AWTF_WDR_Order_No._R4-2021-0044.pdf

ADOPTED: 02/11/21 1

CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD

LOS ANGELES REGION

320 West 4th Street, Suite 200, Los Angeles, California, 90013

(213) 576-6600 Fax (213) 576-6660 http://www.waterboards.ca.gov/losangeles

ORDER NO. R4-2021-0044

(FILE NO. 20-090)

WASTE DISCHARGE REQUIREMENTS

AND

WATER RECLAMATION REQUIREMENTS

CITY OF SANTA MONICA

SUSTAINABLE WATER INFRASTRUCTURE PROJECT (SWIP)

The following Permittee is subject to Waste Discharge Requirements (WDRs) and Water Reclamation Requirements (WRRs) set forth in this Order:

TABLE 1. PERMITTEE INFORMATION

Permittee City of Santa Monica (City or Permittee)

Name of Facility SWIP Advanced Water Treatment Facility (AWTF or Facility)

Facility Address 1771 Main Street Santa Monica, CA 90401

TABLE 2. ADMINISTRATIVE INFORMATION

This Order was adopted and shall become effective on: February 11, 2021

I, Renee Purdy, Executive Officer, do hereby certify that this Order with all attachments is a full, true, and correct copy of the Order adopted by the California Regional Water Quality Control Board, Los Angeles Region (Los Angeles Water Board), on the date indicated above.

Renee Purdy, Executive Officer

City of Santa Monica Order No. R4-2021-0044 SWIP Advanced Water Treatment Facility File No. 20-090

ADOPTED: 02/11/21 2

CONTENTS

1. BACKGROUND INFORMATION

2. RECYCLED WATER DISTRIBUTION SYSTEM

3. ADVANCED-TREATED RECYCLED WATER QUALITY

4. SMURRF TREATED WATER QUALITY

5. GROUNDWATER BASIN

6. PURPOSE OF ORDER

7. REGULATION OF RECYCLED WATER

8. OTHER APPLICABLE PLANS, POLICIES AND AUTHORITIES

1. INFLUENT SPECIFICATIONS

2. RECYCLED WATER TREATMENT SPECIFICATIONS

3. RECYCLED WATER DISCHARGE LIMITATIONS

4. RATIONALE FOR DISCHARGE LIMITATIONS

5. GENERAL REQUIREMENTS

6. SPECIFICATIONS FOR USE OF RECYCLED WATER

7. USE AREA REQUIREMENTS

8. SPECIFICATIONS AND REQUIREMENTS FOR DUAL-PLUMBED SYSTEMS

9. DDW SPECIFICATIONS AND REQUIREMENTS

10. ADDITIONAL PROVISIONS

11. REOPENER

12. ENFORCEMENT

TABLES

TABLE 1. PERMITTEE INFORMATION

TABLE 2. ADMINISTRATIVE INFORMATION

TABLE 3. TERTIARY-TREATED RECYCLED WATER USERS

TABLE 4. BENEFICIAL USES OF GROUNDWATER

TABLE 5. GROUNDWATER QUALITY OBJECTIVES FOR SALTS

TABLE 6. DISCHARGE LIMITATIONS NONPOTABLE USES

ATTACHMENTS

ATTACHMENT A – DEFINITIONS ................................................................................. A-1

ATTACHMENT B – SWIP PROJECT FLOW DIAGRAM ................................................ B-1

ATTACHMENT C1 – AWTF PROCESS FLOWDIAGRAM ............................................ C-1

ATTACHMENT C2 – RECYCLED WATER DISTRIBUTION AREA ............................... C-2

ATTACHMENT C3 – SANTA MONICA GROUNDWATER SUBBASINS ...................... C-3

ATTACHMENT D - STANDARD PROVISIONS ............................................................. D-1

ATTACHMENT E – MONITORING AND REPORTING PROGRAM (MRP) CI-10569 ... E-1

ATTACHMENT F – DDW CONDITIONAL ACCEPTANCE LETTER............................... F-1

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The California Regional Water Quality Control Board, Los Angeles Region (Los Angeles

Water Board) finds the following:

1. BACKGROUND INFORMATION

1.1. Permittee

The City of Santa Monica (City or Permittee) is a beachside city of 8.3 square miles on the west side of Los Angeles County. The City has a population of approximately 93,000 and produces municipal and commercial wastewater that is mostly conveyed to the Hyperion Water Reclamation Plant, owned and operated by the City of Los Angeles, Bureau of Sanitation.

1.2. Sustainable Water Infrastructure Project (SWIP)

Overview

The City of Santa Monica is developing a recycled water program to achieve long-term water self-sufficiency. When fully implemented, the Sustainable Water Infrastructure Project (SWIP) will allow the City to reuse up to 1.5 million gallons per day (mgd) of stormwater, brackish water, dry-weather runoff, and treated wastewater within the city. A conceptual flow diagram of the SWIP is included in Attachment B and the project consists of the following:

1.2.1. Advanced Water Treatment Facility (AWTF)

Construction and operation of an AWTF that will collect up to 1.5 mgd raw wastewater, stormwater, and dry-weather runoff from the city and produce up to 1.2 mgd advanced treated recycled water for nonpotable and indirect potable reuse. The AWTF advanced treated recycled water will be mixed with treated water from the Santa Monica Urban Runoff Recycling Facility (SMURRF) before being used for nonpotable reuse and, subject to future permitting, indirect potable reuse.

1.2.2. Civic Center Stormwater Harvesting Tank

Construction and operation of a 1.5 million gallon below-grade stormwater harvesting tank under the City’s Civic Center parking lot to convey stormwater and dry-weather runoff from the City’s Municipal Separate Storm Sewer System and Civic Center parking lot to the

AWTF.

1.2.3. SMURRF Upgrades

Installation of a Reverse Osmosis unit at the SMURRF and enclosing the UV system and final effluent basin. The SMURRF currently acts as a Best Management Practice (BMP) for stormwater management and treats both stormwater and dry weather runoff for nonpotable reuse.

Since there is often insufficient stormwater and dry-weather runoff to run the SMURRF, the SMURRF influent is supplemented with potable water. To reduce the need for potable water, the City also plans to convey brackish water from the City’s Clean Beaches Initiative tank to

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the SMURRF. Section 4 includes additional information on the SMURRF processes.

1.2.4. Injection Wells

Installation of a groundwater injection and monitoring well network to operate the SWIP as a Groundwater Replenishment Reuse Project (GRRP). Advanced treated recycled water from the AWTF and upgraded SMURRF will be conveyed to the injection wells through an extension of the existing recycled water pipeline. A groundwater monitoring plan will also be developed to monitor the impacts the injected water has on the groundwater basin before the GRRP begins operation.

Elements Permitted by the Los Angeles Water Board:

This permit only regulates the activities in the SWIP involving nonpotable reuse.

Specifically, the permit regulates the AWTF and the AWTF effluent water quality. The City will submit an updated Report of Waste Discharge (ROWD) to the Los Angeles Water Board once the GRRP is incorporated into the Engineering Report and approved by the State Water Resources Control Board, Division of Drinking Water (DDW). The Los Angeles Water Board will then consider amending this Order to permit operation of the GRRP.

1.3. Facility and Project Description

The AWTF will produce up to 1.2 mgd advanced treated recycled water from a mixture of raw wastewater from the City’s sanitary sewer, stormwater, and dry-weather runoff, when available. The influent to the AWTF will be 100% raw wastewater when no other sources are available. When stormwater or dry-weather runoff is available, the typical influent will be up to 70% raw wastewater and 30% stormwater or dry-weather runoff. If the AWTF is shut down or if the water does not meet Title 22 specifications, the wastewater will be directed to the sewer for treatment at the City of Los Angeles’ Hyperion Water Reclamation Plant. Treatment at the Santa Monica AWTF will consist of headworks fine screening, Membrane Bioreactor (MBR), cartridge filtration, Reverse Osmosis (RO), Ultraviolet-Advanced Oxidation Process (UVAOP), chlorine disinfection, and post treatment stabilization as presented below and in Attachment C1:

Headworks Fine Screen – To minimize the presence of inert solids such as grit, hair, and fibrous materials entering the MBR, a headworks system will screen the raw influent wastewater, stormwater, and dry-weather runoff. A single 2 mm perforated drum screen with a hydraulic capacity of

1.5 mgd will provide the required screening with no possibility of unscreened bypass to downstream processes.

MBR – After the headworks, screened influent will flow by gravity, mix with Return Activated Sludge (RAS), and enter the MBR. The MBR consists of two biological trains and two membrane trains. Each biological train will be divided into two compartments, one anoxic zone and one aerobic zone, to provide nitrification-denitrification of the wastewater along with oxidizing the

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wastewater. One MBR feed pump per biological train will pump the water from the aeration tank to a common MBR feed tank that allows flow into either membrane tank. RAS will flow by gravity over an overflow weir into a common RAS channel, where it will mix with screened influent and be discharged to either biological train. This mixture of RAS with influent maintains a sufficient concentration of mixed liquor suspended solids (MLSS) in the MBR. Each train is sized to provide half the capacity of the AWTF while meeting the appropriate pathogen reduction credits. Waste Activated Sludge (WAS) will be discharged to the Sump Pump Station to maintain a desired MLSS concentration within the MBR. The Sump Pump Station will ultimately discharge WAS to the downstream sanitary sewer.

An automatic Clean-in-Place (CIP) system will be installed for the membranes that consists of dosing acid and/or sodium hypochlorite into the membrane tanks to remove accumulated organic matter or crystalized salts.

Cartridge Filtration - Cartridge filtration is typically provided upstream of RO units to protect the membranes. The cartridge filters will be selected based on acceptance under the Surface Water Treatment Rule for pathogen reduction credits. The cartridge filters are made of pleated microfiber media that is NSF-61 certified for removal of cyst-sized particles.

Monitoring of the cartridge filters will be performed to ensure they remain within the prescribed limits for flow rate, pressure differential, and discharge turbidity.

RO – Following cartridge filtration, flow will pass through the RO system, which removes dissolved inorganic and organic components in the MBR filtrate. To control scaling and to protect the RO membranes, pretreatment consisting of chemical dosing with a threshold inhibitor and sulfuric acid for pH control will be provided. A CIP system and a flushing water system for the RO membranes are essential to maintain the RO performance. RO concentrate is discharged to the Sump Pump Station for disposal to the Hyperion Water Reclamation Plant via the downstream sanitary sewer.

UVAOP – The UVAOP at the AWTF will consist of UV irradiation with chlorine added as an oxidant upstream of the UV trains for advanced oxidation. UVAOP is used to disinfect RO permeate and destroy constituents of emerging concern (CECs) that pass through the RO membranes due to their low molecular weight and low ionic charge, notably N-Nitrosodimethylamine (NDMA) and 1,4-dioxane. UVAOP effectively reduces and inactivates pathogenic microorganisms and achieves the maximum disinfection credits allowed for target microorganisms. The chlorine used for oxidation also provides the disinfectant residuals needed for further virus reduction in the downstream chlorine contact tank. The inactivation of microorganisms and reduction of micropollutants vary with the UV dose, which is a product of the UV light intensity and the exposure time, and the chlorine dose.

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Chlorine Disinfection – Discharge from the UVAOP will flow to a chlorine contact tank for further virus reduction. Residual free chlorine concentration from the UVAOP will serve as the base for chlorine concentration, with an injection point upstream of the chlorine contact tank to add additional free chlorine if higher chlorine contact time (CT) values are needed. The chlorine contact tank provides 11.2 minutes of hydraulic retention time at peak flow. A tracer study will be performed to determine the baffling factor in CT calculations.

Post Treatment Stabilization - To stabilize the product water and protect the distribution system against corrosion, sodium carbonate is added to the flow to adjust the pH before it enters the distribution system and the pipelines to the injection wells.

2. RECYCLED WATER DISTRIBUTION SYSTEM

The City plans to distribute a mixture of advanced-treated recycled water, stormwater, dry-weather runoff, and SMURRF effluent for nonpotable uses such as landscape irrigation and toilet/urinal flushing in dual-plumbed systems. Table 3 below lists the recycled water users and Attachment C2 depicts the current recycled water distribution area.

TABLE 3. TERTIARY-TREATED RECYCLED WATER USERS

Recycled Water User Facility Owner

Use Type Address Land Use

Tongva Park City Irrigation 1700 Main Street Parks/

Open Space

Palisades Park City Irrigation 1250 Ocean

Avenue Parks/

Open Space

Memorial Park City Irrigation 1401 Olympic

Boulevard Parks/

Open Space

Municipal Cemetery City Irrigation 1823 15th Street Institutional/ Public Lands

Municipal Bus Yard City Irrigation 1620 6th Street Downtown

Core

Parking Lot near Metro Station

City Irrigation 1636 5th Street Institutional/ Public Lands

City Hall City Irrigation 1685 Main Street Institutional/ Public Lands

Median at Olympic Boulevard

City Irrigation 1401 – 2400

Olympic Boulevard

Public Right-of-Way

Parkway at Colorado and 11th Street

City Irrigation 1600 11th Street Public

Right-of-Way

Landscape at Colorado Esplanade

City Irrigation 224 Colorado

Avenue Public

Right-of-Way

The Rand Corp Private Irrigation/ Dual

Plumbed System 1776 Main Street

Institutional/ Public Lands

Step Up On Colorado L.P. Private Irrigation 520 Colorado

Avenue Downtown

Core

The Waverly Owners Association

Private Irrigation 1705 Ocean

Avenue Institutional/ Public Lands

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Recycled Water User Facility Owner

Use Type Address Land Use

Water Garden Company

LLC

Private Irrigation 1620 26th Street Office Campus

Public Safety Building City Dual-Plumbed

System 333 Olympic

Drive Institutional/ Public Lands

Median at Olympic Boulevard

City Irrigation

1000-2400 Olympic

Boulevard Median

Public Right-of-Way

I-10 Freeway Landscaping State/

Caltrans District 07

Irrigation 1702 Santa

Monica Freeway State

Right-of-Way

Other/ Filling Station City

Other/ Filling Station for Street Cleaning, Sewer

Jetting

1000 Olympic Boulevard, 1300 Ocean Avenue, 1600 Delaware Avenue, 1600

Main Street, 300 Colorado Avenue

Public Right-of-Way

3. ADVANCED-TREATED RECYCLED WATER QUALITY

The advanced-treated recycled water produced at the AWTF will meet the requirements in Title 22 of the California Code of Regulations (22 CCR), Chapter 3, Article 5.2 for indirect potable reuse: Groundwater Replenishment – Subsurface Application. The advanced treated recycled water will be higher quality than is required for nonpotable reuse applications, including decorative fountains.

4. SMURRF TREATED WATER QUALITY

4.1. The City of Santa Monica owns and operates the SMURRF, which currently treats stormwater and dry-weather runoff for nonpotable reuse. The City has been operating the SMURRF since 2000 as a stormwater and dry-weather runoff Best Management Practice (BMP).

4.2. The treatment system at the SMURRF currently consists of screening, grit removal, dissolved air flotation, ultrafiltration, UV disinfection, and sodium hypochlorite disinfection.

4.3. In the future, the City intends to convey brackish groundwater from the Clean Beaches Initiative (CBI) project tank to the SMURRF, at which time the City will add reverse osmosis (RO) treatment to the SMURRF. This additional treatment is necessary to ensure the SMURRF water meets Title 22 diluent water requirements before it is mixed with the advanced-treated recycled water and injected into the groundwater basin.

4.4. Influent water quality to the SMURRF and CBI project tank was monitored for 341 different pollutants from November 18, 2018 to November 25, 2019. The SMURRF and the CBI tank influent exceeded the Maximum Contaminant Levels (MCLs), or Notification Levels (NLs) for several pollutants. However, the additional treatment by reverse osmosis will reduce those pollutant concentrations to below the MCLs and NLs. The water quality of the

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SMURRF and CBI tank influent in wet and dry weather is similar; however, iron and manganese concentrations tend to be higher during wet weather in the SMURRF influent. PFOS and PFOA were also closely monitored to ensure the planned treatment process will be sufficient to keep the concentrations of these pollutants below their NLs. The City is continuing to monitor the SMURRF and CBI tank influent to determine its suitability as diluent water in the future.

4.5. The effluent from the SMURRF with RO will be required to meet all MCLs and NLs before use as a diluent water, and will be monitored once the advanced-treatment upgrades are complete.

5. GROUNDWATER BASIN

5.1. The Santa Monica Groundwater Basin (SMGB) is nonadjudicated and encompasses a surface area of approximately 50 square miles. The boundaries of the basin underlie the entire city limits and extend beyond the city boundaries into those of the City of Los Angeles to the north, east, and south. There are five separate subbasins within the SMGB, namely the Arcadia, Charnock, Coastal, Crestal, and Olympic subbasins. See Attachment C3 for a map depicting each of the subbasins. The subbasin boundaries loosely coincide with major geological structural features (e.g., faults) in the SMGB, but in some cases are defined using a combination of topography, sedimentation and/or geologic faulting. The sediments/rocks within and beneath the City of Santa Monica’s portion of the SMGB are divided into two broad groups: (1) a potentially water-bearing sediments group (these deposits tend to be readily capable of absorbing, storing, transmitting and yielding groundwater to water wells) and (2) a non-water-bearing rocks group, which underlies the water-bearing sediments group and which is comprised by geologically old, lithified, or cemented sedimentary rocks and/or crystalline rocks of low permeability.

5.2 This Order does not currently permit any groundwater recharge operations that will take place in the future. The recycled water use areas, as well as the groundwater injection locations, are located above the SMGB in the Los Angeles Coastal Plain. The City must submit an amended Report of Waste Discharge and amended Antidegradation Study, as described in section 8.3.2 below, and these WDRs must be amended before such use is permissible.

6. PURPOSE OF ORDER

6.1. On April 22, 2020, the City submitted a Report of Waste Discharge to the Los Angeles Water Board to permit the use of AWTF advanced-treated recycled water for nonpotable uses. On May 01, 2020 the Los Angeles Water Board requested additional information to complete the application. The City provided additional information on June 08, 2020 and the Los Angeles Water Board deemed the ROWD complete on August 21, 2020.

6.2. The City submitted a Title 22 Engineering Report for the production, distribution, and use of advanced-treated recycled water from the City’s new

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AWTF on April 22, 2020 for which DDW provided comments on June 01, 2020. The City submitted a revised Title 22 Engineering Report dated July 16, 2020 and DDW conditionally approved the Title 22 Engineering Report on August 19, 2020.

6.3. This Order includes findings and requirements necessary to ensure the advanced-treated recycled water produced by the AWTF complies with the applicable policies. The City is responsible for producing recycled water that is at least equivalent to disinfected tertiary recycled water, processing individual end-user applications, inspecting point-of-use facilities, and ensuring end-users’ compliance with the requirements contained in this Order. The actual delivery of recycled water to end-users is subject to approval by DDW and/or its delegated local health agency.

7. REGULATION OF RECYCLED WATER

7.1. State authority to oversee recycled water use is shared by the State Water Resources Control Board (State Water Board) including DDW, and the Los Angeles Water Board. DDW is the agency with the primary responsibility for establishing water recycling criteria under the California Code of Regulations (CCR) title 22 to protect the health of the public while using recycled water.

The State Water Board and the regional water boards are responsible for issuing WDRs and WRRs for water that is used or proposed to be used as recycled water.

7.2. On January 6, 1977, the State Water Board adopted Resolution No. 77-1, Policy with Respect to Water Reclamation in California, which includes principles that encourage and recommend funding for water recycling and its use in water-short areas of the state. On September 26, 1988 the Los Angeles Water Board also adopted Resolution No. 88-012, which encourages the beneficial use of recycled wastewater and supports water recycling projects.

7.3. The State Water Board adopted the Water Quality Control Policy for Recycled Water (Recycled Water Policy, State Water Board Resolution No. 2009-0011) on February 3, 2009 and amended the Policy on January 22, 2013 (State Water Board Resolution No. 2013-0003). The Recycled Water Policy was further amended and adopted on December 11, 2018 (State Water Board Resolution No. 2018-0057) by the State Water Board and approved by the Office of Administrative Law (OAL) on April 08, 2019. In part, the purpose of the Recycled Water Policy is to increase the beneficial use of recycled water from municipal wastewater sources in a manner consistent with state and federal water quality laws and regulations and to protect groundwater resources. This Order includes requirements consistent with the Recycled Water Policy.

7.4. In section 4 of the amended Recycled Water Policy (Resolution No. 2018- 0057), the State Water board and the regional water boards are the two

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primary agencies with jurisdiction over the use and regulation of recycled water. The State Water Board:

• establishes general policies governing the permitting of recycled water projects,

• develops uniform water recycling criteria appropriate to particular uses of water and processes,

• approves wastewater change petitions filed by wastewater dischargers for recycled water projects that have the potential to decrease flow in any portion of a watercourse such as a river or stream,

• adopts statewide orders for the permitting of recycled water projects,

• reviews and approves Title 22 engineering reports for recycled water use, and

• allocates and disperses funding for recycled water projects consistent with its roles of protecting water quality, public health, and sustaining water supplies.

The State Water Board also exercises general oversight of recycled water projects, including review of regional water board permitting practices.

The regional water boards issue permits that include requirements needed to protect water quality, human health, and the environment consistent with the State and Regional Water Quality Control Plans, policies, and applicable law.

The regional water boards also exercise their authority to encourage the use of recycled water.

7.5. CWC section 13523(a) provides that a regional water board, after consulting with and receiving recommendations from DDW or its delegated local health agency, and after any necessary hearing, shall, if it determines such action to be necessary to protect the health, safety, or welfare of the public, prescribe WRRs for water that is used or proposed to be used as recycled water. CWC section 13523 further provides that, at a minimum, the WRRs shall include, or be in conformance with, the statewide water recycling criteria established by DDW pursuant to CWC section 13521.

7.6. CWC section 13523.5, on WRRs, states that a regional water board may not deny issuance of WRRs to a project that violates only a salinity standard in a Basin Plan. This provision does not apply to WDRs. WDRs for projects that recycle water may contain effluent and other limitations on discharges of salts, as necessary to meet water quality objectives, comply with the Antidegradation Policy or otherwise protect beneficial uses.

7.7. Pursuant to CWC section 13523, the Los Angeles Water Board has consulted with DDW regarding the proposed recycling project and has incorporated their recommendations into this Order.

7.8. Section 7.4 of the Recycled Water Policy states that site-specific groundwater monitoring shall not be required for irrigation projects where recycled water is

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applied at rates that minimize percolation of recycled water below the plants’ root zone and account for the nutrient levels in the recycled water and nutrient demand by plants when applying fertilizers. The Recycled Water Policy also includes exceptions to this exemption from groundwater monitoring including when a regional water board determines there are unique site-specific conditions or such project-specific monitoring is required under the accepted salt and nutrient management plan, applicable basin plan, or other water board program such as the Irrigated Lands Program. Unique site-specific conditions include but are not limited to recycled water that is proposed to be used for irrigation over high transmissivity soils over a shallow (5 feet or less) high quality groundwater aquifer or proposed to be stored in unlined ponds where the regional water board determines that it will result in an unacceptable threat to groundwater quality. This Order is being issued without site-specific groundwater monitoring since the irrigation permitted under this Order requires the recycled water to be applied at rates that minimize percolation below the plants’ root zone. The exceptions to the exemption do not apply because there are no site-specific conditions that may result in an unacceptable threat to groundwater quality when recycled water is used in compliance with this Order.

7.9. It is the intent of the recycled water policy for salts and nutrients to be addressed regionally rather than imposing requirements solely on individual recycled water projects. Section 6.1.2 of the Recycled Water Policy states, “Salts and nutrients from all sources must be managed on a basin-wide or watershed-wide basis in a manner that ensures attainment of water quality objectives and protection of beneficial uses. The most effective way to address salt and nutrient loading is typically through the development of regional or subregional salt and nutrient management plans rather than imposing requirements solely on individual recycled water projects or other individual sources of salts and nutrients.”

7.10. A goal of the Recycled Water Policy is to increase the beneficial use of recycled water from municipal wastewater sources in a manner consistent with state and federal water quality laws and regulations. The Recycled Water Policy directs the regional water boards to collaborate with generators of municipal wastewater and interested parties in the development of SNMPs to manage loadings of salts and nutrients to groundwater basins in a manner that is protective of beneficial uses, thereby supporting the sustainable use of local waters. The City is currently developing a Salt and Nutrient Management Plan for the Santa Monica Groundwater Basin. Since there is no SNMP for the Santa Monica Groundwater Basin currently, the City has provided an Antidegradation Study for nonpotable reuse of the recycled water, as described in section 8.3.2 below.

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8. OTHER APPLICABLE PLANS, POLICIES AND AUTHORITIES

8.1. THE BASIN PLAN

8.1.1. The Water Quality Control Plan for the Los Angeles Region: Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan) designates beneficial uses for surface and groundwater;

establishes narrative and numeric water quality objectives that shall be attained or maintained to protect the designated (existing and potential) beneficial uses and conform to the State’s antidegradation policy; and includes implementation provisions, programs, and policies to protect all waters in the region. In addition, the Basin Plan incorporates all applicable State Water Board and Los Angeles Water Board plans and policies and other pertinent water quality policies and regulations.

8.1.2. The Basin Plan incorporates the primary MCLs found in the California Code of Regulations by reference. This incorporation is prospective, including future changes to the incorporated provisions as the changes take effect. Groundwater designated for use as domestic or municipal supply shall not contain concentrations of chemical constituents and radionuclides in excess of the MCLs. The Basin Plan also specifies that groundwaters shall not contain taste or odor-producing substances in concentrations that cause nuisance or adversely affect beneficial uses.

8.1.3. The Basin Plan contains water quality objectives for groundwater in the Santa Monica Basin of the Coastal Plain of Los Angeles. The beneficial uses of the receiving groundwater basin are as follows:

TABLE 4. BENEFICIAL USES OF GROUNDWATER

Receiving Water Name Beneficial Uses

Coastal Plain of Los Angeles (Santa Monica Basin;

Department of Water Resources (DWR) Basin No. 4-11.01)

Existing Beneficial Uses:

Municipal and domestic water supply (MUN); industrial service supply (IND); industrial process supply (PROC);

and agricultural supply (AGR).

8.1.4. The Basin Plan water quality objectives for salts in the Santa Monica groundwater basin are:

TABLE 5. GROUNDWATER QUALITY OBJECTIVES FOR SALTS

Basin

DWR

Basin

No.

TDS

(mg/L)

Sulfate (mg/L)

Chloride (mg/L)

Boron (mg/L)

Coastal Plain of Los Angeles Santa Monica

4-11.01 1000 250 200 0.5

8.2 PORTER-COLOGNE WATER QUALITY CONTROL ACT

8.2.1. CWC section 13263 requires that the Los Angeles Water Board prescribe requirements as to the nature of any discharge to waters of the State, implementing any relevant water quality control plan and

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taking into consideration beneficial uses, water quality objectives, and the need to prevent nuisance.

8.2.2. Pursuant to CWC section 13263(g), discharges of waste into water of the state are privileges, not rights. Nothing in this Order creates a vested right to continue the discharge. CWC section 13263 authorizes the Los Angeles Water Board to issue waste discharge requirements that implement any relevant water quality control plan.

8.2.3. CWC section 13267 authorizes the Los Angeles Water Board to require technical and monitoring reports. The attached MRP establishes monitoring and reporting requirements to implement federal and state requirements. CWC section 13267(b) states, in part:

“In conducting an investigation specified in subdivision (a), the regional board may require that any person who has discharged, discharges, or is suspected of having discharged or discharging or proposes to discharge within its region, or any citizen or domiciliary, or political agency or entity of this state who has discharged, discharges, or is suspected of having discharged or discharging, or who proposes to discharge waste outside of its region shall furnish under penalty of perjury, technical or monitoring program reports which the Regional Board requires. The burden, including costs of these reports shall bear a reasonable relationship to the need for the reports and the benefits to be obtained from the reports. In requiring those reports, the regional board shall provide the person with a written explanation with regard to the need for the reports and shall identify the evidence that supports requiring that person to provide the reports.”

8.2.4. The need for technical and monitoring reports required by this Order, including the MRP, are based on the Report of Waste Discharge (ROWD) and Engineering Report; the recommendations from DDW;

and other information in the Los Angeles Water Board’s files for the facility. The technical and monitoring reports are necessary to assure compliance with this Order. The burden, including costs, of providing the technical reports required by this Order bears a reasonable relationship to the need for the reports and the benefits to be obtained from the reports. Specifically, the required monitoring is needed to confirm that operation of the AWTF meets the parameters of this Order and complies with the Basin Plan, thus protecting human health, including drinking water supplies, and the environment.

8.2.5. Pursuant to CWC section 13320, any aggrieved party may seek review of this Order by filing a petition with the State Water Board in accordance with CCR, title 23, sections 2050-2068. The State Water Board must receive the petition by 5:00 p.m., 30 days after adoption of this Order, except that if the thirtieth day following the date of this Order falls on a Saturday, Sunday, or State holiday, the petition must be received by the State Water Board by 5:00 p.m. on the next business

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day. Copies of the law and regulations applicable to filing petitions (http://waterboards.ca.gov/public_notices/petitions/water_quality) may be found on the State Water Boards’ website.

8.2.6. The Los Angeles Water Board has notified the City, interested agencies, and persons of its intent to issue this Order for the production and use of recycled water and has provided them with an opportunity to submit written comments. The Los Angeles Water Board, in a public meeting, heard and considered all comments pertaining to this Order.

(CWC section 13263.)

8.3 ANTIDEGRADATION POLICY

8.3.1. On October 28, 1968, the State Water Board adopted Resolution No.

68-16, Statement of Policy with Respect to Maintaining High Quality of Waters in California (Resolution 68-16), establishing an Antidegradation Policy for the State Water Board and Regional Water Boards.

Resolution 68-16 requires the Los Angeles Water Board, in regulating discharge of waste, to maintain high quality waters of the State until it is demonstrated that any change in quality (1) will be consistent with maximum benefit to the people of the State, (2) will not unreasonably affect beneficial uses, and (3) will not result in water quality less than that prescribed in the Los Angeles Water Board’s policies. Resolution 68-16 requires the discharge to be regulated to meet best practicable treatment or control to assure that pollution or nuisance will not occur and the highest water quality consistent with the maximum benefit to the people of the State be maintained. The Los Angeles Water Board’s Basin Plan incorporates, by reference, the state antidegradation policy.

8.3.2. Section 7.2.2 of the Recycled Water Policy requires that, “for non-potable recycled water projects ineligible or inappropriate for enrollment under statewide water reclamation requirements, project proponents must submit an antidegradation analysis to the Los Angeles Water Board with the report of waste discharge to demonstrate compliance with the Antidegradation Policy.” The City submitted an Antidegradation Study on May 05, 2020 and the Los Angeles Water Board requested revisions to the study on July 24, 2020. The City submitted a revised version of the Antidegradation Study on September 29, 2020 and the study adequately evaluates the potential impacts of the proposed activities associated with nonpotable uses of the recycled water in compliance with the Antidegradation Policy.

8.3.3. This Order regulates discharges to the SMGB. The SMGB contains high quality water, as described in section 8.3.6 below. To the extent use of recycled water for nonpotable uses may result in the discharge to the SMGB, this Order authorizes limited degradation consistent with the Antidegradation Policy as described in the findings below. The analysis is based on the information provided in the Antidegradation Study dated September 29, 2020. A SNMP is currently being developed for the http://waterboards.ca.gov/public_notices/petitions/water_quality http://waterboards.ca.gov/public_notices/petitions/water_quality

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Santa Monica subbasin in accordance with the Recycled Water Policy, which will require ongoing analysis to evaluate inputs into the basin, the salt and nutrient mass balance, and the available assimilative capacity.

8.3.4. This Order requires best practicable treatment and control, which is a combination of advanced treatment, storage, and application methods that implement the requirements of 22 CCR and the Basin Plan.

Recycled water is generated by treating domestic wastewater adequately to make the water suitable for direct beneficial use that would not otherwise occur. The required level of treatment in this Order corresponds to the proposed use of recycled water for nonpotable use.

In addition, this Order includes requirements regarding the storage and application of recycled water to protect water quality and to limit public contact with recycled water, as appropriate. These requirements will assure that pollution or nuisance will not occur and the highest water quality consistent with the maximum benefit to the people of the State be maintained.

8.3.5. The SWIP, including the AWTF, increases the use of local supplies by reusing water that would otherwise flow to the ocean via the Hyperion Water Reclamation Plant or the storm drain system without supporting beneficial uses during transmission. The use of recycled water in place of potable water supplies for the nonpotable uses allowed under this Order improves local water supply availability and reduces the need to rely on imported water.

8.3.6. As part of the Antidegradation Study dated September 29, 2020, the City collected five groundwater samples between 2017 and 2020 and had them analyzed for salts and nutrients. The data collected indicates that the average concentrations of chloride (80 mg/L), sulfate (140 mg/L), TDS (580 mg/L), boron (0.12 mg/L), nitrate (0.8 mg/L), nitrite (0.10 mg/L), and nitrate plus nitrite (0.51 mg/L) in the groundwater are all below the water quality objectives in the Basin Plan for chloride (200 mg/L), sulfate (250 mg/L), TDS (1,000 mg/L), boron (0.5 mg/L), nitrate (10 mg/L), nitrite (1 mg/L), and nitrate plus nitrite (10 mg/L). A conservative estimate (disregarding any impact of dilution by stormwater) of the advanced-treated recycled water concentrations for chloride (28 mg/L), sulfate (3.2 mg/L), TDS (120 mg/L), boron (0.3 mg/L), nitrate (3.9 mg/L), nitrite (<0.1 mg/L), and nitrate plus nitrite (0.9 mg/L) also indicates the water quality objectives in the Basin Plan for salts and nutrients will be achieved. Based on these conservative estimates, the advanced-treated recycled water is expected to have lower concentrations of TDS, chloride, and sulfate but higher concentrations of boron (0.3 mg/L vs 0.12 mg/L), nitrate (3.9 mg/L vs

0.8 mg/L), and nitrate plus nitrite (0.9 mg/L vs 0.51 mg/L) than the current groundwater quality. Since there is limited data on the concentrations of salts and nutrients in the Santa Monica Basin, the above comparisons are only rough estimates and additional

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groundwater data is needed to provide an accurate picture of the actual current groundwater quality. The City is in the process of collecting additional groundwater data to support the antidegradation analysis for the indirect potable reuse operations. The additional data will provide a more accurate estimate of the current groundwater quality before recycled water is injected directly into the aquifer. As required by the Antidegradation Policy, the Los Angeles Water Board finds that the limited degradation of groundwater with respect to boron and nitrogen species that may occur as the result of using the advanced-treated recycled water for the nonpotable uses permitted under the conditions of this Order provides maximum benefit to the people of California, provided the recycled water treatment and use are managed to ensure long-term reasonable protection of beneficial uses to waters of the State.

8.3.7. 22 CCR imposes limitations on the uses of recycled water, based on the level of treatment and the specific use to protect public health. By restricting the use of recycled water to those meeting the requirements in 22 CCR, this Order ensures the water will be used safely. To the extent that the use of recycled water may result in some waste constituents entering the environment after effective source control, advanced treatment and other control measures are implemented, the conditions of this Order limiting the use of recycled water to agronomic rates is part of the suite of treatment, storage, and application measures that comprise best practical treatment and control for irrigation. Other types of uses that may be approved such as toilet/urinal flushing in dual-plumbed systems, dust control, , and other short-term or infrequent applications are unlikely to result in sufficient loading of waste constituents that impact water quality.

8.3.8. Constituents associated with recycled water that have the potential to degrade groundwater include salinity, nutrients, pathogens (represented by coliform bacteria), disinfection byproducts (DBPs), constituents of emerging concern (CECs), and endocrine disrupting chemicals (EDCs).

The Los Angeles Water Board finds that the use of recycled water permitted under this Order will not unreasonably affect beneficial uses or result in water quality that is less than that is described in the applicable policies. The characteristics and requirements associated with each of the recycled water constituents of concern are discussed below:

a. Salinity is measured in water through various measurements, including but not limited to, total dissolved solids (TDS) and electrical conductivity. Excessive salinity can impair the beneficial uses of water. Salinity levels in the receiving water can be affected by the use of recycled water if the recycled water has elevated concentrations of salinity. This Order requires the advanced-treated recycled water from the AWTF to meet the salinity water quality

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objectives for the Santa Monica Groundwater Basin. The AWTF will remove salts using a reverse osmosis system. Although the water delivered to customers for irrigation will be a mixture of advanced-treated recycled water from the AWTF and stormwater and dry-weather runoff treated by the SMURRF, and potable water when alternate water supplies are insufficient to meet the demand, the main source of water will be the advanced-treated recycled water from the AWTF. Since stormwater and dry weather runoff have low salt concentrations and the majority of water used for irrigation is from the AWTF, and the fact that the advanced-treated recycled water is required to meet the water quality objectives for salts, the use of nonpotable water for irrigation in the Land Use area will not impair the beneficial uses of groundwater in the SMGB.

b. Nitrogen is a nutrient that may be present in recycled water. The AWTF will be designed to remove nitrogen from wastewater using a membrane bioreactor and reverse osmosis system. The AWTF will reduce the concentration of nitrogen compounds below the primary MCLs and Basin Plan objectives, as required in this Order. In addition, this Order requires application of recycled water to take into consideration nutrient levels in recycled water and nutrient demand by plants. Application of recycled water at agronomic rates and considering soil, climate, and plant demand minimizes the movement of nutrients below the plants' root zone. When applied to cropped (or landscaped) land, some of the nitrogen in recycled water will be taken up by the plants, lost to the atmosphere through volatilization of ammonia or denitrification, or stored in the soil matrix. As a result, nitrogen will not impair an existing and/or potential beneficial use of groundwater.

c. Pathogens and other microorganisms may be present in recycled water based on the disinfection status. Coliform bacteria are used as a surrogate (indicator) because they are present in untreated wastewater, survive in the environment similar to pathogenic bacteria, and are easy to detect and quantify. Pathogens are generally limited in their mobility when applied to land.

The AWTF will include multiple systems that will remove pathogenic microorganisms, including a membrane bioreactor, cartridge filters, reverse osmosis, and UVAOP. The recycled water will meet the pathogenic microorganism requirements for filtered wastewater in 22

CCR § 60301.230.

In addition, setbacks from recycled water use areas are required in 22 CCR as a means of reducing pathogenic risks by coupling pathogen inactivation rates with groundwater travel time to a domestic water supply well or other potential exposure route (e.g.

water contact activities). In general, a substantial unsaturated zone

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reduces pathogen survival compared to saturated soil conditions.

Fine grained soil particles (silt or clay) reduce the rate of groundwater transport and therefore are generally less likely to transport pathogens. Setbacks also provide attenuation of other recycled water constituents through physical, chemical, and biological processes.

d. Disinfection by-products (DBPs) consist of organic and inorganic substances produced by the interaction of chemical disinfectants with naturally occurring substances in the water source. Common disinfection by-products include trihalomethanes, haloacetic acids, bromate, and chlorite. DBPs present in wastewater will be reduced by treatment at the AWTF and the recycled water will receive additional treatment when applied to land. Biodegradation, adsorption, volatilization, and other attenuative processes that occur naturally in soil will reduce the concentrations and retard migration of DBPs in the subsurface.

e. Chemicals of Emerging Concern (CECs) in recycled water as defined in the Recycled Water Policy are chemicals in personal care products, pharmaceuticals including antibiotics, antimicrobials;

industrial, agricultural, and household chemicals; hormones; food additives; transformation products, inorganic constituents; and nanomaterials. CECs are new classes of chemicals, diverse, and relatively unmonitored chemicals. Many of them are so new that standardized measurement methods and toxicological data for interpreting their potential human or ecosystem health effects are unavailable. The State Water Board convened a CEC Advisory Panel to address questions about regulating CECs with respect to the use of recycled water. The Panel’s primary charge was to provide guidance for developing monitoring programs that assess potential CEC threats from various water recycling practices, including groundwater recharge/reuse and urban landscape irrigation. The Panel provided recommendations for monitoring specific CECs in recycled water used for groundwater recharge reuse. Monitoring of health-based CECs or performance indicator CECs is not required for recycled water used for landscape irrigation and other nonpotable uses due to the low risk of ingestion of the water; however the RO system of the AWTF will reduce the concentration of CECs in the recycled water. The CEC monitoring recommendations were made part of the Recycled Water Policy and since this Order does not provide coverage for groundwater recharge activities, CEC monitoring is not required in this Order.

f. Endocrine disrupting chemicals (EDCs) are mostly man-made, found in various materials such as pesticides, metals, additives, or contaminants in food, and personal care products. Human exposure to EDCs occurs via ingestion of food, dust and water, via inhalation

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of gases and particles in the air, and through the skin. Perchlorate is an EDC that may be present in hypochlorite solutions, which is a type of disinfectant used to treat the recycled water from the AWTF.

Formation of perchlorate in hypochlorite solution can be minimized when proper manufacturing, handling, and storage conditions are followed. Perchlorate accumulation has been documented in fruit and seed-bearing crops and leafy vegetation irrigated with perchlorate contaminated water. Recycled water currently makes up less than one percent of California agricultural water supply. Much of the recycled water used for agricultural irrigation is either undisinfected or is disinfected by means that do not result in perchlorate generation, such as ultraviolet light and chlorine gas.

The AWTF will disinfect the recycled water using ultraviolet light in addition to sodium hypochlorite. Some sources of agricultural water supply in some areas of the state contain perchlorate, such as surface water from Colorado River or groundwater sources in areas near industrial or military application sites (e.g. Riverside, San Bernardino, and Los Angeles counties). The blending of sources of irrigation water will further reduce any concentration of perchlorate present in recycled water and will be unlikely to affect beneficial uses or degrade groundwater quality. In addition, the RO system of the AWTF will reduce the concentration of EDCs in the recycled water prior to distribution.

8.3.9. Using recycled water for nonpotable reuse is to the maximum benefit to the people of the State. The use of recycled water for irrigation and dual-plumbed systems reduces the region’s dependence on imported potable water.

8.3.10. With regard to the land application areas, application of recycled water for irrigation is limited to agronomic rates and therefore is not expected to measurably impact groundwater quality or lead to any degradation.

To further limit the extent of any degradation, the recycled water is also required to meet the groundwater quality objectives in the Basin Plan for salts and nutrients. To the extent there is any degradation, the use of recycled water for irrigation is to the maximum benefit to the people of the State and the application in accordance with agronomic rates, in addition to the advanced treatment provided by the AWTF, constitutes best practicable treatment and control.

8.4. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) AND

NOTIFICATION

A draft Initial Study/ Mitigated Negative Declaration (IS/MND) for the SWIP was circulated for a 30-day public review from…