope e. Place one over each marked meter f. Heat the shrink wrap with a blow torch or hair dryer (the heat will shrink the wrap in place) 4. It is highly recommended that the tow rope be loaded onto a spool. 5. Blue ice / gel packs need to be frozen. 6. A refrigerator must be available for storage after collection. 7. Prepare 4% baking soda solution per Appendix B. 4 CDFW Quagga/Zebra Mussel Plankton Tow Sampling Procedure. October 2014

61 Vertical Tow Protocol Note: A minimum of 1000 liters should be filtered from a given site. See Appendix B for example calculations. 1. If using a net with a valve, make sure the valve is closed; lower the net off the side of the boat perpendicular to the surface of the water. Lower the net 15 meters or 1 meter above the bottom, whichever is deeper. 2. Count the graduation marks and record the depth of the net. Depth distance information is needed to determine the volume of water sampled. 3. Do not allow the net to contact the bottom of the water body. Touching the bottom will clog the net. If this happens, draw the net back up to the surface and thoroughly wash all of the material off. Do not dispense any of the bottom material into the sample bottle. 4. Pull the net up at a rate of about ½ meter per second. Pulling at a faster rate will create a wave in front of the net that will reduce filtering efficiency and may also damage veligers. 5. As the net is drawn towards the surface, maintain vertical alignment so that the center axis of the net is perpendicular to the surface of the water. 6. After the net is drawn above the water line slowly dip the net in and out of the water several times while maintaining vertical alignment to wash any material clinging to the inner surface of the net into the cod end. Do not submerge the bridle ring while dipping the net. 7. Depending on how the cod end is configured, dispense or decant the tow material into the sample bottle. Repeat steps 1-7 until a minimum of 1000 liters of water has been filtered through the net. 8. Label the bottle with the waterbody, site name, date/time and name of collector, preservation type, analysis type, and agency. 9. Complete the field data sheet and the Lab Submission Form located at the end of Appendix D. 10. Place the bottle in a cooler with gel packs or blue ice. 11. Continue to the next site. Samples must remain chilled to prevent degradation. Samples should be preserved in the parking lot per the preservation protocol found in Appendix C. 5 CDFW Quagga/Zebra Mussel Plankton Tow Sampling Procedure. October 2014

62 Horizontal Tows Vertical tows are preferred to horizontal tows. However, horizontal tows may be required when sampling shallow water. 1. If the water is stagnant or the flow rate is slow, the net can be pulled in a horizontal direction with the net below the surface. A ballast weight may have to be attached to keep the net submerged. 2. The total length of the tow can be determined using the graduation marks on the tow rope. 3. See Appendix B for example calculations. Sample Identification 1. Samples need to be marked for identification when received at the Shellfish Health Lab. Adhesive labels should be used and information should be recorded with permanent ink. Ethanol used for preservation will cause ink to run; therefore, ethanol must be kept off any labels or identification markings. It is recommended that bottles be marked with a waterbody and site name (use of abbreviations is ok), preserved and then have the label, with more detail, placed on each bottle. 2. Include a lab sample submission/chain of custody (COC) form with all shipments and deliveries. A copy of the submission form is included in this document at the end of Appendix D. Important information to include is: date of collection, the collector s name, waterbody name, description of locations, GPS data or waypoint, total tow depth, water depth, net hoop diameter, time and means of preservation, and both storage condition and storage location prior to shipment. Appendices A. Decontamination protocol for equipment used to collect plankton samples for quagga and zebra mussel larvae detection analysis. B. Reagent preparation and plankton tow calculations. C. Plankton tow preservation protocol for the detection of quagga and zebra mussel veliger larvae D. Sample submission guidelines and sample submission form E. CDFW regional office contacts for aquatic invasive species monitoring 6 CDFW Quagga/Zebra Mussel Plankton Tow Sampling Procedure. October 2014

63 Appendix A Decontamination protocol for equipment used to collect plankton tow samples for quagga and zebra mussel larvae detection analysis After the tow samples have been collected from a water body all equipment coming into contact with the water must be decontaminated prior to use elsewhere. For thorough decontamination, equipment will have to be soaked in an acetic acid solution (vinegar) and then sprayed with a 10% bleach solution. The vinegar dissolves the veliger s shell but will not denature DNA. The bleach will denature DNA but will not dissolve shells. Therefore, the vinegar must be used before the bleach so DNA will be exposed to the denaturing bleach. Vinegar and bleach can present safety hazards if not used properly. Material Safety Data Sheets (MSDS) are included at the end of this appendix for both vinegar and bleach. Heed all MSDS precautions and follow all MSDS procedures, practices, safeguards and requirements when using vinegar and bleach. Protocol: 1. Place items to be decontaminated in the 18 gallon Rubbermaid tote. 2. Fill the tote with enough household vinegar to completely cover all of the items. 3. Soak the items in vinegar for a minimum of 2 hours (24 hours is preferred). 4. After soaking in vinegar thoroughly rinse the items in tap water. 5. Spray the items with a 10% bleach solution and allow the items to sit for 15 minutes. 6. Alternatively, a 10% bleach solution can be prepared in a Rubbermaid tote or a similar type of container and used to soak items for 15 minutes following the vinegar soak. 7. After the bleach treatment, thoroughly rinse all of the items off with tap water and allow them to air dry. The vinegar can be reused multiple times. It s recommended that vinegar be poured back into the original container for storage. The ph of the vinegar should be checked periodically to make sure the value is approximately 2 to 3. This can be done with ph paper. Appendix A. Plankton Tow Sampling Equipment Decontamination Protocol. October 2014

64 The Clorox Company 1221 Broadway Oakland, CA Tel. (510) Material Safety Data Sheet I Product: CLOROX REGULAR-BLEACH Description: CLEAR, LIGHT YELLOW LIQUID WITH A CHARACTERISTIC CHLORINE ODOR Other Designations Distributor Emergency Telephone Nos. Clorox Bleach EPA Reg. No II Health Hazard Data Clorox Sales Company 1221 Broadway Oakland, CA III Hazardous Ingredients For Medical Emergencies call: (800) For Transportation Emergencies Chemtrec (800) DANGER: CORROSIVE. May cause severe irritation or damage to eyes and skin. Vapor or mist may irritate. Harmful if swallowed. Keep out of reach of children. Some clinical reports suggest a low potential for sensitization upon exaggerated exposure to sodium hypochlorite if skin damage (e.g., irritation) occurs during exposure. Under normal consumer use conditions the likelihood of any adverse health effects are low. Medical conditions that may be aggravated by exposure to high concentrations of vapor or mist: heart conditions or chronic respiratory problems such as asthma, emphysema, chronic bronchitis or obstructive lung disease. FIRST AID: Eye Contact: Hold eye open and rinse with water for minutes. Remove contact lenses, after first 5 minutes. Continue rinsing eye. Call a physician. Skin Contact: Wash skin with water for minutes. If irritation develops, call a physician. Ingestion: Do not induce vomiting. Drink a glassful of water. If irritation develops, call a physician. Do not give anything by mouth to an unconscious person. Inhalation: Remove to fresh air. If breathing is affected, call a physician. IV Special Protection and Precautions Ingredient Concentration Exposure Limit Sodium hypochlorite 5-10% Not established CAS# Sodium hydroxide <1% 2 mg/m 1 CAS# mg/m 2 1 ACGIH Threshold Limit Value (TLV) - Ceiling 2 OHSA Permissible Exposure Limit (PEL) Time Weighted Average (TWA) None of the ingredients in this product are on the IARC, NTP or OSHA carcinogen lists. V Transportation and Regulatory Data No special protection or precautions have been identified for using this product under directed consumer use conditions. The following recommendations are given for production facilities and for other conditions and situations where there is increased potential for accidental, large-scale or prolonged exposure. Hygienic Practices: Avoid contact with eyes, skin and clothing. Wash hands after direct contact. Do not wear product-contaminated clothing for prolonged periods. Engineering Controls: Use general ventilation to minimize exposure to vapor or mist. Personal Protective Equipment: Wear safety goggles. Use rubber or nitrile gloves if in contact liquid, especially for prolonged periods. KEEP OUT OF REACH OF CHILDREN VI Spill Procedures/Waste Disposal Spill Procedures: Control spill. Containerize liquid and use absorbents on residual liquid; dispose appropriately. Wash area and let dry. For spills of multiple products, responders should evaluate the MSDS s of the products for incompatibility with sodium hypochlorite. Breathing protection should be worn in enclosed, and/or poorly ventilated areas until hazard assessment is complete. Waste Disposal: Dispose of in accordance with all applicable federal, state, and local regulations. VIII Fire and Explosion Data Flash Point: None Special Firefighting Procedures: None Unusual Fire/Explosion Hazards: None. Not flammable or explosive. Product does not ignite when exposed to open flame. DOT/IMDG/IATA - Not restricted. EPA - SARA TITLE III/CERCLA: Bottled product is not reportable under Sections 311/312 and contains no chemicals reportable under Section 313. This product does contain chemicals (sodium hydroxide <0.2% and sodium hypochlorite <7.35% ) that are regulated under Section 304/CERCLA. TSCA/DSL STATUS: All components of this product are on the U.S. TSCA Inventory and Canadian DSL. VII Reactivity Data Stable under normal use and storage conditions. Strong oxidizing agent. Reacts with other household chemicals such as toilet bowl cleaners, rust removers, vinegar, acids or ammonia containing products to produce hazardous gases, such as chlorine and other chlorinated species. Prolonged contact with metal may cause pitting or discoloration. IX Physical Data Boiling point...approx. 212F/100C Specific Gravity (H 2 0=1)... ~ 1.1 at 70 o F Solubility in Water... complete ph...~ , 1991 THE CLOROX COMPANY DATA SUPPLIED IS FOR USE ONLY IN CONNECTION WITH OCCUPATIONAL SAFETY AND HEALTH DATE PREPARED 08/09

65 Fisher Science Education 6771 Silver Crest Road, Nazareth, PA (800) Emergency Number: (800) Page 1 of 3 S25623 Material Safety Data Sheet Section 1 Chemical Product and Company Identification Catalog Numbers: S25623 Product Identity: Distilled White vinegar 5% Chemical Family: Not Applicable Synonyms: No Information Available Recommended Use: Laboratory chemicals Manufacturer s Name: AquaPhoenix Scientific, Inc., 9 Barnhart Dr., Hanover, PA 17331, (866) Emergency Contact Number (24hr): Chemtel (800) Issue Date: 01/03/07 Revision Date: 02/19/12, 08/03/12 Section 2 Hazard Identification Emergency Overview: If ingested give large quantities of water. Get medical attention. Wash areas of contact for at least 15 minutes. Appearance: Clear, colorless liquid Odor: Vinegar-like Target Organs: Eyes, skin, respiratory system, teeth. Potential Health Effects/ Routes of Exposure: Eyes: Causes irritation, redness, pain, tearing. Skin: Causes irritation, redness and pain. Ingestion: May cause irritation of the digestive tract. Inhalation: Not likely to be a hazard by inhalation. Chronic Effect / Carcinogenicity: None (IARC, NTP, OSHA) Aggravated Medical Conditions No information Available. These chemicals are considered hazardous by OSHA. See section 11 for toxicological information. See section 12 for potential environmental effects. Section 3 Composition, Information on Ingredients Acetic Acid, CAS# , 5% v/v Water, purified, CAS# , 95% w/v Section 4 First Aid Eyes: Immediately flush eyes with water for at least 15 minutes. Get medical assistance immediately. Skin: Flush with water for 15 minutes. Get medical assistance if irritation develops. Ingestion: DO NOT induce vomiting. Dilute with water or milk. Get medical assistance. Inhalation: Remove to fresh air. Give artificial respiration if necessary. If breathing is difficult, give oxygen. Notes to Physician Treat symptomatically. Section 5 Fire Fighting Measures Flash Point: No information Available Autoignition Temperature: No information Available Explosion Limits Upper No Information Available Lower No Information Available

66 Extinguishing Media: Any means suitable for extinguishing surrounding fire. Unsuitable Extinguishing Media: No information available Fire & Explosion Hazards: Not considered to be a fire or explosion hazard Fire Fighting Instructions / Equipment: Use normal procedures. Use protective clothing. Use NIOSHapproved breathing equipment. Hazardous Combustion Products: No information Available. Sensitivity to mechanical impact No information available. Sensitivity to static discharge No information available. Specific Hazards Arising from the Chemical: No information available NFPA Rating: (estimated) Health: 2; Flammable: 0; Reactivity: 0 Section 6 Accidental Release Measures Personal Precautions Use personal protective equipment. Ensure adequate ventilation. Avoid contact with skin, eyes and clothing. Remove from all sources of ignition. Environmental Precautions Should not be released into environment. Methods for Containment and Clean Up Soak with inert material. Keep in suitable and closed containers for disposal. Always obey local regulations. Section 7 Handling and Storage Handling: Wash hands after handling. Avoid contact with skin and eyes. Wear personal protective equipment. Storage: Keep container tightly closed. Store in a cool, dry, well-ventilated area. Protect from freezing. Section 8 Exposure Controls, Personal Protection Acetic Acid, CAS# , ACGIH TLV: 25mg/m3, OSHA PEL: 25mg/m3 Water, purified, CAS# , ACGIH TLV: NA, OSHA PEL: NA Engineering Measures/ General Hygiene: Normal ventilation is adequate Personal Protection Equipment: Skin Protection: Chemical resistant gloves. Eye/Face Protection: Safety Glasses or goggles. Respiratory Protection: Normal ventilation is adequate Section 9 Physical and Chemical Properties Appearance/Physical State: Clear, colorless liquid Odor: Vinegar-like % Volatility: No Information Available Boiling Point: C Specific Gravity: No Information Available Melting Point: 16.6C Vapor Pressure: No Information Available Vapor Density: 2.07 Flash Point: No information Available Evaporation Rate: No information Available Coefficient of water/oil distribution: Not Available ph: Acidic Odor Threshold: Not Available Flammability: No Information Available Decomposition Temperature: No Information Available Solubility: Infinite Partition Coefficient n-octanol/water: Not Available Relative Density: No Information Available Molecular Weight: Section 10 Stability and Reactivity Chemical Stability: Stable under normal conditions of use and storage. Incompatible Materials: Strong bases Conditions to Avoid: No information Available Hazardous Decomposition Products: irritating fumes Hazardous Polymerization: Does not occur Hazardous Reactions: None under normal processing. Section 11 Toxicological Information Routes of Exposure/Symptoms/Corrosiveness See Section 2 LD50 orl-rat: 3310 mg/kg (Acetic Acid) LC50 inhalation-rat: 5620 ppm/ 1hr. (Acetic Acid) Irritation: No information Available Page 2 of 3 S25623

67 Toxicologically Synergistic: No Information Available Chronic Exposure Carcinogenicity No known carcinogenic chemicals. Sensitization No information available. Mutagenic Effects not mutagenic in AMES test. Reproductive Effects Experiments have shown reproductive toxicity effects on laboratory animals for acetic acid. Developmental Effects (Immediate/Delayed) No information available. Teratogenicity No information available. Other Adverse Effects No information available. Endocrine Disruptor Information No information available. Section 12 Ecological Information Ecotoxicity: Acetic Acid has high biochemical oxygen demand, and a potential to cause oxygen depletion in aquatic systems. Persistence and Degradability: Expected to be biodegradable Mobility: No Information Available Bioaccumulation/ Accumulation: No Information Available Section 13 Disposal Considerations Chemical waste generates must determine whether a discarded chemical is classified as a hazardous waste. Comply with all local, state, and federal regulations. Section 14 Transport Information DOT Not Regulated Section 15 Regulatory Information (not meant to be all inclusive) OSHA Status: These chemicals are considered hazardous by OSHA. Canada DSL: This chemical is listed on Canada s DSL list. TSCA: These chemicals are listed on the TSCA Inventory. SARA Title III Section 313: Not Applicable RCRA Status: Not Applicable CERCLA Reportable Quantity: Acetic Acid 5000lbs. WHMIS: Not-controlled Section 16 Additional Information Disclaimer: The information on this MSDS applies to this specific material as supplied. It may not be valid for this material if it is used in combination with any other materials. It is the user s responsibility to determine the suitability and completeness of this information for his own particular use. No warranty is implied regarding the accuracy of the data or the results to be obtained form the products use. Page 3 of 3 S25623

68 Appendix B Reagent preparation and plankton tow calculations A. Conversions To convert feet to meters multiply by To convert inches to centimeters multiply by 2.54 To convert cubic meters to liters multiply by 1000 Conversions if a measuring cup is used: 1 ounce = approximately 30 milliliters 1 cup = 8 ounces 1 cup = approximately 250 milliliters B. Preparation of a 4% baking soda (sodium bicarbonate) solution Use the following formula to prepare a 4 % by weight (W/V) solution: grams of baking soda to add = 0.04 g baking soda x desired volume in ml Example: to make a 1 liter solution of 4% baking soda solution, add 40 grams of baking soda to 1000 milliliters of deionized water. A standard 28 mm soda bottle cap holds about 5 grams of baking soda and ½ teaspoon of baking soda is about 3 grams. These values can be used to prepare a solution that is approximately 4% baking soda. For example, adding a level soda bottle capful of baking soda to a 250 ml Nalgene container that is approximate ½ full with water would provide a solution of baking soda close enough to 4% that it could be used to adjust the ph of plankton tow samples per the protocol described in Appendix A. C. Preparation of a 10% bleach (sodium hypochlorite) solution Use the following formula to prepare a 10% bleach solution 0.1 x total volume of solution desired = volume of bleach to add Example: Add 50 milliliters of bleach to 450 milliliters to prepare a 10% bleach solution (V/V). A measuring cup can be used to measure the bleach and water at a 1:10 proportion. It s recommended that the bleach solution be prepared in a 32 oz. Spraymaster (gray) spray bottle. The gray bottle will help protect the bleach from degradation. Appendix B. Reagent Preparation and Plankton Tow Calculations. October 2014

69 D. Determination of a vertical tow volume in liters To determine a vertical tow volume multiply the area of the plankton net hoop by the total depth of all the tows in the sample bottle and then multiply by Round the value to 2 significant figures. area of the net hoop (m 2 ) x tow depth (m) x 1000 liters / m 3 = total tow volume (L) Table 1 Relationship between net diameter, area of the net hoop and the minimum tow depth required to achieve a 1000 liter tow volume Net Diameter Area of Plankton Net Hoop Minimum Tow Depth to get 1000 Liters Total Volume 5 inches (13 cm) 0.01square meters 100 meters 8 inches (20 cm) 0.03 square meters 33.4 meters 12 inches (30 cm) 0.07 square meters 14.3 meters 20 inches (50 cm) 0.20 square meters 5.3 meters Example: A 30 cm net is used to collect 3 x 20 meter tows. All 3 of the tows are dispensed into the sample collection bottle m 2 x 60 m x 1000 L / m 3 = 4200 liters of source water represented in the bottle E. Determination of horizontal tow volume in liters It is difficult to determine horizontal volume. An estimate can be made in the same way vertical tow volume is calculated. That is, the length of the tow in meters multiplied by the hoop diameter in square meters then multiplied by 1000 L / m 3. Horizontal tows do not account for veliger depth distribution and there is often a lot of sediment in horizontal tows. For these reasons horizontal tows are discouraged. Appendix B. Reagent Preparation and Plankton Tow Calculations. October 2014

70 Appendix C Plankton tow preservation protocol for the detection of quagga and zebra mussel veliger larvae Objective: Preserve the integrity of veliger shells and tissues in plankton tow samples so that veligers are amenable to PCR and CPLM analysis. Summary: Add 5 ml of a 4% (W/V) baking soda solution per 100 ml plankton tow sample then bring the volume to 20% absolute ethanol (V/V). Protocol: 1. After tows have been poured into the collection bottle, mark the level with a Sharpie and measure the height of the liquid using a ruler with millimeter graduations. 2. Divide the height measurement by The quotient is the level to which the 4% baking soda solution is added. This will be a relatively small quantity. A small cup should be used to pour the solution into the tow. 4. Divide the measurement in step 1 by The quotient is the level to which absolute ethanol is added. 6. The sample is now preserved. Store the sample under refrigeration conditions until shipping. Note: After the addition of baking soda and ethanol the ph of the sample should be 8.0 or slightly higher. The ph can be measured in the field with ph paper. If the ph is below 8.0, add more baking soda solution. The ph of the sample will also be measured in the laboratory at the time of analysis and reported with results. A ph below 8.0 at the time of analysis means that more baking soda solution should be added at the time of preservation 1 Appendix C. Plankton Tow Preservation Protocol. October 2014

71 Example preservation calculations: Tow samples are collected and dispensed into a 250 ml Nalgene container. The tow sample level is measured at 65 mm. 65 mm / 0.95 = 68.4 mm (~ 68 mm) mark 68 mm on the bottle and add the baking soda solution to this level. 65 mm / 0.76 = 85.5 mm (~ 86 mm) mark 86 mm on the bottle and add absolute ethanol to this level. Note: Samples must remain chilled. All samples should be placed in a cooler with gel or blue ice packs immediately after collection so they do not warm up and begin to degrade. Do not freeze the samples. Freezing damages shells and reduces detection sensitivity. Samples need to be preserved as soon as possible after collection (no more than 3 hours after collection). 2 Appendix C. Plankton Tow Preservation Protocol. October 2014

72 Appendix D Sample submission guidelines and submission form Note: The California Department of Fish and Wildlife Shellfish Health Laboratory is located at the UC Davis Bodega Marine Laboratory. As per the instructions below, samples need to be mailed to the Bodega Marine Laboratory where they will be routed to the Shellfish Health Laboratory. Samples may also be hand delivered to the Shellfish Health Lab per the instructions below. Authorized Submissions: Samples submitted to the Bodega Marine Laboratory Shellfish Health Lab (SHL) are usually collected by California Department of Wildlife (CDFW) personnel or individuals working with CDFW personnel. The SHL accepts samples from any California State, out-of-state, or federal personnel qualified to collect samples. The SHL will also accept samples from water management personnel and academic institutions. Laboratory capacity is limited. First priority will be given to CDFW submissions. Compromised samples will not be tested. It is recommended that sample collection follow the CDFW Quagga/Zebra Mussel Plankton Tow Sampling Protocol Sample Delivery Options: Properly preserved and maintained plankton tow samples collected for lab analysis may be either hand delivered or shipped to the SHL. Include a sample submission form with each set of samples. Make sure samples are clearly marked for identification. Samples should be delivered or shipped to the SHL within 1 week of collection. Contact Information: Contact Jim Snider at the SHL for any questions regarding quagga/zebra mussel testing. Phone: (707) James.Snider@wildlife.ca.gov Hand Delivered Samples: Hand delivered samples should be transported in a cooler and maintained at refrigeration temperature during transport. Samples may be hand delivered during normal business hours; Monday through Friday, 9:00 am to 5:00 pm. The lab is closed on weekends and holidays. Call Jim Snider prior to delivery to make sure personnel will be available to receive samples. Arrangements may be made for afterhours deliveries, contact Jim Snider for arrangements. Appendix D. Sample Submission Guidelines. October 2014

73 Shipping Samples: Shipped samples should be packaged in a styrofoam packer (or a similar type cold packer) contained secondarily in a cardboard box. Use gel packs to keep samples chilled. Do not use wet ice. The Bodega Marine Lab (BML) shipping and receiving department is open Monday through Thursday and closed on Fridays, weekends, and holidays. All freight must be received no later than Thursday in any given week. Samples should be shipped for next day delivery. Samples that are held over the weekend by the courier service will be considered compromised and will not be tested. Samples collected late in the week may be held over the weekend if properly preserved and refrigerated and shipped the following week. Location: The location of the BML can be found at: &spn= , &ctz=420&t=m&z=13 The CDFW Shellfish Health Lab is located in rooms N307 and N310. Entrance to the BML is gated. The gate closes at 5:00 pm. Shipping Address: Bodega Marine Laboratory Shellfish Health Attention Jim Snider 2099 Westside Road Bodega Bay, CA Reporting Results: Results will be reported in letter or memo format and will be ed to designated contacts. Laboratory Fees: Currently there is no fee for quagga/zebra mussel plankton tow testing at the SHL. Appendix D. Sample Submission Guidelines. October 2014

74 CDFW Shellfish Health Laboratory Submission Form Quagga/Zebra Mussel Plankton Tows Name: Agency: Phone #: Mailing Address: Waterbody: Site Location: Title: Was the sample preserved at the time of collection with baking soda and 20% absolute ethanol and stored at refrigeration temperature as per Appendix A: Plankton tow preservation protocol for the detection of quagga and zebra mussel veliger larvae in this Document? Yes No If no, please specify the preservation method used: Plankton Net Diameter (include units): Plankton Net Mesh Size (include units): Sample No. Collection Date Sample Description Indicate Horizontal or Vertical Tow (H or V) Total Tow Depth in Container (indicate feet or meters) Appendix D. Sample Submission Form. October 2014

75 Appendix E CDFW regional office contacts for aquatic invasive species monitoring Contact information subject to change. For the most up to date information refer to: Region 1 Northern Region Counties: Del Norte, Humboldt, Lassen, Mendocino, Modoc, Shasta, Siskiyou, Tehama, and Trinity 601 Locust Street, Redding, CA L. Breck McAlexander Louis.McAlexander@wildlife.ca.gov Office: (530) Fax: (530) Region 2 North Central Region Counties: Alpine, Amador, Butte, Calaveras, Colusa, El Dorado, Glenn, Lake, Nevada, Placer, Plumas, Sacramento, San Joaquin, Sierra, Sutter, Yolo and Yuba 1701 Nimbus Road, Rancho Cordova, CA Angie Montalvo Angie.Montalvo@wildlife.ca.gov Mobile (530) Fax: (916) Region 3 Bay Delta Region Counties: Alameda, Contra Costa, Marin, Napa, Sacramento, San Mateo, Santa Clara, Santa Cruz, San Francisco, San Joaquin, Solano, Sonoma, and Yolo 7329 Silverado Trail, Napa, CA Catherine Mandella Catherine.Mandella@wildlife.ca.gov Mobile: (831) Fax: (707) Region 4 Central Region Counties: Fresno, Kern, Kings, Madera, Mariposa, Merced, Monterey, San Benito, San Luis Obispo, Stanislaus, Tulare and Tuolumne 1234 E. Shaw Avenue, Fresno, CA Kelley Aubushon Kelley.Aubushon@wildlife.ca.gov Office: (559) X-285 Fax: (559) Appendix E. CDFW regional office contacts for aquatic invasive species monitoring

76 Region 5 South Coast Region Counties: Los Angeles, Orange, San Diego, Santa Barbara and Ventura 4665 Lampson Avenue, Los Alamitos, CA Eloise Tavares Eloise.Tavares@wildlife.ca.gov Office: (562) Fax: (562) Region 6 Inland Deserts Region Counties: Imperial, Inyo, Mono, Riverside and San Bernardino P.O. Box 2160, Blythe, CA David Vigil David.Vigil@wildlife.ca.gov Mobile: (760) Fax: (760) Appendix E. CDFW regional office contacts for aquatic invasive species monitoring

77 APPENDIX C Alternative Actions Considered Infeasible

78 Introduction Since the initial discovery of quagga mussels in Lake Piru, United Water Conservation District (United) has analyzed and researched multiple action options related to containment and control. United has settled on mechanical scraping, lake level management, and copper treatment as the most effective and economically feasible path forward for population control and is focusing staff time and resources on these options. The following discusses the containment and control measures that have been evaluated by United and are considered infeasible at this time. For the purposes of this document infeasible is defined as measures that are not economically feasible for a small water district, unsafe for staff, precluded by the regulatory environment, not effective, and/or not practical for significantly combating the quagga mussel population in a meaningful way that would contribute to the 100% containment criteria that is currently required by Fish and Game Code. Any of these options may become feasible in the future given technological advances, further research, or additional funding and resources. Filtration or Chemical Treatment of Water Releases at Santa Felicia Dam United conducted a screening level evaluation of potential options to prevent the release of mussels downstream through physical/mechanical methods and chemical treatment of the water released from the outlet works (GEI 2016b). Based on the volume of flow requiring treatment, the study identified gravity filtration using a mixed media system (anthracite coal, silica sand, and ilmenite sand) and chemical treatment using sodium hypochlorite as the most feasible alternatives. However, the total present value cost (construction and recurring operation and maintenance costs) of the gravity filtration alternative was estimated to be between $24M and $263M (to treat 25 cubic feet per second (cfs) and 600 cfs, respectively), and the total present value cost for treatment using sodium hypochlorite was estimated to be between $19M and $196M (to treat 25 cfs and 600 cfs, respectively). The footprint of the treatment facilities was estimated as greater than 10 acres, which exceeds the amount of land United would have available for this project. Based on the results of the study, both of these alternatives were considered economically infeasible. However, it is also unknown how filtering out plankton of sizes comparative to quagga mussel veligers would affect the ecosystem of Piru Creek and critical habitat for southern California steelhead. Therefore, filtering veligers may also be precluded by the federal regulatory environment. Tarping Tarping involves placing a tarp over the mussels for at least one month to create anoxic (i.e., no oxygen) conditions, which result in mortality of mussels under the tarp. The tarps are held down with sandbags, rebar, or chain. During the Summer of 2014, United performed a pilot program in which two 75-foot x 25-foot tarps were deployed in two different locations of Lake Piru. The effort resulted in mortality to mussels under the tarp, but was labor-intensive and at times unsafe for the divers involved. Therefore tarping is considered infeasible because it is considered unsafe

79 to tarp vertical substrates limiting the applicability and economically infeasible to be conducted in a way that would make an impact on the population. Also, this approach would not prevent the release of veligers to the creek by mussels that were not tarped or are already in the infrastructure. Complete Dewatering of Lake Piru Completely draining the lake is not feasible or practical due to physical and regulatory limitations. United could theoretically decrease the lake levels to the top of the intake tower. However, at that point, the lake would still contain approximately 400 AF of water. While this water would evaporate over time, it is unlikely that the entire lake would dry before the following wet season. In addition, United s water release requirements under their FERC license preclude implementation of this approach. Removal of Mussels from Lower Piru Creek Mechanical removal of mussels from lower Piru Creek is considered infeasible and precluded by the regulatory environment. Extracting rocks from the stream for mussel removal would disturb the aquatic system of the creek and result in excess turbidity in Piru Creek that could harm southern California steelhead and other biota. In addition, the extent of the infestation is such that only a small number of mussels could be removed without extensive extraction of substrate from the creek. This action also does not prevent the release of more veligers from the lake. Surface Coatings (Nonfouling Release) United engineers evaluated options for surface coatings and concluded that none would be adequate to protect the infrastructure and they definitely would not prevent veligers from being released to the creek. After the large volume release in June 2017, mussels were adequately scoured from the infrastructure and the engineers are no longer concerned about the infrastructure given that a new intake tower and outlet works will be built soon to ensure dam safety. The new intake structure and outlet works will provide redundant pipelines that can be dried and cleaned to protect the infrastructure, therefore surface coatings are not considered necessary to protect the infrastructure or adequate to address release of viable veligers to Piru Creek. Acoustic Deterrents (Cavitation) The engineers at United have researched acoustic deterrents and determined that the technology is not adequate to effectively address the release and settlement of quagga mussels at Lake Piru. Also, cavitation is already a significant issue in the current infrastructure at Santa Felicia Dam. The engineers are concerned that purposely causing additional cavitation would pose a safety

80 concern for personnel and would threaten the integrity of the infrastructure. Also acoustic deterrents would not prevent the passage of viable veligers through the dam during high flows. Plankton Tows California Department of Fish and Wildlife (CDFW) staff have shown interest in the use of large-scale plankton tows to decrease the number of veligers in the lake. While United is open to discussing a pilot study using this approach, United staff are critical of the potential for this approach to significantly contribute to the required 100% mortality that Fish and Game Code requires for approval of the Plan. Also, Lake Piru often has significant sediment loads that would quickly clog the fine nets required for this approach. Also, it is not clear that if a large-scale effort to remove veligers were successful, it would not also remove phytoplankton and zooplankton that are important to the ecosystem along with the veligers potentially having unknown impacts on southern California steelhead. This option may also be economically infeasible given the significant staff time that would be required to filter out a significant amount of veligers. Therefore, United recommends focusing resources on an eradication effort that would have more lasting impacts that are broader reaching throughout the lake and the creek. However, United is open to further discussion if CDFW can provide literature, personnel, or funding to initiate a pilot study that would demonstrate the effectiveness of this approach. Fish Biocontrol United assisted with an initial study of fish biocontrol at the docks in Lake Piru. The results of the study suggested that the fish would not be effective at significantly decreasing the quagga mussel population. While United is open to more studies using this approach, United staff are critical of the potential for this approach to significantly contribute to the required 100% mortality that Fish and Game Code requires for approval of the Plan. United is focusing staff time and resources on an eradication effort that would have more lasting impacts that are broader reaching throughout the lake and the creek. However, United is open to further discussion if CDFW can provide literature, personnel, or funding to initiate a pilot study that would demonstrate the effectiveness of this approach. Zequanox While Zequanox remains an option for site-specific treatments, it is not economically feasible for lake-wide treatment. Therefore, United is pursuing the copper treatment option instead as an economically feasible way to treat quagga mussels throughout the lake and the creek.

81 APPENDIX D Examples of Education Materials

82

83 Examples of Education Materials Rack Card, Distributed at the Entrance Gate Front: Back:

84 Examples of Education Materials Warning Sign, Posted Outside the Entrance and Alongside the Road Leading Into the Recreational Area

85 Posted in the following locations: Information board at the entry/exit kiosk; Information board at the Olive Grove Campground; Information board at the Marina Docks; Information board at the Reasoner Canyone Boat Ramp; Information board at the Day Use Picnic/Recreation Area; and, Information board at the Juan Fernandez Boat Launch. Examples of Education Materials

86 Examples of Education Materials Posted in the following locations: Information board at the entry/exit kiosk; Information board at the Olive Grove Campground; Information board at the Marina Docks; Information board at the Reasoner Canyone Boat Ramp; Information board at the Day Use Picnic/Recreation Area; and, Information board at the Juan Fernandez Boat Launch.

87 Posted in the following locations: Information board at the entry/exit kiosk; Information board at the Olive Grove Campground; Information board at the Marina Docks; Information board at the Reasoner Canyone Boat Ramp; Information board at the Day Use Picnic/Recreation Area; and, Information board at the Juan Fernandez Boat Launch. Examples of Education Materials

88 Examples of Education Materials Posted in the following locations: Along Piru Canyon Road at Santa Felicia Dam (approximately 1.5 miles from the lake entrance), at the entry to the water treatment plant (approximatley 1.25 miles from the lake entrance), and at the entrance to Bobcat Cove approximately 0.5 miles from the lake entrance). Information board at the entry/exit kiosk; Information board at the Olive Grove Campground; Information board at the Marina Docks; Information board at the Reasoner Canyone Boat Ramp; Information board at the Day Use Picnic/Recreation Area; and, Information board at the Juan Fernandez Boat Launch. *Note the scale of these signs has been reduced to fit this document.

89

90 APPENDIX E Lake Piru Recreational Area Vessel Inspection Checklist

91 LAKE PIRU RECREATION AREA VESSEL INSPECTION PERMIT ALL VESSELS MUST SUBMIT TO EXIT INSPECTION & WILL BE RECORDED IN QID (QUAGGA INSPECTION DATABASE) Failure to undergo an EXIT inspection PRIOR to departure may result in Citation, Fine or Both [per UWCD Ordinance 15] Notice: It is unlawful to possess, import, ship or transport in the state, or place, plant or cause to be placed or planted in any water within the state, zebra or quagga mussels [CA Fish & Game Code Sections and [UWCD Ordinance 15 Section 5.6(L)] to receive, bring or cause to be brought into the recreation area, any fish, crustacean, amphibian or aquatic plant from any location; [UWCD Ordinance 15, Section 5.6(0)] to launch any boat on the water of Lake Piru that has not successfully passed an invasive species (including but not limited to quagga mussels) inspection at the parks entry area [UWCD Ordinance 15, Section 5.6(P)] or to leave the Lake Piru Recreation Area with any boat, personal watercraft, aquaplane or float tube which has not been cleaned, drained and dried in a manner specified by the District, and passed an invasive species (including but not limited to quagga mussels) inspection at the park s entry area. Lake Piru is an INFESTED body of water. Only YOU can keep Quagga mussels from spreading by ensuring your boat is CLEAN, DRAINED and DRY. Zebra and quagga mussels have the potential to: Disrupt the ecosystem Encrust boats and clog engines Foul docks, ramps and waterlines Litter beaches with sharp, smelly shells Owner/Operator (Print Name):_ Address: City: State: Zip: Phone: Watercraft History: Date of Last launch: Location of Last Launch: Does Watercraft have a VIT: [ ] Yes [ ] No From Where; List tag #: Vessel Information: Check One: [ ] Fishing Boat [ ] Ski/Wake Board [ ]Pontoon [ ]Sailboat [ ]Kayak/Canoe [ ] Float Tube Registration or CF #: Make/Model: Vessel Length: Hull Material: [ ] Aluminum [ ] Fiberglass [ ] Wood [ ] Other: Color/Description: Was vessel given a VIT: [ ] Yes [ ] No If Yes, what is tag #: Inspection Areas: Comments: Vehicle Rear Yes No Trailer Structure, railings, bunks, spare tire Yes No Axle Yes No Vessel Hull Yes No Prop/shafts/outdrive (propeller on the engine) Yes No Motor Intakes Yes No Transom Yes No Trim tabs Yes No Transducers Yes No Through hull fittings Yes No Bait tank/live wells/ski compartments Yes No Anchor/fenders and lines Yes No Was bilge plug pulled? Yes No Is bilge dry? Yes No Mussels/aquatic life present Yes No Quarantine recommended Yes No Reason: Inspector Name: Inspector ID #: By signing this permit, you certify that you have been provided information advising you that Lake Piru is known to be infested with quagga mussels; that you acknowledge that unsafe boating conditions may or do exist; you acknowledge that launching in shallow conditions may be hazardous and present unforeseen obstacles and dangers; that prior to departure, your boat will undergo an exit inspection to ensure that your vessel was cleaned, drained and is dry; that you have been advised to allow your vessel to dry for a minimum of 5 consecutive days before launching at any other waterbody; and that your vessel was inspected and your permit has been signed by a Certified Inspector. I declare, under penalty of perjury, that I have read and understand the foregoing and that all information I have provided is true and correct. Owner/Operator signature: _Date:

92 APPENDIX F Standard Operating Procedures Invasive Species Boat Inspection and Equipment Decontamination

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94 STANDARD OPERATING PROCEDURES FOR CLEANING, DECONTAMINATING, AND INSPECTING EQUIPMENT EXPOSED TO AREAS CONTAMINATED WITH QUAGGA MUSSELS September 2015 United Water Conservation District

95 Table of Contents 1.0 Introduction General Avoidance/Minimization Measures for Planning and Conducting Work General Cleaning, Decontamination, and Inspection Procedures for Large Equipment (Vehicles, Construction and Facility Equipment, and Watercraft) Cleaning Methods Draining Equipment Brushing Air Removal Vacuuming Decontamination Methods High-Pressure Water Wash Thermal Treatment General Guidelines for Inspections Vehicles: Trucks, Cars, SUVs and Trailers Construction and Facility Equipment: Bulldozers, Excavators, Tractors, Dump Trucks, Water Trucks, and Others Watercraft: Boats, Barges, Rafts, Harvesters and Other Marine Equipment (nonrecreational) Prevention, Cleaning, and Decontamination Procedures for Small Tools and Equipment (Waders, Wetsuits, Monitoring Equipment, Watercraft Gear, and Miscellaneous Tools) Prevention Decontamination Following Work in Contaminated Sites... 7

96 1.0 INTRODUCTION This document presents standard operating procedures (SOPs) developed to prevent the spread of quagga mussels (Dreissena rostriformis bugensis), an invasive species, during performance of activities by United Water Conservation District (United) personnel, and parties under contract or under permit with United. Quagga mussels have been identified in Lake Piru, the Santa Felicia Dam outlet works, and in areas of lower Piru Creek. The objective of these SOPs is to ensure that all equipment exposed to contamination in the course of conducting activities associated with United s operations or projects be decontaminated and inspected prior to leaving the facilities, and be required to undergo an appropriate drying period prior to use at other locations. For the purpose of these SOPs, exposure is defined as 1) direct contact with a contaminated water body, 2) direct contact with wet surfaces adjacent to a contaminated water body, or 3) contact with a contaminated item or material (e.g., contact with a contaminated wet suit). All United personnel are responsible for implementing these SOPs when operating equipment or using small tools or equipment in and adjacent to 1) Lake Piru, 2) Santa Felicia Dam outlet works, and 3) lower Piru Creek. Although these SOPs are developed to prevent the transport of quagga mussels from contaminated areas to other water bodies, the measures outlined in this document will also serve to prevent the transport and dispersal of other invasive species, and therefore, these SOPs will also be implemented when conducting activities in middle Piru Creek because of the presence of New Zealand mudsnails. All parties (contractors) performing work on behalf of United or under permit with United will be required to either adopt the measures outlined in this document or develop a plan that identifies equivalently effective measures to prevent the transport of quagga mussels (and other invasive species) from contaminated areas to other water bodies. The prevention plan must be submitted to United for review and approval prior to initiation of work in the identified contaminated areas. These SOPs include avoidance and minimization measures to be implemented during the project planning process and work activities, and decontamination and inspection protocols for use upon completion of a project, prior to removal of equipment from a contaminated work site. The procedures are dependent upon the type of equipment. The general types of equipment addressed in this document include but are not limited to: Large equipment o Vehicles (trucks, cars, sport utility vehicles (SUVs), and trailers. o Construction and facility equipment (bulldozers, excavators, tractors, dump trucks, water trucks, etc.). o Watercraft (boats, barges, rafts, marine harvester, and other marine equipment) used for non-recreational activities. Small equipment o Tools and equipment such as waders, wetsuits, monitoring equipment, watercraft gear, and miscellaneous tools. SOPs specific to large equipment are presented in Section 3 (General Cleaning Decontamination, and Inspection Procedures for Large Equipment [Vehicles, Construction

97 and Facility Equipment, and Watercraft]). SOPs for small tools and equipment are presented in Section 4 (Prevention, Cleaning, and Decontamination Procedures for Small Tools and Equipment [Waders, Wetsuits, Monitoring Equipment, Watercraft Gear, and Miscellaneous Tools]). 2.0 GENERAL AVOIDANCE/MINIMIZATION MEASURES FOR PLANNING AND CONDUCTING WORK Adequate planning should take place prior to conducting field work in areas contaminated with invasive species. When feasible, efforts will be made to use equipment that is dedicated for exclusive use at the contaminated facility. If available, equipment will be selected based on its ability to be easily decontaminated and inspected. All field activities should be conducted in a manner to minimize contact between equipment and potential sources of contamination. This can be done by employing the following avoidance and minimization measures when possible: 1. Plan work to minimize contact with aquatic plant life. 2. Avoid or minimize activities that result in running boats and/or equipment onto mud or sediment. 3. Avoid or minimize work that may result in plants, sediment and/or fish getting inside boats or other equipment. 4. Arrange to have a catch pan or container available in boats and equipment to store small tools or equipment that have been exposed to contaminated areas in order to prevent contact with boat decks or surfaces on large equipment, and bilges and stationary storage units. 5. Avoid driving or maneuvering through areas of mud and dense vegetation. 3.0 GENERAL CLEANING, DECONTAMINATION, AND INSPECTION PROCEDURES FOR LARGE EQUIPMENT (VEHICLES, CONSTRUCTION AND FACILITY EQUIPMENT, AND WATERCRAFT) All equipment exposed to contamination in the course of conducting activities associated with United s operations or projects will be cleaned, decontaminated and inspected prior to leaving the facilities where the exposure occurred. Equipment from rental agencies and outside contractors is subject to the same cleaning, decontamination, and inspection requirements as equipment owned by United. Following decontamination, all equipment will be required to undergo an appropriate drying period prior to use at other locations, as per the 100th Meridian Initiative web site ( drying time calculator, which provides estimated drying times needed to kill quagga mussels, based upon location and month. Employees tasked with cleaning or decontamination efforts will be trained on all cleaning and decontamination equipment and chemical use, provided with and trained in usage of necessary personal protection equipment for performing activities, and trained in methods and applicable laws and regulations associated with chemical decontamination and disposal. 3.1 Cleaning Methods Equipment should be drained and cleaned prior to decontamination procedures to remove all water, visible plant material, debris, mud and aquatic organisms. In general, cleaning will include brushing, handpicking and scraping. Areas to be cleaned include, but are not limited to, trailer frames, axels and wheels, wheel wells, tracks, vessel hulls, anchors, props, jet engines, ropes, boat bumpers, paddles, pumps, tanks, etc. and any part of equipment that

98 has come in contact with a contaminated source. Specific cleaning processes are detailed below Draining Equipment The best method for draining equipment is to remove all drain plugs and position the piece of equipment in such a way to allow maximum drainage. This is particularly important for watercraft. Drain plugs on watercraft should be removed, outdrives and props lowered so that water can drain. In addition, when possible, the vessel should be placed on an incline to allow draining to occur by gravity Brushing Brushing may be used in conjunction with other physical removal methods such as vacuuming, washing and hand picking. Brushing provides a pre-cleaning measure for removing the majority of plant material, debris and aquatic life from equipment. Brushing will remove most surface soil, plant material and foreign matter. A combination of soft, medium and stiff bristled brushes may be used. The type of brush used will depend upon the surface being cleaned. Bristles of medium length and stiffness are desired for removal of soil and other matter from fabrics and upholstery. Stiff bristles are recommended for the tread of wheels, metal surfaces and other hard surfaces. Metal bristles may also be used to remove heavier materials but increased wear and tear to the equipment will result Air Removal High-pressure compressed air blasting may be used to assist in the removal of plant material, debris, mud and moisture. This can be achieved by the use of an air compressor and the appropriate nozzle. High pressure compressed air should only be used on hardened surfaces and should not be used on mechanical components such as pumps and motors or on electrical components. This cleaning method should only be used in conjunction with vacuuming or within a confined space, as all materials being dislodged will need to be removed and disposed of properly Vacuuming Vacuuming may be used in conjunction with air removal methods for the removal of debris, moisture and particle matter from confined spaces that cannot be accessed by any other means. To prevent the spread of invasive species following the cleaning process, collected matter or materials should be double bagged and transported to an onsite disposal landfill or spoils pile. 3.2 Decontamination Methods Following implementation of the cleaning methods outlined above, all large equipment that has been exposed to contamination will be decontaminated using a high-pressure water wash thermal treatment. In the future, United may revise these SOPs to include chemical treatment processes. The decontamination process is described below High-Pressure Water Wash Thermal Treatment Thermal treatments involve the use of extremely hot temperatures to kill quagga mussels and other invasive species. High-pressure application of hot water has proven to be effective when appropriate temperature and contact times are met. All equipment surfaces, compartments and components that have been exposed to a contaminated source should be decontaminated with this process implementing the following guidelines.

99 Decontamination equipment should be used in a designated area designed to contain contaminated wash water. Washing system should be capable of maintaining a minimum of 3,000 PSI. Temperatures for water (at the point of contact) should be in the range of 140 to 160 degrees Fahrenheit. Employees should wear gloves, a face shield, an apron and any other personal protective gear necessary. Prior to decontaminating any equipment not owned by United, employees should request permission from the owner/operator and have the owner/operator sign a liability waiver. All equipment that may be required for use at another location will undergo a mandatory drying period before being placed into service at another location. o Upon completion of decontamination procedures, a tag will be attached to the equipment stating the date the decontamination was completed, and the date the equipment will be available for use at another location (based on recommendations for dry times from the 100th Meridian Initiative Web site ( To the extent feasible, equipment will be placed in a well-ventilated area with exposure to sunlight to promote adequate drying and all compartments, cabs or areas that may house moisture should be left open in order to allow air and heat to thoroughly dry the areas. 3.3 General Guidelines for Inspections Following implementation of the cleaning and decontamination methods outlined above, all large equipment that has been exposed to contamination will be inspected. Inspectors will be trained in the standard operating procedures for inspection and decontamination established by the Pacific States Marine Fisheries Commission and the Western Regional Panel. Inspections will be carried out at a dedicated inspection station area whenever possible. Whenever feasible, inspections will be conducted in tandem with decontamination activities. Inspectors will conduct a pre-cleaning inspection to identify problem areas and determine whether hand removal of large accumulations of soil and debris is necessary before decontamination. Post decontamination inspections will be conducted to verify that all attached materials deemed capable of spreading invasive species have been removed. If a piece of equipment is found to be contaminated, that piece of equipment shall not be placed into service until it has undergone a second decontamination process and has been reinspected. Inspectors will be equipped with the following tools. Under vehicle inspection mirror Flashlight Step stool Mechanics creeper Crescent wrench Metric socket set Gloves Collapsible table Sample jars

100 Zip lock bags Ink pen Two-way radio Inspectors will use the following inspection guidelines as a reference for identifying areas of concern Vehicles: Trucks, Cars, SUVs and Trailers Trucks, cars, SUVs, and trailers will be inspected to ensure that all water, visible plant material, debris, mud, and aquatic organisms have been removed during the cleaning and decontamination process. Extra care and attention will be given to the referenced areas and to cracks and crevices, undercarriages, wheel wells, and wheels as these areas are at a greater risk for trapping moisture and debris that may be contaminated. The following is a list of the specific areas that will be visually inspected on all trucks, cars, SUVs, and trailers. Quarter panels Tires, treads & wheels Fender and wheel wells Spare tire mounting unit & spare tire Front and rear bumpers Grill Underside of radiator Brake systems Bottom portion of transmission Differentials Stabilizers Shock, leaf springs and coils Front and rear axles Beds and trunk hatches that may have housed contaminated personal equipment Suspension Exhaust system Light housings Undercarriage Construction and Facility Equipment: Bulldozers, Excavators, Tractors, Dump Trucks, Water Trucks, and Others Construction and facility equipment is especially prone to contamination given the complex mechanical structure. Tracked equipment consists of numerous areas, particularly crevices and cracks where the potential for contaminated materials to become lodged or trapped is high. All construction and facility equipment will undergo a thorough inspection following decontamination, with special attention paid to the following components. Crevices Panels Axles Tensioners

101 Support rollers Sprockets Idlers Link pins Tracks Rubber or gridded areas Beneath fenders Hatches Casings Grills Watercraft: Boats, Barges, Rafts, Harvesters and Other Marine Equipment (nonrecreational) Inspections of all watercraft and water related equipment will follow the same standard principles of inspections of other equipment, with close attention to detail given the high risk for contamination. Watercraft and water related equipment have many compartments and areas that are complex and not readily visible. Careful visual inspections will be conducted to ensure they are cleaned, drained, and have been successfully decontaminated. Inspection of watercraft should include, but not be limited to, the following components. All surfaces will be inspected for water, debris, signs of any life stage of quagga mussels, aquatic plant growth or organisms. Organisms too small for visual detection, may be detectable by tactile monitoring (by touch through rubbing a hand over a surface). Small mussels will feel like sandpaper or sesame seeds. In areas where visual monitoring is not feasible, the inspector will employ tactile monitoring methods. Vessel Hull Transom: The transom is at the back of the vessel where the engine is attached. The transom may have several items of importance which mussels can attach to, including the out drive, trim tabs, transducers, and bilge plug area. Outdrive: The outdrive is attached to the transom on stern-drive watercraft and to the lower unit on outboard watercraft. It has intricate parts that make it easy for mussels to attach, hide and grow. Propeller/Shafts: Mussels can attach and live on or around the area where the propeller attaches to the lower unit of the drive shaft. Mussels can also attach to the shaft or connecting points of the vessel. These can be difficult to see and should be inspected with a flashlight and through tactile monitoring. Trim Tabs: Trim tabs are located on the lower portion of the transom and are usually metal plates that help stabilize the vessel while underway. The inspector should visually inspect the underside of the trim tabs and use tactile monitoring methods on corners and edges. Transducers: These are located on the transom or bottom of the hull near the stern of the vessel. They are used in conjunction with a computer to determine depth, speed and water temperature. Bilge Plug/Plug: All bilge plugs or containment plugs should be pulled prior to inspection by the vessel/equipment operator.

102 Through Hull Fittings: Through hull fittings in all watercraft have the potential to store mussels. The inspector will visually look inside through hull fittings with a flashlight and use tactile monitoring to feel for irregularities. Compartments: Compartments should be dry and clear of all water and debris. Some compartments do not drain completely due to the way they are manufactured, and should be wiped dry. Bilge: The bilge is at the bottom of the inside stern of the vessel. It may not be visible in all vessels. The bilge should be clean of all water, moisture and debris. Anchor/Fenders and Line: Anchors are regularly placed in contact with mud or debris and should be carefully inspected. Trolling Motor: Trolling motors can pick up plants and debris while being used and must be inspected. Tanks/Pumps: Equipment with storage tanks and or pumps are exposed to contaminated water sources. All closed storage tanks and pumps used in a contaminated water source will be decontaminated after their use. 4.0 PREVENTION, CLEANING, AND DECONTAMINATION PROCEDURES FOR SMALL TOOLS AND EQUIPMENT (WADERS, WETSUITS, MONITORING EQUIPMENT, WATERCRAFT GEAR, AND MISCELLANEOUS TOOLS) To prevent the spread of quagga mussels and New Zealand mudsnails outside of infested areas, United, its contractors, and any of its representatives will follow the standard operating procedures below when conducting tasks that involve water contact at contaminated sites. 4.1 Prevention If work must be conducted in both contaminated and non-contaminated sites, workers will conduct work at non-contaminated sites first. If the status of contamination at any site is uncertain, workers will assume the site is contaminated and will not move to another site until equipment is decontaminated and allowed to dry for the recommended dry time (available on the 100th Meridian Initiative Web site at Once work is conducted in a known contaminated site, workers will not move to a non-contaminated site to work until equipment has been decontaminated and allowed to dry for the recommended dry time (available on the 100th Meridian Initiative Web site at Where possible, the District s staff will establish equipment designated for use in contaminated sites only. The equipment will be labeled and stored in a manner that clearly designates it for use only at contaminated sites. Workers will avoid the use of felt-soled wading boots, when possible. 4.2 Decontamination Following Work in Contaminated Sites Workers will clean all small tools and equipment as well as wetsuits, waders, and wading boots that come in contact with water, mud, aquatic vegetation, etc. with a stiff brush and clean water, removing all mud and vegetation. If separate wading boots are used, the worker will remove the insoles from the boots (these procedures also apply if wet-wading in shoes or sandals). This should be conducted on a dirt

103 surface where the cleaning water will not discharge to a water body. This is the most important step in decontamination. The solution added below is intended to kill any organisms that are not removed during this step. Workers will soak wetsuits, waders, and wading boots in a 35 parts per thousand (ppt) solution of potassium chloride (KCl) for no less than 20 minutes. Solutions in concentrations of 35 ppt solution can be made by thoroughly mixing one cup of dry KCl salt crystals (water softener salts) in one gallon of water. This can be done in a five-gallon bucket or other container that is dedicated for infected waters. After soaking in solution, the materials will be rinsed in fresh water and dried thoroughly, if possible. KCl salt is stored at Lake Piru, at the Santa Felicia Dam shop and the Freeman Diversion, and may be stored at other locations when needed. Workers should ask their supervisor for the latest KCl storage areas. Workers will properly clean and decontaminate wading gear and small tools and equipment based on the requirements stated above after every use and prior to storage, this includes gear dedicated to contaminated sites. Following decontamination procedures, small tools and equipment will be allowed to dry for the recommended dry times (available on the 100th Meridian Initiative Web site at prior to use at another location. After use, the KCL solution will be discharged into an open containment device (e.g., small plastic pool) and allowed to evaporate. Remaining precipitate will be bagged and deposited in waste disposal. Contaminated sites will most likely change over time. Supervisors are responsible for keeping staff informed regarding current contaminated areas.

104 Reference Documents California Department of Fish and Wildlife A Guide to Cleaning Boats and Preventing Damage, Don't Move a Mussel. Colorado Parks and Wildlife Aquatic Nuisance Species (ANS) Watercraft Decontamination Manual. U.S. Bureau of Reclamation (Reclamation) Inspection and Cleaning Manual for Equipment and Vehicles to Prevent the Spread of Invasive Species. Technical Memorandum No nual2012.pdf

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107 APPENDIX G Memorandum of Understanding Between United and Ventura County Fire Protection District

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111 APPENDIX H United Request for Concurrence for Temporary Suspension of Migration Releases from Lake Piru dated December 2, 2016

112 Board of Directors Bruce E. Dandy, President Robert Eranio, Vice President Daniel C. Naumann, Secretary/Treasurer Sheldon G. Berger Lynn E. Maulhardt Edwin T. McFadden III Michael W. Mobley Legal Counsel Anthony H. Trembley UNITED WATER CONSERVATION DISTRICT Conserving Water Since 1927 General Manager Mauricio E. Guardado, Jr. December 2, 2016 Anthony Spina National Marine Fisheries Service 501 West Ocean Blvd. Long Beach, California Subject: Santa Felicia Project FERC License No Request for Concurrence Temporary Suspension of Migration Releases from Lake Piru In a letter dated September 15, 2016, the Federal Energy Regulatory Commission (FERC) designated United Water Conservation District (United) to act as their nonfederal representative for the purpose of informal consultation with the National Marine Fisheries Service (NMFS), pursuant to Section 7 of the Endangered Species Act (ESA) for the Santa Felicia Project No. 2153, located in Ventura County, California. Specifically, this designation is for proposed reductions of water releases from Santa Felicia Dam below that required by the project license issued by FERC. These releases are being conducted for endangered southern California steelhead (Oncorhynchus mykiss). Any extended reduction in water releases would require that FERC issue a waiver. At this time, United is proposing to suspend steelhead migration water releases between January 1 and May 31, 2017, to minimize the release of invasive, non-native quagga mussels (Dreissena rostriformis bugensis) into the Santa Clara River. To fulfill the requirements of Section 7 of the ESA, United is requesting to initiate informal consultation with NMFS regarding the effects of this proposed action on the endangered southern California steelhead and its designated critical habitat. United has made the determination that this proposed action is not likely to adversely affect steelhead or its critical habitat and seeks NMFS s concurrence with this determination. Quagga mussels were first discovered in Lake Piru on December 18, Since that time, United has been working with the California Department of Fish and Wildlife (CDFW) to develop and implement a monitoring and control plan for quagga mussels that will satisfy the requirements of Fish and Game Code section During this time, United has continued to conduct water releases as required by the project license and the associated Water Release Plan developed in compliance with the biological opinion issued by NMFS. Quagga mussels have been detected in lower Piru Creek from the Santa Felicia outlet works downstream for approximately 0.23 miles to United s property line with Rancho Temescal. The extent of infestation downstream of this point is unknown. However, quagga mussels have not yet been detected at the confluence of lower Piru Creek with the Santa Clara River and on the Santa Clara River downstream of the confluence. 106 N. 8 th Street S Santa Paula, California S Phone (805) S Fax (805) S

113 UNITED WATER CONSERVATION DISTRICT CDFW has informed United that its most recent draft control and monitoring plan does not meet the requirements of Fish and Game Code section 2301 because it does not contain measures to attempt to fully contain the release of quagga mussels from Lake Piru to lower Piru Creek and the Santa Clara River. In recent discussions, CDFW has requested that United pursue obtaining approvals from NMFS and FERC to suspend steelhead migration water releases. These releases are of particular concern to CDFW because they occur when the Santa Clara River has surface flows from the Piru Creek confluence to the ocean and could successfully transport quagga mussels downstream to the Santa Clara River. Therefore, United proposes to temporarily suspend migration releases between January 1 and May 31, 2017 to eliminate this source for the potential spread of the quagga mussels. This request is only for one migration season because United is pursuing a plan to eradicate quagga mussels for the fall of United has determined that implementing this action is not likely to adversely affect steelhead or its critical habitat. Lower Piru Creek is approximately six miles long and only about third of that is currently expected to be suitable spawning and rearing habitat for steelhead. Other tributaries with much more extensive spawning and rearing habitat exist within the Santa Clara River watershed (i.e., Santa Paula Creek, Sespe Creek) and are available to migrating steelhead when there is not adequate hydrological connection to Piru Creek. In addition, based on a snorkel survey conducted on October 20, 2016 in Piru Creek from the United/Temescal property line upstream to the Santa Felicia Dam, United believes there are likely no juvenile fish currently present in the creek that may transition to smolts. This survey was supplemented by a second survey November 14, 2016, focused on vegetated areas no more than 500 feet downstream of the Santa Felicia Dam. A total of eight O.mykiss were observed during surveys. All fish observed were six inches or greater in size, four fish were larger than 12 inches. Only a single individual (6-7 inches in length) was observed at a size class with the potential for smolting. United hereby requests NMFS concurrence that the proposed action of suspending migration water releases is not likely to result in adverse effects to steelhead or its designated critical habitat. Sincerely, cc: John Aedo, FERC Ed Pert, CDFW Richard Burg, CDFW John O Brian, CDFW Catherine McCalvin Environmental Planning and Conservation Manager

114 APPENDIX I NMFS Response to United Request for Concurrence for Temporary Suspension of Migration Releases from Lake Piru dated December 2, 2016

115 UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE West Coast Region 501 West Ocean Boulevard, Suite 4200 Long Beach, California January 19, 2017 Catherine McCalvin United Water Conservation District 106 N. 8th Street Santa Paula, California Re: Endangered Species Act Section 7(a)(2) request for concurrence for Temporary Suspension of Migration Releases from Lake Piru, Santa Felicia Project FERC License No Dear Ms. McCalvin: On December 9, 2016, NOAA s National Marine Fisheries Service (NMFS) received United Water Conservation District s (United) December 2, 2016, informal consultation request under Section 7 of the U.S. Endangered Species Act (ESA). 1 This request concerns a temporary suspension of water releases from Santa Felicia Dam Hydroelectric Project (Project) into Piru Creek, and potential effects on the endangered Southern California Distinct Population Segment of steelhead (Oncorhynchus mykiss) and designated critical habitat for this species. NMFS prepared this response to your request pursuant to Section 7(a)(2) of the ESA, implementing regulations at 50 CFR 402, and agency guidance. This response underwent pre-dissemination review using standards for utility, integrity, and objectivity in compliance with applicable guidelines issued under the Data Quality Act (section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001, Public Law ). This response will be available through NMFS Public Consultation Tracking System [ A complete record of this consultation is on file at the Southern California Branch of the California Coastal Area Office in Long Beach, California. Proposed Action and Action Area United is proposing to temporarily suspend water releases (between January 1, 2017, and May 31, 2017) that are specifically intended to facilitate migration of adult and juvenile steelhead ( migration releases ). These migration releases are 200 cfs and are required by reasonable and prudent alternative (RPA) 2 of NMFS May 5, 2008, biological opinion ( 2008 BiOp ) concerning the Santa Felicia Dam Hydroelectric Project (Project), which is operated under license from the Federal Energy Regulatory Commission (FERC). United requests the temporary suspension of the migration 1 In a letter dated September 15, 2016, the Federal Energy Regulatory Commission designated United Water Conservation District as the non-federal representative for informal consultation with the National Marine Fisheries Service, under Section 7 of the U.S. Endangered Species Act for the Santa Felicia Hydroelectric Project.

116 releases to minimize the spread of a non-native invasive species (quagga mussel) from Lake Piru into the Santa Clara River. Action Agency s Effects Determination United has determined the proposed temporary suspension of migration releases is not likely to adversely affect endangered steelhead or designated critical habitat for this species, and requested NMFS concurrence with this determination. Effects of the Action Under the ESA, effects of the action means the direct and indirect effects of an action on the listed species or critical habitat, together with the effects of other activities that are interrelated or interdependent with that action (50 CFR ). The applicable standard to find that a proposed action is not likely to adversely affect listed species or critical habitat is that all of the effects of the action are expected to be discountable, insignificant, or completely beneficial. Beneficial effects are contemporaneous positive effects without any adverse effects to the species or critical habitat. Insignificant effects relate to the size of the impact and should never reach the scale where take occurs. Discountable effects are those extremely unlikely to occur. Implementing the migration releases are one of several required elements of RPA 2 in the 2008 BiOp, which must be implemented to ensure that FERC s ongoing action avoids jeopardizing the survival and recovery of endangered steelhead, and destroying or adversely modifying designated critical habitat for this species. Temporarily suspending the migration releases, even for one season, would violate FERC s requirements under the 2008 BiOp and Section 7 of the ESA. Temporarily suspending the migration releases is expected to adversely affect designated critical habitat for endangered steelhead. The timing, duration, and frequency of the migration releases were deliberately designed under the RPA to coincide with naturally elevated river discharge throughout the Santa Clara River Watershed and, therefore, the migration of adult and juvenile steelhead. Because the Project captures and stores water during winter and spring (including rain-induced discharge pulses) that would otherwise flow downstream into Piru Creek downstream of Santa Felicia Dam, suspending the migration releases would reduce the quality and availability of the freshwater migration corridor for adult and juvenile steelhead (see the 2008 BiOp for additional details). Moreover, the migration releases represent the principal source of water creating and maintaining the freshwater migration corridor in Piru Creek. Therefore, the high-magnitude water releases during winter and spring, which the proposed action would eliminate, is expected to reduce and occasionally eliminate the conservation value of the freshwater migration corridor in Piru Creek. The proposed action is also expected to adversely affect endangered steelhead because water quantities of the appropriate timing and with sufficient duration and frequency supporting migration of adult and juvenile steelhead include elevated discharge pulses in winter and spring (2008 BiOp). Because the proposed action would preclude the migration releases, the likelihood that adult and juvenile steelhead could immigrate and emigrate in Piru Creek is expected to 2

117 decrease. This is because these life stages typically migrate during periods of elevated flows (see the 2008 BiOp and references therein), and the rain-induced discharge pulses that prompt migration of these life stages are expected to be frequently lacking due to the proposed action. As a result, the proposed action increases the likelihood that adult and juvenile steelhead would be unable to complete essential life-history functions. Conclusion Based on this analysis, NMFS disagrees with United s determination that the proposed action is not likely to adversely affect endangered steelhead and designated critical habitat for this species. Furthermore, because the migration releases are required by RPA 2 of the 2008 BiOp for the Santa Felicia Dam Hydroelectric Project, suspending the migration releases would require reinitiation of formal consultation for the Project, in accordance with 50 CFR Technical Assistance Regarding Control or Eradication of Mussels Based on the information available to NMFS, the proposed action appears to be part of a broader mussel control and eradication program (hereafter Program ) to minimize the spread of the invasive mussel. For this reason, the remainder of this letter provides technical assistance to United for the purpose of informing a future Section 7 formal consultation with NMFS. NMFS supports the effort to eradicate the invasive mussel from Lake Piru and related efforts to minimize the spread of this invasive species into the Santa Clara River. As described in United s December 2, 2016, request for concurrence, United began collaborating with the California Department of Fish and Wildlife (CDFW) to develop an eradication and control plan following discovery of the mussels in Lake Piru on December 18, The entirety of a proposed Program, including the temporary suspension of migration releases and other interrelated and interdependent activities, should be provided to NMFS for the purpose of supporting Section 7 formal consultation. Segmenting the broader action into smaller parts, and then initiating consultation on a segmented part, as requested by United, is inconsistent with Section 7 of the ESA and its implementing regulations. In formulating the Program, United should give consideration to the appropriate lead federal action agency for ESA compliance. Although FERC administers the license for the Project, FERC does not appear to be an action agency for ESA compliance on the Program itself. 2 Based on NMFS current understanding, United appears to require an NPDES permit from the California Regional Water Quality Control Board (Board) before implementing the Program. Issuance of an NPDES permit appears to constitute a federal action, because U.S. EPA grants permit authority, under the Clean Water Act, to the Board for administering the NPDES Program. Therefore, EPA appears to represent the appropriate lead for consulting with NMFS on the Program. We therefore recommend that United coordinate with EPA regarding ESA compliance for the Program. 2 We recommend FERC discuss with NMFS how the Program, once it has been fully defined and all the interrelated and interdependent activities are identified, comports with FERC s obligations under the 2008 BiOp. 3

118 In accordance with requirements under the ESA, United working in concert with the lead federal action agency should develop a Program that includes a meaningful plan to avoid and minimize effects on endangered steelhead and designated critical habitat to this species. The Program may also be subject to public review under the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA, owing to EPA s issuance of the NPDES permit). As a result of CEQA and NEPA requirements, the environmental documents (i.e., Environmental Impact Report, and Environmental Impact Statement) must demonstrate that adverse effects to the human environment, including aquatic resources, have been avoided or minimized, and that any residual effects have been fully mitigated. Efforts to avoid and minimize adverse effects to aquatic resources in the creek may necessitate developing and then implementing a method for maintaining continuous deliveries of water from upstream sources that lack the invasive species (i.e., tributaries to the creek main stem upstream of the dam) to the creek or (and) developing a rescue-and-relocation plan, perhaps in collaboration with CDFW, for the protection of aquatic biota in the creek. Furthermore, depending on the effects of the Program on aquatic biota in the creek, including steelhead, the aquatic resources may experience a temporary loss of service (e.g., owing to temporarily dewatering and desiccating the creek), the effects of which must be minimized (and fully compensated under CEQA and NEPA). In addition, if a molluscicide is used, United should collaborate with and rely upon EPA to identify the specific molluscicide that is reasonable and appropriate for use. Avoiding and minimizing adverse effects is relevant and important because, in part, discussions to date with United have focused solely on the control or eradication of the mussel, and related consequences to the affected environment. However, the anticipated effects to native riparian and aquatic-dependent species could be significant and widespread, potentially involving harm and injury to water-dependent biota throughout Piru Creek. The mechanisms for harm and injury appear to potentially involve application of a molluscicide to the waterway or (and) forced dewatering and desiccation of the creek. One essential prerequisite for reliably predicting and estimating the type, amount and extent of effects involves performing an assessment of the resources in Piru Creek that would be affected by the Program. This resource assessment should be performed throughout the entirety of Piru Creek downstream of the dam, not solely confined to the reach of Piru Creek under United s control. The information obtained from this assessment is crucial to reliably inform the ESA consultation (and the CEQA and NEPA environmental documents). Once the Program is fully defined, the lead federal action agency should submit a request for formal consultation under Section 7 of the ESA to NMFS if the Program may affect endangered steelhead and/or designated critical habitat. The request should include the following information: A complete description of the action being considered, including all of the interrelated and interdependent activities; 4

119 An environmental assessment containing a detailed interpretation regarding the applicability of proposed molluscicide; A description of the manner in which the action may affect any listed species or critical habitat, and an analysis of any cumulative effects; and Detailed information regarding Piru Creek resources that would be affected. NMFS would be pleased to provide further technical assistance to United and the lead federal action agency on formulating aspects of the Program to help develop a proposed action that will include measures to avoid or minimize adverse effects to endangered steelhead, possibly including a relocation plan in the event the Program involves any dewatering actions. Please contact Rick Bush at (562) or via at Rick.Bush@noaa.gov if you have a question concerning this letter or if you would like additional information. Sincerely, Alecia Van Atta Assistant Regional Administrator California Coastal Office cc: Ed Pert, California Department of Fish and Wildlife John Aedo, Federal Energy Regulatory Commission John O Brien, California Department of Fish and Wildlife Mary Larson, California Department of Fish and Wildlife Rich Burg, California Department of Fish and Wildlife Roger Root, U.S. Fish and Wildlife Service Tony Kish, Environmental Protection Agency, Washington, D.C. Administrative Record: SWR2002PR8222 5

120 APPENDIX J Lake Piru Hydrodynamic Model for a Lake Level Management Strategy

121 Introduction In December 2013 quagga mussels were detected in Lake Piru. Since then, United Water Conservation District (United) has been working on containment, control and prevention through a variety of activities including a vessel inspection program, education, monitoring, and development of a Quagga Mussel Monitoring and Control Plan. As part of this plan, several control and containment options have been evaluated. Lake level management through water releases was identified as one of the more promising approaches. It is hypothesized that water releases following periods of lake stratification will be an optimal way to control quagga populations, as high quagga mortality will occur in the hypoxic zone (the deeper zones in a stratified lake), and a subsequent decrease in water level will desiccate and kill many of the mussels living in the lake at elevations higher than the hypoxic zone boundary. The effectiveness of United s lake level management strategy will depend on a number of factors which are currently not well understood, including: 1. Timing, frequency and depth of stratification in Lake Piru; 2. Dissolved oxygen concentrations in the hypoxic zone during stratification in Lake Piru; 3. Quagga mussel and veliger mortality rate in the hypoxic zone; 4. United s ability to lower lake levels following periods of lake stratification, considering operational, water resources, environmental and regulatory constraints. United is currently developing a linked Lake Piru Hydrodynamics and Quagga Population Model in order to determine an optimal lake level management strategy to control the Quagga population in Lake Piru. The model will simulate conditions for the period, which includes wet and dry periods, high and low lake levels (including spill events), and multiple conservation releases. Lake monitoring data for calibration of temperature and dissolved oxygen are available for parts of this period. This report details the current state of development of the model used to simulate various environmental parameters in the Lake Piru water column. Initial results suggest that the model will develop into a useful tool as calibrations are generally promising for key parameters. Lake Piru Hydrodynamics Model Model Description The Lake Piru Hydrodynamics Model uses the open-source General Lake Model (GLM) for simulating lake dynamics, coupled with the Aquatic EcoDynamics model (AED2) for simulations of water quality (Hipsey et al., 2014). The model is available at The GLM is a one-dimensional hydrodynamic model computing vertical profiles of temperature, salinity and density by accounting for the effects of inflows/outflows and surface heating and cooling (Figure 1). The integrated AED2 model computes vertical profiles of dissolved oxygen for this application, but can also be configured to simulate a wider range of water quality and aquatic ecosystem parameters. October 2017 Quagga Model Progress Report 2

122 Figure 1. General Lake Model The water balance components used in the Lake Piru model include surface mass fluxes (evaporation, rainfall), inflows (gaged surface flows, runoff from the surrounding catchment) and outflows (withdrawals, overflow). The model computes the dynamics of the inflows and outflows on a daily timestep, however the surface mass fluxes occur hourly based on hourly meteorological input data. The R package glmtools is used to run the GLM-AED2, to produce lake profile graphs of temperature and dissolved oxygen, and to export model data output to excel files. Model Inputs The GLM configuration file (glm.nml) is included in Appendix 1. The file includes parameters and settings related to mixing, water quality, time controls, lake morphometry, output file details, initial conditions, meteorological conditions, information about inflows and outflows, and input parameters for the Bird solar radiation model. The AED2 configuration file (aed2.nml) used default settings, although it is possible that some parameters in the oxygen model will be modified when finalizing calibration with the currently available or future monitoring data. Model calibration suggested increased mixing was required in the model compared to default settings, which was likely related to boating activity (Nedohin and Elefsinoiotis, 1996; Yousef, 1974) common to Lake Piru. Therefore, a wind factor of 1.8 was used, and mixing parameters were increased from the default values (see Model Calibration). Further refinements may be needed to improve calibration results. Lake morphometry was based on a lake survey performed in While morphometry has changed somewhat during the modeling period (e.g. lake capacity was 83,244 acre-feet in 2005 and 81,986 acre- October 2017 Quagga Model Progress Report 3

123 feet in 2015), the most current morphometry was selected for modeling of lake level management scenarios. Initial conditions (January 1, 2002) assumed complete mixing with a temperature of 9 C, salinity of 0.7 ppt and dissolved oxygen of 300 mmol/m 3. The following input data time series were used to run the model (see figures 2 through 4): Inflow flow rate. Daily average flow rates were based on USGS Piru Creek above Lake Piru CA. Flow rates were normalized so that annual water balance based on outflows, rain and evaporation closed. Inflow temperature. Daily average water temperature was calculated based on temperature monitoring data in Middle Piru Creek. Temperature monitoring data in Middle Piru Creek was sparse, and temporal trends were used to fit an average daily temperature time series that applies to all years (Figure 3). Hourly inflow temperature monitoring data were available from July 15, 2002 October 18, 2002, February 10, 2016 March 10, 2017, and thirteen grab samples were available from the periods and Inflow salinity. Daily average salinity was calculated based on monitoring data in Middle Piru Creek and correlations with flow rate. Salinity was set constant at 0.75 ppt when inflows were less than 1 cfs, and at 0.38 ppt when inflows exceeded 1000 cfs. At intermediate flows, salinity was calculated using the following regression equation: Salinity [ppt] = x exp( x log (Discharge [cfs])) Inflow dissolved oxygen. Concentrations were set constant at 280 mmol/m 3 (9 mg/l), based on the average of measured dissolved oxygen concentrations during Outflow flow rate. Daily average outflow rates for the baseline scenario were calculated from USGS Piru Creek below Santa Felicia Dam CA. For analyzing alternative release scenarios, flow rates will be altered. Air temperature. Hourly average air temperature were used from the Temescal (LPF) Remote Automated Weather Station (RAWS), located approximately 1,000 ft west of Lake Piru at an elevation of 1140 ft. Missing data were substituted by air temperatures from the Piru California RAWS station (approximately 5 miles southwest of Lake Piru) or manually interpolated. Relative humidity. Hourly average relative humidity from the Temescal (LPF) RAWS station was used in the model. Missing data were completed by a correlation with the relative humidity form Simi Valley California RAWS station (approximately 12 miles south of Lake Piru). Solar radiation. Hourly average shortwave radiation was obtained from the Temescal (LPF) RAWS station. Missing data were completed by correlations with the shortwave radiation data from the Piru California and Simi Valley California RAWS stations. Wind speed. Hourly average wind speed from Temescal (LPF) RAWS station was used in the model. Windspeed from Temescal station did not correlate with windspeeds available from nearby stations (Simi Valley, Piru, Whitaker Peak), which is likely related to the and therefore missing data were estimated by using the average of the prior and next year s wind speed data, with some manual interpolations. Periods with missing data were infrequent and usually short-lived (hours to days), except for the periods September November 2002, October 2004 February 2005, December 2006 June 2007, and July For these periods, modeling results may be less accurate on a daily to weekly timeframe, but monthly predictions should be more accurate given the consistent wind pattern October 2017 Quagga Model Progress Report 4

124 generally observed throughout the years (see moving averages in Figure 4). Temescal station data were also edited for the period 3/27/2013 3/15/2015 to correct an error in unit conversion in the raw data. Rainfall. Daily rainfall from United s gage #160 at Lake Piru was used in the model. Model Calibration Modeled lake levels correlate well with measured daily levels for the modeling period (Figure 5). Inflows were adjusted by a factor of 1.03 to improve calibration for years , a dry period with low lake levels. This adjustment factor is very small, and reflects the error introduced in the model by the changing lake morphometry, and inaccuracies in some components of the water balance (e.g. inflow and evaporation measurements). Lake monitoring data for temperature and dissolved oxygen profiles were available for approximately two months in 2003, one month in 2008, and (mostly) bi-weekly from March 2014 onwards. Limited monitoring data is available for calibration under high lake level conditions, since lake levels have been low since the end of the 2012 conservation release. Therefore, it is anticipated that the model will continue to be updated and calibrations will improve as more monitoring data become available in the future. The model calibration with currently-available temperature data is almost completed (Figure 6). Calculated temperature profiles track the measured temperatures well, with two exceptions. First, temperature calibration appears off during September of 2008, during a conservation release when water levels decreased rapidly. It is possible that the model is less accurate for simulating rapidlychanging conditions, given that the manual recommends the model be used as a tool for modeling longterm conditions, i.e. months to decades (Hipsey et al. 2014). Second, the model appears to under predict lake temperatures somewhat in winter/spring (March 2014 April 2014 and December 2014 March 2015). Additional monitoring data will be useful in optimizing calibration for these conditions. Model calibration for dissolved oxygen is currently underway. Final model calibration will also incorporate sensitivity analysis to determine the most sensitive model parameters and inputs. After model calibration using the currently available monitoring data is complete, model runs will be used to inform the quagga model and optimize United s lake level management strategy. Preliminary Model Results Preliminary model results indicate lake stratification occurs during most years, as indicated by temperature as well as dissolved oxygen profiles (Figure 7). A hypoxic zone with dissolved oxygen concentrations less than 50 mmol/m 3 (~ 1.6 mg/l) develops during most years, suggesting quagga mortality due to oxygen limitation is likely to occur. During most years, the maximum depth of the hypoxic layer during summer stratification is between m from the bottom (33 66 ft). This implies that for maximum quagga control, a water release to these depths would need to occur. However, during periods of low lake level conditions the hypoxic zone is shallower, and releases down to the hypoxic zone boundary layer may be difficult to achieve due to operational restraints at the lake. October 2017 Quagga Model Progress Report 5

125 Quagga Population Model The Quagga Population model is currently under development. The model will use time series outputs from the Lake Piru Model (lake area, lake volume, dissolved oxygen profiles) to calculate mortality and population dynamics of quagga mussels and veligers in Lake Piru. United started monitoring quagga population and growth in Lake Piru in These data will be used to determine appropriate model inputs such as quagga concentrations and growth parameters, as well as for calibration purposes. Given the amount of monitoring data available for Lake Piru, and the progress that has been made so far with calibrating the hydrodynamic model for key model parameters, the quagga model is likely to develop into a useful tool to determine an optimal lake level management strategy to control the Quagga population in Lake Piru. References Hipsey, M.R., Bruce, L.C., and Hamilton, D.P. (2014). GLM - General Lake Model. Model overview and user information. AED Report #26. The University of Western Australia, Perth, Australia. 42pp. Nedohin, D.N, and Elefsinoiotis, P. (1996). The effects of motor boats on water quality in shallow lakes. Toxicol. Environ. Chem., 61, Yousef, Y.A. (1974). Assessing effects on water quality by boating activity. National Environmental Research Center, Office of Research and Development, U.S. Environmental Protection Agency. Environmental Protection Technology Series, EPA-670/ October 2017 Quagga Model Progress Report 6

126 FIGURES Figure 2. Model inputs for inflows (flow rate, salinity), outflows (flow rate) and rainfall (daily averages). October 2017 Quagga Model Progress Report 7

127 Figure 3. Model inputs for inflows (temperature). October 2017 Quagga Model Progress Report 8

128 Figure 4. Model inputs for meteorological data (hourly). Black dotted line indicates 24-hour moving average. October 2017 Quagga Model Progress Report 9

129 Figure 5. Calibration of lake level (open circles = measurements, line = model output). October 2017 Quagga Model Progress Report 10

130 Figure 6. Lake temperature calibration results. For , data were collected bi-weekly for most months, but only one profile per month is shown here. Orange lines are for modeled temperatures, blue lines for field observations. Vertical axes indicate depth (m); horizontal axes indicate temperature ( C) October 2017 Quagga Model Progress Report 11

131 Figure 6 (continued). Lake temperature calibration results. For , data were collected bi-weekly for most months, but only one profile per month is shown here. Orange lines are for modeled temperatures, blue lines for field observations. Vertical axes indicate depth (m); horizontal axes indicate temperature ( C). October 2017 Quagga Model Progress Report 12

132 Figure 7. Modeled temperature and dissolved oxygen profiles (preliminary results prior to complete calibration). October 2017 Quagga Model Progress Report 13