TAC MPRWA Agenda Packet 02-03-14

8/13/2019 TAC MPRWA Agenda Packet 02-03-14

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AgendaMonterey Peninsula Regional Water Authority (MPRWA)

Technical Advisory Committee (TAC)Regular Meeting

10:30 AM, Monday, February 3, 2014Council Chamber580 Pacific Street

Monterey, California

CALL TO ORDER

ROLL CALL

PLEDGE OF ALLEGIANCE

REPORTS FROM TAC MEMBERS

PUBLIC COMMENTSPUBLIC COMMENTS allows you, the public, to speak for a maximum of three minutes on anysubject which is within the jurisdiction of the MPRWA TAC and which is not on the agenda. Anyperson or group desiring to bring an item to the attention of the Committee may do so byaddressing the Committee during Public Comments or by addressing a letter of explanation to:MPRWA TAC, Attn: Monterey City Clerk, 580 Pacific St, Monterey, CA 93940. The appropriatestaff person will contact the sender concerning the details.

APPROVAL OF MINUTES

1. January 6, 2014

AGENDA ITEMS

2. Receive Report, Discuss and Provide Direction on the Ground Water Replenishment(GWR) Schedule, Response to Business Coalition Questions, and Product WaterNegotiations

3. Receive Report, Discuss and Provide Direction on the Cost Comparison Between theGround Water Replenishment Project and the Monterey Peninsula Water SupplyDesalination Project.

4. Receive Report, Discuss and Provide Direction on Status of Construction Permits for theMonterey Peninsula Water Supply Project Test Slant Well, Bore Holes, andHydrogeological Analysis

5. Receive and Discuss a Brine Disposal Report Prepared for the Authority by Interns fromthe Monterey Institute of International Studies (Information Only)

ADJOURNMENT


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Created date 01/31/2014 10:23 AM Monday, February 3, 2014

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The Monterey Peninsula Regional Water Authority is committed to include the disabled in all ofits services, programs and activities. For disabled access, dial 711 to use the California RelayService (CRS) to speak to staff at the Monterey City Clerks Office, the Principal Office of theAuthority. CRS offers free text-to-speech, speech-to-speech, and Spanish-language services24 hours a day, 7 days a week. If you require a hearing amplification device to attend ameeting, dial 711 to use CRS to talk to staff at the Monterey City Clerks Office at(831) 646-3935 to coordinate use of a device or for information on an agenda.

Agenda related writings or documents provided to the MPRWA are available for publicinspection during the meeting or may be requested from the Monterey City Clerks Office at 580Pacific St, Room 6, Monterey, CA 93940. This agenda is posted in compliance with CaliforniaGovernment Code Section 54954.2(a) or Section 54956.


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Monterey Peninsula Regional Water AuthorityAgenda Report

Date: February 03, 2014

Item No: 2.

06/12

FROM: Executive Director Cullem

SUBJECT: Receive Report, Discuss and Provide Direction on the Ground WaterReplenishment (GWR) Schedule, Response to Business Coalition Questions, andProduct Water Negotiations.

RECOMMENDATION:

Staff recommends that the TAC review the GWR schedule, noting focused scheduleactivities, review the MRWPCA responses to the Business Coalition Questions, andreview the status of GWR Product Water Negotiations with the purpose of establishing a

recommended decision date after which declaratory relief should be pursued.

DISCUSSION:

Attachment #1 is the latest (7 October 2013) schedule for completion of the GWRproject. Italicized dates represent the most recent completion dates while standard typereflects the dates established during settlement negotiations (10 September 2013).Items shown in red are suggested by staff to be critical, those in yellow as approachingcritical. All others do not seem to be critical or near critical as of this date.

Attachment #2 is the MRWPCA Proposed Groundwater Replenishment ProjectPhasing.

Attachment #3 is the Business Coalition Five Questions to the JPA TAC MRWPCAResponses.

ATTACHMENTS:

1. GWR focused schedule dated 3 Feb 2014.2. MRWPCA Proposed Groundwater Replenishment Project Phasing3. Business Coalition Five Questions to the JPA TAC MRWPCA Responses


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FOCUSEDSchedule and Task List for MPWSP Post Settlement (REV 3 Feb 2014)

CPUC Calendar Dates NOTE: Sept 10th entries shown in BLUEand rev Oct 7th entries in italics

Task Due Date Responsible Party Notes

Comments on

Settlement AgreementsDue

August 30, 2013 Complete

Reply Comments onSettlement Agreements

Due

September 13, 2013 Complete

PrehearingConference: Status ofSettlement Motion (ifany), of CEQA work

& other matters

September 16, 2013 Complete

Quarterly Check-in Callwith Settling Parties

October 2013 MPRWA In Progress

Informational Hearing

on SettlementAgreements

December 2-3, 2013


January 2014 MPRWA

DEIR circulated forComment

February 28, 2014


April 2014 MPRWA

Comments on DEIRDue

April 14, 2014

Common OutlineOpening Briefs due

April 29, 2014

Reply Briefs due May 14, 2014

FEIR published June 17, 2014

ProposedDecision on Phase I

Mailed

July, 2014 Phase 1


July 2014 MPRWA

Commission Action onPhase I

August, 2014


October 2014 MPRWA

GWR Phase -Testimonyof Interested Parties

(from Settlement K)

December 2014


January 2015 MPRWA

GWR Phase -Settlement discussion

commencing (fromSettlement K)

January 2015


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FOCUSEDSchedule and Task List for MPWSP Post Settlement (REV 3 Feb 2014)


GWR Phase -Concurrent Rebuttal

Testimony (fromSettlement K)

January 2015

GWR Phase -Evidentiary Hearings(from Settlement K)

February 2015

GWR Phase - Briefing(from Settlement K)

March 2015


April 2015 MPRWA

GWR Phase - ProposedDecision (fromSettlement K)

June 2015

Quarterly Check-in Call

with Settling Parties

July 2015 MPRWA

GWR Phase - FinalDecision (fromSettlement K)

July 2015


October 2015 MPRWA


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SECURITIZATIONTask

Due Date Responsible Party Notes

Draft Timeline and

Implementation Plan

August 2013 MPWMD Complete

Meet with LegislativeDelegation re: Timeline

and ImplementationPlan

August 2013 MPWMD & MPRWA Complete

Initial Revision andRedline of Legislation

Early September 2013 MPWMD Complete

Obtain Cal-Am Input onDraft Legislation

Late September 2013 MPWMD, MPRWA, &Cal-Am

In Progress

Retain NecessaryAdditional

Financial/LegalConsultants (Charles

Atkins)

October 2013 MPWMD In Progress

Revise FinancialComparison of

Securitization v. Cal-AmFinancing

Draft 1-2 Page Factsheet describing

legislation

October 2013Early October 2013

MPWMD & Cal-Am In Progress

Meeting withCommunity/InterestGroups and Cities

October-December2013

MPWMD & MPRWA In Progress

Further ReviseLegislation as

Necessary

October-November2013

November 2013

In Progress

Draft Summary ofLegislation

Legislative CounselPrepares Cover and

Digest

December 2013

Early January 2014

MPWMD

Legislative Counsel

Introduce LegislationMeet with LegislativeDelegation re strategy

January 2014Late January 2014

MPWMD, MPRWA, &Cal-Am

Lobbying Effort February-April 2014 MPWMD, MPRWA, &Cal-Am

Legislative CommitteeHearings

Legislation Adopted

February-March 2014

April-May 2014Initial Draft of Motion forFinancing Order

April 2014June 2014

MPWMD

Perform Analysis toDemonstrate Annual

Customer BenefitsExceed 1.0% of Total

Annual RevenueRequirement

April 2014June 2014

MPWMD & Cal-Am

Motion for FinancingOrder

May 2014July 2014

MPWMD

Obtain CPUC FinancingOrder

August 2014With Commission

Order on securitizationfinancing contingent on


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Action on Phase 1 asatisfaction of remain

crit from setl KPreliminary Discussionswith Bond Underwriters

September-December2014

MPWMD

Drafting of

documentation for bondrequests

September 2014-April

2015

MPWMD & Cal-Am

Preliminary Discussionswith Rating Agencies

February-April 2015 MPWMD


Obtain Rating on WaterRate Relief Bonds

July-August 2015 MPWMD

NEW ITEM

Determine internal costsof Cal-Am and AW tocomply withsecuritization structureto be included in ratesto Monterey Districtcustomers

July-August 2015 Cal-Am NEW ITEM

Obtain Letters FromRatings AgenciesDemonstrating No

Impact to AmericanWater

July-August 2015 MPWMD NEW ITEM

Obtain Legal Opinionthat Securitization DoesNot Create a Taxable

Event for Cal-Am

July-August 2015 MPWMD

Verification of AnnualCustomer Benefits

Exceed 1.0% of TotalAnnual Revenue

Requirement

July-August 2015 (orprior to Issuance of

Bonds)

MPWMD & Cal-Am

Cal-Am Creates SPE September 2015 MPWMD & Cal-Am

Water Rate ReliefBonds Issued

TBD(End of 2015?)


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GWR FOCUSEDSchedule and Task List for MPWSP Post Settlement (REV 3 Feb 2014)


Task Due Date Responsible Party NotesFile Motion forBifurcation of theGWR Decision

August 2013 MRWPCA Complete and Granted

Board Actions toApprove Revised

Governance CommitteeAgreement

October 2013August/Sept 2013

MPWMD, MPRWA,County, & Cal-Am

To be Completed inOctober

Executed Agreementsfor GWR Source Water

and/or DeclaratoryRelief

June 2014Sept/Nov 2013

MRWPCA Meet & Confer inProgress

Draft WPA

Mar 2014Oct/Dec 2013

MPWMD & MRWPCA

Obtain Representationsfrom DPH re Use of

Extracted GWR WaterOct 2014

Oct/Dec 2013

MRWPCA

Obtain Representationsfrom RWQCB re Use ofExtracted GWR Water

Oct 2014Oct/Dec 2013

MRWPCA

Storage Agreementwith Seaside Basin

WatermasterJul 2014

Oct/Dec 2013

MRWPCA & MPWMD

GWR Basis of DesignComplete with At Least

10% DesignJul 2014

Oct/Dec 2013

MRWPCA

GWR Financing PlanSufficient for SRF

FundingAug 2014

Oct/Dec 2013

MRWPCA & MPWMD

Agreement on Terms ofWPA May 2014

January 2014

Cal-Am, MRWPCA,&MPWMD

Perform RevenueRequirement Analysis

Including Any DebtEquivalency Effect

Jul 2014Jan-Mar 2014

MRWPCA & MPWMD

Perform Assessment ofGWR Positive and

Negative Externalitiesfor Any Premium

June 2014Jan-Mar 2014

MRWPCA & MPWMD


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ShowingDEIR Circulated July 2014 MRWPCADilution WaterRequirements

July-October 2014 MRWPCA

Project Approved andFEIR

October 2014 MRWPCA

All Permits for GWRConstruction Obtained ???

January 2015

MRWPCA


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Source Wells FOCUSEDSchedule and Task List for MPWSP Post Settlement (REV 3 Feb

2014)



Drill ExploratoryBoreholes

Sept. 2013 February2014

Cal-Am PENDING

CommenceHydrogeologic Studyand Technical Report

August 2013 Cal-Am / SVWC Draft completed. ?

Permits for CEMEXSite Test Well

January 2014 Cal-Am NOV 2014?

Drill CEMEX Site TestWell

February 2014 Cal-Am DELAYED

Results of Test WellOperation Obtained

February 2014 February 2016

Cal-Am DELAYED

Hydrogeologic Studyand Technical Report

Complete and ResultsFiled with CPUC

June 2015Cal-Am DELAYED

Necessary Agreementsfrom CEMEX for

Source Wells

Nov. 2015, or sooner Cal-Am ?

All Necessary Permitsfor Construction of

Source Wells Obtained

Nov. 2015, or sooner Cal-Am ?


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MRWPCA Proposed Groundwater Replenishment Project Phasing

F/FCEQA Technical

201520142013 2016

F/FCEQA Technical

REGULATORY

PERMITTING &

ENGINEERING REPORT

REGULATORY PERM

CDPH/SWRCB

Constructio

REGULATORY PERMITTING

CDPH/SWRCB

Updated 1/2/14

PILOT PLANT &

WELL TESTING

EIR Scoping:

Project

Understanding,

Notice of

Preparation,

and

Public MeetingAdmin Draft

Facility Plan

Final Facilities

Plan Report

Start Up

CPUC Hearings &

Workshops

Dec. 2016

Water Quality

Sampling &

Shunt Tests

Public

Review of

Draft EIR

Respond to

Comments

Product Water

Conveyance,

Injection Well

Design, Siting

Source Water

Rights &

Purchase

Agreement

Final EIR

Certify EIR and

Approve GWR

Facility Design

Mobilization &

Site Retrofits

IAP Meetings

SRF & Title XVI

Funding

Coordination

Internal Draft

Facilities Plan &

Feasibility StudyReports

Technical

Reports for

Admin Draft

EIR

Facility Testin

Dec. 2014

Pilot Test Start

& Monitoring

Well Install

Outreach

Meetings

Internal Draft

Facilities Plan &

Technical

Reports and

Admin Draft

EIR

Preparation

2ndAdmin/

Screen-

check Draft

EIR Prep

Public

Review Draft

EIR Prep

Product Water

Conveyance,

Injection Well

Easements and

Design

Refinements

Scoping Report

Technical Team

Prepares

Conceptual

Design

Information

Source Water

Treatment

Product Water

Conveyance

Groundwater

Injection

Cal Am

Distribution

ProjectDescription &Alternatives

Source Water

Treatment

Product Water

Conveyance

GroundwaterInjection

Cal Am

Distribution

Background

Development &

Investigations

Alternative

Analysis Report

SRF & Title XVI

Applications

Final Feasibility

Study Report

RFP for Design

& Build

CPUC

Determination

Construction

July 2015

CPUC

Settlement

Hearings

Facilities & Feasibility ReportsFacilities & Feasibility Reports


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Joint Powers Authority Member Entities:Boronda County Sanitation District, Castroville Community Services District, County of Monterey, Del Rey Oaks, Fort Ord, Marina Coast Water District, Monterey,

Moss Landing County Sanitation District, Pacific Grove, Salinas, Sand City, and Seaside.

Business Coalitions Five Questions to the JPA TACMRWPCA Responses

1. Is there an agreement with the local governments that clearly states thewastewater from these jurisdictions is available for GWR?

a. MRWPCA Legal Counsel has determined that, pursuant to Statelaw, once wastewater flows are provided to or delivered to theregional conveyance lines then that wastewater is owned by theMRWPCA to use 1) as it so determines, or 2) as agreed upon inprevious agreements.

2. Who currently has rights to the water in the reclamation ditches and willproducers of the source wastewater have rights to the reclaimedwastewater?

a. For the MRWPCA EIR, the Reclamation Ditch and the BlancoDrain are being classified as alternative supplemental sourcewater components. It is our understanding that flows in both theReclamation Ditch and Blanco Drain may be considered waters ofthe state under the jurisdiction of the State Water ResourcesControl Board (SWRCB) and would be comprised of precipitation-driven runoff, urban runoff, and agricultural return flows. For thepoints of diversion being considered in the Reclamation Ditch andBlanco Drain, the SWRCB website, http://www.waterboards.ca.gov/waterrights/water_issues/programs/ewrims/index.shtml showsthat no permits have been issued to divert surface flowsdownstream of these points of diversion. However, there appearto be pending permit applications for diversions in some of thestreams in the upland areas of the Reclamation Ditch watershed(i.e., upstream of the City of Salinas). Staff is preparing anapplication to request that the SWRCB make a determination toallow the use of these sources. In coordination with MPWMD, staffwill be consulting the SWRCB for the correct determination of usesfor these sources which may result in the preparation of anapplication.


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Response to Business CoalitionJanuary 29. 2014Page Two

3. Who has to approve the injection of the advanced treated water into localaquifers as part of the GWR process; in other words, from whom and how

many permits are needed?a. The California Department of Public Health (CDPH) formally

approves a project after review and approval of the projectscomprehensive engineering report. One permit is issued to injectthe water into local aquifers by the Central Coast Regional WaterQuality Control Board (RWQCBG). The permit includes CDPHand RWQCB requirements to protect all groundwater beneficialuses and water quality. A USEPA permit for a Class Vunderground injection well is not required. In July 2014, the CDPHDrinking Water Program is tentatively scheduled to become aDivision within the State Water Resources Control Board. As part

of this transition, the CDPH/RWQCB approval and permittingprocess may be modified, but the permit issued for an injectionproject that uses recycled water will still be crafted to protectbeneficial uses of groundwater and groundwater quality. Otherpermit(s), authorizations, or approvals will be required from localentities including: MPWMD, Seaside Basin Watermaster,Monterey County Environmental Health, City of Seaside, and FortOrd Reuse Authority to construct the injections and monitoringwells for the project.

4. What is the projected timeline for the GWR process from today to the time the

first gallons of water are pumped from the recharged aquifer into the CAWdistribution system?

a. Our target for project completion is January 1, 2017.

5. What is the projected cost per AF (+/- 10%) of the GWR water at the time it istaken from the recharge aquifer for delivery to Cal Am (or other distributor)and what is a definitive estimate of the cost of water to Cal Am customers?

a. The range in cost per acre foot is still estimated to be $2,500/AF.As the feasibility and facilities planning documents begin to shoreup some project costs this summer, the figure will have more

clarity. We have contacted Cal Am regarding the estimate of thecost of water to Cal Am customers as we currently do have not thecost for distribution. Additional information is attached regardinganticipated Cal Am water costs.

Z:\General Manager\Mayors JPA-MPR Water Authority\Business Coalitions GWR Questions-Responses 1-29-14.doc


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Item No: 3.

06/12


SUBJECT: Receive Report, Discuss and Provide Direction on the cost comparisonbetween the Ground Water Replenishment project and the MontereyPeninsula Water Supply Desalination project.

RECOMMENDATION:

Staff recommends that the TAC review, and provide direction on the current costelements for both GWR and DESAL as well as available present value or annualized

costs.

DISCUSSION:

The CDM bid price for the Cal-Am DESAL project reflects a $2.2 million price differencebetween the 6.4 mgd plant and the 9.6 mgd plant. This small difference suggests thatannual operating costs will be major factors in allowing GWR to be price- competitivewith DESAL.

To date, Cal-Am has very good estimates of DESAL capital costs, but has not yetdetailed the cost elements comprising O&M. On the other hand, the Pollution Control

Agency has developed fairly detailed cost elements for O&M but has not yet fullyidentified all GWR capital costs.

Accordingly, it is important to identify all cost elements of both projects, particularlypresent values or annualized costs of leases, electrical power, operations, andmaintenance. Until we are able to identify similar cost elements we will continue tocompare apples with oranges.

Keith Israel from the Pollution Control Agency will provide an update on current costelements of the GWR project.

Ian Crooks from Cal-Am will provide an update on the current cost elements of theDESAL project.

ATTACHMENTS:

Pollution Control Agency Listing of GWR Cost Elements


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Joint Powers Authority Member Entities:Boronda County Sanitation District, Castroville Community Services District, County of Monterey, Del Rey Oaks, Fort Ord, Marina Coast Water District, Monterey,

Moss Landing County Sanitation District, Pacific Grove, Salinas, Sand City, and Seaside.

1/30/2014

GWR Annualized Cost Components

1. Capital recovery (assume 30-year SRF loan)

2. Operations and maintenance costs

a. Power

b. Chemicals

c. Labor

d. Materials

e. Equipment replacement

f. Miscellaneous costs

3. Treatment costs for water through secondary treatment

4. Transmission (lease of RUWAP)

5. Contributions from various parties towards annualizedcosts

Z:\General Manager\Mayors JPA-MPR Water Authority\GWR annualized costs components 1-30-14.doc


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Item No: 4.

06/12


SUBJECT: Receive Report, Discuss and Provide Direction on status of permits forconstruction of Cal-Ams DESAL test slant well and bore holes as well statusof the hydrogeological analysis.

RECOMMENDATION:

Staff recommends that the TAC receive a report from Cal-Am on the status of the testslant well and bore hole construction and an update on the hydrogeological task forcewhich will analyze the test data.

DISCUSSION:

Attached is a copy of the staff report considered by the Water Authority at a specialmeeting held on January 30. The purpose of the special meeting was to addressproblems with the issuance of City of Marina permits that have now resulted in a delayof the release of the DEIR for the Monterey Peninsula Water Supply Project (MPWSP).

Ian Crooks from Cal-Am will provide the TAC with an update on the slant well, boreholes, and the hydrogeological analysis.

ATTACHMENTS:

Staff report to the Water Authority dated January 30, 2014


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Item No: 5.

06/12


SUBJECT: Receive and Discuss a Brine Disposal Report prepared for the MPRWA byInterns from the Monterey Institute of International Studies.

RECOMMENDATION:

Staff recommends that the TAC receive and discuss the attached Brine Disposal Reportprepared for the MPRWA by two MIIS interns.

DISCUSSION:

Monterey Institute of International Studies (MIIS) students Rainey Graeven andNereyda Montano have served as interns for the Water Authority during the last quarterof 2013. They submitted an authoritative report to the Authority in December. The reportis included herein for TAC review and discussion.

Both interns completed their service to the Authority by staffing the MPRWA duringWhale Fest 25 & 26 January 2014.

ATTACHMENT:

The Environmental Implications of Brine Disposal in Monterey Bay Brine Disposal -byRainey Graeven & Nereyda Montono


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Prepared for:

Monterey Peninsula Regional Water Authority

Rainey Graeven

Nereyda MontaoMonterey Institute of International Studies

December 20, 2013


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&


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This report provides a summary of the issues surrounding brine disposal in the Monterey Bay.

It examines existing research regarding brine disposal methods from a variety of desalinationplants located throughout the world, and analyzes the applicability of these methods to the

Monterey Bay. Based on an analysis of available research, we have determined that ocean brine

disposal is the most suitable and economically feasible method of brine disposal for theMonterey Bay. The report concludes by offering recommendations in order to minimize and

mitigate the potential negative environmental externalities and consequences associated with

ocean brine disposal in the Monterey Bay.

In the coming years, the Monterey Peninsula will undergo a drastic shift in water supply.

Beginning in January of 2017, the region is legally obligated by the state of California to reduceits dependency on the Carmel River by 70%. In order to meet local water demand, local

administration and CalAm water company have agreed to build a desalination plant. Among the

many controversial issues associated with desalination, brine disposal is a particularly significantissue for the Monterey Bay. Not only is the Monterey Bay home to a highly diverse ecosystem, athriving marine tourism industry, and numerous profitable fisheries, but it also encompasses the

Monterey Bay National Marine Sanctuary, a federally protected marine area. The brine disposal

associated with desalination could pose serious threats to the Monterey Bays economy and theecosystem itself. This report identifies the various methods of brine disposal, considers whether

or not these methods are feasible for the Monterey Bay, and suggests ways to minimize

environmental alterations and disturbances resulting from brine disposal.

Modern desalination technology has been around since the 1930s (Cooley et al., 2013), and

has been used in the United States since the 1960s; the literature and research surroundingdesalination largely focuses on the various methods of desalination and brine disposal. Literature

regarding brine disposal is oftentimes site-specific, detailing how a specific method of brine

disposal affects the local ecosystem and/or why that method was chosen. This literature is

helpful in outlining some of the potential problems resulting from various methods of brinedisposal; however, the applicability of these cases to the Monterey Bay remains uncertain.

Because the exact method of brine disposal, salinity of the saltwater and the reject brine, and

ecosystem habitat are all unique to each specific location, some of the existing research can beused to predict how the Monterey Bay ecosystem might respond, but there is potential for

unforeseeable consequences and reactions.

Glater & Cohen (2006) explicitly compare the various methods of brine disposal used for

inland desalination plants, namely evaporation ponds and deep well injection. Deep well

injection entails injecting liquid solutions into wells between ranging from a couple hundred toseveral thousand feet deep, meanwhile evaporation ponds involve drying out the reject brine over

large surfaces of varying size and relatively shallow depths. Once the evaporation process is

complete, the remaining byproduct, salt, can then be harvested and manufactured into


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commercial salt (Glater & Cohen, 2006). Of the two methods, deep well injection is the more

cost-effective method of inland brine disposal (Glater & Cohen, 2006). Currently, liquid toxicand hazardous waste account for most of the deep well injections in the United States. The only

state currently using deep-well injection for brine disposal is Florida. Though deep-well injection

has been deemed a feasible alternative for brine disposal from some desalination plants, there are

noteworthy drawbacks, including selecting suitable well sites and the cost involved. The lesscost-efficient form of brine disposal for inland plants is evaporation ponds. Glater & Cohen

(2006) argue that evaporation ponds pose the fewest environmental concerns; however, theseponds require highly specific conditions. Evaporation ponds are limited to desalination plants

that pump a maximum of 5 million gallons per day (MGD). In addition, evaporation ponds

require relatively arid conditions, and substantial land for the evaporation process (Glater &Cohen, 2006).

In a 2011 report on ocean brine disposal, Elimelech & Phillip indicated that no research

has been done to examine the long-term effects of brine disposal on the marine environment.They note that both elevated salinity levels and the chemicals used in the treatment process are

harmful to marine life; however, the degree of harm is unknown. In terms of potentially harmfulchemical additives, the main chemicals used in the reverse osmosis desalination plants includeantiscalants, coagulants, and cleaning chemicals (i.e. surfactants, alkaline and acid solutions, and

metal chelating agents), all of which may pose risks to aquatic life (Elimelech & Phillip, 2011).

The report goes on to discuss other environmental impacts associated with ocean brine

disposal, particularly high salinity levels, and offers suggestions to minimize the effects of high

salinity levels. The report cites mixing brine with either power plant cooling water or treated

wastewater, a strategy common in Australia and Spain. This method uses efficient diffusersystems and strategically locates outfall pipes in areas of high hydrodynamic activity for rapid

mixing and dissipation of the salinity load (Elimelech & Phillip, 2011: 716). The report expands

upon this idea of strategic outfall placement by stating that the areas that are least sensitive tobrine disposal are high-energy oceanic coasts that have strong waves and exposed rocky shores

(Elimelech & Phillip, 2011: 716).

Furthermore, the report argues that how and when the seawater is treated also plays a

critical role in the environmental impact of the discharged brine. Specifically, membrane-based

pre-treatment using microfiltration or ultrafiltration can further reduce the overall impact of the

brine disposal (Elimelech & Phillip, 2011). This method uses fewer chemicals than the standardseawater pre-treatment method of coagulation followed by sand filtration (Elimelech & Phillip,

2011). Effective pre-treatment also reduces the rate of fouling and chemical cleaning

(Elimelech & Phillip, 2011), suggesting both environmental and economic benefits can be gainedfrom effective early treatment. Elimelech & Phillip (2011) caution that long-term research is

limited but provide valuable insight on how to minimize environmental degradation and

disruptions from ocean brine disposal.

In March of 2012, in support of an amendment to the Ocean Plan, a science advisory

panel prepared a report for the California State Water Resources Control Board about managingbrine discharges to coastal waters (SCCWRP 2012). The five panel members reviewed existing

literature on the topic of brine disposal and concluded that concentrate can be disposed of with


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minimal environmental effects if properly executed (SCCWRP 2012:ii). However, the report

notes that very few peer-reviewed studies have evaluated sublethal effects of desalinationdischarges (SCCWRP 2012:9). The report goes on to note that few studies have evaluated

worst-case embayment areas such as the Monterey Bay, where there is little circulation

(SCCWRP 2012:14).

Few regulations exist for brine discharges around the world (SCCWRP 2012: ii). Regulationsmay limit salinity changes based on incremental change, percentage change or absolute change.

For example, a limit may be salinity increments within 1 ppt or 5% of ambient salinity levels, or

an absolute maximum level of 40 ppt. Evaluation is typically at the boundary of a mixing zonewhose dimensions are of order 50 m to 300 m around the discharge (SCCWRP 2012: ii). Salinity

limits are usually an increment of 1 to 4 ppt relative to ambient levels (SCCWRP 2010:4).

Although there is substantial variation on the specifics of these regulations, most share two

important elements: (1) a salinity limit and (2) a point of compliance expressed as a distancefrom the discharge (SCCWRP 2012:4).

Table 1 shows regulations and salinity limits for selected desalination brine discharges.

California desalination plants in Carlsbad and Huntington Beach have an absolute salinity limitof less than or equal to 40 ppt. On the other hand, desalination plants in Australia have relativeregulations on salinity limits. For example, in Sydney, Australia the salinity limit is an increment

of less than or equal to 1 ppt relative to ambient.

Table 1: Regulations for select desalination brine discharges (Source: SCCWRP 2012)

Data on the effects of brine discharge on flora and fauna, including California biota, are

extremely limited (SCCWRP 2012:11). Often times the data available are not peer-reviewed orthere are flaws in the study design. There is only one existing published study that documents

the impacts of brine discharge on Californias marine biota (SCCWRP 2012:11). Voutchkov(2006) conducted laboratory studies on 18 different species including algae and various species

of fishes. He concluded that none of the species seemed to be affected by elevated salinity levels

up to 10 ppt of ambient levels (SCCWRP 2012:11). However, there are a couple of perceivedflaws in the study: (1) the only measure of biological effect reported is survival and (2) the

species were exposed to elevated salinity levels for only 19 days. It is also important to note that


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all of the other studies examined by the expert panel reported that a 2 to 3 ppt increase has the

potential to produce significant deleterious effects in sea grasses and mollusks (SCCWRP2012:11). Due to the limited number of studies on this topic, it cannot be concluded that

California biota are not affected by elevated salinity levels.

Brine disposal from desalination plants is accomplished by one of three methods: thesemethods include ocean brine disposal, evaporation ponds, and deep well injection. Evaporation

pond technology is widely practiced in arid regions in the Middle East and Australia (NTUA

2012: 25). Evaporation ponds impact the environment relatively minimally and should be

utilized whenever possible; however, the numerous requirements for pond evaporation eliminatethis as an alternative for brine disposal in the Monterey Bay. In terms of climate, evaporation

ponds require a highly arid climate (Glater & Cohen, 2006), not found in the Monterey Bay area.

Furthermore, evaporation ponds corresponding desalination plant must take in at most 5 MGD(Glater & Cohen, 2006), which is much smaller than the size of the Monterey Peninsula Water

Supply Projects planned desalination plant of 9 MGD (Dolqueist et al.,2012). Beyond climateand plant size, evaporation ponds require extensive acquirable land, which is virtually non-existent and/or exorbitant in cost in and around the Monterey Peninsula. As a result of the

geographical, climate, and physical limitations, evaporation ponds are not an option for the

Monterey Bay.

Having eliminated evaporation ponds as a potential form of brine disposal, deep-well

injections and ocean brine disposal are the only remaining alternatives. Both methods pose

environmental threats and can result in the disruption of ecosystems. Although the deep-wellinjection method is technically feasible, there are various reasons why this is not the method of

choice by many desalination facilities. These drawbacks include the difficulty in selecting a

suitable well site, the costs involved in conditioning the waste brine, the possibility of corrosionand subsequent leakage in the well casing, seismic activity which could cause damage to the welland subsequently result in ground water contamination; and uncertainty of the well half-life

which can only be estimated using mathematical simulation techniques (Glater & Cohen, 2006:

7). Though some of these drawbacks also pertain to other forms of brine disposal, finding anappropriate site for the wells, the possibility of corrosion and groundwater contamination are

particularly alarming and relevant concerns for the Monterey Bay. For these reasons, deep well

injection has yet to be used or even considered in California (Glater & Cohen 2003).

Worldwide, all desalination plants of significant capacity discharge brine into oceans andestuaries (Cooley et al., 2013: 13). Ocean brine disposal remains the only suitable method ofbrine disposal for the Monterey Bay in the foreseeable future. The Monterey Bays

mediterranean climate and the premium coastal real estate eliminate evaporation ponds as a

viable option, while a lack of pre-existing injection wells, potential contamination ofgroundwater, and the threat of increased seismic activity in an area already highly sensitive to

earthquakes eliminate the potential for deep-well injection. Ocean brine disposal can disrupt


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natural salinity balances and cause environmental damage to marine ecosystems, especially

sensitive marshes and fisheries (Cooley et al., 2013: 13).

Ocean brine disposal presents both legal and environmental concerns for the Monterey

Bays economy and ecosystem; however, it is the sole option for brine disposal for this region.

Because there are significant threats and concerns associated with this method, especially in theMonterey Bay and in and around the Monterey Bay National Marine Sanctuary, the

precautionary principle should be enacted. In this case, the precautionary principle implies thatbecause there is a lack scientific certainty regarding ocean brine disposal, let alone in the

Monterey Bay, and scientists caution against the many unknowns associated with ocean brine

disposal, disposal standards and monitoring efforts should be stringent and overly prudent.Salinity levels of reject brine should follow strict regulatory standards, and close monitoring of

ocean conditions and reject brine dispersal is vital. Moreover, if and when future desalination

plants are constructed along the Monterey Peninsula, special attention should be given to

potential cumulative impacts from multiple desalination plants and aggregate reject brineflowing into the Monterey Bay.

Though the full extent of environmental consequences associated with ocean brine disposal islargely unknown, it is the most feasible method for the Monterey Bay. Due to its understudied

nature, we recommend a salinity increase of no more than 5% of that occurring naturally in the

waters around the discharge. This increment will amount to about 1.7 ppt (SCCWRP 2012: iii).Although various reports have recommended a salinity increase of 2 to 3 ppt, we recommend amore conservative limit for two reasons: (1) the region is an embayment area which is associated

with less circulation and (2) the high level of biodiversity in the Monterey Bay, including anumber of sensitive benthic species. Additionally, the discharge method should include co-

disposal with power plant cooling water or wastewater. If pure brine is released, multiportdiffusers would help reduce salinity in the near field and increase dilution (SCCWRP 2012:23).

Multiport diffusers are structures consisting of closely spaced ports which inject turbulent jets athigh velocity into the receiving water body. A multiport diffuser is an effective device for the

disposal of water containing wastes into a natural body of water due to the high degree of

dilution that can be obtained.

Unintended consequences should be expected due to the enigmatic nature of brine disposal.

Therefore, a monitoring program of the discharge and the receiving area should be required(SCCWRP 2012:44). This monitoring should include analyses of benthic conditions and other

sensitive areas in the bay that are most prone to changes. Additionally, the toxicity of the brine

discharges should be tested in laboratories using local species of the Monterey Bay. Whenexamining the potential effects that brine could have on species residing in the Monterey Bay, itis important to consider not only whether these species survive, but also how they will be

affected in terms of migration, reproduction, and other important life stages. The laboratory tests

should include sub-lethal endpoints to recognize whether and how the species are being affected.

According to Carol Reeb, a marine biologist and fisheries geneticis at Stanfords

Hopkins Marine Station, squid can potentially be affected by brine discharge in the region (Reeb


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2013). Sandy sea floor, abundant in the Monterey Bay, is critical habitat for market squid, one of

Californias most valuable fisheries. Squid build egg nurseries in the sand, and dense plumes ofhigh-salinity water would have the potential to sink and settle over the vast amounts of squid egg

capsules on the seafloor. As of now, no one knows how brine will impact developing squid

embryos and many other species comprising Monterey Bays benthic communities (Reeb 2013).

In conclusion, there is no doubt that there is a water shortage in California, and that the

Monterey Bay authorities must find some way to provide residents with sufficient water.However, it is important to ensure that the regions marine tourism industry, profitable fisheries,

and its highly diverse ecosystem continue to thrive. Desalination and brine disposal will likely

pose threats to the Monterey Bay environment. In order to limit these environmentalramifications, it is crucial that the regions authority figures in charge of desalination and brine

disposal move forward in a conscientious and precautionary manner.

Cooley, H., Ajami, N., and Heberger, M. (Pacific Institute). Key Issues in SeawaterDesalination in California: Marine Impacts. Pacific Institute. (2013).

http://www.pacinst.org/wp-content/uploads/2013/12/desal-marine-imapcts-full-report.pdf

Dolqueist, L.A., Stoddard, J., Manatt, P. & P., and Leeper, S. E. Application of California-

American Water Company (U210W) for Approval of the Monterey Peninsula Water Supply

Project and Authorization to Recover All Present and Future Costs in Rates. (2012): 1-94.http://www.cpuc.ca.gov/Environment/info/esa/mpwsp/pdf/CAW_Application_PDFA_.pdf

Elimelech, M., and Phillip, W.A."The Future of Seawater Desalination: Energy, Technology, andthe Environment." Science333.6043 (2011): 712-17.

http://www.sciencemag.org/content/333/6043/712.full.html

Glater, J., and Cohen, Y., Brine Disposal from Land Based Membrane Desalination Plants: ACritical Assessment. Metropolitan Water District of Southern California. (2003): 1-16.

http://www.twdb.state.tx.us/wrpi/rwp/3rdRound/2011_RWP/RegionK/Files/Reference_Do

cs/Brackish_Desal/BRINE%20DISPOSAL.pdf

National Technical University of Athens (NTUA). Report on the evaluation of existing methods

on brine treatment and disposal practices. SOL-BRINE. (2012).http://uest.ntua.gr/solbrine/uploads/files/Deliverable_1.1.pdf

Reeb, C., Consider desalinations effect on sea floor.Monterey Herald. 2013 August 10.http://www.montereyherald.com/opinion/ci_23838232/carol-reeb-consider-desalinations-effect-sea-floor

Southern California Coastal Water Research Project (SCCWRP). Management of BrineDischarges to Coastal Waters: Recommendations of a Science Advisory Panel. California

Water Resources Control Board. (2012).

http://www.waterboards.ca.gov/water_issues/programs/ocean/desalination/docs/dpr051812.pdf


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Voutchkov, N. 2006. Innovative Method to Evaluate Tolerance of Marine Organisms.

Desalination & Water Reuse 16:28-34.

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