Section 1. Executive Summary

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2 EXECUTIVE SUMMARY 1.1 Introduction The purpose of this report is to address measures taken and planned to be taken by the Santa Clarita Valley Sanitation District (District) to quantify and control sources of chloride in the Santa Clarita Valley from July 2007 to June The District operates two water reclamation plants (WRPs) in the Santa Clarita Valley, the Saugus and Valencia WRPs, along with more than thirty miles of District s operated trunk lines and one pumping plant. The Saugus and Valencia WRPs discharge treated wastewater into the upper reaches of the Santa Clara River. The District is currently facing significant water quality and regulatory challenges regarding the concentration of chloride being discharged to the river from the Saugus and Valencia WRPs. The discharges contain chloride in excess of the water quality objective for the upper Santa Clara River of 100 mg/l, which was established by the California Regional Water Quality Control Board, Los Angeles Region (Regional Board) in 1978 to reflect existing water quality conditions. To address chloride in the upper reaches of the Santa Clara River, the Regional Board adopted Resolution on May 6, This resolution is known as the Upper Santa Clara River Chloride Total Maximum Daily Load (TMDL), and it sets forth a comprehensive Implementation Plan for evaluating and attaining the water quality objective for the upper Santa Clara River. It became effective May 4, One of the tasks required under the TMDL Implementation Plan, Task 3, requires a plan to be submitted annually addressing measures that have been taken, and are planned, to quantify and control sources of chloride in the District s sewerage system. This report was prepared in accordance to the requirements under Task 3 of the Upper Santa Clara River Chloride TMDL Implementation Plan. 1.2 Sources of Chloride Loadings This report addresses chloride sources from July 2007 to June Chloride loadings from 2001 to mid-2007 were fully characterized in previous reports by the District, Santa Clarita Valley Joint Sewerage System Chloride Source Report, October 2002, Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan, November 2005, Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan, November 2006, and the Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan, November The last report, the Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan, November 2007, contained information for the first half of In this report data have been updated to reflect the entire 2007 calendar year (January 2007 to December 2007) and information from the first half of the current year, January 2008 to June This report builds upon the methodologies established in the previous four reports. The reader should bear in mind that the data presented herein are, in many cases, estimates based on numerous assumptions and best professional judgment. Many inputs are difficult to quantify and this analysis represents the best available information at this time. The primary source of chloride in the District s sewerage system is chloride present in potable water served to the community. Potable water in the area is derived from two sources: imported water delivered under the State Water Project (SWP) and local groundwater. The chloride concentration in these two sources varies depending on a number of factors, most notably rainfall patterns. To estimate chloride loading in the potable water supply, water quality and quantity data from the local water suppliers were used Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan 1-1

3 The residential sector also contributes a substantial chloride loading. The flow volume for residential discharges was estimated using a differential method, whereby other known flow volumes were subtracted from the total system flow volume to obtain the residential wastewater flow rate. This method was validated in the Santa Clarita Valley Joint Sewerage System Chloride Source Report, October 2002, in which residential flow volumes were determined using both this differential method and a rigorous modeling technique based on extensive field data collection. There was excellent agreement between the two methods. The chloride loading contributed from self-regenerating water softeners (SRWS) was also estimated using a differential method, whereby all other chloride loadings were subtracted from the total chloride loading and the difference was assumed to be contributed by SRWS. Residential non-srws chloride contributions were estimated using concentration data taken from the Santa Clarita Valley Joint Sewerage System Chloride Source Report, October Other sources of chloride in the District s sewerage system include disinfection at the WRPs, the industrial sector, the commercial sector, and hauled waste. Chloride introduced at the Saugus and Valencia WRPs during disinfection of wastewater using sodium hypochlorite was quantified using the District s operational records. Industrial loadings of chloride were estimated using chloride sampling data from industrial dischargers, combined with flow information from District s permit and surcharge records. Commercial loadings of chloride were estimated using concentration data taken from the Santa Clarita Valley Joint Sewerage System Chloride Source Report, October 2002, along with flow information taken from the District s service charge records. The contribution of chloride from hauled waste was determined using sample data to characterize concentration and waste manifests to determine volume. The results of the updated quantification of chloride sources in the District s sewerage system from July 2007 to June 2008 indicate that the two largest sources of chloride on the system continue to be the potable water supply and residential SRWS. The estimated chloride from water supply peaked in 2003 at 12,800 pounds per day of chloride, representing 85 mg/l chloride in the system effluent. This peak coincided with drought conditions in northern California and thus a high chloride content in SWP water provided in the area. In the first half of 2008, the potable water supply contributed 49 percent of the chloride loading in the District s sewerage system and the mass loading of chloride from the potable water supply was 12,700 pounds per day. The chloride loading from SRWS peaked in 2003/2004 at approximately 9,100 pounds per day, representing a contribution of 58 mg/l in the system effluent. This coincided with implementation of a prohibition on the installation of SRWS in the Santa Clarita Valley. The SRWS contribution maintained a downward trend in the first half of 2008, due to the Automatic Water Softener Rebate Program Phase II and community-wide public outreach effort to convince residents to remove existing SRWS. For the first half of 2008, the chloride loading from SRWS was an estimated 5,200 pounds per day, representing a contribution of 30 mg/l in the system effluent. Based on the SRWS chloride loading for the first half of 2008, there are an estimated 3,900 SRWS still active in the community. This is down from a peak estimate of approximately 6,500 in the timeframe. A graphical depiction of the breakdown in chloride sources for the first half of 2008 is presented in Figure Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan 1-2

4 Residential (Non-SRWS) 16% 24 mg/l 4,099 ppd Figure (First Half) Chloride Sources Commercial Industrial 4% 3% 5 mg/l 4 mg/l 899 ppd 730 ppd Liquid Waste Disposal 0% 0.4 mg/l 69 ppd Disinfection 8% 12 mg/l 2,034 ppd Residential (SRWS) 20% 30 mg/l 5,238 ppd Water Supply 49% 73 mg/l 12,712 ppd The District will continue to monitor and quantify chloride sources on an on-going basis. Continued efforts will include collection of data on industrial chloride concentrations and flowrates, industrial self-monitoring of chloride concentrations, quantification of commercial flowrates, tracking of treatment plant sodium hypochlorite use, tracking of volumes of wastes accepted at the Saugus Liquid Waste Disposal Station, collection of groundwater chloride data from local water purveyors, and monitoring of chloride concentrations and flowrates at the Saugus and Valencia WRPs. An update of the chloride sources will be submitted to the Regional Board each year as part of the annual progress report required under the Upper Santa Clara River Chloride TMDL Implementation Plan, Task Chloride Source Control Measures The District has conducted a ground breaking, nationally recognized source control program for chloride in the Santa Clarita Valley. Because SRWS are the largest controllable source of chloride in the Santa Clarita Valley, the source control efforts from July 2007 to June 2008 have continued to focus on the removal of these units. However, efforts to reduce chloride sources have also focused on the industrial sector, commercial sector, hauled waste, and treatment plant operations. Chloride in water supply is also being examined. From July 2007 to June 2008, the District continued the Automatic Water Softener Rebate Program Phase II and the community wide outreach program to encourage residents to remove SRWS. In addition, the District continued to pursue other available avenues to restrict the use of residential SRWS. The District launched the Automatic Water Softener Rebate Program Phase I in November 2005 in order to provide a financial incentive for residents to remove SRWS. The Automatic Water Softener Rebate Program Phase I offered residents $100 for the removal of SRWS and $150 for the removal of SRWS and replacement with a qualified non-salt alternative unit. The rate of participation in the Automatic Water Softener Rebate Program Phase I slowed substantially in the fall of 2006, indicating that a stronger incentive was necessary for residents to voluntarily remove their SRWS Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan 1-3

5 The District began development of an upgraded incentive program in June The new rebate program was designed to enhance and accelerate the voluntary removal of SRWS and to be consistent with the provisions of the California Health and Safety Code Section The goal of the Automatic Water Softener Rebate Program Phase II was to provide compensation to residents for the reasonable value of their SRWS and the cost of removal and disposal of the unit. In order to determine the reasonable value of various types of SRWS in use, and the likely cost of removal and disposal of the units, the District researched and compiled available information regarding purchase price, useful life, and the cost of installation, removal, and disposal of SRWS. The District also worked extensively with water softening companies, retailers, homebuilders, and developers in the winter of 2006 and spring of 2007 to obtain information for consideration in the reasonable value determination. The District launched the Automatic Water Softener Rebate Program Phase II on May 1, The program provides compensation for the reasonable value of SRWS and removal and disposal of the SRWS at no cost to the resident if specific plumbers are used (and residents that remove the units themselves receive $50 for removal). The reasonable value of the SRWS is determined based on the sales price and installation date of the unit, and a 12-year average service life expectancy for a unit. Rebates of $325 to $2,000 per SRWS were offered for the removal and disposal of non-rental SRWS from within the District s service area from May 1, 2007 to January 31, On February 1, 2008, the minimum value of the rebates was reduced to $275 to account for the additional depreciation of the SRWS. Currently rebates are offered from $275 to $2,000 for the removal and disposal of non-rental SRWS installed prior to March In order to treat all community members equally, residents that participated in the Automatic Water Softener Rebate Program Phase I are eligible for the difference between the new rebate amount and the $100 or $150 incentive provided under the Automatic Water Softener Rebate Program Phase I. In May 2007, the District estimated that approximately one-quarter of the SRWS installed in the Santa Clarita Valley were rental units. In order to expedite removal, the District developed contractual agreements with the retail water softening companies that provide rental SRWS units to residents in the Santa Clarita Valley for the removal of approximately 1,580 rental units by June The agreements provide compensation for eligible units that are removed, disabled, and surrendered to the District within the allocated time period. Rayne Dealership Corporation signed an agreement with the District on September 12, 2007 to remove approximately 530 rental SRWS from the District s service area by October 31, On December 12, 2007, Culligan Water Conditioning of Orange County signed an agreement for the removal of approximately 1,000 rental SRWS by June 30, 2009 and Guaranteed Water Systems, Incorporated agreed to remove approximately 50 rental SRWS by December 31, These three companies provide the majority of rental service for SRWS in the Santa Clarita Valley. A major public outreach campaign was launched in May 2007 with the commencement of the Automatic Water Softener Rebate Program Phase II. The public outreach program is multi-faceted and from July 2007 to June 2008 the campaign included the use of press releases, television commercials, movie theater, newspaper, radio, and Money Mailer advertisements, street banners and flags, water bill inserts, newsletter articles, and robocalls. Throughout the year, the District also sent letters to all new homeowners each month informing them of the 2003 ordinance banning the installation of SRWS and the 2005 ordinance banning discharges from saltwater pools to the sewer, and encouraging them to take advantage of the SRWS rebate program, if a SRWS was already installed in their home. In addition, the District continued to update the chloride website, staff the toll-free line, and participate in community events Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan 1-4

6 From May 1, 2007 to June 30, 2008, the District received 1,523 rebate program applications and removed 1,560 SRWS from the Santa Clarita Valley. As a result of the Automatic Water Softener Rebate Program Phase I and II, 1,992 SRWS have been removed from the District s service area from November 30, 2005 to June 30, The District s Board of Directors introduced the Santa Clara River Chloride Reduction Ordinance of 2008 (Ordinance) on May 27, 2008 and it was adopted on June 11, The Ordinance was supported by the requisite findings detailed in the Staff Report in Support of Findings Necessary for Adoption of an Ordinance Pursuant to California Health and Safety Code Section , with Addendum. The Ordinance requires the removal and disposal of all existing SRWS installed in the District s service area within 180 days after the effective date of the Ordinance. On and after the effective date of the Ordinance, the District will compensate owners of residential SRWS within its service area for 75 percent of the reasonable value of each removed residential SRWS and the reasonable cost of the removal and disposal of that residential SRWS. In accordance with the provisions of Section of the California Health and Safety Code, the Ordinance must be approved by majority vote in a voter referendum within the District s service area before it can become effective. The Ordinance will appear as Measure S on the November 4, 2008 ballot. If approved by a majority vote on November 4, 2008, the Ordinance will take effect on January 1, Although many source control efforts have focused on the residential sector, the District has also conducted extensive source control efforts for other sectors. For the industrial sector, the District operates a comprehensive industrial waste source control program that includes permitting, inspections, monitoring, and enforcement. Under this program, industrial dischargers in the Santa Clarita Valley have either been assigned a chloride discharge limit of 100 mg/l or assigned a performance-based chloride limit that reflects implementation of chloride reduction practices to the extent technologically and economically feasible. For the commercial sector, the District is aggressively enforcing the prohibition on the use of SRWS. Numerous notifications about the prohibition have been made to commercial businesses, and hundreds of on-site inspections to verify compliance have been conducted. In addition, the District has required implementation of best management practices to reduce chloride discharges from commercial swimming pools. The District is firmly committed to reducing chloride sources in the sewerage system to the maximum extent technologically and economically feasible, and will continue to explore innovative and effective means to bring about this reduction Chloride Source Identification/Reduction, Pollution Prevention, and Public Outreach Plan 1-5