• 2011 Recycled Water Master Plan Update [link to the report].
• Recycled Water Study [link to the report].

According to the Recycled Water Master Plan, its purpose “is to evaluate opportunities to maximize non-potable reuse [of recycled water treated to tertiary standards] if IPR (Indirect Potable Reuse) projects are not pursued” [emphasis in italics is mine].

IPR refers to a series of advanced treatment processes applied to the tertiary water that results in purified water that is in essence distilled water and then to store that water in an underground aquifer or to blend it with imported raw water in an above-surface reservoir.

Nonpotable recycled water, of course, is limited to use in specific agricultural, irrigation, and certain industrial settings. A separate pipeline infrastructure must be built to deliver that water (“purple pipe water”), and you definitely can’t drink it.

This blog post, therefore, focuses on the subject of the companion to the Recycled Water Master Plan, the City of San Diego’s Recycled Water Study.

After considering a number of options, the Recycled Water Study mainly examined two possible ways IPR projects can be pursued in San Diego: 1) use IPR water to recharge groundwater resources, or 2) mix it with imported water that is piped into and stored in local reservoirs (sometimes referred to as “reservoir augmentation”). IPR, as you probably know, results in water that is of higher quality than the water we import from the Colorado River and Northern California and it can be used for any purpose, including for drinking, and delivered using our existing potable water infrastructure.

Another option examined in the Recycled Water Study, Direct Potable Reuse (DPR)–which would deliver the purified recycled water directly into the water distribution system instead of mixing it with imported reservoir water—has not been well-studied and would be difficult to implement without the development of new statewide regulations, so the study concludes it is not on the table for the near future in San Diego.

The Recycled Water Study envisions that continuous increases in the price of imported water along with decreased reliability and availability of imported supplies will soon make the relatively expensive IPR process competitive with imported prices (it’s already competitive with, if not cheaper than, the cost of desalinated water)…and will eventually be dramatically less expensive than imported supplies.

The Recycled Water Study was the outgrowth of an agreement between San Diego Coastkeeper, the San Diego Chapter of the Surfrider Foundation, and the City of San Diego, whereby the environmental groups agreed not to oppose the EPA’s Regional Water Board’s, and Coastal Commisssion’s approval of San Diego’s Clean Water Act waiver that allows the Point Loma Wastewater Treatment Plant to continue discharging into the ocean the sewage receiving only Advanced Primary instead of Secondary treatment. The waiver expires in 2015, with an application due a year before expiration, so time is of the essence.

If San Diego chooses not to pursue upgrades to the Point Loma treatment plant to full Secondary treatment standards before the expiration of the current waiver, there is widespread speculation that the governmental agencies are not likely to renew the waiver and the city could face huge financial penalties AND be faced with a full upgrade to the treatment plant.

Upgrading Point Loma to Secondary treatment at its current load would be exceedingly expensive partly because of the large wastewater flow it receives and partly because there’s little room to expand on the limited hillside space it occupies facing the ocean along Point Loma’s western slope.

So…the Recycled Water Study envisions that if enough water is recycled, particularly via the advanced IPR treatment process, a good deal less wastewater would be sent to Point Loma. Point Loma then would be burdened with treating less wastewater and it would be much less expensive to upgrade to Secondary treatment standards. In that scenario, the city could even apply for federal financial assistance to upgrade Point Loma to Secondary treatment. If nothing is done and the waiver expires, the city would face large fines, be forced to upgrade to Secondary treatment at greater ratepayer expense and would not be eligible for federal financial assistance.

The Recycled Water Study concludes that groundwater recharge opportunities are extremely limited given San Diego’s geography. As such, using IPR water for reservoir augmentation is the most realistic option for San Diego to incorporate purified recycled water into its its potable water portfolio.

(the above photos show a portion of the advanced treatment facility being used for the Water Purification Demonstration Project. Click to enlarge)

Therefore, a Water Purification Demonstration Project examining the feasibility of using the IPR process focusing on reservoir augmentation by the City of San Diego is currently underway. A prototype advanced treatment facility at the North City Water Reclamation Plant is producing a limited amount of IPR water while a parallel scientific study is being conducted on the feasibility of blending IPR water with imported water in the San Vicente Reservoir.

When the Demonstration Project is completed, a number of unfinished regulations and guidelines addressing IPR must be approved by federal, state, and local agencies before San Diego can implement IPR reservoir augmentation on a large scale.

One problem with the NR&C vote on Wednesday, though, is that the committee simply “approved” both reports to advance to the City Council. The motion to approve both plans made no recommendation as to which plan to implement; that is, whether to commit to nonpotable recycling in the future, or recommend a combination of nonpotable recycling and IPR projects.

This decision tree from the Recycled Water Master Plan illustrates the issue:

There was, however, some indication of the direction towards which the committee leans on this question.

During discussion before the vote, Councilmember Sherri Lightner appeared to favor developing a balanced plan, incorporating nonpotable and potable recycled water, especially since a significant amount of nonpotable water infrastructure already exists and there are contracts and plans already in place to expand that form of recycled water use.

Another issue is that the Recycled Water Study raises the possibility of a much larger capacity facility to produce the advanced treatment product water (or several new satellite IPR facilities) to achieve a goal of producing as much as 100 million gallons per day (GPD) of IPR water, and it implies that because the San Vicente Dam Raise Project will more than double the capacity of the reservoir, there would be capacity to handle it.

That raised a question in my mind, which I decided to ask during the public comment portion of the NR&C meeting: the fact being that the County Water Authority (CWA) is building the San Vicente Dam raise and it will own the rights to the additional capacity. Would CWA buy IPR water from the city or fill it with imported water? And if all the water in the reservoir will be mixed, would it then be delivered to all the CWA member water agencies…and would they be agreeable? I also suggested that due to the close proximity of El Capitan Reservoir (currently San Diego’s largest), why not consider using both San Vicente and El Capitan as receiving reservoirs for IPR water?

Later, during committee discussion, Councilmember and committee chair David Alvarez asked PUD staff about that. Assistant PUD Director Marsi Steirer allowed that San Diego would only be adding IPR water to the portion of the reservoir capacity that the city owns…and that if the city eventually did produce up to 100 mgd of IPR water, its portion of San Vicente reservoir could consist entirely of IPR water. My question regarding El Capitan was not addressed at that time, but I’ve since learned it was a point of discussion during production of the report.

Ms. Steirer later sent me email addressing that question. With her permission, I’m reprinting a portion of her reply here:

But El Capitan isn’t entirely out of the question: Ms. Steirer also pointed out that the San Diego Reservoir Intertie Study although currently on hold due to U.S. funding constraints, includes plans to consider a connection between San Vicente and El Capitan. The conclusion, she says, is “if an intertie were established either directly or indirectly between San Vicente and El Capitan, we assume that it could accommodate a larger capacity IPR/RA project.”

Councilmember Alavarez also commented that he believes that IPR is 100% the only solution he believes will work to solve the issue of increasing local water supply and reliability, as well as dealing with the Point Loma plant upgrade.

It’s not certain when this item will be docketed for the full City Council, but a condition of the Coastal Commisssion’s approval of the last waiver was that the Study be presented in approximately two years, and that deadline is fast approaching. The City is also pressured to act quickly, because even if the Demonstration Project concludes successfully and the city promptly moves to develop a large-scale IPR operation, it certainly won’t be finished, and most likely construction wouldn’t even be started, by 2015. Therefore, the only way for the City to be assured it will qualify for one or more additional waivers would be to get an approval and timeline in place to implement a significant amount of IPR, and thus justify the delay in upgrading the Point Loma treatment plant.

Related local news reports:

• Sewage recycling would save San Diego money: Study / North County Times
• Recycled water getting another look / U-T San Diego
• Sewage Plan Envisions Massive Expansion of Wastewater Recycling / Voice of San Diego

Although San Diego’s County’s overall grade declined slightly from ASCE’s 2005 report card, the water and wastewater grades have shown some improvement with two Bs and a B+.

The chart on the right compares the grades between the 2005 and 2012 reports:

To produce the report, the ASCE Report Card Team assembled 11 working teams of over 100 expert engineers from the public and private sector to spend a year assessing San Diego’s infrastructure in a variety of categories: aviation, bridges, land and sea ports of entry, levees/flood control/urban drainage, parks/recreation/environment, K-12 school facilities, solid waste, surface transportation, wastewater/collection system, wastewater/treatment, and water.

San Diego’s management of water and wastewater (and associated costs) has been a growing topic of public and political discussion lately, especially as the election season progresses. One mayoral candidate in particular has continuously criticized the Public Utilities Department and reportedly would like to see the entire operation privatized. The County Water Authority’s lawsuit against the Metropolitan Water District on water prices, developments in the Quantification Settlement Agreement (QSA) lawsuit, and Councilmember Lightner’s recently adopted new water policy for the city are other examples of topics that have been regularly in the news, although often in a sensational way.

Objective, non-political information has been difficult to find. The ASCE Report Card helps put lots of these issues in sober perspective.

Following the break are report summaries for each grade given, followed by excerpts from the more detailed discussion further in the report.

B | Wastewater/Collection System

“Wastewater collections systems include gravity pipelines, pump stations, and
pressurized pipelines also known as forcemains. Overall, the condition of the wastewater
collection systems in the San Diego region showed a marked improvement from the
last Infrastructure Report Card in 2005. The collection systems are generally in good
condition, however, portions of the systems remain in fair condition. The primary impetus behind this improvement was an unprecedented and sweeping regulation in California that required wastewater collection agencies to proactively maintain, replace, and fund necessary collection system improvements. The fact that the condition of wastewater collection systems has improved over the past seven years is a very positive trend.”

“From a public policy perspective, it is important that policy makers recognize that, as wastewater collection systems age, the replacement of this vital infrastructure requires continual attention. Recent history has shown that routinely maintaining and replacing wastewater collection system infrastructure is a much more cost-effective and better use of increasingly scarce public dollars than waiting for infrastructure to fail. As such, ASCE strongly encourages policy makers to continue to make tough decisions pertaining to rate adjustments, grant funding, etc., to adequately fund the replacement of this infrastructure before it fails.”

B+ | Wastewater Treatment

“Wastewater treatment and water recycling facilities in San Diego County are well
managed and consistently meet or exceed state and federal regulations. Long-term
asset management plans are in place, regional cooperation is high, and infrastructure
investment over the past decade is paying dividends in the form of fewer wastewater
spills, cleaner beaches, increased production and consumption of recycled water, and
acceptance of wastewater as a valuable commodity. Current programs are adequately
funded in general, however, additional public and private investment will be required to
maintain compliance and to achieve an appropriate level of resource recover energy and
other resources”

B | Water

“The water category includes water supply, potable water supply systems, potable
treatment plants, potable water distribution systems, and recycled water distribution
systems. The condition and capacity of water agency treatment and distributions systems
varies among agencies, but in general they are considered good. There is much to
be positive about in the outlook for water in San Diego; however, there is much to be
concerned about. The region’s focus on diversifying its water supply portfolio over the
last 15 years has been successful, but there is more that needs to be done. Long-term
reliability of our traditional imported water supplies is threatened by environmental issues, climate change, and competing needs. Although agencies have assessed the condition and capacity of their infrastructure as generally good, they have identified replacement and rehabilitation as a high priority to maintain service reliability. The challenge agencies face currently and in the future are managing water rates while balancing capital project funding needs against rapidly rising cost of water supplies, regulatory requirements, and economic cycles.”

______________________________

Here are some selected excerpts from the detailed discussions on water in the report (pages 81-91):

Sewer spills

“Within San Diego County, 47 agencies own, operate, and maintain more than 7,000 miles of collection system pipes and associated pump stations and force mains. The wastewater committee submitted surveys to all agencies and received responses representing 23 agencies with an aggregate total of more than 6,200 miles of pipelines and 206 pump stations, which represents almost 90% of the system in the region. The respondents had a combined average of 91 sanitary sewer overflows (SSO’s) per year for the past five years. This averages to about 1.5 SSO’s per 100 miles of pipe, well below the industry average of two SSO’s per 100 miles for a well performing agency.”

Public involvement is an important ingredient in a well-run wastewater management
system. Use the websites operated by these agencies to find announcements and agenda
listings. Many agencies provide a free subscription service that sends updates and
agendas automatically to your inbox. When important projects and budget matters are
under consideration by the decision-makers, your voice in front of the body or conveyed
through written comments is a powerful and meaningful part of the public policy making
process.

Wastewater treatment

“Wastewater treatment operations in San Diego County are dominated by multi-agency partnerships known in government parlance as joint powers agencies or JPAs. Excepting two cities and the United States Marine Corps Base Camp Pendleton, the remainder and vast majority of wastewater treatment services in the county are provided through JPAs. JPAs can provide economies of scale that cities and special district often cannot achieve on their own.”

Water recycling facilities

“WRF’s in San Diego [have the capacity to] treat and recycle 40 MGD, an amount equal to approximately 124 acre-feet (AF) of water each day. Since an AF of water is enough to meet a family of four’s household potable water demand for a year, San Diego WRFs produce enough water each year to supply over 45,000 households – or roughly 6% of the county’s population. However, a significant volume of the recycled water produced in San Diego is not used to supplant potable water and county WRFs possess over twenty-three (23) MGD in unused capacity.”

Wastewater treatment plants

“Respondents consistently reported a high degree of confidence in: the capacity of their facilities to meet the public’s need both now and in the future; and, in the effectiveness of their operations and maintenance programs.

While all the respondents reported having some form of long-term comprehensive asset management program to ensure assets are repaired or replaced in accordance to established criteria, they expressed less confidence in their ability to appropriately fund future operating and capital improvement programs as planned.”

Water

“There is much to be positive about in the outlook for water in the San Diego region. The SDCWA has secured new imported water supplies through a long-term (45-75 years) water conservation and transfer agreement with the Imperial Irrigation District. The deal, reached in 2003, provided 70,000 acre-feet of highly reliable Colorado River water in 2010 and increases to 200,000 acre-feet annually in 2021. The SDCWA also has a separate, 110-year agreement to receive Colorado River water conserved by lining parts of the Coachella and All-American canals. These projects provide 80,000 acre-feet of water to the region.

In recent years, a conservation ethic has been established that many believe is
permanent.

There is, however, much to be concerned about. Water rates have been steadily
increasing and are likely to do so at least in the near future. In the current economy, the ratepayer has become a lot more cognizant of how much they are paying for water and
are often pushing back at public hearings where rate increases are being considered. The
budgets of water agencies will be a significant challenge in the years to come. In respect to infrastructure, the chief concern is the replacement and rehabilitation of distribution systems. Many agencies are still challenged with replacing cast iron water mains which have been found to be the primary reason for the failures of piping systems. Replacing these types of pipelines has proven to be a costly need. The last concern that needs to be emphasized is the challenge of water supply in the region. While the region is increasing its ability to store water locally, it is highly dependent on water from either the Colorado River or northern California both of which face ongoing challenges.”

Water rates

“Water rates in San Diego County have been increasing. The reasons for this are twofold.
First of all, the cost of purchasing imported water from MWD has increased due to
the reduction in allocation of low-cost Colorado River water resulting in more reliance on higher cost water from the State Water Project. At the same time, the allocation of State Water Project water has been reduced to mitigate environmental concerns in the Bay
Delta. Secondly, the recent drought and regulatory restrictions in the Bay-Delta have
drastically reduced water deliveries from the State Water Project and the Colorado River
increasing unit cost of water to fund fixed infrastructure costs. It is expected that water rates will continue to rise to support infrastructure, new water supplies, and decreasing water sales due to conservation.”

What you can do

“As a region, we have been successful in water conservation. Urban and agriculture water users have reduced their combined consumption by 23%. However, likely population growth, more demands on our external water supplies, and new state law will require us to increase conservation even more. Citizens can also keep up on all of the policy discussions that decision makers are having and participate. In the near future decisions will be made regarding water reclamation, desalination, water rates, and infrastructure replacement; all of which will have an impact on all of us. Much can be learned just by reviewing the agendas of city councils and boards or visiting the websites of your local water agency or water department. San Diego has an arid climate, and water issues will always play an important role in the development of public policy that dictate the future of the region.”

I didn’t find anything in the report about the City of San Diego’s Indirect Potable Reuse project (aka Water Purification Demonstration Project) but that’s clearly another initiative that water users should strive to stay informed about because of its positive role in improving water supply reliability and its relationshiop with wastewater treatment, recycling, and conservation.

The above quoted excerpts have been reprinted with the kind permission of Larry Pierce, the Chair of the ASCE Report Card Team, and Dean Gibson, the President of the San Diego Section of ASCE.

I strongly encourage you to read the entire 2012 San Diego County Infrastructure Report Card posted on the ASCE website.

[video and slides were produced by SDCWA. I'm only posting the two products together here so you can watch the slides and video at the same time...and also to help distribute the presentation from the very knowledgeable and well-spoken Halla Razak]

As explained in the court’s background, the QSA was partly the result of California (legally) using more Colorado River water than had originally been allocated to it because Arizona and Nevada were not using their full apportionment. But when Arizona and Nevada began increasing their take, California’s excess usage was theatened and complex legal proceedings resulted in the QSA which actually is 35 separate agreements among varying interests, including an agreement for San Diego to purchase water from Imperial Irrigation District.

The federal case involved a part of the QSA entitled Colorado River Water Delivery Agreement (CRWDA). Plaintiffs sought (1) a declaration that the Secretary violated NEPA and the CAA in executing the CRWDA and (2) an order immediately ceasing water deliveries under the void CRWDA.

Plaintiffs were the Imperial County Air Pollution Control District (the “Air District”) and the County of Imperial. Federal Defendants are the United States Department of the Interior; Ken Salazar, Secretary of the United States Department of the Interior; the United States Bureau of Reclamation; and Michael L.Connor, Commissioner, Bureau of Reclamation. Intervening Defendants are the Metropolitan Water District (“MWD”), San Diego County Water Authority (“SDCWA”), Imperial Irrigation District (“IID”), and Coachella Valley Water District (“CVWD”).

The federal case against the CRWDA portion of the QSA involved many complicated issues, including a drying Salton Sea contributing to air pollution issues, which can be read in the court’s decision below, which finishes:

“For the reasons set forth above, the Court concludes that Plaintiffs’ claims fail for lack of standing, which is sufficient to defeat Plaintiffs’ motion for summary judgment in its entirety. The Court also finds that Plaintiffs’ NEPA claim fails on the merits. Because these findings are determinative and none of Plaintiffs’ claims survives, the Court declines to consider the additional arguments raised by
Intervening Defendants. The Court therefore DENIES Plaintiffs’ motion for summary judgment, GRANTS Federal Defendants’ cross motion for summary judgment, and DENIES AS MOOT Intervening Defendants’ cross motion for summary judgment.”

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Filed under: Water Tagged: Quantification Settlement Agreement (QSA) ]]>