1. CALL TO ORDER
2. ROLL CALL
3. PLEDGE OF ALLEGIANCE
4. PRESENTATIONS/PROCLAMATIONS/ANNOUNCEMENTS
5. BLUE FOLDER ITEMS (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet, and/or public comments received after the printing and distribution of the agenda packet for receive and file.
5.A. FOR BLUE FOLDER DOCUMENTS APPROVED AT THE CITY COUNCIL
MEETING
RECOMMENDATION: Approved
6. PUBLIC COMMENT ON NON-AGENDA ITEMS
This is the appropriate time for members of the public to make comments regarding itemsnot listed on this agenda.
Pursuant to the Brown Act, no action will take place on any items not on the agenda.
7. CONSENT CALENDAR
Business items, except those formally noticed for public hearing, or those pulled for discussion are assigned to the 2 PORTUGUESE BEND ROAD
ROLLING HILLS, CA 90274
(310) 377-1521
AGENDA
Regular City Council Meeting
CITY COUNCIL
Monday, May 23, 2022
CITY OF ROLLING HILLS
7:00 PM
The meeting agenda is available on the City’s website. The City Council meeting will be live-streamed on the City’s website. Both the agenda and the live-streamed video can be found here:
https://www.rolling-hills.org/government/agenda/index.php Members of the public may submit written comments in real-time by emailing the City Clerk’s office at [email protected]. Your comments will become part of the official meeting record. You must provide your full name, but please do not provide any other personal information that you do not want to be published.
Recordings to City Council meetings can be found here: https://www.rolling-hills.org/government/agenda/index.php Next Resolution No. 1300 Next Ordinance No. 376
CL_AGN_220523_CC_BlueFolderItem_7C.pdf
CL_AGN_220523_CC_BlueFolderItem_11A.pdf
CL_AGN_220523_CC_BlueFolderItem_12B.pdf
1 Consent Calendar. The Mayor or any Councilmember may request that any Consent Calendar item(s) be removed, discussed, and acted upon separately. Items removed from the Consent Calendar will be taken up under the "Excluded Consent Calendar" section below. Those items remaining on the Consent Calendar will be approved in one motion. The Mayor will call on anyone wishing to address the City Council on any Consent Calendar item on the agenda, which has not been pulled by Councilmembers for discussion.
7.A. APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR MEETING OF MAY 23, 2022
RECOMMENDATION: Approve.
7.B. APPROVE MOTION TO READ BY TITLE ONLY AND WAIVE FURTHER
READING OF ALL ORDINANCES AND RESOLUTIONS LISTED ON THE AGENDA
RECOMMENDATION: Approve.
7.C. APPROVE THE FOLLOWING CITY COUNCIL MINUTES: MAY 9, 2022 RECOMMENDATION: Approve as presented.
7.D. PAYMENT OF BILLS
RECOMMENDATION: Approve as presented.
7.E. REPUBLIC SERVICES RECYCLING TONNAGE REPORT FOR APRIL 2022.
RECOMMENDATION: Receive and file.
7.F. APPROVE COUNTY OF LOS ANGELES DEPARTMENT OF AGRICULTURAL COMMISSIONER/WEIGHTS AND MEASURES FY 2022/2023 PEST CONTROL AGREEMENT NO. 779 FOR PEST CONTROL SERVICES.
RECOMMENDATION: Approve as presented.
7.G. APPROVE AND AUTHORIZE THE CITY MANAGER TO EXECUTE A
PROFESSIONAL SERVICES AGREEMENT WITH BOLTON ENGINEERING
CORPORATION TO PERFORM A TOPOGRAPHIC SURVEY AT THE CITY HALL
CAMPUS TO SUPPORT THE IMPROVEMENTS REQUESTED BY THE NEEDS
OF SENIOR COMMITTEE
RECOMMENDATION: Approve as presented.
7.H. PENINSULA EMERGENCY WATERSHED MANAGEMENT PROJECT (EWMP)
RESPONSE TO REGIONAL BOARD COMMENTS
RECOMMENDATION: Receive and file.
7.I. APPROVE ROLLING HILLS COMMUNITY ASSOCIATION'S APPLICATION TO
LOS ANGELES COUNTY DEPARTMENT OF PUBLIC HEALTH FOR
CL_AGN_220523_CC_AffidavitofPosting.pdf
CL_MIN_220509_CC_F_A.pdf
CL_AGN_220523_PaymentOfBills.pdf
CL_AGN_220523_Rolling Hills YTD Tonnage Report.pdf
CL_AGN_220523_CC_LA_Co.PestControlAgreemtNo.779.pdf
CL_AGN_220509_Bolton_CHCampus_SurveyProposal.pdf
CA_AGR_220518_PSA_BoltonEng_TopographicSurvey.pdf
PVP EWMP Cover Letter (Mass-Based Approach) 22.05.13.pdf PVP EWMP Response to RB Comments Table 22.05.13.pdf
PVP EWMP 22.05.13.pdf
2 REPLACEMENT OF SEPTIC TANK SERVING THE MAIN GATE AND
AUTHORIZE CITY MANAGER TO SIGN
RECOMMENDATION: Approve as presented.
7.J. ACCEPT EMERGENCY STORM DRAIN REPAIR AT 1 MIDDLERIDGE LANE
NORTH AS COMPLETE, FILE NOTICE OF COMPLETION, AND RELEASE RETENTION AFTER 30 DAY LIEN PERIOD TO EC CONSTRUCTION
RECOMMENDATION: Approve as presented.
7.K. ADOPT RESOLUTION NO. 1299 ACCEPTING CALRECYCLE SB1383 GRANT RECOMMENDATION: Approve as presented.
7.L. REPORT BY BUDGET/AUDIT/FINANCE COMMITTEE ON MEETING HELD ON MAY 9, 2022
RECOMMENDATION: Receive and File
7.M. ADOPT RESOLUTION NO. 1298 MEMORIALIZING A REDUCTION IN THE SELFINSURANCE FUND RESERVES FROM $500,000 TO $250,000 RECOMMENDATION:
Approve as presented.
7.N. UPDATE ON RESTRICTED TRANSPORTATION FUND PROJECTS
RECOMMENDATION: Receive and file.
8. EXCLUDED CONSENT CALENDAR ITEMS
9. COMMISSION ITEMS
10. MATTERS FROM THE CITY COUNCIL
10.A. DISCUSS 2022 SCE RELIABILITY REPORT AND WILDFIRE DETECTION
CAMERAS ON THE PENINSULA (DIERINGER)
RECOMMENDATION: None.
10.B. DISCUSS EXISTING CELLULAR SERVICE ISSUES (BLACK)
RECOMMENDATION: None.
CL_AGN_220523_RHCA_LACoDPH_Application_Septic.pdf
CL_AGN_220523_RHCA_GeoTech_Septic.pdf
PW_STW_220303_SDRepair_1MiddleridgeLaneN.pdf
PW_STW_220418_MiddleridgeLaneN_INV 19092_revised.pdf
PW_STW_220430_MiddleridgeLaneN_Inv 19111_Retention.pdf
PW_STW_220418_MiddleridgeLaneN_CP_Release.pdf
Revised 1383 Award RFA 001.pdf
Exhibit A: 2022Jan3SB1383LocalAssistTermsConditions.pdf Exibit B: 2022Apr25ProcsReqsAmended.pdf
ResolutionNo1288_SB1383_Grant_F_E.pdf
ResolutionNo1299_CalRecycle_SB1383_GrantAcceptance.pdf
ResolutionNo1298_AdministrativeFinancialPolicy.pdf
FN_POL_220518_AdminProcedures_BudgetDebtPolicies.pdf
3 11. BUDGET WORKSHOP
11.A. CITY COUNCIL FISCAL YEAR 2022-23 BUDGET WORKSHOP
RECOMMENDATION: Review the proposed Fiscal Year 2022/23 budget and provide staff with comments and direction.
12. NEW BUSINESS
12.A. PRESENTATION OF EDUCATIONAL VIDEOS ON FIRE FUEL MANAGEMENT IN THE CANYON; RECOGNIZE LEAD BLOCK CAPTAIN GENE HONBO, BLOCK
CAPTAIN DEBRA SHRADER, AND LOS ANGELES COUNTY FIRE
DEPARTMENT FORESTRY DIVISION TREVOR MOORE FOR THEIR
LEADERSHIP IN COMPLETING THE PROJECT; AND DIRECT STAFF TO DISSEMINATE THE VIDEOS THROUGH THE BLOCK CAPTAIN PROGRAM.
RECOMMENDATION: Approve as presented.
12.B. APPROVE AMENDED PROFESSIONAL SERVICES AGREEMENT WITH CHAMBERS GROUP TO PREPARE A CEQA DOCUMENT FOR THE 6TH CYCLE
HOUSING ELEMENT TO ADDRESS COMMENTS FROM THE DEPARTMENT OF
FISH AND WILDLIFE
RECOMMENDATION: Authorize the preparation of a contract amendment approved to form by the City Attorney in a not to exceed amount of $60,000; and authorize the City Manager to execute such an agreement.
12.C. ADOPT RESOLUTIONS NOS. 1295 AND 1296 PERTAINING TO A GENERAL
MUNICIPAL ELECTION CONSOLIDATED WITH THE STATEWIDE GENERAL ELECTION TO BE HELD ON TUESDAY, NOVEMBER 8, 2022
RECOMMENDATION:
Adopt Resolution Nos. 1295 and 1296 pertaining to the General Municipal Election to be held on November 8, 2022 as presented.
13. PUBLIC HEARINGS
13.A. SUBMITTAL OF "ADOPTION DRAFT" 2021-2029 ROLLING HILLS HOUSING
ELEMENT TO HCD
RECOMMENDATION: Authorize staff to submit the revised Draft Housing Element to HCD for their second review, along with the responses to HCD’s CL_AGN_220523_FY2023_Revenue Budget Recommendations.pdf CL_AGN_220523_FY2023_Recommended Budget_General Fund Exp.pdf CL_AGN_220523_FY2023 Summary of Sources and Uses of Funds_General Fund.pdf CL_AGN_220523_Twelve Year History_ Rev Exp and Reserves.pdf CL_AGN_FY22-23_OptionsToCloseBudgetDeficit_v2.pdf
CL_AGN_220523_FY2023 Recommended Budget - Other Funds.pdf CL_AGN_220523_CC_BlueFolderItem_11A_01_Redacted.pdf
Agreement for Planning Services - Chambers-EXECUTED.pdf CL_AGN_220523_CC_BlueFolderItem_12B_IS-MND_ChangeOrder.pdf ResolutionNo1295_CallElection2022_CountyServices.pdf
ResolutionNo1296_EstablishRegulations_CandidateStatement.pdf 4 comments.
14. MATTERS FROM STAFF
15. RECESS TO CLOSED SESSION
16. RECONVENE TO OPEN SESSION
17. ADJOURNMENT
Next regular meeting: Monday, June 13, 2022 at 7:00 p.m. in the City Council Chamber, Rolling Hills City Hall, 2 Portuguese Bend Road, Rolling Hills, California, 90274.
A. April 11, 2022 Comment letter from HCD
B. May 9, 2022 City Responses to HCD Comments
C. Tracked Change Adoption Draft Housing Element
Notice:
Public Comment is welcome on any item prior to City Council action on the item.
Documents pertaining to an agenda item received after the posting of the agenda are available for review in the City Clerk's office or at the meeting at which the item will be considered.
In compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this meeting due to your disability, please contact the City Clerk at (310) 377-1521 at least 48 hours prior to the meeting to enable the City to make reasonable arrangements to ensure accessibility and accommodation for your review of this agenda and attendance at this meeting. 5 Agenda Item No.: 5.A
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: FOR BLUE FOLDER DOCUMENTS APPROVED AT THE CITY COUNCIL
MEETING
DATE: May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approved.
ATTACHMENTS:
CL_AGN_220523_CC_BlueFolderItem_7C.pdf
CL_AGN_220523_CC_BlueFolderItem_11A.pdf
CL_AGN_220523_CC_BlueFolderItem_12B.pdf
6 BLUE FOLDER ITEM (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet, and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
May 23, 2022
7.C APPROVE THE FOLLOWING CITY COUNCIL MINUTES: MAY 9, 2022 FROM: CHRISTIAN HORVATH, CITY CLERK/EXECUTIVE ASSISTANT TO THE CITY
MANAGER
CL_MIN_220509_CC_F_A.pdf
7 BLUE FOLDER ITEM (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet, and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
May 23, 2022
11.A CITY COUNCIL FISCAL YEAR 2022-23 BUDGET WORKSHOP
FROM: CHRISTIAN HORVATH, CITY CLERK/EXECUTIVE ASSISTANT TO THE CITY
MANAGER
CL_AGN_220523_CC_BlueFolderItem_11A_01_Redacted.pdf
8 BLUE FOLDER ITEM (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet, and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
May 23, 2022
12.B APPROVE AMENDED PROFESSIONAL SERVICES AGREEMENT WITH CHAMBERS GROUP TO PREPARE A CEQA DOCUMENT FOR THE 6TH CYCLE
HOUSING ELEMENT TO ADDRESS COMMENTS FROM THE DEPARTMENT OF
FISH AND WILDLIFE
FROM: CHRISTIAN HORVATH, CITY CLERK/EXECUTIVE ASSISTANT TO THE CITY
MANAGER
CL_AGN_220523_CC_BlueFolderItem_12B_IS-MND_ChangeOrder.pdf 9 Agenda Item No.: 7.A
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR MEETING OF MAY 23, 2022
DATE: May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve.
ATTACHMENTS:
CL_AGN_220523_CC_AffidavitofPosting.pdf
10 Administrative Report
7.A., File # 1206 Meeting Date: 05/23/2022
To: MAYOR & CITY COUNCIL
From: Christian Horvath, City Clerk
TITLE
APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR MEETING OF MAY 23, 2022
EXECUTIVE SUMMARY
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS
CITY OF ROLLING HILLS )
AFFIDAVIT OF POSTING
In compliance with the Brown Act, the following materials have been posted at the locations below.
Legislative Body City Council
Posting Type Regular Meeting Agenda
Posting Location 2 Portuguese Bend Road, Rolling Hills, CA 90274 City Hall Window
Meeting Date & Time May 23, 2022 7:00pm Open Session
As City Clerk of the City of Rolling Hills, I declare under penalty of perjury, the document noted above was posted at the date displayed below.
Christian Horvath, City Clerk
Date: May 19, 2022
11 Agenda Item No.: 7.B
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: APPROVE MOTION TO READ BY TITLE ONLY AND WAIVE FURTHER
READING OF ALL ORDINANCES AND RESOLUTIONS LISTED ON THE AGENDA
DATE: May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve.
ATTACHMENTS:
12 Agenda Item No.: 7.C
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: APPROVE THE FOLLOWING CITY COUNCIL MINUTES: MAY 9, 2022 DATE: May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_MIN_220509_CC_F_A.pdf
13 MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Minutes
Rolling Hills City Council
Monday, May 9, 2022
Regular Meeting 7:00 p.m.
1. CALL TO ORDER
The City Council of the City of Rolling Hills met in person on the above date at 7:00 p.m. Mayor James Black presiding.
2. ROLL CALL
Councilmembers Present: Dieringer, Pieper, Mirsch, Mayor Pro Tem Wilson, Mayor Black Councilmembers Absent: None
Staff Present: Elaine Jeng, City Manager
Jane Abzug, City Attorney
John Signo, Planning & Community Services Director
Christian Horvath, City Clerk / Executive Assistant to the City Manager
3. PLEDGE OF ALLEGIANCE – Councilmember Dieringer
4. PRESENTATIONS/PROCLAMATIONS/ANNOUNCEMENTS – NONE
5. BLUE FOLDER ITEMS (SUPPLEMENTAL)
Motion by Councilmember Pieper, seconded by Mayor Black to receive and file supplemental items for 9A and 13A. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
6. PUBLIC COMMENT ON NON-AGENDA ITEMS – NONE
7. CONSENT CALENDAR
7.A. APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR MEETING OF MAY 9, 2022
7.B. APPROVE MOTION TO READ BY TITLE ONLY AND WAIVE FURTHER READING OF ALL
ORDINANCES AND RESOLUTIONS LISTED ON THE AGENDA
7.C. APPROVE THE FOLLOWING CITY COUNCIL MINUTES: APRIL 25, 2022
7.D. PAYMENT OF BILLS
7.E. RECEIVE AND FILE SOUTHERN CALIFORNIA EDISON'S 2022 CIRCUIT RELIABILITY REVIEW
7.F. PULLED BY COUNCILMEMBER DIERINGER
7.G. PULLED BY COUNCILMEMBER MIRSCH
14 MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
7.H. PULLED BY COUNCILMEMBER MIRSCH
7.I. PULLED BY COUNCILMEMBER MIRSCH
Motion by Councilmember Pieper, seconded by Councilmember Dieringer to approve Consent Calendar excluding Items 7F, 7G, 7H and 7I. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
8. EXCLUDED CONSENT CALENDAR ITEMS
7.F. APPROVE THIRD AMENDMENT TO PROFESSIONAL SERVICES AGREEMENT WITH PACIFIC ARCHITECTURE AND ENGINEERING INC. COVERING CONSTRUCTION DOCUMENTS FOR
CITY HALL ADA IMPROVEMENTS PROJECT
Motion by Councilmember Dieringer, seconded by Councilmember Mirsch to approve and direct staff to provide Pacific Architecture and Engineering with hash-marks added to the existing Option 3 diagram to denote and re-iterate the direction provided at the 4/25/22 Council meeting requesting a solution for the back south wall of the council chambers allowing for access by overflow public meeting attendees.” Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
7.G. APPROVE BOLTON ENGINEERING CORPORATION TO PERFORM A TOPOGRAPHIC SURVEY
AT THE CITY HALL CAMPUS TO SUPPORT THE IMPROVEMENTS REQUESTED BY THE
NEEDS OF SENIOR COMMITTEE
Motion by Councilmember Mirsch, seconded by Councilmember Pieper to approve as presented and direct staff to prepare a Professional Services Agreement with Bolton Engineering Corporation. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
7.H. REPORT BY BUDGET/AUDIT/FINANCE COMMITTEE ON MEETING HELD ON APRIL 25, 2022
7.I. INVESTMENT POLICY, FINANCIAL, BUDGET AND DEBT POLICIES AND RESOLUTION NO. 953 - ASSET CAPITALIZATION POLICY
Motion by Councilmember Mirsch, seconded by Councilmember Dieringer to receive and file 7H; and review and confirm the Investment Policy, the Financial, Budget and Debt Policies, with changes as recommended and Resolution No. 953 – Asset Capitalization Policies, and direct staff to prepare a resolution memorializing the reduction in the Self-Insurance Fund Reserves for 7I. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
15 MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
9. COMMISSION ITEMS
9.A. ZONING CASE NO. 21-10: REQUEST FOR APPROVAL FOR A MAJOR MODIFICATION TO A SITE PLAN REVIEW FOR THE CONSTRUCTION OF A NEW 6,094-SQUARE-FOOT RESIDENCE, 4,491-SQUARE-FOOT BASEMENT, 987-SQUARE-FOOT ATTACHED GARAGE, COVERED PORCHES, SWIMMING POOL AND SPA, 1,000-SQUARE-FOOT ACCESSORY DWELLING UNIT, AND OTHER IMPROVEMENTS FOR A PROPERTY LOCATED AT 8 MIDDLERIDGE LANE SOUTH (LOT 254-UR), ROLLING HILLS, CA 90274 (CIMMARUSTI) Presentation by John Signo, Planning & Community Services Director Public Comment: Chris Gunderson, Project Architect
Motion by Councilmember Pieper, seconded by Councilmember Dieringer to receive and file Resolution No. 2022-04 and Zoning Case No. 21-10 for a property located at 8 Middleridge Lane South. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
10. PUBLIC HEARINGS – NONE
11. OLD BUSINESS – NONE
12. NEW BUSINESS
12.A. CONSIDER THE ROLLING HILLS COMMUNITY ASSOCIATION'S REQUEST TO ADOPT THE VEHICLE CODE SECTION 25279
Presentation by Elaine Jeng, City Manager
Public Comment: Jim Aichele, Alfred Visco
Motion by Councilmember Pieper, seconded by Mayor Pro Tem Wilson to follow the City Attorney’s suggested Option 2 authorizing the City Attorney to draft a resolution regulating RHCA’s use of a security vehicle with amber lights and provide input on the posting of signs to make the rule effective. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
12.B. CONSIDER ROLLING HILLS COMMUNITY ASSOCIATION'S REQUEST TO REPLACE SEPTIC
TANK SERVING THE MAIN GATE
Presentation by Elaine Jeng, City Manager
Mayor Black directed staff to communicate with the RHCA that the Council is in support and request they provide a copy of the latest plans including the location of the new septic tank at the May 23, 2022 City Council meeting. Without objection, so ordered.
16 MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
12.C. APPROVE RECLASSIFICATION OF THE CODE ENFORCEMENT OFFICER POSITION TO A
PLANNER POSITION
Presentation by John Signo, Planning & Community Services Director Motion by Councilmember Dieringer to defer the item until the Council is provided more information about the Budget and what monies are available for staff positions. Motion failed for lack of a second.
Motion by Mayor Black, seconded by Councilmember Mirsch to approve the reclassification of the Code Enforcement officer position to a Planner position. Motion carried with the following vote:
AYES: Pieper, Mirsch, Wilson, Mayor Black
NOES: Dieringer
ABSENT: None
12.D. REVIEW FINANCE/AUDIT/BUDGET COMMITTEE'S RECOMMENDATION TO UPDATE THE
CONSOLIDATED TAX AND FEE SCHEDULE
Presentation by John Signo, Planning & Community Services Director Motion by Mayor Black to decrease Committee on Trees and Views Processing fee to $1,000 for complaints against one property and charge additional $1,000 per property for complaints against multiple properties.
Motion failed for lack of a second.
Motion by Councilmember Dieringer, seconded by Mayor Pro Tem Wilson to approve staff recommendation of raising Committee on Trees and Views Processing fee to $6,000 for complaints against one property and $10,000 for complaints against multiple properties. Motion carried with the following vote:
AYES: Dieringer, Mirsch, Wilson
NOES: Pieper, Mayor Black
ABSENT: None
12.E. APPROVE UPDATED CITY COUNCIL COMMITTEE ASSIGNMENTS FOR 2022-2023 Presentation by Christian Horvath, City Clerk / Executive Assistant to the City Manager Motion by Mayor Black, seconded by Mayor Pro Tem Wilson to leave Councilmember Mirsch on the Fire Fuel Committee. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
Motion by Councilmember Pieper, seconded by Mayor Pro Tem Wilson to approve the City Council committee assignments as presented. Motion carried with the following vote:
AYES: Pieper, Mirsch, Wilson, Mayor Black
NOES: Dieringer
ABSENT: None
12.F. CONSIDER SUPPORT FOR FORMATION OF PROPOSED SOUTH BAY HOUSING TRUST; AND
INTEREST IN PARTICIPATING
17 MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Presentation by Christian Horvath, City Clerk / Executive Assistant to the City Manager Public Comment: Jim Aichele, Alfred Visco
Motion by Councilmember Pieper, seconded by Mayor Black to take no action until more information is provided. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
13. MATTERS FROM THE CITY COUNCIL
13.A. RECEIVE AND FILE REPORT ON THE MARCH 30, 2022 FIRE FUEL COMMITTEE MEETING Motion by Councilmember Pieper, seconded by Mayor Pro Tem Wilson to receive and file the report. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
14. MATTERS FROM STAFF
14.A. REVIEW OPTIONS FOR STATE OF THE CITY EVENT
Presentation by Christian Horvath, City Clerk / Executive Assistant to the City Manager Mayor Black directed staff to work with the Mayor to write a letter to go out to the residents. Without objection, so ordered.
City Manager Jeng reported that the Canyon Management Videos were finalized and will be presented at the May 23, 2022 City Council meeting
Public Comment: Marcia Schoettle
15. RECESS TO CLOSED SESSION
Mayor Black recessed the City Council to Closed Session at 8:34 p.m.
15.A. CONFERENCE WITH LEGAL COUNSEL: ANTICIPATED LITIGATION GOVERNMENT CODE SECTION 54956.9(d)(2)
16. RECONVENE TO OPEN SESSION
The City Council reconvened to Open Session at 9:46 p.m. and there was no reportable action.
17. ADJOURNMENT: 9:46 P.M.
The meeting was adjourned at 9:46 p.m on May 9, 2022 in the memory of Rolling Hills resident Dr. Elliott Brunner who passed away. The next regular meeting of the City Council is scheduled to be held on Monday, May 23, 2022 beginning at 7:00 p.m. in the City Council Chamber at City Hall, 2 Portuguese Bend Road, 18 MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Rolling Hills, California. It will also be available via City’s website link at: https://www.rollinghills.org/government/agenda/index.php All written comments submitted are included in the record and available for public review on the City website.
Respectfully submitted,
____________________________________
Christian Horvath, City Clerk
Approved,
____________________________________
James Black, M.D., Mayor
19 Agenda Item No.: 7.D
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: PAYMENT OF BILLS
DATE: May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_AGN_220523_PaymentOfBills.pdf
20 21
Agenda Item No.: 7.E
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: REPUBLIC SERVICES RECYCLING TONNAGE REPORT FOR APRIL 2022.
DATE: May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Receive and file.
ATTACHMENTS:
CL_AGN_220523_Rolling Hills YTD Tonnage Report.pdf
22 Year 2022
Franchise Y/N Y
Month Commodity Tons Collected Tons Recovered Tons Disposed Diversion % Jan Greenwaste 98.26 98.26 - 100.00%
Trash 156.54 - 156.54 0.00%
Jan Total 254.80 98.26 156.54 38.56%
Feb Greenwaste 93.00 93.00 - 100.00%
Trash 134.41 - 134.41 0.00%
Feb Total 227.41 93.00 134.41 40.90%
Mar Greenwaste 111.44 111.44 - 100.00%
Trash 183.40 - 183.40 0.00%
Mar Total 294.84 111.44 183.40 37.80%
Apr Greenwaste 100.44 100.44 - 100.00%
Trash 156.07 - 156.07 0.00%
Apr Total 256.51 100.44 156.07 39.16%
Grand Total 1,033.56 403.14 630.42 39.00%
111.44
CITY OF ROLLING HILLS RESIDENTIAL FRANCHISE
2022
Contract Requires 30% Household -
23 Agenda Item No.: 7.F
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CONNIE VIRAMONTES , ADMINISTRATIVE ASSISTANT
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: APPROVE COUNTY OF LOS ANGELES DEPARTMENT OF
AGRICULTURAL COMMISSIONER/WEIGHTS AND MEASURES FY
2022/2023 PEST CONTROL AGREEMENT NO. 779 FOR PEST
CONTROL SERVICES.
DATE: May 23, 2022
BACKGROUND:
Historically, the City of Rolling Hills maintains an annual agreement with the Los Angeles County Agricultural Commissioner/Weights & Measures Department for pest control services.
These services are provided on an daily and/or on an on-call basis at the rates listed in the agreement and the city has used the agreement for services such as coyote trapping, as well as pest control including rodents and weeds. The attached agreement for Fiscal Year 2022- 2023 is presented for City Council consideration. Of note, most of the hourly rates have increased over last year's rates.
Labor Increase:
Agri/Weight & Measures Inspector III: 5.88%
Agricultural Chemical Sprayer: 5.54%
Pest Control Worker: 6.17%
Warehouse Worker I: 6.82%
Weed Haz & Pest Abatement Worker: 10.26%
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve the agreement as presented and authorize the City Manager to execute the agreement.
24 ATTACHMENTS:
CL_AGN_220523_CC_LA_Co.PestControlAgreemtNo.779.pdf
25 26
27 28
29 30
31 32
33 Agenda Item No.: 7.G
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: APPROVE AND AUTHORIZE THE CITY MANAGER TO EXECUTE A
PROFESSIONAL SERVICES AGREEMENT WITH BOLTON
ENGINEERING CORPORATION TO PERFORM A TOPOGRAPHIC
SURVEY AT THE CITY HALL CAMPUS TO SUPPORT THE
IMPROVEMENTS REQUESTED BY THE NEEDS OF SENIOR
COMMITTEE
DATE: May 23, 2022
BACKGROUND:
At the April 11, 2022 City Council meeting, Council received a presentation from the Rolling Hills Community Association Needs of Seniors Committee on suggested improvements to the City Hall Campus. Council directed staff to work with the city's landscape architect (hired previously to inventory the existing City Hall campus irrigation system) on the suggested improvements and report back at the May 23, 2022 City Council meeting.
At the May 9, 2022 City Council meeting, the Council directed staff to prepare a Professional Services Agreement with Bolton Engineering Corporation.
DISCUSSION:
Staff held a kick off meeting with the landscape architect, Evan Smith and is awaiting his initial report and findings on the irrigation system. Landscape architect Evan Smith expressed at the kick-off meeting the need for a topographic survey of the City Hall campus to ensure the inventoried irrigation system is properly recorded. One of the improvement suggested by the Needs of the Seniors Committee is to level the grassy area between the Rolling Hills Community Association office building and City Hall. To do so appropriate, a topographic survey would be needed.
Previously, the city hired Bolton Engineering Corporation (Bolton) to survey the tennis courts, and to provide civil engineering plans to bring the accessible paths of the tennis courts to comply with the American with Disability Act (ADA). In light of the conversation with the landscape architect Evan Smith, staff reached out to Bolton to find out if topographic survey was available for the City Hall campus at the time the company was commissioned for 34 engineering work at the tennis courts. Bolton confirmed that they did not furnish a topographic survey for the City Hall campus, only the tennis courts. Bolton was asked to provide a proposal to for a topographic survey for the campus. With both sets of data provided by the same company, there is an opportunity to merge the data to have topographic information for the campus and tennis courts to approach the planning holistically.
Additionally, to offset potential General Fund expenditures, staff submitted a future project request using Metro Measure R and M monies to re-imagine and refurbish the parking lot and outer ring of the campus to include Active Transportation elements as well as resurface the asphalt.
FISCAL IMPACT:
Bolton's proposal to provide a topographic survey for the City Hall campus is $5,000. If the City Council should approve to engage for services, there is sufficient budget in the FY 2021- 2022 adopted budget in account 890 Consulting Fees to fund Bolton's professional services fee.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_AGN_220509_Bolton_CHCampus_SurveyProposal.pdf
CA_AGR_220518_PSA_BoltonEng_TopographicSurvey.pdf
35 Bolton Engineering Corporation
25834 Narbonne Ave. Suite 210
Lomita, CA 90717
tel (310) 325-5580 fax (310) 325-5581
April 19, 2022
Client: City of Rolling Hills
2 Portuguese Bend Road
Rolling Hills, Ca
Ordered By: Christian Horvath
[email protected]
Subject: Topographic Survey Proposal – 2 Portuguese Bend Rd.
I. Scope of Work
• Topographic Survey: Locate all structures, hardscape, fences, walls, observable above ground utilities, trees greater than 6” in diameter and spot elevations.
• Prepare drawing showing property lines and topography with contours at 1 foot intervals.
Proposed Fee: $ 5,000.00
Required Retainer: $ 1,500.00
II. Deliverables
Pdf copy and stamped hard copy of topographic survey.
III. Exclusions:
• Fee estimates for surveying are based on the following assumptions. All parts of the property will be reasonably free of visually obstructing vegetation or objects. The subject site will be open and readily available for our entry without delay. The dimensions of the subject property, legal descriptions, and surrounding surveys will close mathematically. The controlling survey monuments will be readily available and in their proper locations.
• Project revisions, additions, and other services not included in the scope of work above are in addition.
Meetings and personal appearances are included only to the extent outlined above. • All fees or levies required by government agencies will be assumed by the client and are not included in the fee proposal. Reproduction and other incurred costs on the client’s behalf are additional. • Easement plotting not included in proposed fee.
• Property line staking not included in proposed fee.
Hourly Rates are as follows:
Principal- $290.00 Reg. Land Surveyor - $160.00 Drafting - $ 100.00 Reg. Chief Engineer - $195.00 1 Person Survey Party - $150.00 Messenger - $ 75.00 Reg. Civil Engineer - $160.00 2 Person Survey Party - $245.00 Staff Engineer- $130.00 Surveyor Office - $120.00
Approximate cost, where indicated, is neither a maximum nor a fixed price unless so stated. Retainers are credited to final billing. Interest rate shall be 12 percent. The undersigned client authorizes BOLTON ENGINEERING CORPORATION (BEC) to perform the above described work. Reproduction costs and Government fees are not included in the fee and shall be paid for by the client. The fee or balance of the fee is due and payable upon completion of the work. Work performed over an extended period will be invoiced monthly and due and payable the 10th of the month following date of invoice. Client acknowledges services are relating to improvement of real property. Accounts unpaid over 30 days will be charged a service charge of one and one half percent per month (18% per annum), not to exceed 5 percent over the rate charged by the Federal Reserve Bank of San Francisco to member banks on the 25th of the month preceding this contract. 36 Bolton Engineering Corporation
If a suit or other legal action is instituted to collect fees, client agrees to pay, in addition, all costs of collection and reasonable attorney's fees. Hourly rates will be adjusted annually. Work may be canceled before completion by written request by either party, and invoiced on an hourly basis to point of cancellation. Client acknowledges this as a "preliminary 20 day notice" and understands that if bills are not paid in full for services furnished, the improved property may be subject to mechanics liens.
Any controversy or claim arising out of or relating to this contract, or the breach thereof, shall be settled by arbitration in accordance with the Rules of the American Arbitration Association, and judgment upon the award rendered by the Arbitrator's may be entered in any Court having jurisdiction thereof. In event that BEC is required to appear in any legal action relating to any work performed under this agreement, client agrees to pay BEC prevailing hourly rates for such appearance, reasonable attorney's fees and costs.
To authorize work under the outlined terms, please sign and initial one copy of this document and return to our offices. Thank you for the opportunity to propose on this project.
Regards,
BOLTON ENGINEERING CORP.
Accepted By:
Signature Date
Title
37 65277.00001\40077817.2
PROFESSIONAL SERVICES AGREEMENT
This Agreement is made and entered into this 23rd day of May 2022 in the City of Rolling Hills, County of Los Angeles, State of California, by and between the City of Rolling Hills, a municipal corporation, (hereinafter, “City”) and Bolton Engineering Corporation, a California corporation, (hereinafter, “Consultant”)
RECITALS.
A. The City desires to retain Consultant to perform a topographic survey and prepare a drawing showing property lines and topography for 2 Portuguese Bend Rd. The scope of the project is defined in Exhibit A, attached hereto and incorporated herein by reference.
B. Consultant is well-qualified by reason of education and experience to perform such services; and
C. Consultant is willing to render such professional services as hereinafter defined.
NOW, THEREFORE, in consideration of the mutual covenants and conditions herein contained, City hereby engages Consultant to perform the services set forth in this Agreement and Consultant agrees to perform those services.
1. SCOPE OF WORK.
Consultant shall perform all work necessary to complete, in a manner satisfactory to the City, the services set forth in the scope of work in Exhibit A, attached hereto and incorporated into this Agreement by reference.
2. COST.
The City agrees to pay Consultant for all the work or any part of the work performed under the Agreement at the rates and in the manner established in Exhibit A.
A. Compensation. Total expenditure made under this Agreement shall not exceed the sum of $5,000. This fee includes all expenses, consisting of all incidental blueprinting, photography, travel, attendance at meetings and miscellaneous costs, estimated to be accrued.
B. Written Approval Required. Any increase in the compensation or scope of work shall be by express written amendment, approved by the City Manager and the Consultant.
3. METHOD OF PAYMENT.
Upon full execution of the Agreement, City shall issue payment to Consultant in the amount of $1,500 as a retainer for Consultant’s services. The Consultant shall thereafter submit to the City, by no later than the 10th day of each month, its bill for services describing the services and the date services were performed and itemizing the fees and costs incurred during the previous month. Such services shall initially be charged against the $1,500 retainer. The City 38 65277.00001\40077817.2
shall pay the Consultant all uncontested amounts set forth in the Consultant's bill within 30 days after it is received. Consultant shall submit an invoice in duplicate addressed to the City at:
c/o Planning Department
2 Portuguese Bend Road
Rolling Hills, CA 90274
4. SUBCONTRACTING.
Consultant shall not be permitted to subcontract any portion of this Agreement without the express written consent of the City.
5. COMMENCEMENT OF WORK.
Consultant shall commence the work described herein upon full execution of this Agreement.
6. ACCOUNTING RECORDS.
Consultant must maintain accounting records and other evidence pertaining to costs Consultant incurs in carrying out its obligations under this Agreement. The records and evidence must be kept available in Consultant’s California office during the Term of Agreement (defined in paragraph 8 of this Agreement) and thereafter for five years from the date of final payment. In the event such records must be moved from that location, Consultant shall notify the City at the address of the Planning Department provided in paragraph 4 of this Agreement.
7. OWNERSHIP OF DATA.
All data, maps, photographs, and other material collected or prepared under the Agreement shall belong to the City and shall not be withheld from the City for any reason.
8. TERM OF AGREEMENT.
This Agreement shall be valid for one year from the date the Agreement is executed by the parties. The City Manager may extend this contract with proof of a good cause. Such extension shall be made in writing by the City Manager to the Consultant.
9. TERMINATION.
A. Breach. This Agreement may be terminated at any time for breach. A breach occurs when Consultant fails to meet an obligation or condition required by this Agreement or the scope of work set out in Exhibit A.
B. Unilateral Termination. The City may terminate unilaterally and without cause upon seven (7) days written notice to the Consultant. All work satisfactorily performed pursuant to this Agreement and prior to the date of termination may be claimed for reimbursement. To the extent any portion of the retainer has not been expended on services provided by Consultant to 39 65277.00001\40077817.2
City, Consultant shall return any and all unexpended funds to City within 30 days of receipt of City’s written notice to terminate.
10. ASSIGNABILITY.
Consultant shall not assign or transfer interest in this Agreement without the prior written consent of the City.
11. AMENDMENT.
It is mutually understood and agreed that no alteration or variation of the terms of this Agreement shall be valid unless made in writing, signed by the parties, and approved by all parties.
12. NON-SOLICITATION CLAUSE.
The Consultant warrants that he or she has not employed or retained any company or persons, other than a bona fide employee working solely for the Consultant, in exchange for any fee, commission, percentage, brokerage fee, gifts, or any other consideration, contingent upon or resulting from the award or making of this Agreement. For breach or violation of this warranty, the City shall have the right to annul this Agreement without liability, or, in its discretion, to deduct from the agreed price or consideration, or otherwise recover the full amount of such fee, commission, percentage, brokerage fee, gift, or contingent fee.
13. INDEMNITY.
Consultant shall indemnify, defend with counsel approved by City, and hold harmless City, its officers, officials, employees and volunteers from and against all liability, loss, damage, expense, cost (including without limitation reasonable attorneys’ fees, expert fees and all other costs and fees of litigation) of every nature arising out of or in connection with Consultant’s performance of work hereunder or its failure to comply with any of its obligations contained in this Agreement, regardless of City’s passive negligence, but excepting such loss or damage which is caused by the sole active negligence or willful misconduct of the City. Should City in its sole discretion find Consultant’s legal counsel unacceptable, then Consultant shall reimburse the City its costs of defense, including without limitation reasonable attorneys’ fees, expert fees and all other costs and fees of litigation. The Consultant shall promptly pay any final judgment rendered against the City (and its officers, officials, employees and volunteers) covered by this indemnity obligation. It is expressly understood and agreed that the foregoing provisions are intended to be as broad and inclusive as is permitted by the law of the State of California and will survive termination of this Agreement.
14. INSURANCE.
A. Insurance Required. Without limiting Consultant’s obligations arising under paragraph 14 - Indemnity, Consultant shall not begin work under this Agreement until it obtains policies of insurance required under this section. The insurance 40 65277.00001\40077817.2
shall cover Consultant, its agents, representatives and employees in connection with the performance of work under this Agreement, and shall be maintained throughout the term of this Agreement. Insurance coverage shall be as follows:
i. Automobile Liability Insurance, with minimum coverage of $300,000 for property damage, $300,000 for injury to one person/single occurrence, and $300,000 for injury to more than one person/single occurrence. ii. General Liability Insurance insuring City of Rolling Hills, its elected and appointed officers, agents, and employees from claims for damages for personal injury, including death, as well as from claims for property damage which may arise from Consultant’s actions under this Agreement, whether or not done by Consultant or anyone directly or indirectly employed by Consultant. Such insurance shall have a combined single limit of not less than $1,000,000.
iii. Worker’s Compensation Insurance, for all Consultant’s employees to the extent required by the State of California.
iv. Professional Liability Coverage for professional errors and omissions liability insurance for protection against claims alleging negligent acts, errors, or omissions which may arise from the Consultant’s operations under this Agreement, whether such operations are by the Consultant or by its employees, subcontractors, or subconsultants. The amount of this insurance shall not be less than one million dollars ($1,000,000) on a claims-made annual aggregate basis, or a combined single-limit-peroccurrence basis. When coverage is provided on a “claims made basis,” Consultant will continue to renew the insurance for a period of three (3) years after this Agreement expires or is terminated. Such insurance will have the same coverage and limits as the policy that was in effect during the term of this Agreement, and will cover Consultant for all claims made by City arising out of any errors or omissions of Consultant, or its officers, employees, or agents during the time this Agreement was in effect.
B. Deductibility Limits for policies referred to in subparagraphs A (i) and (ii) shall not exceed $5,000 per occurrence.
C. Additional Insured. City, its elected and appointed officers, agents, and employees shall be named as additional insured on policies referred to in subparagraphs A (i) and (ii).
D. Primary Insurance. The insurance required in paragraphs A (i) and (ii) shall be primary and not excess coverage.
E. Evidence of Insurance. Consultant shall furnish City, prior to the execution of this Agreement, satisfactory evidence of the insurance required, issued by an insurer 41 65277.00001\40077817.2
authorized to do business in California, and an endorsement to each such policy of insurance evidencing that each carrier is required to give City at least 30 days prior written notice of the cancellation of any policy during the effective period of the Agreement. All required insurance policies are subject to approval of the City Attorney. Failure on the part of Consultant to procure or maintain said insurance in full force and effect shall constitute a material breach of this Agreement .
15. NOTICES.
Any notice required to be given hereunder shall be deemed to have been given by depositing said notice in the United States mail, postage prepaid, and addressed as follows:
CITY: CONSULTANT:
Elaine Jeng, P.E., Dan Bolton
City Manager Bolton Engineering Corporation
2 Portuguese Bend Road 25834 Narbonne Ave., Suite 210
Rolling Hills, CA 90274 Lomita, CA 90717
TEL (310) 377-1521 TEL: (310) 325-5580
FAX (310) 377-2866 FAX: (310)325-5581
16. ENFORCEMENT OF AGREEMENT.
In the event that legal action is commenced to enforce or declare the rights created under this Agreement, the prevailing party shall be entitled to an award of costs and reasonable attorneys’ fees in the amount to be determined by the court.
17. CONFLICT OF INTEREST.
The Consultant represents that it presently has no interest and shall not acquire any interest, direct or indirect, in any real property located in the City which may be affected by the services to be performed by the Consultant under this Agreement. The Consultant further represents that in performance of this Agreement, no person having any such interest shall be employed by it.
A. The Consultant represents that no City employee or official has a material financial interest in the Consultant’s business. During the term of this Agreement and as a result of being awarded this contract, the Consultant shall not offer, encourage, or accept any financial interest in the Consultant’s business by any City employee or official.
B. If a portion of the Consultant’s services called for under this Agreement shall ultimately be paid for by reimbursement from and through an agreement with a developer of any land within the City or with a City franchisee, the Consultant warrants that it has not performed any work for such developer/franchisee within the last 12 months, and shall not negotiate, offer, or accept any contract or request to perform services for that identified developer/franchisee during the term of this Agreement.
42 65277.00001\40077817.2
18. INDEPENDENT CONSULTANT.
The Consultant is and shall at all times remain as to the City a wholly independent contractor. Neither the City nor any of its agents shall have control over the conduct of the Consultant or any of the Consultant’s employees, except as herein set forth. The Consultant shall not at any time or in any manner represent that it or any of its agents or employees are in any manner agents or employees of the City.
19. ENTIRE AGREEMENT OF THE PARTIES.
This Agreement supersedes any and all other agreements, either oral or in writing, between the parties hereto with respect to the employment of Consultant by City and contains all the covenants and agreements between the parties with respect to such employment in any manner whatsoever. Each party to this Agreement acknowledges that no representations, inducements, promises or agreements, orally or otherwise, have been made by any party, or anyone acting on behalf of any party, which are not embodied herein, and that no other agreement or amendment hereto shall be effective unless executed in writing and signed by both City and Consultant.
20. GOVERNING LAW.
This Agreement shall be governed by and construed in accordance with the laws of the State of California, and all applicable federal statutes and regulations as amended.
21. GENERAL TERMS AND CONDITIONS.
A. Non-Discrimination. The Consultant shall not discriminate as to race, creed, gender, color, national origin or sexual orientation in the performance of its services and duties pursuant to this Agreement, and will comply with all applicable laws, ordinances and codes of the federal, state, county and city governments.
B. Compliance with Applicable Law. The Consultant and the City shall comply with all applicable laws, ordinances and codes of the federal, state, county, and city governments.
C. Copyright. No reports, maps, or other documents produced in whole or in part under this Agreement shall be the subject of an application for copyright by or on behalf of the Consultant.
D. Legal Construction. This Agreement shall be construed without regard to the identity of the persons who drafted its various provisions. Each and every provision of this Agreement shall be construed as though each of the parties participated equally in the drafting of same, and any rule of construction that a document is to be construed against the drafting party shall not be applicable to this Agreement. The article and section, captions and headings herein have been inserted for convenience only and shall not be considered or referred to in resolving questions or interpretation or construction. Whenever in this Agreement the context may so 43 65277.00001\40077817.2
require, the masculine gender shall be deemed to refer to and include the feminine and neuter, and the singular shall refer to and include the plural.
E. Counterparts. This Agreement may be executed in counterparts and as so executed shall constitute an agreement which shall be binding upon all parties hereto.
F. Final Payment Acceptance Constitutes Release. The acceptance by the Consultant of the final payment made under this Agreement shall operate as and be a release of the City from all claims and liabilities for compensation to the Consultant for anything done, furnished or relating to the Consultant’s work or services. Acceptance of payment shall be any negotiation of the City’s check or the failure to make a written extra compensation claim within ten (10) calendar days of the receipt of that check. However, approval or payment by the City shall not constitute, nor be deemed, a release of the responsibility and liability of the Consultant, its employees, sub-consultants, and agents for the accuracy and competency of the information provided or work performed; nor shall such approval or payment be deemed to be an assumption of such responsibility or liability by the City for any defect or error in the work prepared by the Consultant, its employees, sub-consultants, and agents.
G. Corrections. In addition to the above indemnification obligations, the Consultant shall correct, at its expense, all errors in the work which may be disclosed during the City’s review of the Consultant’s report or plans. Should the Consultant fail to make such correction in a reasonably timely manner, such correction shall be made by the City, and the cost thereof shall be charged to the Consultant.
H. Waiver; Remedies Cumulative. Failure by a party to insist upon the performance of any of the provisions of this Agreement by the other party, irrespective of the length of time for which such failure continues, shall not constitute a waiver of such party's right to demand compliance by such other party in the future. No waiver by a party of a default or breach of the other party shall be effective or binding upon such party unless made in writing by such party, and no such waiver shall be implied from any omissions by a party to take any action with respect to such default or breach. No express written waiver of a specified default or breach shall affect any other default or breach, or cover any other period of time, other than any default or breach or period of time specified. All of the remedies permitted or available to a party under this Agreement, or at law or in equity, shall be cumulative and alternative, and invocation of any such right or remedy shall not constitute a waiver or election of remedies with respect to any other permitted or available right of remedy.
I. Mitigation of Damages. In all such situations arising out of this Agreement, the parties shall attempt to avoid and minimize the damages resulting from the conduct of the other party.
J. Partial Invalidity. If any provision in this Agreement is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions will nevertheless continue in full force without being impaired or invalidated in any way. 44 65277.00001\40077817.2
K. Attorneys' Fees. The parties hereto acknowledge and agree that each will bear his/her or its own costs, expenses, and attorneys' fees arising out of and/or connected with the negotiation, drafting and execution of the Agreement, and all matters arising out of or connected therewith except that, in the event any action is brought by any party hereto to enforce this Agreement, the prevailing party in such action shall be entitled to reasonable attorneys' fees and costs in addition to all other relief to which that party or those parties may be entitled.
L. Warranty of Authorized Signatories. Each of the signatories hereto warrants and represents that he or she is competent and authorized to enter into this Agreement on behalf of the party for whom he or she purports to sign.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement on the date and year first above written.
CITY OF ROLLING HILLS CONSULTANT
CITY MANAGER: BOLTON ENGINEERING CORP.
______ _____ ________
ELAINE JENG DAN BOLTON
ATTEST:
______ _____
CHRISTIAN HORVATH, CITY CLERK
APPROVED AS TO FORM:
______ _____
MICHAEL JENKINS, CITY ATTORNEY
45 65277.00001\40077817.2
Exhibit A
Scope of Work
I. Scope of Work
• Topographic Survey: Locate all structures, hardscape, fences, walls, observable above ground utilities, trees greater than 6” in diameter and spot elevations. • Prepare drawing showing property lines and topography with contours at 1 foot intervals.
II. Deliverables
Pdf copy and stamped hard copy of topographic survey.
III. Exclusions:
• Reproduction and other incurred costs on the client’s behalf are additional. • Easement plotting not included in proposed fee.
• Property line staking not included in proposed fee.
Hourly Rates are as follows:
Principal- $290.00 Reg. Land Surveyor - $160.00 Drafting - $ 100.00 Reg. Chief Engineer - $195.00 1 Person Survey Party - $150.00 Messenger - $ 75.00 Reg. Civil Engineer - $160.00 2 Person Survey Party - $245.00 Staff Engineer- $130.00 Surveyor Office - $120.00
46 Agenda Item No.: 7.H
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: JOHN SIGNO, DIRECTOR OF PLANNING & COMMUNITY SERVICES THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: PENINSULA EMERGENCY WATERSHED MANAGEMENT PROJECT (EWMP) RESPONSE TO REGIONAL BOARD COMMENTS
DATE: May 23, 2022
BACKGROUND:
On May 13, 2022, the Cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills Estates, Rolling Hills, and the County of Los Angeles (Unincorporated County), along with the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Peninsula WMG, submitted its updated Palos Verdes Peninsula Enhanced Watershed Management Program (Peninsula EWMP) including an updated Reasonable Assurance Analysis (RAA), to the California Regional Water Quality Control Board (Water Board). The updated Peninsula EWMP and RAA have been prepared in accordance with the requirements of the 2021 LA MS4 Permit1, the Los Angeles Regional Water Quality Control Board Guidelines for Conducting RAA (March 2014), and the State Water Board Order WQ 2020-0038 (2020 State Board Order).
The updated Peninsula EWMP and RAA includes the City of Rolling Hills and is consistent with the 2020 State Board Order:
Explains how information considered in the source assessment was used (EWMP Section 2 and Appendix 4.1 RAA Report).
Identifies unavailable, needed information and the assumptions made to substitute for that information along with commitment to acquire the information through the Peninsula CIMP for incorporation in the next adaptive management milestone (EWMP Appendix
4.1 RAA Report 7.1.3 Mercury and Arsenic).
Utilizes all relevant, available data2 to update the EWMP and RAA, including updates to the water body pollutant combination (WBPC) prioritization and source assessment, TMDL milestone achievement, and RAA calibration and validation. Data not used in the RAA has been identified, with explanation as to why this data was disregarded.
Models each WBPC and therefore does not utilize or necessitate justification of a limiting pollutant approach. Table 4-2 in Section 4 of the Updated EWMP provides the results of this analysis for each WBPC supported by the detailed RAA Report in Appendix 4.1. 47 Includes 24-hour management volumes as a clear metric for demonstrating progress in attaining load reduction targets – Table 5-1 in Section 5 of the Updated EWMP provides the implementation schedule for demonstrating progress in attaining these volumetric reductions by subwatershed and analysis region. Water body/pollutant milestones are also included in this table.
Considers ongoing CIMP monitoring data which is sufficient to evaluate attainment of milestones.
EWMP Addendum to include Rolling Hills
On January 31, 2022, an Addendum to the Palos Verdes Peninsula Enhanced Watershed Management Program (EWMP Addendum) to include Rolling Hills as an 85th%, 24-hour runoff retention area was submitted to the Water Board. On April 6, 2022, the Water Board provided the City with comments on the EWMP Addendum that the City. On April 26, 2022, the City responded to those comments and is currently awaiting the Water Board's response.
Although the City is not officially part of the Peninsula EWMP, if the Addendum is approved by the Water Board, the updated Peninsula EWMP will apply to the City.
DISCUSSION:
The Water Board regulates discharges from municipal separate storm sewer systems (MS4s) through the Municipal Separate Storm Sewer System Permit (MS4 Permit). The purpose of the MS4 Permit is to protect the beneficial uses of the receiving waters in the Los Angeles County region by regulating municipal stormwater and non-stormwater discharges from the permittees’ MS4s. The overarching goal of these requirements is to reduce the discharge of pollutants from MS4s to the maximum extent practicable. The Permit allows permittees the flexibility of developing an Enhanced Watershed Management Program (EWMP) to implement the requirements of the Permit.
The City of Rolling Hills has elected to join the Peninsula WMG and the status is currently pending the Water Board's decision. In response the the Water Board's comments, Rolling Hills has been incorporated into the revised EWMP and identified as a full 85th percentile, 24- hour storm retention area as demonstrated through monitoring. Continuous flow monitoring was conducted in Sepulveda Canyon in Rolling Hills for two complete wet-weather seasons, from October 26, 2020 through April 2022. Stormwater run-off that is not contained on properties is conveyed through Rolling Hills via natural, soft-bottom, vegetated drainage courses/canyons providing disconnection of impervious developed areas and ample opportunity for natural bio-retention and infiltration. The no-flow results observed during three 85th%, 24-hr rainfall events as well as the numerous smaller rainfall events that occurred throughout the monitoring period provide evidence that the strategies, control measures and BMPs implemented by Rolling Hills cumulatively retain stormwater runoff up to and including runoff from the 85th percentile, 24-hour storm event, as well as any conditionally exempt nonstormwater discharges.
FISCAL IMPACT:
Costs for McGowan Consulting to revise the EWMP to include Rolling Hills is $23,550 funded by the Stormwater account in the Planning Department.
RECOMMENDATION:
Receive and file.
48 ATTACHMENTS:
PVP EWMP Cover Letter (Mass-Based Approach) 22.05.13.pdf PVP EWMP Response to RB Comments Table 22.05.13.pdf
PVP EWMP 22.05.13.pdf
49 Palos Verdes Peninsula
Enhanced Watershed Management Group
June 30, 2021 (Revised May 13, 2022) Transmitted electronically via FTP site link: https://ftp.watersboards.ca.gov
Renee Purdy, Executive Officer
Regional Water Quality Control Board, Los Angeles Region Attention: Ivar Ridgeway
Subject: Submittal of the Updated Palos Verdes Peninsula Enhanced Watershed Management Program
Dear Ms. Purdy,
The Cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills Estates, Rolling Hills, and the County of Los Angeles (Unincorporated County), along with the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Peninsula WMG, are pleased to submit the updated Palos Verdes Peninsula Enhanced Watershed Management Program (Peninsula EWMP) including an updated Reasonable Assurance Analysis (RAA). The updated Peninsula EWMP and RAA have been prepared in accordance with the requirements of the 2021 LA MS4 Permit1, the Los Angeles Regional Water Quality Control Board Guidelines for Conducting RAA (March 2014), and consistent with State Water Board Order WQ 2020-0038 (2020 State Board Order).
The updated RAA was conducted using the newly released, LACFCD-developed Watershed Management Modeling System 2.0 (WMMS 2.0), for general consistency with other RAA modeling efforts across Los Angeles County. The default WMMS 2.0 LSPC model has been calibrated by LACFCD on a regional basis using data through September 2018. The updated RAA also incorporated Peninsula Coordinated Integrated Monitoring Program (Peninsula CIMP) water quality and flow data collected through June 2020 (the latest complete Peninsula CIMP reporting year data set subjected to QA/QC validation), and as appropriate, utilized this data to calibrate and validate the revised RAA model to best reflect the baseline hydrology and water quality conditions within the Palos Verdes Peninsula EWMP area. Detailed information on the model calibration can be found in Section 5 of the Appendix 4.1 RAA Report.
Consistent with the 2020 State Board Order, the updated Peninsula EWMP and RAA:
1 Order No. R4-2012-0105, NPDES Permit No. CAS00400 Waste Discharge Requirements and National Pollutant Discharge Elimination System (NPDES) Permit for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles and Ventura Counties. 50 Explains how information considered in the source assessment was used (EWMP Section 2 and Appendix 4.1 RAA Report).
Identifies unavailable, needed information and the assumptions made to substitute for that information along with commitment to acquire the information through the Peninsula CIMP for incorporation in the next adaptive management milestone (EWMP Appendix 4.1 RAA Report 7.1.3 Mercury and Arsenic).
Utilizes all relevant, available data2 to update the EWMP and RAA, including updates to the water body pollutant combination (WBPC) prioritization and source assessment, TMDL milestone achievement, and RAA calibration and validation. Data not used in the RAA has been identified, with explanation as to why this data was disregarded. Models each WBPC and therefore does not utilize or necessitate justification of a limiting pollutant approach. Table 4-2 in Section 4 of the Updated EWMP provides the results of this analysis for each WBPC supported by the detailed RAA Report in Appendix 4.1. Includes 24-hour management volumes as a clear metric for demonstrating progress in attaining load reduction targets – Table 5-1 in Section 5 of the Updated EWMP provides the implementation schedule for demonstrating progress in attaining these volumetric reductions by subwatershed and analysis region. Water body/pollutant milestones are also included in this table.
Considers ongoing CIMP monitoring data which is sufficient to evaluate attainment of milestones.
Modifications to Peninsula EWMP including Special Study for Mass-Based Compliance for Machado Lake Nutrient TMDL
The 2020 State Water Board Order (p. 29) recognizes that “Additional fine-tuning to develop more tailored pollutant levels and control plans…will often require updates to regional water quality control plans” and that “water body-specific special studies can provide adequate protections for beneficial uses at reduced compliance costs to local jurisdictions”. Furthermore, Part C.3.b of Attachment N to the 2012 LA MS4 Permit pertaining to the Machado Lake Nutrient TMDL states, “Permittees may be deemed in compliance with water quality-based effluent limitations by demonstrating reduction of total nitrogen and total phosphorous on an annual mass basis measured at the storm drain outfall of the Permittee’s drainage area where approved by the Regional Water Board Executive Officer based on the results of a special study by the Permittee.”
The County of Los Angeles previously completed a special study to establish annual mass-based WQBELs for total nitrogen and total phosphorus under the Machado Lake Nutrient TMDL for its unincorporated areas, including those within the Peninsula EWMP area, which was developed 2 “Available data” includes all data collected through June 30, 2020 by the Peninsula WMG. This date marks the end of the 2019-2020 reporting year of CIMP monitoring results, which includes data that has been analyzed and verified according to the Peninsula CIMP QAPP standard for quality assurance and quality control (QA/QC).
Monitoring data collected after this time has not yet been verified for QA/QC in accordance with this protocol, and so has not been used in the updated RAA and EWMP, but will be used in the next update. 51 following approval of the Special Study Workplan by the Los Angeles Water Quality Control Regional Board3. The updated Peninsula EWMP RAA establishes mass-based loading estimates and WLAs for the entire Peninsula EWMP area, consistent with and following the same approach established in the approved Los Angeles County Machado Lake Nutrient TMDL Special Study4.
The updated RAA utilizes a mass-based approach to assess the annual average loading estimates and the waste load allocations (WLAs) for constituents of concern associated with the Machado Lake Nutrient TMDL.5 The approach is based on and consistent with the Los Angeles County Machado Lake Nutrient TMDL Special Study, which was previously approved by the Regional Board. The implemented approach utilizes both monitoring data and modeling results to estimate the dry and wet weather total nitrogen and total phosphorus loads to Machado Lake during the average annual year. Consistent with the Los Angeles County Special Study, water year 2010 was used as the critical year.
A summary of the approach used to establish the mass-based WLAs for both pollutants of concern is as follows:
1. The average water year was used as the critical year, consistent with the County Special Study.
2. The allowable annual average pollutant load was calculated as the Water Quality Based Effluent Limit (WQBEL) concentration multiplied by the annual average inflow to Machado Lake (8.45 HM3/year) apportioned to the Peninsula EWMP area (directly or via Wilmington Drain). The table below shows the resultant pollutant loads for the Peninsula EWMP area. Allowable annual average pollutant loads applicable to Unincorporated Los Angeles County (taken directly from the approved Special Study) are also included to demonstrate consistency in the approach.
3 LARWQCB (Los Angeles Regional Water Quality Control Board). 2010. Machado Lake Nutrient TMDL – Conditional Approval of the Special Study Work Plan for the Unincorporated Areas of Los Angeles County within the Machado Lake Watershed. May. 4 LACDPW (Los Angeles County Department of Public Works). 2011. Machado Lake Nutrient TMDL Special Study:
Characterization of Water Quality Conditions in the Unincorporated Areas of Los Angeles County within the Machado Lake Watershed Final Report. September. 5 The Machado Lake Nutrient TMDL allows permittees to assess compliance with TMDL WLAs on a mass basis for total nitrogen and total phosphorous by submitting a special study to the LARWQCB. 52 Unincorporated
County
Peninsula
EWMP Area2
Calculation input
Machado Lake watershed (sq-mi) 22.5
Annual average flow condition approved in
the Special Study (hm3/day) 8.45
Interim Concentration
Based WQBELs (mg/L)
TP 1.25
TN 2.45
Final Concentration
Based WQBELs (mg/L)
TP 0.1
TN 1
Compute annual average flow apportioned to the permittees Area tributary to
Machado Lake (Directly
or Via Wilmington Drain)
sq-mi 1.89 4.95
% of Machado
Lake Watershed 8.4% 22.0%
Flow apportioned to the permittees
(hm3/day) 0.71 1.86
Compute the annual WLAs as concentration WQBELs multiplied by apportioned annual average flow
Interim WLA (kg/year) TP 8871 2,322
TN 1,7391 4,550
Final WLA (kg/year) TP 711 186
TN 7101 1,857 1All numbers presented for the Unincorporated County are consistent with the approved WLAs by the LARWQCB.
2The Peninsula EWMP area includes unincorporated Los Angeles County within the EWMP area, but does not include the City of Rolling Hills, which is a full 85th percentile, 24-hour storm retention area.
3. The baseline annual mass-based loads were computed as the summation of annual dry weather and wet weather mass-based loads during the critical year. The dry weather mass-based load was based on dry weather flow and water quality monitoring data collected through the Peninsula CIMP from June 2016 to June 2020. The wet weather mass-based load was obtained using the calibrated WMMS 2.0 model, including Peninsula CIMP data collected through June 2020.
4. The difference between the annual baseline load (step 3) and the annual WLA (step 2) resulted in the target load reduction required to meet the allowable TMDL limits. 53 Utilizing this approach, the RAA demonstrates that annual mass-based loading for total nitrogen from the Peninsula EWMP Area is less than the WLA for the critical condition, while annual massbased loading for total phosphorus from the area is slightly higher than the WLA. Appendix 4.1 of the EWMP provides the details of these RAA results and Chapter 3 of the EWMP describes the projects that have been identified to reduce pollutant loads to achieve the WLAs.
Prior and Current Milestones and Associated Work
The updated EWMP demonstrates achievement of past and current milestones, consistent with the requirements of the 2020 State Board Order. For the Santa Monica Bay subwatershed areas of the Peninsula EWMP, attainment of the final receiving water limitations (RWLs) was established in the previously approved EWMP and no additional milestones were due on or before June 30, 2021. Monitoring data evaluated in this revision of the EWMP/RAA continues to show that TMDL RWLs and/or water quality based effluent limitations (WQBELs) are being met for pollutants of concern in the Santa Monica Bay subwatershed of the Peninsula WMG.
For the Inner Harbor and Cabrillo Marina water bodies of the Los Angeles Harbor to which the Peninsula EWMP areas are tributary, monitoring data demonstrates compliance with relevant Greater Los Angeles Harbor Toxics TMDL interim WQBELs in the bed sediment over a three-year averaging period consistent with TMDL provisions translated into Order No. R4-2012-0175 Attachment N, E.4.a.ii. This is addressed in Table 4-1 in Section 4 of the updated Peninsula EWMP as well as Section 7.6 of the Appendix 4.1 RAA Report. Thus, applicable prior and current milestones are being met within the Los Angeles Harbor subwatershed areas of the Peninsula EWMP and no other work associated with prior or current milestones was due in the previously approved Peninsula EWMP on or before June 30, 2021.
For the Machado Lake subwatershed areas of the Peninsula EWMP, the updated RAA demonstrates that interim WQBELs for Total Nitrogen and Total Phosphorus are being met in all the analysis regions of the Machado Lake subwatershed as discussed in Section 4 of the EWMP and in Section 7.6 of the Appendix 4.1 RAA Report. Final WQBELs are also being met in all analysis regions within the Machado Lake subwatershed of the Peninsula EWMP for Total Nitrogen, Total PCBs, Dieldrin and DDT (all congeners) as demonstrated in the RAA and shown by zero final target load reductions in Table 11 of the Appendix 4.1 RAA Report. The final WQBELs for Total Chlordane, DDE congeners and DDD congeners have not yet been attained within all analysis regions of the Machado Lake subwatershed and additional load reductions are also necessary for indicator bacteria in the Wilmington Drain analysis regions of the Machado Lake Subwatershed to address the 303(d) listing. The updated RAA quantifies the additional capture volume (expressed as 24-hour management volume) needed in each analysis region to satisfy the unmet final target load reductions.
Some of the prior and current action-based milestones have been completed in the Machado Lake subwatershed, including completion of two regional projects identified in the previously approved EWMP. The two remaining regional projects identified in the previously approved Peninsula EWMP have not been completed as planned since feasibility studies were conducted 54 and these projects were determined to be technically or environmentally infeasible. Alternative projects in various stages of implementation (feasibility study, planning or design) have been identified in the updated EWMP and incorporated into the RAA to address the remaining target load reductions. Completion of the additional projects identified in Table 5-1 in Section 5 of the Peninsula EWMP within five years of approval of the updated Peninsula EWMP will provide the needed capture volumes and attain the final WQBELs for the remaining unmet final WQBELs for Machado Lake as well as the RWLs for bacteria in Wilmington Drain. Timely requests for Time Schedule Orders have been submitted by the Peninsula WMG for the Machado Lake Nutrients and Pesticides & PCBs TMDLs to allow time for completion of these additional projects.
Thank you for consideration of our updated Peninsula EWMP and RAA. Please don’t hesitate to contact me should Regional Board staff have any questions or require additional information. 55 56
Palos Verdes Peninsula EWMP: Response to Comments received on March 24, 2022 and April 6, 2022 Comment # Comment Response
RAA Comments
1 In the revised RAA, a 39.1% reduction in the baseline copper loading to the Los Angeles Harbor subwatershed was calculated. This load reduction was calculated based on a 2013 Draft Study conducted by TDC Environmental for CASQA that described the expected percent reduction of copper as a result of the passage of SB 346. Was this load reduction used as an assumption in the watershed baseline conditions or as a model input? If this is correct, staff have concluded the WMP did not provide a sufficiently robust justification to support the specified pollutant load reduction. In addition, since the RAA was updated to included outfall and receiving water monitoring data through June 2020, it’s likely any copper load reductions would have been accounted for as part of the model calibration. For these reasons a 39.1% baseline copper load reduction may not be appropriate and may require the RAA to be re-run.
The EWMP and RAA has been
updated accordingly. See Section 4
and Appendix 4.1.
2 Another concern with the model and/or RAA is the use of the wrong criteria for the Machado Lake Nutrients TMDL. The cities of Palos Verdes Estates, Ranch Palos Verdes and Rolling Hills Estates were not approved for annual mass-based effluent limitations for total nitrogen and total phosphorus discharges. The Machado Lake Nutrients TMDL allows for annual mass-based loading, only after a Permittee has demonstrated total nitrogen and total phosphorous load reductions will be achieved in accordance with a special study workplan approved by the Executive Officer (EO). The County of Los Angeles submitted a special study workplan for the unincorporated County areas within the Machado Lake watershed, which was approved by the EO. The PVP WMG used the County’s approval and applied it to the entire PVP WMP area. While this approach may be acceptable; the cities of Palos Verdes Estates, Rancho Palos Verdes, and Rolling Hills Estates didn’t submit the required workplan to receive approval for this approach as outlined in the Machado Lake Nutrients TMDL. It may be possible for these cities to use the RAA in order to receive approval for the mass-based loads. Be advised, management has not provided clarification to staff at this time, which is important as the deadline specified in the TMDL allowing a mass-based load option has past.
Additional justification for using the
annual mass-based effluent
limitations method of compliance
added to the cover letter. Also see
Appendix 4.1.
3 Additionally, the model and/or RAA may have used the wrong bacteria criteria for E. coli. The data analysis of E. coli indicator bacteria densities discharged to Wilmington Drain used the LREC-1 single sample maximum receiving water limitation of 576/100 mL. However, the new REC-1 bacteria objectives for the geometric mean (100 cfu/100 mL) and the statistical threshold value (320 cfu/100 mL) for E. coli should have been used to evaluate discharges to Wilmington Drain. What criteria was used in the modeling and RAA?
The EWMP and RAA has been
updated accordingly. See Section 4,
Section 5, and Appendix 4.1.
EWMP Comments
1 Section 5.2.2, Table 5-1, page 5-5, lists the structural targeted control measures to be implemented.
However, not all the modeled projects listed in Table 3-1 are included in Table 5-1. The two distributed projects, Rolling Hills Road Street Improvement, 0.06 ac-ft and Palos Verdes Drive East Street Improvement,
0.04 ac-ft are not listed in Table 5-1. These two distributed projects are included in Figures 5-1 and 5-2. If The EWMP has been updated
accordingly. See Section 3 and 5.
57 Comment # Comment Response
these projects will be relied on to meet compliance, then these projects need to be included in Table 5-1 and an implementation schedule needs to be provided.
2 Section 5.2.2, Figures 5-1, 5-2, and 5-3, pages 5-6 to 5-8, presents the projects by WMG member. Do these figures include all the responsible Permittees for each project or just the lead WMG member as listed in Table 5-1? If these figures do not include all responsible Permittees then the WMP needs to include this information.
The EWMP has been updated
accordingly. See Section 5. The
responsible Permittees are listed in
Figures 5-1, 5-2, and 5-3.
3 In Section 3.5.1.1.3 Proposed Regional BMPs, on page 3-25, the Palos Verdes Drive East Street Improvement is listed as a proposed project in the Machado Lake Watershed. However, there is no description of this project in this section. In Section 3.5.1.1.4 Potential Regional BMPs, there is a description of the Palos Verdes Drive East Green Street project. Are these the same project? If so, then the WMP needs to specify whether this is a “proposed” or “potential” project. If these are two different projects then provide a description in Section 3.5.1.1.3. In addition, clarify which project was modeled as listed in Table 3-1 on page 3-11.4. Assess 1st year of CIMP data to verify existing load assumptions and assess the group's contribution of coliform bacteria by July 1, 2016 (Wilmington Drain).
The EWMP has been updated
accordingly. See Section 3. The Palos
Verdes Drive East Street
Improvement is the same project as
the Palos Verdes Drive East Green
Street project. The project is
“potential”.
4 In Section 3.1.2.6, for the Public Information and Participation Program, include the metrics for measuring the effectiveness in achieving each objective listed in Part VIII.D.2 of the Order, as required in Part VIII.D.4.a of the Order.
The EWMP has been updated
accordingly. See Section 3.
5 Per Part IX.G.3.a of the Order, update the Peninsula WMP to be consistent with the requirements of the Regional MS4 Permit and update all references to the previous permit.
The EWMP and RAA have been
updated accordingly.
6 Update the Peninsula WMP to include the Addendum from the City of Rolling Hills. The EWMP and RAA have been updated accordingly.
7 Where necessary, update links and references to the 2018 303(d) list, which is the current 303(d) list (e.g., Sections 1.3.1 and 2.2 of the EWMP).
The EWMP has been updated
accordingly.
8 Table 2-11, page 2-21, the Sediment Target unit is incorrect it should be micrograms/kg not nanograms/kg. The units have been corrected. 9 Section 2.2.3, page 2-23, second paragraph, in the sentence “Thus, there appears to have been no degradation in sediment quality in these three water bodies since adoption of the TMDL.” Besides Los Angeles Harbor and Cabrillo Marina, what is the third water body this sentence is referencing? The EWMP has been updated
accordingly. The Peninsula drains to
two waterbodies in the Los Angeles
Harbor Watershed: Inner Harbor
and Cabrillo Marina.
10 Section 2.3, page 2-26, tenth bullet, Figure 1-1 does not show the Peninsula agencies’ MS4s, major outfalls, or major structural controls.
The EWMP has been updated
accordingly. Figure 1-1 shows the
Peninsula agencies’ MS4s and major
outfalls. Figure 3-1 shows the
structural controls modeled in the
RAA.
11 Section 2.3.1, page 2-28, Table 2-14 is not consistent with the narrative that follows. For example, sanitary sewer, septic systems, and RV waste are sources of bacteria, and wildfires are sources of PAHs and increase The EWMP has been updated
accordingly. Sources have been
58 Comment # Comment Response
TSS. Does Table 2-14 present only the MS4 sources of priority pollutants that the Peninsula WMP will be addressing? If so, then this needs to be clarified in the WMP. updated to be consistent with the
narrative.
12 Section 2.3.2, Table 2-17, page 2-42: According to the Addendum to the Palos Verdes Peninsula EWMP submitted by the City of Rolling Hills, "The Portion of the Peninsula WMG with drainage tributary to Santa Monica Bay consists of approximately 14.8 square miles, which is about 3.6% of the Santa Monica Bay Watershed (414 sq. mi.)." Therefore, the calculation of the percentage of the Santa Monica Bay DDT and PCBs TMDL annual mass-based wasteload allocation should be based on 3.6% not 3.8%. Update, the Santa Monica Bay TMDL Annual Mass-Based WLA in Table 2-17, to 0.97 g/year and 5.05 g/year for DDT and PCBs, respectively.
The EWMP has been updated
accordingly. The SMB TMDL Annual
Mass-Based WLA has been updated
in Table 2-17.
13 In the second column of Table 2-18, page 2-43 there is an asterisk on the units, is there a missing footnote? The EWMP has been updated accordingly. A footnote has been
added in Table 2-18
14 Update Figure 2-12, on page 2-50, to use the E. coli STV of 320 cfu/100 mL as the receiving water criteria. The EWMP has been updated accordingly. Figure 2-12 has been
removed. Narrative reflects the
change of receiving water criteria.
15 Footnote (c) of Table 3-1, page 3-11, states, “Does not include non-Peninsula EWMP drainage area.” Is this statement still valid now that Rolling Hills is joining the WMP? The EWMP and RAA has been
updated accordingly. Rolling Hills is
now a part of the Peninsula EWMP.
16 Section 3.5.1.1.1, San Ramon Canyon, page 3-14: Water Conservation/Supply is listed as one of the benefits of the San Ramon Canyon project. Does this project retain stormwater onsite? The EWMP has been updated
accordingly. Additional details about
project water supply benefit has
been added to Section 3.5.1.1.1.
17 In Table 4-3, page 4-6, the final target load reduction value of 1.5 ac-ft for analysis region LAH-CM has footnote 1. Footnote 1 does not seem to apply, should this be a different footnote reference? The EWMP and RAA have been
updated accordingly. Footnote has
been revised in Table 4-3.
18 In Table 5-1, page 5-5, the "Final TLR Equivalent 24-hour Management Volume” values for analysis regions WD-Solano and LAH-IH do not match the values in Table 4-3 and Appendix 4.1 RAA, Section 7.6, Table 11.
The EWMP and RAA has been
updated accordingly. See consistent
values from Section 4, Section 5, and
Appendix 4.1.
19 In Section 10.1, page 10-1, the annual reporting period is from July 1st through June 30th of the following year. Correct footnote 87 to reflect these dates not June 1st through July 30th.
The EWMP has been updated
accordingly. Footnote corrected.
20 Per Part IX.A.4.l of the Order, identify the lead agency for the Peninsula WMG. The EWMP has been updated accordingly. See Section 1
identifying the City of RPV as the
lead agency for the Peninsula WMG.
21 Remove any statements intended to make implementation of actions contingent on funding or informationgathering. While such issues may be cited in a separate request for a scheduling change to the Los Angeles The EWMP has been updated
accordingly.
59 Comment # Comment Response
Water Board Executive Officer, they cannot be used to create a contingency. To the extent that any contingency statements remain in the WMP, the Board gives them no effect. 60 PALOS VERDES
PENINSULA ENHANCED
WATERSHED
MANAGEMENT PROGRAM
Submitted By:
Palos Verdes Peninsula
Watershed Management Group
Revised: May 13, 2022
61 Palos Verdes Peninsula
Enhanced Watershed Management Program
i | Page
Table of Contents
1. Introduction and Background ............................................................................................................1-1
1.1. Introduction ...............................................................................................................................1-1
1.2. Peninsula Watershed.................................................................................................................1-2
1.3. Water Quality Issues and the History of Water Quality Regulations.........................................1-4
1.3.1. Federal Law, State Law, and Regulatory Framework.........................................................1-4
1.3.2. California Environmental Quality Act.................................................................................1-5
1.4. Water Quality Requirements.....................................................................................................1-6
1.5. The Enhanced Watershed Management Program ....................................................................1-7
1.5.1. Watershed Management Goals and Priorities...................................................................1-7
1.5.2. Water Quality Management Approach..............................................................................1-7
1.6. Reasonable Assurance Analysis and Watershed Control Measures........................................1-10
1.7. Adaptive Management ............................................................................................................1-11
2. Identification of Water Quality Priorities...........................................................................................2-1
2.1. Water Quality Characterization and Prioritization ....................................................................2-1
2.2. Receiving Water Characterization .............................................................................................2-3
2.2.1. Santa Monica Bay...............................................................................................................2-8
2.2.2. Machado Lake..................................................................................................................2-16
2.2.3. Greater Los Angeles Harbor.............................................................................................2-23
2.3. Source Assessment ..................................................................................................................2-27
2.3.1. Watershed Sources of Priority Pollutants........................................................................2-27
2.3.2. Characterization of Stormwater and Non-Stormwater Discharge Quality......................2-42
3. Selection of Watershed Control Measures........................................................................................3-1
3.1. Minimum Control Measures......................................................................................................3-2
3.1.1. L.A. County Flood Control District Minimum Control Measures.......................................3-2
3.1.2. Assessment and Modification of Minimum Control Measures (Participating Agencies, Excluding LACFCD)..............................................................................................................................3-2
3.1.4 Fifth Term MS4 Permit Minimum Control Measures ............................................................3-4
3.2. Non-stormwater Discharge Measures.......................................................................................3-5
3.3 Targeted Control Measures.......................................................................................................3-6
3.3.1 Control Measures identified in TMDLs/Implementation Plans.........................................3-6 62 Palos Verdes Peninsula
Enhanced Watershed Management Program
ii | Page
3.4 Nonstructural Targeted Control Measures................................................................................3-8
3.5 Structural Targeted Control Measures ......................................................................................3-9
3.5.1 Performance Evaluation of Structural Control Measures..................................................3-9
3.5.2 85th Percentile, 24-hour Runoff Retention Areas ............................................................3-32 Rolling Hills Nature-Based Runoff Retention Area ..........................................................................3-34
4. Reasonable Assurance Analysis .........................................................................................................4-1
4.1. RAA Summary ............................................................................................................................4-1
4.2. Reasonable Assurance Analysis .................................................................................................4-2
5. Implementation Schedule..................................................................................................................5-1
5.1. Introduction ...............................................................................................................................5-1
5.2. Schedules...................................................................................................................................5-2
5.2.1. Nonstructural Best Management Practices Schedule .......................................................5-3
5.2.2. Structural Best Management Practice Schedule ...............................................................5-3
6. EWMP Implementation Costs and Financial Strategy .......................................................................6-1
6.1. EWMP Implementation Costs....................................................................................................6-1
6.1.1. Methodology......................................................................................................................6-1
6.2. Summary of Costs......................................................................................................................6-3
6.3. Financial Strategy.......................................................................................................................6-5
6.3.1. Summary ............................................................................................................................6-5
6.3.2. Other Potential Funding Options.......................................................................................6-8
6.3.3. Prioritization.....................................................................................................................6-10
7. Legal Authority...................................................................................................................................7-1
8. Coordinated Integrated Monitoring Program ...................................................................................8-1
9. Adaptive Management Process.........................................................................................................9-1
9.1. Modifications.............................................................................................................................9-1
9.1.1. Reporting............................................................................................................................9-1
9.1.2. Implementation .................................................................................................................9-2
9.2. Receiving Water Limitations......................................................................................................9-3
10. Reporting Program & Assessment...............................................................................................10-1
10.1. Annual Report......................................................................................................................10-1
10.2. Monitoring Report ...............................................................................................................10-2
10.2.1. Data Reporting .................................................................................................................10-2 63 Palos Verdes Peninsula
Enhanced Watershed Management Program
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10.2.2. Chronic Toxicity Reporting...............................................................................................10-2
10.2.3. TMDL Reporting ...............................................................................................................10-2 List of Tables
Table 1-1: Jurisdictional Areas within Each Peninsula EWMP Watershed ................................................1-2 Table 2-1: Peninsula EWMP Priority Pollutants.........................................................................................2-2 Table 2-2: Peninsula EWMP Area Water Bodies and Beneficial Uses Designated in the Basin Plan.........2-4 Table 2-3: TMDLs Applicable to the Peninsula EWMP...............................................................................2-6 Table 2-4: 303(d) Listed Pollutants in Peninsula EWMP Watersheds........................................................2-7 Table 2-5: SMBBB TMDL Bacteria Objectives............................................................................................2-8 Table 2-6: Allowable Exceedance Day(s) by Period and Monitoring Location ..........................................2-9 Table 2-7: Number of Exceedance Days Above Allowable Receiving Water Limitations........................2-10 Table 2-8: Number of Year-Round Rolling Six-Week Geomean Exceedances of Receiving Water Limitations .................................................................................................................................................................2-11 Table 2-9: Nutrient TMDL Numeric Targets and Load Allocations for Machado Lake ............................2-19 Table 2-10: Monthly Average TN and TP Concentration in Machado Lake.............................................2-20 Table 2-11: Machado Lake Toxics TMDL In-Lake Numeric Targets..........................................................2-22 Table 2-12: Greater Harbor Toxics TMDL Marine Sediment Targets.......................................................2-24 Table 2-13: Water Quality Exceedances in Greater Los Angeles Harbor Waters to which Peninsula WMG is Tributary...................................................................................................................................................2-25 Table 2-14: Potential Watershed Sources of Palos Verdes Peninsula Priority Pollutants.......................2-29 Table 2-15: Land Use Distribution within the Palos Verdes Peninsula Watersheds................................2-30 Table 2-16: Automotive Sources of Metals in Stormwater .....................................................................2-35 Table 2-17: Santa Monica Bay DDT & PCBs 3-Year Rolling Average Outfall Data....................................2-43 Table 2-18: Machado Lake Pesticides & PCBs 3-Year Rolling Average Concentrations in Storm-Borne Sediment..................................................................................................................................................2-44 Table 3-1: Summary of Modeled Regional BMPs ....................................................................................3-11 Table 4-1: Interim Wet Weather Target Load Reduction Summary..........................................................4-3 Table 4-2: Final Wet Weather Target Load Reduction Summary ..............................................................4-4 Table 4-3: Peninsula EWMP RAA Summary ...............................................................................................4-6 Table 5-1: Structural TCM Implementation Schedule................................................................................5-5 Table 6-1: WMMS 2.0 Cost Function .........................................................................................................6-2 Table 6-2: Range of Soft Costs for Regional Projects.................................................................................6-3 64 Palos Verdes Peninsula
Enhanced Watershed Management Program
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Table 6-3: Estimated Capital and O&M Costs for Regional BMPs.............................................................6-4 Table 6-4: Funding Option Priorities........................................................................................................6-10 Table 7-1: Water Quality Ordinance Language..........................................................................................7-1 List of Figures
Figure 1-1: Peninsula EWMP Area and Existing Monitoring Locations......................................................1-3 Figure 2-1: Santa Monica Bay Total Coliform Concentrations 2016-2020 ..............................................2-12 Figure 2-2: Santa Monica Bay Fecal Coliform Concentrations 2016-2020 ..............................................2-13 Figure 2-3: Santa Monica Bay Enterococci Concentrations 2016-2020...................................................2-14 Figure 2-4: Storm Drains Entering Machado Lake ...................................................................................2-18 Figure 2-5: Machado Lake Monitoring Stations.......................................................................................2-21 Figure 2-6: Greater LA Harbor Waters and Monitoring Stations.............................................................2-26 Figure 2-7: Total Nitrogen Concentrations in Peninsula Machado Lake Outfall flows from 2016-2020.2-46 Figure 2-8: Total Phosphorus Outfall Concentrations in Peninsula Machado Lake Outfall flows 2016-2020 .................................................................................................................................................................2-47 Figure 2-9: Total Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016- 2020)........................................................................................................................................................2-48 Figure 2-10: Fecal Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016- 2020)........................................................................................................................................................2-49 Figure 2-11: Enterococci Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016- 2020)........................................................................................................................................................2-50 Figure 3-1: Modeled Regional Projects....................................................................................................3-10 Figure 3-2: Casaba Estates (formerly Butcher Ranch) Post-Development Design Conditions. ...............3-13 Figure 3-3: San Ramon Canyon Project....................................................................................................3-14 Figure 3-4: Chandler Quarry Project Drainage Area Map........................................................................3-16 Figure 3-5: Chandler Quarry Project Drainage and Water Quality Concept Plan....................................3-17 Figure 3-6: Chandler Quarry Project Infiltration System Concept Design ...............................................3-18 Figure 3-7: Torrance Airport Drainage Area ............................................................................................3-20 Figure 3-8: Conceptual Layout of Torrance Airport Basin .......................................................................3-21 Figure 3-9: Geologic Hazards in the Palos Verdes Peninsula Watershed ................................................3-24 Figure 3-10: Proposed PVP Multi-Benefit Flow Diversion Drainage Area ...............................................3-26 Figure 3-11: Proposed Eastview Park Infiltration Project Drainage Area ................................................3-28 Figure 3-12 85th Percentile, 24-Hour Runoff Retention Areas Excluded from RAA.................................3-33 65 Palos Verdes Peninsula
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Figure 3-13 Rolling Hills Nature-Based Stormwater Runoff Retention Area ...........................................3-35 Figure 5-1: 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD-1 and WD-Solano) ...................................................................................................................................................................5-6 Figure 5-2: 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1) ..........................5-7 Figure 5-3: 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA ..............................5-8 List of Appendices
Appendix 1.0 LA County Flood Control District Summary
Appendix 3.1 Nonstructural Targeted Control Measures
Appendix 3.2 Structural Best Management Practices
Appendix 4.1 Reasonable Assurance Analysis Report
Appendix 4.2 Requirements for Achieving Receiving Water Limits 66 Palos Verdes Peninsula
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1. INTRODUCTION AND BACKGROUND
1.1. INTRODUCTION
The Los Angeles Regional Water Quality Control Board (Regional Board) regulates discharges from municipal separate storm sewer systems (MS4s) through the Municipal Separate Storm Sewer System Permit (MS4 Permit). The purpose of the MS4 Permit is to protect the beneficial uses of the receiving waters in the Los Angeles County region by regulating municipal stormwater and non-stormwater discharges from the permittees’ MS4s. The overarching goal of these requirements is to reduce the discharge of pollutants from MS4s to the maximum extent practicable.1 The Permit allows permittees the flexibility of developing an Enhanced Watershed Management Program (EWMP) to implement the requirements of the Permit. Implementation is to be achieved on a watershed basis through customized strategies, control measures, and BMPs to ensure that discharges from the permittees’ MS4s:
i. Achieve applicable WQBELs,
ii. Do not cause or contribute to exceedances of receiving water limitations, and iii. Do not include non-storm water discharges that are effectively prohibited.
Following the adoption of the 2012 MS4 Permit, the Cities of Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills Estates, along with the County of Los Angeles (Unincorporated County), and Los Angeles County Flood Control District (LACFCD), collectively referred to as the Peninsula WMG, began to collaborate on the initial development of an Enhanced Watershed Management Program (EWMP) to implement the requirements of the MS4 Permit on a watershed scale and address the water quality priorities for the Palos Verdes Peninsula watersheds. The Peninsula WMG coordinated with other agencies and watershed management groups in the initial development of the 2016 EWMP, including the City of Los Angeles, the Dominguez Channel EWMP Group, and the Beach Cities EWMP Group. The initial Peninsula EWMP was approved by the Regional Board in April 2016. The City of Rolling Hills has elected to join the Peninsula WMG and has been incorporated into this revised EWMP. The City of Rancho Palos Verdes is the lead agency for the Peninsula WMG.
This revised EWMP reevaluates the Peninsula WMG’s water quality priorities identified during the initial development of the 2016 EWMP in Section 2, presents an updated program of BMPs intended to achieve these water quality priorities in Section 3The results of the revised EWMP are significantly different than the initial EWMP due to availability of Coordinated Integrated Monitoring Program (CIMP) monitoring data and continuous flow monitoring data within the Peninsula WMG area used to calibrate the updated Reasonable Assurance Analysis (RAA) model. The updated Reasonable Assurance Analysis (RAA) results are summarized in Section 4 and the BMP implementation schedule is summarized in Section 5. The financial strategy incorporating new sources of funding for implementation is detailed in Section 6, Section 7 provides the Legal Authority language, Section 8 refers to the Coordinated Integrated Monitoring Program, Section 9 summarizes the Adaptive Management process, and Section 10 summarizes the Reporting Program.
1 Reference: http://www.swrcb.ca.gov/water_issues/programs/stormwater/municipal.shtml 67 Palos Verdes Peninsula
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1.2. PENINSULA WATERSHED
The geographic scope of the Peninsula EWMP (as shown in Figure 1-1) is comprised of the incorporated Cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills, Rolling Hills Estates, and unincorporated areas of the County of Los Angeles and LACFCD facilities (See Appendix 1.0 for a description of the LACFCD and its responsibilities within the Peninsula WMG).
The Palos Verdes Peninsula is situated in the southwestern portion of Los Angeles County atop the Palos Verdes Hills, which are bounded to the north by the cities of Torrance and Lomita, to the east by the San Pedro area of the City of Los Angeles, and to the south and west by the Pacific Ocean. The Peninsula WMG area is divided into two HUC-12 equivalent watersheds: 1) Santa Monica Bay (SMB) Watershed and 2) the Greater Dominguez Channel Watershed Management Area, which is subdivided into two subwatersheds, the Los Angeles Harbor Subwatershed and the Machado Lake Subwatershed. A change in drainage divides the Peninsula WMG from the northeast to the southwest with the westerly and southwesterly portion draining into Santa Monica Bay and the northeasterly portion draining to Machado Lake and the Los Angeles Harbor. The SMB Watershed accounts for 58% (14.8 square miles) of the total Peninsula WMG area, and includes portions of the cities of Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, and Rolling Hills Estates. The Los Angeles Harbor Subwatershed accounts for 18% (4.5 square miles) of the total Peninsula WMG area and includes portions of the cities of Rancho Palos Verdes, Rolling Hills, and Rolling Hills Estates. The Machado Lake Subwatershed accounts for 24% (6.2 square miles) of the total Peninsula WMG area, and includes portions of the cities of Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, Rolling Hills Estates, and the unincorporated areas of the County of Los Angeles. Drainage from the Peninsula WMG agencies is conveyed via natural soft bottom canyons in conjunction with structured storm drain systems. Table 1-1 provides the Peninsula EWMP area identified by watershed and agency, and Figure 1-1 provides a map of the Peninsula EWMP watershed and jurisdictional boundaries, including existing water quality monitoring sites in the Peninsula EWMP area.
Table 1-1: Jurisdictional Areas within Each Peninsula EWMP Watershed Permittee Rancho
Palos
Verdes
Palos
Verdes
Estates
Rolling
Hills
Rolling
Hills
Estates
County of
Los Angeles
Total
Land Area within Santa
Monica Bay Watershed
(Square Miles)
9.35 4.35 0.64 0.46 0 14.8
Land Area within Machado
Lake Subwatershed
(Square Miles)
1.07 0.39 1.3 2.78 0.7 6.2
Land Area within Los
Angeles Los Angeles Harbor
Subwatershed
(Square Miles)
3.02 0 1.1 0.34 0 4.5
Total EWMP Area 13.5 4.8 3.0 3.6 0.7 25.6
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Figure 1-1: Peninsula EWMP Area and Existing Monitoring Locations Peninsula-RW1
Peninsula-RW2
SMB 7-1
SMB 7-2
SMB 7-3
SMB 7-4 SMB 7-5
Receiving Water Site
Outfall Site
TMDL Site
City of Rolling Hills
(Full 85th Percentile
24-Hour Storm Retention Area)
Rolling Hills
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1.3. WATER QUALITY ISSUES AND THE HISTORY OF WATER QUALITY
REGULATIONS
1.3.1. FEDERAL LAW, STATE LAW, AND REGULATORY FRAMEWORK The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for all inland surface waters, estuaries, and coastal waters. The federal Environmental Protection Agency (EPA) is ultimately responsible for implementation of the CWA and its associated regulations. In 1972 the National Pollution Discharge Elimination System (NPDES) was created through Section 402 of the Federal Clean Water Act. The NPDES prohibits discharges of pollutants from any point source, including the MS4 system, into the nation's waters except as allowed under an NPDES permit. The MS4 system includes curbs and gutters, man-made channels, catch basins and storm drains.
The CWA allowed the federal EPA to authorize the NPDES Permit Program to state governments, enabling states to perform many of the permitting, administrative, and enforcement aspects of the NPDES Program. California, like other states, implements the CWA by promulgating its own water quality protection laws and regulations. As long as this authority provides equivalent protections as the federal CWA, EPA can delegate CWA responsibilities to the state while retaining oversight responsibilities. In some cases, California has established requirements that are more stringent than federal requirements.
The 1970, the Porter-Cologne Water Quality Control Act granted the California State Water Resources Control Board (SWRCB) broad powers to protect water quality. The SWRCB chartered nine Regional Water Quality Control Boards (Regional Boards) with regulatory responsibility for developing and enforcing water quality objectives and implementation plans to best protect the beneficial uses of local waterbodies. To protect clean water at the local level, municipalities in Los Angeles County and the County of Los Angeles unincorporated areas are required to obtain a discharge permit from the Regional Board to discharge stormwater through the MS4 into Waters of the United States, hence the MS4 Permit. The Los Angeles Regional Water Quality Control Board (Regional Board) is the governing regulatory agency for water quality within the Peninsula WMG area.
Section 303(d) of the CWA requires states to regularly identify waterbodies not meeting water quality objectives. These waters are often referred to as "303(d) listed" or "impaired" waters. Development and approval of the 303(d) list is a lengthy state and federal process. A list is not effective until the USEPA approves the list. The current 303(d) list for California was approved by USEPA on April 6th, 2018. Changes from the previous 303(d) list include removal of sediment toxicity for the Santa Monica Bay Offshore/Nearshore, and revising the list of Category 2 Water Body Pollutant Combinations by adding arsenic and mercury impairments for the Santa Monica Bay Offshore/Nearshore.
Waterbodies that are listed on the 303(d) list typically require development of a Total Maximum Daily Load (TMDL) for the pollutant(s) impairing the use of water. A TMDL establishes the maximum amount of a pollutant that a waterbody can receive and still meet water quality standards. Depending on the nature of the pollutant, TMDL implementation requires limits on the contributions of pollutants from point sources (waste load allocation), nonpoint sources (load allocation), or both.
Adoption of a TMDL requires an amendment to the Water Quality Control Plan (known as the Basin Plan) for the Los Angeles Region. The Regional Board's Basin Plan is designed to preserve and enhance water quality and protect the beneficial uses of regional waters. Specifically, the Basin Plan (i) designates beneficial uses for surface and ground waters, (ii) sets narrative and numerical objectives that must be 70 Palos Verdes Peninsula
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attained or maintained to protect the designated beneficial uses and conform to the state's antidegradation policy, and (iii) describes implementation programs to protect all waters in the Region.
The Basin Plan is reviewed and updated as necessary (Regional Board 1994, as amended). Following adoption by the Regional Board, the Basin Plan and subsequent amendments are subject to approval by the State Board, the State Office of Administrative Law (OAL), and the Environmental Protection Agency (EPA). The MS4 Permit includes effluent limitations, receiving water limitations, minimum control measures (MCMs), and TMDL provisions, and outlines the process for developing watershed management programs, including the EWMP. Development of an EWMP is one of the options outlined in the MS4 Permit to address effluent limitations, receiving water limitations, and TMDLs. The EWMP must also incorporate MCMs, which are programs required to be implemented to address water quality issues.
1.3.2. CALIFORNIA ENVIRONMENTAL QUALITY ACT
The stormwater structural controls that will be implemented as a result the EWMP may require discretionary approval subject to review under the California Environmental Quality Act (CEQA). The LACFCD has prepared a Programmatic Environmental Impact report (PEIR) for all EWMP groups in which they are a part. This PEIR covers CEQA requirements for the EWMPs as a whole. The Peninsula WMG intends to comply with CEQA when implementing structural BMPs contained in this updated EWMP.
Public agencies responsible for carrying out or approving stormwater structural controls are identified as the lead agency. The environmental review required imposes both procedural and substantive requirements. At a minimum, the lead agency will adhere to the consultation and public notice requirements set forth in the CEQA Guidelines, make determinations whether the proposed stormwater structural control is a “project”, and if so, conduct an initial review of the project and its environmental effects. The lead agency will identify and document the potential environmental impacts of the proposed project in accordance with CEQA, (Public Resources Code Section 21000 et seq.), and the CEQA Guidelines (Title 14 of the California Code of Regulations, Section 15000, et seq.).
Certain classes of projects have been determined not to have significant effect on the environment and are exempt from the provisions of CEQA by statute or category. When a public agency decides that a project is exempt from CEQA, and the public agency approves or determines to carry out the project, the agency may file a Notice of Exemption. For projects deemed not exempt, the lead agency will prepare an Initial Study and decide whether a Negative Declaration is applicable for the project, or depending on the potential effects, a further, and more substantial review may be conducted in the form of an Environmental Impact Report (EIR). A project may not be approved as submitted if feasible alternatives or Mitigation Measures are not able to substantially lessen the significant environmental effects of the project. Moreover, environmental review must include provisions for wide public involvement, formal and informal, in orderto receive and evaluate public reactions to environmental issues, and when deciding the matter, the lead agency must consider all comments it receives (Cal. Pub. Res. Code § 21091(d)(1); 14 CCR § 15074(b)). The lead agency will use the EIR in determining the environmental effects of the proposed storm water project, and whether or not to approve the proposed project. If the proposed project is approved, all conditions and mitigations made in the adopted EIR will become part of any subsequent actions taken by the lead agency. The CEQA process will also be used by permitting agencies, funding agencies and the public to support proposed project decisions.
The National Environmental Policy Act (NEPA) comes into play less often than CEQA, but may be included for storm water projects involving federal funding. A joint NEPA and CEQA review process is encouraged to improve coordination and avoid redundancies. Like CEQA, the NEPA process provides opportunities to address issues related to proposed projects early in the planning stages. NEPA was codified under Title 42 of the United States Code sections 4331 et seq. (42 U.S.C. 4331 et seq.). 71 Palos Verdes Peninsula
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1.4. WATER QUALITY REQUIREMENTS
The Regional Board designates "beneficial uses" for waterbodies in the watersheds that it governs and adopts water quality objectives to protect these uses through the Basin Planning process2. In some cases, EPA may also promulgate objectives where it makes a finding that the state's objectives are not protective enough to protect the beneficial use. The nature of the objectives is directly related to the type of beneficial use. For example, the freshwater warm habitat beneficial use protects aquatic organisms resident in warm-water streams. The associated water quality objectives are for those constituents known to affect both the growth and reproduction of aquatic life. These objectives range from physical characteristics such as temperature, dissolved oxygen, and pH to potential toxic constituents including metals and organics. In California, the objectives for metals and a number of organic compounds have been established by the federal EPA rather than the state (California Toxics Rule, 2000). The EPA promulgated numeric water quality criteria for priority toxic pollutants and other water quality standards provisions based on the determination that the numeric criteria were necessary (since the state had been without numeric water quality criteria for many priority toxic pollutants as required by the CWA) to protect human health and the environment. These Federal criteria are legally applicable in the state for inland surface waters, enclosed bays and estuaries for all purposes and programs under the CWA. The State Water Resources Control Board (State Water Board) adopted the Water Quality Control Plan for Ocean Waters in California, California Ocean Plan in 1972 and adopted the most recent amended Ocean Plan on February 4, 2019. The Ocean Plan also establishes water quality objectives and a program of implementation to protect beneficial uses at all MS4 discharge points within Los Angeles County coastal watersheds. See Chapter 2 for more details.
2 See Regional Board’s Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties, accessed May 07, 2021. 72 Palos Verdes Peninsula
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1.5. THE ENHANCED WATERSHED MANAGEMENT PROGRAM
1.5.1. WATERSHED MANAGEMENT GOALS AND PRIORITIES
Addressing MS4 discharges on a watershed scale allows permittees to meet the requirements of the Permit and address water quality priorities in an integrated and collaborative way. The conditions of the receiving waters drive management actions, which in turn focus on the measures to address pollutant contributions to and from the MS4.
The ultimate goals of the EWMP is to ensure that discharges from the MS4:
1. Achieve applicable Water Quality Based Effluent Limitations (WQBELs) that implement TMDLs,
2. Do not cause or contribute to exceedances of receiving water limitations,
3. Non-stormwater discharges from the MS4 are not a source of pollutants to receiving waters.
1.5.2. WATER QUALITY MANAGEMENT APPROACH
Development of an EWMP is one of the options outlined in the MS4 Permit held by Permittees to address effluent limitations, receiving water limitations, and TMDLs. The EWMP includes an evaluation of existing water quality conditions, including characterization of storm water and non-storm water discharges from the MS4 and receiving water quality to support identification and prioritization/sequencing of management actions. At a minimum, water quality priorities within each Watershed Management Area must include achieving applicable water quality-based effluent limitations and/or established receiving water limitations.
The MS4 permit requires that this EWMP identify strategies, control measures, and BMPs to implement on a watershed scale, with the goal of creating an efficient program to focus collective resources on meeting watershed priorities and effectively controlling the source of pollutants to and from the MS4.
See Chapter 2 of this EWMP for an evaluation of existing water quality conditions and classification of waterbody pollutant combinations as Category 1 (Highest Priority), Category 2 (High Priority), and Category 3 (Medium Priority).
This EWMP has incorporated State agency input from various sources on priority setting and implementation issues. Specific priorities incorporated include, but are not limited to, the following:
• The EWMP is consistent with priorities listed in SB 985 and is in accordance with the Storm Water Resource Plan Guidelines3 for all categories with the exception of those which are more applicable to the Peninsula Coordinated Integrated Monitoring Plan and the California Water Service Urban Water Management Plan.
• The Peninsula WMG lies within the South Bay subregion of the LA IRWMP and will include its regional projects in the LA IRWMP database.
• The Stormwater Strategic Initiative4 identifies prioritization of projects to address issues facing the storm water program. Efforts described within this EWMP have used the same priorities in mind, 3 Storm Water Resource Plan Guidelines. State Water Resources Control Board. December 15, 2015. 4 Stormwater Strategic Initiative. State Water Resources Control Board. June 25, 2015. 73 Palos Verdes Peninsula
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including, but not limited to optimizing the use of stormwater as a resource and providing consistent and widespread messaging to broaden the understanding of the value of stormwater. • The Strategy to Optimize Resource Management of Storm Water5 identifies four main goals, all of which the EWMP has incorporated: 1) Change the Perspective that Storm Water is a Waste or Hazard, and Treat it as a Valuable Water Resource; 2) Manage Storm Water to Preserve Watershed Processes and Achieve Desired Water Quality and Environmental Outcomes; 3) Implement Efficient and Effective Regulatory Programs; and 4) Collaborate in order to Solve Water Quality and Pollutant Problems with an Array of Regulatory and Non-Regulatory Approaches • The California Water Action Plan6 describes several actions to address the drought in California. The actions which this EWMP has incorporated include: making conservation a California way of life; increasing regional self-reliance and integrated water management across all levels of government; protecting and restoring important ecosystems; managing and preparing for dry periods; expanding water storage capacity and improving groundwater management; and providing safe water for all communities.
• The EWMP has incorporated goals in line with the California Stormwater Quality Association’s 2019Strategic Plan7 and 2020 Vision for Sustainable Stormwater Management8, including:
Collaboration – Advance collaboration to address water quality problems in California; Education/Outreach – Advance the knowledge of stormwater quality professionals and increase the awareness and knowledge of policy-makers and regulators in California regarding stormwater issues;
Implementation Guidance – Advance the quality of implementation guidance for environmentally beneficial and cost-effective adaptive management approaches to improving stormwater quality in California that emphasize true source control and operational source control over treatment;
Regulatory Review – Advance the development of consistent, proactive, and flexible stormwater policy and regulations consistent with the maximum extent practicable (MEP) standard of pollutant reduction through the incorporation of the latest scientific and economic information to promote the protection of water quality of beneficial uses; and Scientific Assessment – Advance the understanding of pollutants of concern and their sources, fate, and transport, and the effectiveness of best management practices (BMPs) to control them.
In order to achieve the goals of the MS4 Permit, the approach of the EWMP is to:
• Prioritize water quality issues resulting from stormwater and non-stormwater discharges from the MS4 to receiving waters,
• Identify and implement strategies, control measures, and BMPs that:
o Achieve applicable water quality-based effluent limitations9 o Prevent exceedances of receiving water limitations10
5 Strategy to Optimize Resource Management of Storm Water. State Water Resources Control Board. December 11, 2015. 6 California Water Action Plan. California Natural Resources Agency, California Department of Food and Agriculture, and the California Environmental Protection Agency (Cal/EPA). January 14, 2016. 7 CASQA Strategic Plan and Organizational Goals (April 2019) accessed May 26, 2021.. 8 Vision for Sustainable Stormwater Management – October 2020. California Stormwater Quality Association (CASQA). October 2020.
9 Pursuant to Part VI.B and Attachments J through S of the Permit pursuant to corresponding compliance schedules 10 Pursuant to Parts V and X and Attachments J through S of the Permit 74 Palos Verdes Peninsula
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o Cumulatively retain the runoff volume from the 85th%, 24-hour storm event for the drainage area tributary to the applicable receiving water
o Prevent non-stormwater discharges that are effectively prohibited11 o Reduce the discharge of pollutants to the maximum extent practicable12 • Execute an integrated monitoring program and assessment program13 to determine progress towards achieving applicable limitations and/or action levels.
• Modify strategies, control measures, and BMPs as necessary based on analysis of monitoring data collected pursuant to the Monitoring and Reporting Program (MRP) to ensure that applicable water quality-based effluent limitations and receiving water limitations and other milestones set forth in the EWMP are achieved in the targeted timeframes.
The overall approach is adaptive, whereby BMPs will be implemented, their effectiveness monitored and modifications to this EWMP will be made as needed. These modifications will maintain consistency with the assumptions and requirements of applicable TMDL Waste Load Allocations. 11 Pursuant to Part III.A of the Permit
12 Pursuant to Part IV.A.1 of the Permit
13 Pursuant to Attachment E – MRP of the Permit
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1.6. REASONABLE ASSURANCE ANALYSIS AND WATERSHED CONTROL
MEASURES
As part of the initial EWMP development, a Reasonable Assurance Analysis (RAA) was conducted on a watershed level, to determine through quantitative analysis or modeling, the target load reductions (TLRs) necessary for each of the Peninsula EWMP priority pollutants in order to achieve water quality objectives for areas of the EWMP not addressed through retention of the 85th%, 24-hr storm event. As a part of the Peninsula EWMP’s adaptive management process, the Peninsula WMG is required to submit a revised EWMP to the Regional Board, including an updated RAA, by June 30, 2021.
Building upon the original EWMP, the Revised RAA has been updated to include recent CIMP monitoring data, project planning and implementation, and modeling advances over the past five years. The updated wet weather RAA was conducted using the Watershed Management Modeling System 2.0 (WMMS 2.0), the latest modeling tool developed by LACFCD, to determine a cost-effective implementation strategy to meet applicable water quality priorities. For dry weather, a revised semi-quantitative approach was implemented to update the dry weather portion of the revised RAA.
A suite of Watershed Control Measures (i.e. BMPs) to be implemented to achieve the necessary TLRs is described in Chapter 3 of this revised EWMP. Watershed Control Measures are subdivided into 1) Minimum Control Measures, 2) Non-Stormwater Discharge Measures 3) TMDL Control Measures and 4) other control measures. A schedule has also been developed in Chapter 5 for the strategies, control measures and BMPs to be implemented by each individual Permittee within its jurisdiction and for those that will be implemented by multiple Permittees on a watershed scale. The schedules will measure progress on a semi-regular basis during permit term(s) and incorporate:
1) Deadlines occurring within the permit term for all applicable interim and/or final water quality-based effluent limitations and/or receiving water limitations to implement TMDLs, 2) Interim deadlines and numeric milestones within the permit term for any applicable final water qualitybased effluent limitation and/or receiving water limitation to implement TMDLs, where deadlines within the permit term were not otherwise specified, and
3) Watershed priorities related to addressing exceedances of receiving water limitations. 76 Palos Verdes Peninsula
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1.7. ADAPTIVE MANAGEMENT
An adaptive management process will continue to be implemented to further refine and adapt the EWMP to become more effective, based on, but not limited to the following:
1. Progress toward achieving the outcome of improved water quality in MS4 discharges and receiving waters through implementation of the watershed control measures,
2. Progress toward achieving interim and/or final water quality-based effluent limitations and/or receiving water limitations, or other numeric milestones where specified, according to established compliance schedules,
3. Achievement of interim milestones;
4. Reopening of TMDLs and new 303(d) listings;
5. Re-evaluation of the highest water quality priorities identified for the Watershed Management Area based on more recent water quality data for discharges from the MS4 and the receiving water(s) and a reassessment of sources of pollutants in MS4 discharges,
6. Availability of new information and data from sources other than the Permittees’ monitoring program(s) within the Watershed Management Area that informs the effectiveness of the actions implemented by the Permittees,
7. Regional Water Board recommendations; and
8. Recommendations for modifications to the EWMP solicited through a public participation process.
Based on the results of the adaptive management process, modifications necessary to improve the effectiveness of the EWMP will be reported in the Annual Report, and as part of the Report of Waste Discharge (ROWD). Any necessary modifications to the EWMP will be implemented upon acceptance by the Regional Water Board Executive Officer within 60 days of submittal if the Regional Water Board Executive Officer expresses no objections.
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2. IDENTIFICATION OF WATER QUALITY PRIORITIES
This updated Enhanced Watershed Management Program (EWMP) re-evaluates water quality priorities identified for the Palos Verdes Peninsula Watershed Management Group (Peninsula WMG) during the initial development of the EWMP. Water quality priorities have been revised based on updated information and recent water quality data collected in the receiving water and re-assessment of sources of pollutants in the watershed based on discharge water quality data collected from Peninsula WMG outfalls since the initial development of the EWMP.
During the initial development of the EWMP, an evaluation of existing water quality conditions was conducted in order to evaluate and prioritize water quality issues. Available data from applicable Total Maximum Daily Loads (TMDLs), the State’s 303(d) list of impaired water bodies, and available monitoring data collected between 2003-2015 were analyzed. For this update, recent information as well as four years of receiving water and outfall water quality monitoring data collected between 2016 and 2020 under the Palos Verdes Peninsula Coordinated Integrated Monitoring Program (Peninsula CIMP) have been assessed as summarized below in Section 2.2 Receiving Water Characterization and Section 2.3 Source Assessment.
2.1. WATER QUALITY CHARACTERIZATION AND PRIORITIZATION
The updated receiving water characterization in Section 2.2 has been used to identify pollutants of concern for the Peninsula WMG and to classify them into the following three waterbody-pollutant combination categories:
CATEGORY 1: Waterbody-pollutant combinations for which water quality-based effluent limitations and/or receiving water limitations are established pursuant to a Total Maximum Daily Load (TMDL) as identified in Part VI.B TMDL Provisions and Attachments J through S of the MS4 Permit.
CATEGORY 2: Pollutants for which data indicate water quality impairment in the receiving water according to the State Board’s Water Quality Control Policy for Developing California’s Clean Water Act Section 303(d) List (State Listing Policy) and for which MS4 discharges may be causing or contributing to the impairment but for which a TMDL has not been established.
CATEGORY 3: Pollutants for which there are insufficient data to indicate water quality impairment in the receiving water according to the State’s Listing Policy but for which data indicating exceedances of applicable receiving water limitations may be occurring and for which MS4 discharges may be causing or contributing to the exceedance.
This categorization forms the basis for prioritizing pollutants to be addressed by the EWMP. All of the identified Peninsula WMG’s pollutants of concern fall into either Category 1 or 2 classification. There are no Category 3 pollutants identified based on the receiving water characterization. Table 2-1 summarizes the priority pollutant categorization for the Peninsula EWMP. As shown, Category 1 and Category 2 pollutants are considered with Highest and High Priority, respectively, in identifying control measures to be implemented in each watershed. Highest priority pollutants include those with water quality-based effluent limitations and/or receiving water limitations established pursuant to a TMDL. High priority pollutants include those for which data indicate impairment of receiving water limitations and for which the source assessment detailed in Section 2.3 has identified MS4 discharges as a potential source. 78 Palos Verdes Peninsula
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Table 2-2: Peninsula EWMP Priority Pollutants
Category Priority Pollutant
Waterbody
Santa
Monica Bay
Santa
Monica Bay
Beaches
Machado
Lake
Wilmington
Drain
Inner Los
Angeles
Harbor
Cabrillo
Marina
1 Highest
Chlordane (water, sediment, fish tissue) x
Copper (water and sediment) x x
DDT (water, sediment, fish tissue) x x x x x
Dieldrin (water, sediment, fish tissue) x
Indicator Bacteria x
Lead (water and sediment) x x
Total Nitrogen x
Total PAHs x x
PCBs (water, sediment, fish tissue) x x x x x
Total Phosphorus x
Trash x x
Zinc (water and sediment) x x
2 High
Arsenic x
Indicator Bacteria x
Mercury x
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2.2. RECEIVING WATER CHARACTERIZATION
The Peninsula WMG area encompasses portions of the drainage area tributary to three receiving waterbodies: the Santa Monica Bay, Machado Lake (which includes Wilmington Drain), and the Greater Los Angeles Harbor. Existing water quality is characterized for each of these receiving waters using the following information:
● Water Quality Control Plans
o Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan)14 o California Ocean Plan15
● Applicable TMDLs
o Santa Monica Bay Bacteria Dry and Wet Weather TMDLs
o Santa Monica Bay Marine Debris TMDL
o Santa Monica Bay DDT and PCBs TMDL
o Machado Lake Trash TMDL
o Machado Lake Pesticides and PCBs TMDL
o Machado Lake Nutrient TMDL
o Long Beach and Greater Los Angeles Harbor Toxics TMDL16 ● California Water Quality Control Board Surface Water Quality Assessment Integrated Reports o 2014/2016 303(d) List of Impaired Waterbodies
o 2018 303(d) List of Impaired Waterbodies
● Monitoring Data and Reports
o PVP CIMP Water Quality Data
o Machado Lake Water Quality Monitoring Data collected by City of Los Angeles o Greater Los Angeles Harbor Waters Coordinated Compliance Monitoring and Reporting Water Quality Monitoring Data collected by the Greater Harbor Waters Regional Monitoring Coalition
The sections below provide more details on the updated information utilized to evaluate existing water quality for the Peninsula WMG’s three receiving waters: Santa Monica Bay, Machado Lake and Greater Los Angeles Harbor waters.
WATER QUALITY CONTROL PLANS
The Peninsula WMG watersheds are subject to both the Basin Plan and California Ocean Plan, which set water quality objectives and implementation provisions to protect the quality of surface and marine 14 Los Angeles Regional Water Quality Control Board. Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. Last accessed online on March 26, 2021.
https://www.waterboards.ca.gov/losangeles/water_issues/programs/basin_plan/basin_plan_documentation.html 15 State Water Resources Control Board, 2019. Water Quality Control Plan for Ocean Waters in California, California Ocean Plan effective February 4, 2019.
16 As recognized by the footnote in Attachment K-4 of the 2012 LA MS4 Permit, the Peninsula WMG members have entered into an Amended Consent Decree with the United States and the State of California, including the Regional Board, pursuant to which the Regional Board has released the Peninsula WMG members from responsibility for Toxic pollutants in the Dominguez Channel and the Greater Los Angeles and Long Beach Harbors. Accordingly, no inference should be drawn from the submission of this EWMP or from any action or implementation taken pursuant to it that the Peninsula WMG has waived any rights under the Amended Consent Decree.
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waters, respectively, and to ensure that the beneficial uses of these waters are maintained. For this EWMP update, the most recent versions of the Basin Plan and Ocean Plan available as of the preparation of this document were consulted to determine beneficial uses and water quality objectives applicable to the Peninsula WMG. The beneficial uses of the Peninsula WMG’s receiving waters as designated in the Basin Plan are summarized in Table 2-2, and the beneficial use acronyms used in the table are defined as follows:
MUN – Municipal and Domestic Supply
IND – Industrial Service Supply
GWR – Groundwater Recharge
NAV – Navigation
COMM – Commercial and Sport Fishing
REC1 – Water Contact Recreation
REC2 – Non-Contact Water Recreation
WARM – Warm Freshwater Habitat
MAR – Marine Habitat
WILD – Wildlife Habitat
BIOL – Preservation of Biological Habitats
RARE – Rare, Threatened, or Endangered Species
aquatic habitat
MIGR – Migration of Aquatic Organisms
SPWN – Spawning, Reproduction, and/or Early
Development
SHELL – Shellfish Harvesting
WET – Wetland Habitat
Table 2-3: Peninsula EWMP Area Water Bodies and Beneficial Uses Designated in the Basin Plan Water Body
MUN
IND
GWR
NAV
COMM
REC1REC2
WARM
MAR
WILD
BIOL
RARE
MIGR
SPWN
SHELL
WETb
Los Angeles County Coastal Nearshore Zone^ E E E E E E E E Ee Ef Ef Ear Los Angeles County Coastal Offshore Zone E E E E E E E Ee Ef Ef E Machado Lake P* E E E E E E
Coastal Streams of Palos Verdes P* I I I I E E
Canyon Streams of Palos Verdes P* I I I I E E
Point Vicente Beach E E E E E E P E
Los Angeles Harbor – Other Inner Areas E E E P E E Ee P Los Angeles Harbor – Marinas (Cabrillo) E E E E E E E P E: Existing beneficial use; P: Potential beneficial use; I: Intermittent beneficial use * Asterisked MUN designations are designated under SB 88-63 and RB 89-03. Some designations may be considered for exemption at a later date.
b Water bodies designated as WET may have wetlands habitat associated with only a portion of the water body. Any regulatory action would require a detailed analysis of the area.
^ Nearshore is defined as the zone bounded by the shoreline and a line 1000 feet from the shoreline or the 30-foot depth contours, whichever is further from the shoreline. Longshore extent is from Rincon Creek to the San Gabriel River Estuary. e One or more rare species utilizes all ocean, bays, estuaries, and coastal wetlands for foraging and/or nesting. f Aquatic organisms utilize all bays, estuaries, lagoons, and coastal wetlands, to a certain extent, for spawning and early development. This may include migration into areas which are heavily influenced by freshwater inputs. arAreas exhibiting large shellfish populations include Malibu, Point Dume, Point Fermin, White Point and Zuma Beach.
TOTAL MAXIMUM DAILY LOADS (TMDLS) AND 303(D) LISTINGS
Waterbodies or waterbody segments that do not meet water quality standards consistent with beneficial uses are considered impaired and placed on the State Water Resources Control Board’s 303(d) list of impaired waters which includes identification of the specific pollutant(s) causing the impairment, i.e., waterbody/pollutant combinations. TMDLs are required to be developed for pollutants that are causing impairment for each listed waterbody or waterbody segment. Where appropriate, TMDLs assign waste 81 Palos Verdes Peninsula
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load allocations (WLAs) to MS4 dischargers to ensure that the total amount of a particular pollutant entering a receiving waterbody from the MS4 will not cause the water quality objectives in that water body to be exceeded and thereby impair its beneficial uses. Table 2-3 shows existing TMDLs applicable to the Peninsula WMG that were evaluated to identify Category 1 water body pollutant combinations. 82 Palos Verdes Peninsula
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Table 2-4: TMDLs Applicable to the Peninsula EWMP
TMDL Water Body Segments
Addressed by TMDL
Pollutants
Addressed by
TMDL
Regional Board Resolution Number Effective Date
Santa Monica Bay Beaches Bacteria Wet
and Dry Weather TMDLs
Santa Monica Bay
Beaches
Indicator Bacteria
(Total Coliform
Fecal Coliform
Enterococcus)
2002-022 (Wet TMDL) &
2002-004 (Dry TMDL);
Amended by R12-007
July 15, 2003;
R12-007 effective July 2,
2014
Santa Monica Bay Nearshore and
Offshore Debris TMDL Santa Monica Bay Trash R10-010 Amended by R19-004 March 20, 2012
R19-004 effective date
pending
Santa Monica Bay DDT and PCBs TMDL
Santa Monica Bay
Santa Monica Bay
Beaches
DDT
PCBs Established by USEPA March 26, 2012
Machado Lake Trash Machado Lake Trash 2007-006
Amended by R19-14
March 6, 2008
R19-14 effective date
pending
Machado Lake Pesticides and PCBs
(Toxics) TMDL Machado Lake
Chlordane
Dieldrin
PCBs
DDT
R10-008 March 20, 2012
Machado Lake Nutrient TMDL Machado Lake
Algae
Total Nitrogen
Total Phosphorus
Ammonia
Chlorophyll a
Dissolved Oxygen
Odor
2008-006 March 11, 2009
Dominguez Channel and Greater Los
Angeles and Long Beach Harbor Waters
Toxic Pollutants TMDL
Inner Harbor
Cabrillo Marina
DDT
PCBs
Copper
Lead
Zinc
PAHs
R11-008 March 23, 2012
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The State’s 2014/2016 and 2018 303(d) lists have been reviewed to identify waterbody impairments applicable to the Peninsula WMG that are not yet being addressed by a TMDL. Table 2-4 below summarizes the waterbody pollutant combinations identified on these 303(d) lists that are the basis for Peninsula EWMP Category 2 water body pollutant combinations.
Table 2-5: 303(d) Listed Pollutants in Peninsula EWMP Watersheds Impaired Waterbody Segment Pollutant Causing Impairment Santa Monica Bay Arsenic
Santa Monica Bay Mercury
Wilmington Drain Coliform Bacteria
WATER QUALITY MONITORING DATA
The Peninsula WMG, implements the Palos Verdes Peninsula Coordinated Integrated Monitoring Program (CIMP). The data collected by the CIMP are used to assess water quality priorities and effectiveness of EWMP projects and programs. The CIMP established two (2) new near-shore monitoring locations in the Santa Monica Bay (approximately 1000 feet offshore) for collection of receiving water monitoring data during three (3) wet weather events and two (2) dry weather events per year. The CIMP also includes weekly indicator bacteria monitoring conducted in accordance with the Santa Monica Bay Beaches Bacteria TMDL at five (5) historical Santa Monica Bay shoreline locations.
In addition, some CIMP receiving water data evaluated in this water quality prioritization has been collected by other agencies or groups including:
● Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL data collected under the Coordinated Compliance Monitoring and Reporting Plan (CCMRP) implemented by the Regional Monitoring Coalition (RMC) for the Greater Harbor Waters, and ● Machado Lake in-lake water quality, sediment and fish tissue data collected by the City of Los Angeles under the Machado Nutrient and Pesticides and PCBs TMDLs.
The following sections are organized by watershed and include a characterization of each receiving water body based on applicable TMDLs, 303(d) listings and recently collected water quality data. 84 Palos Verdes Peninsula
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2.2.1. SANTA MONICA BAY
The Palos Verdes Peninsula is known for its steep cliffs and rocky intertidal coastal habitat and tidepools.
Sandy beaches on the Peninsula are few and small, most with difficult access. The portion of the Peninsula WMG with drainage tributary to Santa Monica Bay consists of approximately 14.8 square miles, which is about 3.6% of the Santa Monica Bay Watershed (414 sq. mi.).
INDICATOR BACTERIA
The Santa Monica Bay Beaches (SMB Beaches) were first designated as impaired due to fecal indicator bacteria on the State’s 1998 303(d) list of impaired waters. The Regional Board subsequently issued the SMB Beaches Bacteria TMDLs (SMBBB TMDLs) for wet and dry weather conditions, which became effective on July 15, 2003 and were subsequently amended on July 2, 2014. All of the Peninsula shoreline monitoring sites have been delisted from the 2014/16 and 2018 303(d) lists in accordance with the State Water Resources Control Board’s delisting criteria, however the SMBBB TMDLs continue to remain in effect.
The SMBBB TMDLs include single-sample and six-week rolling geometric mean numeric objectives for total coliform, fecal coliform and enterococcus densities measured in most probable number per 100 milliliters (MPN/100mL). The TMDLs set waste load allocations (WLAs) based on the single sample objectives as an allowable number of days on which the single sample bacteria objectives could be exceeded at shoreline monitoring sites along the Santa Monica Bay (allowable exceedance days). The TMDLs divide the calendar year into three separate periods, each with specified numbers of allowable single-sample exceedance days:
● Summer dry-weather (April 1 – October 31),
● Winter dry weather (November 1 – March 31), and
● Wet weather (Year-round)
The six-week rolling geometric mean applies year-round during all weather conditions.
Table 2-5 shows the single sample and geometric mean bacteria objectives for the three types of indicator bacteria and Table 2-6 presents the allowable number of exceedance days at each monitoring location along the Peninsula WMG’s shoreline.
Table 2-6: SMBBB TMDL Bacteria Objectives
Constituent Six-Week Rolling Geometric Mean Single Sample Total Coliform* 1,000 MPN/100 mL 10,000 MPN/100 mL
Fecal Coliform 200 MPN/100 mL 400 MPN/100 mL
Enterococcus 35 MPN/100 mL 104 MPN/100 mL
*Total Coliform density shall not exceed a daily maximum of 1,000/100 mL if the ratio of total to fecal coliform exceeds 0.1
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Table 2-7: Allowable Exceedance Day(s) by Period and Monitoring Location Shoreline Monitoring Location Period
Winter Dry Weather (b) Summer Dry Weather (c) Wet Weather (d) (e)
SMB 7-1 (Malaga Cove) 1 0 2
SMB 7-2 (Bluff Cove) 1 0 0
SMB 7-3 (Long Point) 1 0 1
SMB 7-4 (Abalone Cove) 0 0 1
SMB 7-5 (Portuguese Bend Cove) 1 0 1
(a) Allowable Exceedance days based on weekly sampling; (b) Final period beginning July 15, 2009;
(c) Final period beginning July 15, 2006;
(d) Wet weather days include days with rain events of ≥ 0.1 inches of precipitation and the three days following the end of the rain event;
(e) Final period beginning July 15, 2021
To meet the monitoring requirements of these TMDLs, a SMB Beaches Bacteria TMDLs Coordinated Shoreline Monitoring Plan was developed by a committee of responsible agencies including representatives from the Peninsula WMG. The five shoreline monitoring sites established for the Peninsula WMG area (SMB 7-1 through 7-5) are shown on Figure 1-1. These five shoreline monitoring sites historically demonstrated fewer exceedance days than the reference beach (Leo Carrillo) used in the TMDL and were therefore considered anti-degradation sites which were required to maintain their existing high quality. The five Peninsula shoreline monitoring sites have historically and continue to be sampled for indicator bacteria along the Palos Verdes Peninsula shoreline on a weekly basis. The data summarized in Table 2-7 and Table 2-8 indicate that exceedances of the single sample and rolling six-week geometric mean receiving water limitations are infrequent at these shoreline monitoring sites and even during the 2016-17 rainy season, which exceeded the number of wet days for the critical 90th percentile wet year, there were very few exceedances.
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Table 2-8: Number of Exceedance Days Above Allowable Receiving Water Limitations Station ID SMB 7-1 SMB 7-2 SMB 7-3 SMB 7-4 SMB 7-5
Season* Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Reporting
Year
Number of Exceedances of Annual Allowable Exceedance Days 2019-20 0 0 1 0 0 0 0 0 0 1 0 0 1 0 0
2018-19+ 0 0 0 0 0 1 0 0 1 0 1 0 1 0 0
2017-18 0 0 0 0 0 0 0 2 0 0 0 0 0 0 0
2016-17* 0 0 2 0 0 0 0 0 2 0 0 2 0 0 0
+ From 11/19/18 through 1/14/19 enterococcus samples were run with 0:0 dilution rather than standard 1:10 dilution in an attempt to lower the detection limits for enterococcus following changeover in laboratories and method of analysis from EPA 1600 membrane filtration to IDEXX Enterolert® which may have resulted in increase in false positive exceedances. * The number of wet days during the 2016-17 rainy season exceeded the number of wet days during the critical 90th percentile rain year 87 Palos Verdes Peninsula
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Table 2-9: Number of Year-Round Rolling Six-Week Geomean Exceedances of Receiving Water Limitations Station ID SMB 7-1 SMB 7-2 SMB 7-3 SMB 7-4 SMB 7-5
Reporting
Year
Number of Rolling Six-Week Geomean Exceedances
2019-20 1 0 0 0 0
2018-19 + 2 0 0 0 1
2017-18 0 0 0 0 0
2016-17* 2 0 0 1 0
+ From 11/19/18 through 1/14/19 enterococcus samples were run with 0:0 dilution rather than standard 1:10 dilution in an attempt to lower the detection limits for enterococcus using IDEXX Enterolert® analytical method which may have resulted in an increase in false positive results and geomean exceedances * The number of wet days during the 2016-17 rainy season exceeded the number of wet days during the critical 90th percentile rain year 88 Palos Verdes Peninsula
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In addition, two nearshore receiving water monitoring stations located approximately 1,000 feet offshore in the Santa Monica Bay are being used to assess the effects of stormwater discharges on Santa Monica Bay receiving water quality. Each of these stations is situated directly in line with one of the two (2) CIMP outfall monitoring locations and wet weather nearshore receiving water sampling occurs in the Santa Monica Bay as soon as safety allows following outfall sampling. Four complete years of wet and dryweather data from these receiving water sites have been collected beginning with reporting year 2016-
17. Out of the forty (40) samples collected offshore in the Santa Monica Bay during this four-year period, only three (3) samples, or 7.5% of samples, exhibited elevated indicator bacteria results above Ocean Plan objectives. Figure 2-1, Figure 2-2, Figure 2-3 show fecal indicator bacteria concentrations observed in receiving water samples collected under the PVP CIMP between 2016 and 2020. The horizontal line in each graph represents the Ocean Plan target for each respective species. As can be seen in these graphs, indicator bacteria concentrations in the Santa Monica Bay receiving water are consistently well below the 2012 Ocean Plan targets17.
17 While these graphs compare data to the 2012 Ocean Plan, bacteria targets in the most recent (2019) Ocean Plan are consistent with the 2012 Ocean Plan.
Figure 2-2: Santa Monica Bay Total Coliform Concentrations 2016-2020 89 Palos Verdes Peninsula
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Figure 2-3: Santa Monica Bay Fecal Coliform Concentrations 2016-2020 90 Palos Verdes Peninsula
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PCBS AND DDTS
The Palos Verdes Shelf portion of Santa Monica Bay is an active EPA Superfund site that is subject to Superfund Remedial Action Objectives which include institutional controls, natural recovery, capping, and monitored attenuation, and are expected to result in improved water quality. 18 From 1947 to 1971 large quantities of DDT were discharged from the Montrose Chemical plant in Los Angeles to the Los Angeles County Joint Water Pollution Control Plant (JWPCP) which discharges to the Palos Verdes Shelf. PCBs also entered the JWPCP from several industrial sources in the Los Angeles area. These DDT and PCBs discharges passed through the JWPCP and were deposited on the Palos Verdes Shelf. There have also been reports of recently discovered illegal offshore dumping of waste barrels containing DDT acid sludge between Catalina Island and the Palos Verdes coast19. There is also concern that the rate of erosion on the southwest portion of the Palos Verdes Shelf could bring previously buried deposits to the surface. 18 USEPA: Santa Monica Bay DDT and PCBs TMDL
19https://www.latimes.com/projects/la-coast-ddt-dumping-ground/#nt=1col-7030col1-mainnt=00000173-4a29- dafc-a977-dabb7b330001-liA9promoSmall-1col-7030col1-main Figure 2-4: Santa Monica Bay Enterococci Concentrations 2016-2020 91 Palos Verdes Peninsula
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Concentrations of DDT and PCBs deposited in the surface sediments of the Santa Monica Bay have decreased substantially since the early 1970s and during this time period the benthic communities in the Palos Verdes shelf and Santa Monica Bay have improved substantially to the point where impairments to benthic communities are not seen; however, DDT and PCBs are still present at levels of concern for bioaccumulation and human health20. This contamination of DDT and PCBs in the sediments of Santa Monica Bay, largely centered on the Palos Verdes shelf, has led to a large number of fish advisories for much of Santa Monica Bay and a commercial fishing ban in the area around the Palos Verdes Shelf. As a result, the US EPA issued the Santa Monica Bay DDT and PCBs TMDL in 2012 and the TMDL objectives were established to meet fish concentrations for human consumption.
Four complete years of nearshore receiving water quality data have been collected under the PVP CIMP in the Santa Monica Bay and analyzed for total DDT and PCBs. Of these dry and wet-weather samples collected over the past four years, only one (1) out of forty (40) samples or 2.5% resulted in detection of 4,4’- DDT at a concentration between the method detection limit and the reporting limit. This sample was collected during a summer dry weather sampling event in the fourth year of CIMP monitoring. None of the forty (40) receiving water samples collected over the past four years have resulted in detections of Total PCBs above the Ocean Plan objective for total PCBs.
TRASH
The Santa Monica Bay nearshore beneficial uses are impaired by the accumulation of suspended and settleable debris. In 2008 and 2009, Regional Board staff conducted site visits along beaches in the southern and northern parts of the Santa Monica Bay to document the trash problem, though no beaches along the Peninsula WMG area were included in these site visits. Common items found on every beach evaluated included: plastic bags, candy wrappers, cigarette butts, styrofoam, beverage containers, straws, and paper. To address this impairment, the Regional Board issued the Santa Monica Bay Nearshore and Offshore Marine Debris TMDL (SMB Marine Debris TMDL), which went into effect on Mar 20, 2012. The SMB Marine Debris TMDL established a numeric target of zero trash and zero plastic pellets in the Santa Monica Bay based on the narrative water quality objectives in both the Basin Plan and the Ocean Plan.
ARSENIC & MERCURY
The Santa Monica Bay is listed on the State’s 2014/16 and 2018 303(d) Lists as being impaired by arsenic and mercury based on sediment and fish tissue data collected under the Hyperion Treatment Plant NPDES Permit no. CA0109991 between January 2006 and June 2010. Nineteen (19) of 19 fish tissue samples collected in the Santa Monica Bay exceeded the USEPA Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories Volume 1: Fish Sampling and Analysis21 for arsenic in fish tissue of 0.0034 ppm. Two (2) of thirty-two (32) sediment samples exceeded the Basin Plan narrative objective for mercury based on the effects range median for saline waters (predictive of sediment toxicity) for mercury of 0.71 20 USEPA: Santa Monica Bay DDT and PCBs TMDL
21 USEPA. Office of Science and Technology Office of Water. Guidance for Assessing Chemical Contaminant Data for Use In Fish Advisories Volume 1: Fish Sampling and Analysis. EPA 823-B-00-007 (November 2000). 92 Palos Verdes Peninsula
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mg/Kg dry weight22. In addition, two (2) of nineteen (19) fish tissue samples exceeded the OEHHA fish contaminant goal of 0.22ppm23.
TOXICITY
The Santa Monica Bay Offshore/Nearshore water body was removed from the 2014/16 and 2018 303(d) lists for sediment toxicity at the recommendation of USEPA, indicating that Peninsula shoreline waters are no longer considered to be impaired for sediment toxicity.
Some intermittent water column toxicity has been observed in the nearshore receiving water quality monitoring data collected under the PVP CIMP. One (1) out of twenty-four (24) wet weather nearshore receiving water samples collected under the PVP CIMP over the past four years has indicated toxicity, however the toxic effect was not sufficiently elevated to require the performance of a toxicity identification evaluation (TIE) and subsequent follow up wet-weather sampling showed no further toxic effects during wet weather.
During the third and fourth years of PVP CIMP dry weather monitoring, three (3) of four (4) dry weather receiving water samples collected in the Santa Monica Bay at receiving water site RW-1 off Malaga Cove in Palos Verdes Estates indicated low-level persistent toxicity. A TIE was performed on the initial receiving water sample showing toxicity collected at RW-1. The result of this TIE was inconclusive, though divalent cationic metals were suggested as the potential constituents causing the observed effects during that dry weather receiving water monitoring event. Follow up sampling at an ‘upstream’ shoreline monitoring found no toxicity present closer to the shoreline nor were metals observed above Ocean Plan limits in either the nearshore or shoreline receiving water sites. Based on monitoring data collected to date, there is no evidence that MS4 discharges have caused or contributed to these intermittent nearshore toxicity results nor has a cause of the toxicity been identified.
2.2.2. MACHADO LAKE
Machado Lake is located in the Ken Malloy Harbor Regional Park, which is a 231-acre Los Angeles City Park serving the Wilmington and Harbor City communities. Machado Lake was created by damming one of the last wetland systems in Los Angeles in 1971. The lake was intended for boating and fishing but over the years water quality generally declined, boating was stopped, and signs were posted warning of the risk of eating fish from the lake.
The Peninsula WMG areas do not drain directly into Machado Lake. The portion of the Peninsula WMG which contributes runoff to Machado Lake consists of approximately 6.2 square miles, which is about 27% of the Machado Lake watershed drainage area (approximately 22.6 sq. mi. in total). Drainage from the Peninsula WMG areas exits the Palos Verdes Peninsula in an easterly or northeasterly direction where it 22 Long, E.R., D.D. MacDonald, S.L. Smith, and F.D. Calder. Incidence of adverse biological effects within ranges of chemical concentrations in marine and estuary sediments. Environmental Management. 19, (1): 81-97 (1995).
23 Klasing, S. and Brodberg, R. Development of Fish Contaminant Goals and Advisory Tissue Levels for Common Contaminants in California Sport Fish: Chlordane, DDTs, Dieldrin, Methylmercury, PCBs, Selenium, and Toxaphene. Pesticide and Environmental Toxicology Branch Office of Environmental Health Hazard Assessment California Environmental Protection Agency. (June 2008). 93 Palos Verdes Peninsula
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is comingled with drainage from the cities of Torrance and Lomita prior to flowing into three of the four major drainage systems entering Machado Lake: Wilmington Drain, Project 77 and Project 510 (Figure 2- 4). As shown in Table 2-3, Machado Lake is impaired for organochlorine pesticides, PCBs, nutrients, and trash. Over 80% of the Peninsula WMG’s Machado Lake watershed drains to Machado Lake through Wilmington Drain. Wilmington Drain is listed on the State’s 303(d) List for indicator bacteria.
Machado Lake underwent renovations as part of the City of Los Angeles’s Machado Lake Ecosystem Rehabilitation Project funded by Prop O which was completed in 2017. The primary goal of the Rehabilitation Project was to improve water quality in Machado Lake while also enhancing natural habitat and recreational features of the park. The project consisted of in-lake improvements that included dredging approximately 239,000 cubic yards of lake sediment and capping the lake bottom with an AquaBlok bio-layer cap, constructing an oxygenation system, and rehabilitating the dam structure at the south end of the lake. Storm drain facility improvements included installing five (5) Continuous Deflection Separation (CDS) systems at the major storm drain inlets to treat storm water before it enters the lake.
The vegetation, habitat, and park improvements included invasive plant removal, replanting of native species, and installation of fencing and walkways. The project has been undergoing an optimization period since the project was completed, and the City of Los Angeles began conducting receiving water monitoring in Machado Lake on September 11, 2017. The Machado Lake Ecosystem and Rehabilitation Project optimization period is expected to last between three to five years to allow for control measures such as vegetation for water quality treatment to be fully established. As part of the City of Los Angeles’ Machado Lake Ecosystem and Rehabilitation Project, planning efforts are underway to pump treated water from Terminal Island’s Advanced Water Purification Plant to Machado Lake to offset impacts of evapotranspiration. This is expected to lower pollutant concentrations to below the required levels for Machado Lake TMDLs.
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Figure 2-5: Storm Drains Entering Machado Lake
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NUTRIENTS
Machado Lake is identified on the State’s 303(d) list of impaired water bodies due to eutrophic conditions, algae, ammonia, and odors. Eutrophication is defined by increased nutrient loading to a waterbody and the resulting increased growth of biota, phytoplankton and other aquatic plants. To address these impairments, the Regional Board issued the Machado Lake Eutrophic, Algae, Ammonia, and Odors (Nutrient) TMDL, which became effective March 11, 2009. The chemical pollutants that most stimulate excessive aquatic vegetative growth and stimulate eutrophication are nitrogen and phosphorus, thus numeric receiving water limitations were set for these constituents in the Machado Lake Nutrient TMDL.
Table 2-9 presents numeric targets and interim and final load and waste load allocations for Machado Lake.
Table 2-10: Nutrient TMDL Numeric Targets and Load Allocations for Machado Lake Date Numeric Target WLAs and LAs
(Monthly Average Concentration)
March 11, 2009
(1st Interim)
- Total Phosphorus
1.25 mg/L
Total Nitrogen
3.5 mg/L
March 11, 2014
(2nd Interim)
- Total Phosphorus
1.25 mg/L
Total Nitrogen
2.45 mg/L
September 11, 2018
(Final)
Total Phosphorus
0.1 mg/L (monthly average)
Total Nitrogen
1.0 mg/L (monthly average)
Ammonia
5.95 mg/L (hourly average)
2.15 mg/L (30-day average)
Dissolved Oxygen*
5 mg/L (single sample minimum)
*Measured at 0.3-m above the sediment)
Chlorophyll-a
20 μg/L (monthly average)
Total Phosphorus
0.1 mg/L
Total Nitrogen
1.0 mg/L
Just over two years of in-lake water quality data have been collected by City of Los Angeles following completion of the Machado Lake Ecosystem Rehabilitation Project24. Nutrient data is collected via grab sampling from two in-lake monitoring stations: ML-1 and ML-2 (Figure 2-5), and a thirty-day rolling average in-lake concentration is calculated on a monthly basis for Total Nitrogen and Total Phosphorus. 24 Water quality monitoring data collection began September 2017, following completion of the Machado Lake Ecosystem Rehabilitation Project, and was available through June 2020 at the time of this update. 96 Palos Verdes Peninsula
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Table 2-10 below shows monthly average Total Nitrogen and Total Phosphorus concentrations calculated for Machado Lake. With the exception of Total Nitrogen monthly average concentration in January and April 2020, all in-lake monthly average concentrations of Total Nitrogen and Total Phosphorous have been higher than applicable receiving water limitations established in the TMDL.
Table 2-11: Monthly Average TN and TP Concentration in Machado Lake Month/Year
Total Nitrogen Monthly
Average (mg/L,
calculated)
Total Phosphorus
Monthly Average (mg/L,
calculated)
September 2017 - 0.2
October 2017 - 0.18
November 2017 1.70 0.17
December 2017 1.35 0.14
January 2018 1.24 0.27
February 2018 - 0.28
March 2018 1.14 0.42
April 2018 1.98 0.29
May 2018 3.65 0.38
June 2018 2.70 0.27
July 2018 2.88 0.38
August 2018 4.43 0.54
September 2018 2.30 0.27
October 2018 2.78 0.32
November 2018 3.10 0.33
December 2018 1.58 0.32
January 2019 1.56 0.38
February 2019 1.14 0.28
March 2019 - 0.28
April 2019 - 0.30
May 2019 1.45 0.31
June 2019 1.38 0.33
July 2019 1.8 0.3
August 2019 2.2 0.3
September 2019 2.2 0.3
October 2019 2.3 0.3
November 2019 2 0.2
December 2019 1.4 0.4
January 2020 0.8 0.28
February 2020 1.3 0.28
March 2020 1.2 0.21
April 2020 1 0.19
May 2020 1.5 0.21
June 2020 1.6 0.26
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Figure 2-6: Machado Lake Monitoring Stations
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ORGANOCHLORINE PESTICIDES AND PCBS
Machado Lake is identified on the State’s 303(d) List of impaired water bodies as impaired due to Chlordane, Dieldrin, Chem A, DDT and PCBs in fish tissue25. The Machado Lake Pesticides and PCBs TMDL (Machado Lake Toxics TMDL) was issued by the Regional Board to address these impairments and became effective March 20, 2012. Polychlorinated Biphenyls (PCBs) and organochlorine pesticides belong to a broad group of synthetic chlorinated hydrocarbons. PCBs include up to 209 different chlorinated chemical compounds which are called congeners. Chlordane, Dieldrin and DDT are organochlorine pesticides that were widely used until the late 1970s and 1980s. Organochlorine pesticides and PCBs are highly lipophilic and will accumulate in the fatty tissues of exposed wildlife and bioaccumulate as they move through the food chain. Chem A (abbreviation for chemical group A) is a suite of bio-accumulative pesticides that includes chlordane and dieldrin. The 1998 303(d) listing (and subsequent listings) for Chem A was predominately based on fish tissue concentrations of chlordane and dieldrin while the other Chem A pollutants have not been detected in tissue in over 25 years. Therefore, the Machado Lake Toxics TMDL addresses the Chem A listing by establishing water quality, sediment and fish tissue targets for chlordane and dieldrin.
The Machado Lake Pesticide and PCBs TMDLs established numeric targets for pesticides and PCBs in water, sediment, and fish tissue to protect aquatic life, fishing, and other recreational uses in the lake.
The California Toxics Rule (CTR) criteria for human health (including protection for consumption of organisms) are the numeric targets for the water column, while the sediment numeric targets are based on the freshwater Threshold Effect Concentration guidelines compiled by NOAA, and the fish tissue targets are based on OEHHA Fish Contaminant Goals. Table 2-11 presents these water column, sediment, and fish tissue numeric targets for the Machado Lake organochlorine pesticides and PCBs.
Table 2-12: Machado Lake Toxics TMDL In-Lake Numeric Targets Pollutant Water Column Target
(ng/L)
Sediment Target
(μg/kg dry weight)
Fish Tissue Target
(ng/g wet weight)
Total PCBs 0.17 59.8 3.6
DDT (all congeners) 0.59* 4.16 No target
DDE (all congeners) 0.59* 3.16 No target
DDD (all congeners) 0.84 4.88 No target
Total DDT -- 5.28 21.0
Chlordane 0.59 3.24 5.6
Dieldrin 0.14 1.9 0.46
*Water column targets for 4,4’ DDT, 4,4’ DDE and 4,4’ DDD only Since September 2017, following completion of the Machado Lake Ecosystem Rehabilitation Project, water quality, sediment and fish tissue samples have been collected by City of Los Angeles in Machado Lake. Sediment grab samples collected in October 2017 showed non-detects for all constituents listed in Table 2-11. Results of in-lake water column monitoring conducted via grab sampling in March 2018 showed one exceedance of the CTR criteria for protection of human health for Total Chlordane (the calculated for Total Chlordane of 2ng/L was the result of the gamma-Chlordane analysis). Fish tissue grab and composite samples collected in May 2019 showed multiple exceedances of the OEHHA fish tissue targets for Total Chlordane and Total PCBs.
25 Machado Lake Pesticides and PCBs TMDL
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TRASH
Machado Lake is identified on the State’s 303(d) List of impaired water bodies due to trash26.
Consequently, the Regional Board issued the Machado Lake Trash TMDL, which became effective March 6, 2008. Existing beneficial uses impaired by trash in Machado Lake are Water Contact Recreation (REC1), Non-contact Water Recreation (REC-2), Warm Freshwater Habitat (WARM), Wildlife Habitat (WILD), Rare, Threatened, or Endangered Species (RARE), and Wetland Habitat (WET). Common items that have been observed in Machado Lake include styrofoam cups, styrofoam food containers, glass and plastic bottles, paper cartons, packaging materials, plastic bags, and cans. Heavier debris can be transported during storms as well. The numeric target for this TMDL is zero trash in Machado Lake and on the shoreline. The TMDL assigns limits on point sources of trash, such as discharges from the MS4, and nonpoint sources of trash, such as direct discharges from areas of Ken Malloy Harbor Regional Park adjacent to the lake such as parking lots, recreational, and picnic areas. Dischargers can comply with WLAs through structural trash capture devices installed in the storm drain system or through nonstructural source control BMPs.
2.2.3. GREATER LOS ANGELES HARBOR
The Peninsula WMG areas do not drain directly into the Greater Los Angeles Harbor. Drainage from the Peninsula EWMP area exits the cities of Rancho Palos Verdes and Rolling Hills Estates in an easterly or southeasterly direction via storm drains and becomes comingled with MS4 discharges from the City of LA.
The portion of the Peninsula EWMP area which contributes runoff to Greater Los Angeles Harbor consists of approximately 4.5 square miles, which is about 4.1% of the Dominguez Channel Watershed Management Area (approximately 109.4 sq. mi. total) that drains to the Los Angeles Harbor27. Specific Los Angeles Harbor water segments to which the Peninsula WMG contributes runoff include the Inner Harbor and Cabrillo Marina (Figure 2-6). These segments are listed on the State’s 303(d) list as impaired by copper, lead, zinc, Polycyclic Aromatic Hydrocarbons (PAH) compounds, DDT and PCBs. These impairments exist in the water, sediments and fish tissue within the Los Angeles Harbor waters. Fish consumption advisories also currently exist for DDT and PCBs in certain fish species in all of the Los Angeles Harbor waters.
The Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL (Harbor Toxics TMDL) was issued by the Regional Board to address the constituents causing water quality impairment and became effective on March 23, 2012. The applicable water quality objectives for this TMDL are narrative objectives for Chemical Constituents, Bioaccumulation, Pesticides, and Toxicity in the Basin Plan and the numeric water quality criteria promulgated in 40 CFR section 131.38 (the California Toxics Rule (CTR)). In addition, marine sediment targets were determined for the Dominguez Channel and Greater Los Angeles and Long Beach Harbor waters using the narrative standards of the Basin Plan, State Water Quality Control Plan for Enclosed Bays and Estuaries – Part 1 Sediment Quality (SQO Part 1) and the sediment quality guidelines recommended by the State Listing Policy28.
The following Table 2-12 provides the marine sediment targets for the Dominguez Channel and Greater Los Angeles and Long Beach Harbor waters applicable to the Peninsula WMG priority pollutants. 26 Machado Lake Trash TMDL
27 Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL 28 Long, ER, LJ Field and DD MacDonald. 1998. Predicting Toxicity in Marine Sediments with Numerical Sediment Quality Guidelines, Environ. Toxicol. Chem. 17:4, 714-727. MacDonald, DD, CG Ingersoll and TA Berger. 2000. Development and evaluation of consensus-based sediment quality guidelines for freshwater ecosystems. Arch. Environ. Contam. Toxicol. 39:20-31. 100
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Table 2-13: Greater Harbor Toxics TMDL Marine Sediment Targets Pollutant Marine Sediment Target
Copper 34 mg/kg
Lead 46.7 mg/kg
Zinc 150 mg/kg
Total PCBs 22.7 ug/kg
Total PAHs 4,022 ug/kg
Total DDT 1.58 ug/kg
The Harbor Toxics TMDL requires monitoring by the responsible parties under the Coordinated Compliance Monitoring and Reporting Plan29. The Coordinated Compliance Monitoring and Reporting program includes sampling for both water quality and sediment quality within 12 distinct water quality groups, each water quality group representing a water body within the greater harbor waters, as well as fish tissue sampling at four different locations (Figure 2-6).
In 2019, an assessment of bed sediment quality over a three-year averaging period in comparison with interim TMDL objectives provided in Attachment N Part E.2.a. of the 2012 LA MS4 Permit was performed under the Coordinated Compliance Monitoring Program. Most water bodies within the Greater Los Angeles Harbor were found to have met the interim three-year average concentration-based sediment objectives including the two water bodies to which stormwater from the Peninsula WMG is tributary:
Inner Los Angeles Harbor and Cabrillo Marina. Thus, there appears to have been no degradation in sediment quality in these two water bodies since adoption of the TMDL. In evaluating progress toward attainment of the final objectives, sediment quality in the Los Angeles Harbor was assessed using California’s Sediment Quality Objectives (SQO) for aquatic life benthic community based on multiple lines of evidence: sediment chemistry, sediment toxicity, and benthic community condition. Per this methodology, the qualitative sediment conditions of Unimpacted or Likely Unimpacted are protective of the benthic community. Based on the analysis incorporating monitoring events in 2013, 2016, and 2018, the Inner Los Angeles Harbor, including Cabrillo Marina, was determined to be Not Protective.
As shown in Table 2-13 receiving water data collected over the past four years in the two Greater Los Angeles Harbor water bodies to which the Peninsula WMG is tributary indicates that the CTR criteria for the protection of aquatic life is consistently exceeded for dissolved copper in the Cabrillo Marina while there have been some exceedances of the CTR criteria for dissolved copper as well total DDx in the Los Angeles Outer Harbor.
29 Anchor QEA. Coordinated Compliance Monitoring and Reporting Plan for the Greater Harbor Waters Regional Monitoring Coalition. August 2019.
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Table 2-14: Water Quality Exceedances in Greater Los Angeles Harbor Waters to which Peninsula WMG is Tributary
Total Water Quality Exceedances of CTR Aquatic Life Criteria/Total Samples Collected Between 2016 and 2020 Constituent Los Angeles Inner Harbor Cabrillo Marina
Copper (Dissolved) 8/51 8/10
Lead (Dissolved) 0/51 0
Zinc (Dissolved) 0/51 0
4.4’ - DDT 0/51 0
Total DDx 7/51 1/10
Total PCBs 3/51 0
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Figure 2-7: Greater LA Harbor Waters and Monitoring Stations 103
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2.3. SOURCE ASSESSMENT
The focus of this Source Assessment is on watershed sources contributing to the presence of pollutants in stormwater discharges conveyed through the MS4.
A source assessment was conducted with the initial development of the EWMP to identify potential sources in discharges to the MS4 and from the MS4 to receiving waters and other potential stressors related to MS4 discharges causing or contributing to the WBPCs classified as Category 1, 2, or 3. Per the MS4 Permit, the following available data and documents were considered in the identification of known and suspected sources of the Peninsula WMG’s priority pollutants:
● Findings from the Peninsula WMG’s Illicit Connections and Illicit Discharges Elimination Programs ● Findings from the Peninsula WMG’s Industrial/Commercial Facilities Control Programs ● Findings from the Peninsula WMG’s Development Construction Programs ● Findings from the Peninsula WMG’s Public Agency Activities Programs ● TMDL Implementation Plans
● TMDL Source Investigations
● Findings from MS4 Permittees’ monitoring programs
● Watershed model results
● Other pertinent data, information, or studies related to pollutant sources and conditions that contribute to the highest water quality priorities
● Locations of the Peninsula Agencies’ MS4s including, at a minimum, all major outfalls and major structural controls for stormwater and non-stormwater that discharge to receiving waters ● Other known and suspected sources of pollutants in non-stormwater or stormwater discharges from the MS4 to receiving waters within the EWMP area
This source assessment has been updated based on outfall monitoring data collected via the Coordinated Integrated Monitoring Program (CIMP) as well as updated information on potential watershed sources of priority pollutants.
2.3.1. WATERSHED SOURCES OF PRIORITY POLLUTANTS
There are two general categories of stormwater pollutant sources, point sources and non-point sources.
Non-point sources, by definition, include pollutants that reach receiving waters via routes other than a defined conveyance/point source and are not regulated by the MS4 Permit nor included in the reasonable assurance analysis. An example of such a non-point source could be trash deposited on the beach by recreational use which is then transported into the receiving water by wind or tide action. Point source discharges are regulated through NPDES permits and include stormwater and urban runoff (also referred to as non-stormwater discharges) through the MS4. Stormwater runoff in the watershed is regulated through one of several types of National Pollutant Discharge Elimination System (NPDES) permits, including MS4 permits, a statewide MS4 permit for Caltrans; a statewide Construction General Permit (CGP) for construction sites disturbing 1 acre or more of land; and a statewide Industrial General Permit (IGP).
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This section will first consider historical and current land uses in the Peninsula WMG watersheds, identify key pollutant fate and transport mechanisms characteristic of the watersheds, and then consider relevant point and non-point sources of priority pollutants that may be present in the watersheds based on land uses. This source assessment will help to shape appropriate pollutant control measures in subsequent chapters of this EWMP.
Potential sources of the priority pollutants in the watershed and potential fate and transport mechanisms that could cause these pollutants to reach the MS4 are summarized in Table 2-14. 105
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Table 2-15: Potential Watershed Sources of Palos Verdes Peninsula Priority Pollutants Potential Source Pollutants OC Pesticides PAHs Bacteria Nutrients Metals
TSS/Turbidity
Trash
WATERSHED SOURCES
Residential land areas ● ● ● ● ● ●
Agricultural activities (e.g., animal husbandry) ● ● ●
Construction activities ● ● ●
Landscaping, gardening ● ●
Pet waste ● ●
Wildlife ●
Native geology ● ●
Land surface erosion ● ● ●
Commercial activity ● ● ● ● ●
Car washing ● ●
Transportation sources (e.g., brake and tire wear) ● ● ● Pavement erosion ● ● ●
Sanitary sewer ● ●
FATE AND TRANSPORT MECHANISMS
Atmospheric Deposition ● ● ●
Wildfires ● ● ● ●
Resuspension in soil particles ● ● ●
Land surface erosion ● ● ● ● ●
Sanitary sewer overflows ● ● ●
● ●
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Watershed Land Uses
Understanding historical and current land uses in the watershed helps to identify potential sources of priority pollutants in stormwater runoff. Following the arrival of Europeans to the Los Angeles Basin, the lands of the Palos Verdes Peninsula were first used for cattle ranching and then later for dry farming of barley, hay, grain and garbanzo beans.30 Residential development on the Palos Verdes Peninsula began in 1913 when J.P. Morgan purchased 16,000 acres of ranch land, however major development was delayed until after World War I and thereafter growth of residential development proceeded at a modest pace until the 1950s when growth accelerated and then grew explosively during the 1960s. 31 Today the Palos Verdes Peninsula is effectively built-out and is dominated by single-family residential (55.6%) and open space (32.8%) land uses, limited multi-family residential (2.8%) and commercial areas (2.2%), and does not include any industrial land uses. There are also locations where horse uses exist in designated semi-rural residential areas of the Peninsula. There are no IGP facilities within the PVP EWMP area. Construction sites are by nature transitory pollutant sources and are subject to oversight by MS4 agencies through their issuance of building permits – the impact of construction sources of pollutants are indirectly incorporated into the CIMP monitoring data and therefore captured in the reasonable assurance modeling. Caltrans’ MS4 permit incorporates TMDL WLAs and as such it is assumed that Caltrans land uses will meet their WLAs individually and such areas have been excluded from the reasonable assurance modeling exercise.
A breakdown of land uses by watershed is shown in Table 2-15. Drainage within the Peninsula WMG area is conveyed via natural, soft-bottom canyons and engineered storm drain networks.
Table 2-16: Land Use Distribution within the Palos Verdes Peninsula Watersheds Watershed COM EDU OS OTHER OTHER (R) PUB MFR SFR
Dominguez Channel: Machado
Lake & Harbor Watersheds
3.10% 5.00% 18.40% 3.90% 1.40% 0.40% 2.90% 64.80%
Santa Monica Bay 1.60% 3.30% 41.20% 0.30% 0.00% 0.50% 2.70% 50.20% Total 2.20% 3.90% 32.80% 1.60% 0.50% 0.40% 2.80% 55.60% COM: Commercial
EDU: Educational facility
OS: Open space (i.e., park, recreational facility (i.e., stable, golf course), preserved land, and vacant) Other: Churches, cemetery
Other (R): Covered Reservoir
PUB: Public facility (i.e., fire, police, city hall)
MFR: Multi-family residential
SFR: Single-family residential
Note: A total of 0.2% are zoned as roads and are not included in this table. 30 Gales, Donald M. 1988. Handbook of Wildflowers, Weeds, Wildlife, and Weather of the South Bay and Palos Verdes Peninsula.
Third Edition.
31 Gales 1988.
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POLLUTANT FATE AND TRANSPORT MECHANISMS WITHIN THE WATERSHED Pollutant fate and transport mechanisms should also be considered in source characterization to the extent they contribute or reduce pollutant loading to receiving waters.
ROAD INFRASTRUCTURE
Roadways with curb and gutter are considered part of the MS4 system and as such serve to transport pollutants from the watershed to receiving waters. However, transportation activities on the roadways also generate pollutant. Pollutants originate from cars, roadway degradation, and landscaping along the roadways. Typical contaminants associated with these include sediment, heavy metals, oils and grease, debris, fertilizers, and pesticides, among others32. The use and wear of cars is one of the most prevalent sources of roadway pollutants. Vehicle brake pads constitute the single largest source of copper33. Tires and engine parts are also a source of metals pollutants—tire wear accounts for over 50 percent of the total cadmium and zinc loads in urban runoff34. Roadways can also be a source of nutrients from atmospheric deposition of nitrogen and from fertilizers and pesticides used during parkway landscaping activities.
ATMOSPHERIC DEPOSITION
Atmospheric (or air) deposition is the transfer of pollutants from air to land. Pollutants in the atmosphere deposit onto solid surfaces and are then washed off by rain, becoming entrained in the stormwater runoff that reaches receiving waters. Atmospheric deposition of pollutants to developed and undeveloped surfaces in the watershed can be a major source of pollutants, especially in major metropolitan areas.
Typical pollutants associated with atmospheric deposition are metals, PAHs, PCBs, and nitrogen. These pollutants enter the atmosphere from point sources (i.e., an industrial facility emitting metals and PAHs into the air) and mobile sources such as trucks and automobiles.
WILDFIRES
The Palos Verdes Peninsula is in a very high fire hazard severity zone and, when they occur, wildfires can mobilize pollutants and thereby increase stormwater pollutant loading due to several factors including:
increased runoff associated with soil hydrophobicity which results from fire, increased mobility of contaminants from soil, release of previously bound contaminants in vegetation, and higher erosion rates.
Total suspended solids (TSS) concentrations in stormwater runoff often increase by orders of magnitude in post-fire systems thereby increasing the transport of particulate bound pollutants. Combustion of plants and natural materials has also been reported to release metals which are then mobilized by storms.35
Southern California Coastal Water Research Project (SCCWRP) conducted a study comparing post-fire stormwater runoff data from five wildfires in natural open space between 2003 and 2009 in comparison 32 Caltrans (California Department of Transportation). 2003. Discharge characterization study report. California Department of Transportation, Sacramento, CA.
33 TDC Environmental 2004, Copper Sources in Urban and Shoreline Activities. San Francisco, CA. 34Davis A.P., M. Shokouhian, and S. Ni. 2001. Loading estimates of lead, copper, cadmium, and zinc in urban runoff from specific sources. Chemosphere.
35 Burke, M.P., T.S. Hogue, A. Kinoshita, J. Barco, C. Wessel, E.D. Stein 2013. Environmental Monitoring and Assessment 185:10131–10145. Pre- and post-fire pollutant loads in an urban fringe watershed in Southern California. 108
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with stormwater runoff data from sixteen unburned natural areas and six developed areas. The study found average copper, lead and zinc fluxes were hundreds of times higher from burned areas than unburned areas.36 Even more striking, the flux of PAHs from natural burned areas was four times greater than from adjacent unburned urban areas. Ash fallout on unburned watersheds produced three times greater flux of PAHs and metals. Prior to the wildfires, most of the burned areas were dominated by sage scrub [similar to natural plant communities on the Palos Verdes Peninsula], or chaparral plant communities. It is also notable that the study did not address potential toxic effects from flame retardants commonly used in combatting wildfires.37
SCCWRP conducted a more recent study of the 2009 Station Fire which consumed 660 square kilometers of the Angeles National Forest. Much of the area had not burned in over 60 years which meant there was a potentially large store of anthropogenic lead contamination resident in vegetation and soil due to air deposition during the time that lead additives were still used in gasoline. Stormwater quality sampling was conducted from four storm events post-fire at two-hour intervals for a total of 54 grab samples. These results were compared with 131 grab samples from four storm events during the storm year preceding the Station Fire. Post-fire peak stormwater flows during two of the storm events post-fire were 15 and 17 times the largest storm during the preceding pre-fire year and yet these post-fire peak flows were produced with only 80% and 65% of the pre-fire storm precipitation depth. The sediment volume delivered during the post-fire storm year was ten times the total volume deposited in the preceding fifteen years at Devil’s Gate Reservoir. Mean seasonal total suspended solids concentration in stormwater increased 100-fold following the fire. Median concentrations of lead increased by more than 100 times the magnitude post-fire, while median concentrations of zinc increased by 10 times, and copper by 9 times. Although the burned watershed monitored in this study was largely undeveloped, the concentrations of metals measured were in the range of concentrations typically measured from highway drainage, industrial areas and mining operations.38
NATURAL CANYON DRAINAGE SYSTEMS
On the Palos Verdes Peninsula the improved MS4 is interconnected with natural canyon drainage courses that naturally detain and retain runoff, effectively serving as nature-based stormwater retention systems.
Intense rain events can cause erosion in the natural canyons and increase transport of sediments and mobilize storm-borne sediment pollutants; for this reason, it is important to protect these canyons from hydromodification. Overall, these natural canyon drainage courses serve to attenuate pollutants and reduce stormwater pollutant loading to receiving waters. The reasonable assurance model has been calibrated against storm flow data from the CIMP monitoring to more accurately reflect the storm runoff reduction provided by these natural canyon systems.
ORGANOCHLORINE PESTICIDES
Organochlorine pesticides (OC pesticides) are a large group of legacy pesticides, including chlordane, dieldrin, and DDT, that were previously used widely throughout the United States. Even though they have been banned from use for many years, they are slow to degrade and continue to persist in the 36 SCCWRP 2012. ED Stein, JS Brown, TS Hogue, MP Burke, A Kinoshita. pp. 11-28 in: Stephen Weisberg and Karlene Miller (eds.), Southern California Coastal Water Research Project 2012 Annual Report. Southern California Coastal Water Research Project.
Costa Mesa, CA.
37 SCCWRP 2012.
38 Burke et al. 2013.
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environment. Because of their chemical and physical properties these pollutants tend to partition and bind preferentially to the surfaces of soil particles. When transported in stormwater-borne sediment to local receiving waters, OC pesticides have been shown to accumulate in the fatty tissue of fish and wildlife and bio-magnify in the food-web. Soils historically treated with DDT and chlordane continue to be a source of pollutants in the storm-borne sediment discharges from the MS4 on the Palos Verdes Peninsula as evidenced by the recent CIMP monitoring results discussed in the next section.
DDT
The history of DDT use was summarized in the staff report to the Machado Lake Toxics TMDL as follows:
“DDT first became widely used as a pesticide in 1939; the use was focused on controlling insects that transmit diseases such as malaria and typhus during World War II. DDT for agricultural and commercial uses became widespread in the United States after 1945. 1959 was the peak of DDT use in the United States when approximately 80 million pounds were applied. In California, DDT was used for the control of both agricultural and urban pests like mosquitoes and cockroaches. In 1963, the California Department of Food and Agriculture declared DDT a restricted material. The last year that substantial amounts of DDT were applied in California was 1970 when 1.2 million pounds of DDT were applied primarily to agricultural areas.”39
Considering the ubiquitous use of DDT from 1939 through 1970 and understanding the history of land use and development on the Palos Verdes Peninsula, it is reasonable to expect that DDT was used in residential applications and that DDT and its breakdown products, DDE and DDD may remain in soils within the Palos Verdes Peninsula.
CHLORDANE
The history of chlordane use was summarized in the staff report to the Machado Lake Toxics TMDL as follows:
“Chlordane was first registered and approved for both agricultural and non-agricultural uses in the United States in 1948. Non-agricultural uses of chlordane included treating pests in residential lawns and gardens as well as structural pests such as termites.
Chlordane was used on a variety of agricultural crops including corn, citrus, deciduous fruits and nuts, and vegetables. In 1978, the U.S. EPA cancelled the use of chlordane on all food crops and for applications to lawns and gardens, although it was still registered for use in termite control. In 1988, the U.S. EPA cancelled all uses for chlordane.”40 Due to the widespread use of chlordane on residential lawns and gardens, it is reasonable to expect that chlordane may remain in soils within the watershed.
DIELDRIN
The history of dieldrin use was summarized in the staff report to the Machado Lake Toxics TMDL as follows:
39 Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010, page 13. 40 Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010, page 15 110
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Dieldrin was widely used from 1950 – 1970 as a structural pesticide for the control of termites and as an agricultural pesticide for cotton, corn, and citrus crops. The agricultural use of dieldrin was banned by the US Department of Agriculture in 1970 and in 1987 all uses of dieldrin were cancelled.41
Historical agricultural land uses on the Palos Verdes Peninsula are not known to include cotton, corn or citrus crops. Since the use of dieldrin in residential areas was mainly as a structural termiticide and was not widely applied in lawns and gardens, it is less likely that dieldrin will be present in soils. If present, dieldrin would exhibit similar fate and transport properties as chlordane and DDT, i.e., it would partition on storm-borne sediment. As discussed in the next section, to-date dieldrin has not been detected in storm borne sediment of the CIMP outfall monitoring.
POLYCHLORINATED BIPHENYLS (PCBS)
Polychlorinated biphenyls (PCBs) are mixtures of synthetic organic chemicals that were commonly used for various applications from approximately 1929 until 1979 when the U.S. banned PCB manufacturing, processing, distribution, and use. PCBs may be present in products that were made before 1977 but are still in use today, such as transformers, fluorescent lighting fixtures, household caulking, paints and waxes42.
U.S. EPA identifies the following list of products and materials that if produced and installed prior to the 1979 ban may still contain PCBs:43
● Transformers and capacitors
● Electrical equipment including voltage regulators, switches, re-closers, bushings, and electromagnets
● Oil used in motors and hydraulic systems
● Old electrical devices or appliances containing PCB capacitors ● Fluorescent light ballasts
● Cable insulation
● Thermal insulation material including fiberglass, felt, foam and cork ● Adhesives and tapes
● Oil-based paint
● Caulking
● Plastics
● Carbonless copy paper
● Floor finish
Considering the predominantly residential nature of development on the Palos Verdes Peninsula and the limited industrial sources, either current or in the past, presence of PCBs in exposure to stormwater is most likely limited to external building materials such as caulk or paint or in utility transformers or residuals in soils associated with spills from ruptured utility transformers.
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
41 Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010, page 15 42 USEPA: Santa Monica Bay DDT and PCBs TMDL 43 https://www.epa.gov/pcbs/learn-about-polychlorinated-biphenyls-pcbs#commercial 111
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Polycyclic aromatic hydrocarbons (PAHs) are a group of organic contaminants that are associated with the release of petroleum products (petrogenic sources) or form from the incomplete combustion of hydrocarbons (pyrogenic sources). PAHs are an environmental concern because they are toxic to aquatic life and because several of the individual PAH compounds are suspected human carcinogens. Research has shown that the dominant source of origin is pyrogenic (combustion of organic matter) in the Los Angeles Region, and PAHs are often deposited through atmospheric deposition and delivered to waterbodies in stormwater runoff44. Other non-point sources may include leaking motor oil, tire wear and vehicular exhaust.
METALS
General wear and tear of automotive parts can be a source of metals. For example, brake wear and tire wear can release copper, lead, and zinc into the environment and contribute concentrations of metals to roads and in turn stormwater runoff. Motor oil and automotive coolant spills are another potential source of metals. One study found that cars are the leading source of metal loads in stormwater, producing over 50 percent of copper, cadmium, and zinc loads45.
Table 2-17: Automotive Sources of Metals in Stormwater46 Source Cadmium Chromium Copper Iron Nickel Lead Zinc
Gasoline ● ● ● ●
Exhaust ● ●
Motor oil and grease ● ● ● ●
Antifreeze ● ● ● ● ● ●
Undercoating ● ●
Brake Linings ● ● ● ● ●
Tires ● ● ● ●
Asphalt ● ● ● ●
Concrete ● ● ●
Diesel Oil ● ● ● ●
Engine wear ● ● ● ●
Fertilizers, herbicides, and pesticides used for lawn and landscape maintenance can contain metals such as cadmium, copper, mercury, zinc, lead, iron, and manganese47. Algaecides, wood preservatives, galvanized metals, and paints when used in exposure to stormwater can also be a source of these metals.
ARSENIC
44 Sabin, L.D., K.A. Maruya, W. Lao, D. Diehl, D. Tsukada, K.D. Stolzenbach, and K.C. Schiff 2009. Exchange of Polycyclic Aromatic Hydrocarbons among the Atmosphere, Water, and Sediment in Coastal Embayments of Southern California, U.S.A. Environmental Toxicology and Chemistry, Vol. 29, No. 2, pp. 265-274. 45 Schueler, T., and H.K. Holland. 2000. The Practice of Watershed Protection. Center for Watershed Protection, Ellicott City. 46 Nixon, H., and J.D. Saphores. 2007. Impacts of motor vehicle operation on water quality: Clean-up costs and policies. Transportation Research Part D. Transport and Environment. 47 County of Los Angeles. 2010. Multi-pollutant TMDL Implementation Plan for the Unincorporated County Area of Los Angeles River Watershed. County of Los Angeles, Los Angeles, CA 112
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Arsenic is a natural component of the Earth's crust and low levels of the element are found in all environmental media. Anthropogenic sources of arsenic include nonferrous metal mining and smelting, pesticide application, coal and oil combustion, wood combustion, and waste incineration. Most anthropogenic arsenic is emitted to the atmosphere through high temperature processes (e.g., coal and oil combustion, smelting operations, and waste incineration) and occurs as fine particles which are transported by wind and air currents until they are returned to earth by wet or dry deposition.48 Arsenic found in soil, either naturally occurring or from anthropogenic releases, forms insoluble complexes with iron, aluminum, and magnesium oxides found in soil surfaces, and is relatively immobile.
However, under reducing conditions, arsenic can be released from the solid phase, resulting in soluble mobile forms of arsenic, which may potentially leach into groundwater or result in runoff of arsenic into surface waters. Arsenic is largely immobile in agricultural soils; therefore, it tends to concentrate and remain in upper soil layers indefinitely. Terrestrial plants may accumulate arsenic by root uptake from the soil or by absorption of airborne arsenic deposited on the leaves.49 Arsenic can also leach from wood treated with chromated copper arsenate (CCA). Ammoniacal copper zinc arsenate (ACZA) is another arsenic-containing waterborne preservative, though not as widely used as CCA.
Based on current and historical land use, potential sources of arsenic within the Palos Verdes Peninsula watersheds may include air deposition and residuals in soils from pesticide application, with very minor contributions from leaching of wood used in landscaping or exterior building materials exposed to stormwater that have been treated with arsenate-type wood preservatives. Arsenic present in stormwater discharges would be expected to be associated primarily with storm-borne sediments.
COPPER
Research beginning in the 1990s to address copper impairment of lower South San Francisco Bay has provided a wealth of information on sources of copper releases to stormwater from urban and suburban areas. A study prepared by TDC Environmental in 2004 of copper sources in urban and stormwater runoff to San Francisco Bay identified vehicle brake pads, followed by atmospheric deposition, architectural copper, industrial use, potable water discharged to storm drains, soil erosion and copper algaecides, in order of significance.50 Other studies from other parts of the U.S. and internationally have also contributed to the body of evidence for the importance of these sources in stormwater runoff from developed areas.
The relative importance of copper sources depends on land use within a watershed as well as proximity to nearby air pollution sources.
Sources of copper in deposits from air pollution can be a result of combustion of vehicle or stationary source fuels, including wood burning. TDC Environmental estimated comparable emission rates of copper from industrial air emissions and emissions from fires (both residential wood burning and forest fires). Air pollution may convey copper from local sources or air emission sources outside the immediate area that are then deposited in a watershed, either via dry air deposition or wet air deposition during rainfall. In 2006 a study of atmospheric dry deposition of metals was conducted at six urban sites and one nonurban site within the coastal region of the Los Angeles air basin. Mean flux of copper at the urban sites ranged from 11 to 34 micrograms per square meter per day whereas the flux of copper at the non-urban Malibu 48 https://www.atsdr.cdc.gov/toxprofiles/tp2-c6.pdf 49 https://www.atsdr.cdc.gov/toxprofiles/tp2-c6.pdf 50 TDC Environmental, 2004. Copper Sources in Urban Runoff and Shoreline Activities – Information Update. Prepared for the Clean Estuary Partnership. November 2004.
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Creek Watershed site was 3.7 micrograms per square meter per day—the Malibu Creek watershed is generally upwind of the Los Angeles metropolitan area which further removes it from urban influence. 51 Architectural copper if left uncoated will develop a patina of copper oxides which are water soluble. The amount of copper washed off architectural features is proportional to the surface area, so copper roofs provide the greatest surface area, with gutters and flashing providing a lesser surface area.52 Trace levels of copper may occur naturally in soils or be present because of application of coppercontaining pesticides. The TDC Environmental study estimated an average value of 38.57 mg Cu/kg soil based on data from the State Water Resources Control Board’s construction stormwater database for the San Francisco Bay area. Copper-containing pesticides are widely used to control fungi, mildew, algae and roots. Common applications include control of roots in sewers, controlling algae in swimming pools and ponds, and preventing rot and mildew on wood, roofing and other outdoor surfaces. Copper is also used in lawn and garden fungicides.53
Copper in the potable water supply may arise from the raw water supply, from algaecides used to control algae in reservoirs, or by dissolution from copper pipes.54 Potable water may flow into the storm drain system due to runoff from outdoor irrigation, hydrant flushing, and other sources of outdoor water use such as car washing or patio cleaning.
Antifouling hull paints or coatings are applied to marine vessels to prevent the attachment and growth of “fouling organisms” such as barnacles, oysters, mussels, shipworms, or algae that attach to boat hulls.
Copper has been a standard biocide in anti-fouling hull paints for many decades, and copper- based antifouling hull paints are currently the most commonly used antifouling coating. Copper in hull paint can slowly leach into the water column and be released from the hull as particles that fall to the bed sediments, causing impairment55. There are no marinas or boat maintenance facilities within the Peninsula WMG watersheds, however it is noteworthy that Cabrillo Marina in Los Angeles Harbor exhibits ongoing elevated dissolved copper concentrations as discussed in Section 2.2.3.
Based on the preceding discussion of major sources of copper and understanding of current and past land uses on the Palos Verdes Peninsula, potential sources of copper in stormwater discharges from the watershed may include releases from vehicle brake pads, use of algaecides in pools or fountains, pesticide application in landscapes, and air deposition.
LEAD SOURCES
Potential sources of lead to the watershed may include historical and current air deposition of lead from leaded gasoline used historically in automobiles and currently in general aviation fuel, lead wheel weights on vehicles, and lead in paint on buildings constructed prior to 1977. Beginning in November 1973 U.S.
EPA began requiring the phase out of lead in all grades of gasoline—at the time the average lead content in gasoline was 2-3 grams per gallon amounting to 200,000 tons of lead emissions per year in the U.S. By 1995 leaded fuel accounted for only 0.6 percent of total gasoline sales and less than 2,000 tons of lead 51 Sabin, L.D., J.H. Lim, K.D. Stolzenbach and K.C. Schiff, 2006. Atmospheric Dry Deposition of Trace Metals in the Coastal Region of Los Angeles, California, U.S.A. Environ Toxicol Chem. 2006 Sep;25(9)2334-41. 52 TDC Environmental 2004. 53 TDC Environmental 2004.
54 TDC Environmental 2004.
55 Metz, V. and Gregg, J. Boat Hull Coating Selection and Hull Cleaning for Water Pollution Prevention: Water Quality Factsheet for Marina Operators and Boaters. Water Quality Program, California Coastal Commission. (2017). 114
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emissions per year. Effective January 1, 1996, the Clean Air Act banned the sale of leaded fuel in on-road vehicles.56 The nearby Torrance Airport located just north of the Palos Verdes Peninsula is a general aviation airfield and a potential source of air deposition of lead within the Palos Verdes Peninsula watershed due to the use of leaded avgas fuel in piston engine aircraft.
A 2009 study by Sabin found that the mean flux of lead due to air deposition at urban sites in the Los Angeles basin ranged from 8.3 to 29 micrograms per square meter per day, whereas the flux at the nonurban site in Malibu Creek Watershed was 1.4 micrograms per square meter per day.A significant drop in concentration of lead was observed in the study by Sabin when compared with the study done 15 years earlier in 1987—this was attributed to the elimination of lead from gasoline in the late 1980s.57 Aviation gasoline for piston airplanes, known as avgas, still includes lead additives and is widely used for general aviation aircraft thus continuing to be a source of lead in air deposition. Jet aircraft and turbine-powered propeller aircraft do not use avgas. Efforts to develop an operationally safe and suitable replacement for the leaded additive in avgas have been underway for over a decade. 58 According to the California Department of Toxic Substances Control (DTSC), prior to 2010 approximately
1.6 million pounds of lead wheel weights fell from vehicles each year onto roadways. Roadway traffic pulverizes lead wheel weights into dust which then contaminates the air and washes into storm drains.
As of January 1, 2010, California law prohibits the manufacture, sale or installation of wheel weights containing more than 0.1% lead.59
In 1977 the U.S. Consumer Product Safety Commission effectively banned lead in paint in residential properties and buildings by limiting the allowable concentration to 0.06 percent.60 Deteriorating or improperly abated lead paint in older buildings can endanger human health, especially that of children, and may cause release of lead to the environment, including stormwater.
MERCURY
According to USEPA, on a global level, gold mining is the largest source of anthropogenic mercury emissions, followed by stationary combustion of coal, non-ferrous metals production and cement production.61 No gold mining or non-ferrous metals industrial sources are known to have existed on the Palos Verdes Peninsula with the exception of a former cement mixing facility located on the site of the former Chandler sand and gravel quarry. Thus, the predominant sources of mercury that might be encountered on the Palos Verdes Peninsula are mercury deposited as a result of air deposition or improper disposal of mercury-containing consumer products. USEPA maintains a website with information on products that contain mercury.62
ZINC
A study was commissioned by the California Stormwater Quality Association (CASQA) to identify major and minor sources of zinc as a water pollutant and to assist MS4 Permittees in focusing source control measures in a cost-effective manner. The two major sources of zinc in urban runoff identified by the study 56 https://archive.epa.gov/epa/aboutepa/epa-takes-final-step-phaseout-leaded-gasoline.html 57 Sabin et al. 2006. 58 Federal Aviation Administration 2013. Fact Sheet – Leaded Aviation Fuel and the Environment. June 19, 2013. 59 http://www.dtsc.ca.gov/PollutionPrevention/ToxicsInProducts/leadwheelweights.cfm 60 https://www.cpsc.gov/Recalls/1977/cpsc-announces-final-ban-on-lead-containing-paint 61 https://www.epa.gov/international-cooperation/mercury-emissions-global-context#types 62 https://www.epa.gov/mercury/resources-mercury-science-and-research 115
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were outdoor surfaces treated with zinc (especially galvanized steel surfaces) and tire wear debris. Other local sources depending on land use may include zinc-containing paint, recycled tire shred and crumb products, industrial air emissions, zinc-rich soils, and mining. Minor sources of zinc in urban runoff include vehicle brake pads, wheel weights, vehicle exhaust, zinc-preserved wood, and certain types of roofing and siding materials. 63
Galvanized steel has long been used as a cost-effective material for outdoor applications such as: roofing, gutters, flashing, drainage pipe, and chain-link fencing. Zinc sheet has drawn recent interest in the design community for its appearance and longevity as a building roofing material and use as siding for commercial and institutional buildings. A body of literature since the late 1980s has documented relatively high concentrations of zinc in runoff from outdoor zinc surfaces, and consistent with this occurrence, zinc concentrations are typically highest in urban runoff from industrial land uses. The amount of zinc washed off outdoor surfaces is directly proportional to the exposed surface area. Other factors include the quality of zinc material and the presence of temporary or permanent coatings over the zinc surface. Galvanized wire fencing has surprisingly large surface area, for example a 6-foot-high industrial gauge (6-gauge) chain link fence has a surface area of 2.2 square meters per meter of length.64 The presence of coatings over the zinc surface reduces or substantially eliminates exposure to weather depending on the permanence of the coating—temporary passivation coatings reduce zinc losses for several years but eventually wash away, whereas painted zinc surfaces nearly eliminate zinc in runoff. Location is also important because when large zinc surfaces like galvanized chain-link fencing are sited over permeable surfaces in the landscaped buffers between properties, infiltration of runoff into a soil drip zone substantially reduces zinc levels in runoff.65
Nearly all rubber products, including tires, contain zinc oxide which is used to accelerate the vulcanization process. “According to the International Zinc Association, zinc oxide improves tire wear abrasion performance, protects against ultraviolet radiation, reduces thermal effects caused by internal friction, helps bond rubber to metal (such as the steel cord of tires), reduces rubber shrinkage during curing, and helps keep product molds clean.”66 In the U.S., the main outdoor use for rubber is in vehicle tires.
Tires also comprise the majority of California’s rubber waste and through strong efforts by CalRecycle, about half of waste tire material is reused within the state. Reuse applications for waste tires that have the potential to disperse zinc into the environment include combustion as tire-derived fuel, tire retreads, and tire shred and crumb products such as those used in artificial turf infill and rubberized asphalt.67 There are no facilities permitted to use tire-derived fuel for combustion within the Los Angeles area.68 Tire wear from on-road vehicles is expected to be the predominant source of zinc within the watershed.
To the extent that rubberized asphalt paving is used for road resurfacing within the watershed, there may be contributions of zinc from this use as well. There is limited information currently available on the significance of rubberized asphalt as a source of zinc in stormwater runoff. 63 TDC Environmental, 2015. Zinc Sources in California Urban Runoff prepared for California Stormwater Quality Association. April 2015.
64 Golding 2006. A Survey of Zinc Concentrations in Industrial Stormwater Runoff. Washington State Department of Ecology, Environmental Assessment Program. Publication No. 06-03-009. 65 Blok 2005. Blok, J. (2005). "Environmental Exposure of Road Borders to Zinc." The Science of the Total Environment 348(1-3):
173-190. 66 TDC Environmental, 2015. 67 TDC Environmental, 2015. 68 California Air Resources Board, 2015. 2015 Report on Air Emissions from Facilities Burning Waste Tires in California. June 2015. 116
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Air deposition of zinc can also be important. The 2006 study by Sabin found that the mean flux of zinc due to air deposition at urban sites in the Los Angeles basin ranged from 69 to 228 micrograms per square meter per day whereas zinc flux at the non-urban Malibu Creek Watershed site was 15 micrograms per square meter per day.69
Typical California soils have a mean zinc concentration of 149 mg/kg, with few soil types exceeding 200 mg/kg. However, a few soil formations (e.g., the Bedford Canyon formation and fresh carbon-rich portions of the Monterey formation) have much higher zinc levels in excess of 300 mg/kg. High-zinc soils may increase zinc levels in urban runoff and creeks where these soils are exposed.70 Since the marine sediment target for zinc in the Harbor Toxics TMDL is set at 150 mg/kg in sediment, discharge of suspended sediment associated with soils exhibiting zinc concentrations only slightly above the mean soil concentration in California could cause exceedance of the target even without loading from additional sources.
BACTERIA
Sources of indicator bacteria potentially present in the Peninsula WMG’s watersheds based on land uses include both anthropogenic and non-anthropogenic sources such as:
● Animal wastes – horses, dogs, cats, etc.
● Gardening activities - application of animal manure that has not been fully composted to gardens and landscapes are a source of bacteria
● Organic food waste from commercial activities when dumpsters are left uncovered in exposure to stormwater, or subject to scattering by vectors such as seagulls, pigeons, rats, and racoons ● Illegal dumping from recreational vehicle/vessel holding tanks among others, can be a source of elevated levels of total coliform bacteria
● Sanitary sewer overflows, leaks and/or illicit connections of sanitary lines to the storm drain system
● Illegal connections and discharges are also possible sources of bacteria in stormwater discharge ● Open defecation associated with recreational activities or people without housing ● Non-anthropogenic sources of indicator bacteria include – soils, decaying vegetation, wildlife such as birds, opossums, raccoons, etc.
Sanitary sewer systems and septic systems are potential sources of contaminants. Cracks in aging sewer laterals and mainlines, root intrusion and fats/oils/grease clogs can contribute to sanitary sewer leaks and overflows. When sanitary sewers overflow or leak, they can release raw sewage into the environment.
Raw sewage contains high concentrations of indicator bacteria and nutrients and may also contain other pollutants such as suspended solids, pathogenic organisms, toxic pollutants, oil and grease.
NUTRIENTS
69 Sabin et al. 2006.
70 TDC Environmental, 2015.
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Possible sources of nutrients include runoff from residential and commercial areas associated with landscaping activities and use of fertilizer for lawns and gardens, including organic fertilizer such as compost or manure. Maintenance activities such as washing cars, parking lots and driveways can contribute nutrients to the watershed since some detergents contain phosphorus. Other sources of nutrients include food wastes and domestic animal wastes in exposure to stormwater, or occasional sewer overflows. Key sources of nutrients identified in the Palos Verdes Peninsula Nutrient Implementation Plan71 were fertilizer applied to turf and landscapes, horse manure, and dry air deposition of nitrogen:
● Manure - Within the portion of the Palos Verdes Peninsula that drains to Machado Lake equestrian activities and horse keeping are common. Horse manure can be a source of nutrients in runoff. The average 1,000-pound animal produces over 102 pounds of total nitrogen and 18.8 pounds of total phosphorous per year72. Information from the Model Equestrian Center Project provides support for the understanding that equestrian centers are a source of nutrients in stormwater runoff.
● Numerous reports document the linkages between excess nutrients in local water bodies and the augmentation of naturally occurring soil nutrients with nitrogen and phosphorus applied in commercial fertilizers, whether organic or synthetic. The desire for green turf and the use of tropical or exotic plants may lead to the overuse or the misapplication of nitrogen and phosphorus fertilizers. Because single-family residences are the predominant land use within the Palos Verdes Peninsula, the application of fertilizer to residential landscapes and to a lesser extent commercial landscapes, ball fields and parks are potential sources of nutrients. The excess nutrients accumulated in the soils can be transported to waterways through excessive irrigation or stormwater runoff.
● Air deposition of nitrogen due to air pollution, particularly onto impervious surfaces where it can be readily washed into storm drains is a known source of nitrogen, the predominate species being NHO3 (nitric acid), NO2 (nitrogen dioxide) and NH3 (ammonia)73.
TRASH
Statewide and local studies have documented the presence of trash in state waters and the accumulation of land-based trash in the ocean. Trash discarded on land may be transported through storm drains to waterways, shorelines, and the ocean. Street and storm drain trash studies conducted in regions across California have provided insight into the composition and quantity of trash that flows from urban streets into the storm drain system and out to adjacent waters.74 The major source of trash results from litter that is intentionally or accidentally released/deposited onto roadways or other land uses in the watershed by human activity or animal vectors. Transport mechanisms which cause the litter to reach the storm drain system include wind action, dispersion by vectors and movement with surface runoff during storm events.
The Statewide Trash Amendments identify certain priority land uses that have been shown in multiple studies to have high trash generation rates, specifically these include high-density residential land uses 71 Palos Verdes Peninsula Subwatershed Coordinated Implementation Plan in Compliance with the Machado Lake Eutrophic, Algae, Ammonia and Odors (Nutrient) TMDL, March 11, 2011. 72 Wheeler and Zajaczkowski. Horse Stable Manure Management, Publication G-97. Penn State College of Agricultural Sciences Cooperative Extension, Agricultural and Biological Engineering 73 Palos Verdes Peninsula Subwatershed Coordinated Implementation Plan. 2011. 74 SWRCB Resolution 2015-0019. Amendment to the Water quality Control Plan for Ocean Waters of California to Control Trash and Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays and Estuaries of California. 118
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with at least ten developed dwelling units per acre, industrial land uses, commercial land uses, mixed urban land uses, and public transportation stations.75
2.3.2. CHARACTERIZATION OF STORMWATER AND NON-STORMWATER
DISCHARGE QUALITY
The Peninsula WMG began conducting outfall monitoring consistent with the CIMP beginning in 2016.
The outfall monitoring program includes:
Outfall Monitoring: Stormwater outfall water quality and flow monitoring is conducted at six (6) locations during three (3) wet weather events per year. Two (2) of these outfall monitoring locations (SD-1 and SD-2) are used to evaluate stormwater discharges from the Palos Verdes Peninsula to the Santa Monica Bay. Four (4) outfall monitoring locations (Rolling Hills Estates (RHE) City Hall, Lariat, Solano, and Valmonte) are used to evaluate stormwater discharges from the Palos Verdes Peninsula to the Dominguez Channel Watershed, including the Wilmington Drain, Machado Lake and the Greater Los Angeles Harbor surface waterbodies. The CIMP outfall data also includes continuous flow monitoring and monthly grab samples for Total Nitrogen and Total Phosphorus in two (2) of the afore mentioned outfall locations with baseline flows to quantify discharges of nutrients from the Palos Verdes Peninsula to Machado Lake and assess attainment of the Machado Lake Nutrient TMDL targets.
Non-stormwater Outfall Monitoring: Periodic storm drain screening and monitoring is also conducted to assess whether there are significant dry weather discharges from the storm drains on the Palos Verdes Peninsula that need to be added to the monitoring program.
Since the initial development of the EWMP, four complete years of outfall monitoring data have been collected and validated and are available for use in this characterization and, importantly, for calibration of the model supporting the reasonable assurance analysis.
Trends in this data are summarized in the following subsection for purposes of updating the source assessment for the following Peninsula WMG Category 1 and 2 priority pollutants: organochlorine pesticides (chlordane, DDT and its breakdown products DDE and DDD, dieldrin), PCBs, polycyclic aromatic hydrocarbons (PAHs), metals (arsenic, copper, lead, mercury, zinc), nutrients (nitrogen, phosphorus), fecal indicator bacteria, and trash.
The following summarizes findings and trends in this stormwater discharge quality from the four completed monitoring years between July 2016 and June 2020.
ORGANOCHLORINE PESTICIDES AND POLYCHLORINATED BIPHENYLS (PCBS) Stormwater outfall monitoring for bioaccumulative organochlorine pesticides and PCBs is conducted by filtering the sediment fraction from stormwater samples at each of the outfall monitoring sites (two outfalls tributary to Santa Monica Bay and four outfalls tributary to Machado Lake). Sediment samples filtered from each storm event are archived and composited by site for the entire storm year (at least 75 SWRCB Final Staff Report for Amendment to the Water Quality Control Plan for Ocean Waters of California to Control Trash and Part 1 Trash Provisions for Inland Surface Waters, Enclosed Bays, and Estuaries of California. 119
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three sample events) to accumulate sufficient sample to analyze all the required organochlorine pesticides as well as PCBs.
For the Santa Monica Bay DDT and PCBs TMDL, waste load allocations (WLAs) set by the USEPA to attain fish tissue concentration limits for human consumption are based on the calculated three-year average mass of DDT and PCBs discharged from the Santa Monica Bay watershed area of the Peninsula assigned as a percentage of the total mass based WLA for the entire Santa Monica Bay Watershed. In order to estimate stormwater loading of DDT and PCBs to the Santa Monica Bay during TMDL development, a study by Curren et al. (2011) was used along with data collected by the City of Los Angeles between 2007 and 2010. Estimated stormwater loads from Santa Monica Bay watersheds were found to be lower than TMDL calculated allowable waste loads necessary to achieve sediment targets; therefore, the WLAs in the TMDL for DDT and PCBs are based on existing MS4 loading estimates, and MS4 dischargers are essentially in an anti-degradation condition76. Table 2-17 demonstrates that the rolling three-year average Santa Monica Bay outfall monitoring results meet the assigned WLAs for both DDT and PCBs, consequently RAA modeling is not necessary for this water body pollutant combination.
Table 2-18: Santa Monica Bay DDT & PCBs 3-Year Rolling Average Outfall Data 3-Year Period Monitoring Station DDT (g/year) PCBs (g/year) Santa Monica Bay TMDL Annual Mass-Based WLA* 0.97 5.05
3-Year Averages
2016-17 thru 2018-19
Peninsula-SD1 0.0582 0.0677
Peninsula-SD2 0.0795 0.0634
2017-18 thru 2019-20
Peninsula-SD1 0.0570 0.0014
Peninsula-SD2 0.8836 0.2267
*The WLAs indicated in the TMDL are assigned to the entire Santa Monica Bay Watershed. The WLAs shown here are calculated as a percentage of the TMDL WLAs based on the Peninsula EWMP area.
Note: Flow data for stormwater outfall event 1/19/17 is not available for SD-2 due to personnel error in deploying equipment during the monitoring event and is therefore not included in this calculation The Machado Lake Pesticides and PCBs WLAs are set differently than for the Santa Monica Bay in that for Machado Lake the WLAs are expressed as three-year average concentrations in the sediment fraction of the discharge, rather than as total pollutant mass discharged. The organochlorine pesticide 4,4’- dichlorodiphenyltrichloroethane (DDT) and its breakdown products 4,4’- dichlorodiphenyldichloroethylene (DDE) and 4,4’dichlorodiphenyldichloroethane (DDD) are assigned WLAs individually and grouped as Total DDT in the Machado Lake Toxics TMDL. Outfall monitoring data from the Palos Verdes Peninsula generally supports the underlying assumption in the Machado Lake Toxics TMDL that a three-year averaging period would provide a means to meet concentration-based sediment targets for Dieldrin and PCBs since Dieldrin has not been observed to occur in sediment samples 76 USEPA: Santa Monica Bay DDT and PCBs TMDL
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above detection limits, and PCBs have only exceeded the 3-year average concentration in sediment at one site for one 3-year period. By contrast, as shown in Table 2-18, the data for the DDT breakdown product DDE and for Chlordane show that sediment discharges from all four monitored outfalls tributary to Machado Lake exceed the rolling three-year WLA consistently for those constituents and yet for DDT itself, the WLAs are met. This is evidence that DDT is degrading in the environment. This data also demonstrates that residuals present in sediments on the Palos Verdes Peninsula from legacy use of DDT and Chlordane are ubiquitous. The results vary widely from storm year to storm year, and it is unclear whether the variability is related to timing of sample collection during the storm hydrograph, the intensity of particular storm events, or a combination of these and other variables. Despite the variability in the data, DDE and Total Chlordane concentrations in sediment discharges are consistently above the WLAs across all four sites. This data has been combined with data collected for total suspended solids (TSS) in these samples and incorporated into the reasonable assurance modeling for Machado Lake.
Table 2-19: Machado Lake Pesticides & PCBs 3-Year Rolling Average Concentrations in Storm-Borne Sediment Constituent
Final
Machado
Lake
Pesticides
and PCBs
TMDL WLA
(µg/kg) *
3-Year Period
Average Rolling 3-year Monitoring Results by Outfall Location (µg/kg) RHE City Hall RHE City Hall
Duplicate Valmonte Solano Lariat
Sum DDD 4.88
2016-17 thru 2018-19 21.77 8.5 1.99 3.26 1.73
2017-18 thru 2019-20 22.2 8.87 2.73 279.8 3.37
Sum DDE 3.16
2016-17 thru 2018-19 14.9 13.93 6.6 27.43 30.33
2017-18 thru 2019-20 17.23 16.93 10.00 100.4 36.3
Sum DDT 4.16
2016-17 thru 2018-19 0.98 1 0.58 1.33 0.2
2017-18 thru 2019-20 1.42 1.74 1.02 2.03 1.33
Total
Chlordane 3.24
2016-17 thru 2018-19 15.47 8.27 28.96 48.07 9.7
2017-18 thru 2019-20 16.81 9.47 30.46 110.41 14.93
Total PCB
Congeners 59.8
2016-17 thru 2018-19 7 12.53 0.97 81.68 1.29
2017-18 thru 2019-20 1.37 7.2 0.83 1.35 1.13
*Applied as a 3-year average
METALS
Total and dissolved metals have been monitored in stormwater discharges from the RHE City Hall outfall site, which is representative of discharges to the Los Angeles Harbor since all of the typical land uses found on the Palos Verdes Peninsula are included in the catchment tributary to the RHE City Hall MS4 Outfall site. This data has been utilized in the reasonable assurance modeling for the Los Angeles Harbor to assess 121
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the necessary load reductions for copper and zinc to meet the waste load allocations for the Los Angeles Harbor water segments to which the Peninsula WMG is tributary.
Arsenic and mercury have been added to the outfall monitoring sites for the Santa Monica Bay in response to recent 303(d) listings, however sufficient data are not yet available to support the reasonable assurance modeling.
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
Total PAHs in discharges from the RHE City Hall outfall site representative of discharges to the Los Angeles Harbor have been analyzed as the sum of acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenzo(a,h)anthracene, fluorene, indeno(1,2,3-c,d)pyrene, phenanthrene, and pyrene. Results for Total PAHs measured in stormwater samples from this site have been used in the RAA modeling to assess load reductions needed to meet the waste load allocations for the Los Angeles Harbor.
NUTRIENTS – DRY WEATHER
Monthly dry weather monitoring for Total Nitrogen and Total Phosphorus has been conducted in storm drain outfalls tributary to Machado Lake with presence of significant year-round baseline flows associated with rising groundwater. In Figure 2-7 Total Nitrogen concentrations in these monthly year-round baseline dry weather flows are compared with the water quality objective for Machado Lake of 1.0 mg/L over the course of four complete reporting years. These results show periods when the Total Nitrogen results remain near or below the water quality objective interspersed by periods when the Total Nitrogen results are consistently above the water quality objective.
In Figure 2-8 Total Phosphorus concentrations in these monthly year-round baseline dry weather flows are compared with the water quality objective for Machado Lake of 0.1 mg/L over the course of four complete reporting years. These results show periods when the Total Phosphorus results at the RHE City Hall site remain near or below the water quality objective interspersed with short-term excursions above the water quality objective. By contrast, at the Valmonte monitoring site the Total Phosphorus results are consistently above the water quality objective.
Total Nitrogen and Total Phosphorus monitoring also have been conducted at four storm drain outfalls tributary to Machado Lake during wet weather along with wet weather flow monitoring. This stormwater monitoring data along with the monthly dry weather data has been incorporated into the reasonable assurance modeling to assess necessary load reductions needed to meet the overall nutrient WLAs for Machado Lake.
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Figure 2-8: Total Nitrogen Concentrations in Peninsula Machado Lake Outfall flows from 2016-2020 123
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TRASH
Trash is not a pollutant amenable to reasonable assurance modeling. The Peninsula WMG agencies are individually responsible for meeting WLAs for trash TMDLs and/or complying with the Statewide Trash Provisions as appropriate, and for monitoring and reporting consistent with their approved plans.
FECAL INDICATOR BACTERIA
As shown in Figure 2-9, Figure 2-10, and Figure 2-11 fecal indicator bacteria densities of Total Coliforms, Fecal Coliforms and Enterococci in stormwater discharged from the Peninsula MS4 outfalls to Santa Monica Bay (SD-1 and SD-2 ) do exceed the single-sample water quality based effluent limitations (WQBELs) during wet weather and these results are typical of MS4 discharges. There does not appear to be an increasing or decreasing trend in these wet weather indicator bacteria densities over the four years of CIMP monitoring nor has there been degradation of recreational water quality of the Santa Monica Bay shoreline or nearshore waters off the Palos Verdes Peninsula, as discussed in Section 2.2.1. Given that the Figure 2-9: Total Phosphorus Outfall Concentrations in Peninsula Machado Lake Outfall flows 2016-2020 124
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Palos Verdes Peninsula beaches for which monitoring data exists have been removed from the 303(d) list for indicator bacteria impairments and the fact that there is no apparent degradation of recreational water quality, reasonable assurance modeling is not necessary for indicator bacteria in the Santa Monica Bay.
E. Coli indicator bacteria densities in stormwater discharged from the RHE City Hall MS4 outfall to Wilmington Drain consistently exceed the STV of 320 cfu /100 mL for fresh waters designated for limited water contact recreation. These indicator bacteria densities have remained relatively consistent during the four years of CIMP monitoring. This stormwater outfall monitoring data has been incorporated into the reasonable assurance modeling to assess necessary load reductions to address the 303(d) listing for Wilmington Drain.
Figure 2-10: Total Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-2020) 125
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Figure 2-11: Fecal Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-2020) 126
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Figure 2-12: Enterococci Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-2020) 127
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3. SELECTION OF WATERSHED CONTROL MEASURES
This chapter identifies Watershed Control Measures (WCMs) to be implemented through the Participating Agencies’ jurisdictional stormwater management programs, and collectively on a watershed scale. The WCMs are structural and/or nonstructural controls designed with the following objectives:
● Prevent or eliminate non-stormwater discharges to the MS4 that are a source of pollutants from the MS4 to receiving waters.
● Implement pollutant controls necessary to achieve all applicable interim and final water quality-based effluent limitations and/or receiving water limitations pursuant to corresponding compliance schedules.
● Ensure that discharges from the MS4 do not cause or contribute to exceedances of receiving water limitations.
● Retain the runoff volume of the 85th%, 24-hour storm event, where feasible.
The goal is to create an efficient program that focuses individual and collective agency resources on water quality priorities (WQPs). The WCMs are categorized as:
● Minimum Control Measures (MCMs),
● Non-stormwater Discharge (NSWD) Measures, and
● Targeted Control Measures (TCMs), which are designed to achieve applicable water quality-based effluent limitations and receiving water limitations.
Each WCM category may be further categorized through type: structural or nonstructural, and structural WCM may be categorized by status as well: existing, planned, proposed, or potential. Combined with Chapter 4 (RAA) and Chapter 5 (Compliance Schedules), the EWMP addresses the nature, scope, and timing of implementation for each WCM and provides interim milestones for the WCMs to achieve TMDL compliance. Also discussed are the responsibilities of each Permittee.
Since the Machado Lake TMDLs and the Los Angeles Harbor Toxics TMDL WLAs were calculated based on the average annual water year, the revised RAA used the average water year (Water Year 2010) as the critical condition to establish wet weather nutrient and organic pollutant target load reductions (TLRs) in the Peninsula Machado Lake watershed management area (WMA)77, including the Wilmington Drain WMA1 tributary to Machado Lake, and the Los Angeles Harbor WMA. Consistent with all existing Los Angeles region freshwater bacteria TMDLs, the RAA used the 90th percentile water year (Water Year 2011) as the critical condition to establish wet weather bacteria TLRs in the Wilmington Drain WMA to address the 303(d) listing. Based on these critical conditions, the RAA estimated the following 24-hour stormwater runoff management volumes needed to meet all the non-zero TLRs: 1.3 acre-ft for the Machado Lake WMA, 0.5 for the Wilmington Drain – Solano WMA, 7.4 acre-ft for the Wilmington Drain WMA, 5.4 acreft for Los Angeles Harbor – Inner Harbor WMA, and 1.5 acre-ft for the Los Angeles Harbor – Cabrillo Marina WMA. These 24-hour management volumes are intended to be addressed through LID implementation, existing/planned BMPs, and proposed green streets and regional BMPs as described in this chapter.
Please note that this estimate does not reflect an estimate of recharged groundwater but is simply an estimate of the reduced amount of stormwater runoff leaving the Peninsula EWMP Area as a result of BMP implementation as discussed herein.
77 Both Machado Lake and Wilmington Drain WMAs are subwatersheds to the HUC-12 Dominguez Channel Watershed. 128
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3.1. MINIMUM CONTROL MEASURES
The Minimum Control Measures (MCMs) are baseline WCMs required for all Permittees. The MCMs are defined in the MS4 Permit (excluding modifications set forth in an approved EWMP) and are implemented individually by each Permittee. The objectives of the MCMs are to 1) result in a significant reduction in pollutants discharged into receiving waters and 2) satisfy the requirements of 40 CFR §122.26(d)(2)(iv).
The MCMs are separate from Targeted Control Measures, which are included in the EWMP to specifically address WQPs.
The MS4 Permit allows the modification of certain MCMs programs, so long as the modified actions are set forth in the approved EWMP and are consistent with 40 CFR §122.26(d)(2)(iv). The modifications are based on an assessment to identify opportunities for focusing resources on WQPs. The term “modifications” refers only to instances where language from the MS4 Permit MCM provisions is removed and/or replaced. The Permittees in the Peninsula EWMP have implemented the MCMs (Development Construction Program, Industrial/Commercial Facilities Program, Illicit Connection and Illicit Discharges Elimination Program, Planning and Land Development Program, Public Agency Activities Program, Public Information and Participation Program, and Progressive Enforcement and Interagency Coordination Program) as applicable and will continue to do so as required. Any control measures that are enhancements of the existing programs (i.e. do not conflict with the MS4 Permit MCM provisions) are included in the separate category of Targeted WCMs.
A summary of the assessment of each MCM program as well as a determination as to whether each Participating Agency will implement the MCM provisions either 1) as stated in the corresponding section of the MS4 Permit or 2) with modifications to focus resources on WQPs can be found in Section 3.1.2. The implementation of the MCMs are annually reported in the NPDES Individual Annual Reports.
3.1.1. L.A. COUNTY FLOOD CONTROL DISTRICT MINIMUM CONTROL
MEASURES
The LACFCD will implement the MCMs as defined in the MS4 Permit. See Appendix 1 for additional information.
3.1.2. ASSESSMENT AND MODIFICATION OF MINIMUM CONTROL MEASURES (PARTICIPATING AGENCIES, EXCLUDING LACFCD)
The following section is an assessment of the MS4 Permit MCMs, intended to identify opportunities for modifying MCMs to focus resources on WQPs. This section applies to all participating agencies where applicable, excluding the LACFCD.
3.1.2.1 DEVELOPMENT CONSTRUCTION PROGRAM
The purpose of the MS4 Permit Development Construction Program is to track, inspect and enforce implementation of BMPs on construction sites and to ensure that construction projects of one acre or more have coverage under the Construction General Permit. The Permittees are not modifying this Program and will implement it as defined in the MS4 Permit.
3.1.2.2 INDUSTRIAL/COMMERCIAL FACILITIES PROGRAM
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The purpose of the MS4 Permit Industrial/Commercial Facility Program is to track, inspect, and enforce implementation of BMPs at industrial and commercial facilities and to ensure coverage under the Industrial General Permit where appropriate. There are currently no sites subject to the Industrial General Permit within the jurisdictional authority of the Peninsula WMG nor any commercial sites within the City of Rolling Hills. The Permittees are not modifying this Program and will implement it as defined in the MS4 Permit.
3.1.2.3 ILLICIT CONNECTION AND ILLICIT DISCHARGES ELIMINATION PROGRAM The purpose of the MS4 Permit Illicit Connection and Illicit Discharge (IC/ID) Elimination Program is to detect, investigate and eliminate IC/IDs to the MS4. The Permittees are not modifying this Program and will implement it as defined in the MS4 Permit.
3.1.2.4 PLANNING AND LAND DEVELOPMENT PROGRAM
Following MS4 Permit provisions, Permittees cannot modify the Planning and Land Development Program to be less strict than requirements in the MS4 Permit. The Permittees will implement the Program as defined in the MS4 Permit.
3.1.2.5 PUBLIC AGENCY ACTIVITIES PROGRAM
The Public Agency Activities Program consists of several sub-programs. Many of the MS4 Permit provisions within the sub-programs consist of baseline operation and maintenance (O&M) control measures that do not appear to offer clear benefits from modification. The sub-programs that do suggest a prioritized approach – such as street sweeping and catch basin cleaning frequencies – already provide this opportunity (frequencies are based on an agency’s assessment of trash and debris generation). As such the Cities are not modifying this Program and will implement it as defined in the MS4 Permit.
3.1.2.6 PUBLIC INFORMATION AND PARTICIPATION PROGRAM
The MS4 Permit allows an agency to implement the requirements of the Public Information and Participation Program (PIPP) 1) by participating in a County-wide effort, 2) by participating in a Watershed Group effort, 3) individually within its jurisdiction or 4) through a combination of these approaches. The Agencies will implement the PIPP following a combination of approaches.
In terms of Program modifications, the MS4 Permit provisions provide flexibility to focus efforts on WQPs through the development of the Program. As such, the Cities will implement it as defined in the MS4 Permit. Modifications to elements of the PIPP MCM Program were made to address the Peninsula WMG watershed priorities through activity-specific outreach programs targeted at the following residential activities:
a) DIY auto activities
b) DIY home improvement activities
c) DIY landscaping and gardening activities
d) Pet owner activities
e) Rainwater Harvesting and Downspout Disconnection
Each Permittee will implement the Residential Outreach Program through a combination of individual, watershed, and Countywide program efforts to implement Residential Outreach Program elements. 130
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The Peninsula WMG implement a customized PIPP strategy, developed collaboratively with the Beach Cities WMG, to better address watershed priorities, including; hosting Sustainable Gardening and Landscaping and Integrated Pest Management (IPM) webpages with the South Bay Environmental Services Center (SBESC) providing information regarding alternative pest controls and best management practices for fertilizer use, developing a BMP tip card targeting mobile businesses that generate waste water to mitigate non-stormwater discharges, developing a Small Site Construction brochure focused on illicit discharge mitigation measures, developing a comprehensive Homeowner’s Guide to Rainwater Harvesting to encourage the interception and collection of stormwater on residential properties, maintaining pet waste collection and clean-up stations in municipal parks, developing horse keeping and manure outreach material, facilitating the management of landscape for brush and fire control by providing unlimited green waste collection to residents which minimizes potential leaching of phosphorus from accumulated vegetation and helps to prevent brush fires which mitigates the release of toxic pollutants, and promoting water conservation and stormwater pollution and prevention messages via email blasts and the SBESC website.
Outreach metrics may include impressions, educational materials distributed, website views/interactions, or individuals signed up to receive information. Agencies will annually report outreach metrics in the Individual Annual Report.
3.1.2.7 PROGRESSIVE ENFORCEMENT AND INTERAGENCY COORDINATION Following MS4 Permit provisions, Permittees cannot modify the Progressive Enforcement and Interagency Coordination Program. The Permittees will implement the Program as defined in the MS4 Permit.
3.1.4 FIFTH TERM MS4 PERMIT MINIMUM CONTROL MEASURES
Previous iterations of the WMP included a review of the substantive enhancements and additions to the MCMs. The purpose of the review was to highlight new provisions that would address WQPs. The MCM Provisions of the Fifth Term MS4 Permit do not include significant changes. As such, a review of expected Fifth Term MS4 Permit MCM provisions is not included in the WMP. The implementation of the Enhanced MCMs is annually reported in the NPDES Individual Annual Reports and Permittees will continue to report the implementation of Enhanced MCMs. .
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3.2. NON-STORMWATER DISCHARGE MEASURES
The Participating Agencies will require dischargers that drain to their respective MS4s to implement the Non-stormwater Discharge (NSWD) Measures. If the Participating Agencies identify non-stormwater discharges from the MS4 as a source of pollutants that cause or contribute to exceedances of receiving water limitations, the WCMs will be modified and implemented – subject to the adaptive management process – to effectively eliminate the source of pollutants consistent with the MS4 Permit. In these instances, potential WCMs may include prohibiting the non-stormwater discharge to the MS4, requiring the responsible party to 1) incorporate additional BMPs to reduce pollutants in the non-stormwater discharge or conveyed by the non-stormwater discharge or 2) divert to a sanitary sewer for treatment, or strategies to require the non-stormwater discharge to be separately regulated under a general NPDES permit.
The Permittees in the Peninsula WMP have implemented the NSWD Measures as applicable and will continue to do so as required by the MS4 Permit. The implementation status of the NSWD Measures have not changed since the August 2019 Peninsula EWMP. See Appendix 3.1 for enhanced dry weather runoff reduction control measures.
The implementation of NSWD Measures have been annually reported in the NPDES Individual Annual Reports and the Watershed Progress Report. The results of the most recent joint NSW Screening and Monitoring were provided in the 2017-18 Peninsula Watershed Report Volume II IMCR in Section 6.3c and Table 6f which summarized the work completed to investigate the sources of any significant nonstormwater discharges at outfalls within the Peninsula WMG. The WMG regularly assesses dry weather water quality monitoring data and other information to confirm the results of the NSW Screening and Monitoring.
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3.3 TARGETED CONTROL MEASURES
Targeted Control Measures (TCMs) are additional control measures beyond the baseline MCMs and NSWD measures of the MS4 Permit that are intended to target the Peninsula WMG’s WQPs based on potential pollutant sources identified in the updated source assessment in Section 2.3. TCMs may be divided into two categories: nonstructural and structural. The selection of structural and nonstructural control measures to address WQPs within the Peninsula WMG is a vital component of the EWMP planning process.
The Participating Agencies continue to implement structural and nonstructural control measures in the watershed. There are many different types of structural and nonstructural control measures that provide varying benefits from their implementation. The following sections and corresponding appendices describe TCMs that may be implemented (where implementation is conditional upon factors such as site constraints, governing body approval, etc.), as well types of structural BMPs available to the Peninsula WMG.
3.3.1 CONTROL MEASURES IDENTIFIED IN TMDLS/IMPLEMENTATION PLANS This section describes the nonstructural control measures that have been previously identified in TMDLs and corresponding implementation plans and the status of their implementation. For those TMDLs that do not sufficiently identify control measures, control measures are identified in the planned Targeted Control Measures as described in the following sections in this chapter. For more information on the TMDLs refer to Section 2: Water Quality Priorities.
3.3.1.1 SANTA MONICA BAY BEACHES BACTERIA TMDL
To meet the requirements of Santa Monica Bay Beaches Bacteria (SMBBB) TMDL, a Coordinated Shoreline Monitoring Plan (CSMP) was developed by a committee of responsible agencies, including representatives from the Peninsula WMG. The Peninsula WMG monitoring sites historically experience fewer exceedance days than the reference beach used in the TMDL and are therefore in an anti-degradation condition78.
Furthermore, as discussed in Section 2.2.1, all of the Peninsula shorelines monitoring sites have been delisted from the 303(d) list in accordance with the State Water Resources Control Board’s delisting criteria. As a result, control measures in the approved Implementation Plan include continued implementation of MCMs to protect or enhance existing water quality, and as-needed investigation if an excessive number of exceedances occurs at a monitoring site. As discussed in Section 2.2.1, monitoring results consistently demonstrate attainment of the dry and wet weather SMBBB TMDL receiving water limitations, therefore a RAA modeling effort is not required for this water body pollutant combination.
Summer-dry and winter-dry weather data at the SMBBB TMDL compliance monitoring locations (CMLs) collected up to TMDL Year 2015 were evaluated in the initial RAA to conclude that the dry weather water quality was better than that of the referenced beach based on long-term average exceedance rates. For the revised RAA, the summer-dry and winter dry- weather monitoring data collected between Year 2015 and 2019 have been evaluated to verify that the dry weather exceedance rates have not degraded from historical levels and continue to meet their receiving water limitations.
3.3.1.2 SANTA MONICA BAY NEARSHORE AND OFFSHORE DEBRIS TMDL 78 The antidegradation policy applies to waters that are determined to have high water quality and requires that existing high quality be maintained.
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Compliance with the Santa Monica Bay Debris TMDL is based on installation of structural best management practices such as full capture or partial capture systems, institutional controls, or any best management practices, to attain a reduction in the amount of trash in the Santa Monica Bay. Through a joint project among the PVP Agencies 1,112 catch basins have been retrofit with certified full capture Connector Pipe Screens within the Santa Monica Bay watershed areas of the Peninsula WMG, funded in part through a $600,000 Prop 84 Santa Monica Bay Restoration Commission Grant. See Permittee’s individual Annual Reports for status and information on compliance with the Santa Monica Bay Nearshore and Offshore Debris TMDL.
3.3.1.3 SANTA MONICA BAY DDT &PCBS TMDL
Data summarized in Section 2.3.1 demonstrates that the rolling three-year average Santa Monica Bay outfall monitoring results meet the assigned WLAs for both DDT and PCBs, consequently RAA modeling is not necessary for this water body pollutant combination.
3.3.1.4 MACHADO LAKE TRASH TMDL
Compliance with the Machado Lake TMDL is based on installation of structural best management practices such as full capture or partial capture systems, institutional controls, implementation of a Minimum Frequency of Assessment and Collection (MFAC) program, or any best management practices, to attain a reduction in the amount of trash in the Machado Lake Watershed. To date, over 2,000 full capture trash devices have been installed in Peninsula WMG catch basins tributary to Machado Lake, partially funded by Proposition 84 Stormwater Grant funding. These devices were installed in accordance with the compliance schedule outlined in the TMDL. See Permittee’s individual Annual Report for status and information on compliance with the Machado Lake Trash TMDL.
3.3.1.5 MACHADO LAKE NUTRIENTS TMDL AND MACHADO LAKE PESTICIDES & PCBS TMDL To meet the requirements of the Machado Lake Nutrients TMDL, the Peninsula WMG monitors the Machado Lake outfalls on a monthly basis. To meet the requirements of the Machado Lake Pesticides & PCBs TMDL, the Peninsula WMG collects sediment samples from the Machado Lake outfalls during every wet weather event and compiles the samples for analysis. See data summarized in Chapter 2. The Peninsula WMG developed a plan for achievement of compliance with the Machado Lake Nutrients TMDL in the Palos Verdes Peninsula Subwatershed Coordinated Implementation Plan (2011), which served as guidelines for an adaptive implementation of source control programs and development of structural best management practices.
Infiltration projects reducing nutrients, pesticides, and PCBs flow to Machado Lake, such as the Chandler Ranch Project, have been constructed and the Peninsula WMG continues to pursue structural projects to within the Peninsula Watershed and support project opportunities outside of the Peninsula Watershed such as the Torrance Airport Stormwater Project.
For nutrients, pesticides, and PCBs source control programs, the Peninsula WMG in a collaborative effort with the Beach Cities, developed Sustainable Gardening and Landscaping and Integrated Pest Management (IPM) webpages, provided information regarding alternative pest controls and best management practices for fertilizer use, a BMP tip card targeting mobile businesses that generate waste water to mitigate non-stormwater discharges, developed a Small Site Construction brochure focused on illicit discharge mitigation measures, developed a comprehensive Homeowner’s Guide to Rainwater Harvesting to encourage the interception and collection of stormwater on residential properties, maintain 134
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pet waste collection and clean-up stations in municipal parks, and developed horse keeping and manure outreach material.
3.4 NONSTRUCTURAL TARGETED CONTROL MEASURES
Following MS4 Permit provisions, the Peninsula WMG has developed customized strategies, control measures and O&M control measures to implement the EWMP. Addressing WQPs will be based on a multi-faceted strategy initially focused on source control. If pollutants are not generated or released, they will not be available for transport to the receiving waters. In addition, if soils can be stabilized, sediment controlled, and dry-weather runoff and initial flushes of stormwater runoff eliminated or greatly reduced, the major transportation mechanisms will be eliminated or greatly reduced, and fewer pollutants will reach the receiving waters. Since there is a substantial body of research demonstrating that wildfires can be a significant source of toxic pollutants in stormwater, prevention of wildfires is also an important source control measure for preventing pollutant mobilization and transport of the Peninsula WMG, which is identified as a very high fire hazard severity zone. See detailed discussion in Section 2.3.1.
Many of the highest WQPs, such as copper, lead, and zinc, are released into the atmosphere, resulting in widespread aerial deposition onto impervious surfaces in the Watershed. In addition, these pollutants are discharged directly onto streets, highways, parking lots, and driveways from motor vehicle components such as brakes, wheel weights, and tires. The Participating Agencies have concluded that the most costeffective and long-lasting way to address WQPs is to develop and support state-wide or regional measures that will encourage or require, if necessary, product or material substitution at the manufacturing stage.
This can be a complex and time-consuming process, but the payoff in water quality improvement can be tremendous.
The nonstructural TCMs supplement the MCM efforts with targeted source control measures such as incentives for irrigation control and upgraded street sweeping equipment, designed with the objective of achieving interim and final water quality-based effluent limitations and/or receiving water limitations.
Planned and potential nonstructural TCMs for each participating agency can be found in the Appendix 3.1. 135
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3.5 STRUCTURAL TARGETED CONTROL MEASURES
Structural TCMs are Structural BMPs that, in combination with MCMs, are designed with the objective to achieve interim and final water quality-based effluent limitations and/or receiving water limitations and where feasible to achieve retention of runoff from the 85th percentile, 24-hour storm event. Structural TCMs are an important component of the Peninsula WMG’s load reduction strategy. These BMPs are constructed to capture runoff and filter, infiltrate, or treat stormwater. If properly maintained, these BMPs can have high pollutant removal efficiencies); however, they tend to be more expensive than nonstructural BMPs. The two prevailing approaches for implementing Structural BMPs are regional and distributed approaches. Both serve important purposes and should be considered in combination to determine the best possible implementation strategy to meet the Peninsula WMG’s water quality goals.
Appendix 3.2 provides a description of each of the major structural BMP subcategories.
DISTRIBUTED BMPS
Distributed Structural BMPs are generally built at the site-scale. They are intended to treat stormwater runoff at the source and usually capture runoff from a single parcel or a small area consisting of multiple parcels and public rights of way. They may also include nature-based solutions such as natural habitat restoration, and in particular on the Palos Verdes Peninsula natural canyon habitat and riparian canyon restoration.
REGIONAL BMPS
Regional BMPs refer to large structural BMPs that receive flows from neighborhoods or large areas and may provide multiple benefits such as: improved water quality, increased water supply, improved flood management, enhanced park space, restored habitat, improved public access to waterways, creation of new recreational opportunities, enhanced green spaces at school, reduced heat local island effect, increased number of trees or other vegetation, or implementation of nature-based solutions79.
3.5.1 PERFORMANCE EVALUATION OF STRUCTURAL CONTROL MEASURES Except for areas where runoff from the 85th percentile, 24-hour is retained, the performance of existing and planned BMPs in the Peninsula EWMP area is evaluated through the RAA following provisions of the MS4 Permit, both in terms of volume capture (based on BMP design criteria) and predicted effluent quality. An analysis of BMP Performance data has been summarized in Appendix 4.1 and a summary of modeled BMPs is included in Figure 3-1 and Table 3-1 below. Refer to Section 4 (Reasonable Assurance Analysis) for more detail on the RAA.
3.5.1.1 REGIONAL BMPS
This chapter contains a summary of existing, planned, proposed, and potential Regional BMPs within the Peninsula EWMP area
. These project categories are defined as follows:
• Existing – constructed and on-line Regional BMPs.
79 Los Angeles County, California – Code of Ordinances. Flood Control District Code. Chapter 16 - The Los Angeles Region Safe, Clean Water Program. Accessed May 2021.
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• Planned – some planning for the Regional BMP has been conducted (i.e. preliminary design report, feasibility study).
• Proposed – initial planning for the Regional BMP has begun, but feasibility studies and preliminary design reports have not yet been completed.
• Potential – alternative locations where conditions may be suitable for a Regional BMP It is important to note that the EWMP is subject to adaptive management during the implementation phase (see Section 9 of this EWMP). The Participating Agencies may notify the Regional Board that alternative, equivalent actions are proposed in place of the actions described herein. It is important for the Participating Agencies to have flexibility during the implementation phase if proposed Regional BMPs are found to be infeasible or less desirable than alternatives. Regional BMPs will be subject to feasibility studies and/or alternatives analyses. In some cases, the actions proposed herein may be determined to be less preferred compared to other alternatives. If a preferred alternative action is identified and selected, the responsible agency will notify the Regional Board of the newly selected alternative(s) and demonstrate its equivalency.
Figure 3-1: Modeled Regional Projects
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Table 3-20: Summary of Modeled Regional BMPs
Watershed
Management
Area
Project Name Lead WMG
Member
Completed,
Planned, or
Proposed
BMP Type
Drainage
Area
(ac)
Impervious
Drainage
Area (ac)
BMP
Volume
(ac-ft)
Infiltration
/Treatment
Capacity
Wilmington Drain
(WD-1)
Torrance Airport
Stormwater Basin
Project Phase II
Rolling Hills
Estate
Torrance[a]
Planned
Subsurface
Detention &
Diversion to
Sewer
74 (PVE) 15 (PVE)
21[b] 2.2 cfs
678 (RPV) 263 (RPV)
1,113 (RHE) 539 (RHE)
441 (LAC) 112 (LAC)
Rolling Hills Road
Green Street
Improvement
Rolling Hills
Estate Proposed Pervious
Pavement 0.4 (RHE) 0.4 (RHE) 0.04 1 in/hr
Machado Lake
(ML-1)
Casaba Estates LID Rolling Hills
Estate Completed Surface Retention Basin 28 (RHE) 7 (RHE) 0.4 0.9 in/hr Rolling Hills Country
Club Regional LID
Project – West
Rolling Hills
Estate Completed
Surface Retention
&
Infiltration Basin
358 (RHE) [c] 60 (RHE) 3.8 482 in/hr
Rolling Hills Country
Club Regional LID
Project – East
Rolling Hills
Estate Completed
Surface Retention
&
Infiltration Basin
51 (RHE) 2.0 (RHE) 0.7 1.3 in/hr
Palos Verdes Drive
East Green Street
Improvement
Rolling Hills
Estate Potential
Green
Infrastructure -
TBD
2.6 (RHE) 0.5 (RHE) 0.3 1 in/hr
Los Angeles
Harbor – Inner
Harbor (LAH-IH)
Eastview Park
Regional Project
Rancho Palos
Verdes Proposed
Subsurface
Retention,
Treatment and
Diversion
345 (RPV) 123 (RPV) 1.2 0.6 cfs
Notes:
RPV-Rancho Palos Verdes; PVE-Palos Verdes Estates; RHE-Rolling Hills Estates; RH-Rolling Hills; LAC – Los Angeles County Unincorporated; TOR-Torrance (a) The Peninsula WMG has agreed to collaborate with City of Torrance to utilize this project to receive and manage stormwater runoff from the Peninsula EWMP area. (b) The Torrance Airport Stormwater Basin Project total estimated BMP volume is 21 ac-ft. The Peninsula WMG RAA June 2021 model that did not include Rolling Hills demonstrates that for the Wilmington Drain (WD-1) Watershed Management Area (WMA), 8 ac-ft of 24-hour management volume is needed to meet the final target load reductions. See Section 4 and Section 5 of the EWMP and Appendix 4.1 RAA Report. (c) Does not include Rolling Hills 85%, 24-hr stormwater runoff retention area. 138
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3.5.1.1.1 COMPLETED REGIONAL BMPS
CASABA ESTATES (FORMERLY BUTCHER RANCH) 80
The Casabas Estates regional BMP project was completed in 2013. The project is approximately 8.55 acres located in Rolling Hills Estates. It is bounded on the south by Palos Verdes Drive North, easterly by Monticello Drive, and westerly by Palos Verdes Drive East. The project consists of residential lots, one new Commercial Recreational lot, parking lots, private roads, and allows for keeping of horses on the residential lots.
The project involved re-grading a portion of the pre-existing ravine to remove standing water conditions.
This ravine area was rehabilitated into a vegetated bioretention system to retain and infiltrate runoff from the site. The project receives runoff from offsite (through an existing 24” diameter culvert under Palos Verdes Drive East) from onsite and offsite areas (a total of 28.62 acres). The new bioretention system was designed to retain and infiltrate onsite and offsite runoff in a volume greater than the 85th percentile, 24- hr storm event; therefore, the project was modeled in the RAA as a Regional EWMP Project. See Figure 3- 2 for post-development design conditions.
The Casaba Estates project includes multiple benefits in addition to the stormwater quality benefits that will be observed. These additional benefits may include, but are not limited to, the following:
● Beneficial Use Protection. This project will result in higher water quality which will help to protect recreational beneficial uses and support public health (and wellness) in Machado Lake and the Greater LA Harbor.
● Neighborhood Greening and Public Recreation. This project includes green space within this development which can positively impact the aesthetics, as well as property values, of urbanized areas. Property value tends to increase when an urban neighborhood has green space or trees in sight (CNT, 2010). Green infrastructure and green space can also alleviate urban heat-island effects by reducing temperatures by about 5o
F through shade and evaporation (CNT, 2010).
● Water Conservation/Supply. The stormwater retained onsite recharges groundwater which is being used for potable or non-potable purposes by the adjacent golf course, thus offsetting reliance on imported water supply.
80 Bolton Engineering Corp. Hydrology and Hydraulic Calculations. September 13, 2010. 139
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Figure 3-2: Casaba Estates (formerly Butcher Ranch) Post-Development Design Conditions (Bolton Engineering Corp. Hydrology and Hydraulic Calculations.
September 13, 2010).
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SAN RAMON CANYON
The San Ramon Canyon project is located in the City of Rancho Palos Verdes. The project was completed in October 2014. The project consists of a mid-canyon inlet structure connected to a 3,900-foot long and a 54-inch pipe that outlets below the oceanfront bluff, bypassing a highly erodible section of the canyon (see Figure 3-3). The project inlet is located slightly upstream of the upper switchback along Palos Verdes Drive East and substantially reduces the amount of flow being delivered to an existing, and overwhelmed, storm drain at Palos Verdes Drive South/25th Street. This project improves water quality by substantially reducing erosion and minimizing debris and sediment transport to this drain by diverting all stormwater runoff from a greater than ¼ inch rain event to the underground pipe, diverting it from the erosive canyon.
Two tunnels (over 2,300 feet in total) were dug, about 4,000 linear feet of 54-inch steel pipe was laid, an aesthetically-pleasing sculpted concrete outlet structure was built at the beach, a well-anchored concrete inlet structure was installed in the canyon bottom (acts as a detention basin), the canyon streambed was restored to historic elevations, new native habitat landscaping was installed, affected portions of the Palos Verdes Drive East roadway and storm drain system were repaired and improved, and hiking trail access points were created. Due to the nature of this project its benefits could not be quantified in the RAA model. However, as mentioned above, this project significantly improves the quality of the downstream receiving water and addresses PCBs, DDT, and Sediment Toxicity.
The San Ramon Canyon project includes multiple benefits in addition to the stormwater quality benefits that have been accrued. These additional benefits include, but are not limited to, the following:
● Beneficial Use Protection. This project protects recreational beneficial uses and supports public health (and wellness) in Santa Monica Bay
● Habitat. This project restores and protects the existing streambed and the surrounding ecosystem to encourage infiltration and biologic uptake.
● Flood Management. This project decreases flood risk by reducing runoff rate and volume. ● Water Conservation/Supply. The stormwater retained onsite recharges the groundwater which is being used for potable or non-potable purposes by the golf course, thus offsetting reliance on imported water supply.
Figure 3-3: San Ramon Canyon Project
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CHANDLER RANCH/ROLLING HILLS COUNTRY CLUB PROJECT 81
Redevelopment of the former Chandler Quarry in the City of Rolling Hills Estates was completed in 2018 through private funding to construct a 114-home subdivision (Chandler Ranch) and reconfigure the Rolling Hills Country Club golf course and clubhouse. The golf course portion of the project was constructed on the site of the former quarry, with the golf course and subsurface infiltration gallery designed to provide the same hydraulic retention and infiltration capacity as the former quarry, an exception to the Peninsula’s typical geological constraints. The new homes that are part of this redevelopment are still under construction, however the stormwater infiltration systems have been fully operational since January 2018 and the golf course is also completed. The project site lies within the Machado Lake subwatershed of the Dominguez Watershed Management Area (DWMA). The 226-acre project site is now comprised of the Chandler Ranch homes under development the Rolling Hills Country Club, and golf course.
The regional project consists of three (3) infiltration galleries along with a pretreatment system for each gallery that consists of a suite of catch basin inserts, drainage swales, barrancas and, for the largest gallery, a biofiltration basin. The largestsubsurface infiltration gallery has been designed as a regional BMP system to capture the 50-year storm runoff event from its 705.2-acre tributary area. This regional project well exceeds the standard for retention of the 85th percentile, 24-hour storm.
See Figure 3-4, Figure 3-5, and Figure 3-6.
The Chandler Ranch/Rolling Hills Country Club project has multiple benefits in addition to the stormwater quality benefits. These additional benefits include, but are not limited to, the following:
● Beneficial Use Protection. This project protects the multiple beneficial uses of Machado Lake and supports public health (and wellness) through protection of this public recreational asset. ● Neighborhood Greening and Public Recreation. This project increases green space within this neighborhood which positively impacts the aesthetics, as well as property values, of adjacent areas.
Property value tends to increase when an urban neighborhood has green space or trees in sight (CNT, 2010). Green infrastructure and green space can also alleviate urban heat-island effects by reducing temperatures by about 5o
F through shade and evaporation (CNT, 2010). Replacement of the landfilling and concrete plant uses of the former quarry site with green space has decreased the associated air pollutants including dust from the concrete and inert landfill activity, as well as diesel truck trips along local roadways.
● Water Conservation/Supply. The stormwater retained onsite recharges groundwater and is used by the golf course for non-potable purposes, thus offsetting reliance on imported water supply. ● Public Education/Awareness. This project incorporates stormwater infrastructure within a recreational facility, creating an awareness of stormwater quality and its importance. 81 Hunsaker and Associates. Water Quality Mitigation Plan. June 16, 2010. 142
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Figure 3-4: Chandler Quarry Project Drainage Area Map
Source: Hunsaker and Associates. Water Quality Mitigation Plan. June 16, 2010. 143
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Figure 3-5: Chandler Quarry Project Drainage and Water Quality Concept Plan Source: Hunsaker and Associates. Water Quality Mitigation Plan. January 29, 2016 144
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Figure 3-6: Chandler Quarry Project Infiltration System Concept Design Source: Hunsaker and Associates. Water Quality Mitigation Plan. January 29, 2016 145
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3.5.1.1.2 PLANNED REGIONAL BMPS
The Peninsula WMG has planned regional BMPs which are at levels varying from a concept plan to a final design. The anticipated pollutant removals associated with these BMPs were modeled in the RAA prior to determining additional BMPs necessary for each drainage area. A summary of Planned Regional BMPs within the Peninsula EWMP area is included below.
TORRANCE AIRPORT BASIN
A planned regional BMP located within the City of Torrance adjacent to the Torrance Airport will capture and divert urban stormwater flows into the sanitary sewer. This project is located within the Machado Lake Watershed, outside the Peninsula WMG watershed (see Figure 3-7). The agencies with tributary area to this planned regional BMP include the cities of Torrance, Rolling Hills, Rolling Hills Estates, Rancho Palos Verdes, Palos Verdes Estates, and unincorporated Los Angeles County.
The purpose of the project is to divert stormwater flows from the storm drain to be pre-treated and then stored in subsurface reservoirs for controlled release to the sanitary sewer system and ultimately to the Joint Water Pollution Control Plant (JWPCP) in the City of Carson where the Metropolitan Water District (MWD) has constructed the Regional Recycled Water Advanced Purification Center demonstration plant to treat storm water for regional groundwater infiltration. See Figure 3-8. The project was modeled in the RAA and is predicted to achieve the TLRs for the entire Wilmington Drain WMA, while also capturing stormwater from the 24-hour, 85th percentile event .
The Torrance Airport project will have multiple benefits in addition to the stormwater quality benefits which may include, but are not limited to, the following:
● Beneficial Use Protection. This project will prevent stormwater runoff from reaching the Machado Lake, and instead divert these flows to the sanitary sewer and ultimately to the JWPCP, thus resulting in improved water quality, protection of beneficial uses, and support of public health and wellness in Machado Lake.
● Flood Management. This project will decrease flood risk by reducing runoff rate and volume. ● Water Conservation/Supply. The stormwater diverted to sanitary sewer system and ultimately to the JWPCP will provide a source of urban stormwater flow for recycled water and potential regional groundwater infiltration.
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Figure 3-7: Torrance Airport Drainage Area
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Figure 3-8: Conceptual Layout of Torrance Airport Basin 148
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3.5.1.1.3 PROPOSED REGIONAL BMPS
The Peninsula WMG has proposed regional BMPs, in addition to those already existing and planned, in order to achieve the TLRs. Appendix 4.1 provides greater detail on the current land use designation, location, and potential design capture volume of each site. The proposed BMP sites were scored and ultimately ranked by the sum score from these characteristics:
- Drainage area
- Site area
- Completion status
- Land use
- Estimated infiltration rate
- Estimated depth to groundwater
- Geotechnical hazards
- Sensitive environmental area
- Liquefaction potential.
The sites with the largest drainage area were scored the highest. The land use with the highest accessibility is listed first. Within each land use designation, the sites have been scored from largest to smallest. Ultimately, these locations can serve as a starting point for the continued implementation of the EWMP. Note that with Regional BMPs there are opportunities for multiple agencies to benefit from the same site. The land uses are ranked as follows:
OPEN SPACE AND RECREATION: Sites designated for open space, parks, and recreational activities were ranked with the highest potential for future regional BMPs. This ranking is based on the fact that these types of areas have a high likelihood of being publicly owned eliminating or reducing any high land acquisition costs, they generally have a high percentage of landscaped area available, and they have a greater opportunity for multiple benefits.
MUNICIPAL INSTITUTION: Sites owned by a municipality and designated for government use were ranked with the second highest potential for future Regional BMPs. This ranking is based on the institution being municipally-owned and presenting a higher likelihood of collaboration than a privately-owned facility. Although this may be the case, many Municipal Institutions may not be willing to take on maintenance responsibilities which could result in the necessity of land acquisition or maintenance agreements.
GOLF COURSES/COUNTRY CLUBS: Sites designated as golf courses or country clubs were ranked with the third highest potential for future Regional BMPs. This ranking is based on the fact that these types of areas generally have a high percentage of landscaped area available and have a greater opportunity for multiple benefits. Although this may be the case, land acquisition for these sites is expected to be a difficult and costly process.
EDUCATIONAL USE: Sites designated for educational use were ranked with the fourth highest potential for future Regional BMPs. These sites generally have a high percentage of landscaped area available and have a greater opportunity for multiple benefits; however, gaining cooperation is expected to be difficult.
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COMMERCIAL USE: Sites designated as commercial areas were ranked with the fifth highest potential for future regional BMPs. This ranking is based on the fact that these types of areas generally have a high percentage of parking available which could potentially be retrofitted for infiltration opportunities. Although this may be the case, land acquisition for these sites is expected to be a difficult and costly process.
The available sites were then further assessed by the Peninsula WMG to determine locations for Regional BMPs. Note that the sites presented do not represent the only sites available for the Peninsula WMG. The site selection process took into account the following characteristics:
LOCATION IN RELATION TO RAA RESULTS: The RAA provides an estimation of runoff reduction to be provided in each area in order to meet the water quality objectives. The sites should be selected to take this into consideration.
GIS DATA: GIS data was further analyzed to screen projects based on criteria such as land use, topography, hydrologic features, streets and roads, existing storm drain infrastructure, and storm drain invert depth.
PROJECT BENEFITS: Projects with potential multiple benefits were prioritized due to the increase in the overall benefit and support for these projects. Benefits to take into consideration included, but were not limited to, the following:
Water quality benefits
Water supply benefits
Recreational use
Multi-agency benefits
Publicly owned
Storage availability
Funding available
Project readiness
Flood control benefits
Proximity to pollutant sources or impaired waters
Adjacent to existing storm drain
PROJECT CONSTRAINTS: Potential project constraints were a key component in site selection and elimination. It is important to take into consideration any constraints that may result in project infeasibility prior to the design phase. Constraints that were taken into consideration include:
High groundwater
Potential for deleterious geotechnical impacts (land movement) Low infiltration rates
Existing soil contamination/proximity to existing soil contamination Brownfields82
Existing groundwater contamination/proximity to existing groundwater contamination Potential for soil instability (liquefaction zones, hillside areas) 82 With certain legal exclusions and additions, the term "brownfield site" means real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant (Environmental Protection Agency).
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Existing private ownership (requires land acquisition) Cost Effectiveness (determined through RAA)
Historical landmarks
The participating agencies of the Peninsula Watershed Management Group has encountered geotechnical and geological constraints in the process of developing projects. Due to the unique geological nature of the Palos Verdes Peninsula, infiltration is often infeasible. Frequent geologic movement is prevalent throughout the Palos Verdes Peninsula and extensive research has documented areas where geotechnical hazards exist and are a concern. See Figure 3-9. These geologic conditions coupled with additional areas where rising groundwater is a known concern have limited the feasibility of infiltration projects in many areas within the Palos Verdes Peninsula.
Figure 3-9: Geologic Hazards in the Palos Verdes Peninsula Watershed These locations served as a starting point for the RAA, which was the final step to determine where BMPs were needed and the pollutant removal that could be observed through implementation of a BMP.
BMPs were identified in a prioritized manner. Prioritization was based on cost (low cost BMPs were prioritized); BMP effectiveness for the pollutants of concern (BMPs that had greater treatment efficiency for the pollutant of concern in a particular analysis region were prioritized over other BMPs); and implementation feasibility as determined by desktop screening. In general, structural BMPs were identified that would result in the greatest load reduction per dollar. This was accomplished by targeting land uses with the greatest drainage area with imperviousness, and BMPs with the greatest performance, 151
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particularly for the controlling pollutant. The Proposed BMPs resulting from the selection process are described below.
MACHADO LAKE WATERSHED BMPS
The Machado Lake Watershed has limited areas capable of implementing infiltration projects due to limited areas with storm drains, available right-of-way, geotechnical hazards, specifically land subsidence, and lack of available space. Despite these limitations, construction of a large infiltration system was completed at the former Chandler Quarry (Chandler Ranch/Rolling Hills Country Club Project) in 2018.
Alternatives to regional infiltration-type projects have also been proposed: the Palos Verdes Peninsula Multi-Benefit Flow Diversion Project and the Rolling Hills Road Green Street Improvement. The Peninsula WMG will continue efforts to identify projects within and outside of the geotechnically challenged Machado Lake Watershed. In previous iterations of the Peninsula EWMP (2016, 2019), projects in the Machado Lake Watershed were considered “proposed regional BMPs.” After further investigation and communication with potential project collaborators or land owners, the projects as they were initially conceived were found to be infeasible (South Coast Botanic Garden Regional BMP, Palos Verdes Landfill Regional BMP, and the Valmonte Regional BMP). The South Coast Botanic Garden Regional BMP was removed because at this time, a regional-scale project is not feasible. The County is prioritizing planning of alternate regional projects (Palos Verdes Peninsula Multi-Benefit Flow Diversion Project and Torrance Airport Project) with the Peninsula agencies. Feasibility investigations have shown that site conditions are not conducive for stormwater capture.
PALOS VERDES PENINSULA MULTI-BENEFIT FLOW DIVERSION PROJECT The EWMP initially conceived the closed Palos Verdes Landfill (PVLF) as a potential location for diversion of a major storm drain into a flow-through regional stormwater treatment facility. Due to impaired groundwater and subsurface contamination at this inactive landfill, which is under the oversight of DTSC, the scale of the original proposed project, which was sized to manage large storm flows, was subsequently determined to be infeasible due to constraints associated with the proposed project site on the PVLF Main Site. A smaller scale project is currently proposed to divert baseline flows for beneficial use for irrigation.
The proposed project would address significant year-round baseline flow from rising groundwater in a major storm drain system tributary to Machado Lake within the WD-1 Analysis Region, i.e., the Machado Lake Wilmington Drain subwatershed. See Figure 3-10.
The Palos Verdes Peninsula Multi-Benefit Flow Diversion project would have multiple benefits in addition to the stormwater quality benefits that will be accrued. These additional benefits may include, but are not limited to, the following:
● Beneficial Use Protection. This project will result in higher water quality which will help to protect recreational beneficial uses and support public health (and wellness) in Machado Lake. Furthermore, beneficially using the baseline flows emerging from the Palos Verdes Hills within the Palos Verdes Peninsula for enhancing parks and open space is a sustainable use for capture flows that reduces the demand of imported water.
● Neighborhood Greening and Public Recreation. The primary uses proposed for the captured flows will be to replace potable water used for irrigation of nearby parks and public landscaping. The use of native and climate-appropriate plants in landscaping would maximizes the use of nature-based 152
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solutions by limiting use of turf grass only for playing fields. Green infrastructure and green space can also alleviate urban heat-island effects by reducing temperatures by about 5o F through shade and
evaporation (CNT, 2010).
● Water Conservation/Supply. The primary water supply benefits to accrue from the captured flows are to offset current potable water use for irrigation, thus offsetting reliance on imported water supply.
● Public Education/Awareness. This project will beneficially use captured runoff to enhance recreational benefits, creating an awareness of stormwater and its value as a resource. This project will provide public education opportunities in the form of on-site educational materials, such as placards and interpretive signage.
Legend
Storm Drain Diversion
Tributary Area
Flow Direction
Figure 3-10: Proposed PVP Multi-Benefit Flow Diversion Drainage Area 153
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ROLLING HILLS ROAD GREEN STREET IMPROVEMENT
Redevelopment of Rolling Hills Road from Palos Verdes Drive North to the northern boundary of Rolling Hills Estates with Torrance has been proposed to the conceptual design level. The project concept has received significant community engagement through the City of Rolling Hills Estates’ Traffic and Safety Committee. The preferred project conceptual design received City Council approval on December 8, 2020. This section of roadway will be significantly improved to include bike lanes and pedestrian/equestrian multi-use pathways on both sides of Rolling Hills Road and will incorporate green infrastructure features consistent with the City of Rolling Hills Estates’ Green Street Policy. Due to grade/elevation change along the length of the roadway and current unimproved soft shoulders, during storm conditions the current drainage conditions along the roadway result in erosion and transport of sediment into downstream MS4s. Roadway realignment is likely to be associated with this project and will include the installation of rolled curbs and gutters and related drainage improvements. Project construction will be scheduled after the neighboring City of Rolling Hills completes installation of a new sanitary sewer line along this same stretch of roadway. Benefits of the project include but are not limited to improved pedestrian, equestrian and bicycle safety; connectivity to local bicycle routes in the adjacent City of Torrance; stormwater quality improvements through reduced sediment and associated pollutant transport; and enhanced multi-modal transportation and recreational opportunities. Potential green street elements could include porous paving, biofiltration, bioswales or dry wells.
LOS ANGELES HARBOR WATERSHED BMPS
EASTVIEW PARK INFILTRATION PROJECT
Eastview Park is a large park space near the southeast corner of the intersection of Western Avenue and Westmont Drive in Rancho Palos Verdes (see Figure 3-11). A large storm drain main runs adjacent to the park, draining approximately 350 acres. There are two sanitary sewer outfall tunnels running through Eastview Park at depths ranging from 145-208 ft. If feasible, treatment at this location could consist of a subsurface infiltration BMP capable of capturing the 1-inch design storm83 is proposed. Assuming a depth of 6 feet, the project footprint would be approximately 3.5 acres. Multiple benefits include pollutant load reduction and groundwater recharge. Significantly more work is needed to investigate the feasibility, costeffectiveness, and design details of such a BMP. In the case that infiltration is not a feasible option or unforeseen constraints affect the project, alternative BMPs could be proposed in the Los Angeles Harbor Watershed.
The Eastview Park Infiltration project would have multiple benefits in addition to the stormwater quality benefits that will be observed. These additional benefits may include, but are not limited to, the following:
● Beneficial Use Protection. This project will result in higher water quality which will help to protect recreational beneficial uses and support public health (and wellness) at the Greater LA Harbor. ● Neighborhood Greening and Public Recreation. This project will increase the green space within this development which can positively impact the aesthetics, as well as property values, of urbanized areas. Property value tends to increase when an urban neighborhood has green space or trees in sight (CNT, 2010). Green infrastructure and green space can also alleviate urban heat-island effects by 83 The 1.00 -inch storm was selected for load reduction purposes and is larger than the 85th percentile storm (approximately 0.85-inch).
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reducing temperatures by about 5oF through shade and evaporation (CNT, 2010). Recreation opportunities also can be increased by increased green space which may decrease the amount of cars on the road, subsequently decreasing the associated pollutants. ● Water Conservation/Supply. The stormwater retained onsite will recharge the groundwater which could potentially be used for potable or non-potable purposes in the future, thus offsetting reliance on imported water supply.
● Public Education/Awareness. This project will incorporate stormwater infrastructure within an area which is highly used by the public creating an awareness of stormwater quality and its importance.
The onsite BMP may serve as public education opportunities in the form of on-site educational materials, such as placards and interpretive signage.
Figure 3-11: Proposed Eastview Park Infiltration Project Drainage Area 155
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3.5.1.1.4 POTENTIAL REGIONAL BMPS
In addition to the existing, planned, and proposed BMPs, several opportunities will be considered for implementation. In many cases, significantly more work is needed to investigate the feasibility, costeffectiveness, and design details of these BMPs; however, they will be considered during the implementation phase of the EWMP. As further information is gathered, the Participating Agencies may be inclined to select the below opportunities as alternative or supplemental to the proposed BMPs listed above. The revised RAA model projected that to meet the TLRs, the Peninsula Watershed Management Group needs to develop additional projects to manage stormwater besides projects that are existing, planned, or proposed. This includes projects that would manage additional stormwater for Rancho Palos Verdes and Rolling Hills Estates in the ML-1 WMA, for Rancho Palos Verdes and Rolling Hills Estates in the LAH-IH WMA, and for Rancho Palos Verdes in the LAH-CM WMA. See Section 4 and Section 5.
The EWMP is subject to adaptive management during the implementation phase (see Section 9 of this EWMP) and it is important for the Participating Agencies to have flexibility during the implementation phase if proposed Regional BMPs are found to be infeasible or less desirable than alternatives.
POTENTIAL MACHADO LAKE WATERSHED BMPS
HARBOR CITY PARK
A stormwater capture project at Harbor City Park would provide water quality improvements to Machado Lake. An earlier project concept, included in the EWMP developed by the Dominguez Channel Watershed Management Group, assumed an infiltration project with 2,230 acres diverted to the project from Cities of Los Angeles, Lomita, and unincorporated Los Angeles County. On behalf of the Peninsula WMG, the County of Los Angeles initiated discussion with City of Los Angeles and Los Angeles County Sanitation Districts to evaluate feasibility of expanding the project to include tributary area from the Palos Verdes Peninsula, diverting stormwater and dry weather runoff from a total capture area of 4,783 acres to be infiltrated or diverted to the Joint Water Pollution Control Plant in Carson for treatment.
WALTERIA DETENTION BASIN
The Walteria Detention Basin was constructed for flood protection in 1962 by the LACFCD. The basin has a perimeter of approximately one mile and extends to an approximate depth of 100 feet and has a total capacity of approximately 1,005 acre-feet. The primary function of the Walteria Detention Basin is to provide flood protection and as such it is operated to detain flows that enter the basin during storm events. During storm conditions the basin receives runoff from a tributary area of approximately 2,287 acres with 7.6% of that area (174 acres) contributed by the Peninsula WMG, with the balance of the area contributed by the City of Torrance. The facility is operated as a detention basin and when a major storm is forecast or following a significant storm event, the level in the basin is pumped down to maintain sufficient flood protection capacity for adjacent communities and to sustain capacity of downstream flood conveyance infrastructure. When such discharge is necessary, the discharge is pumped into a 54-inch diameter storm drain, i.e., through the Project No. 584 storm drain, and comingles with flows from other MS4 agencies before eventually discharging to Wilmington Drain and on to Machado Lake. The Peninsula WMG also understands that it is also necessary to periodically pump the level in the basin down for maintenance purposes.
The Walteria Detention Basin was identified as a potential location for a regional BMP in the Peninsula EWMP, pending the results of a Special Study Monitoring Program. The City of Torrance and the LACFCD collaborated and completed the two-year Special Study Monitoring program to characterize water quality of the stormwater flowing into and out of the basin. Results of the monitoring effort can be found in the 2017-18 Watershed Annual Report.
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Although it is not feasible to use Walteria Basin as an in-situ water quality treatment system (such as through application of aluminum sulfate or other flocculants) since such approaches could diminish the flood protection capacity of the basin, the Peninsula WMG is interested in further analysis to assess how the basin could be utilized as part of a regional system of stormwater capture projects in conjunction with the Torrance Airport Regional Project, the Harbor City Park Regional Project, and the Palos Verdes MultiBenefit Flow Diversion Project to meet Machado Lake TMDL WLAs on a mass basis for the tributary area to the basin.
FERN CREEK & VALMONTE CANYON CROSSING RESTORATION PROJECT (FERN CREEK MULTI-BENEFIT
WETLAND RESTORATION PROJECT)
Fern Creek Canyon and Valmonte Canyons are natural drainage courses that converge at the western corner of Ernie Howlett Park in Rolling Hills Estates where stormwater flows from the two canyons are directed into an improved culvert and cross under Ernie Howlett Park via a subsurface storm drain that connects into the MS4 leading to Wilmington Drain and Machado Lake. As observed through years of dry weather monitoring, Valmonte Canyon does not exhibit flow during dry weather, however Fern Creek Canyon receives groundwater discharges and exhibits low or intermittent flows throughout the year along its lower reach. The mouth of Fern Creek Canyon as it enters the culvert has been adversely impacted by periodic storm debris flows from upper reaches of the canyon which accumulate at the mouth below the culvert entrance. Restoring the creek bed at the mouth of the canyon and management of debris flows could reduce nutrient loading to Machado Lake associated with these year-round low flows. The land at this location is currently privately held and is used for horse keeping, but is not suitable for residential development, thereby making land acquisition for public open space and recreation potentially feasible in the future by the City of Rolling Hills Estates. This project would have multiple benefits in addition to year-round water quality benefits for Machado Lake including, but not limited to, improvement of riparian habitat, permanent trail access and connectivity of the multi-use trail system at the crossing of Fern Creek and Valmonte Canyon Trails (currently trail access is conditional by permission of the property owner), restoration and protection of stream habitat, and enhanced passive and active recreational opportunities.
ACADEMY CANYON AND TRAIL RESTORATION PROJECT
This project would restore and preserve a one-mile section of natural canyon drainage course and hiking trail that has been adversely impacted by hydromodification. Erosion of the canyon invert has eroded portions of the trail and exposed sections of a 2,000 linear foot section of subterranean sewer line.
Restoration work would involve canyon, trail and sewer line stabilization, trail enhancement, stormwater management to protect from future hydromodification and improvement of stormwater quality through erosion remediation and control, enhancement of wildlife habitat, and enhancement of recreational and educational opportunities. The trail crest is located adjacent to an independent K-12 day school—the school has listed the canyon as a certified wildlife habitat with the National Wildlife Federation and includes the canyon in its environmental education programs. At its terminus near Palos Verdes Drive North, Academy Canyon drainage is directed into a box culvert and flows via the subsurface MS4 to Wilmington Drain and Machado Lake. Reversing the impacts of hydromodification will enhance the nature-based retentive function of this natural canyon thereby reducing storm flow and associated pollutant loading to Machado Lake.
PALOS VERDES DRIVE EAST GREEN STREET
The City of Rolling Hills Estates is considering redevelopment of Palos Verdes Drive East roadway from Palos Verdes Drive North to the northern boundary of Rolling Hills Estates with the City of Lomita. Due to grade/elevation change along the length of the roadway, roadway curvature and unimproved soft 157
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shoulders, during storm conditions the current drainage conditions along the roadway result in erosion and transport of sediment into downstream MS4s and cause stormwater to flow across the roadway at several locations. Conceptual planning for the project has not yet begun but would incorporate the City’s Green Street Policy and include/consider the following improvements and benefits: pedestrian, equestrian and vehicular safety; drainage improvements; stormwater quality improvements through reduced sediment and associated pollutant transport; and enhanced multi-modal transportation and recreational opportunities.
REOPENER FOR THE MACHADO LAKE NUTRIENT AND PESTICIDES AND PCBS TMDL A reconsideration of the Machado Lake Nutrient TMDL was scheduled for September 11. 2016, and the Peninsula WMG submitted a request for reconsideration on September 7, 2016. At the time Regional Board TMDL staff indicated that a sufficient body of in-lake monitoring data collected by the City of Los Angeles following completion of the lake rehabilitation project would be needed prior to a reconsideration. The Peninsula WMG subsequently requested the Machado Lake Nutrient and Pesticides & PCBs TMDL implementation schedules be extended as part of the Regional Board’s Consideration of Extension of Final TMDL Implementation deadlines for Certain TMDLs in the Los Angeles Region in November 2020; however, the Machado Lake TMDLs were ultimately not considered for extension in that action. A TMDL reopener to allow reevaluation of the TMDL schedules for final compliance is an avenue which the Peninsula WMG continues to support.
POTENTIAL SANTA MONICA BAY WATERSHED BMPS
MALAGA COVE WATER REUSE 84
The City of Palos Verdes Estates has implemented dewatering measures to prevent nuisance rising groundwater from damaging homes and businesses in Malaga Cove. The nuisance groundwater removed from these dewatering sites is currently discharged into the local storm drain system and/or to the nearby Pacific Ocean. This potential project could divert this water to a nearby school site or a nearby parkway in Palos Verdes Estates for irrigation use. This project would serve as a dry weather/low flow diversion rather than as stormwater capture or treatment project.
In 2019, the City of Palos Verdes Estates completed a source tracking study of dry weather storm drain flows in this area for presence of HF183 human markers and found no persistent human sources in the City’s MS4 system upstream of Malaga Cove Beach. Although this potential project has not been included in the load reductions modeled in the RAA, if needed in the future, it has the potential to contribute to additional pollutant removal by reducing or eliminating non-stormwater discharges and low flow wet weather flows from the drainage area.
More work would be required to investigate the feasibility, cost-effectiveness, and design details of such a BMP. The Malaga Cove Water Reuse project could have additional benefits besides water quality benefits including offsetting current use of potable water in landscaping of nearby areas.
PORTUGUESE BEND LANDSLIDE COMPLEX MITIGATION PROJECT 85 (ABALONE COVE WATER REUSE) The City of Ranchos Palos Verdes has implemented dewatering measures to prevent nuisance groundwater and runoff from damaging homes and businesses. In the City of Rancho Palos Verdes, continuous-withdrawal dewatering wells have been installed to slow the progression of the Abalone Cove Landslide and the Portuguese Bend Landslide. The nuisance groundwater removed from these dewatering 84 RMC. “Abalone Cove Project and Malaga Cove Plaza Project Conceptual Evaluation.” August 06, 2009. 85 Information gathered from a feasibility study which is currently being conducted for this project. 158
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sites is currently discharged into the local storm drain system and/or to the nearby Pacific Ocean. The City of Rancho Palos Verdes conducted and completed a feasibility study of the Portuguese Bend Landslide Complex (PBLC) to investigate additional mitigation measures to reduce landslide movement and protect Santa Monica Bay coastal water quality. Although this potential project has not been included in the load reductions modeled in the RAA, it has the potential to contribute to additional pollutant removal by reducing or eliminating non-stormwater discharges and low flow wet weather flows from the drainage area. Additionally, the PBLC Mitigation project will serve to protect the restored rocky reef from excessive sediment deposition from stormwater discharges through drainage improvements, flow detention basins, bioswales, and coastal sage scrub habitat restoration.
More work is needed to investigate the cost-effectiveness and design details of such a BMP.
3.5.1.1.5 STAKEHOLDER INCORPORATION
STAKEHOLDER MEETINGS
The Peninsula WMG initially solicited stakeholder input on the Peninsula EWMP development. These stakeholders included: City Staff, City Council Members and Water Quality and Flood Protection Oversight Committee, Governmental Organizations Staff, Non-Governmental Environmental Organizations Staff, Non-Governmental Organizations Staff, and residents. Several public workshops were held and ultimately stakeholder feedback was incorporated. The Participating Agencies have and will continue to conduct project-specific stakeholder and community engagement through public workshops, meetings, and project presentations at the Safe, Clean Water Program South Santa Monica Bay Watershed Area Steering Committee meetings.
3.5.2 85TH PERCENTILE, 24-HOUR RUNOFF RETENTION AREAS
As provided in Order R4-2021-0105 Part IX.A.4.k., Watershed Management Programs may demonstrate that strategies, control measures, and BMPs cumulatively retain the runoff volume from the 85th percentile, 24-hour storm event for the drainage area tributary to the applicable receiving water and for such areas an RAA is not required. Furthermore, as provided in Order R4-2021-0105 Part X.B.2.b.iii., a Permittee is deemed in compliance with final WQBELs and receiving water limitations if it has retained all conditionally exempt, non-essential non-stormwater and all stormwater runoff up to and including the volume equivalent to the 85th percentile, 24-hour event for the drainage area tributary to the applicable receiving water provided the Permittee is implementing all actions and schedules in an approved Watershed Management Program. Watershed areas that fully retain the 85th percentile, 24-hour runoff volume and were excluded from the RAA analysis are shown in Figure 3-12 and described in the subsequent narrative.
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Figure 3-12 85th Percentile, 24-Hour Runoff Retention Areas Excluded from RAA 160
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ROLLING HILLS NATURE-BASED RUNOFF RETENTION AREA
The City of Rolling Hills (Rolling Hills) is a small, entirely residential semi-rural community of single-family homes with fewer than 2,000 residents in three square miles. By design, it is a model of low-impact development utilizing nature-based solutions for management of stormwater. Its zoning code includes strict standards for development ratios on each property and limits disturbed area during development.
A substantial area of land in Rolling Hills is constrained from development due to steep hillsides and canyons; the use of these areas as wildlife habitat and for native vegetation is emphasized. Rolling Hills’ zoning code further promotes the preservation and appreciation of open space by requiring easements for equestrian/hiking trails on all lots. There are approximately 30 miles of unpaved equestrian/hiking trails throughout the city.86
Under Rolling Hills municipal code87, only 40% of the net area of a residential lot may be disturbed during construction and the remaining area of the lot must remain in its natural, pre-development state. Only 35% of the net lot area may be developed with impervious surfaces, including structures, patios, and other paved areas. Given that the minimum lot size in Rolling Hills is 1 acre, with many substantially larger lots, the limitation on lot coverage preserves significant permeable area throughout the city. Additionally, driveways may not cover more than 20% of the area of the yard in which they are located, and uncovered motor courts/parking pads may not cover more than 10% of the yard in which they are located.
Roads within the City have many green street features. They are designed as narrow, two-lane undivided winding roads 20 to 25 feet wide with rolling to steep grades lined with significant naturalized landscaping.
There are no sidewalks or curb-and-gutter systems, and roads are not designed to be stormwater conveyance systems.88
Stormwater run-off that is not contained on properties is conveyed through Rolling Hills via natural, soft bottom, vegetated drainage courses/canyons (see Figure 3-13), providing disconnection of impervious developed areas and ample opportunity for natural bioretention and infiltration as described in Section
2.3.1: Pollutant Fate and Transport Mechanisms within the Watershed. There is limited public infrastructure and no city-owned or maintained storm drains, roads, sidewalks, or curb-and-gutter, though there are some limited, discontinuous drainage improvements owned/operated by the Los Angeles County Flood Control District (LACFCD).
86 City of Rolling Hills 1990. General Plan – Land Use Element. June 25, 1990. 87 Rolling Hills Municipal Code, Title 17 https://library.municode.com/ca/rolling_hills/codes/code_of_ordinances?nodeId=TIT17ZO 88 City of Rolling Hills 1990. General Plan – Circulation Element. June 25, 1990. 161
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Figure 3-13 Rolling Hills Nature-Based Stormwater Runoff Retention Area The net effect of Rolling Hills’ planning and land development standards along with its extensive network of natural canyon drainage systems is to promote retention and infiltration, creating a system of naturebased solutions for stormwater management. Along with the Minimum Control Measures, NonStormwater Discharge Measures, and Targeted Non-Structural Control Measures described in Sections
3.1, 3.2 and 3.3, this system of nature-based runoff retention measures effectively retains runoff from the 85%, 24-hr rain event within Rolling Hills as demonstrated through monitoring.
Continuous flow monitoring was conducted in Sepulveda Canyon in Rolling Hills for two complete wetweather seasons, from October 26, 2020 through April 2022. Sepulveda Canyon is the largest canyon system within the Machado Lake tributary area of City, and the second largest in the City as a whole. It extends from the top of the Palos Verdes Peninsula at the drainage divide between the Machado Lake and Santa Monica Bay watersheds, running northward to the City’s northern boundary. Sepulveda Canyon consists of approximately 280 acres lying entirely within Rolling Hills with tributary land use representative of the City as a whole.
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The continuous flow monitoring was conducted using an ultra-sonic sensor and data logger within a culvert at the Middleridge Road crossing (33.773522, -118.348538), which is an accessible location near the bottom of the canyon suitable for flow monitoring. No flow was recorded by the Sepulveda Canyon monitoring equipment during two complete wet seasons except for during one intense rain event that occurred from December 29 - 30, 2021. Monthly visual field inspections conducted between November 2020 and June 2021 confirmed the absence of flows and documented the site conditions during storm events. In Rolling Hills the 85th %, 24-hr rain event ranges from 1.0 - 1.1 inches, depending on location.
From October 26, 2020, through April 30, 2022, there were four (4) rainfall events greater than or equal to (≧) the 85th%, 24-hr event with numerous lesser rainfall events occurring. No flow was measured at the Sepulveda Canyon monitoring station during three of the ≧85th%, 24-hr rain events which ranged from 1.13 to 1.38 inches of rainfall, nor was any flow measured during the smaller rain events. The fourth large rain event, which occurred from December 29-30, 2021, was more intense and more than twice the 85th% 24-hour storm depth; the LA County rain gauge at the Rolling Hills Fire Station recorded 2.36 inches in the 24-hour period from 10am on December 29th through 10am on December 30th, 2021, which was in excess of the 95%, 24-hour storm depth. In total, the Rolling Hills Fire Station rain gauge recorded more than 3 inches for that entire rain event which spanned 31 hours and produced flow at the Sepulveda Canyon monitoring station beginning approximately 14 hours after the rain event began. That rainfall event provides an estimate of the upper bound on the retentive capacity of runoff retention in Rolling Hills. The no-flow results observed during the three other ≧85th%, 24-hr rainfall events as well as the numerous smaller rainfall events that occurred throughout the monitoring period provide evidence that the strategies, control measures and BMPs implemented by Rolling Hills cumulatively retain stormwater runoff up to and including runoff from the 85th percentile, 24-hour storm event, as well as any conditionally exempt non-stormwater discharges.
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4. REASONABLE ASSURANCE ANALYSIS
4.1. RAA SUMMARY
The MS4 Permit requires that a Reasonable Assurance Analysis (RAA) be conducted for the waterbodypollutant combinations addressed by this EWMP for areas not addressed through retention of the 85%, 24-hr storm event. The RAA involves the identification and evaluation of potential BMP implementation scenarios with respect to the MS4 Permit-specified effluent and receiving water limits (RWLs) for the priority pollutants of concern for the Peninsula WMG. The RAA demonstrates achievement of these effluent and receiving water limits for each waterbody-pollutant combination addressed in this EWMP.
As part of the Adaptive Management process as prescribed by the MS4 Permit, the RAA must be updated by June 30, 2021, and submitted for review and approval by the Regional Water Board Executive Officer.
Further refining the original RAA (2015), the revised RAA continues to conform to Permit requirements and the (2014) guidelines developed by the Regional Board. Per MS4 Permit provisions, the revised RAA incorporates recent monitoring data, project planning and implementation, and modeling advances.
Additionally, the revised RAA addresses issues and comments raised by the State Water Resources Control Board (SWRCB, 2020), such as inclusion of relevant data for model calibration, non-structural Best Management Practices (BMP) credit, and application of the limiting pollutant approach.
The updated wet weather RAA was conducted using the Watershed Management Modeling System 2.0 (WMMS 2.0), the latest modeling tool developed by Los Angeles County Flood Control (LACFCD), to determine a cost-effective implementation strategy to meet applicable water quality standards (i.e. TMDL waste load allocations [WLA] and Basin Plan Objectives) and targets. For dry weather, a revised semiquantitative approach was implemented to update the dry weather portion of the revised RAA.
The RAA process:
1. Applied an acceptable model tailored to the Peninsula WMG based on available outfall and receiving water data collected through June 2020.
2. Calculated target load reductions (TLRs) necessary to achieve applicable water quality targets.
3. Demonstrated that the existing and proposed suite of projects will attain the TLRs. Where this was not demonstrated, volumetric management needs have been documented to show what needs to be achieved in order to demonstrate compliance.
The final MS4 WLAs for total nitrogen and total phosphorus are expressed in the following two ways in the Machado Lake Nutrients TMDL:
• Monthly average WQBEL concentration.
• Annual average pollutant load calculated as the WQBEL concentration multiplied by the annual average inflow to the Machado Lake (8.45 HM3/year) apportioned to each WMA tributary to Machado Lake (directly or via Wilmington Drain). This method was initially established in the Los Angeles County Machado Lake Nutrient TMDL Special Study (LACDPW, 2011) following conditional approval of the work plan by LARWQCB (LARWQCB, 2010).
Of the two acceptable pathways to meet targets, the annual average pollutant load method was selected to determine the allowable load in subsequent TLR calculations. 164
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The revised and updated Peninsula RAA therefore meets the objectives and requirements of the MS4 Permit and RAA Guidance Document, demonstrating that a reasonable assurance of compliance will be achieved in each analysis region if the TLRs are fully and appropriately managed.
Refer to the Reasonable Assurance Analyses provided in Appendix 4.1 for the rationale of the Model Selection and Overview and the RAA Approach. Refer to Appendix 4.2 for requirements for achieving RWLs for each pollutant category.
4.2. REASONABLE ASSURANCE ANALYSIS
The Reasonable Assurance Analysis for the Peninsula WMG is included in Appendix 4.1.
Table 4-1 summarizes the interim target load reductions (TLRs) established by the RAA, which yielded interim TLRs of zero for all analysis regions in the Machado Lake and Wilmington Drain WMAs. For the Santa Monica Bay and Los Angeles Harbor WMAs, no RAA is required to demonstrate compliance with the interim MS4 WLAs because receiving water monitoring demonstrates the pollutants are below the interim RWLs.
See Table 4-2 for the final TLR summary. For the Santa Monica Bay WMA, no RAA is required to demonstrate compliance with the final MS4 WLA because receiving water monitoring shows the pollutants are meeting the RWLs.
For the non-zero TLRs in the Machado Lake WMA, all the TLR-equivalent 24-hour management volumes are less than the 85th percentile, 24-hour design storm runoff volume. As a result, the recommended approach is to meet the final TLRs rather than trying to meet the full 85th percentile, 24-hour design storm runoff capture alternative. For the Machado Lake analysis region, the largest 24-hour management volume was selected as the target compliance metric, since management of the largest volume will result in management of all others. For the Wilmington Drain WMA, since bacteria was not modeled and 85th percentile 24-hour design storm capture projects are planned for both tributary analysis regions, the full 85th percentile, 24-hour runoff volume is shown as the compliance volume.
For analysis regions in the Los Angeles Harbor WMA, the 85th percentile 24-hour design storm runoff volume of each analysis region is less than the maximum TLR-equivalent 24-hour runoff management volumes in that analysis region. Therefore, the recommended approach is to meet the full 85th percentile 24-hour runoff capture alternative.
Table 4-3 summarizes the results of the Peninsula EWMP RAA for all analysis regions and shows that the TLRs will be met through a combination of LID, Regional and Distributed BMPs. More details on the completed, planned, proposed and potential BMPs to be implemented to meet these TLRs is provided in Section 3.
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Table 4-21: Interim Wet Weather Target Load Reduction Summary WMA
Analysis
Region
Pollutant Critical Condition Baseline Load Allowable Interim Load
Interim Target Load
Reduction
TLR
Equivalent 24-
Hour
Management
Volume (ac-ft)
Absolute
% of
Baseline
Load
Machado
Lake
ML-1
Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved Total Phosphorus Average Runoff Year 38.4 lb/yr 475 lb/yr 0 lb/yr 0% 0.0 Machado Lake -
Wilmington Drain
WD-1
Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved Total Phosphorus Average Runoff Year 346 lb/yr 3,731 lb/yr 0 lb/yr 0% 0.0 WD -
Solano
Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved Total Phosphorus Average Runoff Year Final TLR = 0%, hence RAA achieved Los Angeles Harbor
LAH - IH
Total Copper
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
Receiving water monitoring shows all interim RWLs have been met. Hence no RAA needed.
LAH-CM
Total Copper
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
Receiving water monitoring shows all interim RWLs have been met. Hence no RAA needed.
Santa Monica
Bay
SMB
DDx (Total)
Total PCBs Receiving water monitoring shows all RWLs have been met. Hence no RAA needed.
SMBBB
Total Coliform
Fecal Coliform
Enterococci
Receiving water monitoring shows all RWLs have been met. Hence no RAA needed. 166
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Table 4-22: Final Wet Weather Target Load Reduction Summary Subwatershed
Analysis Region
Pollutant Critical Condition Baseline Load
Final Target Load Reduction
Absolute % of Baseline
Load
TLR Equivalent 24-
Hour Management
Volume
(ac-ft)
Machado Lake
ML-1
Total PCBs Average Water Year 7.5E-04 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 1.0E-03 lb/yr 9.0E-04 lb/yr 88% 1.3 DDT (All congeners) Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0 DDE (All congeners) Average Water Year 6.4E-04 lb/yr 5.7E-04 lb/yr 89% 1.3[1] DDD (All congeners) Average Water Year 6.3E-04 lb/yr 5.2E-04 lb/yr 82% 1.1 Total Chlordane Average Water Year 2.1E-04 lb/yr 1.3E-04 lb/yr 64% 0.7 Dieldrin Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0 Total Nitrogen Average Water Year 119 lb/yr 0 lb/yr 0% 0.0 Total Phosphorus Average Water Year 38.4 lb/yr 0.4 lb/yr 1% 0.1 n/a 85th Percentile 24-Hour
Storm 1.6 ac-ft 1.6 ac-ft 100% 1.6
Machado Lake - Wilmington Drain
WD-1
Total PCBs Average Water Year 3.6E-03 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 4.9E-03 lb/yr 4.3E-03 lb/yr 88% 7.4 DDT (All congeners) Average Water Year 6.0E-05 lb/yr 0.0E+00 lb/yr 0% 0.0 DDE (All congeners) Average Water Year 3.1E-03 lb/yr 2.7E-03 lb/yr 89% 7.4 DDD (All congeners) Average Water Year 3.1E-03 lb/yr 2.5E-03 lb/yr 82% 6.2 Total Chlordane Average Water Year 9.9E-04 lb/yr 6.3E-04 lb/yr 64% 4.2 Dieldrin Average Water Year 5.6E-05 lb/yr 0 lb/yr 0% 0.0 Total Nitrogen Average Water Year 1510 lb/yr 0 lb/yr 0% 0.0 Total Phosphorus Average Water Year 346 lb/yr 47.2 lb/yr 14% 0.6 Bacteria (E. coli) 90th Percentile Wet
Year 8.3 1012 MPN/yr 4.2 1012 MPN/yr 51% 6.0
n/a 85th Percentile 24-Hour
Storm 8.01 ac-ft 8.01 ac-ft 100% 8.0[1]
WD-Solano
Total PCBs Average Water Year 2.07E-04 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 2.84E-04 lb/yr 2.5E-04 lb/yr 88% 0.5 DDT (All congeners) Average Water Year 3.47E-06 lb/yr 0 lb/yr 0% 0.0 DDE (all congeners) Average Water Year 1.77E-04 lb/yr 1.6E-04 lb/yr 89% 0.5 DDD (All congeners) Average Water Year 1.76E-04 lb/yr 1.4E-04 lb/yr 82% 0.4 167
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Subwatershed
Analysis Region
Pollutant Critical Condition Baseline Load
Final Target Load Reduction
Absolute % of Baseline
Load
TLR Equivalent 24-
Hour Management
Volume
(ac-ft)
Total Chlordane Average Water Year 5.72E-05 lb/yr 3.6E-05 lb/yr 64% 0.3 Dieldrin Average Water Year 3.21E-06 lb/yr 0 lb/yr 0% 0.0 Total Nitrogen Average Water Year 42 lb/yr 0 lb/yr 0% 0.0 Total Phosphorus Average Water Year 9 lb/yr 0 lb/yr 0% 0.0 Bacteria (E. coli) 90th Percentile Water
Year 0.46 1012 MPN/yr 0.23 1012 MPN/yr 50% 0.5
n/a 85th Percentile 24-Hour
Storm 0.57 ac-ft 0.57 ac-ft 100% 0.6[1]
Los Angeles Harbor
LAH - IH
Total Copper Average Water Year 8.1 lb/yr 4.5 lb/yr 55% 2.2[2] Total Lead Average Water Year 1.7 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 33.5 lb/yr 17.4 lb/yr 52% 2.0 4,4'-DDT Average Water Year 1.3E-05 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 4.7E-03 lb/yr 4.6E-03 lb/yr 96% 10.4 Total PCBs Average Water Year 3.5E-03 lb/yr 1.0E-03 lb/yr 30% 0.9 Total PAHs Average Water Year 4.4E-01 lb/yr 9.8E-03 lb/yr 2% 0.1 n/a 85th Percentile 24-Hour
Storm 5.4 ac-ft 5.4 ac-ft 100% 5.4[1]
LAH-CM
Total Copper Average Water Year 1.8 lb/yr 0.87 lb/yr 49% 0.5[2] Total Lead Average Water Year 0.4 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 8.2 lb/yr 4.1 lb/yr 50% 0.5 4,4'-DDT Average Water Year 3.3E-06 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 1.2E-03 lb/yr 1.2E-03 lb/yr 96% 2.8 Total PCBs Average Water Year 8.8E-04 lb/yr 2.6E-04 lb/yr 30% 0.3 Total PAHs Average Water Year 1.1E-01 lb/yr 2.5E-03 lb/yr 2% 0.1 n/a 85th Percentile 24-Hour
Storm 1.5 ac-ft 1.5 ac-ft 100% 1.5[1]
[1] Bold value is the representative 24-hour management runoff volume for each analysis region. For WD-1 and WD-Solano, the 85th percentile, 24-hour storm volume is selected since bacteria was not modeled.
[2] TLR for Total Copper does not account for expected reductions over time due to copper brake pad phase-outs in California. See Appendix 4.1 RAA Section 8.2.1. 168
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Table 4-23: Peninsula EWMP RAA Summary
Analysis Region
Management Volume
Final Target Load
Reduction
BMP Load Reduction Summary
LID Redevelopment Regional Projects[2] Distributed Projects Total Load Reduction Assurance
Achieved?
Absolute % Absolute % Absolute % Absolute % Absolute %
ML-1 24-Hour[1] 1.3[3] ac-ft 100 0.003 ac-ft 0.2 1.25 ac-ft 96 0.04 ac-ft 0.4 1.3 ac-ft 100 Yes WD-1 85%, 24-Hour 8.0[3] ac-ft 100 0.02 ac-ft 0.6 8.0 ac-ft 100 0 ac-ft 0 8.0 ac-ft 100 Yes WD-Solano 85%, 24-Hour 0.6[3] ac-ft 100 <0.01 ac-ft 0.5 0.6[4] ac-ft 100 0 ac-ft 0 0.6 ac-ft 100 Yes LAH-IH 85%, 24-Hour 5.4[3] ac-ft 100 0.03 ac-ft 0.6 5.4 ac-ft 100 0 ac-ft 0 5.4 ac-ft 100 Yes LAH-CM 85%, 24-Hour 1.5[3] ac-ft 100 <0.01 ac-ft 0.5 1.5 ac-ft 100 0 ac-ft 0 1.5 ac-ft 100 Yes [1] The 24-hour management volume is the equivalent runoff management volume that will achieve all TLRs. It does not necessarily equate to BMP capacity. A project located at analysis region outlet may have more 24-hour management capacity than a project with same BMP capacity but is located further upstream in the analysis region. The 24-hour management volume of a project needs to be computed via a continuous modeling simulation using the calibrated Peninsula EWMP WMMS 2 model. [2] Regional projects include existing and proposed projects discussed in Section 3 of the EWMP and modeled in the RAA. [3] Please see the Appendix 4.1 RAA Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region. [4] Includes the Walteria Basin Special Study for analysis region WD-Solano. It is assumed that the Peninsula WMG will continue working with LACFCD and City of Torrance to assess how the Walteria Basin can be utilized as part of a regional stormwater capture project in conjunction with other regional projects in the Wilmington subwatershed to meet TLRs in the WD-Solano analysis region.
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5. IMPLEMENTATION SCHEDULE
This Chapter provides the implementation schedule for the Peninsula EWMP. The implementation schedule will be used to measure progress toward addressing the highest water quality priorities (WQPs) and achieving final water quality-based effluent limitations (WQBELs) and receiving water limitations (RWLs). As noted in Chapter 4 and Appendix 4.1 Reasonable Assurance Analysis (RAA), interim WQBELs have been met for all water body pollutant combinations (WBPCs).
5.1. INTRODUCTION
Provisions of the MS4 Permit describe how receiving water limits (RWLs) goals are to be attained for various WBPCs identified through adaptive management of the EWMP. Specifically, the following categories of WBPCs are to be addressed by the EWMP:
• WBPCs addressed through a TMDL (Category 1 pollutants) • 303(d)-listed WBPCs (Category 2 Pollutants)
o Pollutants in the same class as those identified in a TMDL and for which the waterbody is 303(d)- listed
o Pollutants not in the same class as those identified in a TMDL, but for which the waterbody is 303(d)-listed
• Non 303(d)-listed WBPCs (Category 3 pollutants)
o Pollutants for which there are exceedances of RWLs, but for which the waterbody is not 303(d)- listed
Refer to Section 2 for the priority pollutant categorization for the Peninsula EWMP. 170
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5.2. SCHEDULES
Per Permit provisions, TMDL schedules must be incorporated into the EWMP to demonstrate that watershed control measures (WCMs) selected during EWMP development will adequately address these WBPCs in a timely manner so that MS4 discharges of the pollutants will not cause or contribute to exceedances of RWLs.
This updated EWMP incorporates TMDL schedules outlined in the Permit and, where necessary, interim milestones and dates for their achievement during the next five-year Permit term. These schedules will be used to measure progress towards addressing the highest water quality priorities and achieving applicable WQBELS and/or RWLs.
These schedules will meet the following criteria:
• Schedules must be adequate for measuring progress on a watershed or subwatershed scale. • Schedules must be developed for all WCMs that will be implemented individually and on a watershed scale.
Schedules must also incorporate the following:
• Applicable interim and/or final TMDL deadlines occurring within the Permit term identified in Permit. • Interim milestones and dates for their achievement within the Permit term must be developed for any applicable TMDL(s) where deadlines within the next 5-year Permit term are not otherwise specified.
• Interim milestones and dates for their achievement within the Permit term must be developed for Water Quality Priorities not addressed through a TMDL (Category 2 and 3 WBPCs) based on the following criteria:
o Milestones must be based on measurable criteria or indicators, to be achieved in the receiving waters and/or MS4 discharges,
o A schedule with dates for achieving the milestones must be developed, and o A final date for achieving the receiving water limitations as soon as possible must be determined.
The Peninsula WMG has identified Category 1 and 2 WBPCs as summarized in Table 2-1.
Table 5-1 below outlines the dates and corresponding water quality objectives to be achieved by the Peninsula EWMP.
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5.2.1. NONSTRUCTURAL BEST MANAGEMENT PRACTICES SCHEDULE The RAA does not assume or separately quantify a load reduction for the implementation of nonstructural BMPs. Rather, because recent monitoring data was used during calibration, it was assumed that the calibrated baseline model effectively accounted for the load reduction accomplished by existing nonstructural BMPs already being implemented in the Peninsula EWMP area. These nonstructural BMPs consist of Minimum Control Measures (MCMs), Nonstormwater Discharge (NSWD) Measures and Nonstructural Targeted Control Measures (TCMs) as described in Chapter 3 and Appendix 3.1.
In accordance with the State Board Order (SWRCB, 2020), all non-structural BMP credits are required to be adequately justified. As such, the RAA has calculated load reductions associated with quantifiable nonstructural BMPs (for copper reductions resulting from phase out of copper in brake pads).
In 2010, California Senate Bill 346 (SB 346) was enacted to eliminate nearly all use of copper in brake pad manufacturing. In 2013, TDC Environmental prepared a draft detailed study for the California Stormwater Quality Association (CASQA) describing the expected percent reduction for copper as a result of the passage of SB 346 (TDC Environmental, 2013). The TDC study identified three possible implementation scenarios, the least aggressive of which estimated that a 52% load reduction in copper will be achieved by 2032 due to the brake pad phase-out.
Although there is an expectation that copper loads in urban runoff will decrease over time as a result of SB 346, the updated RAA did not attempt to take credit for this load reduction at this time. Following the collection of additional watershed-specific water quality data in the future, adaptive management may be utilized by the Peninsula WMG to update the TLR for copper and/or the load reductions expected to be achieved by this source control program.
5.2.2. STRUCTURAL BEST MANAGEMENT PRACTICE SCHEDULE
STRUCTURAL MINIMUM CONTROL MEASURE SCHEDULE
Pollutant load reductions are anticipated through each Participating Agency’s effective implementation of the structural LID BMP requirements of the Planning and Land Development Program.
STRUCTURAL TARGETED CONTROL MEASURE SCHEDULE
The RAA (Chapter 4) and Appendix 4 RAA Report demonstrates the cumulative effectiveness of BMPs to be implemented, supports BMP selection, and provides target load reduction (TLR) goals optimized across the entire watershed.
The plan depicted in the RAA is considered a potential scenario. Through the adaptive management process, the Participating Agencies may select different types and/or locations of BMPs as described in Chapter 3. The proposed implementation schedule for the projects needed to meet the 24-hour management volumes identified in the RAA can be found in Table 5-1. In addition to the projects listed in Table 5-1 and shown in Figure 5-1, Figure 5-2, and Figure 5-3, the Peninsula WMG is also collaboratively identifying and seeking funding for other regional projects. The Peninsula WMG agencies draining to modeled projects are listed in Figure 5-1, Figure 5-2, and Figure 5-3. These agencies would be responsible for the development of the modeled projects.
In the WD-1 analysis region, the Torrance Airport Project as proposed will meet the 85%, 24- hour management volume required to meet final target load reductions. The Rolling Hills Road 172
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Street Improvement/Green Street project is a proposed project that will only be relied upon if the Torrance Airport Stormwater Basin Project does not proceed as planned.
In the Machado Lake ML-1 analysis region, the City of Rolling Hills Estates intends to meet its 24-hour management volume via the ML-1 RHE Project, and the Palos Verdes Drive East Street Improvement/Green Street will only be relied upon if it is integrated into the ML-1 RHE Project.
These projects listed below were not modeled in the RAA due to uncertainty of their feasibility, future design, and performance:
• Walteria Basin Special Study: Walteria Basin is a flood control basin that receives runoff from 174 acres of drainage area (which includes 55 acres of impervious area) from Palos Verdes Estates in analysis region WD-Solano. The Peninsula WMG will continue working with LACFCD and the City of Torrance to assess how the Walteria Basin can be utilized as part of a regional system of stormwater capture project in the Machado Lake watershed to meet TLRs in the WD-Solano analysis region.
• Palos Verdes Multi-Benefit Flow Diversion Project. This project is currently proposed as a dry weather flow management project within analysis region WD-1. The Peninsula WMG submitted this project for FY 21-22 SCW Technical Resources Program funding and it has been approved by the South Santa Monica Bay Watershed Area for inclusion in its FY 21-22 Stormwater Investment Plan being forwarded to the Regional Oversight Committee and Los Angeles County Board of Supervisors for final technical resources funding approval. A wet weather flow management component will be further evaluated if additional wet weather projects are required to meet the final TLR through the Peninsula EWMP adaptive management process. • Harbor City Park Stormwater Capture Project. This project is a signature regional project proposed by the Dominguez Channel WMG. It is hydrologically connected to the Torrance Airport Stormwater Capture Project and can potentially capture and treat excess stormwater runoff from analysis region WD-1. The project was approved for SCW Technical Resources Program FY 20-21 funding. The Peninsula WMG is interested in collaborating with the Dominguez Channel WMG to share in the benefits of reduced load if additional wet weather projects are required to meet the final TLR through the Peninsula EWMP adaptive management process. 173
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Table 5-24: Structural TCM Implementation Schedule
[a] The Torrance Airport Stormwater Basin Project is a collaborative effort with the City of Torrance. Subwatershed Analysis Region Project Name Responsible
WMG Member
Estimated Schedule
Modeled
24-Hour
Management
Volume
(ac-ft)
Final TLR
Equivalent
24-Hour
Management
Volume
(ac-ft)
Targeted
Milestone Site Investigation and
Feasibility Study Design and Permitting Construction/
Implementation
Machado Lake -
Wilmington
WD-1
Torrance Airport
Stormwater Basin
Project Phase II
RPV, RHE, PVE,
LA County, and
TOR[a] Completed in 2019 Completed in 2019 Completion Date: 2027 7.4 8.0 • Machado Lake
Nutrient TMDL
Final Deadline
Date:
(September 11,
2018)
• Machado Lake
Pesticides and
PCBs TMDL
Final Deadline
Date:
(September 30,
2019)
WDSolano
WD-Solano PVE
Project/Study PVE, LACFCD Completion Date: 2024 TBD Completion Date: 2027 0.57 0.6 Machado Lake
ML-1
Casaba Estates LID RHE Project completed in 2013 0.06
1.3 Rolling Hills Country
Club Regional LID
Project – West
RHE Project completed in 2018 0.82
Rolling Hills Country
Club Regional LID
Project – East
RHE Project completed in 2018 0.02
ML-1 RHE Project
(may replace PVDE
Green Street
Improvement)
RHE Completion Date: 2024 Completion Date: 2025 Completion Date: 2027 0.35 ML-1 RPV Project RPV Completion Date: 2024 Completion Date: 2025 Completion Date: 2027 0.04 LA Harbor
LAH -
IH
Eastview Park
Regional Project RPV Completion Date: 2022 Completion Date: 2025 Completion Date: 2030 1.16
5.38 Long Beach and
Greater LA
Harbor Toxics
TMDL Final
Deadline Date:
(March 23, 2032)
LAH-IH
(cont.)
LAH-IH RPV Project RPV Completion Date: 2024 Completion Date: 2027 Completion Date: 2032 3.42 LAH-IH RHE Project RHE Completion Date: 2025 Completion Date: 2028 Completion Date: 2030 0.80 LAHCM
LAH-CM RPV Project RPV Completion Date: 2024 Completion Date: 2026 Completion Date: 2032 1.51 1.51 174
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Note:
PVE = Palos Verdes Estates; RPV =Rancho Palos Verdes; RHE = Rolling Hills Estates. LAC = Unincorporated Los Angeles County Due to comparatively low volumes, LID redevelopment distributed projects are not shown in the figure Figure 5-14: 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD-1 and WD-Solano) LACFCD
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Note:
RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates
Due to comparatively low volumes, LID redevelopment is not shown in the figure Figure 5-15: 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1) 176
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Note: RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates Due to comparatively low volumes, LID redevelopment is not shown in the figure Figure 5-16: 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA 177
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6. EWMP IMPLEMENTATION COSTS AND FINANCIAL
STRATEGY
The purpose of this section is to present the financial strategy and to represent the strategic options available to the permittees for financing the program costs associated with this updated EWMP. This section provides an order-ofmagnitude estimate of the financial resources and an outline for the financial strategy associated with those costs that may be required to attain the goals of the EWMP. The financial strategy is defined as the options available to the Peninsula WMG to finance the EWMP implementation, including a prioritization of these options.
6.1. EWMP IMPLEMENTATION COSTS
Planning-level estimates of costs associated with implementation of the proposed structural BMPs within the Peninsula WMG area are provided herein based on results from the RAA (Section 4). This section includes an evaluation of the overall economic impacts the proposed projects and programs may have on the community. The cost estimates are preliminary and are based on the best available information to date. The estimated costs will be refined as EWMP implementation progresses with the use of actual BMP implementation costs. Costs associated with implementation of non-structural programs are not provided herein.
Cost opinions are presented as an aid for decision makers, and contain considerable uncertainties. Given the iterative and adaptive nature of the EWMP and the many variables associated with the projects, the budget forecasts are order-of magnitude estimates, and are subject to change based on BMP effectiveness assessments, results of outfall and receiving water monitoring, and additional studies such as site specific objectives which could modify water quality objectives for a specific water body-pollutant combination.
6.1.1. METHODOLOGY
Costs estimated for structural BMPs include capital as well as “soft” costs, which include considerations such as contingency and permitting.
The capital, operation and maintenance (O&M) and 20-year life-cycle costs of the proposed projects were estimated using the following information and cost functions:
• For the Torrance Airport Stormwater Capture Project, the presented costs were extracted from the Safe Clean Water Program Feasibility Study submitted in October 2020 (City of Torrance, 2020). • The cost of the remaining projects was estimated based on key modeling parameters using the cost functions presented in the WMMS 2.0 Phase II Report (LACFCD, 2020c). The cost functions are summarized in Table 6-1.
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Table 6-25: WMMS 2.0 Cost Function
BMP Type BMP Component Capital Cost[1] Annual O&M
Cost[1] Life Cycle Cost[1]
Pervious Pavement $253(A) $5.1 (A) $253(A) + $5.1(A) (Yr) Subsurface
Retention +
Infiltration
Diversion $7,000(In) $320(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) + $320
(In)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Subsurface
Retention +
Filtration
Diversion $7,000(In) $320(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) + $320
(In)(Yr) + [$177,000
+$70,000](Eff) + [$1,000 +
$3,000](Eff)*(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Pump $177,000(Eff) $3,000(Eff)
Filtration $70,000(Eff) $1.000(Eff)
Subsurface
Retention +
Diversion to
Sewer
Diversion $7,000(In) $320(In) [$7000 + $12,000](In) +
$12.6(Vf) + $6,000(Yr) + $320
(In)(Yr) + $177,000(Ps) +
$3,000(Ps)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Pump $177,000(Ps) $3,000(Ps)
Sewer Diversion $67,000
[1] A – BMP footprint in ft2
; Eff – Treatment rate in cfs ; In – Inflow rate in cfs; Ps – Sewer diversion rate in cfs; Vf – BMP storage capacity in ft3
;
Soft costs are project costs that cannot be calculated on a unit cost basis. For conceptual cost estimating, these costs are generally calculated as a percentage of total capital costs.
The soft costs considered for each BMP were:
• Contingency – Costs intended to compensate for any estimating inaccuracy based on assumptions or measured values, unanticipated market conditions, scheduling delays and acceleration issues, lack of bidding competition, and subcontractor defaults.
• Construction Management – The costs associated with management and oversight of the construction of the BMP, from project initiation until completion of the contract. • Mobilization and Demobilization – The costs associated with activation/deactivation of equipment and manpower resources for transfer to/from a construction site until completion of the contract. • Permitting – Cost, including permit fees and personnel hours, of obtaining required permits for BMP installation. Examples of permits needed may include erosion and sediment control, stormwater, construction, and public space permits.
• Engineering and Planning – Costs associated with BMP and site design, as well as access for maintenance, environmental mitigation, buried objects, safety/security, traffic control, limited space, and site restoration.
The expected costs for each of these soft costs as percent of total project capital costs are presented in Table 6-2. These percentages were based on literature, best professional judgment, and data from past projects.
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Table 6-26: Range of Soft Costs for Regional Projects
Cost Item Low Cost Assumption
(% of Capital Cost)
High Cost Assumption
(% of Capital Cost)
Contingency 10% 20%
Construction Management 8% 15%
Mobilization and Demobilization 3% 5%
Permitting 3% 5%
Engineering and Planning 10% 20%
Total 38% 50%
6.2. SUMMARY OF COSTS
The Reasonable Assurance Analysis (RAA) for the Peninsula EWMP indicates that the 24-hour management volume of runoff and stormwater required to be captured within the Watershed to comply with RWLs and WQBELs is: 1.3 acre-ft for the Machado Lake WMA, 0.5 for the Wilmington Drain – Solano WMA, 7.4 acre-ft for the Wilmington Drain WMA, 5.4 acre-ft for Los Angeles Harbor – Inner Harbor WMA, and 1.5 acre-ft for the Los Angeles Harbor – Cabrillo Marina WMA.
Table 6-3 presents the estimated capital cost to construct or implement each modeled structural BMP and the associated annual O&M costs. The cost summary does not include already-completed regional projects (Casaba Estates LID and Rolling Hills Country Club LID) or projects that are not included in the RAA (Harbor City Park Stormwater Capture Project). The cost of the Palos Verdes Peninsula Multi-benefit Flow Diversion Project will be determined as part of the Project’s Safe, Clean Water Program Feasibility Study.
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Table 6-27: Estimated Capital and O&M Costs for Regional BMPs Analysis
Region Lead Agency Project Capital Annual O&M Cost
20-Year Life
Cycle Cost
ML-1 Rolling Hills
Estates
Palos Verdes Drive East Street
Improvement $2,859,000 $58,000 $4,012,000
ML-1 Rolling Hills
Estates
ML-1 RHE Regional Project $254,000 $40,000 $1,060,000
ML-1 Rancho Palos
Verdes ML-1 RPV Regional Project $30,000 $40,000 $821,000 WD-1
Rancho Palos
Verdes and
Torrance
Torrance Airport Stormwater
Basin Project Phase 2 $12,000,000 $118,000 $13,700,000
WD-1 Rolling Hills
Estates
Rolling Hills Road Street
Improvement $481,000 $10,000 $675,000
LAH-IH Rancho Palos
Verdes Eastview Park $781,000 $42,000 $1,619,000
LAH-IH Rolling Hills
Estates
LAH-IH RHE Regional Project $2,308,000 $47,000 $3,241,000 LAH-IH Rancho Palos
Verdes LAH-IH RPV Regional Project $540,000 $41,000 $1,363,000 LAH-CM Rancho Palos
Verdes LAH-CM RPV Regional Project $913,000 $9,000 $968,000 181
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6.3. FINANCIAL STRATEGY
6.3.1. SUMMARY
Financing the implementation of the Peninsula EWMP has historically been the greatest challenge confronting the Peninsula WMG. In the absence of stormwater utility fees (aside from those specified for maintenance), the Peninsula WMG had no dedicated revenue stream to pay for implementation of the EWMP. The absence of a stable stormwater funding mechanism not tied to municipal General Funds became ever more critical with the approval of the fourth term MS4 Permit, which greatly magnified the cost challenges associated with managing stormwater. This prompted the City Manager Committees of the California Contract Cities Association and the League of California Cities, Los Angeles Division, to form a City Managers’ Working Group (Working Group) to review stormwater funding options after the Clean Water, Clean Beaches funding initiative that was proposed by LA County failed to move forward. The result was a Stormwater Funding Report that noted, “the Los Angeles region faces critical, very costly, and seriously underfunded stormwater and urban runoff water quality challenges.” The Report found that funding stormwater programs is so complex and dynamic, and that the water quality improvement measures are so costly, that Permittees could not depend on a single funding option at the time. The Report also included a variety of recommendations, including organizational recommendations; education and outreach program recommendations; recommendations for legislation; Clean Water, Clean Beaches recommendations; local funding options; and recommendations for the Regional Water Board89.
The Watershed Group carefully considered the recommendations of the Report during the development of the original financial strategy for the EWMP, and placed focus on the local funding options presented in the Report to secure the needed funding for initial implementation of the EWMP.
The challenges associated with financing the implementation of the EWMP have since been partially addressed and ameliorated with the passage of Measure W, which was approved by voters in Los Angeles County with 69.45% of the vote in the general election held on November 6, 2018. Measure W successfully proposed the implementation of a special parcel tax of 2.5 cents per square foot of impermeable area to be included on property tax bills in Los Angeles County beginning in October 2019. As presented on the ballot, funds generated through Measure W are to be utilized for “improving/protecting water quality; capturing rain/stormwater to increase safe drinking water supplies and prepare for future drought; protecting public health and marine life by reducing pollution, trash, toxins/plastics entering Los Angeles County waterways/bays/beaches.” The special parcel tax is initially anticipated to amount to an annual, county-wide commitment of up to $285 million, though this could decrease slightly over time as exemptions and credits are processed.
The passage of Measure W also created the Safe Clean Water Program (SCWP), which is administered by the County of Los Angeles and is designed to provide local, dedicated funding for stormwater and urban runoff management programs and projects. Total revenue will be distributed per the following breakdown: 10% will be allocated to the District Program (for the Los Angeles County Flood Control District to distribute funds, provide staff support, and oversee capacity building programs), 40% to the Municipal Program, and 50% to the Regional Program.
The Municipal Program will provide cities with direct funding proportional to the revenues generated within their boundaries. The Peninsula WMG may utilize these funds to finance the implementation of the EWMP, including public LID projects and many of the other WCMs outlined in Section 3. 89 League of California Cities. (2014). Providing Sustainable Water Quality Funding in Los Angeles County. Prepared By City Managers Working Group. Los Angeles County Division May 21, 2014. 182
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The Regional Program will allocate funds through nine Watershed Area Steering Committees (WASCs) into the competitive Infrastructure, Technical Resources, and Scientific Studies Programs. Respectively, the Infrastructure Program will provide funding for multi-benefit regional projects including design, permits, CEQA compliance, grant-writing, right-of-way and land acquisition, construction, and long-term operations and maintenance of projects; the Technical Resources Program will provide funding for the development of project feasibility studies; and the Scientific Studies Program will provide funding for scientific studies, technical studies, monitoring, modeling, and other similar activities. The Peninsula WMG falls under the jurisdiction of the South Santa Monica Bay WASC.
With the implementation of the SCWP underway, the Peninsula WMG now have a reasonably dependable revenue stream to offset, albeit only partially, the high costs of the multi-faceted strategy for the selection and implementation of WCMs outlined in Section 3. The Peninsula WMG has coordinated the proposed implementation schedule (outlined in Section 5) with the financial strategy outlined in this chapter.
However, uncertainties associated with future risks persist. For instance, there are multiple TMDLs in multiple watersheds that must be addressed despite limited resources.
The Peninsula Agencies will set priorities to construct these facilities strategically, and in accordance with the administrative and financial limitations and requirements of the SCWP framework, and seek alternative outside funding in order to close funding gaps.
To address the Water Quality Priorities (WQPs), the Peninsula WMG is going to pursue a multi-faceted financial strategy. In addition, the Peninsula WMG has coordinated the proposed implementation schedule (see Section 5) with the financial strategy. The participating agencies are committed to developing projects through the design phase so that they are shelf ready to take advantage of grants and federal infrastructure funding that may become available. In collaboration with City of Torrance, the Participating Agencies secured Prop 1 Stormwater Planning grant funding for the preliminary design and feasibility study for the Torrance Airport Project and supported the subsequent application for SCW Regional Program Infrastructure funding for design, which was approved and included in the South Santa Monica Bay (SSMB) Watershed Area Steering Committee (WASC) FY 20-21 Stormwater Investment Plan (SIP). The Torrance Airport Project has the potential to address the highest water quality priorities of the Machado Lake Nutrient and Pesticides and PCBs TMDLs within the WD-1 WMA. The Peninsula WMG is planning to submit the Torrance Airport Project to the SSMB WASC for construction funding by the FY2122 Call for Projects deadline. The participating agencies also received SCW Regional Program Technical Resources funding to complete feasibility studies during FY2122 for the Palos Verdes Peninsula MultiBenefit Flow Diversion and during FY2021 for the Harbor City Park Regional projects for the WD-1 WMA.
The participating agencies also succeeded in securing SCW Technical Resources Program funding for the Eastview Park Infiltration Project feasibility study as part of the SSMB WASC FY 20-21 SIP. The Eastview Park Project will address priority pollutants under the Long Beach and Greater LA Harbor Toxics TMDLs in the LAH-IH WMA.
The continued exploration and leveraging of additional sources of funding will be necessary to finance the implementation of the WCMs. Notably, these may include Municipal Safe Clean Water Program funds and other existing funding measures (such as Measures H, A, and M), various grant programs administered by local, state and federal agencies, local fees such as inspection fees, and Clean Water State Revolving Fund program financing agreements to the extent feasible.
Additionally, the Peninsula WMG will also support programs to increase water conservation, reduce dry weather discharges to the storm drain system, and reduce TSS during wet weather. Successfully accomplishing these efforts could reduce the money needed in the long term to capture and/or treat stormwater discharges to comply with TMDLs and address other WQPs. 183
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In the long term, the challenge of financing the WCMs for the Peninsula WMG has partially been alleviated with the passage of Measure W and the ongoing implementation of the SCWP, which have established a reasonably dependable revenue stream for local water quality programs. Nonetheless, implementation of the WMP will require the cooperation of many entities, including business, environmental organizations, and the Regional Board.
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6.3.2. OTHER POTENTIAL FUNDING OPTIONS
The financial strategy to fund the EWMP requires the utilization of multiple funding options. The Peninsula WMG will work together to maximize cost-effectiveness and each individual agency will be responsible for seeking funding for its share in EWMP implementation. The sections below outline multiple approaches to funding and allow each jurisdiction to consider and select the funding options that best fit the specific preferences of their agency. For each funding option, a brief description is included that includes benefits and challenges associated.
EDUCATION AND OUTREACH
The Peninsula WMG implements public outreach and engagement on a watershed-based level and at the individual participating agency level. Projects proposed for SCW funding are reviewed by various stakeholders: government, non-profit, and business and available for public review and comment at the Watershed Advisory Steering Committee (WASC) level.
LEGISLATION
Legislative action has changed the face of contemporary stormwater management. This includes passage of laws, adoption of regulations, and interpretation of laws and enforcement of regulations by the courts at local, state and federal levels. These legislative activities impact all aspects of stormwater management by local governments, as well as the private sector, such as developers who provide basic infrastructure as a part of their developments, industrial facilities that discharge stormwater from their properties, and those conducting ground disturbing construction activities. The Peninsula WMG will continue participation in stormwater legislation advocacy efforts led by the League of California Cities and California Contract Cities and California Stormwater Quality Association (CASQA). The challenges associated with legislation include time and resources. Incorporating new legislation requires a significant amount of time and political influence. Although these options have great potential, they will likely not be available in the short term.
FEDERAL AND STATE GRANTS
Federal and State Grant programs are made available for agencies to receive funding for projects which fall under the guidelines of the grant.
Factors considered in the financial strategy include the following:
• Matching Funds. Almost all grants include matching requirements, which can be up to 50% of the total project costs. Additionally, grant development and administration can take up significant resources, particularly from the small agencies associated with the Peninsula WMG. • Shovel ready projects are typically preferred. Grant programs are generally structured to favor projects that are “shovel ready”, while projects without substantially complete design plans are less likely to be selected.
• Grants are competitive. Each grant program has a set allocation of funds that are available within a defined region (i.e. statewide). As regulatory pressures are increased throughout California and the United States, the competition for securing this type of funding will significantly increase. • Project eligibility. Project eligibility is dependent on the grant program which may not support the project type as needed.
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• Long-term O&M funding. In general, grants are structured to help fund project construction costs.
Separate funding streams for the operations and maintenance costs would be needed.
The Peninsula agencies are committed to pursuing and leveraging these opportunities with their SCW Regional and Municipal funding as well as other local funding sources as they become available.
LOCAL FUNDING OPTIONS
The agencies may consider local funding options to address stormwater funding. Local funding options would typically be pursued within individual agencies. Local funding options include:
• Safe Clean Water Municipal Program funds allocated as local return proportional to the revenues generated within the municipality for activities such as project development, design, construction, monitoring, and O&M;
• Revising street sweeping contracts to provide NPDES trash control programs; • Adoption of water conservation fees to provide funding for reducing irrigated runoff to conserve water and reduce dry weather discharges;
• Local, statewide, or regional fees on car rentals to contribute to copper and zinc clean-up costs and incorporate stormwater quality features into street and highway projects funded by bonds and other street funds;
• Increase in commercial facility inspection fees.
Local funding options may be considered in the financial strategy for short-term funding.
CLEAN WATER STATE REVOLVING FUND
The Clean Water State Revolving Fund (CWSRF) program is a federal-state partnership that provides lowcost financing (at half of the most recent General Obligation Bond Rate at the time of funding approval –
1.6% in March 2015) with terms up to 30 years for a wide range of water quality infrastructure projects.
This fund is likely to be the vehicle for delivery of federal infrastructure funding to local projects once it becomes available to states. The Peninsula WMG could use CWSRF for individual projects or groups of projects as there is no maximum funding limit. The CWSRF can be used for a variety of projects including stormwater measures to manage, reduce, treat, or recapture stormwater or subsurface drainage water; water conservation, efficiency, and reuse; and watershed pilot projects meeting criteria in CWA §122.
TRANSPORTATION BONDS
Another consideration is future transportation bonds. This can be pursued by encouraging the Metropolitan Transportation Authority (MTA) to include funding stormwater quality features, such as Green Streets, in future bonds and encourage Council of Governments to develop strategic transportation plans that include mitigations designed to address water quality issues from transportation projects.
RECOMMENDATIONS FOR THE REGIONAL WATER QUALITY CONTROL BOARD The Regional Board should request funding for a staff position that would be responsible to identify and distribute information on the available federal, state, non-profit, corporate and other sources of funds; and establish an on-line resource center to assist the cities in complying with the stormwater permit requirements.
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6.3.3. PRIORITIZATION
The Group continues to support programs to increase water conservation, reduce dry-weather discharges to the storm drain system, and reduce TSS during wet weather. Successfully accomplishing these efforts could reduce the funds needed in the long term to capture and/or treat stormwater discharges to comply with TMDLs and address other WQPs.
The Peninsula WMG and/or the Participating Agencies will also pursue state grants (i.e. IRWMP, Proposition 1, Proposition 84, etc.) and potential federal infrastructure funding to implement stormwater BMPs.
In the long term, financing the WCMs for the Peninsula Watershed will require establishing dependable revenue streams for local water quality programs with the cooperation of many entities, including business and environmental organizations. Participating Agencies will begin utilizing existing funds to implement the EWMP as well as pursue additional funding in accordance with Table 6-4 below.
Table 6-28: Funding Option Priorities
Agency Funding Priorities Integration with Existing
Infrastructure Improvement Plans
County
1. Federal and State Grants
2. Local Funding Options & Stormwater Fees (Measure W Safe Clean Water Program)
3. Seek allocation in the General Fund; investigate bond and loan opportunities (i.e. CWSRF)
4. Continued participation in stormwater funding advocacy efforts led by the League of California Cities and California Contract Cities and CASQA
• Incorporation of stormwater
improvements in capital improvement
plan for public facilities
• Design guidelines updated and
included green street standard plans
which include elements such as bioretention planters, porous pavement, tree wells, etc.
LACFCD
1. Federal and State Grants
2. Local Funding Options & Stormwater Fees (Measure W Safe Clean Water Program)
3. Seek allocation in the Flood Fund
• Incorporation of stormwater
improvements in capital improvement
plan for public facilities
•
RPV
PVE
RHE
RH
1. Federal and State Grants
2. Local Funding Options & Stormwater Fees (Measure W Safe Clean Water Program)
3. Continued participation in stormwater funding advocacy efforts led by the League of California Cities and California Contract Cities and CASQA
• Incorporation of stormwater
improvements in capital improvement
plan for public facilities
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7. LEGAL AUTHORITY
This section covers information such as documentation and references/links to water quality ordinances for each participating agency. These documents demonstrate adequate legal authority to implement and enforce Watershed Control Measures (WCMs) identified in this plan and as required in the MS4 Permit.
The goal of these WCMs is to create an efficient program that focuses on the watershed priorities by meeting the following objectives:
• Prevent or mitigate non-storm water discharges to the MS4 that are a source of pollutants from the MS4 to receiving waters.
• Implement pollutant controls necessary to achieve all applicable interim and final water qualitybased effluent limitations and/or receiving water limitations pursuant to corresponding compliance schedules.
• Ensure that discharges from the MS4 do not cause or contribute to exceedances of receiving water limitations.
The WCMs include the minimum control measures, non-stormwater discharge measures and targeted control measures (i.e. controls to address TMDL and 303(d) listings). As the requirement to incorporate these WCMs is an element of the MS4 Permit, the legal authority to implement them results from each agency’s legal authority to implement the NPDES MS4 Permit.
Table 7-1 includes the water quality ordinance for each agency with a reference link. Additionally, the participating agencies have developed and adopted LID ordinances and Green Street Policies which provides legal authority to enforce the Planning and Land Development Program.
Table 7-1: Water Quality Ordinance Language
City Water Quality Ordinance Reference
Rancho Palos
Verdes
Chapter 13.10 - STORM WATER AND URBAN RUNOFF
POLLUTION CONTROL
https://www.municode.com/library/ca/rancho_p
alos_verdes/codes/code_of_ordinances?nodeId=
TIT13PUSE_CH13.10STWAURRUPOCO
13.10.020 Purpose – This chapter is also intended to provide the city with the legal authority necessary to control discharges to and from those portions of the municipal storm water system over which it has jurisdiction as required by the municipal NPDES permit.
Palos Verdes
Estates
Chapter 13.08 – STORM DRAINS AND STORM WATER
MANAGEMENT AND POLLUTION CONTROL
http://www.codepublishing.com/ca/palosverdes
estates/
13.08.Purpose and Intent– The purpose of this chapter is to protect and enhance the quality of surface waters and surface water bodies, including the Santa Monica Bay and Machado Lake, in a manner consistent with the Federal Clean Water Act (33 U.S.C.
Sections 1251 et seq.), the California Porter-Cologne Water Quality Control Act (Cal. Water Code Sections 13000 et seq.), and the municipal National Pollutant Discharge Elimination System (NPDES) permit.
Rolling Hills Chapter 8.32 - Storm Water Management and Pollution Control
https://library.municode.com/ca/rolling_hills/cod
es/code_of_ordinances?nodeId=TIT8HESA_CH8.3
2STWAMAPOCO
8.32.030 - Purpose and intent.
A. The purpose of this chapter is to comply with the Federal Clean Water Act, the California Porter-Cologne Water Quality Control Act, and the Municipal NPDES Permit by:
1. Reducing pollutants in storm water discharge to the maximum extent practicable;
2. Regulating illicit connections and illicit discharges and thereby reducing the level of contamination of storm water and dry weather runoff into receiving waters; and
3. Regulating non-storm water discharges to the storm sewer system. 188
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Rolling Hills
Estates
Chapter 8.38 - STORMWATER AND URBAN RUNOFF
POLLUTION CONTROL
https://library.municode.com/ca/rolling_hills_est
ates/codes/code_of_ordinances?nodeId=TIT8HES
A_CH8.38STURRUPOCO
8.38.030 Construction and Application – This chapter will be construed to assure consistency with the requirements of the Clean Water Act and the Porter-Cologne Water Quality Control Act, and their implementing regulations, and the municipal NPDES permit.
LACFCD Flood Control District Code, Chapter 21 - Stormwater and Runoff Pollution Control
https://library.municode.com/HTML/16274/level
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H21STRUPOCO_21.01PUIN
21.01 - Purpose and Intent - The purpose and intent of this chapter is to regulate the stormwater and non-stormwater discharges to the facilities of the Los Angeles County Flood Control District for the protection of those facilities, the water quality of the waters in and downstream of those facilities, and the quality of the water that is being stored in water-bearing zones underground. 189
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8. COORDINATED INTEGRATED MONITORING PROGRAM
The Participating Agencies implement a customized Coordinated Integrated Monitoring Program (CIMP) based on the provisions set forth in Attachment E of the MS4 Permit. The data collected by the CIMP are used to assess the effectiveness of the EWMP projects and programs in addressing water quality priorities, specifically in achieving water quality-based effluent limitations (WQBELs) and receiving water limitations (RWLs) per compliance schedules. The customized CIMP includes the following program elements:
• Receiving Water Monitoring
• Storm Water Outfall Monitoring
• Non-Storm Water Outfall Monitoring
• Regional Studies
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9. ADAPTIVE MANAGEMENT PROCESS
Adaptive management is the process by which new information about the state of the watershed is incorporated into the EWMP.
Following the previous 2018 and 2020 Adaptive Management processes, the Peninsula WMG is required to submit an updated EWMP and Reasonable Assurance Analysis (RAA) by June 30, 2021 for review and approval by the Regional Board. The updated RAA detailed in Appendix 4.1, utilizes all relevant, available data, including updates to the water body pollutant combination prioritization, source assessment, TMDL milestone achievements, and control measure performance data. As further elaborated in the updated EWMP (Section 2, Section 3, RAA Report in Appendix 4.1, etc.), the EWMP is adaptively managed following the process described in the MS4 Permit.
The process is implemented by the participating agencies and submitted to the Regional Water Board for review and approval as required by the MS4 Permit and as deemed appropriate. The purpose of the adaptive management process is to improve the effectiveness of the EWMP based on – but not limited to – consideration of the following:
1. Progress toward achieving interim and/or final water quality-based effluent limitations and/or receiving water limitations in §VI.E and Attachments L through R of the MS4 Permit, according to established schedules;
2. Progress toward achieving improved water quality in MS4 discharges and achieving receiving water limitations through implementation of the watershed control measures based on an evaluation of outfall-based monitoring data and receiving water monitoring data;
3. Achievement of interim milestones;
4. Reopening of TMDLs;
5. Re-evaluation of the water quality priorities identified for the Watershed Management Area (WMA) based on more recent water quality data for discharges from the MS4 and the receiving water(s) and a reassessment of sources of pollutants in MS4 discharges;
6. Availability of new information and data from sources other than the MS4 Permittees’ monitoring program(s) within the WMA that informs the effectiveness of the actions implemented by the Permittees;
7. Regional Water Board recommendations; and
8. Recommendations for modifications to the Enhanced Watershed Management Program solicited through a public participation process.
9.1. MODIFICATIONS
Based on the results of the adaptive management process, the participating agencies may find that modifications of the EWMP are necessary to improve effectiveness. Modifications may include new deadlines and interim milestones, with the exception of those deadlines established in a TMDL.
9.1.1. REPORTING
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Modifications are reported in the Annual Report and as part of the Report of Waste Discharge (ROWD) required pursuant to the MS4 Permit. The background and rational for these modifications are included by addressing the following points:
• Identify the most effective control measures and describe why the measures were effective and how other control measures will be optimized based on past experiences. • Identify the least effective control measures and describe why the measures were deemed ineffective and how the control measures will be modified or terminated. • Identify significant changes to control measures during the prior year and the rationale for the changes.
• Describe all significant changes to control measures anticipated to be made in the next year and the rationale for the changes. Those changes requiring approval of the Regional Water Board or its Executive Officer shall be clearly identified at the beginning of the Annual Report. • Include a detailed description of control measures to be applied to New Development or Redevelopment projects disturbing more than 50 acres. • Provide the status of all multi-year efforts that were not completed in the current year and will continue into the subsequent year(s).
• Provide the status of multi-year/future regional BMPs, both planned and proposed. • Provide the status of efforts to secure funding for structural TCMs both for capital investments and O&M.
9.1.2. IMPLEMENTATION
Modifications are implemented upon approval by the Regional Water Board Executive Officer or within 60 days of submittal if the Regional Water Board Executive Officer expresses no objections. 192
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9.2. RECEIVING WATER LIMITATIONS
The adaptive management process fulfills the requirements in MS4 Permit to address continuing exceedances of receiving water limitations.
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10. REPORTING PROGRAM & ASSESSMENT
The reporting information provided below is based on the requirements of the MS4 Permit. These implementation reports and monitoring reports allow the Regional Board to assess implementation progress and program effectiveness.
10.1. ANNUAL REPORT
Each year as directed by the MS4 Permit, all Permittees are required to submit an Individual Annual Report. Each year the participating agencies in the Peninsula EWMP will also submit a joint Watershed Annual Report to the Regional Water Board Executive Officer. The Watershed Annual Report will present a summary of information that will allow the Regional Board to assess implementation progress and effectiveness of the watershed management program90.
The reporting process is intended to meet the following objectives to assess:
• Each agency's participation in the Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program.
• The impact of each agency's storm water and non-storm water discharges on the receiving water.
• Monitoring results in comparison to receiving water limitations, numeric water quality-based effluent limitations, and non-storm water action levels. • The effectiveness of control measures in reducing discharges of pollutants from the MS4 to receiving waters.
• Whether the quality of MS4 discharges and the health of receiving waters is improving, staying the same, or declining as a result watershed management program efforts, and/or TMDL implementation measures, or other Minimum Control Measures. • Whether changes in water quality can be attributed to pollutant controls imposed on new development, re-development, orretrofit projects.
The Annual Report will identify data collected and strategies, control measures and assessments implemented for each watershed within the participating agency's jurisdiction. The participating agencies will submit annual reports as required by the MS4 Permit. 90 Annual reports will cover summary from previous fiscal year beginning July 1st through June 30th of the following year. 194
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10.2. MONITORING REPORT
10.2.1. DATA REPORTING
Analytical data reports will be submitted on a semi-annual basis, or as directed by the MS4 Permit. CEDENformatted data will be sent electronically to the Regional Water Board's Storm Water site at [email protected]. These data reports will summarize:
• Exceedances of applicable WQBELs, receiving water limitations, or any available interim action levels or other aquatic toxicity thresholds.
• Basic information regarding sampling dates, locations, or other pertinent documentation. • The annual watershed monitoring report will summarize efforts to address water quality exceedances.
10.2.2. CHRONIC TOXICITY REPORTING
Aquatic toxicity monitoring results will be submitted to the Regional Board on an annual basis as part of the watershed and monitoring report as well as in the semi-annual basis data report submittal.
10.2.3. TMDL REPORTING
The participating agencies will also report on progress of TMDL implementation on an annual basis as part of the watershed and monitoring report and submit to the Regional Water Board Executive Officer. 195
Appendix 1.0
LA County Flood Control District Summary
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In 1915, the Los Angeles County Flood Control Act established the LACFCD and empowered it to manage flood risk and conserve stormwater for groundwater recharge. In coordination with the United States Army Corps of Engineers the LACFCD developed and constructed a comprehensive system that provides for the regulation and control of flood waters through the use of reservoirs and flood channels. The system also controls debris, collects surface storm water from streets, and replenishes groundwater with storm water and imported and recycled waters. The LACFCD covers the 2,753 square-mile portion of Los Angeles County south of the east-west projection of Avenue S, excluding Catalina Island. It is a special district governed by the County of Los Angeles Board of Supervisors, and its functions are carried out by the Los Angeles County Department of Public Works. The LACFCD service area is shown in Figure 1.A -1.
Unlike cities and counties, the LACFCD does not own or operate any municipal sanitary sewer systems, public streets, roads, or highways. The LACFCD operates and maintains storm drains and other appurtenant drainage infrastructure within its service area. The LACFCD has no planning, zoning, development permitting, or other land use authority within its service area. The permittees that have such land use authority are responsible under the Permit for inspecting and controlling pollutants from industrial and commercial facilities, development projects, and development construction sites. (Permit, Part II.E, p.
17.)
The MS4 Permit language clarifies the unique role of the LACFCD in storm water management programs: “[g]iven the LACFCD’s limited land use authority, it is appropriate for the LACFCD to have a separate and uniquely-tailored storm water management program. Accordingly, the storm water management program minimum control measures imposed on the LACFCD in Part VI.D of this Order differ in some ways from the minimum control measures imposed on other Permittees. Namely, aside from its own properties and facilities, the LACFCD is not subject to the Industrial/Commercial Facilities Program, the Planning and Land Development Program, and the Development Construction Program.
However, as a discharger of storm and non-storm water, the LACFCD remains subject to the Public Information and Participation Program and the Illicit Connections and Illicit Discharges Elimination Program. Further, as the owner and operator of certain properties, facilities and infrastructure, the LACFCD remains subject to requirements of a Public Agency Activities Program.”
(Permit, Part II.F, p. 18.)
Consistent with the role and responsibilities of the LACFCD under the Permit, the EWMPs and CIMPs reflect the opportunities that are available for the LACFCD to collaborate with permittees having land use authority over the subject watershed area. In some instances, the opportunities are minimal, however the LACFCD remains responsible for compliance with certain aspects of the MS4 permit as discussed above.
In some instances, in recognition of the increased efficiency of implementing certain programs regionally, the LACFCD has committed to responsibilities above and beyond its obligations under the 2012 Permit. For example, although under the 2012 Permit the Public Information and 197
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Participation Program is a responsibility of each Permittee, the LACFCD is committed to implementing certain regional elements of the PIPP on behalf of all Permittees at no cost to the Permittees. These regional elements include:
Maintaining a countywide hotline (888-CLEAN-LA) and website (www.888cleanla.com) for public reporting and general stormwater management information at an estimated annual cost of $250,000. Each Permittee can utilize this hotline and website for public reporting within its jurisdiction.
Broadcasting public service announcements and conducting regional advertising campaigns at an estimated annual cost of $750000.
Facilitating the dissemination of public education and activity specific stormwater pollution prevention materials at an estimated annual cost of $100,000. Maintaining a stormwater website at an estimated annual cost of $10,000.
The LACFCD will implement these elements on behalf of all Permittees starting July 2015 and through the Permit term. With the LACFCD handling these elements regionally, Permittees can better focus on implementing local or watershed-specific programs, including student education and community events, to fully satisfy the PIPP requirements of the 2012 Permit.
Similarly, although water quality monitoring is a responsibility of each Permittee under the 2012 Permit, the LACFCD is committed to implement certain regional elements of the monitoring program. Specifically, the LACFCD will continue to conduct monitoring at the seven existing mass emissions stations required under the previous Permit. The LACFCD will also participate in the Southern California Stormwater Monitoring Coalition’s Regional Bioassessment Program on behalf of all Permittees. By taking on these additional responsibilities, the LACFCD wishes to increase the efficiency and effectiveness of these programs. 198
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Figure 1.A-1 Los Angeles County Flood Control District Service Area 199
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Figure 1.A-2 Los Angeles County Flood Control District Areas in Peninsula WMG 200
Appendix 3.1
Nonstructural Targeted Control Measures
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3.1 NONSTRUCTURAL TARGETED CONTROL MEASURES
Table 3.1-1 lists implemented enhanced nonstructural TCMs for each participating agency. The BMP effectiveness from 4 is based on similar BMPs listed in Tetra Tech’s CLRP for Chollas Creek Watershed in San Diego County, 2012.
The responses for each agency under Table 3-3 are defined as follows:
R Regulatory TCM. The TCM is to be implemented through legislative measures that have the support of the Peninsula WMG.
C Completed TCM. The TCM is preexisting (has been in effect for several years or more).
Table 3.1-2 lists the anticipated pollutants to be addressed through each Nonstructural TCM. The pages following Table 3-4 describe each of the listed controls. It is important to note that the LACFCD are operating regional stormwater programs and consequently incorporating localized institutional TCMs may not be feasible. As such their exclusion from such TCMs is justified. 202
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Table 3.1-1: Enhanced Nonstructural Targeted Control Measures (TCMs) Targeted Control Measure
BMP effectiveness with respect to
WQPs1 Agency
Priority
Pollutant
Reduction
Sediment
reduction
Volume or
flow
reduction
LACFCD County
Unincorporated
Palos
Verdes
Estates
Rancho
Palos
Verdes
Rolling
Hills
Rolling
Hills
Estates
Planning and Land Development
LID and Green Streets Staff Training ❑ ❑ ❑ N/A C C C C C Industrial/Commercial Facilities
Restaurant Certification Program ◆ ◇ ❑ N/A C C NA C
Dry weather runoff reduction
Irrigation Reduction Incentives Program ◆ ◆ ◆ N/A C C C C C Public Information and Participation
Downspout Disconnect Program ❑ ❑ ◆ N/A C C C C C
Targeted Outreach ◆ ◆ ◆ C C C C C C
Horse Manure Management ◆ ◇ ◇ N/A C N/A C C C
Public Agency Activities
Enhanced Street Sweeping ◆ ◆ ◇ N/A C C C NA C
Adopt Sewer System Management Plan (SSMP) ◆ ◇ ◇ N/A C C C NA C Increased Street Sweeping Frequency or Routes ◆ ◆ ◇ N/A C NA C Jurisdictional SW Management
Prepare guidance documents to aid in implementation
of MS4 Permit MCMs ❑ ❑ ❑ C C C C C
Regulatory Initiatives
Brake Pad Replacement Program ◆ ◆ ◇ R R R R R R
Lead Reduction Program ◆ ◆ ◇ R R R R R R
Zinc Reduction Program ◆ ◆ ◇ Watershed Group
Apply for grant funding for stormwater projects
(Measure W Safe Clean Water Program) ◆ ◆ ◆ C C C C NA C Ordinances
Water Efficient Landscaping ◆ ◇ ◆ N/A C C C C C
Green Building Ordinance ◆ ❑ ❑ N/A C
Enhanced Irrigation Runoff Reduction Program ◆ ❑ ◆ N/A C C C C C Adoption of LA County Fire Code ◆ ◆ ◆ C C C C C C
✗– Planned TCM P – Potential TCM C – Completed/Implemented TCM R - Regulatory TCM ◆ Primary pollutant reduction ❑ Secondary pollutant reduction ◇ Pollutant not addressed 1 BMP effectiveness ratings based on similar BMPs listed in Tetra Tech’s CLRP for Chollas Creek Watershed in San Diego County, 2012. 203
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Table 3.1-2: Anticipated Pollutants to be addressed through Enhanced Nonstructural TCMs Targeted Control Measure
Category 1 Category 2
SMB
Trash
SMB DDT
& PCBs ML Trash
ML Pesticides &
PCBs
(Chlordane, DDT,
Dieldrin, and
PCBs)
ML Nutrients
(Total Nitrogen
and Total
Phosphorus)
Harbor Toxics
(Copper, DDT,
Lead, PAHs,
PCBs, and Zinc)
SMB
Beaches
Indicator
Bacteria
SMB
Arsenic
SMB
Mercury
Wilmington
Drain
E. coli
Restaurant Certification
Program √ √ √ √ √ √ √
Rainwater Harvesting
Program √ √ √ √ √ √ √
Irrigation Reduction
Incentives Program √ √ √ √ √ √ √ √
Targeted Outreach √ √ √ √ √ √ √ √ √ √
Horse Manure Management √ √ √
Enhanced Street Sweeping √ √ √ √ √ √ √ √ √
Adopt Sewer System
Management Plan √ √ √ √ √
Increased Street Sweeping
Frequency or Routes √ √ √ √ √ √ √ √ √ √
Wildfire Prevention
Program √ √ √ √ √ √
Prepare Guidance
Documents √ √ √ √ √ √ √ √ √ √
Brake Pad Replacement
Program √
Lead Reduction Program √
Zinc Reduction Program √
Apply for Grant Funding
(SCW Regional and
Municipal Program)
√ √ √ √ √ √
√
√ √ √
Water Efficient Landscaping √ √ √ √ √ √ √ √
Green Building Ordinance √ √ √ √ √ √ √ √ √ √
Enhanced Irrigation Runoff
Reduction Program √ √ √ √ √ √ √ √
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INDUSTRIAL/COMMERCIAL FACILITIES
RESTAURANT CERTIFICATION PROGRAM
The Restaurant Certification Program educates restaurants on restaurant best management practices, including proper disposal of wastes and spill prevention. This program enhances the Commercial MCMs by implementing an annual program of restaurant inspections. Additionally, through promotion of green business or ocean-friendly certification programs, agencies encourage restaurants to go above and beyond local stormwater regulations to help prevent pollution.
The program is currently being implemented by the City of Rancho Palos Verdes, Palos Verdes Estates, and Rolling Hills Estates.
DRY WEATHER RUNOFF REDUCTION
IRRIGATION REDUCTION INCENTIVES PROGRAM
This measure will provide incentives such as rebates for irrigation reduction (i.e. runoff reduction) practices such as xeriscaping and turf conversion. All agencies are currently involved in this effort through the West Basin Municipal Water District rebate incentives program and promotion by the South Bay Cities Council of Governments Environmental Services Center.
ENHANCED IRRIGATION RUNOFF REDUCTION PROGRAM
Reductions to irrigation runoff help to achieve runoff volume reduction and associated pollutant load reductions. This BMP, which doubles as a water conservation initiative, incorporates good landscaping practices to limit irrigation runoff. Measures to reduce irrigation runoff can be implemented wherever landscapes are irrigated. Residential, commercial, recreational, and industrial land uses can be targeted by incentive policies and programs. The Peninsula WMG agencies already implement Water Efficient Landscaping ordinances. Additional implementation methods being implemented include:
• Municipal Landscape Retrofits converting municipal landscaping to drought tolerant, low irrigation landscaping
• Landscape Irrigation Efficiency Program for large landscape residential water users • Weather-based irrigation controller exchange events through West Basin Municipal Water District
• Turf Conversion Programs implemented through West Basin Municipal Water District to encourage the conversion of lawns and gardens to drought tolerant, low irrigation landscaping • California Friendly Landscape Workshops through West Basin Municipal Water district and South Bay Environmental Services Center
• Rain barrel distribution through South Bay Environmental Services Center The County of LA and the cities of Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, and Rolling Hills Estates are currently implementing this program.
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PUBLIC INFORMATION AND PARTICIPATION
DOWNSPOUT DISCONNECT PROGRAM
This Program encourages homeowners to redirect their downspouts to a rain garden or rain barrel program. This program is currently being implemented for the Peninsula WMG through the West Basin Municipal Water District and through the South Bay Cities Council of Governments website and direct outreach by individual agencies.
TARGETED OUTREACH
Within the Public Information and Education Program, targeted activity-specific residential outreach is conducted to address watershed priorities. This targeted outreach effort is focused on residential do-ityourself (DIY) auto, home improvement, and gardening activities and pet owner activities and is implemented through the promotion of successful existing workshops and programs and the development and dissemination of dual print/electronic outreach pieces targeted at residential activities for which City staff have identified a clear need. The Permittees will adapt the PIPP over time to address new information, water quality priorities and stormwater management program priorities – activities listed below provide examples of how the PIPP is currently being enhanced. The targeted residential outreach includes:
• Promotion of the CalRecycle Used Oil Collection and Filter Recycling Program • Promotion of sustainable landscaping, gardening and water efficiency programs offered through West Basin Municipal Water District
• Waste management and recycling outreach
• Promotion/hosting of household hazardous waste collection events • Development and distribution of outreach pieces including a dual print/digital mobile business tip card, small site construction brochure, and a print brochure showcasing Native and Drought Tolerant Plant Gardens and Landscapes on the Palos Verdes Peninsula • Maintenance and promotion of Environmentally Friendly Landscaping, Gardening and Integrated Pest Management outreach webpages
• Maintenance of California-friendly demonstration gardens throughout the Peninsula • Maintenance of pet waste stations in municipal parks
• Development and distribution of South Bay Homeowners Guide to Rainwater Harvesting • Dissemination of Wildfire Prevention materials from CalFire
HORSE MANURE MANAGEMENT
Where residential horse keeping is allowed, the Peninsula WMG agencies implement and enforce Horse Manure Management ordinances requiring the proper handling and disposal of horse manure to prevent its accumulation, runoff, or leaching. Peninsula WMG agencies that allow residential horse keeping also provide manure collection services through the solid waste contract. Additionally, public outreach materials describing stormwater BMPs for horse keeping are targeted to horse owners and equestrian businesses throughout the Peninsula. These efforts work to address pollutants generated from existing equestrian facilities which are a recognized source of nutrients. In Rolling Hills Estates, the completed Model Equestrian Center Project at the Peter Weber Equestrian Center (PWEC) serves an educational function in addition to the water quality improvements realized through retrofits to the facility.
Interpretive signage throughout the PWEC identifies horse keeping BMPs for owners of horses boarded 206
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at the facility, horse trainers, and children who attend pony camps at the facility (as well as their parents).
Pony camp materials used at the facility include worksheets on environmentally friendly horse keeping practices.
PUBLIC AGENCY ACTIVITIES
ENHANCED STREET SWEEPING
Improved street and median sweeping technology enhances the potential for wet weather pollutant load reductions for bacteria, metals, non-metal toxics, and nutrients. Increasing the sweeping frequency, increasing the area of impervious cover swept, or upgrading the sweeping equipment can result in an increase in pollutant load removal2
. Most of the Peninsula Agencies contract street sweeping to private companies. These companies have already phased in regenerative sweepers.
Regenerative air sweepers have the ability to clean a larger path than vacuum sweepers, can remove smaller debris more efficiently and release less exhaust and particulates back into the environment.
Generally speaking, regenerative air systems are more environmentally friendly than are vacuum sweepers. Regenerative air sweepers are similar to vacuum sweepers in that there is a suction tube located on one side of the sweeping head. However, the key difference between regenerative and vacuum sweepers is that, unlike vacuum sweepers which exhaust the particulate-laden used air back into the atmosphere, regenerative air sweepers work on a closed loop system. In most applications, they also are a better choice than are vacuum sweepers. As the regenerative air sweepers circulate the air on a continuous basis. 3
The cities of Palos Verdes Estates and Rancho Palos Verdes implement this Program. Additionally, the County of Los Angeles has incorporated regenerative sweepers in its street cleaning program.
ADOPT SEWER SYSTEM MANAGEMENT PLAN (SSMP)
All agencies are enrolled in the statewide Waste Discharge Requirements for Sanitary Sewer Systems, which required the development and implementation of a SSMP in mid-2009. The goal of the SSMP is to reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. This goal also addresses WQPs. Elements of the SSMP include:
• Sanitary sewer system operation and maintenance program • Design and performance provisions
• Overflow emergency response plan
• FOG Control Program
• System Evaluation and Capacity Assurance Plan
INCREASED STREET SWEEPING FREQUENCY OR ROUTES
This measure works to increase the street sweeping frequency, jurisdiction-wide or in high trashgenerating areas and/or include additional routes (e.g. center medians and intersections). 2 City of San Diego: San Diego River Watershed Comprehensive Load Reduction Plan – Appendix A: BMP Representation Summary (2012)
3 An Overview of Power Sweeping Equipment Technology (www.worldsweeper.com) 207
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REGULATORY INITIATIVES
BRAKE PAD REPLACEMENT PROGRAM
Efforts of the California Stormwater Quality Association (CASQA) and Sustainable Conservation led to the passage of the SB 346 legislation in 2010 and signed by the Governor on September 25, 2010. This legislation is a milestone that will significantly reduce the level of copper in metropolitan area waters throughout the state. SB 346 requires incremental reduction in the amount of copper in vehicle brake pads, which constitute the single largest source of copper in metropolitan environments4. Already in effect, new codes required on brake pads sold in California will provide information on copper content and a notice that on and after January 1, 2014 any motor vehicle brake friction materials sold in California must contain no more than 0.1 percent by weight of the following materials: cadmium and its compounds, chromium (VI) salts, lead and its compounds, mercury and its compounds, and asbestiform fibers.
According to industry data on brake pad copper content, “SB 346 should reduce annual statewide copper emissions by more than 1.2 million pounds per year and should reduce brake pad copper levels by about 95%”5
. Additionally, based on available information, which was largely developed through a lengthy collaboration among brake pad manufacturers, government agencies, and environmental groups in the Brake Pad Partnership, a preliminary estimate of copper runoff reduction due to this piece of legislation was developed.
In 2013, TDC Environmental prepared a draft detailed study for the California Stormwater Quality Association (CASQA) describing the expected percent reduction for copper as a result of the passage of SB 346 (TDC Environmental, 2013). The TDC study identified three possible implementation scenarios, the least aggressive of which estimated that a 52% load reduction in copper will be achieved by 2032 due to the brake pad phase-out.
Although there is an expectation that copper loads in urban runoff will decrease over time as a result of SB 346, the updated RAA did not attempt to take credit for this load reduction at this time. Following the collection of additional watershed-specific water quality data in the future, adaptive management may be utilized by the Peninsula WMG to update the TLR for copper and/or the load reductions expected to be achieved by this source control program.
LEAD REDUCTION PROGRAM
The SB 346 legislation was passed by the Senate, approved by the Governor, and filed with the Secretary of State on October 11, 2010. This bill prohibits the manufacture, sale, or installation in California of a wheel weight that contains more than 0.1% lead. Additionally, this bill requires that if the department identifies an alternative to lead contained in wheel weights as a chemical of concern, then the lead alternative would remain subject to the evaluation process, as prescribed, to determine how best to limit exposure or to reduce the level of hazard posed by the lead alternative.
Through the implementation of SB 757, a reduction in lead will be observed for the Peninsula WMG.
ZINC REDUCTION PROGRAM
The Department of Toxic Substances Control (DTSC) adopted new Safer Consumer Product Regulations that became effective October 1, 2013. These regulations contain a process for identifying and prioritizing Chemicals of Concern in Priority Products containing these constituents, as well as a process for eliminating or reducing the adverse impacts of Chemicals of Concern in Priority Products. It will apply to 4 Moran, Kelly. 2011. Brake Pad Copper Reduction – MRP Section C.13.c. Report 2011 5 Ibid. 208
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most consumer products placed into the stream of commerce in California. It specifically applies to adverse environmental impacts, including adverse water quality impacts, and it contains a petition process for identification and prioritization of chemicals and projects. CASQA, supported by Peninsula WMG, has started the process of conducting research and building a file of critical information to support the designation of zinc in tires as a future priority product/constituent combination.
Measures:
• As a watershed group, plan to work with others to use the Department of Toxic Substances Control’s Safer Consumer Product Regulations to reduce the zinc in tires, which is one of the greatest sources of zinc in urban areas.
ORDINANCES
WATER EFFICIENT LANDSCAPING ORDINANCE
The Peninsula WMG agencies implement and enforce water efficient landscaping ordinances to promote the design, installation, and maintenance of landscaping in a manner that conserves water resource and minimizes irrigation water runoff.
Additionally, the Peninsula Agencies jointly developed and have been distributing a tri-fold color brochure promoting Native & Drought Tolerant Plant Gardens and Landscapes on the Palos Verdes Peninsula. This brochure was developed with input from the Palos Verdes Peninsula Land Conservancy, Los Angeles County Fire Department and South Coast Botanic Garden staff.
GREEN BUILDING ORDINANCE
The City of Rancho Palos Verdes, the largest of the Peninsula WMG agencies, implements a Green Building Construction ordinance, effective January 1, 2014, that establishes incentives such as expedited plan review and fee reductions, and outlines procedures for participation in the agency’s voluntary green building program. This program encourages the design and development of single-family, multifamily residential, commercial, institutional and mixed-use projects that are sited, designed, constructed and operated to enhance the well-being of occupants, and to minimize negative impacts on the community and natural environment. In addition, all of the Peninsula WMG agencies have adopted or customized the 2010 California Green Building Standards Code.
The Green Building Ordnance is based on a point system in which a developer earns points for incorporating certain aspects of the program into their design. Some of the specific stormwater quality aspects of this program are identified below in Table 3.1-3 209
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Table 3.1-3: Green Building Ordinance Program Stormwater Quality Aspects Category Stormwater Benefit
Stormwater Control:
• Permeable Paving Material
• Filtration and/or Bio-Retention Features
• Non-Leaching Roofing Materials
• Smart Stormwater Street Design
• Rainwater Harvesting System
• Vegetated Roof
Encourages incorporation of stormwater BMPs which
directly benefits stormwater quality
Irrigation Control:
• Plants Grouped by Water Needs
• Resource Efficient Landscapes
• High-Efficiency Irrigation System
Reduces irrigation demand which subsequently
reduces dry weather flows
Impervious Area Reduction:
• Construction Footprint
• Minimal Turf in Landscape
• Trees
Reduces impervious areas which subsequently
reduces stormwater runoff
Non-toxic Materials Reduces exposed toxic materials during and after construction
Vandalism Deterrence Practices and
Vandalism Management Plan
Reduces the potential for vandalism which
subsequently reduces the potential for exposed
contaminants associated with vandalism (i.e. spray
paint, trash, etc.)
Pedestrian, bicycle, and public transit access
Reduces vehicle use which subsequently reduces
pollutants associated with vehicles (i.e. organics, oil, grease, metals, etc.)
Structural Pest Controls
Reduces likeliness of needing pest-control which
subsequently reduces potential for related
contaminants to be exposed to stormwater
Green Building Education Increases environmental awareness including stormwater quality
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WILDFIRE PREVENTION PROGRAM
There is a substantial body of research demonstrating that wildfires can be a significant source of pollutants in stormwater while also increasing stormwater runoff from burned areas. Consequently, the prevention of wildfires is an important control measure for preventing mobilization and increased discharge of pollutants in stormwater. The agencies have adopted the most recent fire standards in Title 32 of the Los Angeles County Code (Fire Code). These include more restrictive building standards relating to fire and public safety than those adopted by the State Fire Marshal in the California Building Code.
Because the Palos Verdes Peninsula is a very high fire hazard severity zone, CalFire encourages risk reduction through reduction of fire fuel, especially on properties adjacent to natural open space. The agencies offer green waste collection to residents through their solid waste franchise contracts to encourage the prompt removal of accumulated leaves and landscape debris to prevent brush fires which also minimizes the potential for leaching of nutrients from accumulated dead vegetation. The agencies disseminate information to residents on the management of landscapes for brush and fire control. 211
Appendix 3.2
Structural Best Management Practices (BMPs)
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3.2 STRUCTURAL BMP SUBCATEGORIES
Structural BMPs fall under a variety of subcategories that correspond to their function and water quality benefit. Some of the most common of these subcategories are described below. These subcategories will be used throughout the EWMP to describe existing, planned, and potential regional and distributed BMPs.
INFILTRATION BMPS
Infiltration BMPs allow for stormwater to percolate through the native soils and recharge the underlying groundwater table, subsequently decreasing the volume of water discharged to the downstream waterbodies. These BMPs must be constructed in areas where the native soils have percolation rates and groundwater levels appropriate for infiltration.
INFILTRATION BASIN
An infiltration basin consists of an earthen basin with a flat bottom. An infiltration basin retains stormwater runoff in the basin and allows the retained runoff to percolate into the underlying soils.
The bottom of an infiltration basin is typically vegetated with dryland grasses or irrigated turf grass.
INFILTRATION TRENCH
An infiltration trench is a long, narrow, rock-filled trench with no outlet other than for overflow.
Runoff is stored in the void space between stones and infiltrates through the bottom and sides of the trench. Infiltration trenches provide the majority of their pollutant removal benefits through volume reduction. Pretreatment is important for limiting amounts of coarse sediment entering the trench which can clog and render the trench ineffective.
INFILTRATION GALLERY
An infiltration gallery may consist of a modular, multi-chamber pre-cast concrete arch system usually installed below grade. An infiltration gallery retains stormwater runoff in the basin and allows the retained runoff to percolate into the underlying soils.
BIORETENTION WITH NO UNDERDRAIN
Bioretention facilities with no underdrain are landscaped shallow depressions that capture and infiltrate stormwater runoff. These facilities function as a soil and plant-based filtration device that removes pollutants through a variety of physical, biological, and chemical treatment processes. The facilities normally consist of a ponding area, mulch layer, engineered media, and vegetation. As stormwater passes down through the media, pollutants are filtered, adsorbed, and biodegraded by the soil and vegetation.
DRYWELL
Drywells are similar to infiltration trenches in their design and function; however, drywells generally have a greater depth to footprint area ratio and can be installed at relatively deep depths. A drywell is a subsurface storage facility designed to temporarily store and infiltrate runoff. A drywell may be either a small excavated pit filled with aggregate or a prefabricated storage chamber or pipe segment. 213
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POROUS PAVEMENT
Porous pavements (concrete, asphalt, and pavers) contain small voids that allow water to pass through to a gravel base. They come in a variety of forms; they may be a modular paving system (concrete pavers, grass-pave, or gravel-pave) or poured in place pavement (porous concrete, permeable asphalt). Porous pavements treat stormwater and remove sediments and metals within the pavement pore space and gravel base. While conventional pavement results in increased rates and volumes of surface runoff, properly constructed and maintained porous pavements allow stormwater to percolate through the pavement and enter the soil below. This facilitates groundwater recharge while providing the structural and functional features needed for the roadway, parking lot, or sidewalk. The paving surface, subgrade, and installation requirements of porous pavements are more complex than those for conventional asphalt or concrete surfaces.
BIOTREATMENT BMPS
Biotreatment BMPs treat stormwater through a variety of physical, chemical, and biological processes prior to being discharged to the MS4 system. These BMPs should be considered where Infiltration BMPs are infeasible.
BIORETENTION WITH UNDERDRAINS
Bioretention stormwater treatment facilities are landscaped shallow depressions that capture and filter stormwater runoff. These facilities function as a soil and plant-based filtration device that removes pollutants through a variety of physical, biological, and chemical treatment processes. The facilities normally consist of a ponding area, mulch layer, engineered media, and vegetation. As stormwater passes down through the media, pollutants are filtered, adsorbed, biodegraded, and sequestered by the soil and vegetation. Bioretention with underdrain systems are utilized for areas containing native soils with low permeability or steep slopes, where the underdrain system routes the treated runoff to the storm drain system.
VEGETATED SWALES
Vegetated swales are open, shallow channels with low-lying vegetation covering the side slopes and bottom that collect and slowly convey runoff flow to downstream discharge points. Vegetated swales provide pollutant removal through settling and filtration in the vegetation (usually grasses) lining the channels. In addition, although it is not their primary purpose, vegetated swales also provide the opportunity for volume reduction through subsequent infiltration and evapotranspiration and reduce the flow velocity. Where soil conditions allow, volume reduction in vegetated swales can be enhanced by adding a gravel drainage layer underneath the swale allowing additional flows to be retained and infiltrated. Where slopes are shallow and soil conditions limit or prohibit infiltration, an underdrain system or low flow channel for dry weather flows may be required to minimize ponding and convey treated and/or dry weather flows to an acceptable discharge point. An effective vegetated swale achieves uniform sheet flow through a densely vegetated area for a period of several minutes (depending on design standard used).
WET DETENTION BASIN
Wet detention basins are constructed, naturalistic ponds with a permanent or seasonal pool of water (also called a “wet pool” or “dead storage”). Aquascape facilities, such as artificial lakes, are a special form of wet pool facility that can incorporate innovative design elements to allow them to function as a stormwater treatment facility in addition to an aesthetic water feature. Wet ponds require base 214
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Appendix 3.2 - 3 | Page
flows to exceed or match losses through evaporation and/or infiltration, and they must be designed with the outlet positioned and/or operated in such a way as to maintain a permanent pool. Wet ponds can be designed to provide extended detention of incoming flows using the volume above the permanent pool surface.
DRY EXTENDED DETENTION BASIN
Dry extended detention basins are basins whose outlets have been designed to detain the stormwater runoff to allow particulates and associated pollutants to settle out. Dry extended detention basins do not have a permanent pool; they are designed to drain completely between storm events. They can also be used to provide hydromodification and/or flood control by modifying the outlet control structure and providing additional detention storage. The slopes, bottom, and forebay of Dry extended detention basins are typically vegetated.
PRE TREATMENT BMPS
Pre-treatment BMPs are typically not used as primary treatment; however, they are highly recommended for preliminary treatment in order to prolong the life and prevent clogging of the downstream system in a treatment train.
MEDIA FILTERS
Media filters are usually designed as multi-chambered stormwater practices; the first is a settling chamber, and the second is a filter bed filled with sand or another filtering media. As stormwater flows into the first chamber, large particles settle out, and then finer particles and other pollutants are removed as stormwater flows through the filtering medium. They can also be used as pretreatment, with their location prior to any infiltration or biotreatment BMP.
CATCH BASIN INSERTS
Catch basins inserts typically include a grate or curb inlet and a sump to capture sediment, debris, and pollutants. Filter fabric can also be included to provide additional filtering of particles. The effectiveness of catch basin inserts, their ability to remove sediments and other pollutants, depends on its design and maintenance. Some inserts are designed to drop directly into existing catch basins, while others may require retrofit construction. Similar to media filters, catch basin filters can also be used as a pre-treatment BMP for infiltration and biotreatment BMPs.
HYDRODYNAMIC SEPARATORS
Hydrodynamic separators are typically vertically oriented cylinders or rectangular vaults with baffles, weirs, and screens to direct flow to settle, separate and remove oil, sediment and floatables through the force of gravity. The effectiveness of hydrodynamic separators depends on its design and maintenance. Hydrodynamic separators are typically used in combination with other pre-treatment BMPs.
SEDIMENT CHAMBERS
Sediment chambers are typically wet detention basins allowing preliminary settling areas for large debris and sediment. As water reaches a predetermined level, it flows over a weir into bed of filter medium, usually composed of sand, soil, gravel, or a combination. The medium filters out small sediment and other pollutants.
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RAINFALL HARVEST
Rainfall Harvest BMPs capture rainwater to be reused in lieu of discharging directly to the MS4.
ABOVE GROUND CISTERNS
Cisterns are large above ground tanks that store stormwater collected from impervious surfaces for non-potable domestic consumption. Above ground cisterns are used to capture runoff. Mesh screens are typically used to filter large debris before the stormwater enters the cistern. The collected stormwater could potentially be used for landscape irrigation and some interior uses, such as toilets and washing machines. The collection and consumption of the stormwater results in pollution control, volume reduction, and peak flow reduction from the site.
UNDERGROUND RETENTION
Underground retention systems function similarly to above ground cisterns in that they collect and use stormwater from impervious surfaces. These systems are concealed underground and can allow for larger stormwater storage and capture additional impervious surfaces not easily captured in an above ground system (e.g. parking lots and sidewalks). Water is then infiltrated into the ground via medium, usually composed of sand, soil, gravel, or a combination.
DIVERSION SYSTEMS
Flow diversion systems collect and divert runoff, flow diversion structures can primarily be sued in two ways.
LOW FLOW DIVERSION
Low flow diversion structures may be used to direct dry weather or small wet weather flows to a treatment facility via the sanitary sewer system or to a infiltration system, preventing the low flows from reaching a receiving water body. This is typically done with low flow runoff, which occurs during periods of dry weather or for small rain events at the beginning and end of the wet season.
STORMWATER DIVERSION
Stormwater diversion structures can also be used to direct storm flows from the MS4 into other structural BMPs. For example, diverted flow can be fed into a regional BMP, which may include underground detention.
216
Appendix 4.1
Reasonable Assurance Analysis Report
217
Prepared for
Palos Verdes Peninsula Watershed Management Group
Reasonable Assurance Analysis
Revised Palos Verdes Peninsula EWMP 2021
Prepared by
Geosyntec Consultants, Inc.
6167 Bristol Parkway Ste 390
Culver City, CA. 90230
Project Number CWR0644
May 2022
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean i May 2022
TABLE OF CONTENTS
1. Introduction........................................................................................................... 1
2. Water Body Pollutant Combinations.................................................................... 2
3. Model Selection and Overview ............................................................................ 4
3.1. WMMS 2.0 LSPC........................................................................................ 4
3.1.1. Updating Weather Data .................................................................. 7
3.1.2. Adding Indicator Bacteria as a Modeled Constituent .................... 7
3.1.3. Use of Surrogate Pollutants............................................................ 8
3.1.4. Model Calibration and Validation.................................................. 8
3.1.5. Revising LSPC Sub-Basin Boundaries .......................................... 8
3.2. WMMS 2.0 SUSTAIN ................................................................................ 9
4. RAA Approach ................................................................................................... 10
4.1. Wet Weather RAA Approach.................................................................... 11
4.2. Dry Weather RAA Approach .................................................................... 12
5. Model Calibration and Validation ...................................................................... 13
5.1. Hydrologic Calibration.............................................................................. 14
5.2. Water Quality Calibration ......................................................................... 17
6. Critical Condition Definition.............................................................................. 21
6.1. Machado Lake ........................................................................................... 21
6.2. Wilmington Drain...................................................................................... 21
6.3. Los Angeles Harbor................................................................................... 21
7. Target Load Reductions...................................................................................... 22
7.1. Santa Monica Bay WMA .......................................................................... 22
7.1.1. Indicator Bacteria ......................................................................... 22
7.1.2. PCBs and DDT............................................................................. 22
7.1.3. Mercury and Arsenic .................................................................... 23
7.1.4. Trash and Marine Debris.............................................................. 23
7.2. Machado Lake WMA ................................................................................ 23 219
TABLE OF CONTENTS (Continued)
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean ii May 2022
7.2.1. Nutrients....................................................................................... 24
7.2.2. Pesticides and PCBs..................................................................... 25
7.3. Wilmington Drain WMA........................................................................... 26
7.3.1. Nutrients....................................................................................... 26
7.3.2. Pesticides and PCBs..................................................................... 26
7.3.3. Bacteria (E. coli)........................................................................... 27
7.4. Los Angeles Harbor WMA........................................................................ 27
7.4.1. Metals........................................................................................... 27
7.4.2. Pesticides and PCBs. .................................................................... 28
7.5. 85th Percentile, 24-Hour Design Storm Simulation................................... 28
7.6. Interim and Final Wet Weather TLR Summary ........................................ 28
8. Stormwater Control Overview............................................................................ 34
8.1. Methods to Select and Prioritize BMPs..................................................... 34
8.2. Quantified Non-Structural BMPs.............................................................. 34
8.2.1. Copper Brake Pad Reduction ....................................................... 35
8.3. Representing Structural BMPs.................................................................. 35
8.3.1. Regional and Distributed Structural Projects............................... 36
8.3.2. LID Redevelopment ..................................................................... 39
9. Wet Weather RAA Results................................................................................. 41
9.1. Machado Lake WMA ................................................................................ 41
9.2. Wilmington Drain WMA........................................................................... 45
9.3. Los Angeles Harbor WMA........................................................................ 49
10. Dry Weather RAA Result................................................................................... 53
10.1. Santa Monica Bay WMA .......................................................................... 53
10.2. Machado Lake WMA ................................................................................ 54
10.3. Wilmington Drain WMA........................................................................... 55
10.4. Los Angeles Harbor WMA........................................................................ 55
11. BMP Cost Opinion ............................................................................................. 55
12. Conclusions......................................................................................................... 57 220
TABLE OF CONTENTS (Continued)
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean iii May 2022
13. References........................................................................................................... 58
LIST OF TABLES
Table 1. Updated Waterbody Pollutant Combinations..................................................... 3 Table 2. Default BMPs Modeled in SUSTAIN................................................................ 9 Table 3. Calibration Metrics........................................................................................... 14 Table 4. Summary Calibrated Hydrology Modeling Parameters ................................... 15 Table 5. Model Performance Summary - Hydrology ..................................................... 15 Table 6. Summary of Calibrated FIB Modeling Parameters.......................................... 17 Table 7. Summary of Calibrated Total Nitrogen Loading Parameters........................... 18 Table 8. Summary of Calibrated Sediment Loading Parameters ................................... 18 Table 9. Summary of Calibrated Sediment-Associated Pollutant Parameters ............... 19 Table 10. Water Quality Model Calibration Summary .................................................. 19 Table 11. Final Wet Weather Target Load Reduction Summary ................................... 30 Table 12. Interim Wet Weather Target Load Reduction Summary................................ 33 Table 13. Summary of Modeled Project......................................................................... 38 Table 14. Redevelopment LID BMP Modeling Parameters........................................... 40 Table 15. Peninsula Machado Lake WMA (ML-1) RAA Summary.............................. 42 Table 16. Peninsula Wilmington Drain WMA RAA Summary..................................... 46 Table 17. Peninsula Los Angeles Harbor WMA RAA Summary.................................. 50 Table 18. Dry Weather RAA Summary ......................................................................... 53 Table 19. WMMS 2.0 Cost Function.............................................................................. 55 Table 20. Project Cost Opinion Summary...................................................................... 56
LIST OF FIGURES
Figure 1. HRU Overview for Peninsula EWMP Area...................................................... 5 Figure 2. Hydraulic Network, Subwatershed, and Weather Station Overview................ 6 Figure 3. Analysis Region Overview.............................................................................. 10 Figure 4. Dry Weather RAA Process ............................................................................. 12 Figure 5. Locations of CIMP Monitoring Stations Utilized for Calibration .................. 13 Figure 6. Comparison of Modeled and Monitored Flows at RHECH............................ 16 Figure 7. Total Nitrogen Concentration Comparison..................................................... 20 221
TABLE OF CONTENTS (Continued)
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean iv May 2022 Figure 8. Modeled Regional and Distributed Projects.................................................... 37 Figure 9. 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1)43 Figure 10. 24-Hour Management Volume Status in Machado Lake WMA (ML-1)...... 44 Figure 11. 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD1 and WD-Solano).......................................................................................................... 47 Figure 12. 24-Hour Management Volume Mapping in Wilmington Drain WMA (WD-1 and WD-Solano)............................................................................................................. 48 Figure 13. 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA. 51 Figure 14. 24-Hour Management Volume in Peninsula LA Harbor WMA................... 52
LIST OF ATTACHEMTNS
Attachment A Supplementary Calibration Exhibits
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 1 May 2022
1. INTRODUCTION
As specified in the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit1 (Permit), the Cities of Palos Verdes Estates, Rancho Palos Verdes, and Rolling Hills Estates, together with the County of Los Angeles and the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Palos Verdes Peninsula (Peninsula) Watershed Management Group (WMG), developed an Enhanced Watershed Management Program (EWMP) for their drainage areas within the Santa Monica Bay, Machado Lake (including Wilmington Drain) and Los Angeles Harbor watersheds. As a part of demonstrating progress and adaptive management, the Peninsula WMG is required to submit a revised EWMP to the Los Angeles Regional Water Quality Control Board (LARWQCB), including an updated Reasonable Assurance Analysis (RAA), by June 30, 2021.
This report has been prepared to summarize the approach and results of the revised RAA.
Building upon the original and revised updated plans in 2015 and 2018, the revised RAA has been conducted to conform to the original RAA guidelines developed by the LARWQCB (LARWQCB, 2014a). The revised RAA also provides updates to include recent monitoring data, project planning and implementation, and modeling advances over the past five years. Where appropriate, it also addresses issues and comments raised by the State Water Resources Control Board (SWRCB, 2020), such as inclusion of relevant data for model calibration, non-structural Best Management Practices (BMP) credit, and application of the limiting pollutant approach.
The updated wet weather RAA was conducted using the Watershed Management Modeling System 2.0 (WMMS 2.0), the latest modeling tool developed by LACFCD, to determine a cost-effective implementation strategy to meet applicable water quality standards (i.e., TMDL waste load allocations [WLA] and Basin Plan Objectives) and targets. This modeling platform was approved and endorsed by the LARWQCB as an acceptable regulatory approach for developing the RAA. WMMS 2.0 has the capability of representing wet and dry weather flow discharges, although based on a variety of factors, dry weather flows were not modeled using WMMS 2.0 as part of this effort. For dry weather, a revised semi-quantitative approach was implemented to update the dry weather portion of the revised RAA.
1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. 223
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 2 May 2022 The RAA was completed for the full geographic domain of the Peninsula EWMP area.
Unless otherwise noted, all Water Body Pollutant Combinations (WBPCs) identified in the Peninsula EWMP have been addressed as part of this revised RAA.
2. WATER BODY POLLUTANT COMBINATIONS
The WBPCs defined in the original Peninsula EWMP were revised based on the most recent updates to applicable TMDLs and 303(d) listings, as well as the available Coordinated Integrated Monitoring Program (CIMP) monitoring data. The updated WBPC list is summarized in Table 1.
As with the original Peninsula EWMP, this RAA was done to address all Category 1 WBPCs by meeting the interim and final MS4 waste load allocations (WLAs), and all Category 2 and 3 WBPCs where the Peninsula WMG may have caused or contributed to historical exceedances.
224
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 3 May 2022 Table 1. Updated Waterbody Pollutant Combinations
Category Pollutant
Waterbody
SMB(a) SMB
Beaches ML(b) WD(c) IH(d) CM(e)
1 Chlordane
(water, sediment, fish tissue) [1]
Wet
Dry
Copper
(water and sediment) [2]
Wet
Dry
Wet
Dry
DDT
(water, sediment, fish tissue) [2]
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Dieldrin
(water, sediment, fish tissue) [1]
Wet
Dry
Indicator Bacteria Wet
Dry
Lead
(water and sediment) [2]
Wet
Dry
Wet
Dry
Total Nitrogen[3] Wet
Dry
Total PAHs[2] Wet
Dry
Wet
Dry
PCBs
(water, sediment, fish tissue) [2]
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Total Phosphorus[3] Wet
Dry
Trash Wet Wet
Zinc
(water and sediment) [2]
Wet
Dry
Wet
Dry
2 Arsenic Wet
Dry
Indicator Bacteria Wet
Mercury Wet
Dry
3 Analysis of monitoring data from outfalls and receiving waters do not currently result in the identification of any Category 3 WBPCs
Abbreviations:
a = Santa Monica Bay, b = Machado Lake, c = Wilmington Drain, d = Inner Harbor, e = Cabrillo Marina Notes:
1. Machado Lake Pesticides and PCBs TMDL Water Quality Based Effluent Limits (WQBELs) for Chlordane and Dieldrin address the associated 303(d) listing for ChemA, therefore this listing is not shown in the table. Please refer to revised Peninsula EWMP Chapter 2 for additional descriptions.
2. The Dominguez Channel and Greater Los Angeles and Long Beach Harbor Toxics TMDL WQBELs for Total PAHs, Copper, DDT, Lead, PCBs and Zinc address associated 303(d) listings in harbor waterbodies for Toxicity, Benthic Community Effects, Benzo(a)pyrene, Chrysene, Dibenz[a,h]anthracene, Phenanthrene, and Pyrene, therefore these listings are not shown in the table. Please refer to revised Peninsula EWMP Chapter 2 for additional description.
3. Machado Lake Nutrient TMDL WQBELs for TN and TP address associated 303(d) listings for Algae, Ammonia, Eutrophic Conditions, and Odor, therefore these listings are not shown in the table. Please refer to revised Peninsula EWMP Chapter 2 for additional description. 225
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3. MODEL SELECTION AND OVERVIEW
While the original RAA leveraged the strengths of the Structural BMP Prioritization and Analysis Tool (SBPAT) to perform the wet weather modeling analysis, the revised RAA used the newly released WMMS 2.0 modeling platform to maintain consistency with the majority of RAAs across Los Angeles County. Developed by LACFCD and publicly released in May 2020, WMMS 2.0 utilizes remote sensing, water quality, and hydrology data collected through 2018 to simulate contaminant loading, runoff volume, and flow rate. WMMS 2.0 contains two major components: the Loading Simulation Program in C++ (LSPC) to determine hydrology and pollutant loading; and the System for Urban Stormwater Treatment and Analysis Integration (SUSTAIN) to assist in BMP selection and performance. Detailed descriptions of each model component are provided below).
An advantage of using the WMMS 2.0 model is the extensive regional calibration effort that has gone into the recent update of the model.
3.1. WMMS 2.0 LSPC
WMMS 2.0 LSPC (version 6.0) is capable of simulating watershed hydrology, sediment erosion and transport, and water quality processes from both upland contributing areas and receiving streams. Long-term, hourly rainfall data and average monthly evapotranspiration values are used along with land use-linked catchment imperviousness, soil properties, and land use-specific pollutant buildup/wash off rates to estimate wet weather runoff volumes and pollutant loading. WMMS 2.0 LSPC utilizes the following spatial and temporal data to conduct the simulation:
• Hydrologic response unit (HRU), which is a combination of:
o Soils
o Land cover
o Groundwater recharge potential
o Topography
o Land use
• Hydraulic network (dams, debris basins, spreading grounds, water reclamation plants, storm drains, open channels)
• Subwatershed/subbasin
• Hourly and spatially interpolated precipitation and evapotranspiration data.
Figure 1 illustrates the HRUs and the hydraulic network, and the subwatershed boundary of the Peninsula EWMP area. Figure 2 illustrates the weather station coverage for the Peninsula LSPC model.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 5 May 2022 Figure 1. HRU Overview for Peninsula EWMP Area
227
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 6 May 2022 Figure 2. Hydraulic Network, Subwatershed, and Weather Station Overview 228
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 7 May 2022 The default2 WMMS 2.0 LSPC model has been configured, calibrated, and validated through a regional approach against flow and water quality monitoring data collected at all Mass Emission Stations (MES) in Los Angeles County. The following pollutants are included in the downloaded version of the WMMS 2.0 platform:
• Total Nitrogen
• Total Phosphorus
• Total Zinc
• Total Lead
• Total Copper
• Total Cadmium, and
• Total Suspended Solids (TSS)
The application of this model provides an estimate of the target load reduction (TLR), a numerical expression of the Permit compliance metrics (e.g., allowed mass per day for metals for wet weather and allowable exceedance days per year for bacteria), that serves as a basis for confirming, with reasonable assurance, that implementation of the proposed stormwater runoff or dry weather best management practices (BMPs) will result in attainment of the applicable TMDL WLA based WQBELs in the Permit for Category 1 pollutants, or the Water Quality Objectives for Category 2 pollutants.
The subsections below summarize the modifications to the default WMMS 2.0 LSPC model that were used to conduct the revised RAA.
3.1.1. Updating Weather Data
The default WMMS 2.0 LSPC model database includes precipitation data up to September 2018. Additional hourly rainfall data collected up to June 2020 from Los Angeles County Automatic Local Evaluation in Real Time (ALERT) rain gauges were requested and amended to the model database in accordance with the default WMMS 2.0 rain gauge coverage assignment.
3.1.2. Indicator Bacteria as a Modeled Constituent
Because none of the default constituents in WMMS 2.0 LSPC model can be used as a surrogate pollutant for fecal indicator bacteria (FIB), a representative FIB had to be added to the model. HRU-specific event mean concentration (EMCs) for FIB were established using monitoring data collected via the Peninsula CIMP through June 2020. 2 The term “default” refers to the “as-downloaded” model released by LACFCD in May 2020. 229
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 8 May 2022 However, no bacteria modeling was necessary for the updated Peninsula RAA for the following reasons:
• While indicator bacteria is a Category 1 WBPC for the Santa Monica Bay and Santa Monica Bay Beaches, no modeling was required to demonstrate reasonable assurance of compliance in the Santa Monica Bay watershed since water quality data demonstrates compliance is already being achieved. See Section 7.1 for further details on the Santa Monica Bay watershed.
• While indicator bacteria is a Category 2 WBPC for Wilmington Drain, the Peninsula subwatersheds tributary to Wilmington Drain will be managed with 85th percentile regional projects. Therefore, bacteria modeling was not required for these subwatersheds. See Section 7.3 for further details on the Wilmington Drain watershed.
3.1.3. Use of Surrogate Pollutants
Pollutant load rate and concentration for WBPCs involving the seven default WMMS 2.0 LSPC model pollutants and the added indicator bacteria were obtained from the WMMS
2.0 LSPC output files directly. A subset of the directly modeled pollutants was used as surrogate pollutants to establish pollutant loading and concentration of pollutants not directly modeled in the WMMS 2.0 LSPC model. Details on surrogate pollutant selection and assignment are presented in Section 7.
3.1.4. Model Calibration and Validation
The default WMMS 2.0 LSPC model has been calibrated by LACFCD on a regional basis using data through September 2018. Geosyntec further calibrated and validated the WMMS 2.0 LSPC model using Peninsula CIMP monitoring data collected up to June 2020 to best reflect the baseline hydrology and water quality conditions within the Peninsula EWMP area. This date was selected as it marks the most recently complete CIMP annual reporting year, and therefore is inclusive of the latest available data that has been properly QC’d by the Peninsula WMG. Detailed information on the model calibration can be found in Section 5.
3.1.5. Revising LSPC Sub-Basin Boundaries
Since the default LSPC subwatershed boundaries were developed at a regional scale and cover the entire Los Angeles Basin, they were found to contain some minor inaccuracies at the finer spatial resolution used for the revised RAA. As part of the revised RAA process, the subwatershed boundaries were refined to more accurately reflect the drainage boundaries within the Peninsula EWMP area.
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3.2. WMMS 2.0 SUSTAIN
Utilizing hourly hydrograph and pollutograph outputs from LSPC, WMMS 2.0 SUSTAIN (version 2.1) provided estimates of water balance such as volumes evapotranspired, diverted, captured, treated, and/or released by various BMPs, as well as a conceptually optimal spatial distribution of BMPs based on cost-effectiveness to achieve TLR goals. WMMS 2.0 SUSTAIN also has a batch-processing framework to inform selection, configuration, and placement of BMPs throughout a watershed-based on defined evaluation criteria, such as cost and TLR. The default WMMS 2.0 SUSTAIN model was used to determine the estimated performance of BMPs summarized in Table
2. Table 2. Default BMPs Modeled in SUSTAIN
BMP Type Performance Type
Distributed BMP
Bioretention/biofiltration (with
optional underdrain) Volume reduction and flow-through treatment Pervious pavement Volume reduction and flow-through treatment Cistern/Rain barrel Volume reduction
Drywell Volume reduction
Proprietary treatment unit Flow-through treatment
Regional BMP
Infiltration gallery Volume reduction
Retention/detention basin Volume reduction and flow-through treatment Constructed wetland Volume reduction and flow-through treatment Sewer diversion Volume reduction
Regional treatment facility Flow-through treatment
For the revised RAA, WMMS 2.0 SUSTAIN was used to estimate the performance of existing and proposed distributed and regional BMPs, thereby assuring that an effective and suitable suite of stormwater management BMPs is implemented to meet applicable interim and final TLR goals. This approach is therefore used to demonstrate a reasonable assurance of compliance for all modeled WBPCs. Details on modeled BMPs can be found in Section 8.
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4. RAA APPROACH
Consistent with the original Peninsula EWMP RAA, the revised RAA was completed for the Peninsula EWMP analysis regions. An analysis region is defined by one of the following conditions:
1. A subwatershed that drains to a compliance monitoring location (CML) (e.g. WD1)
2. Area tributary to the open beach between two CMLs (SMB-7-03_7-04)
3. Area tributary to an existing waterbody (e.g. LAH-IH) As shown in Figure 3, there are 16 analysis regions in the Peninsula EWMP area. Among the analysis regions in the Dominguez Channel – Los Angeles Harbor HUC-12 watershed, analysis regions WD-Solano and WD-1 are tributary to Machado Lake via Wilmington Drain. Analysis region ML-1 is tributary to Machado Lake directly. Analysis regions LAH-IH and LAH-CM are tributary to Los Angeles Inner Harbor and Cabrillo Marina respectively.
Figure 3. Analysis Region Overview
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4.1. Wet Weather RAA Approach
The approach for representing wet weather flows and pollutant management for the RAA, including model determination and calibration, data inputs, critical condition selection calibration performance criteria, and output types, were selected for consistency with the RAA Guidance Document (LARWQCB, 2014b), as well as the functionality of WMMS
2.0. The process for determining the wet weather RAA included the following sequential steps for the Peninsula EWMP area:
1. Identify current WBPC list, including all quantifiable parameters requiring model simulation.
2. Revise, as needed, the contributing MS4 service areas to represent the Peninsula EWMP (e.g. remove lands or areas not required to be analyzed and adjust boundaries to match at a more detailed scale). This includes land owned and operated by Caltrans and the 85th-percentile 24-hour storm runoff retention area in City of Rolling Hills.
3. For analysis regions draining to a CML, review the Peninsula CIMP and SMBBB TMDL monitoring data and assess if the analysis region is already in compliance.
Remove analysis regions that area in compliance based on monitoring data.
4. Perform hydrologic and water quality calibration on the WMMS 2.0 LSPC model using Peninsula CIMP outfall monitoring data.
5. Identify WBPC-specific critical conditions.
6. Develop TLRs for identified WBPCs during the respective critical condition.
7. Identify the following with respect to structural and non-structural BMPs:
a. Significant variations to BMPs accounted for in the original Peninsula EWMP (e.g., differences in LID implementation levels);
b. Exclude original Peninsula EWMP projects that were found to be technically infeasible at the scale originally proposed, such as the Valmonte Regional BMP and Palos Verdes Landfill Regional BMP; c. Identify new BMPs that have been implemented since 2014 and were not accounted for in the original EWMP; and
d. Identify new BMPs that are planned for implementation and were not accounted for in the original EWMP.
8. Evaluate the pollutant load reductions of existing and proposed BMPs.
9. Compare these estimates with the final TLRs.
10. Revise the BMP implementation scenarios until all final TLRs are met, thereby reasonably assuring compliance with wet weather permit goals. 233
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4.2. Dry Weather RAA Approach
Consistent with the original EWMP RAA, a semi-quantitative approach was implemented as summarized in Figure 4 to perform dry weather RAA and to demonstrate reasonable assurance of meeting applicable permit goals.
Figure 4. Dry Weather RAA Process
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5. MODEL CALIBRATION AND VALIDATION
The default WMMS 2.0 LSPC watershed model was configured, calibrated, and validated by LACFCD through a regional approach against flow and water quality monitoring data collected at all Los Angeles County Mass Emission Stations (MES) between water years 2008 and 2018 (LACFCD, 2020a). Geosyntec further calibrated the model using Peninsula CIMP wet weather outfall flow and water quality data collected through June 2020. The calibrated Peninsula LSPC model was used as the foundation for performing the wet weather RAA. Figure 5 shows the CIMP monitoring locations used in model calibration and validation.
Figure 5. Locations of CIMP Monitoring Stations Utilized for Calibration 235
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 14 May 2022 Calibrations were performed to meet the specifications of the RAA Guidelines Document (LARWQCB, 2014b), which are summarized in Table 3. Consistent with the regional WMMS 2.0 calibration process, percent bias (PBIAS) is the primary statistic used to evaluate the agreement between modeled-predicted and observed data. PBIAS quantifies systematic over- or under-prediction. Low values of PBIAS indicate a better fit. The lower bound of the “Fair” threshold is the minimum acceptable criteria for the model calibration. If a “Fair” threshold is not met during the model validation process, additional model adjustments are made to attain the threshold at the validation site. If such effort is not successful, additional investigations such as site monitoring investigations or further data collection would be completed to examine potential issues in the modeled and monitored data.
Table 3. Calibration Metrics
Category
Percent Difference Between Model-Predicated and Observed Data (PBIAS) Very Good Good Fair
Hydrology /
Flow ±0 – 10% >±10% - 15% >±15% - 25%
Sediment ±0 – 20% >±20% - 30% >±30% - 40%
Water Quality ±0 – 15% >±15% - 25% >±25% - 35%
Pesticides /
Toxics ±0 – 20% >±20% - 30% >±30% - 40%
Details of the calibration and validation approach and results are presented in the following subsections.
5.1. Hydrologic Calibration
The objective of hydrologic calibration is to compare observed and model-predicted wet weather flow rates at monitoring sites and achieve a “Fair” agreement or better for the computed PBIAS metric.
As part of the Peninsula CIMP, continuous year-round flow data is collected at the Rolling Hills Estates City Hall (RHECH) and Valmonte outfall monitoring sites. For the remaining outfall monitoring sites, flow monitoring data is collected only during wet weather events, which is also when water quality samples are collected. With the exception of RHECH, the available wet weather flow rates were either too sporadic or too low, with no more than 15% of recorded wet weather flow above 0.1 cubic feet per second (cfs). As a result, and to avoid overly reducing runoff generation parameters, the hydrologic calibration only utilized continuous wet weather flow data collected at the RHECH monitoring site.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 15 May 2022 The hydrologic calibration required the evaluation of subsurface storage, infiltration, and groundwater recession modeling parameters. The calibration was performed by iteratively applying multipliers to HRU-specific modeling parameters. It should be noted that the majority of the Peninsula EWMP area first drains to vegetated natural canyons, where a significant portion of the runoff is detained and infiltrated prior to reaching downstream monitoring locations. This finding is consistent with the observation of the low flow rates at monitoring locations during the majority of the wet weather events. To account for the natural canyons throughout the Peninsula EWMP area, it is assumed that a fraction of the surface runoff is infiltrated in the natural canyons. The numeric value of the fraction was iteratively determined along with other HRU-specific modeling parameters until satisfactory calibration criteria were met. The resulting hydrology parameter ranges are presented in Table 4.
Table 4. Summary Calibrated Hydrology Modeling Parameters Parameter Description Unit Peninsula Model
Range of Values
INFILT Index to Infiltration Capacity in/hr 0.4-8
AGWRC Base groundwater recession none 0.99
INTFW Interflow inflow parameter - 0.05-0.1
IRC Interflow inflow recession
parameter - 0.03
ROUTE_SURO Fraction of surface runoff
routed to the stream - 0.15
Notes: For hydrologic parameters not listed in the table, the default WMMS 2.0 model values were used without modification.
Table 5 presents a summary of the statistical results of the hydrologic calibration.
Calculations of R2
, NSE, and PBIAS were based on a comparison of modeled and observed daily flow. For the PBIAS metric, all modeled flows were within or better than the “Fair” percent difference range, achieving the minimum acceptable criteria for the Regional Board RAA Guidance. R2 and NSE are supplementary hydrological calibration metrics and show an acceptable correlation between modeled and observed flow data.
Table 5. Model Performance Summary - Hydrology
Calibration
Metrics
Comparison Locations
RHECH
PBIAS +19.2
To further evaluate the temporal trends of the hydrology calibration, comparisons between model and observed monthly flows were evaluated by examining the time series 237
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 16 May 2022 plots and the average monthly flows between November 2016 and June 2020. See Figure
6. Figure 6. Comparison of Modeled and Monitored Flows at RHECH 238
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5.2. Water Quality Calibration
The RAA Guideline requires water quality calibration based on available monitoring data from each analysis region over the most recent 10 years. The default WMMS 2.0 LSPC watershed model has been regionally calibrated and validated using data collected at Los Angeles County MES and CIMP receiving water monitoring stations throughout the Los Angeles County between water years 2008 and 2018. Building upon such effort, Geosyntec further calibrated the LSPC model using water quality data collected at Peninsula CIMP outfall monitoring locations shown in Figure 5. Modeling was completed for the following constituents:
• E. coli
• Total Suspended Solids (TSS)
• Nutrients – Total nitrogen and total phosphorus
• Metals – Total copper, total lead, and total zinc.
As discussed in Section 3.1.2, FIB representation was added to the WMMS 2.0 LSPC model to demonstrate compliance to water quality objectives that are expressed in exceedance days. HRU-specific land use bacteria EMCs from WMMS 1.0 were adopted as the starting point of the calibration. The next step in the calibration process was an iterative application of multipliers to EMCs across all HRUs. Specifically, the FIB modeling parameters were calibrated against E. Coli monitoring data collected at outfall site RHECH. The calibrated parameters are summarized in Table 6.
Table 6. Summary of Calibrated FIB Modeling Parameters
Parameter Description Units Peninsula Model
Range of Values
SOQC
Concentration of
constituent in surface
outflow
MPN/
100mL 500 – 45,500
IOQC
Concentration of
constituent in interflow
outflow
MPN
/100mL 500 – 45,500
Note: For parameters not listed in the table, the default WMMS 2.0 model values were used.
Total nitrogen was modeled as a non-sediment-associated pollutant in WMMS 2.0 LSPC.
The total nitrogen build-up/wash-off parameter values are summarized in Table 7. 239
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 18 May 2022 Table 7. Summary of Calibrated Total Nitrogen Loading Parameters Parameter
Name Description Units Peninsula Model Values
ACQOP Accumulation rate of
total nitrogen on surface lb/acre/day 0 - 3
SQOLIM Maximum storage of
total nitrogen on surface lb/acre 0 - 12
Although TSS is not a pollutant of concern for the Peninsula EWMP area, it is a representative pollutant for sediment-associated pollutant simulation in LSPC. TSS load can be used as a surrogate for organic pollutants of concern that are not modeled directly in LSPC (i.e. PAHs, DDT, and PCBs). TSS calibration was performed by iteratively applying multipliers to HRU-specific parameter associated with sediment load buildup on the land surface. The range of values for TSS build-up/wash-off parameters are summarized in Table 8.
Table 8. Summary of Calibrated Sediment Loading Parameters Parameter
Name Description Units
Peninsula
Model Range
of Values
ACCSDP
Rate at which solids
accumulate on the land
surface
lb/acre/day 0 – 0.016
KSER
Coefficient in the
detached sediment wash
off equation
- 0 - 2
Note: TSS associated parameters that are not listed in the table, the default WMMS 2.0 model values were used without modification.
Metals and total phosphorous were modeled in WMMS 2.0 LSPC as sediment-associated pollutants. Calibration for metals was performed by iteratively applying HRU specific multipliers to LSPC model parameters associated with metal potency factors in order to maintain the same relative ratios among HRUs determined in the regionally calibrated WMMS 2.0 LSPC model. The model values associated with metal potency factors are summarized in Table 9.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 19 May 2022 Table 9. Summary of Calibrated Sediment-Associated Pollutant Parameters Pollutant Parameter
Name Description Units
Peninsula
Model
Range of
Values
Total Copper POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 0.4
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 0.4
Total Lead POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 0.09
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 0.09
Total Zinc POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 2.1
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 2.1
Total
Phosphorus
POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 6.4
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 6.4
Note: For parameters not listed in the table, the default WMMS 2.0 model values were used without modification.
Table 10 presents a summary of results for water quality calibration. Calculations of PBIAS are based on a comparison of modeled and observed daily average concentration at each outfall monitoring site. In reference to the RAA Guideline calibration metrics summarized in Table 3, all modeled pollutant concentrations were within the range for “Very Good” agreement with observed data.
Table 10. Water Quality Model Calibration Summary
Calibration
Metric
Pollutants RHECH
PBIAS
E. coli -2.9
TSS 14
Total Copper 1.4
Total Lead 7.1
Total Zinc 4.9
Total Nitrogen -2.0
Total Phosphorus 6.7
To further evaluate the temporal trends of the water quality calibration, comparisons between modeled and observed monthly flows were assessed using the time series plots of flows between November 2016 and June 2020. Please see Attachment A for the 241
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 20 May 2022 resultant comparison plots. The time series plots for total zinc concentration is shown in Figure 7 as an example. The remaining time series plots are included in Attachment A.
Figure 7. Total Nitrogen Concentration Comparison.
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6. CRITICAL CONDITION DEFINITION
Consistent with RAA Guideline Document (LARWQCB, 2014b), the RAA was performed on the critical conditions defined in the applicable TMDLs. Determination of the critical conditions is summarized in the subsections below.
6.1. Machado Lake
The final MS4 WLAs in Machado Lake Nutrient TMDL and Machado Lake Pesticides and PCBs TMDL were both calculated based on the average water year, which is used as the critical condition for the wet weather RAA. LACFCD performed a hydrologic analysis to define the “average” water year during the WMMS 2.0 model development.
Water Year 2010 was identified as the representative average water year in the Dominguez Channel watershed3 based on analysis of the most recent 10-years of rainfall data (LACFCD, 2020c). As such, Water Year 2010 was used as the critical condition to establish wet weather nutrient and organic pollutant TLRs in the Peninsula Machado Lake watershed management area (WMA)
6.2. Wilmington Drain
Wilmington Drain WMA is a subwatershed tributary to Machado Lake. As explained in Section 6.1, Water Year 2010 represents the average water year and was used as the critical condition to establish wet weather nutrient and organic pollutants in the Peninsula Wilmington Drain WMA.
6.3. Los Angeles Harbor
According to the Dominguez Channel and Greater Los Angeles and Long Beach Harbor Toxics TMDL (herein referred as the “Los Angeles Harbor Toxics TMDL”), the MS4 WLAs to Los Angeles Harbor waterbodies were calculated based on average annual condition. As such, the average water year was used as the critical condition to establish wet weather TLRs for metals and toxics pollutants. Again, Water Year 2010 was used as the critical wet weather condition.
3 Both Machado Lake and Wilmington Drain WMAs are subwatershed to the HUC-12 Dominguez Channel Watershed.
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7. TARGET LOAD REDUCTIONS
The following subsection documents the development of wet weather and year-round4 TLRs for each of the Peninsula EWMP WMAs for all modeled WBPCs. A justification for WBPCs that did not require modeling to demonstrate compliance to applicable water quality standard are also provided. The dry weather RAA process, as described in Section
4.2 using the decision tree, do not require development of dry-weather specific TLRs.
Section 10 summarizes the dry weather RAA results.
7.1. Santa Monica Bay WMA
Wet weather WBPCs in the Santa Monica Bay WMA include bacteria, trash and marine debris, PCBs, DDT, mercury, and arsenic. No modeling was conducted within the Santa Monica Bay WMA for the updated RAA, as reasonable assurance of compliance is already demonstrated via monitoring data.
7.1.1. Indicator Bacteria
The five SMBBB shoreline CMLs established for the Peninsula EWMP area (SMB 7-1 through 7-5) historically demonstrated fewer exceedance days than the reference beach (Leo Carrillo) used in TMDL development and were therefore considered antidegradation sites when the TMDL was developed. The five Peninsula shoreline monitoring sites were sampled for indicator bacteria along the Palos Verdes Peninsula shoreline on a weekly basis. Data collected up through June 2020 indicate that exceedance of wet weather single sample limits are infrequent. All five sites generally averaged less than one exceedance day above the annual wet weather allowable exceedance days over the past 10 years, except during the 2016-17 rainy season which was wetter than the critical year. Given these findings, zero TLR were determined for analysis regions tributary to SMB-7-1 through 7-5. This is consistent with the TMDL’s approach that acknowledges that historic bacteria exceedance rates for each of these subwatersheds are, on average, lower than that of the reference beach.
7.1.2. PCBs and DDT
For PCBs and DDT, the WLAs for the entire Santa Monica Bay watershed were determined as equal to the existing estimates of annual loads for DDTs and PCBs.
Therefore, consistent with the TMDL, it is assumed that there is a required load reduction of zero for PCBs and DDT, and no RAA is required. Additionally, four complete years of nearshore receiving water quality data have been collected under the Peninsula CIMP 4 Year-round TLRs that account for both wet and dry weather TLRs were only developed for area with observed non-exempt dry weather flow.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 23 May 2022 in the Santa Monica Bay and analyzed for total DDT and PCBs. Of these dry and wetweather samples collected, only one (1) out of forty (40) samples or 2.5% resulted in detection of 4,4’- DDT at a concentration between the method detection limit and the reporting limit. This sample was collected during a summer dry weather sampling event in the fourth year of CIMP monitoring. None of the forty (40) receiving water samples collected over the past four years have resulted in detections of Total PCBs above the Ocean Plan objective for total PCBs. This data further validates the conclusion that the Peninsula WMG is in compliance with the TMDL MS4 WLA for total DDTs and total PCBs, and no RAA is needed for these WBPCs.
7.1.3. Mercury and Arsenic
Mercury and arsenic were recently added to the 303(d) list for Santa Monica Bay based on sediment and fish tissue data collected under the Hyperion Treatment Plant NPDES Permit no. CA0109991 between January 2006 and June 2010. There’s no existing data or evidence tying either of these pollutants to stormwater MS4 discharges. Arsenic and mercury have been added to the outfall monitoring sites for the Santa Monica Bay in response to recent 303(d) listings, however insufficient data are available to support the need for RAA.
7.1.4. Trash and Marine Debris
Compliance with the Santa Monica Bay Debris TMDL will be met through a phased retrofit of catch basins throughout the Peninsula Santa Monica Bay WMAs. Trash exclusion devices, along with trash source controls to meet each interim compliance deadline and the final compliance deadline are the management controls planned to achieve compliance. Hence, these constituents do not require a TLR to be calculated and were not modeled as part of the revised RAA.
7.2. Machado Lake WMA
Wet weather and year-round pollutants of concern in the Machado Lake watershed include trash, PCBs, DDT, total chlordane, dieldrin, total nitrogen, and total phosphorus.
Compliance with the Machado Lake Trash TMDL has been met through retrofit and ongoing maintenance of catch basins throughout the Machado Lake WMAs with trash exclusion devices. Hence, trash does not require a TLR and was not modeled as part of the revised RAA. TLRs for the remaining WBPCs were established using the calibrated WMMS 2.0 LSPC model. While the model is only capable of representing a subset of the WBPCs directly, justifications were provided to establish TLRs for the other WBPCs to comply with the State Board’s requirement to demonstrate attainment of water quality standards for all compliance targets (SWRCB, 2020).
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7.2.1. Nutrients
The final MS4 WLAs for total nitrogen and total phosphorus are expressed in the following two ways in the Machado Lake Nutrients TMDL:
• Monthly average WQBEL concentration.
• Annual average pollutant load calculated as the WQBEL concentration multiplied by the annual average inflow to the Machado Lake (8.45 HM3 /year) apportioned
to each WMA tributary to Machado Lake (directly or via Wilmington Drain). This method was initially established in the Los Angeles County Machado Lake Nutrient TMDL Special Study (LACDPW, 2011) following conditional approval of the work plan by LARWQCB (LARWQCB, 2010).
Of the two acceptable compliance pathways, the annual average pollutant load method was selected to determine the allowable load in subsequent TLR calculations.
The following approach was implemented to calculate a TLR for total nitrogen and total phosphorus in Peninsula Machado Lake WMA:
1. The analysis region was modeled in LSPC for water year 2010 in order to obtain the baseline wet weather pollutant load. The number of wet days during the modeled year were also defined based on the precipitation data.
2. For analysis regions with observed dry weather flow, the baseline dry weather pollutant load was estimated by multiplying the average measured daily dry weather flow from water year 2010 by the average dry weather pollutant concentrations.
3. For analysis regions without observed dry weather flow as determined through the non-stormwater outfall screening and source investigation report (Peninsula WMG, 2018), the dry weather pollutant load was assumed to be zero.
4. The total baseline load was computed by summing the dry weather and wet weather pollutant load computed in Step 1 and 2.
5. The allowable load was calculated as the WQBEL concentration multiplied by the annual average inflow to the Machado Lake (8.45 HM3/year) apportioned to the analysis region tributary to the Machado Lake.
6. The difference between the annual baseline load (step 4) and the annual allowable load (step 5) resulted in a TLR for the average water year, which was the load reduction required to meet the allowable TMDL concentration.
7. A TLR equivalent 24-hour runoff management volume was estimated as the following:
a. First, estimate the annually managed runoff volume by dividing the TLR by the annual baseline runoff volume.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 25 May 2022 b. Next, add an in-stream diversion to a hypothetical retention BMP with a 24- hour drawdown time at the outlet of analysis region and iteratively size until the diverted (and hence managed) runoff volume is equal to or greater than the annually managed runoff volume. The retention volume of this hypothetical retention BMP was determined to be the 24-hour runoff management volume. Both load-based TLRs and the equivalent 24-hour runoff management volumes are considered acceptable Peninsula EWMP compliance metrics
7.2.2. Pesticides and PCBs
PCBs, DDT, total chlordane, and dieldrin are Category 1 WBPCs in the Machado Lake WMA due to inclusion in the Machado Lake Pesticides and PCBs TMDL. The final MS4 WLA in the TMDL is expressed as the annual loading of pollutants calculated as the sediment-based WQBEL multiplied by the annual TSS load.
These pollutants cannot be modeled directly in WMMS 2.0 LSPC. Instead, TSS was modeled and used as a surrogate to compute the TLR based on data demonstrating the amount of pollutant associated with TSS particulates.
The following approach was implemented to calculate a TLR for each organic pollutant in the Peninsula Machado Lake WMA.
1. The analysis region was modeled in LSPC to obtain TSS load during water year 2010.
2. Particulate strength (organic-to-TSS ratio) for PCBs, DDT, total chlordane, and dieldrin were calculated using paired wet weather monitoring data collected at outfall monitoring within the Machado Lake and Wilmington Drain WMAs.
3. The baseline pollutant load was computed by multiplying the baseline TSS load and the organic pollutant particulate strength.
4. An average baseline pollutant concentration was computed as the annual baseline
5. The allowable load was calculated as the sediment-based WQBEL multiplied by the annual TSS load.
6. The difference between the baseline load and the allowable load resulted in a TLR for water year 2010 was the load reduction required to meet the applicable water quality standard.
7. A TLR equivalent 24-hour (daily) runoff management volume was estimated as the following:
a. First, estimate the annually managed TSS load by dividing the TLR by the particulate strength.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 26 May 2022 b. Next, an in-stream diversion to a large hypothetical retention BMP with a 24-hour drawdown time at the outlet of analysis region was iteratively sized until the diverted (and hence managed) TSS load equal to or greater than the annually managed TSS load. The retention volume of this hypothetical retention BMP was deemed as the 24-hour runoff management volume. Both load-based TLR and the equivalent 24-hour runoff management volume are considered eligible Peninsula EWMP compliance metrics.
7.3. Wilmington Drain WMA
Wilmington Drain is an impaired waterbody that drains to Machado Lake. Hence, WBPCs applicable to the Machado Lake WMA (trash, PCBs, DDT, total chlordane, dieldrin, total nitrogen, and total phosphorus) are also applicable to the Wilmington Drain WMA. In addition, Wilmington Drain is a 303(d) listed receiving water for bacteria (E. coli), making this a Category 2 WBPC for the Wilmington Drain WMA.
Compliance with the Machado Lake Trash TMDL has been met through a phased retrofit of catch basins throughout the Wilmington Drain WMA. Therefore, trash does not require a TLR and was not modeled as part of the revised RAA. TLRs for the remaining pollutants of concern were established using the calibrated WMMS 2.0 LSPC model.
While the model is only capable of modeling a subset of WBPCs directly, a justification was provided to how the TLRs were developed for the other WBPCs in order to demonstrate the attainment of water quality standards for all compliance targets (SWRCB, 2020).
7.3.1. Nutrients
Due to inclusion in the Machado Lake Nutrients TMDL, total nitrogen and total phosphorous are Category 1 WBPCs in Wilmington Drain. The same approach described in Section 7.2.1 was used to establish TLRs and TLR-equivalent 24-hour runoff management volumes for total nitrogen and total phosphorus.
7.3.2. Pesticides and PCBs
Due to inclusion in the Machado Lake Toxic TMDL, PCBs, DDT, total chlordane, and dieldrin are Category 1 WBPCs in the Machado Lake WMA. The same calculation approach described in Section 7.2.2 was used to determine TLRs and TLR-equivalent 24- hour management volumes for PCBs, DDT, total chlordane, and dieldrin TLRs. 248
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7.3.3. Bacteria (E. coli)
Although Wilmington Drain is a 303(d)-listed waterbody for bacteria, modeling was not conducted as part of the updated RAA due to the fact that the Wilmington Drain watershed area will be fully captured and managed via 85th percentile regional projects.
If future bacteria modeling is conducted, it will account for the latest State Board guidance regarding the statistical threshold value (STV) as well as local applications of this standard.
7.4. Los Angeles Harbor WMA
Wet weather pollutants of concern in the Los Angeles Harbor watershed include PCBs, DDT, total copper, total lead, total zinc, and PAHs. TLRs were established using the calibrated Los Angeles Harbor LSPC model. While the model is only capable of representing a subset of WBPCs directly, justification was provided to establish TLRs for the other WBPCs in order to comply with the State Board’s requirement to demonstrate the attainment of water quality standards for all compliance targets (SWRCB, 2020).
7.4.1. Metals
Due to inclusion in the Dominguez Channel and Greater Los Angeles Harbor Toxics and Metals TMDL, total copper, total lead, and total zinc are considered Category 1 WBPCs for the two Los Angeles Harbor waterbodies the Peninsula EWMP area drains to (Inner Harbor and Cabrillo Marina). The final MS4 WLA in the TMDL are expressed in the following three ways:
1. Annual loading of pollutants calculated as the California Toxics Rule (CTR) saltwater chronic criteria-based water-column WQBEL concentration multiplied by the average annual flow volume.
2. Annual loading of pollutants calculated as the sediment-based WQBELs multiplied by the annual average TSS loading. The WQBEL is based on the Los Angeles Region Water Quality Control Plan to address the TMDL. It is adopted from the sediment numeric targets developed in the Screening Quick Reference Tables (SQuiRTs) developed by National Oceanic and Atmospheric Administration (NOAA).
3. Annual mass-based MS4 WLA apportioned to Peninsula WMG’s tributary areas to the Los Angeles Harbor.
According to the MS4 Permit Attachment N, all three approaches are acceptable to demonstrate TMDL compliance. Method 2 was used as the allowable load in subsequent TLR calculations. The same calculation approach described in Section 7.2.2 was used to 249
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 28 May 2022 establish TLRs and TLR-equivalent 24-hour management volumes for total copper, total lead, and total zinc, with one modification to Step 3. This modification did not require development of particulate strengths as the metal loads can be directly represented in WMMS 2.0 LSPC model.
7.4.2. Pesticides and PCBs.
Because of the Dominguez Channel and Greater Los Angeles Harbor Toxics and Metals TMDL, PCBs, DDT, total chlordane, and dieldrin are defined as Category 1 WBPCs for the two Los Angeles Harbor waterbodies draining the Peninsula EWMP area (Inner Harbor and Cabrillo Marina). The same calculation approach described in Section 7.2.2 was used to establish TLRs and TLR-equivalent 24-hour management volumes for PCBs, DDT, total chlordane, and dieldrin.
7.5. 85th Percentile, 24-Hour Design Storm Simulation
As an alternative path of demonstrating compliance with the MS4 Permit, the Peninsula WMG evaluated the option of fully capturing the 85th percentile, 24-hour design storm runoff from each WMA. The hydrology simulation was performed using the calibrated Peninsula WMMS 2.0 LSPC model. LACFCD has included the 85th percentile design storm hyetograph as part of the WMMS 2.0 database. The design storm depth for the Peninsula WMG varies from 0.8 to 1.1 inches (LACDPW, 2006).
7.6. Interim and Final Wet Weather TLR Summary
Final TLRs were developed for each modeled pollutant using the established numeric targets. TLRs are listed by analysis region for each modeled WBPC in Table 11. WBPCs for both Machado Lake and Wilmington Drain are applicable to analysis regions in the Wilmington Drain WMA (WD-1 and WD-Solano). WBPCs for the Machado Lake are applicable to analysis regions in the Machado Lake WMA (ML-1). WBPCs for the Los Angeles Harbor are applicable to the analysis regions of the Los Angele Harbor WMAs and. Specifically, WBPCs are apportioned to the Inner Harbor (LAH-IH) and to Cabrillo Marina (LAH-CM).
For the Machado Lake and Wilmington Drain WMAs, the calculation yielded zero total PCBs TLRs in all analysis regions. This is consistent with the recent CIMP monitoring, which showed no exceedance of total PCBs in the past five years. The calculation also yielded zero total nitrogen TLRs for all analysis regions and yielded zero total phosphorus TLRs for WD-Solano. A 1% total phosphorous TLR was calculated for ML-1 and a 14% total phosphorus TLR was calculated for WD-1. The primary reason of the resultant zero or little total nitrogen and total phosphors TLRs is the that the calibrated model, which reflected Peninsula WMG’s watershed management over the past decade, significantly 250
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 29 May 2022 showed reduction in wet weather runoff and associated less total nitrogen and total phosphorus load in comparison to the baseline condition used in the development of total nitrogen and total phosphorus MS4 WLAs in the TMDL. For the non-zero TLRs in the Machado Lake WMA, all the TLR-equivalent 24-hour management volumes are less than the 85th percentile, 24-hour design storm runoff volume. As a result, the recommended approach is to meet the final TLRs rather than trying to meet the full 85th percentile, 24- hour design storm runoff capture alternative. For the Machado Lake analysis region, the largest 24-hour management volume was selected as the target compliance metric, since management of the largest volume will result in management of all others. For the Wilmington Drain WMA, since bacteria was not modeled, and 85th percentile 24-hour design storm capture projects are planned for both tributary analysis regions the full 85th percentile, 24-hour runoff volume is shown as the compliance volume.
For analysis regions in the Los Angeles Harbor WMA, the 85th percentile, 24-hour design storm runoff volume of each analysis region is less than the maximum TLR-equivalent 24-hour runoff management volumes in that analysis region. Therefore, the recommended approach is to meet the full 85th percentile, 24-hour runoff capture alternative.
251
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 30 May 2022 Table 11. Final Wet Weather Target Load Reduction Summary Subwatershed
Analysis Region
Pollutant Critical Condition Baseline Load
Final Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent
24-Hour
Management
Volume
(ac-ft)
Machado Lake
ML-1
Total PCBs Average Water Year 7.5E-04 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 1.0E-03 lb/yr 9.0E-04 lb/yr 88% 1.3 DDT (All congeners) Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0 DDE (All congeners) Average Water Year 6.4E-04 lb/yr 5.7E-04 lb/yr 89% 1.3[1] DDD (All congeners) Average Water Year 6.3E-04 lb/yr 5.2E-04 lb/yr 82% 1.1 Total Chlordane Average Water Year 2.1E-04 lb/yr 1.3E-04 lb/yr 64% 0.7 Dieldrin Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0 Total Nitrogen Average Water Year 119 lb/yr 0 lb/yr 0% 0.0 Total Phosphorus Average Water Year 38.4 lb/yr 0.4 lb/yr 1% 0.1 n/a 85th Percentile 24-Hour Storm 1.6 ac-ft 1.6 ac-ft 100% 1.6 Machado Lake - Wilmington Drain
WD-1
Total PCBs Average Water Year 3.6E-03 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 4.9E-03 lb/yr 4.3E-03 lb/yr 88% 7.4 DDT (All congeners) Average Water Year 6.0E-05 lb/yr 0.0E+00 lb/yr 0% 0.0 DDE (All congeners) Average Water Year 3.1E-03 lb/yr 2.7E-03 lb/yr 89% 7.4 DDD (All congeners) Average Water Year 3.1E-03 lb/yr 2.5E-03 lb/yr 82% 6.2 Total Chlordane Average Water Year 9.9E-04 lb/yr 6.3E-04 lb/yr 64% 4.2 Dieldrin Average Water Year 5.6E-05 lb/yr 0 lb/yr 0% 0.0 Total Nitrogen Average Water Year 1510 lb/yr 0 lb/yr 0% 0.0 Total Phosphorus Average Water Year 346 lb/yr 47.2 lb/yr 14% 0.6 n/a 85th Percentile 24-Hour Storm 8.01 ac-ft 8.01 ac-ft 100% 8.0[1] WD-Solano
Total PCBs Average Water Year 2.07E-04 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 2.84E-04 lb/yr 2.5E-04 lb/yr 88% 0.5 DDT (All congeners) Average Water Year 3.47E-06 lb/yr 0 lb/yr 0% 0.0 DDE (all congeners) Average Water Year 1.77E-04 lb/yr 1.6E-04 lb/yr 89% 0.5 DDD (All congeners) Average Water Year 1.76E-04 lb/yr 1.4E-04 lb/yr 82% 0.4 252
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 31 May 2022 Subwatershed Analysis Region Pollutant Critical Condition Baseline Load
Final Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent
24-Hour
Management
Volume
(ac-ft)
Total Chlordane Average Water Year 5.72E-05 lb/yr 3.6E-05 lb/yr 64% 0.3 Dieldrin Average Water Year 3.21E-06 lb/yr 0 lb/yr 0% 0.0 Total Nitrogen Average Water Year 42 lb/yr 0 lb/yr 0% 0.0 Total Phosphorus Average Water Year 9 lb/yr 0 lb/yr 0% 0.0 n/a 85th Percentile 24-Hour Storm 0.57 ac-ft 0.57 ac-ft 100% 0.6[1] Los Angeles Harbor
LAH - IH
Total Copper Average Water Year 8.1 lb/yr 4.5 lb/yr 55% 2.2[2] Total Lead Average Water Year 1.7 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 33.5 lb/yr 17.4 lb/yr 52% 2.0 4,4'-DDT Average Water Year 1.3E-05 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 4.7E-03 lb/yr 4.6E-03 lb/yr 96% 10.4 Total PCBs Average Water Year 3.5E-03 lb/yr 1.0E-03 lb/yr 30% 0.9 Total PAHs Average Water Year 4.4E-01 lb/yr 9.8E-03 lb/yr 2% 0.1 n/a 85th Percentile 24-Hour Storm 5.4 ac-ft 5.4 ac-ft 100% 5.4[1] LAH-CM
Total Copper Average Water Year 1.8 lb/yr 0.87 lb/yr 49% 0.5[2] Total Lead Average Water Year 0.4 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 8.2 lb/yr 4.1 lb/yr 50% 0.5 4,4'-DDT Average Water Year 3.3E-06 lb/yr 0 lb/yr 0% 0.0 DDx (Total) Average Water Year 1.2E-03 lb/yr 1.2E-03 lb/yr 96% 2.8 Total PCBs Average Water Year 8.8E-04 lb/yr 2.6E-04 lb/yr 30% 0.3 Total PAHs Average Water Year 1.1E-01 lb/yr 2.5E-03 lb/yr 2% 0.1 n/a 85th Percentile 24-Hour Storm 1.5 ac-ft 1.5 ac-ft 100% 1.5[1] [1] Bold value is the representative 24-hour management runoff volume for each analysis region. For WD-1 and WD-Solano, the 85th percentile, 24-hour storm volume is selected since bacteria was not modeled.
[2] TLR for Total Copper does not account for expected reductions over time due to copper brake pad phase-outs in California. See Section 8.2.1. 253
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 32 May 2022 To demonstrate compliance with interim TMDL WLAs, interim TLRs were developed for Category 1 pollutants that have non-zero TLRs as shown in as summarized in Table
11. No interim TLRs were developed for pollutants without an interim TMDL numeric target. The resultant interim TLRs are summarized in Table 12.
As shown in the table, the calculation yielded zero interim TLRs for all analysis regions in the Machado Lake and Wilmington Drain WMA. For analysis regions in the Los Angele Harbor WMA, no RAA is required to demonstrate compliance with the interim MS4 WLA because receiving water monitoring shows the 3-year average pollutants are below the RWLs at Inner Harbor and Cabrillo Marina for all pollutants of concern (Anchor QEA, 2019).
254
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 33 May 2022 Table 12. Interim Wet Weather Target Load Reduction Summary WMA
Analysis
Region
Pollutant Critical Condition Baseline Load Allowable
Interim Load
Interim Target Load
Reduction
TLR
Equivalent
24-Hour
Management
Volume (acft)
Absolute
% of
Baseline
Load
Machado
Lake
ML-1
Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved Total Phosphorus Average Runoff Year 38.4 lb/yr 475 lb/yr 0 lb/yr 0% 0.0 Machado Lake -
Wilmington Drain
WD-1
Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved Total Phosphorus Average Runoff Year 346 lb/yr 3,731 lb/yr 0 lb/yr 0% 0.0 WD -
Solano
Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved Total Phosphorus Average Runoff Year Final TLR = 0%, hence RAA achieved Los Angeles Harbor
LAH - IH
Total Copper
Receiving water monitoring shows compliance with all interim RWLs. Hence no RAA needed.
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
LAH-CM
Total Copper
Receiving water monitoring shows compliance with all interim RWLs. Hence no RAA needed Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
255
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 34 May 2022
8. STORMWATER CONTROL OVERVIEW
8.1. Methods to Select and Prioritize BMPs
To demonstrate reasonable assurance, dry weather and stormwater runoff BMPs were identified in a prioritized manner to meet the TLRs. Prioritization was based on cost (lowcost BMPs were prioritized first); BMP effectiveness for the pollutants of concern (BMPs that had greater treatment efficiency for the pollutant of concern in a particular analysis region were prioritized over other BMPs); and implementation feasibility as determined by the Peninsula WMG.
Because recent monitoring data was used during calibration, it was assumed that the calibrated baseline model effectively accounted for existing BMPs that were already present in the Peninsula EWMP area (e.g., implementation of street sweeping, catch basin and storm drain cleaning, and low impact development projects completed prior to June 2020, etc.). Since drainage area to the monitoring location utilized for hydrology and water quality calibration does not contain any existing regional stormwater BMPs or green streets, the effects of regional or green street BMPs were not used for calibration.
The performance of existing, location specific regional BMPs has been quantified in this revised RAA.
The RAA was performed according to the following steps:
1. Calculate load reductions associated with existing structural regional and distributed BMPs;
2. Calculate load reductions for proposed regional and distributed BMPs that were identified in existing plans; and
3. If necessary, identify additional BMP capacity needed to meet any remaining TLR for each analysis region.
8.2. Quantified Non-Structural BMPs
In accordance with the State Board Order (SWRCB, 2020), all non-structural BMP credits are required to be adequately justified. Since data is limited with respect to load reductions achieved by most non-structural BMPs, this revised RAA incorporated the assumption that non-structural BMPs implemented prior to June 2020 (including enhanced minimal control measures [MCMs]) have been accounted for as part of the data used in the calibrated baseline condition. As a result, no “blanket” non-structural BMP load reduction credit has been incorporated into the revised RAA. 256
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 35 May 2022 Source controls implemented by the Peninsula WMG included a combination of BMPs such as new or enhanced pet waste controls (ordinance, signage, education/outreach, mutt mitts, etc.), enhanced street sweeping (e.g., 100% vacuum sweepers, increased frequency, posting of ‘No Parking’ signs for street sweeping, etc.), increased catch basin and storm drain cleaning, and other new or enhanced non-structural BMPs that target the pollutants addressed in the EWMP. Although no separate pollutant load reduction was calculated in the RAA for the implementation of these BMPs, the RAA assumes that the Peninsula WMG will continue to implement a variety of these targeted non-structural BMPs.
One specific non-structural regulatory BMP program was accounted for in this revised RAA for which a load reduction could be quantified and forecasted based on phased implementation – the elimination of copper in brake pads.
8.2.1. Copper Brake Pad Reduction
In 2010, California Senate Bill 346 (SB 346) was enacted to eliminate nearly all use of copper in brake pad manufacturing. In 2013, TDC Environmental prepared a draft detailed study for the California Stormwater Quality Association (CASQA) describing the expected percent reduction for copper as a result of the passage of SB 346 (TDC Environmental, 2013). The TDC study identified three possible implementation scenarios, the least aggressive of which estimated that a 52% load reduction in copper will be achieved by 2032 due to the brake pad phase-out.
Although there is an expectation that copper loads in urban runoff will decrease over time as a result of SB 346, the updated RAA did not attempt to take credit for this load reduction at this time. Following the collection of additional watershed-specific water quality data in the future, adaptive management may be utilized by the Peninsula WMG to update the TLR for copper and/or the load reductions expected to be achieved by this source control program.
8.3. Representing Structural BMPs
To represent structural BMPs, WMMS 2.0 SUSTAIN was used to account for BMP storage, infiltration, inflow, and outflow capacities using available BMP as-built drawings or conceptual drawings provided by the Peninsula WMG. For structural BMPs that provide flow-through treatment, the treatment efficacy was represented as either fixed effluent concentration or as a percentage of influent concentration reduction extracted from the following data sources:
• WMMS 2.0 Phase II Report: BMP Model and Optimization Framework (LACFCD, 2020b), which includes effluent concentrations of BMPs included in the default WMMS 2.0 SUSTAIN model.
257
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 36 May 2022 • The International Stormwater Database (IBMPDB; www.bmpdatabase.org), which is a comprehensive source of BMP performance information, comprised of data from a peer-reviewed collection of studies that have monitored the effectiveness of a variety of BMPs in treating water quality pollutants for multiple land use types.
8.3.1. Regional and Distributed Structural Projects
Through the project screening and evaluation process, a total of four regional projects and four distributed projects were modeled in the RAA, Table 13 summarizes project types and key modeling parameters. Project locations and tributary areas to these projects are shown in Figure 8.
The following regional structural projects are planned to receive Peninsula WMG runoff but were not modeled due to uncertainty of their future design and performance:
• Walteria Basin Special Study: Walteria Basin is a flood control basin that receives runoff from 174 acres of drainage area (which includes 55 acres of impervious area) from Palos Verdes Estates in analysis region WD-Solano. The Peninsula WMG will continue working with LACFCD and the City of Torrance to assess how the Walteria Basin can be utilized as part of a regional stormwater capture project in conjunction with other regional projects in the Machado Lake watershed to meet TLRs in the WD-Solano analysis region. • Palos Verdes Multi-Benefit Flow Diversion Project. This project is currently proposed as a dry weather flow management project within analysis region WD1. A wet weather flow management component will be further evaluated if additional wet weather projects are required to meet the final TLR through the Peninsula EWMP adaptive management process.
• Harbor City Park Stormwater Capture Project. This project is a signature regional project proposed by the Dominguez Channel WMG. It is hydrologically connected to the Torrance Airport Stormwater Capture Project and can potentially capture and treat excess stormwater runoff from analysis region WD-1. The Peninsula WMG is interested in collaborating with the Dominguez Channel WMG to share in the benefits of reduced load if additional wet weather projects are required to meet the final TLR through the Peninsula EWMP adaptive management process.
258
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 37 May 2022 Figure 8. Modeled Regional and Distributed Projects
259
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 38 May 2022 Table 13. Summary of Modeled Project
Analysis
Region Project Lead WMG
Member BMP Type Drainage Area (ac)
Impervious
Drainage
Area (ac)
BMP
Volume
(ac-ft)
Infiltration
/Treatment
Capacity
WD-1
Torrance Airport
Stormwater Basin
Project Phase II
Rancho Palos
Verdes and
Torrance[1]
Subsurface Detention &
Diversion to Sewer
74 (PVE) 15 (PVE)
21 2.2 cfs
678 (RPV) 263 (RPV)
1,113 (RHE) 539 (RHE)
441 (LAC) 112 (LAC)
Rolling Hills Road
Street Improvement
Rolling Hills
Estate Pervious Pavement 0.4 (RHE) 0.4 (RHE) 0.04 1 in/hr ML-1
Casaba Estates LID Rolling Hills
Estate Surface Retention Basin 28 (RHE) 7 (RHE) 0.4 0.9 in/hr Rolling Hills Country
Club Regional LID
Project – West
Rolling Hills
Estate
Surface Retention &
Infiltration Basin 358 (RHE) [2] 60 (RHE) 3.8 482 in/hr Rolling Hills Country
Club Regional LID
Project – East
Rolling Hills
Estate
Surface Retention &
Infiltration Basin 51 (RHE) 2.0 (RHE) 0.7 1.3 in/hr
Palos Verdes Drive
East Street
Improvement
Rolling Hills
Estate Pervious Pavement 2.6 (RHE) 0.5 (RHE) 0.3 1 in/hr LAH-IH Eastview Park
Regional Project
Rancho Palos
Verdes
Subsurface Retention,
Treatment and Diversion 345 (RPV) 123 (RPV) 1.2 0.6 cfs [1]The Peninsula WMG has agreed to collaborate with City of Torrance to utilize this project to receive and manage stormwater runoff form Peninsula EWMP area. [2]Does not include non-Peninsula EWMP drainage area.
PVE = Palos Verdes Estates; RPV = Rancho Palos Verdes; RHE = Rolling Hills Estates: LAC = Unincorporated Los Angeles County 260
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 39 May 2022
8.3.2. LID Redevelopment
The 2012 MS4 Permit established new criteria for redevelopment projects, requiring certain sized projects to capture, retain, or infiltrate the 85th percentile, 24-hr design storm or the 0.75-inch design storm, whichever is greater, or treat 150% of the peak stormwater runoff rate resulting from a 1-year, 1-hour design storm, via the implementation of low impact development (LID) BMPs. All LID BMPs constructed through June 2020 were assumed to be accounted for in the model via the monitoring and calibration process.
Moving forward, LID was assumed to be implemented at the annual redevelopment rate of 0.038% per year. In accordance with this redevelopment rate, which was summarized in the 2019-20 Peninsula WMG Annual Watershed Report (Peninsula WMG, 2020), redevelopment that is subject to an LID ordinance was modeled assuming an annual redevelopment of 0.038% per year across all Peninsula WMG agency jurisdictions for residential, commercial, industrial, institutional, and transportation land uses. To estimate load reductions associated with these redevelopment BMPs, the land use percentages were multiplied by the respective land use areas in each analysis region. This resulted in a calculated area that would be treated by LID BMPs each year. This area was multiplied by the applicable number of years until the TMDL final deadlines, as LID BMPs will be implemented each year at the assumed rate. The total land use area assumed to be redeveloped for each analysis region was then modeled as being treated by assumed BMPs and the total load reduction was quantified.
To maintain consistency with the BMP types observed in redevelopment activities todate in the Peninsula EWMP area, 52% of the redeveloped land is projected to implement bioretention or similarly functioning systems that fully capture the on-site 85th percentile, 24-hour storm runoff. The remaining 48% of the redeveloped area will implement biofiltration systems that treat 1.5 times on-site 85th percentile 24-hour storm runoff.
Modeling parameters of the bioretention and biofiltration units are summarized in Table
14. 261
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 40 May 2022 Table 14. Redevelopment LID BMP Modeling Parameters
Bioretention Biofiltration
Max Years of
Redevelopment
Modeled
5 years[1] (Machado Lake and Wilmington Drain)
12 years[2] (Los Angeles Harbor)
Pond Depth 12 inches
Infiltration Rate 5 in/hr n/a
Soil Depth (in) 24
Effluent Concentration
Total Copper n/a 5.7 ug/L[3]
Total Lead n/a 0.32 ug/L[3]
Total Zinc n/a 12 ug/L[3]
TSS n/a 10 mg/L[3]
E. coli n/a See footnote 4 1 5 years was assumed based on the expected coverage length of the MS4 Permit. 2 Based on the effect year of the final Dominguez Channel and Los Angeles Harbor Toxic TMDL (2032).
3 Default WMMS 2.0 SUSTAIN Parameter for Biofiltration BMP (LACFCD, 2020b) 4 It is assumed that biofiltration BMP does not provide significant E. coli treatment. 262
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 41 May 2022
9. WET WEATHER RAA RESULTS
9.1. Machado Lake WMA
Load reduction calculations for the Machado Lake WMA (analysis region ML-1) are summarized in Table 15. Through the RAA, the collective load reductions achieved by all existing and proposed BMPs were equal to or greater than all the TLRs within the analysis region. Hence, reasonable assurance was demonstrated.
As discussed in Section 7, a TLR-equivalent 24-hour stormwater management volume was computed for each non-zero TLR. Through the RAA, the 24-hour management volume achieved by a project was computed as the representative volume apportioned to the load reduction that was or would be achieved by the project. The resultant 24-hour management volume of a project may or may not be equal to its static detention capacity shown in Table 13. The approach of tying the 24-hour management volume metric to TLR result in prioritizing more efficient BMPs that provide more load reduction per BMP capacity. The 24-hour management volume of each project, and the cumulative 24-hour management volume achieved by all projects, are shown in Figure 9. As shown in the figure, for each analysis region, the cumulative 24-hour management volume achieved by all projects exceed the maximum 24-hour management need in each analysis region.
Hence, reasonable assurance was also demonstrated throughout the Machado Lake WMA using the 24-hour runoff volume as the compliance metric.
To spatially represent the RAA output, the 24-hour management volume is illustrated in Figure 10. The 24-hour management volume of a regional project was reflected to its drainage area. In addition to the existing and proposed projects discussed in Section 8.3.1, two additional projects (ML-1 RHE Project and ML-1 RPV Project) were necessary to meet the 24-hour management volume requirement. Although these two projects were not explicitly modeled in the RAA, they are intended to manage drainage areas that do not drain to modeled projects (i.e. non-horizontally shaded area) in Figure 10 and provide the 24-hour management volume specified in Figure 9.
263
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 42 May 2022 Table 15. Peninsula Machado Lake WMA (ML-1) RAA Summary Analysis Region
Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
LID Redevelopment Regional Projects[2] Distributed Projects Total Load Reduction Assurance
Achieved?
Absolute % Absolute % Absolute % Absolute % Absolute %
ML-1a
Total PCBs 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a DDx (Total) 9.0E-04 lb/yr 88% 2.3E-06 lb/yr 0.2% 8.8E-04 lb/yr 85% 3.1E-05 lb/yr 3.0% 9.0E-04 lb/yr 88% Yes DDT (All
congeners) 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a DDE (all
congeners) 5.7E-04 lb/yr 89% 1.4E-06 lb/yr 0.2% 5.5E-04 lb/yr 85% 1.9E-05 lb/yr 3.0% 5.7E-04 lb/yr 89% Yes DDD (All
congeners) 5.2E-04 lb/yr 82% 1.4E-06 lb/yr 0.2% 5.1E-04 lb/yr 79% 1.9E-05 lb/yr 3.0% 5.2E-04 lb/yr 82% Yes Total
Chlordane 1.3E-04 lb/yr 64% 4.6E-07 lb/yr 0.2% 1.3E-04 lb/yr 63% 6.2E-06 lb/yr 3.0% 1.4E-04 lb/yr 66% Yes Dieldrin 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a Total
Nitrogen 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a Total
Phosphorus 0.4 lb/yr 1% 0.1 lb/yr 0.2% 24.4 lb/yr 63% 1.1 lb/yr 2.9% 25.6 lb/yr 67% Yes 24-Hour
Management
Volume[1]
1.3[3] ac-ft 100% 0.003 ac-ft 0.2% 1.25 ac-ft 96% 0.04 ac-ft 0.4% 1.3 ac-ft 100% Yes [1] The 24-hour management volume is the equivalent runoff management volume that will achieve all TLRs. It does not necessarily equate to BMP capacity. A project located at analysis region outlet may have more 24-hour management capacity than a project with same BMP capacity but is located further upstream in the analysis region. The 24-hour management volume of a project needs to be computed via a continuous modeling simulation using the calibrated Peninsula EWMP WMMS 2 model
[2] Regional projects include existing and proposed projects discussed in Section 8.3.1 and the estimated benefit of the additional project (ML-1 RHE Project and ML1 RPV Project) [3] Please see Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region. 264
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 43 May 2022 Note:
RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates
Due to comparatively low volumes, LID redevelopment is not shown in the figure Figure 9. 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1)
265
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 44 May 2022 Figure 10. 24-Hour Management Volume Status in Machado Lake WMA (ML-1). 266
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 45 May 2022
9.2. Wilmington Drain WMA
As discussed in Section 7.6, the 85th percentile, 24-hour storm runoff volume was determined as the compliance metric for the Peninsula Wilmington Drain subwatershed (analysis regions WD-1 and WD-Solano). To demonstrate reasonable assurance, the cumulative 24-hour management capacity of planned stormwater control measures shall be equal to or greater than the 85th percentile, 24-hour storm runoff volume for each analysis region.
The 24-hour management capacity of the existing and planned stormwater control measures are summarized in Table 16. The 24-hour management volume breakdown by project category and Peninsula WMG agency is shown in Figure 11. To spatially represent the RAA output, the 24-hour management volume is also illustrated in Figure 12 where the 24-hour management volume of a regional project was reflected to its drainage area. For analysis region WD-Solano, the Peninsula WMG will continue to work with LACFCD and the City of Torrance to assess how the Walteria Basin can be utilized as a part of a regional stormwater capture project. The combination of these controls will be designed to achieve the TLRs in the WD-Solano analysis region in the areas without existing projects as shown in Figure 12.
267
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 46 May 2022 Table 16. Peninsula Wilmington Drain WMA RAA Summary
Analysis
Region
85th Percentile
24-Hour Runoff
Volume
BMP Load Reduction Summary
LID Redevelopment Regional Project Distributed Project Total Load Reduction RAA
Achieved?
Absolute % Absolute % Absolute % Absolute %
WD-1 8.0 [1] ac-ft 100% 0.02 ac-ft 0.6% 8.0 ac-ft 100% <0.01 ac-ft 0% 8.0 ac-ft 100% Yes WDSolano 0.6[1] ac-ft 100% <0.01 ac-ft 0.5% 0.6[2] ac-ft 100% 0 ac-ft 0% 0.6 ac-ft 100% Yes [1]Please see Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region. [2] Includes the Walteria Basin Special Study for analysis region WD-Solano. It is assumed that the Peninsula WMG will continue working with LACFCD and City of Torrance to assess how the Walteria Basin can be utilized as part of a regional stormwater capture project in conjunction with other regional projects in the Wilmington subwatershed to meet TLRs in the WD-Solano analysis region. 268
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 47 May 2022 Note:
PVE = Palos Verdes Estates; RPV =Rancho Palos Verdes; RHE = Rolling Hills Estates. LAC = Unincorporated Los Angeles County
Due to comparatively low volumes, LID redevelopment distributed projects are not shown in the figure Figure 11. 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD-1 and WD-Solano)
269
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 48 May 2022 Figure 12. 24-Hour Management Volume Mapping in Wilmington Drain WMA (WD-1 and WD-Solano)
270
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 49 May 2022
9.3. Los Angeles Harbor WMA
As discussed in Section 7.6, the 85th percentile, 24-hour storm runoff volume was determined as the compliance metric for the Peninsula Los Angeles Harbor WMA (analysis regions LAH-IH and LAH-CM). To demonstrate reasonable assurance, the cumulative 24-hour management capacity of planned stormwater control measures shall be equal to or greater than the 85th percentile, 24-hour storm runoff volume for each analysis region.
The 24-hour management capacity of the existing and planned stormwater control measures are summarized in Table 17. The 24-hour management volume breakdown by project category and Peninsula WMG agency is shown in Figure 13. To spatially represent the RAA output, the 24-hour management volume is also illustrated in Figure 14, where the 24-hour management volume of a regional project was reflected to its drainage area.
As shown Figure 13 and Figure 14, three additional projects (LAH-IH RPV Project, LAH-IH RHE Project and LAH-CM RPV Project) were necessary to fully capture the 85th percentile, 24-hour runoff from the non-horizontal shaded area shown in the figure.
The 24-hour management volume need of each of the additional projects is quantitatively shown in Figure 13. As shown in Table 17, the cumulative management capacity of the Eastview Park Regional Project, LID redevelopment and the three additional regional projects are sufficient to fully capture the 85th percentile, 24-hour storm from both analysis regions in the Los Angeles Harbor WMA. Hence, reasonable assurance is demonstrated.
271
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 50 May 2022 Table 17. Peninsula Los Angeles Harbor WMA RAA Summary
Analysis
Region
85th Percentile
24-Hour Runoff
Volume
BMP Load Reduction Summary
LID Redevelopment Regional Project Distributed Project Total Load Reduction RAA
Achieved?
Absolute % Absolute % Absolute % Absolute %
LAHIH 5.4 [1] ac-ft 100% 0.03 ac-ft 0.6% 5.4 ac-ft 100% 0 ac-ft 0% 5.4 ac-ft 100% Yes LAHCM 1.5[1] ac-ft 100% <0.01 ac-ft 0.5% 1.5 ac-ft 100% 0 ac-ft 0% 1.5 ac-ft 100% Yes [1]Please see Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region. 272
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 51 May 2022 Note: RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates Due to comparatively low volumes, LID redevelopment is not shown in the figure Figure 13. 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA.
273
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 52 May 2022 Figure 14. 24-Hour Management Volume in Peninsula LA Harbor WMA 274
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 53 May 2022
10. DRY WEATHER RAA RESULT
The dry weather RAA was completed in accordance with the approach outlined in Section
4.2. The Peninsula WMG has attempted to eliminate non-exempt dry weather MS4 discharges using a suite of structural BMPs and non-structural source controls (e.g., water conservation incentives, enhanced IDDE efforts, enhanced education/outreach, and inspection/enforcement to prevent sources of non-stormwater flow). To date, monitoring has shown that the WMG has been successful in this endeavor, and successfully eliminated most of the non-exempt dry weather flows. The Peninsula WMG plans to capture and intercept the remaining dry weather flow with regional dry weather capture projects, such as the Palos Verdes Peninsula Multi-Benefit Flow Diversion Project and the Torrance Airport Stormwater Project. The analysis summary of dry weather flows is shown in Table 18. A WMA-specific discussion of the dry weather RAA is presented in the following subsections.
Table 18. Dry Weather RAA Summary
Watershed
Management
Area
Analysis
Region
Is non-exempt dry
weather flow
currently nonexistent and/or
sufficiently treated or
diverted?
Are sufficient
structural BMP
proposed to intercept,
treat or divert 100%
of dry weather
runoff?
Is dry weather
reasonable
assurance
demonstrated
through
monitoring?
Santa Monica
Bay All Yes n/a Yes
Machado Lake ML-1 Yes n/a Yes
Wilmington
Drain
WD-1 No Proposed Yes[1]
WD-Solano Yes n/a Yes
Los Angeles
Harbor
LAH-IH Yes n/a Yes
LAH-CM Yes n/a Yes
[1] Assuming completion of the Palos Verdes Peninsula Multi-benefit Flow Diversion Project and/or the Torrance Airport Stormwater Capture Project will sufficiently manage all dry weather flows.
10.1. Santa Monica Bay WMA
As shown in Section 2, dry weather pollutants of concern in the Santa Monica Bay WMA include bacteria, trash and marine debris, PCBs, DDT, arsenic, and mercury.
For dry weather indicator bacteria in Santa Monica Bay, final compliance deadlines for dry weather have passed. Therefore, a RAA is not required. However, the following discussion is provided for informational purposes. Historic summer-dry and winter-dry weather monitoring data at all Peninsula SMBBB compliance monitoring locations show 275
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 54 May 2022 water quality to be better than that of the reference beach based on long-term average exceedance rates. Dry weather exceedance rates at these beaches have historically ranged from 0 – 3% across both seasons. In addition, compliance monitoring locations SMB-7- 1 through SMB-7-5 are open beach sites located on segments of shoreline that have all been removed from the States 303(d) list of impaired waterbodies, with no observed dry weather discharges affecting water quality. Therefore, reasonable assurance of compliance has successfully been demonstrated for this WBPC.
For DDT and PCBs, the annual TMDL based WLA accounts for both dry and wet weather. As summarized in Section 7.1.2 Four complete years of nearshore receiving water quality data have been collected under the Peninsula CIMP in the Santa Monica Bay and analyzed for total DDT and PCBs. Only one (1) out of forty (40) samples or
2.5% resulted in detection of 4,4’- DDT at a concentration between the method detection limit and the reporting limit. This sample was collected during a summer dry weather sampling event in the fourth year of CIMP monitoring. None of the forty (40) receiving water samples collected over the past four years have resulted in detections of Total PCBs above the Ocean Plan objective for total PCBs. Therefore, dry weather reasonable assurance is demonstrated.
As discussed in Section 7.1.3, there’s no existing data or evidence tying arsenic and mercury pollutants to MS4 discharges. Both pollutants have been added to the outfall monitoring sites for the Santa Monica Bay in response to recent 303(d) listings, however sufficient data are not yet available to support the dry weather RAA.
For trash and marine debris, compliance with the Santa Monica Bay Debris TMDL is being met through a phased retrofit of catch basins throughout the Peninsula Santa Monica Bay WMA along with source controls to meet the final compliance deadline.
In summary, reasonable assurance of compliance during dry weather is demonstrated for the Peninsula Santa Monica Bay WMA.
10.2. Machado Lake WMA
As part of the Peninsula CIMP, the Peninsula WMG completed a non-stormwater runoff source investigation study (Peninsula WMG, 2018). According to the study findings, no dry weather flow is observed through Machado Lake WMA. Therefore, reasonable assurance of compliance during dry weather is demonstrated for the Peninsula Machado Lake WMA.
276
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 55 May 2022
10.3. Wilmington Drain WMA
According to non-stormwater runoff source investigation study findings, dry weather flow is only observed in the WD-1 analysis region and has been determined to be associated with natural flows, i.e., rising groundwater or springs entering the MS4. The dry weather runoff and pollutants have been accounted for as part of the wet weather RAA summarized in Section 9.2. In addition, Peninsula WMG has planned to intercept and divert 100% of dry weather runoff draining to the WD-1 analysis region with the Palos Verdes Peninsula Multi-benefit Flow Diversion Project and the Torrance Airport Stormwater Capture project.
In summary, reasonable assurance of compliance during dry weather is demonstrated for the Peninsula Wilmington Drain WMA.
10.4. Los Angeles Harbor WMA
The Peninsula WMG is addressing dry weather pollutants of concern in the Los Angeles Harbor WMA via 100% non-exempt dry weather flow capture. As part of the Peninsula CIMP, the Peninsula WMG have performed a non-stormwater runoff source investigation study. According to the study findings, dry weather flow is not observed in both LAH-IH and LAH-CM analysis regions. Therefore, reasonable assurance of compliance during dry weather is demonstrated for Peninsula Los Angeles Harbor WMA.
11. BMP COST OPINION
The capital, operation and maintenance (O&M) and 20-year life-cycle costs of the proposed projects were estimated for EWMP planning purposes. For the Torrance Airport Stormwater Capture Project, the presented costs were extracted from the Safe Clean Water Program Feasibility Study submitted in October 2020 (City of Torrance, 2020).
The cost of the remaining projects was estimated based on key modeling parameters using the cost functions presented in the WMMS 2.0 Phase II Report (LACFCD, 2020c). The cost functions are summarized in Table 19.
Table 19. WMMS 2.0 Cost Function
BMP Type BMP
Component
Capital
Cost[1]
Annual O&M
Cost[1] Life Cycle Cost[1]
Pervious Pavement $253(A) $5.1 (A) $253(A) + $5.1(A) (Yr) Subsurface
Retention +
Infiltration
Diversion $7,000(In) $320(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) +
$320 (In)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Diversion $7,000(In) $320(In)
277
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 56 May 2022 BMP Type BMP
Component
Capital
Cost[1]
Annual O&M
Cost[1] Life Cycle Cost[1]
Subsurface
Retention +
Filtration
Pretreatment $12,000(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) +
$320 (In)(Yr) + [$177,000
+$70,000](Eff) + [$1,000 +
$3,000](Eff)*(Yr)
Storage $12.6(V) $6,000
Pump $177,000(Eff) $3,000(Eff)
Filtration $70,000(Eff) $1.000(Eff)
Subsurface
Retention +
Diversion to
Sewer
Diversion $7,000(In) $320(In)
[$7000 + $12,000](In) +
$12.6(Vf) + $6,000(Yr) +
$320 (In)(Yr) + $177,000(Ps)
+ $3,000(Ps)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Pump $177,000(Ps) $3,000(Ps)
Sewer
Diversion $67,000
[1] A – BMP footprint in ft2
; Eff – Treatment rate in cfs ; In – Inflow rate in cfs; Ps – Sewer diversion rate in cfs; Vf – BMP storage capacity in ft3
;
The resultant project costs are summarized in Table 20. The cost summary does not include already-completed projects (Casaba Estates LID and Rolling Hills Country Club LID) or projects that are not included in the RAA (Harbor City Stormwater Capture Project). The cost of the Palos Verdes Peninsula Multi-benefit Flow Diversion Project will be determined as part of the Project’s Safe, Clean Water Program Feasibility Study.
Table 20. Project Cost Opinion Summary
Analysis
Region Lead Agency Project Capital
Annual
O&M
Cost
20-Year Life
Cycle Cost
ML-1 Rolling Hills
Estates
Palos Verdes Drive East Street
Improvement $2,859,000 $58,000 $4,012,000
ML-1 Rolling Hills
Estates
ML-1 RHE Regional Project $254,000 $40,000 $1,060,000
ML-1 Rancho Palos
Verdes ML-1 RPV Regional Project $30,000 $40,000 $821,000 WD-1
Rancho Palos
Verdes and
Torrance
Torrance Airport Stormwater
Basin Project Phase 2 $12,000,000 $118,000 $13,700,000
WD-1 Rolling Hills
Estates
Rolling Hills Road Street
Improvement $481,000 $10,000 $675,000
LAH-IH Rancho Palos
Verdes Eastview Park $781,000 $42,000 $1,619,000
LAH-IH Rolling Hills
Estates
LAH-IH RHE Regional Project $2,308,000 $47,000 $3,241,000 LAH-IH Rancho Palos
Verdes LAH-IH RPV Regional Project $540,000 $41,000 $1,363,000 LAH-CM Rancho Palos
Verdes LAH-CM RPV Regional Project $913,000 $9,000 $968,000 278
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 57 May 2022
12. CONCLUSIONS
To update the RAA for the revised Peninsula EWMP, a modeling approach that utilizes WMMS 2.0 has been applied using the rationale, analytical basis, and process described in this RAA report. The RAA process:
1. Applied an acceptable model tailored to the Peninsula WMG based on available outfall and receiving water data collected through June 2020.
2. Calculated target load reductions (TLRs) necessary to achieve applicable compliance targets.
3. Demonstrated that the existing and proposed suite of projects will attain the TLRs.
Where this was not demonstrated, volumetric management needs have been documented to show what needs to be achieved in order to demonstrate compliance.
The revised and updated Peninsula RAA therefore meets the objectives and requirements of the LA MS4 Permit and RAA Guidance Document, demonstrating that a reasonable assurance of compliance will be achieved in each analysis region if the TLRs are fully and appropriately managed.
279
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 58 May 2022
13. REFERENCES
LACDPW (Los Angeles County Department of Public Works). 2011. Machado Lake Nutrient TMDL Special Study: Characterization of Water Quality Conditions in the Unincorporated Areas of Los Angeles County within the Machado Lake Watershed Final Report. September.
LACDPW. 2006. Los Angeles County Hydrology Map. Accessed January 2021 from <link>
LACFCD (Los Angeles County Flood Control District). 2020a. WMMS 2.0 Average and 90th Percentile Water Year Simulation. Accessed December 2020 from <link> LACFCD. 2020b. WMMS 2.0 Phase II Report: BMP Model and Optimization Framework. Accessed December 2020 from <link>
LACFCD. 2020c. WMMS 2.0 Average & 90th Percentile Water Year. Accessed January 2021 from <link>
LARWQCB (Los Angeles Regional Water Quality Control Board). 2010. Machado Lake Nutrient TMDL – Conditional Approval of the Special Study Work Plan for the Unincorporated Areas of Los Angeles County within the Machado Lake Watershed. May.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2012. Attachment A to Resolution No. R12-009. Amendment to the water quality control plan for the Los Angeles Region to revise the TMDL for bacteria in the Malibu Creek Watershed. Adopted June 7.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014a. Guidelines for Conducting Reasonable Assurance Analysis in a Watershed Management Program, Including an Enhanced Watershed Management Program. Los Angeles, CA.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014b. Water Quality Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. Accessed January 2021 from <link>.
Peninsula WMG (Watershed Management Group). 2020. Annual Watershed Report – Reporting Year 2019 – 20. December.
Peninsula WMG (Watershed Management Group). 2018. Non-Stormwater Outfall Screening and Source Investigation Report. November.
280
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 59 May 2022 SWRCB (State Water Resources Control Board). 2020. In the Matter of Review of Approval of Watershed Management Programs and an Enhanced Watershed Management Program Submitted Pursuant to Los Angeles Regional Water Quality Control Board Order R4-2012-0175. SWRCB/OCC FILES A-2386, A-2477 & A-2508.
Sacramento, CA.
TDC Environmental, 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles County from the Brake Pad Copper Reductions Mandated by SB 346. Prepared for Richard Watson & Associates, Inc.
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Attachment A
Supplementary Calibration Exhibits
282
E. Coli
Total Suspended Solids
283
Total Copper
Total Lead
284
Total Zinc
Total Phosphorus
285
Total Nitrogen
286
Appendix 4.2
Requirements for Achieving Receiving Water
Limits
287
Palos Verdes Peninsula
Enhanced Watershed Management Program
Appendix 4.2-1 | Page
APPENDIX 4.2 REQUIREMENTS FOR ACHIEVING RECEIVING WATER
LIMITS FOR POLLUTANT CATEGORIES
Provisions of the MS4 Permit describe how compliance with receiving water limits (RWLs) are to be attained for various water body-pollutant combinations (WBPC) identified through adaptive management of the EWMP. Requirements for achieving RWLs for each priority pollutant category is described in the following sections.
WBPCS ADDRESSED BY A TMDL (CATEGORY 1 POLLUTANTS)
For WBPCs addressed by a TMDL, adherence to all requirements and compliance dates set forth in the approved EWMP will constitute compliance with applicable interim TMDL-based water quality-based effluent limits and interim receiving water limits outlined in the Permit. Most of the WBPCs addressed through a TMDL have corresponding interim and/or final compliance milestones that fall within the term of the Permit. However, there are a few WBPCs being addressed by a TMDL for which interim compliance milestones need to be developed within the term of the Permit. Table 5-2 summarizes the applicable TMDL compliance dates and those that have been developed for the EWMP.
During the adaptive management process, if a WBPC within the Peninsula WMG is added to the State’s 303(d) list that falls within the same class as those being addressed by a TMDL, the WBPC will be added to the list of Water Quality Priorities and the following actions will be completed following Permit provisions:
• It will be demonstrated that Watershed Control Measures (WCMs) selected to achieve the applicable TMDL provisions will also adequately address MS4 contributions of the pollutant(s) within the same class. Assumptions and requirements of the corresponding TMDL provisions must be applied to the additional pollutant(s), including interim and final requirements and deadlines for their achievement, such that the MS4 discharges of the pollutant(s) will not cause or contribute to exceedances of receiving water limitations.
• The WBPC will be included in the revised Reasonable Assurance Analysis (RAA). • Dates for their achievement will be developed consistent with those in the applicable TMDL.1 303(D) LISTED WATER BODY POLLUTANT COMBINATIONS (CATEGORY 2 POLLUTANTS) Currently, indicator bacteria (E. coli) in the Wilmington Drain Subwatershed, in addition to Arsenic and Mercury in Santa Monica Bay Subwatershed, are the only 303(d)-listed pollutants within the Peninsula WMG that are not being addressed by a TMDL. These WBPCs are not in the same class as any existing TMDL within the Dominguez Channel or Santa Monica Bay Watershed Management Area portions of the Peninsula EWMP Area. Although a definitive linkage between indicator bacteria in Wilmington Drain and MS4 discharges from the Peninsula WMG has not been demonstrated, the MS4 system may cause or contribute to this impairment. Mercury and arsenic were recently added to the 303(d) list for Santa Monica Bay based on sediment and fish tissue data collected under the Hyperion Treatment Plant NPDES Permit no. CA0109991 between January 2006 and June 2010. There’s no existing data or evidence tying 1 The Peninsula WMG has requested modification of the Machado Lake Nutrient TMDL deadline. That request is pending.
288
Palos Verdes Peninsula
Enhanced Watershed Management Program
Appendix 4.2-2 | Page
either of these pollutants to stormwater MS4 discharges. No modeling was conducted within the Santa Monica Bay WMA for the updated RAA, as reasonable assurance of compliance is already demonstrated via monitoring data. Therefore, the following actions have been completed as part of the EWMP to address indicator bacteria in Wilmington Drain, in addition to Arsenic and Mercury in Santa Monica Bay:
• WBPC (indicator bacteria) was included in the RAA.
• WCMs were selected to address contributions of indicator bacteria from MS4 discharges coming from the Peninsula WMG, such that these MS4 discharges will not cause or contribute to the exceedance of the receiving water limits coliform bacteria.
• Milestones and dates for BMP implementation have been identified to control MS4 discharges such that they do not cause or contribute to exceedances of receiving water limitations within a timeframe that is as short as practicable, taking into account the technological, operational, and economic factors that affect the design, development, and implementation of the WCMs that are necessary. • Milestones relate to a specific water quality endpoint (e.g., percent load reduction) and dates relate either to taking a specific action or meeting a numeric water quality endpoint. • If the identified dates are beyond the term of the Permit, the following will apply per Permit provisions:
o In drainage areas where retention of all nonstormwater runoff and all stormwater runoff from the 85th percentile, 24-hour storm event will be achieved, efforts will continue to target implementation of WCMs identified in the EWMP, including WCMs to eliminate nonstormwater discharges that are a source of pollutants to receiving waters. o For areas where retention of the volume described above is technically infeasible and where the Regional Board determines that MS4 discharges cause or contribute to the water quality impairment, development of a stakeholder-proposed TMDL may be initiated upon approval of the EWMP. For MS4 discharges from these drainage areas to the receiving waters, any extension of this compliance mechanism beyond the term of the Permit will be consistent with the implementation schedule in a TMDL for the WBPC(s) adopted by the Regional Board.
NON 303(D)-LISTED WATER BODY POLLUTANT COMBINATIONS (CATEGORY 3 POLLUTANTS) There have been no Category 3 Pollutants identified within the Peninsula WMG. 289
Agenda Item No.: 7.I
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: APPROVE ROLLING HILLS COMMUNITY ASSOCIATION'S
APPLICATION TO LOS ANGELES COUNTY DEPARTMENT OF PUBLIC
HEALTH FOR REPLACEMENT OF SEPTIC TANK SERVING THE MAIN
GATE AND AUTHORIZE CITY MANAGER TO SIGN
DATE: May 23, 2022
BACKGROUND:
In a letter dated April 11, 2022, the Rolling Hills Community Association (RHCA) requested to install a new septic tank to service the Main Gate. The referenced letter noted that the replaced septic tank would also serve the new kitchen and restroom proposed for the tennis courts common area.
The RHCA leases the tennis courts, and the City Hall campus from the City. Per the lease agreement, the RHCA maintain and operates the tennis courts. To replace the referenced septic tank, located in the area adjacent to the guest lane approaching the Main Gate, a permit is required from the Los Angeles County Department of Public Health. As the owner of the property, RHCA is requesting that the City submit the required forms to the Los Angeles County Department of Public Works to commence the permitting process. RHCA has a contractor, Peninsula Septic Service on standby to implement the tank replacement upon permit issuance.
The City and the RHCA planned separate projects at the tennis courts. The RHCA plans to improve the common areas of the tennis courts to add amenities like a restroom, kitchen, and a gazebo. To comply with the American with Disability Act (ADA), the City plans to bring the walkways of the tennis courts to ADA standards. Over the last three years, these improvements have been placed on hold.
The proposed amenities would add effluent to the existing septic tank and would trigger tank replacement by the Los Angeles Department of Public Health. In light of the City's 8" sewer main project, the RHCA decided to hold off on the septic tank replacement in the event that that the City constructs the 8" line, the effluent from the proposed amenities could be 290
discharged to the sewer main instead of the septic tank.
The 8" sewer main has been in the design phase for the past 12 months and at the January 2022 City Council Strategic Planning Session, the City Council decided not to dedicate General Fund to construct the 8" sewer main line. Instead, the City Council discussed pursing grant funds for the project. In consideration of the City Council's actions, the RHCA decided to revisit the septic tank replacement project.
At the May 9, 2022 City Council meeting, staff was directed to communicate with the RHCA that the Council was in support and requested a copy of the latest plans including the location of the new septic tank.
DISCUSSION:
The RHCA has provided their application including plans as requested. It is attached for Council's review.
FISCAL IMPACT:
There is no fiscal impact to complete the permitting forms requested by the RHCA.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_AGN_220523_RHCA_LACoDPH_Application_Septic.pdf
CL_AGN_220523_RHCA_GeoTech_Septic.pdf
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Agenda Item No.: 7.J
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: CHRISTIAN HORVATH,
THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: ACCEPT EMERGENCY STORM DRAIN REPAIR AT 1 MIDDLERIDGE
LANE NORTH AS COMPLETE, FILE NOTICE OF COMPLETION, AND
RELEASE RETENTION AFTER 30 DAY LIEN PERIOD TO EC
CONSTRUCTION
DATE: May 23, 2022
BACKGROUND:
On December 30, 2021, the easement adjacent to Middleridge Lane South developed multiple sinkholes during a storm event. As a result the RHCA contacted LA County Department of Public Works (LACDPW) on January 3, 2022 to request assistance and repair. On January 6, 2022, LACDPW informed the RHCA and City that they had found documentation confirming that the City of Rolling Hills was responsible for maintenance of the subject drain via a 1972 signed agreement between the Los Angeles County Flood Control District and the City. On January 9, 2022 the City Manager sent an email update to the Council and adjacent neighbors updating them on the above and the steps being taken to address the issues. While the city initially tried to engage LA County through our General Services agreement, they were unable to commit time and resources due to extenuating circumstances including lack of manpower due to COVID-19 and other emergency projects.
Staff contacted private contractors who visited the site and provided feedback on repair scope of work, schedule, and cost. In the meantime, the RHCA, in anticipation of projected rain directed staff to place sandbags and tarp over the sink holes. Staff also received a phone call from the resident at 1 Middleridge Lane North regarding potentially related concerns.
On Tuesday, January 18, 2022, EC Construction (ECC) was on site to investigate as to whether the broken drainpipe was the cause of the upper sinkhole and determine a more clear scope of work. The coupling (pipe connector) was the issue at the upper and lower sinkholes.
During this visit ECC also visited 1 Middleridge Lane North at staff request due to assess potential stormwater drain issues in the canyon. At that time, it was challenging for them to ascertain what exactly might be happening in the canyon and so direction was focused on the more imminent sinkhole issues at 1 Middleridge Lane South. 323
On Monday, January 24, 2022, the City Council unanimously adopted Resolution No. 1287, directed the City Attorney to draft a construction contract with ECC and authorized the City Manager to execute. On Monday, February 7, 2022, the final executed contract was received and work commenced thereafter. On Tuesday February 8, 2022, ECC took a second look at 1 Middleridge Lane North and reported that there was a sinkhole in the resident's yard coming from a stand pipe with a metal cover. The 24" Corrugate Metal Pipe (CMP) empties in the aforementioned canyon. ECC advised the resident, that if the resident's grounds crews could hand dig around the sinkhole and expose the CMP- they could return in few days to provide some insight into what might be required to address. On February 9, 2022, the resident at 1 Middleridge Lane North contacted staff to follow-up on their concerns.
Work at 1 Middleridge Lane South was completed on Friday, February 11, 2022. At this time ECC was able to gain further insight into the potential issues and found the bottom of the CMP was gone and water was eroding the dirt under the CMP, causing it to collapse and create the sink hole. The catch basin in the street at the intersection of Middleridge Lane North & South was determined to be the source of water flowing through the CMP on the property. The exit point is down the canyon between 1 Middleridge North and the property to the North. ECC pointed out that this was a much more difficult repair because of the terrains as well as the trees / vegetation requiring removal in order to replace the CMP.
ON March 14, 2022, the City Council passed Resolution 1293 directing the City Attorney to draft a construction contract and authorizing the City manager to execute, approve the resolution for emergency work, and appropriate $48,645 from the General Fund Reserves to Fund 40 for the repair.
DISCUSSION:
The work completed and originally described ECC's estimate to repair the issue was as follows:
1. Remove existing vegetation as required to access damaged pipe.
2. Excavate dirt and remove approx 100 LF of existing 24” CMP.
3. Install 100 LF of new 24” CMP.
4. Backfill pipe with 1 sack slurry, 1’ over new pipe, backfill the remaining with dirt to finish grade.
FISCAL IMPACT:
The repair to the storm drain line was an unexpected expense and not budgeted in the FY 2021-2022 adopted budget.
The final cost was $47,028.56 which includes an additional $4728.56 for the breaking and removal of four concrete encasements surrounding the old CMP Pipe that were found during the work and not included as part of the original estimate.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
PW_STW_220303_SDRepair_1MiddleridgeLaneN.pdf
PW_STW_220418_MiddleridgeLaneN_INV 19092_revised.pdf
PW_STW_220430_MiddleridgeLaneN_Inv 19111_Retention.pdf
324
PW_STW_220418_MiddleridgeLaneN_CP_Release.pdf
325
BID PROPOSAL AND CONTRACT
2213 CHICO AVE./SO. EL MONTE, CA 91733
Phone: (626) 444-9596 Fax: (626) 444-3077
California Contractors License #366814
DATE: 3/3/2022
TO City of Rolling Hills JOB ADDRESS
2 Portuguese Bend Rd
Rolling Hills, CA 90274 1 Middleridge Lane N
We agree to furnish all labor, materials, equipment and supervision necessary to complete the following:
STORM DRAIN REPAIR
1. Remove existing vegetation as required to access damaged pipe.
2. Excavate dirt and remove approx 100 LF of existing 24” CMP.
3. Install 100 LF of new 24” CMP.
4. Backfill pipe with 1 sack slurry, 1’ over new pipe, backfill the remaining with dirt to finish grade.
COST……..$42,300.00
Note: The homeowner at 1 Middleridge Lane N had a photo of a concrete culvert that appeared to be in the canyon between properties. This proposal does not include removing that structure or constructing a new culvert.
Exclusions: permits, inspection fees, SWPPP plan, engineering, survey, relocation of underground utilities, night or weekend work, concrete, slurry, and striping.
The above described work will be performed in a workman like manner and in accordance with standard practices.
TERMS: Unless credit arrangements have been made, in writing, in advance, the invoice for the work described herein is due and payable on presentation. 1 ½ % per month will be charged on a daily basis on all accounts or portions thereof not paid within 10 days of the date of the invoice.
Customer agrees to pay reasonable attorney fees and collection costs incurred by E.C. Construction Co. for the collection of both principal and interest due to customer’s failure to pay per this agreement.
Unless otherwise specified, if this proposal is not accepted within______30___________days from bid date, we reserve the right of cancellation.
APPROVE AND ACCEPTED Respectfully Submitted,
___________________________ E.C. CONSTRUCTION CO.
Date__________________20___ By_________________________ 326
2213 CHICO AVENUE
SOUTH EL MONTE, CA 91733
Fax: (626) 444-3077
E. C. CONSTRUCTION CO.
Phone: (626) 444-9596
Attn: Christian Horvath
2 PORTUGUESE BEND ROAD
ROLLING HILLS, CA 90274
CITY OF ROLLING HILLS
Contract3-21-22 5/18/2022
4/18/2022
19092
1 MIDDLERIDGE LANE N
ROLLING HILLS, CA 90274
STORM DRAIN REPAIR
220309
Our Job No Payment Terms Due Date
Description Price
Re:
Invoice
Invoice Number
Invoice Date
Bill To:
Contrs Lic # 366814
Customer Job No Customer PO
Net 30 Days
STORM DRAIN REPAIR- BASE CONTRACT AMOUNT $42,300.00 42,300.00 CO#1 BREAK & REMOVE 4 CONCRETE ENCASEMENTS SURROUNDING OLD CMP PIPE 4,728.56 $4,728.56
10% RETENTION -4,702.86 -4,702.86
AMOUNT DUE THIS INVOICE $42,325.70
Total Due $ 42,325.70
Subtotal $ 42,325.70
All Sales Taxes Paid
Thank you for your business!
Sales Tax (if applicable) $ 0.00
327
2213 CHICO AVENUE
SOUTH EL MONTE, CA 91733
Fax: (626) 444-3077
E. C. CONSTRUCTION CO.
Phone: (626) 444-9596
Attn: Christian Horvath
2 PORTUGUESE BEND ROAD
ROLLING HILLS, CA 90274
CITY OF ROLLING HILLS
5/30/2022
4/30/2022
19111
1 MIDDLERIDGE LANE N
ROLLING HILLS, CA 90274
STORM DRAIN REPAIR
220309
Our Job No Payment Terms Due Date
Description Price
Re:
Invoice
Invoice Number
Invoice Date
Bill To:
Contrs Lic # 366814
Customer Job No Customer PO
Net 30 Days
REQUEST FOR RELEASE OF RETENTION 4,702.86
Total Due $ 4,702.86
Subtotal $ 4,702.86
All Sales Taxes Paid
Thank you for your business!
Sales Tax (if applicable) $ 0.00
328
329
330
Agenda Item No.: 7.K
Mtg. Date: 05/23/2022
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: JOHN SIGNO, DIRECTOR OF PLANNING & COMMUNITY SERVICES THRU: ELAINE JENG P.E., CITY MANAGER
SUBJECT: ADOPT RESOLUTION NO. 1299 ACCEPTING CALRECYCLE SB1383 GRANT
DATE: May 23, 2022
BACKGROUND:
On January 24, 2022, the City Council directed staff to file an application for the SB 1383 Local Assistance Grant Program and prepare a resolution in support of the application. On February 1, 2022, staff submitted an application to the Department of Resources Recycling and Recovery (CalRecycle) for a one-time grant program meant to provide aid in the implementation of regulations adopted by CalRecycle. This non-competitive grant program provides $57,000,000 of funding to local jurisdictions to assist with the implementation of regulation requirements associated with SB 1383.
On February 14, 2022, the City Council adopted Resolution No. 1288, attached, authorizing the submittal of the CalRecycle Local Assistance Grant Program application and related authorizations. Although the City had already submitted its application to meet the deadline, the resolution is still required by CalRecycle.
On March 14, 2022, the City Council adopted Ordinance No. 374 adding Chapter 8.10 to the Rolling Hills Municipal Code relating to edible food recovery in compliance with SB 1383. The Ordinance was sent to CalRecycle as a supplement to the grant application.
On April 24, 2022, CalRecycle awarded the City of Rolling Hills in the first round of the SB 1383 Local Assistance Grant Program. The City initially requested $20,000 but was awarded $20,183.
DISCUSSION:
The program provides funding to assist local jurisdictions with meeting the requirements below:
Provide organics collection services to all residents and businesses Conduct education and outreach to the community
331
Secure access to recycling and edible food recovery capacity Establish edible food recovery program
Procure recyclable and recovered organic products
Monitor compliance and conduct enforcement
Staff will be working with CalRecycle in the next few weeks on further steps, including possibly revising the grant budget and activities. Grant funds will be used to implement the requirements in Chapter 8.10 regarding food recovery. The grant term ends on April 2, 2024 for first round recipients.
FISCAL IMPACT:
The City is awarded a grant amount of $20,183.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
Revised 1383 Award RFA 001.pdf
Exhibit A: 2022Jan3SB1383LocalAssistTermsConditions.pdf Exibit B: 2022Apr25ProcsReqsAmended.pdf
ResolutionNo1288_SB1383_Grant_F_E.pdf
ResolutionNo1299_CalRecycle_SB1383_GrantAcceptance.pdf
332
Request for Approval
To:
Michelle Martin
Branch Chief, Financial Resources Management Branch
Decision Subject: Awards for the SB '1383 Local Assistance Grant Program, (Greenhouse Gas Reduction Fund, Fiscal Year2021-22)
Action By: April 25, 2022 (Revised Mav 6, 2022)
Summary of Request
Staff requests approval of grant awards for the SB 1383 Local Assistance Grant Program (Program) for fiscal year (FY) 2021-22. Staff received 475 eligible applications totaling $54,929,783 for this grant program.
Funding
The FY 2021-22 Budget Act allocates $60,000,000 to be used to provide grants to local jurisdictions to assist in the implementation of regulations adopted by the Department of Resources Recycling and Recovery pursuant to Chapter 395 of the Statutes of 2016; $3,000,000 (5 percent) has been allocated for administrative costs.
Fund Source Amount
Available
Greenhouse Gas $57.000,000
Reduction Fund
(FY 2021-22\
Total $57,000,000 $41,782.906 $15,217,094
$42p3+7€ $14863,724
Background and Findings
Statutory Authority
Senate Bill (SB) 1383 Lara, Chapter 395, Statutes of 2016, set methane emissions reduction targets for California in a statewide effort to reduce emissions of short-lived climate pollutants.
SB '170 Budget Act of 2021 authorizes CalRecycle to award grants to local jurisdictions to assist in the implementation of programs to meet these statutory requirements.
Program Background
The SB 1383 Local Assistance Grant Program provides funding to assist local jurisdictions Amount to
Fund ltem
$41,782.906
$12;936;276
Amount
Remaining
$15.217.094
$/.4s63J%
Line ltem
Local
Assistance/Grants