Upper Santa Clara River
Comprehensive Human Waste Source Reduction Strategy Scope of Work 1 02/27/2023
Scope of Work for
CHWSRS Work Plan Development and Investigation Implementation
INTRODUCTION
The Upper Santa Clara River (USCR) Watershed Management Group (WMG) has faced multiple challenges achieving recreational water quality standards in the USCR and wasteload allocations within the Santa Clara River Bacteria TMDL (Bacteria TMDL). To support existing efforts conducted under the USCR Watershed Management Plan (WMP) and better protect public health and support recreational beneficial use goals, the USCR WMG began developing a Comprehensive Human Waste Source Reduction Strategy (CHWSRS) Work Plan (Plan) in 2021. The CHWSRS approach leverages recent advancements in the use of human markers and other diagnostic tools, as well as an enhanced focus on targeted source control efforts, to protect recreational beneficial uses and make progress towards compliance with associated water quality standards and Bacteria TMDL requirements. Strategy planning began in 2021 with an initial prioritization and revised WMP language to set the stage for a more effective pathway to improved public health through a reduction in high-risk human pathogen sources.
CHWSRS control measures conducted in parallel with implementation of the WMP will support USCR Bacteria TMDL compliance and long-term WMP goals through an adaptive management process that incorporates significant advances in the state of the science. Ongoing regulatory conversations within the region and the development of implementation approaches such as CHWSRS by the USCR WMG provide support for policies that implement more effective source control efforts. Completing the CHWSRS Work Plan on an accelerated timeline in 2023 will also support regulatory discussions with the Los Angeles Regional Water Quality Control Board on the Bacteria TMDL compliance schedule.
TECHNICAL APPROACH
The goal of CHWSRS is to support the WMG better align implementation actions with the goal of reducing pathogen health risk to recreators. The scope herein will build upon the preliminary catchment prioritization conducted in 2021 to develop a final CHWSRS Work Plan and initiate dry weather human waste source investigations (HWSIs) in Reach
6. This will be accomplished through the tasks outlined below.
TASK 1: PROJECT MANAGEMENT
Tetra Tech will follow established project management protocols and maintain regular communication with the City. The task includes project initiation, scheduling, monthly invoicing, and progress reports, coordination with the City, and other administrative tasks for the duration of this project. Mr. Tim Tringali will collaborate with Mr. Clint Boschen and Ms.
Shannon Quigley-Raymond to provide progress updates and attend monthly virtual coordination meetings. An initial kickoff meeting will be held with the City to discuss the project schedule, coordination requirements , draft Work Plan outline, and project objectives.
Deliverables:
• Monthly invoices and progress updates
• Kickoff call and monthly meetings
Upper Santa Clara River
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TASK 2: CHWSRS WORK PLAN
The USCR CHWSRS Work Plan will prioritize identifying and abating high-risk human sources of pathogens to support the focus on bacteria as a water quality priority for the USCR WMG. Tetra Tech will leverage the annotated draft CHWSRS Work Plan outline developed in 2021 (included as Appendix A) and discussion during the kickoff call to further develop and finalize the plan. The CHWSRS Work Plan will focus only on Reach 6 and emphasize dry weather source identification and abatement activities.
Tetra Tech will incorporate additional data and complete refinements needed to develop the Work Plan. Additional data from water quality monitoring conducted between July 2021 and December 2022 will be incorporated into the prioritization. In addition, refinements to the MS4 catchments and network based on feedback on the initial prioritization will be completed to develop the final Reach 6 prioritization and identify the prioritized catchments for HWSIs. Tetra Tech will also develop an ESRI ArcGIS Online map to accompany the Work Plan and provide easy access and navigation of the available data and layers. The GIS layers in the ArcGIS Online map will include MS4 network, major outfalls, inlets, water quality monitoring sites, and catchments.
Following the data additions and refined prioritization, Tetra Tech will develop a draft CHWSRS Work Plan. Following WMG review, Tetra Tech will incorporate requested updates and edits from the draft in the final Work Plan. Along with the clean final version, Tetra Tech will submit a track changes version with responses to comments in the document.
During the finalization of the Work Plan, a Sampling Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP) will be developed for the program. The overall source investigation approach will include a range of traditional and non-traditional pathogen health risk indicators available to aggressively and effectively track and identify human waste sources of pathogens. Physical, bacterial, viral, and/or chemical markers may be used to support source identification efforts, and will be selected based on available knowledge for the areas of concern.
Deliverables:
• Draft Work Plan
• ESRI ArcGIS Online Reach 6 Catchment Maps
• Final Work Plan
• Draft SAP/QAPP
• Final SAP/QAPP
TASK 3: MEETING AND REGULATORY SUPPORT
During the investigation phase of the project, the WMG will be regularly informed of the status of the HWSI for each AOI by way of updates at monthly WMG CIMP meetings or separate meetings. Validated data will be summarized within a standard series of tables and charts and distributed to the WMG via the monthly meetings. It is assumed that up to eight meetings will be supported by Tetra Tech in the first year.
On an as-needed basis, Tetra Tech will provide the City support for discussions or responses to comments related to Bacteria TMDL compliance strategies. Tetra Tech will prepare presentations and provide content related to the HWSI progress, high-risk based approach to bacteria and participate in up to two Regional Board meetings on the CHWSRS Work Plan or Bacteria TMDL.
Deliverables:
• LA Regional Board regulatory engagement, comment, and meeting support • Up to eight presentations at monthly meetings
TASK 4: HUMAN WASTE SOURCE INVESTIGATIONS
Tetra Tech will initiate HWSIs following the framework outlined in the CHWSRS Work Plan and will investigate up to three dry weather AOIs. To begin, Tetra Tech will prepare a template reporting form (AOI Reporting Form) for each of Upper Santa Clara River
Comprehensive Human Waste Source Reduction Strategy Scope of Work 3 02/27/2023
the three targeted AOIs that will document existing information relevant to the AOI, support additional stakeholder information requests needed to inform planning for each HWSI, and provide a summary of the monitoring plan. The form will also be used for documenting the iterative progress of each AOI HWSI as field and laboratory data are generated.
From the information compiled, any needed modifications to the catchment delineations will be completed and AOI- specific monitoring plans will be finalized by Tetra Tech. The AOI monitoring plan will be documented in a simple and streamlined way within the AOI Reporting Form to facilitate easy communication with the City and WMG regarding the status of and approach to each HWSI. It is anticipated that up to three iterations of this plan will be needed for each AOI to generally reflect the following phases of the investigation: Receiving Water, Outfall, and Catchment Level 1. In addition, the maps developed as part of the CHWSRS Work Plan will be customized with AOI monitoring plan details in ESRI ArcGIS Online. An ESRI Field Maps form will be developed for data collection via the mobile app as part of the investigation. Data collected using the field form will include the status of flow at outfalls and connectivity of any outfall flow to downstream receiving waters.
Following the finalization of the AOI-specific monitoring plan, Tetra Tech will prepare a LACFCD Access Permit application as necessary and submit the corresponding permit fees to support the HWSI receiving water, outfall and catchment phases for the three AOIs. Tetra Tech will then proceed with phased (i.e., receiving water, outfall, and catchment) implementation, relying on the CHWSRS Work Plan-specified Action Levels to guide risk-based decision- making about subsequent steps of the HWSI. Tetra Tech has established a preliminary set of assumptions regarding the number of sample sites, monitoring events, HF183 analytical batches, and HF183 sample analysis rate for each individual phase of the HWSI. These assumptions are documented in Table 1. Monitoring activities for the Receiving Water, Outfall, and Catchment Levels are included in the Scope of Work. Due to the iterative nature of source investigations and the fact that the outcome of monitoring associated with each phase of the HWSI is unknown at this time, the assumptions documented in Table 1 will be closely monitored, and should changes be anticipated, Tetra Tech will provide recommended adjustments.
Table 1. HWSI AOI Assumptions1
Receiving
Water
Phase2
Outfall
Phase3
Catchment
Phase,
Level 13
Catchment
Phase,
Level 23,4
Catchment
Phase,
Level 33,4
Catchment
Phase,
Level 43,4
# of Locations 3 4 3 2 2 2
# of Events 12 12 8 8 8 -
# of HF183 Batches 2 2 2 2 1
Notes:
1 Paired sampling for E. coli and HF183 will occur at all locations, with all E. coli samples analyzed. 2 75% of E. coli samples meet the USCR CHWSRS Work Plan trigger to analyze the paired HF183 samples. 3 65% of E. coli samples meet the USCR CHWSRS Work Plan trigger to analyze the paired HF183 samples. 4 Catchment Investigation levels 2-4 are not included in scope and f ee. E. coli and HF183 samples will be analyzed by contracted accredited analytical laboratories in accordance with specifications defined in the SAP/QAPP.
Upon receipt of analytical laboratory results, Tetra Tech will review the results for completeness and consistency with the Data Quality Objectives specified in the SAP/QAPP. Tetra Tech will coordinate with the laboratories regarding any data quality concerns. Tetra Tech will populate the AOI Reporting Forms with a brief Interim Data Summary upon completing the Receiving Water, Outfall, and Catchment Level 1 Phases for each HWSI (nine total). It is assumed that additional summaries will not be needed in subsequent catchment level phases based on decisions made in earlier phases with respect to the monitori ng results and to allow for timely progression of catchment level investigations. A final data summary will be provided via the AOI Reporting Form after the completion of each HWSIs with laboratory reports and data files in CEDEN-compatible format.
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Assumptions
• Modifications to the catchment delineations will require minor adjustments rather than intensive large- scale changes.
• One catchment investigation will require permitted confined space entry for sampling. • The permit to access Los Angeles County Flood Control District (LACFCD) assets can be used for the investigations, and no other access permits are required. • See Table 1 for HWSI sample analysis and site assumptions. • Tetra Tech will rent a -80C freezer for 1 year t o store the HF183 filters after 1-year, unanalyzed filters will be discarded or transferred to a location of the City’s choice (i.e., alternate laboratory).
Deliverables
• LACFCD Permit Application
• AOI Report Form Template
• Field Maps App
• Interim Data Summaries for each AOI (receiving water, outfall and catchment level 1) • Final Data Summary for each AOI
Upper Santa Clara River
Comprehensive Human Waste Source Reduction Strategy Scope of Work 5 1/30/2023
SCHEDULE
The schedule is summarized in Table 2 below and is based on months from NTP.
Table 2. CHWSRS Work Plan and Investigation Implementation Schedule Task
# Task Name Deliverable Completion
1 Project Management Invoice and Progress
Report Monthly
2 CHWSRS Work Plan
Draft Work Plan 3 Months from NTP
Final Work Plan 4 Months from NTP
2 Draft SAP/QAPP 4 Months from NTP
Final SAP/QAPP 5 Months from NTP
3 Meeting and Regulatory Support
Meeting slides As needed, 16 months
from NTP
3 Talking points, comment
responses
As needed, 16 months
from NTP
4 Human Waste Source Investigations
LACFCD Access Permit
Application
As applicable, 6 months
from NTP
4 Investigations (3 AOIs) 16 months from NTP
4 Final Status Summaries 16 months from NTP
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COST
Tetra Tech proposes to complete the work on a Time and Materials basis and will invoice monthly according to Tetra Tech standard invoicing periods.
Upper Santa Clara River
Comprehensive Human Waste Source Reduction Strategy Scope of Work CHWSRS SOW Appendix A
APPENDIX A: CHWSRS WORK PLAN OUTLINE
DRAFT OUTLINE
Executive Summary
Table of Contents
List of Figures
List of Tables
Appendices
List of Acronyms and Abbreviations
1.0 Introduction
1.1. Purpose
• Discuss project purpose, goals, and desired outcomes
• Brief, big picture- human waste
1.2. Regulatory/Scientific Background
• SCR Bacteria TMDL
• Existing MS4 Permit
1.3. Relationship to the USCR WMP/CIMP
• Recent WMP Update
o Bacteria Priority 1 (highest priority)
o New MS4 Permit
1.4. Progress/Work to Date
• Weekly bacteria sampling at Reach 6 and its two paired outfalls • CIMP monitoring
1.5. Document Organization
• Brief summary and table summarizing how the work plan is organized
2.0 Comprehensive Human Waste Source Reduction Strategy Steps
2.1. Monitoring and Assessment Framework
• Overview and Flow Chart
• Emphasize the following themes:
o Receiving water monitoring, followed by upstream investigations (as needed) to identify/abate sources
o Prioritize areas with greatest REC use/risk
o Prioritize dry weather investigations to focus resources. Also, identify areas that would benefit from near-term wet weather investigations
o Initial use for Catchment Prioritization and then adapt as necessary over time to refine the prioritization and better target Source ID and abatement efforts based on data collected, scientific advancements, regulatory updates, etc.
• Introduce conceptual site model/graphics depicting differences between dry and wet weather sources and transport, and how that informs dry and wet weather investigation and abatement • Introduce Catchment Prioritization approach
o Graphic that communicates the steps and individual components of the scoring. Discuss rationale for the key components selected and how they’re integrated (source composite scores, matrix plots, and other factors)
o Discuss process for delineating catchments and data used o Include table or writeup that briefly summarizes the major human sources considered (sewer exfil, encampments, etc.), why they are important (utilize WMP language, Bacteria TMDL etc.), data used, current assumptions/limitations, and scoring methods
3.0 REC-1 Receiving Water Quality Condition Assessment
Upper Santa Clara River
Comprehensive Human Waste Source Reduction Strategy Scope of Work CHWSRS SOW Appendix A
• Summarize Current Dry and Wet Weather Conditions
o Data analysis methods. Discuss parameters/data period used, analysis methods o Summarize results. Reference CIMP annual report adaptive management language • Describe how the results were used in Catchment Prioritization. Include example maps to show how we linked the receiving water results to catchments to assess connectivity and potential impacts. Reference 303(d)/TMDL segments and overlay on maps o SCR Bacteria TMDL
• Describe data gaps and refinements that can be used to support future prioritization and source identification/abatement efforts
4.0 Upstream Water Quality Condition Assessment
• Summarize Dry and Wet Weather Conditions
• Include paired FIB/HF183 data analysis methods/results. Describe how the results were used in Catchment Prioritization. Include example maps to show how we linked the Reach/Outfall results to catchments to assess connectivity and potential impacts. Reference 303(d)/TMDL segments and overlay on maps
o SCR Bacteria TMDL
• Describe data gaps and refinements that can be used to support future prioritization and source tracking/abatement efforts
5.0 Catchment Prioritization
5.1. Preliminary Catchment Prioritization Results
• Discuss changes based on adjustment factors
• WMA map that shows catchment prioritization rankings (considering dry and wet weather separately)
6.0 Source Identification Monitoring
6.1. Human Waste Source Investigation Overview
• AOI Characterization
• Stakeholder Coordination
• Additional Data/Source Inventory
• Monitoring Strategy
o Toolbox
o Sites
o Timing
• Outcomes
7.0 Source Abatement
7.1. Enforcement and Source Abatement Actions
• Brief overview of key programs/strategies
• Include summary table
7.2. Outcomes
8.0 Performance Monitoring
8.1. Phase 3
• Source Inventory Updates
• Monitoring Activities
• HWSI Coordination and Investigation Close Out
• Outcomes
9.0 Work Plan Adaptation Process
• Allow for flexibility to adapt to changing conditions, resource allocation, progress, potential future refinements due to regulatory/compliance pathway updates, etc. • WMP and RAA updates. Discuss potential use of new indicators and compliance methods in the future depending on regulatory decision-making.
Upper Santa Clara River
Comprehensive Human Waste Source Reduction Strategy Scope of Work CHWSRS SOW Appendix A
• Progress Tracking and Verification (Performance Monitoring) o Verification steps and collaboration needs
o Align with monitoring recommendations and Alternative Indicators o Better incorporation of “risk” in the future to help streamline efforts
10.0 Reporting
10.1. Work Plan
10.2. Progress Updates Per Investigation
10.3. Annual Reporting and CEDEN EDDs
o Adaptive Management, every 2 years as part of the annual reporting
10.4. Monthly Bacteria TMDL Reports
o Weekly sampling
11.0 Continued Work
References