RECEIVED United Water Daniel C. Naumann,

Y United Water ~ CONSERVATION DISTRICT

RECEIVED OCT Oy 2019

FOX CANYON GROUNDWATER MANAGEMENT AGENCY

Boord of Directors

Daniel C. Naumann, President

Michael W. Mobley, Vice President

Bruce E. Dandy, Secretary/Treasurer

Sheldon G. Berger

Robert Eranio

Lynn E. Moulhordt

Edwin T. McFadden Ill

October 4, 2019 General Manager

Mauricio E. Guardodo, Jr.

Jeff Pratt, Executive Director Fox Canyon Groundwater Management Agency 800 South Victoria Avenue Ventura, CA 93009-1610

Subject: Request for Letter of Support from the Fox Canyon Groundwater Management Agency for Proposed Iron and Manganese Treatment Plant at the El Rio Water Treatment and Groundwater Recharge Facility

Dear Mr. Pratt:

The United Water Conservation District (District) is proposing to construct an iron and manganese treatment facility (project) for three (3) existing Lower Aquifer System (LAS) wells as part of the El Rio Water Treatment and Groundwater Recharge Facility (El Rio) located in Oxnard, California. The project is considered a drought resiliency project and will help secure drinking water supplies during periods when water supply and quality becomes impaired in the Upper Aquifer System {UAS). The project will primarily be operated during periods of drought when use of UAS wells is limited by nitrate concentrations or low water levels. The project is in the final design stage and updated construction cost estimates are being developed.

On June 26, 2018, the District was informed by the United States Bureau of Reclamation (USBR) that its application for a 2018 WaterSMART Drought Resiliency project grant was accepted and the District was awarded $300,000 for construction. More recently, the District submitted the project to the Watershed Coalition of Ventura County (WCVC), requesting $2.5 million in grant funding under the 2019 Proposition 1 Integrated Regional Water Management {IRWM) Grant Program. The final grant application will be submitted by WCVC on December 6, 2019. UWCD is seeking a letter of support from the Fox Canyon Groundwater Management Agency (FCGMA) for inclusion with the grant application.

To provide some background on the project, the El Rio facility was originally constructed in 1955 to 1956 for the purpose of minimizing seawater intrusion by reducing groundwater pumping for municipal supply from confined aquifers near the coastline. The Oxnard Hueneme {OH) Pipeline was constructed to provide supplemental drinking water supplies to the cities of Oxnard and Port Hueneme, Naval Base Ventura County at the coast, and several mutual water companies. Pumping was moved to the El Rio facility in the Oxnard Forebay to minimize the influence of extractions on groundwater gradients at the coast.

106 N . 8th Street, Santa Paula, CA 93060 (805) 5 25-4431 Fax : (805) 525- 2661

[email protected] www.unltedwater.org

Legal Counsel

David D. Boyer

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, • ■ Fox Canyon Groundwater Management Agency ~ October 4, 2019 "ij @

The Oxnard Forebay exhibits excellent recharge capabilities. Surface water from the Santa Clara River is distributed to a series of basins totaling an area of approximately 80 acres. The water, which is used to recharge the groundwater basin, is later extracted through a system of twelve (12) wells at the El Rio Facility. The wells were constructed at different depths, with nine (9) wells screened in the UAS at depths of approximately 300 feet, and three (3) wells screened in the LAS at depths of over 1,000 feet. Due to the Surface Water Treatment rule, eight (8) of the UAS wells require disinfection.

As a result of recent drought conditions that started in 2012, nitrate concentrations in the UAS wells have been increasing, corresponding with gradually declining groundwater levels. Production from the LAS wells and subsequent blending with water from the UAS wells has allowed United to maintain nitrate concentrations in delivered water below the maximum contaminant level (MCL) . Nitrate at elevated concentrations in drinking water can cause a condition known as Methemoglobinemia or "Blue Baby Syndrome." Nitrate is regulated as a primary contaminant by the State Water Resources Control Board's (SWRCB) Division of Drinking Water (DDW). However, water produced from the deep LAS wells contain high levels of iron and manganese. Naturally occurring sources of iron and manganese are more common in deep wells and, at high concentrations, affect water's taste, color and odor and cause staining. Although not a health concern, both contaminants are regulated by the DDW as secondary drinking water standards.

The project is comprised of construction of an iron and manganese treatment plant for the LAS wells at El Rio, to blend directly with UAS well water prior to disinfection. The project will improve the operational flexibility and drought resilience of the OH Pipeline system. It will ensure that water can be delivered to OH Pipeline customers even during severe drought conditions while meeting both primary and secondary drinking water standards.

The project directly benefits several economically disadvantaged communities that receive drinking water from the OH Pipeline system.

The District is hopeful that the FCGMA can offer its support for this project, as it benefits a significant portion of the urban population within the boundaries of the agency. The OH well field and pipeline have proven to be an effective project to increase the yield of the Oxnard Plain while minimizing seawater intrusion associated with groundwater extractions that serve the City of Oxnard, the Port Hueneme Water Agency, and others. If you desire more information related to this project, please let us know. Thank you for considering this request.

Maryam Bral, Ph.D., P.E. Chief Engineer

Attachments - IRWMP Prop 1 Project Information Form

Item 2A - Page 2 of 14

Project Information Form (PIF)

A. PROJECT INFORMATION

1. Project Title: Iron and Manganese Removal Project (Phase 1)

2. Project Sponsor(s): United Water Conservation District

3. Eligible Applicant Type: Public Agency ... 4. IRWM Project Region(s) : Watersheds Coalition of Ventura County

5. Does the project provide benefits directly to a Disadvantaged Communities (DAC) and/or Economically Distressed

Areas (EDA) (minimum 75% by population or geography)?

D Yes 0 No If yes, please complete D.8 and/or D.9. Show on map if applicable.

6. Is the Project Sponsor a Tribe, or does the project provide benefits to a Tribe (minimum 75% by population or

geography) as defined by Proposition 1?

D Yes 0 No If yes, please complete D.10. Show on map if applicable.

7. Provide project map. Include location of project, project benefit and/or service area, and other applicable

information .

8. Funding Category:

D DAC Implementation Project

0 General Implementation Project

9. Project Type: ' water quali ty - -;i Other: .__ _______________ ____,

Select most applicable project type. See Section 11.C. of the 2019 Guidelines for full description of eligible project

types. If "Other" is selected, please write in the space provided the proposed project type.

B. SELECTED ELIGIBILITY REQUIREM ENTS 1. Will the project be included in the IRWM Plan, that will be adopted prior to anticipated Agreement Execution?

0 Yes D No 2. Does the project address a critical need(s) and/or priority(ies) of the IRWM Region as identified in the IRWM Plan?

0 Yes D No If yes, complete part a:

a. What IRWM Plan goal(s)/objective(s) does the project address? Identify and explain.

The project meets the following WCVC IRWMP Plan Goals. (1) Protects, conserves, and augments local water supply

(retains the ability to use the El Rio Wellfield and United's O-H System that supplies the City of Oxnard, Port

Hueneme, and mutuals), (2) Protects and improves water quality (allows United to meet nitrate and iron and

manganese water quality standards), (3) Prepares for and adapts to climate change (project anticipates longer and

greater droughts and puts the infrastructure in place to address these impacts).

3. Does the project have an expected useful life consistent with Government Code §16727 (generally 15 years)? If

not, explain why this requirement is not applicable .

The expected life of the infrastructure improvement is assumed to be approximately 40 years (based on

Environmental Protection Agency. 2003. Asset Management: A Handbook for Small Public Water Systems - STEP

Guide Series (EPA 816-R-03-016)

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4. Does the project address and/or adapt to the effects of climate change? Does the project address the climate

change vulnerabilities assessed in the IRWM Plan?

0 Yes D No If yes, please explain below.

Under drought, quality limits use of the 0 -H system. Without recharge, nitrates in the Upper Aquifer System increase.

Generally Lower Aquifer System water can be used to blend, but high iron and manganese levels are limiting the

ability to use the Lower Aquifer System. Nitrate treatment of shallow wells was explored, but due to higher life cycle

cost and inability to use shallow wells if water levels continue to decline, United determined that iron and manganese

treatment for the 0-H System is the preferred method for addressing groundwater quality impairments.

5. Does the project contribute to regional water self-reliance?

0 Yes D No If yes, please explain below.

Project preserves the ability to use water from the El Rio Wellfield and 0-H System which has a temporary extraction

allocation (TEA) of 11,757 AFY. The TEA, as part of Fox Canyon Groundwater Management Agency Emergency

Ordinance E establishes a historical extraction allocation for the El Rio Wellfield at 14,697 AFY, based on the average

annual extractions in years 2003 through 2012. TEA sets the extraction allocation at 80% of the historical allocation;

or 11,757 AFY. TEA is anticipated to be superseded by a different ordinance by the end of 2019.

6. Does the project provide a benefit that meets at least one of the Statewide Priorities as defined in the 2019 IRWM Grant Program Guidelines?

0 Yes D No If yes, please identify below.

Project meets the Statewide Priorities, "Manage and Prepare for Dry Periods", "Provide Safe Water for All

Communities" and "Improvement of Water Quality, including drinking water treatment and distribution."

7. Will CEQA be completed within 12 months of Final Award?

0 Yes

D NA, project is exempt under CEQA

D NA, not a project under CEQA

D NA, project benefits DAC/EDA/Tribe (minimum 75%), or a Tribe is a local project sponsor

□ No 8. Will all permits necessary to begin construction be acquired within 12 months of Final Award?

0 Yes

D NA, project benefits DAC/EDA/Tribe (minimum 75%), or a Tribe is a local project sponsor

□ No

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C. WORK PLAN, BUDGET, and SCHEDULE SUMMARY 1. Project Description: Provide a brief project description summarizing major components, objectives, goals, and

intended outcomes/benefits (quantitative and qualitative). The project intent is to keep the El Rio Wellfield a viable water source. Objectives include building a treatment plant that can treat 3,500 gallons

per minute that is able to handle a maximum iron load of 3.8 mg/Land a maximum manganese load of 0.8 mg/L. The treated water criteria is non

detect for both iron and manganese (less than 30 µg/L and 10 µg/L respectively). The goal for the blended water quality is to maintain nitrate

concentrations well below the maximum concentration limit (currently 10 mg/L of nitrate as N). Project is to design (in progress) and construct a

treatment plant and associated well upgrades, specifica lly: Earthwork, drainage and site grading/paving for the treatment plant; Piping related to

well water supply, treated water, return washwater, and waste solids; Modifications to existing chlorine gas system; Two pressure filter vessels

(12' diameter x 40' length) with dual media consisting of Greensand Plus and anthracite; 195,000 gal lon washwater recovery tank (above ground,

bolted steel); Pump stations related to return washwater, filter drain, and waste-solids disposa l; CMU building for housing air scour blowers,

electrical equipment, ana lytical instruments, and lab space. The project will be divided into two phases. Phase 1 capacity (current design) is 3,500

gpm or 5,646 AFY (current construction cost estimate), Phase 2 capacity (ultimate design) is 8,500 gpm or 13,711 AFY (not included in the

construction cost estimate).

2. Budget: Provide cost estimates for each Budget Category listed in the table below. (Required for Pre-Application

Material Submittal; not required for Final Application Submittal)

Table 1 - Project Budget (a) (b) (c) (d)

Category Cost Share: Non- Requested Grant Other Cost Share (including Total Cost

State Fund Source Amount other State Sources)

(a) Project 328,600 0 0 328,600

Administration

(b) Land Purchase/ 0 0 0 0 Easement

(c) Planning/Design

/Engineering 653,900 0 0 653,900

/Environmental

Documentation

(d) Construction/ 3,201,731 2,500,000 0 5,701,731 Implementation

(e) Grand Total (Sum

rows (a) through 4,184,231 2,500,000 0 6,684,231 (d) for each

Note: Provide information or other documentation to support the cost estimate in a separate attachment. Identify the source of all cost share and other funds. If other funds are not used, describe efforts to obtain other funding and/or why other funding sources were not used.

Project administration cost estimated by past IRWMP grant administrator, design costs based on design engineer bid, construction cost based on

design engineers estimate.

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3. Cost Share Waiver Requested (DAC or EDA)? D Yes 0 No If yes, continue below:

Cost Share Waiver Justification : Describe what percentage of the proposed project area encompasses a DAC/EDA,

how the community meets the definition of a DAC/EDA, and the need of the DAC/EDA that the project addresses.

In order to receive a cost share waiver, the applicant must demonstrate that the project will provide benefits

(minimum 25% by population or geography) that address a need of a DAC and/or EDA. No cost share waiver is requested. However, the District estimates that 45% of the water served in the O-H Pipeline service area benefits

disadvantaged communities (based on geography) . See attached map for additiona l information.

4. Schedule: Include reasonable estimates of the start and end dates for each Budget Category listed in Table 1-

Project Budget. (Required for Pre-Application Material Submittal; not required for Final Application Submittal)

Table 2 - Project Schedule

Category (al (bl

Start Date End Date

(al Direct Project Administration Jul-18 Dec-21

(bl Land Purchase/Easement Not applicable Not applicable

(cl Planning/Design/Engineering/Environmental Jul-18 Dec-19

Documentation

(dl Construction/Implementation Apr-20 Dec-21

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D. OTHER PROJECT INFORMATION

1. Provide a narrative for project justification. If applicable, include references to supporting documentation such as

models, studies, engineering reports, etc. Include any other information that supports the justification for this

project, including how the project can achieve the claimed level of benefits.

In 2016, United prepared a technical memorandum, Feasibility Assessment of Iron and Manganese Removal Facilities at the El Rio Water

Treatment Plant (UWCD 2016). The report incorporated results of an on-site pilot test conducted in 2016. The analysis considered a dual media

(anthracite and manganese dioxide-coated sand) iron and manganese treatment and removal system with a capacity of 3,500 gallons per minute

(gpm), or the equivalent of one Lower Aquifer System well. The analysis showed that treatment of one deep well will achieve project objectives.

The configuration of the deep wells would allow systematic cycling of the wells (one at a time) to ensure reliability and redundancy. Pilot testing

confirmed project feasibility. It should be noted that treatment of one LAS well is considered sufficient given historical drought cycles. The

proposed treatment plant capacity of 3,500 gpm or 5,646 AFY is part of the Phase 1 construction. Should drought conditions persist and worsen,

the proposed treatment plant will be constructed with provisions for expansion (Phase 2) up to 8,500 gpm or 13,711 AFY. Only the Phase 1

construction costs are included within this request. In addition, United did evaluate three scenarios for the removal of nitrates (eliminating the

need to use Lower Aquifer System wells for blending) . The three scenarios considered were : (1) do nothing, (2) treat for iron and manganese and

blend water to deal with nitrates, and (3) operate the upper aquifer wells with a nitrate treatment system. The study found that finished water

quality was better (lower nitrate, iron, and manganese) under Alternative 2 (the project proposed in this grant application). The study also

calculated the 20-year life cycle cost and nitrate removal performance for the three alternatives and found that Alternative 2 (the project

proposed in this grant application) was three times more cost effective in removing nitrates. This evaluation confirmed project cost

effectiveness. In the summer of 2018 United advertised a Request for Proposals for design of the Iron and Manganese Treatment Plant; a design

firm has been selected and design has proceeded to the 30% stage. Design has confirmed design costs and has refined construction costs.

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2. Project Benefits Table:

Table 3 - Project Benefits Anticipated Useful Life of Project (years): 40

Primarv (Reauired) Type of Benefit Claimed:

I Benefit Units*: I AFY ... Water Supply - Groundwater ...

Secondarv (Ootional) Type of Benefit Claimed: , Water Quality - Groundwater ... Benefit Units*: I Other ...

Physical Benefits (At project completion or lifetime, as appropriate)

(a) (bl (c)

Benefit Added Physical Benefit Description Quantitative Benefit

Primary Treatment of local supply so it can be used for potable Continued, reliable use of local groundwater up to the water. TEA of 11,757 AFY for the El Rio Wellfield.

Secondary Lowered concentrations of nitrate, iron, manganese Without project, annua l exceedence probability would be

7.8% for nitrates; 17% for iron, and 21.5% for manganese.

Qualitative Benefits (For Decision Support Tools, please describe non-physical benefits.)

Allows United to invest in infrastructure that improves ability to deliver drinking water during long-term drought.

Comments: [Include narrative on additional benefits, as warranted.]

* DWR may require applicant to convert or modify Benefit Claimed and/or Benefit Units. Where applicable, select one of the following units that corresponds to

the benefit claimed :

• For water supply produced, saved, or recycled, enter acre-feet per year (AFY)

• For water quality, enter constituent concentration reduced in mg/L

• For flood damage reduction, enter inundated acres reduced in acres

• For habitat improved, restored or protected, enter habitat restored in acres

• For fishery benefits, enter increased fishery flow rate in cubic feet per second (cfs)

• For species protection, enter number of species benefited

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3. Does the proposed project provide benefits to multiple IRWM regions [or funding areas]? If the project is located

in another funding area, please provide the information requested in the 2019 Guidelines, Section 1.A.

D Yes 0 No If yes, provide a description of the benefits to the various regions.

4. Provide a narrative on cost considerations. For example, were other alternatives to achieve the same types and

amounts of physical benefits as the proposed project evaluated? Provide a justification as to why the project was

selected (e .g., if the proposed project is not the lowest cost alternative, why is it the preferred alternative? Are

there any other advantages that the proposed project provides from a cost persepctive?)

United evaluated three scenarios for dealing with nitrates. The three scenarios considered were: (1) do nothing, (2)

treat for iron and manganese and blend water to deal with nitrates, and (3) operate the upper aquifer wells with a

nitrate treatment system. The study found that finished water quality was better (lower nitrate, iron, and

manganese) under Alternative 2 (the project proposed in this grant application). The study also calculated the 20-year

life cycle cost and nitrate removal performance for the three alternatives and found that Alternative 2 (the project

proposed in this grant application) was three times more cost effective in removing nitrates.

5. a. Does the project address a contaminant listed in AB 1249?

0 Yes D No If yes, complete parts band c:

b. Describe how the project helps address the contamination .

Project proposes the facilities need to blend high nitrate water with low nitrate water, producing water in the O-H

system below the Maximum Contaminant Level (45 mg/L) .

c. Does the project provide safe drinking water to a small disadvantaged community?

0 Yes D No If yes, provide an explanation on how the project benefits a sma ll disadvantaged

community as defined in the 2019 IRWM Guidelines.

Project will indirectly benefit small disadvantaged communities (<10,000 population) that are scattered throughout

the Oxnard-Hueneme Pipeline service area (see attached map). These communities indirectly benefit because the O-H

pipeline provides wholesale water to the City of Oxnard and Port Hueneme Water Agency that blend the water with

other water sources and distribute directly to the small disadvantaged communities.

6. Does the project provide safe, clean, affordable, and accessible water adequate for human consumption, cooking,

and sanitary purposes (consistent with AB 685) to meet a specific need(s) of a community?

D Yes 0 No If yes, please describe.

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7. Does the project employ new or innovative technologies or practices, including decision support tools that

support the integration of multiple jurisdictions, including, but not limited to, water supply, flood control, land

use, and sanitation?

0 Yes D No If yes, please describe.

Yes. The project includes implementation of an energy efficiency program that automatically controls production

from the LAS wellfield to the minimum needed to sustain clearwell storage levels and minimum needed to blend with

the UAS wellfield to reduce nitrate concentrations safely below the maximum contaminant level in the Oxnard

Hueneme Pipeline. The project also includes installation of longer, more efficient filter vessels. The 12 ft diameter by

40 ft long filter vessels are not common in California.

8. If the project provides benefits (75% by population or geography) to a DAC, explain the need of the DAC and how

the project will address the described need . Explain how the area/community meets the definition of a DAC.

9. If the project provides benefits (75% by population or geography) to an EDA, explain the need of the EDA and how

the project will address the described need. Explain how the area/community meets the definition of an EDA.

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10. If the project provides benefits (75% by population or geography) to a Tribe or a Tribe is the sponsor of the

project, explain the need of the Tribe and how the project will address the described need.

11. Does the project sponsor have legal access rights, easements, or other access capabilities to the property to

implement the project?

El Yes If yes, please describe.

D NA If NA, please describe why physical access to a property is not needed.

D No If no, please provide a clear and concise narrative with a schedule to obtain necessary access.

Project will be constructed on property already owned by United Water Conservation District.

E. ENVIRONMENTAL 1. Please fill out the CEQA Timeline Table below, if applicable:

Table 4 - CEQA Timeline CEQASTEP COMPLETE? (y/n) ESTIMATED DATE TO COMPLETE

Initial Study Not applicable n/a

Notice of Preparation Not applicable n/a

Draft EIR/MND/ND Not applicable n/a

Public Review Not applicable n/a

Final EIR/MND/ND Not applicable n/a

Adoption of Final EIR/MND/ND Not applicable n/a

Notice o·f Determination Not applicable n/a

a. If additional explanation or justification of the timeline is needed, please describe below (optional).

Project is anticipated to qualify as a Categorical Exemption under Section 15301 "Existing Facilities", Section 15303

"New Construction or Conversion of Small Structures" and 15304 "Minor Alterations to Land". A Notice of Exemption

will be filed with the County of Ventura Clerk and California Department of Fish and Wildlife.

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2. Permit Acquisition Plan :

List all permits needed to complete the project. If the project does not provide benefits to a DAC, EDA, or Tribe

(min 75%), all permits needed to begin construction must be acquired within 12 months of Final Award .

No. Type of Permit Permitting Agency Date Acquired or Anticipated 1. Sludge disposal at WWTP City of Oxnard As part of final design, Apr-Oct 2020

2. Sludge discharge to County Sewer County of Ventura As part of final design, Apr-Oct 2020

3. NPDES Constructon General Permit State Water Resources Control Board Before construction, Oct 2020

4 . Domestic Water Supply Amendment State Water Resources Control Board After construction

5.

6 .

n.

For each permit not yet acquired, describe the following:

No. a. Actions taken to date (include dates of any key

b . Any issues or obstacles that may delay acquisition of permit meetings, consultations, submittals, etc.)

1. Consultant required to confirm permits and

2. requirements as part of 90% design.

3.

4.

5 .

n.

3. Permitting Checklist : This checklist is provided as a courtesy for documentation purposes. Not all permits which

may apply are listed. (Required for Pre-Application Material Submittal; not required for Final Application

Submittal)

a. Does the project involve any activities that may affect federally or state listed threatened or endangered species

or their critical habitat that are known, or have a potential, to occur on-site, in the surrounding area, or in the

service area? (i.e. Federal Endangered Species Act Section 7 Consultant and Section 10 Incidental Take Permit,

California Endangered Species Act Permit, and/or ESA & CESA Consistency Determination)

D Yes D No If yes, please explain:

b. Would the proposed project work in, over, or under navigable waters of the US or discharge dredged or fill

material in waters of the US? (i.e. Rivers & Harbors Act Section 10 Permit and/or Clean Water Act Section 404 Permit)

D Yes D No If yes, please explain:

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c. Will the proposed project have the potential to affect historical, archaeological, or cultural resources? (i.e.

National Historic Preservation Act and/or State Historic Preservaton Officer Consultation)

D Yes 12] No If yes, please explain:

d. Will the proposed project discharge into a water of the US? (i.e. Clean Water Act Section 401 and/or 404 Permit)

D Yes 12] No If yes, please explain:

e. Will the proposed project divert the natural flow of a river, stream, or lake? (i.e . Lake or Streambed Alteration

Agreement)

D Yes G No If yes, please explain :

f . Will the proposed project change the bed, channel, or bank of a river, stream, or lake? (i.e. Lake or Streambed

Alteration Agreement)

D Yes G No If yes, please explain:

g. Will the proposed project use any material from the bed, channel, or bank of a river, stream, or lake? (i.e . Lake or

Streambed Alteration Agreement)

D Yes G No If yes, please explain :

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h. Will the proposed project deposit or dispose of debris, waste, or other material containing crumbled, flaked, or

ground pavement where it can pass into a river, stream, or lake? (i.e. Lake or Streambed Alteration

D Yes 0 No If yes, please explain :

i. For water supply projects, do you need to obtain a water right? (Water Rights Permit)

D Yes 0 No If yes, please explain:

j. Is the proposed project within the defined coastal zone? (Coastal Development Permit)

D Yes 0 No If yes, please explain :

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Item 2A - of 14

RECEIVED United Water Daniel C. Naumann,

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