HomeMy WebLinkAboutStringfellow Toxic Waste 1984-1985 HARRIE TT M. WIE D E R
SUPERVISOR, SECOND DISTRICT
ORANGE COUNTY HALL OF ADMINISTRATION
I�Ip • _= 10 CIVIC CENTER PLAZA,P. O. BOX 687, SANTA ANA,CALIFORNIA 92702-0687
PHONE: 834-3220(AREA CODE 714)
November 12, 1985
The Honorable Ruth Bailey
Mayor, City of Huntington Beach
2000 Main Street, City Hall
Huntington reach, California 92648
:mar Ruth:
Thank you for your recent letter expressing the concerns of the City of
Huntington Beach regarding the potential disposal in Orange County of treated
waste water from the Stringfellow Hazardous Waste Site.
You also requested that the Orange County Board of Supervisors remiire an
Envircnnprital Impact Report (EIR) prior to permitting the disposal of
Stringfellow pretreatedwaste into coastal waters.
Ruth, I certainly share vour concerns reqard ncr the environ=- tal
implications of discharging this material into the ocean. In addition, I am
concerned that leakage .from this site poses a serious threat to the ground
water supplies of Orange County and the Chino Basin area. As you know, I
have taken a leadership role in bringing phis issue before the public and to
the attention of local officials. T#ie Orange County Board of Supen.7isors was
the first cSovernn-ental body to urge that an EiR be prepared, and to ask that
Orange County be represented on the Stringfellow Advisory Conrrrittee.
Your reruest indicates that you may not be aware that Orange County does not
have the authority to require an EIR on the Stringfellow clean = project.
That power is vested in the state. The State Departrrent of Health Services
(DOHS) has declared Stringfellaw to be an "emergency" project and thus exempt
from the California Environmental Quality Act (CEQA) which requires an FIR.
This finding by DOHS is pursuant to state and .federal legislation and federal
"Superfund" regulations.
The authority to issue or deny a permit for the discharge of Stringfellow
treated waste water through Orange County rests with the Orange County
Sanitation Districts, not with the Countv. As a member of the Sanitation
Districts Board of Directors, T'm sure you are aware that the Districts voted
to approve the issuance of the permit for Stringfellow discharge through
Orancre County, Supervisor Roger_ Stanton represents Orange County on the
Sanitation District Board. He has consistently opposed the issuance of a
permit and repeatedly asked for an EIR on the Stringfellow project.
The County of. Orange plans to continue to be part of the Stringfellow
Advisory Committee in order to put forth the interests and concerns of our
citizens. Our representative is Robert Griffith, Director of the Courtv's
Hazardous Materials Program Office. Councilwaraan Barbara Brawn represents
the League of Cities and Lee Podolak, President of the Orange County League
of i ouen voters, is the public representative. These members want ccm=ity
involvement in this issue.
CYPRESS•GARDEN GROVE• HLfJTINGTON BEACH • LOS ALAMITOS • ROSSMOOR •SEAL BEACH •STANTON •SUNSET BEACH •WESTMINSTER
The Honorable Ruth Bailev
November 8, 1985
Page ?
As vour Second nistrict Supervisor, I welcome vour input and continued
interest in Stringfellow. In addition, I relieve it is important for the
City of Huntington Beach and the members of the Environmental Board to
understand that it is the state and federal governments which have the
jurisdiction over -the Stringfellow clean up project, both interim and
ultimate solutions. These q-overnmert entities can receive vour input
directly or through the Stringfellow Advisory Committee.
I want to take this opportunity to update you on the Stringfellow project.
As of this writing, the treatment plant at Gli-n Avon has been constructed,
but it is not yet "on line", so that no treated waste water is coming into
Orange County from Stringfellow. TAJaste water from Stringfellow is being
trucked to Casmal_ia in Santa Barbara County; however, the DOHS has given
Casmalia a forty five day notice (up DecemhPx 21, 1985) to alleviate air
quality problems at their landfill or face closure. This makes us even more
aware that hazardous waste disposal is a serious local and regional environ-
T:�ntal problem which must be solved.
Thank ✓ru again for sharing your views on the St--ingfellow issue. If. I or my
stair can be of further assistance, please do not hesitate to contact us.
Sincerelv,
HARRIFIT M. WIEDER
Supervisor, Second District
IYJ/j ge
cc: Each Board Office
Members, Huntington teach City Council
Charles Thcmpson, Citv Administrator, City of Huntington Reach
Members, Huntington Beach Environmental Board
Robert Griffith, Director, Hazardous Materials Program Office
Councilwoman Barbara Brown, City of Fountain Valley
Lee Podolak, President, nrange County League of Wcmien Voters
s ! v - 1 `t--6-3 C 0"Voei/ MlOeTix9
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e Environmental Board .POP- E„f _ ,0ddfPLf COMAte4ft
J-77
CITY OF HUNTINGTON BEACH mado by 4c-/
H 1:N f1.NGTUN BE.1CH Post Office Box 190 • Huntington Beach, California 92648Ae��r �t d a
e1�Ipr*pro a
October 14 , 1985 �/ d
jxmaot
TO: Mayor Ruth Bailey and All City Council Members
SUBJECT: Stringfellow and Toxic Waste Disposal
Dear Mayor Bailey:
The Environmental Board ' s function is to investigate all actual and
any potential threats to a clean environment of the City and its
inhabitants ; thus at our October 10 , 1985 meeting, the Board
unanimously voted to send the following recommendations to the City
Council .
Eased on the fact that secondary treatment of waste under the 301H
waiver could not tak.e place , it is our concern that an EIR be
initiated . By this process' of an EIR, alternate methods such as
co-generation , the extraction of contaminated groundwater and its
treatment onsite to sufficiently allow discharge to surface waters ,
or to extract the contaminated groundwater , and treat it onsite
.sufficiently to put it back into the ground , should be discussed ,
and clarification and criteria should be mandated.
No official method of stopping the waste flow has been set up should
contamination be discovered, so it is in the opinion of the
Environmental Board that we must strongly urge our City officials to
do all in their power politically to halt the present intent of the
EPA and DOHS from piping the waste out through our City via the
County Sanitation District into the five-mile outflow .
The DOHS is proposing to spend another $1 , 000 , 000 to determine the
cancer-causing toxins in sport fish - and the ultimate risk to the
people that eat them. According to the California Regional Quality
Control Board there are a lot of unknowns out there , therefore it is
imperative that an EIR be completed because chemical contamination
could expose regular eaters of all game fish to an unacceptably high
cancer risk .
Granted we are in sympathy with the citizens of Glen Avon regarding
contamination of their water supply, but we cannot condone as a
solution to their problem the risk of pollution to our ocean waters ,
wildlife and our coast and to those who enjoy the swimming, surfing
and fishing off our coast and the danger to the economics of our
coastal cities .
Stringfellow and Toxic waste Disposal
Page Two
Immediate action is requested as we are advised such dumping will
commence in November and we feel it is a potential threat to the
environment of Huntington Beach and our neighboring coastal cities .
Thank you for your prompt and immediate attention to this serious
matter . If there are any further questions , please feel free to
contact us .
Sincerely,
THE ENVIRONMENTAL BOARD
CMw
( 3472d )
cc: The Orange County Board of Supervisors
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^ A2 Orange Court DAILY PILOT/Sunday, October 6, 1986
ran e Coast included in stud
cancer risk in edibles ort fish ca - p
kn
.
SUSAN HOWLETT pesticide DDT and PCBs are causing from the water waste treatment plant
.di the allyP"Stall the most concern. DDT and PCBs, five miles offshore ..is being con-
The Orange Coast will be included c-
used in the manufacturing of ele sidered as one of the possible sources
•�• trical transfot'mers,.have been found of the contaminants,"it is only one of I
yH,�n a$1 million study by slate health in local fish.The federal government the many possible sources."
;t.pfficials to determine',the extent of has banned both: substances as, Schneider said the Orange County
,;cancer-causing toxins in sport fish carcinogenic. sites'for the study include the New-
';and the ultimate risk to the people The cancer advisory led to the port. Pier; Duna Point Harbor and
a •who eat them. posting of warning signs on Los other locations where sport fishing is
California Regional Water Quality Angeles County piers.Fishing-related prevalent.
«;Control Board spokesman Jim Ben- merchants have complained that "'It's not designed to provide speci-
.dett said the study,which includes the business is suffering because of the` fic sources, it is' to determine the
�? area stretching along the coast from visable public warnings. public health risk," Schneider said, ,
the Santa Monica Buy to Dana Point, State Regional Water Quality She added that if the DDT and PCB
I 'will be an assessment of the risk Board Environmental Specialist levels prove to be unusually high, a '
i associated with white croakers and, Joanne E. Schneider said that public warning may be issued to sport
! other edible fish. although the Orange County outfall fishermen along the'Orange Coast.
i ".There are a lot of unknowns out
there, and we have to stretch- our
resources to fill in the holes."
° • The study,scheduled tois begin next �,�,•a y
ts
month,comes on the heels ofa cancer. Flo V Y. frol 1' 1
i advisory issued in April urging the p
i limited consumption of•the white
','croaker and other fish caught in the lik.el to 'arnve soon
«r'Sanw Monica Buy. (,, (,/ i
" The advisory said chemical'con-
lamination could expose regular l
eaters of the fish to an unacceptably
By ROBERT BARKER with the state toxic substance control i
high cancer risk. Or the Daly Pilot San division,told directors of the Orange
Researchers have said that the The shipment of toxic wastewater County Sanitation Districts in Foun-
;,,• front- the Stringfial«w acid pits in tuin Valley Wednesday night.
1 Riverside County to a dumping Orange County Supervisor Itt.►gt r
n the ocean between New Stanton, who has criticized the plan
ground i New-
port Beach and Huntin ton I from,the beginning, said he's unhap-
may begin late next month,about 1 I pY about Felipe's comments that the
months afterinitial forecasts. waste material may be dumped at sea
State.Department of Hculth Ser- '.for up to 20 years.
vices officials have informed local '1 hate to say I told you so, but I
authorities that the first test inj.ofa$3 said it could take 20 years all along
million plant to pre-tn ut tlic jazurd- and they(state officials)said it would
ous materials near the Stringfellow only be u short-term solution f'or two
site will be conducted Oct. 21. or three years. This is a total
If .all goes well, the hazardous contradiction."
th
materials could begin arriving by k a swipe at
long delay also,ch d n ooffic als for refus-
e
pipeline"about 30 days later. for . in g to delay,
full-blown en-
treutnicnt at Huntington Beach lrcnt- g
meet facilities,Stun Felipe,an officiul', (Please see WATER/A2)
WATER FROM STRINGFELLOViT.:.
•`ftom Al
'vironmental studies on the basis that Services,has been a key reason for the officials have protested the operation,
;the cleanup couldn't wait." dela ng potential en-
Officials Y• , � elaimi studies of
Officials -Plan to remove toxins, vironmental hazards have been in.
The shipment of the waste material which include arsenic, nickel and adequate.
about 187,000 gallons aday-at cyanide, from below the ground and Federal and state officials have j
-_'first was expected to begin as early as claimed the, will
"last January,but has run into numer- pre-treat them at the new plant. pose no
'ous delays.Felipe said administrative The materials will then be trucked ' health dangers to people or wildlife.
dealings with the U.S.Environmental about 10 miles,:injected into.sewer.-
Protection, They have'said, however, that the
Agency, which is taking lines'arid sent on'their journey to hazardous materials are encroaching
" 'over responsibility for the cleanup. Huntington Beach. on underground water supplies in the
Chino•area and must'be removed as
f 'from.the state Department of Health Local residents and city and county• ',quickly as possible.
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t1 .WASHINGTON (AP)'— The.ef 1_ The action:opened the way for'the. Superfund^because,taxin authorit
g,_ Y'..:
fort to renew and expand the stalled Mull.committee.to vote Thursday on for_the 5=year=old program expired
"Superfund"program cleared a hur- •'thei:$10"billion, .five-year,package. :Oct.i.`",
dle:.Wednesday;when':ra,House su vhicli:':_.appeared.°fo„.haVed,,.bioad,. 'Anticipat ng tfie.•ezpiiation, EPA
cornmittee-approved a„toxic, waste '.'bipartisan support: ;' Administratorl:eeThomasinAugust f
bill requiring that cleanups be started, ,.-`.The ' subcommittee's bill is a: ordered a -.-money-conserving
at 600 sites through 1990. strengthened version,'of, Superfund."; slowdown ,of;Superfund :activities, .:.,The legislation,adopted by a voice' :.,reauthorization-legislation that"was: including a halt in cleanup work' f57,>,
: -vote of the Public Works and Trans- written in July by the House,Energy . of the nation's:worst toxic sites.
portation Committee's water 're- and Commerce Committee and,has A principal feature of the subcom-
sources subcommittee, was praised been denounced .by. .enviionmen-, mittee's bill is a requirement that the
by,enviroamentalists,'pushing for a _ talists as too weak.,. :' EPA—which has completed only six' 1
strong Superfund bill and was criti-- : House leaders, including Speaker dump cleanups;since 1980—.begin, t
ciied by the Environmental,Protec-'."Thomas P.O'Neill Jr.,D-Mass.,have -'abatement work at 600 sites by Oct,1;
tion'Agency. ;been,'pushing for quicker,action on.'-- 1990.4 - "• $ f
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t �crucial°documents were located in` ;:coatracts'at the th'ree'sites and:fo'r ..
: '• _ fd.r ' different,offices,under desks,. files '',failin tone otiatethelowestpossible:,
g g
` • =and in a room-under lock and key.". ..,;a price when competitive'bidding'was ` l.
�j. is I d? Ttie auditsaid the state mishandled: :not required,
- = `' �$28.5 million in cleanup contracts for
The auditors urged that$'2 million
"From.staff and'wire reports. three.of California.most hazardous
m federal payments,due.the be
= = "waste'dumps: the Stringfellow Acid`' held up'or;denied because`of>im
environmental . officials , : Pits near Riverside, McColl refinery Epdper- esstiactingpro-cedures that '
- have accused the state of improperlyve+ ?dump in Fullerton and the Purity;0il:;` .,
r; administering more than-$28 million ' ; The state routinely did not nego-`
+ r:Co.site near Fresno. '"'
earmarked to clean up three hazard- a tiate for.lower costs.-and had :poor
..-ous waste dumps. r Toxic. -wastewater _.from',.:.the..`;;iecord keeping," said Keith Takata, s {
« in their report released Wednes- #, . 'h:,Stringfellow site is expected io be sent'<•'the regional EPA-Suo'Ofund chief, ;
'.:.�•
day; federal auditors recommended iby pipeline beginning later this year- who 'called the '-report -."`very -
that the Environmental.Protection �for':treatnient m •Huntington Beach .'`negative.''. ;
revoke'California's authority •:;before being discharged. into local.. °--The EPA report ieviewed`l l oori-
r hand out federal funds'to,. rivate 't�ocean waters... ` .;:: ;.;a�, ;;•' ;` ';, ^ racts:awarded by the state:,:for the .
, cleanupLLcompanies without first ob- ' :EPA investigators:cited'.the state,# three sites between March.1983 and
: tainiiig federal approval .;for'ignorintt competitive biddin¢foie.August 1984:',;
EPA officials have until Nov:"y '
','8=fo`decide"";whether•„to_:follow:.the: + 1.'
::z- report's recomrnendations.
• P:`. f:•Federal investigators strongly•criti=
sized the, state Tonic Substances
w•
` ntrol=;Division';:describin .it:'.as
being''in disarray;-'•and':-.noted,Ah t.t�
Please see WASTE/A2):'k
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On the h e if nces tiet een a- r f p ir� ti p p a cal•business'men.'or`--,,'=�'„', -tter�iittl`�•��'who Lris`fi=' .,e%-*�_
�, ma a ru ,gc' sriEbts
-,vast,communist country like China and a .':.proletarian-bureaucrats,-but rather`an-'t:.' ;;or. who`'controls alie''ins:.l't i:iions.
'Yvast.capitalist country.like the-United inevitable consequence of the Industrial_- Mankind`is`at;the'`"watershed.of 'its'
°Slate's is tHat_vvhile:both'_are.degrading- .,�, Revolution.that began`several•hundred :,;'existence'as a apecies'=,and the tram45
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:':the-'environment;;=we^;at-...°leash hiive:the= f•years',Ago; arid-still-marches-on: il- ,`,- „x":-'*
ri ht and.the,. .•is. that there_is.nobody. to`speak:for'
g power,to'protest.and even :': ' ::;;'•`' '
:x;- '
This I �.the`revolution — and riot,the'': mankind:
;s::, ?::• _i I,.Marxian one-that we have never come -,n - " -
sr•::.- . ;It -':.In this,res t,'IViarx,cou?d'not-see-"the
t • . - ' a jr; to terms'wifh .never fully=understood;';`'"`#,future'an r than Nlellori;could,
i. .- and thus never tried'to train or.restrain".' ,`' y,be.
to'conform to the basic ecology of,our -.'_, 1:can see it.more dearly now; liut,�;viieI ,
rg�c F'- r. fr - refuse-to believe it—or blame-it.on`'the:
,E '1 ': sturdy yet fragile planet. It is fatuous
and futile to blame it 'on any.-fori , - • . people,.we do not.like. ;,"1_ F.
,.
government,,for,all nations will soon be_:_ "-, -'r
reverse this frightening modern trend: - ' x' :^ .___,. A ':'.
bailing-out of the same leakylboat. ;w :, rw _ ; '-...•._- " °
Despite the polarity in our-political .- r - b-., ,_....%;, _:--- .
systems,3t turns out that both are more MIS A PITY that the environmental: • . '
alike than,-different in their ruthless movement.1n this`countr,y,-:and-' 1
assault'on.the natural environment -, : ` elsewhere'in`alie.•Western world, 'has-'.:';
which_may r be th'e 'supreme irony:m' become',so identified�-with.'-a,:left=of aj� •
conteriiporaiy ',history,',•confouri8n , ,,, center`-stance,- When' problem`.Tis '' '-
Marxist,and-capitalist,alike t' reaII far more-embracin '•than-that;:°as",
`' `'_:According to the`first§rnmprehen§ive 4 z Y g '
<:.; tendencies both;in China;;arid Soviet ,:
surve 'made.-in`:�Cliina and ublA id " - E, = "`7.'''�. "'` '- . - '.
y p .. Russia make. plain.'',Actually;,~reap z - ,;
;.this "fall in.the' Bulletin of the.Atomic.-' � •
,•&ientists),their�.lakes and forests .have ;:-
conservatives :eveiywheie ought.to-:'be, , °;; _ )
m,the forefront `of.ahis.environmental=�:,, -
:. been:just.as-''rapidly polluted and;eroded ?; scruliriy, for:nothingjs more:important.,,.
<.;as.,'our,s ,hay..e;-`and this:phys,ical ' �.thari.'conserving.and-',protectin g.-rthe..t=.:,;, - - - '
deterioration, 'committed ,in the same ;
world s.dtniinisliing resources.:.' .n - ,'k r
`name-of "progress!'as`.ours, threatens-,., ,,i' -';-r' :_i--
the same long-term damaging effects. ,`Ta". :.r:..,: ;:..; .
°It is,not_a partisan,political;'or,-:even°•. ��;, r
.', :Every, industrial)country;is„abusing .'..'economic; issue;. any'more.:than;public� '`'" '
' and' exploiting•its, 'natural resources; health should be:'If the::world keQp, " _
whether'.on behalf "of 'private profit -or:', ; rushing -headlsing'into:'heedless. _`,-';
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state expansion..It is not a "plot';°on-,the e-Yploitation of;our'physical assets,itwill .; .
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RE: AGENDA •ITEM #12 ' 11/14/84
A _
l SUPPLEMENTAL I ATION
ON REQUEST OF DOHS SAWPA TO DISPOSE -_
.; \ OF PRETREATED STR LOW WASTES.
TO DISTRICTS SEWERAGE SYSTEM
�3 b�
California Environmental Quality Act
The 1978 State Legislature passed Senate Bill 1130, which was signed into
law as Chapter 784 of the 1978 Statutes as an urgency measure effective
September 18, 1978. Section 6 of that Chapter provided an appropriation to be
expended solely for the purpose of abating threatened conditions of nuisance and
• pollution caused by the Stringfellow Quarry Class I Hazardous Waste -Disposal
Site. Section 7 of the Statute provided that the State Water Resources Control
Board may perform any act, if necessary, to implement the provisions of the
Statute. Based upon these provisions, the SWRCB, together with SAWPA and the
State Department of Health Services, have undertaken a program for study and
remedial action relating to the haz.ardous waste removal from the Stringfellow
site.
Assembly Bill No. 26 .was adopted by the Legislature and signed into law by
the Governor as chapter 1302 of the 1982 Statutes, which became operative, in
relevant part, on January .1, 1983. Chapter 1302 added an uncodified law to
specifically provide that the State Department of Health. Services shall have the
responsibility for-conducting the permanent .closure and maintenance of the
Stringfellow site, and in any emergency, as that term is defined., all activities
of the SWRCB and-the State DOHS or any other. State agency, department or
commission incidental to the site closure maintenance shall be exempt from the
requirements of the California Environmental Quality Act -(CEQA) .
Based on these two Statutes, SAWPA and the State DOHS, as the administrative
agency, have entered into contracts for the removal of the hazardous waste and
have made the determination that no comprehensive environmental assessment and
report is required because of the .express legislative finding that the activity
is exempt. The Executive Officer of the Regional Water Quality Control Board,
Mr. James Anderson, and the Manager of SAWPA, are of the opinion that this
exemption applies comprehensively to all facets of the operation, including the
discharge of the treated waste into the CSDOC Santa Ana River Interceptor for
transport to the Districts' Treatment Plants .for. additional treatment and final ,
disposal .
Environmental Protection Agency' s (EPA) Record of Decision
In July, 1984, the USEPA filed a record of decision in compliance with the
National Environmental Policy Act (NEPA) that states, in part, that based on the
results of the Fast Track Remedial Investigation/Feasibility Study, the Toxics
and Waste Management Division recommends installation of an onsite pretreatment
plant for removal of heavy metal and organic contaminants, followed by discharge
to a local Publicly Owned Treatment Works (POTW) system. Sludge from the
treatment process will be deposited at a Class I facility. This alternative
will be implemented during the three to five year interim period prior to:
completion of the full-scale RI-FS and implementation of the final remedy:.' ' Of
the alternatives evaluated, this alternati.ve is the lowest cost and, provides the
greatest protection to public health, welfare and the environment.
The record of decision goes on to note that the operator of a regional
interceptor (SAWPA) must obtain concurrence from the receptor POTW (CSDOC) for
all industrial wastes admitted into its system. CSDOC may deny a permit for
discharge that it believes could adversely affect the operation of its treatment
plant, or which could affect compliance with its NPDES permit requirements. - The
burden of establishing that no adverse effects will result falls upon the waste -
generator (DOHS SAWPA).
The final draft and the final report on the proposal were available'for '
public review and comment to three Riverside County public libraries: The final
report was also distributed to public libraries in Los Angeles and Orange
County; availability of the report was noticed in the Los Angeles Times,,, the
Riverside Press -Enterprise, and the Santa Ana Register.
Further Environmental Considerations
The District' s Regulations for Use of Districts' Sewerage Facilities
(Industrial Waste Ordinance) , adopted and enforced by the Boards of Directors,
impose stringent limitations on industrial. dischargers to provide ongoing
protection of the environment and the public health and safety.
It is the General- Counsel ' s opinion that while the-CEQA exemption is very
broadly worded and thus is subject to a liberal interpretation that -would allow
every aspect of this operation, including the discharge to the CSDOC facilities
and system, to be exempt from the CEQA requirements, that the. District, =in its
own right, could either undertake its own environmental assessment or require
the SAWPA- management to 'do likewise.
j, ,
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0, ', (CITY OF FOUNTAIN VALLEY !,tk Pl/ ne
CITY HALL 10200 SLATER AVENUE FOUNTAIN VALLEY, CALIFORNIA 927"08
FROM THE OFFICE OF THE MAYOR
C;-
December 27 , 1984
. 9 ED
The Honorable Ruth Bailey
Mayor of Huntington Beach [)LC 3 1 1984
City of Huntington Beach
P.O. Box 19 0 "
Huntington Beach, CA 92648 CITY OF HUNTINGTON BEACH
CITY COUNCIL OFFICE
Dear Ruth:
The City of Fountain Valley may be heavily impacted from the String-
fellow discharged wastewater being processed at the Orange County
Sanitation District plant in our City.
We feel it is imperative that the City of Fountain Valley, as well
as your City, be assured that the effluent from Stringfellow will, not
have any greater" impact on our water table or our citizens than what
is already allowed to" go through the wastewater treatement plant on
Ellis Avenue.
It is the City ' s contention that an independent analysis must be made
of the effluent processed at the plant. - The City has taken the lead
in contacting environmental consultants in the engineering field to
complete such an analysis. The analysis would include. analyzing the
existing groundwater; table in" the Orange County Water Basin , the
waste characteristics froin Stringfellow, the efficiency of the pre-
treatment facility at the Stringfellow plant, a complete review of
the Orange County Sanitation District ordinance , a full review of .all
agreements with the Orange County Sanitation District and other
agencies and a complete review of the hydrogeological study informa-
tion of the Orange County Water District Basin. The estimated cost
fo.r, such a study would be $7 , 500 .
On behalf of the City Council of the City of Fountain Valley, I
encourage your City "to participate .in and contribute 'to this study.
Once I have determined the number of cities agreeable to participate
in this type of a study , I will individually assess each city an
equal share.
We feel that this matter is extremely important to all of those who
drink water from the Orange County Water Basin. . I would appreciate
your response to our request as soon as possible .
Very truly yours,
IT OF FOUNTAI VALLEY
E NIE. S �J
Mayor. .
BN/DH/mb
CITY. OF FOUNTAIN VALLEY,
ft CITY HALL 10200 SLATER AVENUE FOUNTAIN VALLEY, CALIFORNIA 92708
. .... .. •• ... - a�+.+cc�r_reeeama�:vsev 3't.
_4y FROM THE OFFICE OF 'THE MAYOR
cow(
December 27 , 1984
D
3 1 1984
The Honorable Ruth Bailey CITY OF HUNTINGTON BEACH
Mayor of Huntington. Beach CITY COUNCIL OFFICE
City of Huntington Beach
P.O Box 190
Huntington Beach, CA 92648
Dear Ruth :
On December 18. the City Council of the City of Fountain Valley
adopted the attached resolution. requesting the Orange County Sanita-
tion -District to reconsider its action- in approving the processing
of pretreated groundwater. from the Stringfellow hazardous waste
disposal site at the Orange County Sanitation District Plant #1 in
the City of Fountain Valley.
� . We are very concerned with the uncertainty . of the affect of the hazard-
ous waste from the Stringfel-low Hazardous waste site on our. ground-
water table . We believe that the - impact on our community was not
considered , since there was no public hearing process. The City
urges that an Environmental Impact Report be completed prior to any
discharging of Stringfellow wastes in the Orange County area.
The City of Fountain Valley will continue to monitor this process and ,
hopefully, the matter will be. add--essed before .discharing commences,
Very truly yours,
9OF FOUNTAIN ; LLEY
' �N IELSEN_\)
Mayor
BN/DH/mb
Attachment
r r
l RESOLUTION NO. 8007
2 A RESOLUTION OF THE CITY COUNCIL OF THE- CITY OF
FOUNTAIN VALLEY R.E:QUESTING THE ORANGE COUNTY
3 SANITATION DISTRICT TO RECONSIDER ITS ACTION IN
APPROVING THE PROCESSING OF PRETREATED GROUNDWATER
. 4 FROM THE STRINGFELLOW HAZARDOUS WASTE DISPOSAL
SITE AT THE ORANGE COUNTY SANITATION DISTRICT
J PLANT #1 IN THE CITY OF FOUNTAIN VALLEY .
G WHEREAS, the Orange County Sanitation District has approved
7 a request of the Santa Ana Watershed Project Authority to issue
8 a permit to the California Department of Health Services. for
9 the processing of pretreated groundwater from the Stringfellow
10 Hazardous Waste Disposal Site at the Orange County Sanitation
11 District Plant #1 in the City of Fountain Valley; and
12 WHEREAS , the pretreated groundwater would be discharged
13 into the Pacific Ocean off the coast of California ; and
14 WHEREAS, it is unknown if the character of the Stringfellow
15 effluent is different from other effluent accepted by the
1G Districts; . and.
17 WHEREAS , it is unknown if the Districts ' . :treatment ordi-
18 nances adequately address the character of the Stringfellow
19 effluent;
20 NOW, THEREFORE, BE IT RESOLVED. by the City Council of the
21 City of Fountain Valley that it does • strongly urge the Orange
22 County _Sanitation District to reconsider its vote to allow .the
23 pretreated groundwater . from Stringfellow Hazardous Waste Disposal
24 Site to be 'treated at the Orange County Sanitation District
25 Plant #1 in Fountain Valley.
BE IT FURTHER iIESULVED that a coiiiplete environmental
27 impact report be completed for that portion of the proposed
28 Stringfell,ow cleanup project which affects Orange County so
29 that alternatives may be developed and discussed, and the
30 , residents of Or.anye County are given an opportunity to express
31 their. concern.
32
s
1
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1 BE IT FURTHER R1SOLVED that the City Council will hold. its �
2 objections in abeyance until a 'full Evi.ronmental Impact Report ,
3 is completed if the Districts assure it that :
4 (1) The character of the proposed effluent has been fully
5 considered as to any toxins or other harmful• substances- that
G may remain after initial treatment; and
i (2) That the Districts ' existing ordinances have adequate
8 protections , monitoring, and testing procedures vis-a-vis those
9 substances in Stringfellow effluent to insure that our community
10 and groundwater are protected.
11 BE IT FURTHER RESOLVED that the City .Council directs the
12 City .Manager to obtain a proposal from the Environmental Consul
13 tantsto analyze , the proposed Stringfellow Treatment Plan and the l
14 adequacy of the -Sanitation District ordinances , protections and
15 other safeguards to protect . the City and its environment.
16 The City. Clerk is hereby directed to send copies of ' this
17 resolution to the Orange County Sanitation District and the
1K Santa- Ana Watershed Project Authority.
19 PASSED AND ADOPTED at an adjourned meeting of the .City Council
20 of the, City of Fountain. Valley at an adjourned meeting thereof
21 he.ld on the 18th day of December, 1984.
22
23
. 24
25
Mayor
6 A!'TEST
• 27 '
28
City C1
29
31 '
32
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M.
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss .
CITY OF FOUNTAIN VALLEY).
I , EVELYN ,'•icCLENDO'N, do hereby certify that -I am the City
i Clerk of the City. of Fountain Valley ; that the ' foregoing Rp.solution
was regularly introduced to said Council at its _Ad1Q �d_.Cbuncil__.__.___
meeting held . on the ].IIth; day of _L a-.rider , 19 84
and was at said m g meeting regularly passed and adopted by . the following,
vote to wit :
AYES: COUNCIL MEM3ERS:. Neal, Voss , Nielsen , Scott, Brown
NAYES : COUNCIL MEMBERS: None
ABSENT: COUNCIL MEMBERS : None
____ — ✓ City Clerk --
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COUNTY SANITATION DISTRICTS o roN°�� AREA COO DE 14D 714
c
S40-2910
OF ORANGE COUNTY, CALIFORNIA 9 6 2-2 41 1
is Lek ' .
P. 0. BOX B127, FOUNTAIN VALLEY,CALIFORNIA 9272B-B127
10844 ELLIS AVENUE(EUCLID OFF-RAMP, SAN DIEGO FREEWAY)
December 279 1984
TO: Orange County Board of Supervisors
City Councils
Water Districts' Boards of Directors
Sanitary Districts' Boards of Directors
Other Interested Parties
SUBJECT: Information on Proposed Discharge of Pretreated Stringfellow
Groundwater to the Sewerage System of the County
Sanitation Districts
The California Department of Health Services (DOHS) and the Santa Ana Watershed
Project Authority (SAWPA) have proposed a plan to pretreat Stringfellow
groundwaters to stringent federal and state standards at an on-site treatment
plant by extracting and hauling contaminated material to an approved Class I
landfill and then safely and economically disposing of the treated water through
the Districts' sewerage system. We know there is concern on the part of many
people about this process and we want you to know that we are sensitive to these
concerns.
The enclosed informational package has been prepared to provide information to
those interested in our decision to accept treated Stringfellow wastewater for
further treatment at the Districts' facilities and eventual discharge. The
informational package is also being made available to other governmental
officials, the public and the press. The packet covers the history of
Stringfellow, the need for the project, environmental assessments done to date,
the proposed treatment system, the proposed operating and discharge permit
conditions, the effect of the discharge and endorsement of the program by
regulatory agencies.
The County Sanitation Districts' Boards have required several stipulations for
acceptance of the Stringfellow treated waters. First, that the public in Orange
County be involved in a full environmental review of the plan, to be conducted
shortly after the first of the year by DOHS and SAWPA. Second, that daily
monitoring of the on-site treated wastewater be maintained and documented. And,
finally, that termination of the discharge occur in the event of non-compliance
with the Districts' Industrial Waste Ordinance. The Boards believe this to be
an efficient and effective plan and we're confident of the Districts'. ability to
safely accept, treat and discharge pretreated wastewaters from Stringfellow.
,-The quantity and the quality of this water are well within our treatment capabi-
lities. We're doing what we believe is right for both the residents of Orange
County as well as those in the vicinity of Stringfellow.
December 27, 1984
Page 2
The plan was created in order to protect the upper (Riverside/San Bernardino)
and lower (Orange County's) Santa Ana River underground fresh water basin from
pollution by Stringfellow groundwaters. A plume of contaminated groundwater is
advancing downhill from the site, towards the underground drinking water
supplies, but is still confined to the local area. Authorities .plan to drill
dewatering wells and extract the water to stop progress of the plume.
The water would then be treated in a two-stage plant at the Stringfellow
location so that contaminants are reduced to levels at or below those required
of the Districts' many industrial users, in accordance with strict federal and
state requirements. The treated water would then be sent into the Sanitation
Districts' sewerage system, treated again, and then sent to an ocean outfall
well off the coast. Acceptance of the pretreated Stringfellow groundwater will
not affect the Districts' ability to meet the California Ocean Plan limits which
have been set by the State Water Resources Control Board to protect the ocean.
A small part of the Districts' treated water is also made available to the
Orange County Water District. The Water District gives it tertiary treatment to
Regional Water Quality Control Board requirements and presently uses it to
re-inject as part of a continuing effort to help prevent the further intrusion
of sea water into the fresh water table. Total water from Stringfellow would
amount to .less than one-tenth of one percent of all water handled by the
Sanitation Districts and will not adversely affect the Sanitation Districts'
facilities or the quality of their treated effluent.
After a study of thirteen alternatives, the plan was submitted by the Santa Ana
Watershed Project Authority (which owns and is paying on an ongoing basis for
capacity rights in the Districts' facilities) , the California Department of
Health Services and the United States Environmental Protection Agency. The plan
is also supported by the California Regional Water Quality Control Board, the
Orange County Water District, and the County of Orange Health Care Agency.
Enclosed is a copy of the informational package. We are also sending several
copies to the manager/administrator of your agency and respectfully ask that
they provide a copy to each Board/Council member and to appropriate staff
members.
If you have any questions, please feel free to call the officials of the
agencies that are sponsoring the project, as listed in the informational
package, or you may contact the undersigned or the Districts' staff.
Richard B. Edgar
Joint Chairman
Enclosure
cc: County Sanitation Districts'
Board Members
a
12/27/84
SUMMARY
OF
PROPOSAL TO DISCHARGE PRETREATED
STRINGFELLOW GROUNDWATERS TO THE
SEWERAGE SYSTEM OF THE
COUNTY SANITATION DISTRICTS OF ORANGE COUNTY
The California Department of Health Services (DOHS) and the Santa Ana Watershed
Project Authority (SAWPA) have submitted a proposal (see Attachment 1) to the
County Sanitation Districts of Orange County (Districts) for the discharge of
130 gallons per minute (187,200 gallons per day) of treated- groundwater to be
extracted from the Stringfellow Hazardous Waste Disposal Site.
The project' s objective is to aid in preserving the underground fresh water
basin of both the upper (Riverside and San Bernardino Counties) and lower
(Orange County) Santa Ana River. The DOHS, in cooperation with SAWPA, the U. S.
Environmental Protection Agency and the California Regional Water Quality
Control Board, has developed a plan which proposes to construct a $2,900,000
treatment plant at Stringfellow to pretreat the contaminated groundwater to
strict standards and then safely and economically dispose of it into the Santa
Ana River Interceptor Sewer System which would then convey it to the Orange
County Sanitation Districts' Joint Treatment Works for further treatment and
disposal in the same manner as other incoming wastewater. The extracted
groundwater will be processed through a two-stage treatment process at the new
Stringfellow treatment plant and tested to assure compliance with the stringent
Federal , State and District requirements before it is hauled by truck 12 miles
to a disposal station at the interceptor. Once in the sewer, it would flow to
the Sanitation Districts' sewage treatment plant and be further treated along
with all the wastewaters of metropolitan Orange County prior to disposal .
The Sanitation Districts' Boards of Directors have approved the plan because it
meets Federal , State and District requirements and treatment and disposal
standards and because they believe it will help solve a problem faced by both
the residents of Orange County and those in the Stringfellow area. The Boards
have imposed several stipulations for acceptance of the pretreated groundwater.
First, a full environmental review with public participation will be conducted
in Orange County by DOHS/SAWPA. This public review will take place shortly
after the first of the year beginning in January, 1985. Second, daily
monitoring will be conducted to assure compliance with the standards. And,
finally, acceptance of the pretreated Stringfellow wastewater will be terminated
if it does not meet the required limitations.
The Santa Ana Watershed Project Authority is a joint powers agency formed as a
result of successful litigation by the Orange County Water District to insure an
adequate supply of high quality water from the Santa Ana River Basin for Orange
County. This joint powers agency's members are the Orange County Water
District, the Chino Basin Municipal Water District, the San Bernardino Valley
Municipal Water District, the Western Municipal Water District, and the Eastern
Municipal Water District.
To improve the groundwater quality in the Santa Ana River Basin and the water
supplies to Orange County, as well as other member agencies, a comprehensive
-1-
groundwater management plan was developed by SAWPA. An integral part of this
plan, which has been in effect for over 10 years, was the extension of a sewer
line (the Santa Ana River Interceptor) from the County Sanitation Districts of
Orange County treatment and disposal facilities into Riverside and San
Bernardino Counties. The plan calls for high saline water from the upper basin
to be placed in the sewer to prevent its entry into the groundwaters of
Riverside and Orange County. In 1972, a wastewater treatment and disposal
agreement was entered into with the Districts whereby SAWPA purchased 5 mgd of
capacity rights in the Districts' treatment and disposal facilities with the
right to additional capacity up to 30 mgd. SAWPA also paid for 30 mgd capacity
in the Santa Ana River Interceptor as it was being constructed.
The purpose of this report is to summarize the project which includes:
1. History of Stringfellow
2. Need for the Project
3. Environmental Assessments
4. Proposed Treatment System
5. Proposed Operating and Discharge Permit
6. Effect of Discharge
7. Endorsements by Regulatory Agencies
1. HISTORY OF STRINGFELLOW
Stringfellow is a former rock quarry in a small canyon in the Jurupa Hills west
of Riverside (see- Attachment 2) . Highway 60 passes just to the south of the
canyon mouth. The community of Glen Avon is approximately one mile south. From
1954 to 1972 Stringfellow was operated as a Class I Hazardous Waste Disposal
Site under permit by the California Regional Water Quality Control Board
(CRWQCB).
The site was voluntarily closed in 1972 when it became evident that it was in
violation of the CRWQCB requirements. Investigations revealed that the basement
rock underlying the site was badly fractured allowing the free movement of
wastes out of the site and into the underlying groundwater.
During the mid to late 1970's several site closure plans were considered. Heavy
rains during this period caused surface impoundments at the site to overflow
into the stream leaving the canyon. Between 1980 and 1982, the site was covered
with a clay cap and concrete channels were installed to divert overland runoff
. around the site. Monitoring wells installed down the canyon from the site have
disclosed that an underground plum has advanced southward several thousand feet
down the canyon despite the cap and channels. Apparently, groundwater from- the
north becomes contaminated as it moves under the site.
In 1982, EPA included Stringfellow on the national priority list and made it
eligible for remedial action funds under Superfund. The State of California
identified it as a high priority site because of the potential effect on
groundwater in the Santa Ana River drainage area. A "fast track" remedial
investigation was conducted by EPA in 1983 and 1984 to identify and evaluate
methods for managing and disposing of contaminated groundwater to stop the
continued down canyon movement of the contaminated plume. This study has been
completed. The proposed interim treatment system identified in the study is
described in the "Proposed Treatment System" portion of this summary,
Section 4.
-2-
1�
Efforts are presently underway at the site to halt the movement of the
contaminated groundwater and extract it from the ground. The California State
Department of Health Services and the U.S. Environmental Protection Agency are
directing these cleanup efforts. Cleanup work currently underway involves the
pumping of up to 60,000 gallons per day (gpd) of contaminated water from
interceptor wells and trucking the wastewater to a Class I disposal site in
Santa Barbara County. This practice is costing approximately $10,000 per day.
This pumping and disposal program of untreated waste was to halt the migration
of the plume so that it would not reach the main underground water supplies
south of Route 60 Freeway. However, recent testing (October-November, 1984)
reveals that the plume has crossed the freeway and is migrating toward the Chino
Water Basin.
2. NEED FOR THE PROJECT
The apparent lack of an adequate leachate barrier at the site has allowed a
portion of the stored wastes to enter and contaminate local groundwaters in the
Pyrite Canyon area. To date, a plume of contaminated groundwater has migrated
downgradient from the dumpsite and recent well sampling results indicate its .
leading edge to be just south of Route 60 Freeway. The rate of movement of this
plume is estimated at approximately 1,000 feet per year. Estimates of the
effect range from currently localized contamination to eventual major
groundwater system contamination.
The plume is relatively confined now while it remains in the canyon. However,
as it reaches the limits of the canyon it will progressively fan out into the
fresh groundwaters. Ultimately, the plume could find its way to the Santa Ana
River and impact the drinking water of Orange County. The feasibility of a
. cleanup project will become progressively more difficult as the contaminated
area increases in size and thus becomes increasingly difficult to adequately
contain. Therefore, it is imperative that immediate remedial action be
implemented.
3. ENVIRONMENTAL ASSESSMENTS
Local . The groundwater from Stringfellow will be pretreated in a treatment
facility at the site to rigid standards imposed by the Districts' Industrial
Waste Ordinance. The Ordinance establishes stringent limitations on wastewater
to be discharged to the Districts' system to assure compliance with state and
federal requirements presently in force to protect the environment. The
Districts' Ordinance limitations on individual discharges enable the Districts'
ocean discharge of treated wastewater to comply with the California Ocean Plan
and EPA's National Pretreatment Standards. The Ocean Plan, adopted by the State
Water Resources Control Board after Environmental Impact Report hearings, and
the EPA's National Pretreatement Standards, establish the maximum concentrations
of toxicants to insure adequate protection of the public health and the
environment.
Federal . In July, 1984, the USEPA filed a Record of Decision in compliance with
the National Environmental Policy Act (NEPA) that states, in part, that based on
the results of a Fast Track Remedial Investigation/Feasibility Study (RI/FS),
the Toxics and Waste Management Division recommends installation of an onsite
pretreatment plant for removal of heavy metal and organic contaminants, followed
-3-
by discharge to a local Publicly Owned Treatment Works (POTW) system. Sludge
from the treatment process will be deposited at an approved Class I landfill .
This alternative is proposed to be implemented during the three to five year
interim period prior to completion of the full-scale RI/FS and implementation of
the final remedy. It- is EPA's determination of the alternatives evaluated, that
this alternative is the lowest cost and provides the greatest protection to
public health, welfare and the environment. EPA's environmental review was
conducted pursuant to the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) .
EPA does not consider remedial actions conducted under CERCLA §104 to be subject
to the National Environmental Policy Act §102(2)(C) which requires preparation
of an Environmental Impact Statement (EIS) for major federal actions
significantly affecting the environment. This position is based on the
"functional equivalent" exception to the EIS requirement. The requirements of
functional equivalency are satisfied when a review of environmental factors is
conducted in accordance with the procedures set forth in the National
Contingency Plan and public participation is incorporated into the
decision-making process.
The National Contingency Plan (NCP) establishes methods and criteria for
determining the appropriateness of proposed remedial actions. In keeping with
the intent and letter of the NCP, an endangerment assessment was conducted of
the groundwater conditions and the projected environmental and public health
hazards. This endangerment assessment was a joint effort conducted by the
State Department of Health Services and CH2M Hill, a consulting engineer to EPA.
The fast-track remedial investigation feasibility study conducted examined
several remedial alternatives. The following technologies were identified as
candidates for the management and disposal of the contaminated extracted
groundwaters from the Stringfellow site.
o Discharge to a publicly owned treatment works (POTW).
o Pretreatment followed by discharge to a publicly owned treatment
works.
o Reinjection into the ground--either onsite or offsite.
o Treatment followed by reinjection into the ground--either onsite or
offsite.
o Solar evaporation.
o Incineration.
o Surface discharge.
o Treatment followed by surface discharge.
o Disposal at a Class I land disposal site.
o Disposal at a Class II-1 land disposal site--with or without treatment.
o Disposal at a permitted hazardous waste treatment facility.
-4-
o Reuse as industrial process water.
o Future treatment of drinking water at the tap.
These remedial alternatives went through an initial screening which resulted in
the consideration of only five alternatives which appeared to be cost effective
for an interim remedial solution. The five selected were pretreatment and
discharge to a publicly owned treatment works; treatment and reinjection into
the ground; treat and surface discharge; disposal at a Class I landfill ; and
disposal at a Class II-1 landfill . The effectiveness of alternatives were
evaluated on the following factors: time, compatibility, reliability/risk of
failure, level of site cleanup, community impact, technology status, potential
environmental impacts, complexity of operation and cost. A complete analysis
may be found in Section 6 of EPA's Hazardous Site Control Division Report
entitled "Fast Track Remedial Investigation Feasibility Study, Stringfellow
Site, Riverside, California." After consideration of all the alternatives, the
selected interim remedial solution, by EPA, is to pretreat the extracted
groundwaters to an acceptable level at the Stringfellow site, test it, and
discharge it to a sanitary sewer where the waste would be co-mingled with
existing sanitary sewer waste and flow to a publicly owned treatment plant for
further treatment and disposal .
Based on the fast-track findings, the EPA, in conformance with the Superfund
regulations, issued the Record of Decision. This Record of Decision was noticed
and public comment was solicited and received. The final draft Fast Track
report was made available for Intergovernmental Review from April 12, 1984 to
May 22, 1984. In addition, a formal public comment period was held from May 21,
1984 to June 8, 1984 for the final Fast Track report. A responsiveness summary
was prepared to address comments received during the public comment periods. It
was then decided to proceed with the interim program to treat the extracted
groundwaters and discharge these treated waters to a publicly owned sewer
system.
The final draft and the final report on the proposal were available for public
review and comment to three Riverside County public libraries. The final report
was also distributed to public libraries in Los. Angeles. and Orange County;
availability of the report was noticed in the Los Angeles Times, the Riverside
Press Enterprise, and the Santa Ana Register.
State. The 1978 California State Legislature passed Senate Bill 1130, which
was signed into law as Chapter 787 of the 1978 Statutes as an urgency measure
effective September 18, 1978. Section 6 of that Chapter provided an
appropriation to be extended solely for the purpose of abating threatened
conditions of nuisance and pollution caused by the Stringfellow Site. Section 7
of the Statute provided that the State Water Resources Control Board may perform
any act, if necessary, to implement the provisions of the Statute. Based upon
these provisions, the SWRCB, together with SAWPA, the State Department of Health
Services and EPA, have undertaken the program for study and remedial action
relating to the waste removal from the Stringfellow site.
Assembly Bill No. 26 was adopted by the Legislature and signed into law by the
Governor as chapter 1302 of the 1982 Statutes, which became operative, in
relevant part, on January 1, 1983. Chapter 1302 added an uncodified law to
specifically provide that the State Department of Health Services shall have the
-5-
responsibility for conducting the permanent closure and maintenance of the
Stringfellow site, and in any emergency, as that term is defined, all activities
of the State incidental to the site closure maintenance shall be exempt from the
requirements of the California Environmental Quality Act.
Further Environmental Reviews. The Districts' Boards of Directors have
stipulated that a full environmental review of the proposal be conducted
concurrent with the project proceeding. The environmental review, which is
expected to be ready for public forum in January, 1985, will be conducted by
DOHS/SAWPA and will provide for public participation in Orange County. It will
focus on the potential and probable impacts that the pretreated Stringfellow
effluent would have on SAWPA's facilities and their environs, the Districts'
facilities and their environs, and to receiving waters upon final discharge.
4. PROPOSED TREATMENT SYSTEM
The interim treatment facilities are intended to be operated for three to five
years while a final remedial investigation, feasibility study, geological study
and design report are completed by DOHS' consultant, JRB and Associates. SAWPA,
under contract with DOHS, issued a Request for Proposals to sanitary engineering
firms for the design, construction and operation of the interim treatment.
facilities which will pretreat the extracted groundwaters to the prescribed
limits. James Montgomery Engineers was issued a contract to provide the design
engineering services. DOHS/SAWPA also have the option of hiring Montgomery to
operate the facility, once constructed. Contracts to construct the facilities
have now been awarded.
The facilities (see Attachment 3) are designed to treat -up to 130 gallons per
minute of extracted groundwater through a two-step system. Water extracted
nearest the Stringfellow site contains heavy metals and organic compounds. The
liquid waste treatment system consists of two sequential operations: first, a
precipitation step to remove the heavy metals fraction contained in the leachate
from the on-site extraction wells, and second, an adsorption step to remove the
organic fraction contained in both the on-site and the mid-canyon groundwater
extraction wells.
The precipitation process consists of equalization tanks to accept the influent
from the wells, influent pumping to a rapid mix unit for addition of
precipitants and flocculants, flocculation and clarification and sand
filtration. From the filters, the effluent is pumped to equalization tanks of
the carbon system. Sludges from the clarifer will be dewatered in filter
presses, with the filtrate recycled to the initial equalization tanks. For the
carbon system, the effluent from the precipitation step will be blended with
influent from the mid-canyon wells, which at the present time only have organic
contamination. The blended waters are then pumped into the carbon beds, with
the efficiency of removal recorded by an analyzer. Effluent from the carbon
beds will be stored on-site for testing to assure compliance with the stringent
discharge limitations of State and Federal authorities and the County Sanitation
Districts. If the treated wastewater is in compliance with the standards, it
will be trucked to the Santa Ana River Interceptor Sewer for conveyance to the
County Sanitation Districts' treatment plants for further treatment and
disposal . If the pretreated Stringfellow wastewater does not meet the
standards, it will be recycled through the treatment plant at the Stringfellow
-6-
site until it meets the limitations or be hauled to an approved Class I disposal
site. Spent carbon from the carbon adsorption system will be returned to the
supplier for thermal destruction or regeneration. Sludges from the lime
precipitation system will be hauled to an authorized Class I disposal facility.
The Sanitation Districts' Ordinance regulates the discharge of radioactive
wastes by reference to Title 17 of the California Administrative Code. Any
proposed discharge, like all other sources, must consistently meet this
requirement. Radiation emitted from radioactive sources is of three basic
types: Alpha, a low energy particle stopped by a sheet of paper; Beta, a small
particle (electron) stopped by cardboard; and Gamma, electromagnetic waves
highly penetrating and capable of traveling long distances. Only Alpha
particles at extremely low concentrations will be present in the proposed
pretreated discharge. EPA's consultant, CH2M Hill , conducted treatability tests
of the contaminated groundwater in the summer of 1984. The results of the
testing were reported in the ,EPA document entitled "Final Test Program Summary
Report, Treatability Testing, Stringfellow Site, August 27, 1984". The testing
demonstrated that the proposed treatment system ( lime precipitation, sand
filtration and activated carbon adsorption) will remove most of the
radioactivity in the contaminated groundwater. The results indicate that the
proposed discharge will conform to Title 17 and will be well within the State
and Districts' standards and will actually conform to the Primary Drinking Water
Standards established by the California State Department of Health Services.
Sufficient redundancy has been designed into the treatment facilities to provide
continuous operation during preventative maintenance procedures. In addition,
the groundwater extraction wells will discharge into storage tanks ahead of the
treatment facilities. Therefore, in the event that the elective short-term
shutdown of the treatment facilities for maintenance is required, then this
option is available. Long-term shutdowns will require hauling to the Class I
industrial waste disposal sites in Santa Barbara or Kern Counties.
Details of the treatability of the leachate and groundwater generated at the
Stringfellow site are contained in the following four reports: "Bench-Scale
Treatability Studies for Liquid Wastes at the Stringfellow Site", final report to
the Santa Ana Regional Water Quality Control Board, July, 1982, by James M.
Montgomery, Consulting Engineers, Inc. ; "Proposed Treatement Requirements for
Treated Stringfellow Wastes" final report to Santa Ana Watershed Project
Authority (SAWPA) , March,1984, by Lowry and Associates; "Fast-Track Remedial
Investigation/Feasibility Study, Stringfellow Site, Riverside, California", final
report to EPA, May, 1984, CH2M Hill ; and "Test Program Summary Report: I.
Mid-Canyon Interceptor Well Field Pilot Testing, II. Treatability Testing,
Stringfellow Site, Riverside County, California," final report to EPA, August,
1984, CH2M Hill .
5. PROPOSED OPERATING AND DISCHARGE PERMIT
The Districts have an industrial waste pretreatment program and sewerage use
ordinance that is approved by the EPA and the CRWQCB. Contained within the
Program are provisions for enforcing industrial waste discharge standards that
are equivalent to, or more restrictive than, existing EPA categorical
pretreatment standards. These stringent standards are designed to protect the
Districts' treatment facilities, to maximize sludge reuse potential , and to
-7-
protect public health and the ocean environment in compliance with the State
Water Resources Control Board's Ocean Plan for the Waters of California. The
permit that SAWPA proposes to issue to DOHS complies with all discharge
standards contained within the Districts' ordinance.
The proposed permit, in its final form, will incorporate language to comply with
the Districts' requirements including unique features that are intended to
assure fail-safe operation and discharge. These include:
a. Unrestricted access to the treatment facilities by SAWPA or the
Districts to perform inspections and to conduct sampling.
b. No vested right to discharge is granted with the permit. The permit
may be cancelled at any time by SAWPA or the Districts.
C. Subsequent changes to SAWPA's or the Districts' Ordinances will be
automatically incorporated into the permit.
d. On-site operation of the treatment systems shall be supervised and
directed by a registered professional engineer knowledgeable in
treatment system operations.
e. All permit limitations must be verified by daily laboratory analysis
and reporting at the treatment site prior to disposal .
f. Permit revocation for violation of the discharge limitations.
g. Hold harmless provision.
6. EFFECT OF DISCHARGE
The discharge limitations set forth in the permit combined with the expected
removal rates of the treatment facilities should adequately protect the
Districts' treatment facilities and sludge reuse potential and the public
health. The proposed discharge of treated groundwater from the Stringfellow
site will not affect the quality of the Districts' ocean discharge nor will it
affect the quality of the treated effluent made available by the Sanitation
Districts to the Orange County Water District for their programs of water
reclamation and groundwater protection. The Water District presently gives
tertiary treatment to a small portion of the Sanitation Districts' secondary
treated water and uses it to reinject as part of a continuing effort to help
prevent the further intrusion of sea water into the fresh water table. The
proposed flow for Stringfellow represents less than 1/10 of 1% of the Sanitation
Districts' total system flow.
Attachment 4 lists the discharge limitation contained in the Districts' Use
Ordinance, the discharge limitations contained in the EPA Pretreatment Standards
for new Electroplaters, the proposed SAWPA permit limitations for the
Stringfellow discharge, the results of the pilot treatability study conducted by
the EPA and State of California Primary Drinking Water Standards.
EPA's consultant, CH2M-Hill , performed the treatability tests on Stringfellow
groundwater during 1984 that were reported in the "Final Test Program Summary
Report, Stringfellow Site, Riverside County, California, August 27, 1984". The
-8-
purpose of the treatability tests was to determine the capability of the system
to achieve the proposed effluent requirements and to develop cost and design
data for a full scale system.
The results of the treatability tests, as shown in Attachment 4, indicate that
the treated discharge can meet the stringent requirements of the proposed
permit. In fact, when contrasted with the State of California Primary Drinking
Water Standards, nearly all of the concentrations of the treated Stringfellow
waste were lower than the maximum contaminant levels set by the State. This is
not to suggest that the discharge is fit to drink - only to place the treated
.discharge in relative terms. It is recognized that the actual performance of
the full scale operation could differ from the pilot treatability tests.
Attachment 5 contrasts the Districts average influent raw sewage pounds per day
of industrial wastes with the proposed permit requirements for Stringfellow and
the results of the EPA treatability tests. The Stringfellow discharge will
contribute relatively low amounts to the existing Orange County industrial
constituents. Removal rates of these constituents through the Districts'
treatment facilities are good. The Districts' ocean discharge is in full
compliance with the limitations set by the State of California's Ocean Plan for
all of the constituents identified in the Stringfellow discharge.
7. ENDORSEMENTS BY REGULATORY AGENCIES
SAWPA has received letters from the following regulatory agencies in support of
the proposed program, copies of which are included as Attachments 6a through 6f.
a. U.S. Environmental Protection Agency Water Mangement Division, dated
July 16, 1984
b.. Orange County Water District, dated July 23, 1984
C. California Regional Water Quality Control Board, Santa Ana Re.gion,
dated July 24, 1984
d. California State Department of Health Services, Toxic Substances
Control Division, dated July 24, 1984
e. U.S. Environmental Protection Agency, Superfund Programs Branch of the
Toxics and Waste Management Division, dated September 18, 1984
f. County of Orange Health Care Agency, Environmental Health, dated
September 26, 1984.
FURTHER INFORMATION ON THE PROGRAM
Further detailed information on the proposed program may be obtained by
contacting:
James Anderson California Regional Water Quality
Control Board (714) 684-9330
Andrew Schlange Santa Ana Watershed Project
Authority (714) 682-6080
-9-
Tom Bailey California Department of Health (916) 324-3773
Services
Keith Takata Environmental Protection Agency (415) 974-8910
-10-
"ATTACHMENT 1"
A' ;: t
_1P,T I
SAN'T �INA Vl,/)'-4 TE �T] C.-N-_' B AS,%V_;NiC-A A 7
ANA V1,77A T ED F� I A A 7 ANGE 'EAEP11A�4 CINC E KI A A Z E R Di S'
ITY WES"EPN A4 V A
PR CT A U MUNICI L E L 57"1:
V AN A E P
^NDREW SC-MANGE
September 14, 1984
Mr. J. Wayne Sylvester
General Manager
COUNTY SANITATION DISTRICTS OF ORANGE COUNTY
10844 Ellis Avenue
Fountain Valley, CA 92708
SUBJECT: PROPOSED DISCHARGE PERMIT FOR TREATED
STRINGFELLOW WASTEWATERS TO THE SANTA
ANA REGIONAL INTERCEPTOR SEWER SYSTEM
Dear Sir:
Transmitted herewith is a proposed permit to be issued by SAWPA to the State
Department of Health Services for the disposal of treated wastewaters from the
Stringfellow Hazardous Waste Site in Glen Avon in Riverside County to the SARI
line. Pursuant to the agreement between SAWPA and the Sanitation Districts, I
am hereby requesting your concurrence in the issuance of this permit to the De-
partment of Health Services.
SAWPA in its responsibilities to improve the groundwater quality and its obliga-
tions to the people in the upper and lower basin to protect these groundwaters,
entered into a contract with the State Department of Health Services to act as
their agent in this interim clean-up program. Considerable amount of effort
over the past several months has gone into the drafting of this permit so that
none of the Districts' programs are jeopardized in the interim "clean-up" program
for the Stringfellow site.
As you know, the U. S. EPA, State Department of Health Services, the Regional
Water Quality Control Board and other agencies have for several years been
seeking a solution for the contaminated waters from the Stringfellow Hazardous
Waste Site. In a recent study conducted by EPA, Region IX, and their consulting
engineers, several remedial alternatives were examined. The following technolo-
gies were identified as candidates for the management and disposal of the con-
taminated extracted groundwaters from the Stringfellow site. These remedial
alternatives which were considered are as follows:
• Discharge to a publicly owned treatment works (POTW).
• Pretreatment followed by discharge to a publicly owned treat-
ment works.
CA YY,'nA
Mr. J. Wayne Sylvester
COUNTY SANITATION DISTRICTS OF ORANGE COUNTY
September 14, 1984
Page Two
• Reinjection into the ground --- either onsite or offsite.
• Treatment followed by reinjection into the ground --- either onsite
or offsite.
• Solar evaporation.
• Incineration.
• Surface discharge.
• Treatment followed by surface discharge.
• Disposal at a Class I land disposal site.
• Disposal at a Class II-1 land disposal site --- with or without treatment.
• Disposal-at a permitted hazardous waste treatment facility.
• Reuse as industrial process water.
• Future treatment of drinking water at the tap.
These remedial alternatives went through an initial screening which resulted in the
consideration of only five alternatives which appeared to be cost effective for an
interim remedial solution. The five selected were pretreatment and discharge to
a publicly owned treatment works; treatment and reinjection into the ground; treat
and surface discharge; disposal at a Class I landfill; and disposal at a Class 11-1
landfill. After consideration of all the alternatives, the cost effectiveness, as well
as the environmental impacts, the selected interim remedial solution is to treat the
extracted groundwaters to an acceptable level and discharge to a sanitary sewer
where the waste would be co-mingled with existing sanitary sewer waste treated
and disposed to the marine environment.
SAWPA, in the execution of its responsibilities to improve and protect the ground-
waters of the Santa Ana. River Basin and its obligations to all those affected by the
groundwaters, offered to the Department of Health Services to act as its agent in
-the implementation of an interim remedial program for the treatment and disposal
of the Stringfellow waste. Under contract to the DOHS, SAWPA prepared an RFP
and solicited proposals from professional engineering firms for the design and con-
struction management of a pretreatment facility which would treat the extracted
groundwaters to the prescribed limits set forth in the proposed permit transmitted
herewith. Five highly qualified professional engineering firms were evaluated to
Mr. J. Wayne Sylvester
COUNTY SANITATION DISTRICTS OF ORANGE COUNTY
September 14, 1984
Page Three
perform the tasks outlined in the RFP. James M. Montgomery, Consulting Engi-
neers of Pasadena were selected to provide the necessary engineering services.
On August 21, 1984, the Board of'Directors of SAWPA issued a contract with the
concurrence of the Department of Health Services to James M. Montgomery for
the design and construction management of the pretreatment facilities.
Also attached with this letter is an implementation schedule of the activities
proposed for the design and construction of these facilities in order that the
treatment can commence by January 1, 1985. You will note that a two-week
start-up period is scheduled in the latter part of December. The EPA has estab-
lished the treatment process and has conducted treatability studies to insure
permit compliance. Your participation in this start-up program is welcomed.
Also, on August 21, 1984, SAWPA authorized the execution of a contract, with
the concurrence of DOHS, with Lowry and Associates to have Mr. Ray E. Lewis
assist SAWPA's staff in the coordination of this project. Mr. Lewis' familiarity
with the Districts' concerns will also help in assuring permit compliance.
I am sure you and your Board realize the importance of the control of the con-
tamination of the groundwaters in the Santa Ana River Basin which affect both
the upper and lower basin users of the groundwaters. This program, after a
thorough investigation, is the best apparent interim remedial solution and con-
tains the safeguards in the design, operation and monitoring of the program to
provide you, the Board of Directors, and the people of Orange'County, that the
utmost caution has been taken to insure a minimum of impacts and the success
of the program. Because of the fast-track program for the design and construc-
tion of the facilities, it would be appreciated if you and your Board would expedite
concurrence in the issuance of this permit.
Very truly yours,
SANTA ANA TERSHED PROJECT AUTHORITY
J Andrew Schlange
nager
rtk
Attachments
SANTA ANA WATERSHED PROJECT AUTHORITY
WASTE PERMIT
STRINGFELLOW HAZARDOUS WASTE SITE
I. NAME AND ADDRESS OF DISCHARGER:
State of California - Department of Health Services
Toxic Substance Control Division
714/744 "P" Street
Sacramento, CA 95814
2. TERMS AND CONDITIONS OF DISCHARGE:
(A) Effective Date of Permit: January 1, 1985.
(B) Location of Origin of Discharge: Stringfellow Hazardous Waste
Site, Glen Avon, Riverside County.
(C) Location of Point of Discharge to SARI System: At trunk dis-
posal stations. (CB-1 and W-1)
(D) Nature of Permitted Discharge: Interim treatment program for
extracted contaminated groundwaters from Stringfellow.
(E) The Discharger hereby agrees to adhere to SAWPA's ordinances,
resolutions and regulations regulating the use and availability
of the SARI System.
(F) The Discharger hereby agrees to permit SAWPA, at any reasonable
time and without prior notice, to inspect and take wastewater
samples.
(G) No vested right of any kind, including the right to discharge,
shall be acquired by the issuance of this Permit.
(H) The Discharger acknowledges and agrees that since the discharge
permitted hereunder will be transported to treatment facilities
operated by the County Sanitation Districts of Orange County,
any changes made in their requirements will be automatically in-
corporated into this Permit.
(I) SAWPA reserves the right to suspend or revoke this Permit for
any violations or non-compliance with SAWPA's ordinances,
resolutions, or regulations governing the Santa Ana Regional
Interceptor (SARI) system.
-1-
(J) The Discharger hereby acknowledges and agrees that since
the discharge permitted hereunder will be transported to
the treatment and disposal facilities of the CSDOC, that at
any reasonable time without prior notice, representatives
of the CSDOC may inspect the interim pretreatment facili-
ties and take wastewater samples to insure permit complaince
as it affects their facilities.
(K) The Discharger hereby agrees that the on-site operation at
the interim pretreatment facilities shall be supervised and
directed by a registered professional engineer knowledgeable
in wastewater and toxic waste facilities operation to insure
competency of operation and meeting permit requirements.
(L) This Permit may not be assigned without the prior written
consent of SAWPA.
(M) This Permit shall be for a three (3) year period expiring on
December 31, 1987.
(N) Fees and Charges: Disposal to the SARI line shall be as
follows: (Cents per gallon)
Basic SAWPA Charge 0.50
___Basic WMWD Charge 0.50
SARI O&M 0.06
Capacity Lease 0.10
SAWPA Contract Management 0.50
1.66*
*Escalated annually to the same degree that charges for
other SAWPA permit fees are escalated.
(0) Other terms and Conditions: See attachment designated
as "Attachment 1" for permit limitations.
SANTA ANA WATERSHED PROJECT AUTHORITY
Date: By:
DISCHARGER:
Date: By:
-2-
"ATTACHMENT 1"
STRINGFELLOW HAZARDOUS WASTE SITE
DISCHARGE PERMIT
GENERAL CONDITIONS
1. All permit limitations must be verified by laboratory analysis at treatment
plant site prior to disposal to the SARI system by a laboratory approved by
SAWPA.
(a) Limitations on heavy metals must be verified on each day of
discharge on a 24-hour flow rated composite.
(b) Limitations on total toxic organics (TTO) must be verified
on a monthly basis, however, a daily certification must be
made in accordance with Section 413.03 of the Federal Clean
Water Act as published in the Federal Register on July 15,
1983, Vol. 48, No. 137.
2. Any samples taken and analyzed by SAWPA at the trunk disposal stations
which are found in excess of permit limitations set forth herein are subject
to the following non-compliance fees and penalties:
(a) $300.00 per pound for each pound, or portion thereof, of heavy
metals in excess of limitation.
(b) $500.00 per pound for each pound, or portion thereof, of TTO
in excess of limitations.
(c) Fees outlined in 2.a and 2.b above are for the first or initial
violations within a 12-month period.
(d) A second violation in either the heavy metals or TTO limita-
tions within a 12-month period, may result in addition to the
fees set forth in 2.a and 2.b the suspension of this permit for
a period not-to-exceed 30 days until discharge can demon-
strate ability to continuously meet permit limitations.
(e) More than three violations within a 12-month period will re-
sult in permit revocation. In the event of permit revocation,
the Discharger may reapply for a discharge permit pursuant
to SAWPA's Ordinance. Before consideration of re-issuance
of a discharge permit to the SARI system, corrective action
must be taken to insure continued permit compliance.
PERMIT LIMITATIONS
1. The initial interim pretreatment facilities are to be designed to treat
0.187 MGD (130 gpm). The following permit limitations are based upon
a maximum daily discharge of 0.187 MGD (130 gpm):
Constituent Max. Mass Limits lbs/day
Arsenic 3.1
Cadmium 0.1
Chromium (total) 3.1
Copper 4.7
Cyanide (total) 2.0
Cyanide (free) 1.6
Lead 0.9
Mercury 0.05
Nickel 5.5
Silver 0.7
Zinc 1.1
Total Toxic Organics (TTO) 0.9
2. The permit limitations as set forth in paragraph 1 above shall become
effective on the effective date of this permit. The Discharger may be
permitted to discharge flows in excess of 0.187 MGD (130 gpm) only
upon approval of SAWPA and subsequent amendment to this permit.
-2-
MONTH AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER JANUARY 1985-
WEEK 19 28 2 9 18 23 30 7 14 21 28 4 1 11 118 25 2 1 9 16 23 1 1988
NOTICE TO PROCEED
PHASE I-DETAILED DESIGN CRITERIA TABULATION
1. INVENTORY/COMPILE EXISTING INFORMATION DESIGN REPORTi DESIGN CONTRACT DOCUMENTSi
BA818 DRAFT O M MANUAL
2. ESTABLISH DETAILED DESIGN CRITERIA SUMMARY COST ESTIMATE
3. IDENTIFY SITE CONSTRAINTS PREPURCHASE
4. DEVELOP DETAILED DESIGN DATA/FACILITIES LAYOUT DOCUMENTS
AWARD
5. EOUIPMENT PROCUREMENT SCHEDULING 811)PERIOD
FINAL O i M MANUAL
6. PREPARATION OF DETAILED PLANS AND SPECIFICATIONS
7. O A M MANUAL
S. COST ESTIMATE
RECOMMENDATION
PHASE 11-CONSTRUCTION/CONSTRUCTION MANAGEMENT TO AWARD RECORD DRAWINGS
1. BID PERIOD ASSISTANCE BID PERIOD PROJECT
ACCEPTANCE
2. CONSTRUCTION ADMINISTRATION
3. CONSTRUCTION INSPECTION/RESIDENT ENGINEERING
4. PROJECT START-UP AND CLOSEOUT
TO BE DETERMINED
PHASE III-FACILITIES OPERATIONS
PROJECT DESIGN BID PERIOD PROJECT CONSTRUCTION START-UP OPERATION
PROJECT ACTIVITY v 001
PROJECT REVIEW ACTIVITIES
PROGRESS REPORTS 8 BILLINGS
DESIGN PROGRESS REPORTS
TAC MEETINGS
CONSTRUCTION MANAGEMENT REPORTS
MEETINGS WITH SAWPA
NOTE:SCHEDULE 18 EXCLUSIVE OF CHANGES REQUIRED A8 A RESULT OF
REVIEW BY THE STATE OF CALIFORNIA AND OTHER INTERESTED
PARTIES
PROJECT ACTIVITIES
DIAGRAM AND SCHEDULE
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ATTACHMENT JA
METALS REMOVAL 0R64AJ1r-G REMOVAL
LIME POLYMER
CL4R/;:IER
STREAM
A
PID /V F OCCULAT10.0 A4114EO
EOLALIZATIO" MEDIA
(06r: EX16TIkG TAMMGE) FILTRd T10AJ
DIRTYFALTER
84CKWA6N
STORAGE or-4H4RGE
C4R60" CLEA" TO POTW
SLUDGE SLUDGE DEWATERE0 405ORPTI&J B4CXKA6N
E. ....... SLU06e TO
FILTER
CO"r4cT PFLUE.QT
TAkIK VA CLAS6 I BACKWASH VE55ELS MRAGE
FILTER 06POGALG/rE
STREAM CAUSTIC
C4R80AJ
Tio"
EOL)4LIZATIOAJ AJEUTRA40 MIXEDM`EaA VESSELS
FILTR4TIOAJ
)JOTES:
I. STREAM A /5 FROM WELLS OW-1 OW-2 OW-4 IW-I AKIO
THE FREAJCJ4 DR41M. AVERAGE FL W r-., iNT;-E:CikO TO f3F-
20 GPM.OF-51GAJ FLOW IS 50 GPM. INTERIM TREATIIENT FACILITIES
2. STREAM 8 /5 FROM A410-CAAJYOAJ WELLS rw-2 4 rw.3. FROM
AVERAGE FLOW/5 EXPECTED TO BE 406PA4. DEGIG"
PLOW 16 80 c7pm. FINAL FAST-TRACK REMEDIAL INVESTIGATION
3. TREATED GROUkIDWATER WILL BE HAULED FEASIBILITY STUDY, STRINGFELLOW SITE, MAY 18, 1984
41JO OISC14ARGF-0 TO A POrW.
4. TREATA81LITY 5TOOJE5 ARE REQUIRED TO eOAJFIRA4 BY CH211-HILL FOR U.S. ENVIRONMENTAL PROTECTION
SYSTEM CDAJF1GUR4T10K1 OF-FIAlr= OESASKI'CARAIWETERS. AGENCY HAZARDOUS SITE CONTROL DIVISION
xx xx XF&149&R@ xxffmlxx x x
RECOMMENDED FREJrREATMENT SYSTEM
ATTACHMENT 3B
INTERIM '
PRETREATMENT, '
FACILITIES
s
JURURA MTS TREATED WASTE
STRINGFELLOW TRUCKED TO
SAWPA APPROVED o
ACID PITS TRUCK DISPOSAL
w c�
STATION H w
tpppo��� f0zzq
"iO
OCSD TREATMENT
0.187 MGD PLANT NO. 1
CONTAMINATED FOUNTAIN VALLEY
GROUND WATER -
1EXTRACTION
WELLS
23 MGD
500 FEET 12 MILES 60 MGD
3p '�c0
SANTA ANA RIVER INTERCEPTOR lbid OCSD 4 - MILE OCSD S - MILE
36 MILES (APPROX) LAND OUTFALL T OCEAN OUTFALL
PROPOSED
US EPA & STATE DEPARTMENT OF HEALTH SERVICES
INTERIM PRETREATMENT AND DISPOSAL
FOR
STRINGFELLOW HAZARDOUS WASTE SITE
ATMCH49V 4
O3WARISC N OF CSDOC AND EPA DLSCHAWE STMMARB
TO PrCPCSED STRRKEIIUM DISCHAR'E QbID7?I' ms Y
SAMPA
�� ��11 EPA 2 Permit Limits EPA 3
CSDOC- Pretreatment Standards for Stringfellow at Pilot Treatment Study
4
Industrial Use Ordinance far New Flsctroplater Peak Daily Discharge Highest Enoo ntered SMM Cr (M IIA OUE
Maximum Allowable Sources Maximum Maximm Allowable Oonoentraticn in Primary Drinking
Concentration (mg/1)** Oonoentration (m1/1) Concentration (mg/l) Treated Groundwater (m3/1) Water Standards (mg/1)
Arsenic 2.0 N.S.* 2.0 0.043 0.05
Cadmium 1.0 0.69 0.064 0.018 0.010
Chrapium 2.0 2.77 2.0 0.005 0.05
Coiper 3.0 3.38 3.0 0.08 N.S.
Lead 2.0 0.69 0.58 0.005 0.05
Mercury 0.03 N.S. 0.03 0.0066 0.002
Nickel 10.0 3.98 3.51 0.16 N.S.
Silver 5.0 0.43 0.43 0.02 0.05
Zinc 10.0 2.61 0.7 0.034 N.S.
Cyanide (Total) 5.0 1.2 1.2 Not Tested N.S.
Total Toxic Organics' 0.58 2.13 0.58 0.024 0.335
*N.S. - Not Specified
**mg/1 - (milligrams per liter) is equivalent to parts per million
1. Effective July 1, 1983. The CSDOC industrial control ordinance entitled "Regulations far Use of Districts Sewerage Facilities" provides for the
enforcement of EPA Industrial Categorical. Pretreatment Standards when they became effective. CSDOC enfcroes the standards that are most restrictive.
2. Federal Register, July 15, M3, pp. 32463-32487. These standards became effective April 27, 1984 fa: non-integrated facilities and June 30, 1984
for integrated facilities.
3. EPA Hazardous Site Control Division "Final Test Program Summary Report, Stringfellow Site, August 27, 198411.
4. California State Department of Health Services, Sanitary Engineering Brands, Primary Drinking Water Standards, June, 1983.
5. This value is sum of limits for endrin, lindane, methoxychlor, tcxa#iene, 2,4-D, 2,4,5-D, silvex and TIHM's.
ATTACHMENT 5
COMPARISON OF CSDOC RAW SEWAGE QUALITY
TO
EXPECTED STRINGFELLOW DISCHARGE QUALITY
CSDOC Average Raw Permit Limit Discharge Quality for
Sewage Quality for Stringfellow at Peak Stringfellow Based on EPA
July 183 - June 184 (lbs/day) Daily Discharge (lbs/day) Treatment Study (lbs/day)
Arsenic 9.6 3.1 0.067
Cadmium 40 0.1 0.028
Chromium 260 3.1 40.008
Copper 700 4.7 0.125
Lead 170 0.9 t 0.008
Mercury 1.2 0.05 0.010
Nickel 140 5.5 0.250
Silver 40 0.7 0.031
Zinc 500 1.1 0.053
Cyanide (Total) 100A 2.0 Not Tested
Total Toxic Organics 5.9B 0.9 0.037
I
A. Estimated
i
B. Includes chlorinated pesticides and PCB's
C. EPA Hazardous Site Control Division, "Final Test Program Summary Report, Stringfellow Site;
August 27, 1984"
�o
ATTACHMENT 6A
�4k.==Z,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
�►�� �� REGION IX
215 Fremont Street
San Francisco. Ca. 94105
1 6 JUL 1984
Santa Ana Watershed Project Authority
2060 Chicago
Suite C-3
Riverside, CA 92507
Attention: Mr. J. Andrew Schlange
Manager
Dear Mr. Schlange:
On January 9 , 1984 , the EPA approved Orange County Sanita-
tion Districts' pretreatment program. In its program submittal ,
the Districts described their capability, authority, and responsi-
bility for implementing Federal pretreatment requirements within
their service area ( including SAWPA' s jurisdiction) . Included
within this authority is the Districts' right to refuse to ac-
cept or to discontinue accepting wastewater discharges to the
sewer system to prevent impairment of the quality of receiving
waters or other problems in the treatment facilities. The EPA
believes that this is the most reasonable and effective means
for -providing comprehensive regulation of the numerous industrial
sources that discharge to POTWs throughout the country.
In addition to our review and approval of OCSD' s pretreatment
program, this office has kept abreast of the proposed sewer dis-
charge permit for treated groundwater- extracted from the String-
fellow site. Since OCSD is operating -an EPA approved pretreatment
program, it has the primary responsibility for assuring compliance
with pretreatment requirements. Nevertheless , after reviewing
the limitations developed by SAWPA for the Stringfellow discharge,
it appears that those limitations will be adequate to protect
water quality and treatment plant operations.
Questions should be addressed to Gregory Baker of my staff
at ( 415) 974-8336 .
Sincerely,
Frank M. Covington
Director, Water Man ement Division
cc: Orange County Sanitation Districts s
ECEI V ED
JUL 17 1984
3. A. W. P. A.
ATTACHMENT
•
erectors • , ,l Officers
PHILIP L.ANTHONY D • Z JOHN GARTHE
KATHRYN L BARR J O President
ROBERT L CLARK 9 • �� JOHN V-FONLEY
DONN HALL First Vice President
JOHN V.FONL.EY /QN 00 ,NC�� LAWRENCE P.KRAEMER,JR.
JOHN GARTHE Second Vice President
LAWRENCE P,KRAEMER,JR.
AUGUST F.LENAIN
L M.CLINE
NOBLE J.W ITE"E" ORANGE COUNTY WATER DISTRICT Secreltary Manager
July 23, 1984
Dlr. Andrew Schlange, Manager
Santa Ana Watershed Project
Authority
2060 Chicago Avenue, Suite C-3
Riverside, CA 92507
Dear Hr. Schlange:
Stringfellow Hazardous Waste Site
The Orange County Water District has reviewed the request for
engineering proposals to provide services, support, and facilities
for the removal, treatment, and disposal of contaminated ground-
water from the Stringfellow hazardous waste site in Riverside
County.
We feel that such a program will have minimum impact on this
District's wastewater reclamation activities conducted at our
Water Factory 21. It is our understanding that -any contaminated
groundwater which is treated prior to disposal in the Santa Ana
River interceptor will probably be diverted around the Orange
County Sanitation Districts' Treatment Plant No. 1, since that
line contains other high- TDS wastewaters, making it less usable
for reclamation.
After reviewing the permit limitations proposed for waste dis-
charges from the Stringfellow cleanup operation, we believe there
would be little if any impact on the water quality and reclamation
activities of this District even if the waters were diverted and
treated at the Sanitation Districts' Plant 'No. 1. Therefore, we
would support the SAWPA program for cleaning up the contaminated
groundwater.
Very truly yours,
David G. Argo
Assistant :Tanager and Chief Engineer
DA/mm
cc: Rayne Sylvester, Orange County Sanitation Districts
10500 ELLIS AVENUE--P.O. 0 O.BOX't3 FOUNTAIN VALLEY,CALIFORNIA 92728 TELEPHONE(714)963-5661/556-8260
—-ATTACHMENT ATTACHMENT 6 C
STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor
CALsFORNIA REGIONAL WATER Q. .,—ITY CONTROL BOARD
SANTA ANA REGION
6809 INDIANA AVENUE, SUITE 200
RIVERSIDE. CALIFORNIA 92306
PHONE: 1714) 684-9330
July 24, 1984
Mr. J. Andrew Schlange, Manager
Santa Ana Watershed Project Authority
2060 Chicago Avenue, Suite C-3
Riverside, CA 92507
Dear Mr. Schlange:
We have reviewed SAWPA's draft permit limits for discharge of treated
extracted groundwater from the Stringfellow site to the SARI line. Based on
our evaluation of the County Sanitation Districts of Orange County' s current
flows and influent and effluent quality, we do not anticipate that the pro-
posed discharge will affect CSOOC' s NPDES permit compliance. In addition, we
note that CSDOC has an EPA-approved pretreatment program, and that this office
recommended approval of the program. This pretreatment program gives the
Districts adequate legal and procedural authority to regulate all discharges
to their system to ensure permit compliance and protection of the treatment
works.
If you have. any questions, please contact me or Kurt Berchtold of my staff.
Sincerely,JAMES W. ANDERSON
Executive Officer
cc: County Sanitation Districts of Orange County
State Departament of Health Services, Sacramento - Tom Bailey
KVB:nao
` 1
DATE OF CAIIFORNIA—HEALTH AND WELFARE 4CY ATTACHMENT 6 D GEORGE DEUKMEJIAN. Gommow
)EEART:►AENT OF HEALTH SER)v.-ES
'IA/AAA P STREET
,ACRAMENTO, CA 95814
(916) 324-3773
July 24, 1984
Mr. Andrew Schlange, General Manager
Santa Ana Watershed Project Authority
2060 Chicago Avenue, Suite C-3
Riverside, CA 92507
Dear Mr. Schlange:
The Department has reviewed the limitations proposed by your agency
for the effluent from a wastewater pretreatment plant to be
constructed at the Stringfellow site discharging to the SARI line.
Effluent discharged to the SARI line at or below these limits would
not, in the judgement of the Department, adversely affect public
health or the environment at any location nor impair subsequent
treatment and disposal operations conducted by the County Sanitation
Districts of Orange County.
The provision of a wastewater pretreatment at the Stringfellow site
will be a vast improvement over present practices which include the
trucking of untreated wastewater over 200 miles across Southern
California for subsequent disposal. The Department expects that any
pretreatment plant established at the Stringfellow site will operate
in full accordance with all applicable federal, state, and local
requirements and regulations.
The Department is in complete support of the program your agency is
developing to construct and operate a first class pretreatment
facility at the Stringfellow site by January, 1985 pursuant to the
terms of the contract between SAWPA and the Department. We look
forward to your continued assistance.
Sincerely,
Thomas E. Bailey, Chief
Program Management Section
Toxic Substances Control Division
ECE; lVEL'
JUL 2 5 ;9fi4
ATTACHMENT 6E
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
f REGION M
215 Fremont Street
18 SEp 1984 San Francisco, Ca. 94105
Mr. Andrew Schlange , General Manager
Santa Ana Watershed Project Authority
2060 Chicago Avenue , Suite C-3
Riverside, CA 92507
Dear Mr. Schlange :
As you know, EPA recently completed a Fast Track Remedial
Investigation/Feasibility Study (RI/FS) to identify and evaluate
alternatives to the current extraction and off-site disposal _
of contaminated groundwater from the Stringfellow site in Glen
Avon, California. As a result, EPA has authorized construction
of an on-site pretreatment plant consisting of lime precipita-
tion for the removal of heavy metals and granular activated
carbon for the removal of organics. Treated effluent would be
discharged to a local publicly owned treatment works system
and sludge would be disposed of at a Class I facility. This
alternative will be implemented during the - three to five year
interim period prior to completion of the full-scale RI/FS and
implementation of the final remedy.
The California Department of Health Services (DOHS) concurs
with this activity and has submitted an application to EPA for
design and implementation funds. The EPA anticipates awarding
approximately two million dollars for this purpose in the next
week.
EPA understands that DOHS has entered into a contract with
SAWPA for design and construction management of this project,
and may soon enter into a contract for construction and opera
tions. Under the current schedule, SAWPA plans to have a pre-
treatment plant operable by January 1985 . In a letter dated
July 16 , 1984 , we explained EPA' s role in SAWPA' s efforts to
obtain a permit from the County Sanitation Districts of Orange
County. The EPA is supportive of SAWPA' s efforts and would
like to commend SAWPA in its effort to expedite this project.
We appreciate your participation in this project. Please
do not hesitate to contact me at (415) 974-8910 if I may be of
any assistance.
Sincerely yours,
Keith Takata, Chief
Superfund Programs Branch ZZ C r FZ 1 V c_
///111
H'1'1'H1.t11�1�1V'1' l�r'
CHARLKS O. KZRNZ, rN.O.. MRA
• OIRicTOR
O u NTti O F RANG E L. Rex CHLING. M.O.
C:> N<ALTN OPPICZM
.�- 3
s HEALTHCARE AGENCY 172fwtiT17TN
�
fANTA AN A.CA 92706 f2700
TSLSPNON61 714/834-7601
MAILING AOORtff1 P.O. SOX 356
SANTA ANA:CA 92702
PUBLIC HEALTH AND MEDICAL SERVICES
ENVIRONMZNTAL HZALTH
September 26, 1984
Mr. J. Andrew Schlange, Manager
Santa Ana Watershed Project Authority
2060 Chicago, Suite C-3
Riverside, CA. 92507
Dear Mr. Schlange:
We have reviewed the Santa Ana Watershed Project Authority's July 1984
Request for Proposals, along with letters from the Regional Water Quality
Control Board, Orange County Water District, County Sanitation Districts
of Orange County and the U.S. Environmental Protection Agency, regarding
the treatment of extracted groundwater from the Stringfellow site to be
discharged into the Santa Ana River Interceptor Sewer.
Based on our evaluation of the available information, it does not appear
that the, proposed discharge will adversely affect the County Sanitation
District's operations or disposal programs. -
We believe that, if the facility is adequately designed and properly
operated, the proposed treatment scheme can provide adequate removal of
contaminants to assure compliance with the pretreatment standards of the
County Sanitation Districts. We concur with the findings of the Regional
Water Quality Control Board and the U.S. Environmental Protection Agency
that the County Sanitation Districts have an adequate pretreatment program
with sufficient authority to terminate wastewater discharges into the
sewer system that threaten to impair the quality of receiving waters or
that create problems in the Districts' treatment facilities.
We have also been informed that the County Sanitation Districts' staff
intend to verify the quality of the discharge by periodic spot checks at
the Stringfellow treatment facility. If problems are subsequently
discovered, this Agency will cooperate with the County Sanitation Districts
of Orange County to insure that appropriate actions are taken.
Mr. Schlange
September 26, 1984
Page 2
In summary, we believe that based upon the current available information,
there are adequate controls to assure that the discharge of treated
groundwater from the Stringfellow site into the Santa Ana River Interceptor
line will not pose a threat to the health and welfare of the people of
Orange County.
If you have any questions, please contact my staff at 834-6925.
Very truly yours, -
qRert E._ Merr n, .S. , MPH, Director
Environmental Health
REM/st
cc: Wayne Sylvester, Orange County Sanitation Districts
Tom Bailey, State Dept. of Health Services
Jim Anderson, Regional Water Quality Control Board
Dave Argo, Orange County Water District
Frank Covington, U.S. EPA
HUNTINGTON BEACH
DEVELOPMENT SERVICES CALIFORNIA COASTAL COMMISSION " a 1 ,441
631 Howard Street San Francisco 9410S— 41 543-8555 k° �'""' *
.. c s�
NOV 2 6 1984 November 17, 1984
TopO, Box 190Commissioners and Interested Persons
Huntt p Bach,PAM9,C%l L. Fischer, Executive Director; James Burns, Deputy
Director for Land Use; Tom Crandall , District Director;
Jack Liebster, Project Planner; James McGrath, Coastal Analyst;
Eric Metz, Wetland Coordinator; Jon Van Coops, Coastal Analyst.
Re: STAFF RECOMMENDATION: CERTIFICATION WITH•SUGGESTED MODIFICATIONS,
ORANGE COUNTY BOLSA CHICA SEGMENT LAND USE PLAN (LUP),
(Public Hearing and Possible Commission Action; for the meeting of
November 27-30, 1984, as described in the enclosed meeting notice)
KEY STAFF-RECOMMENDATION
Background
The Commission, on April 22, 1982, found Substantial Issue with the Bolsa Chica
Land Use Plan (LUP) as submitted, and opened a public hearing on the LUP.
However, after further hearings and Commission discussion, the County withdrew
the Plan. In December 1983 the County .resubmitted the Plan along with a
Supplementary Information document (see Enclosure B). SB 429 was later passed
amending section 30237 into the Coastal Act to provide for the �devel'opment of a
Habitat Conservation Plan. In accompanying' reports staff recommends the
Commission (1) deny the LUP as submitteO, (2) certify the LUP subject to
suggested modifications, and (3) find substantial issue with the HCP. The
suggested modifications to the LUP incorporate elements of both the HCP process
and the County's Supplementary Information where consistent with the Coastal
Act.
Key Staff. Recommendation
Staff recommends that the Commission, after 'denying certification of the Bolsa
Chica Land Use Plan as submitted by the County of Orange, adopt the resolutions
and findings contained in this report, certifying the plan subject to suggested
modifications.
In order to implement this recommendation, the staff recommends a YES vote to
the following motion and the adoption of the Resolution III (page 4) and
findings. An affirmative vote by a majority of the appointed Commissioners' is
needed to pass the resolution.
I move that the Commission -certify the Bolsa Chica Segment
of the Land Use Plan of the County of Orange if it is modified
in conformity with the suggested modifications contained in the
staff report on this matter.
NOTE: Due to the size of the staff report, members of the public on mailing
lists will receive the public notice only. For a complete staff
report or executive summary, please contact Jack Liebster at the
Commission's San Francisco Office at (415) 543-8555 or the" South Coast
District Office at (213) 590-5071. Staff reports are also available"
at local libraries,. as indicated in the hearing notice.
-2-
• S
TABLE-OF CONTENTS
7PAGE.
INTRODUCTION 3
STAFF RECOMMENDATIONN
I. Resolution III: Certification with Modifications 4
II. Suggested Modifications for Certification 5
III. Findings .
A. Land Use Plan 17
B. Wetlands and Other Environmentally Sensitive 23
Habitat Areas
C. Public Access 24
D. Recreation and Visitor-Serving Facilities and 26
Recreation Boating
E. Hazards 26
F. Scenic and Visual Resources 27
G. Public Works 28
H. Energy 30
I. Archaeological Resources 31
IV: . Exhibits
-3-
INTRODUCTION
The history of planning for Bolsa Chica has been long, complex and
controversial. These suggested modifications are a sincere attempt to help
bring that process to a productive resolution. They draw upon the results" of
the additional work completed by the County since the LUP was last before the
Commission and upon the Habitat Conservation Plan (HCP) process resulting from
addition of section .30237 to the Coastal Act (SB $ , 1983). c
These months of effort have yielded valuable results. Perhaps foremost among
these is the milestone agreement among the County, the Department of Fish and
Game, Signal Landmark and the Coastal Conservancy that at least 915 acres of top
quality wetlands will be restored at Bolsa Chica as part of its development.
That agreement is reflected in the suggested modifications.
Another useful concept to come out of the process was the idea of substituting.,.
the "mini-reroute" of Pacific Coast Highway for the proposed bridge over a
navigable ocean entrance, should one be built. However other key controversies,
including the question of the ocean entrance, the diverse objectives of the
different landowners, and the uncertanties about feasibility of various
proposals for Bolsa Chica, have were not been fully resolved to date.
The suggested modifications take the basic Land Use Plan concept developed
through the County's work and the HCP process, identify possible adverse impacts
of such development, and establish policies' to assure these impacts will be
avoided or fully mitigated as required by, the Coastal Act. In some cases,
however, the uncertainty is so great that additional information must be
developed before a determination can be made on whether a plan as suggested in
these modifications is consistent with the Coastal Act.
Any LUP for Bolsa Chica must meet three basic tests:
1. It must be specific,
2. It must meet all policies of Chapter 3 of the Coastal Act, and
3. It must be the least environmentally damaging feasible alternative.
For reasons discussed more thoroughly in the LUP Denial and HCP Substantial
Issue reports and the Findings below, the Commission cannot yet conclude that
the Land Use Plan concept embodying a navigable ocean entrance meets these
tests. Both the County's LUP and the HCP defer the major ocean entrance
feasibility analysis to the Corps of Engineers. The Corps study may well
provide the Commission useful information with which ,to determine the least
environmentally damaging alternative. Howev tfi)t study has not yet been done.
The ability to successfully replace and r More wetlands and environmentally
sensitive habitat areas (ESHAs) that lie in the path of development is another
key concern. Restoration is a necessary quid pro quo for development. Under
the plan contemplated here, this restoration would occur in a presently active
oil field. Such a plan may well prove workable, but additional information on
its feasibility is needed to make the required findings on the Land Use Plan.
Under a strict interpretation of the Act, the Commission co uVin
approve a .
plan subject to such fundamental uncertainties as these. Howe County and
landowners have consistently sought approval of a Land Use order to
justify the investment in further specific studies. The suggested modifications
propose a compromise: approving two alternative Land Use Plans (see Exhibit 1),
one with a navigable ocean entrance, one with a non-navigable entrance. The
Commission can certify the alternative plans now only because the modifications
would create- a review step between the LUP approval and the LCP certification,
at which time the choice of the least environmentally damaging alternative will
be confirmed.
This review "the LUP'Confirmation" - would occur after sufficient studies are
done to fully support a least environmentally damaging feasible alternative
determination. Similarly, a Restoration Plan for the wetlands is to be
completed and reviewed by the Commission at this stage. The proposed
modifications also contain policies with which to evaluate the ocean entrance
and Restoration Plan.
The LUP Confirmation -process will be separate from and occur prior to the.:.-.
implementation phase. The LUP Confirmation process will include a public
hearing, subject to the Commission's usual LUP notice and hearing procedures.
As more fully elaborated in the proposed suggested modifications and findings,
the navigable entrance alternative (Alternative 1) will be reviewed for
consistency with criteria specified in the suggested modifications. If it is
found fully consistent by vote of a .majority of appointee commissioners,
Alternative 1 be confirmed as the certified LUP and the non-navigable entrance
alternative (Alternative 2) will no longer be a component of the LUP. If
Alternative 1 is not found consistent, it will no longer be deemed certified,
and Alternative 2 will become. the certified' LUP.
I. STAFF RECOMMENDATION
Staff recommends that the Commission adopt the following resolution. The
appropriate motion to adopt the resolutions is:
I move that the Commission certify the Bolsa Chica Segment of the
Land Use Plan of the County of Orange if it is modified in conformity
with the suggested modifications contained in the staff report on this
matter.
Staff recommends a YES vote. The motion requires an affirmative vote of 7
Commissioners (majorTUY—of appointed membership for approval .
RESOLUTION III: CERTIFICATION.WITH MODIFICATIONS
The Commission hereby certifies the Land Use Prlan .for the Bolsa
Chica Segment of Orange County subject to the following modifications
and ado ts-the-findin s stated-below on the grounds
that, if modified as suggested be-ow, the Land Use Plan will
meet the requirements of and conform with the policies of Chapter 3
(commencing with Section 30200) of the California Coastal Act to
the extent necessary to achieve the basic state goals specified in
Section 30001.5 of the Coastal Act; the Land Use Plan will contain
a specific access component as required by Section 30500(al of the
Coastal Act; the Land Use Plan will be consistent with applicable
decisions of the Commission that shall guide local government actions
• pursuant to Section 30625(c); and certification of the .Land Use Plan
will meet the requirements of Section 21080.5(d)(i) of the
Environmental Quality Act, as there would be no further feasible
-- - mitigation measures or feasible alternatives which could substantially
lessen significant adverse impacts on the environment. The .suggested
modifications to the submittal are necessary to achieve the basic
state goals set forth in Section 30001.5 of the Coastal Act.
The Commission further directs that if the County of Orange adopts and
transmits its revisions to the Land Use Plan. in conformity with the
suggested modifications, then the Executive birector shall so notify
the Commission.
II. MODIFICATIONS FOR CERTIFICATION
Certification of the Land Use Plan is subject -to the following modifications:
A. LAND USE. PLAN AND MAP (Section III, Part 1)
1. Modify Section III, .Part 1, The Land Use Plan, Exhibit 6, and all
text and exhibits derived therefrom to incorporate Alternatives 1 and
2 as shown in Exhibit 1, as the Land Use Plan.
2. Add to Section III: A, "Land Use Plan Confirmation" review shall-be
conducted y the Coastal Commission on the Plan Alternatives prior to
the County's submittal of the Phase III •LCP Implementation Program.
Alternative 1 shall be the adopted Land Use Plan provided that the
Commission by majority vote of the appointed membership finds at the
time of this review that:
(a) a navigable ocean entrance would have no significant adverse
effects and would conform with Public Works Policy 10;
(b) The Restoration Plan can be accomplished as provided in the
modified LUP; and
(c) The navigable ocean entrance is,consistent with all other
policies of the modified LUP and the Coastal Act.
If the Commission does not find that each of these standards is
satisfied, Alternative 1 shall no longer be the adopted and certified
Land Use Plan and Alternative 2, providing for a non-navigable ocean
entrance shall be the Land Use Plan adopted by the County and deemed
certified by the Commission.
3. Add to olic .2: The policies contained in the suggested
modifications of the Coastal Commission shall take precedence over any
other conflicting policies of the Plan.
4. Add the following. Policy (p III-4): _
Land. Allocation: The Land Use Plan shall provide for the following
uses in the specified amounts within the Planning Area and the Linear
Park:
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(a) Restored wetland at least 915 acres.
(b) Restored Environmentally Sensitive Habitat Area (ESHA):
(a) Eucalyptus grove at least 21 acres-
(b) Coastal dunes at least 28 acres
(c) -Coastal scrub/shrub at least 37 acres
(c) Linear Park (not exclusive of restored ESHA) at least 57 acres
(d) Marina 75 acres
(including at least the following public uses):
(1) Dry Storage 6.5 acres
(2) Launching Ramps 5 acres
(3) Boat Repair 2 acres
(4) Boat Sales/Rental 1 acre
(5) Chandlery and Fuel Dock Facilities 1.5 acres
(e) Huntington Harbor Connection"Channel up to 17 acres
(subject to Public Works Policy 10 (3))
B. WETLANDS AND ENVIRONMENTALLY SENSITIVE HABITAT AREA RESTORATION
Modify Biological Resources/Habitat Management policies, Section III, Part
2 as follows. Conform all other LUP Maps, Text and Figures to these
modifications.
1. Modify Policv. 2- (p III-20)- to. read: At least 915 acres of wetlands
shall e restored, enhanced an maintained as high quality, fully
functioning wetlands wfthin the Bolsa Chica Planning Area as shown in
Exhibit 1, Alternatives 1 and 2.
2. Substitute for- Policy 3- and 4 (p. III-20) -the following:
Restoration-Plan: The owners of, or agents for private lands within
the Bolsa Chica Planning Area shall fund the preparation of a detailed
Restoration Plan for enhancement and restoration - of all the wetlands
and Environmentally Sensitive Habitat Areas (ESHAs) required by the
LUP. The plan shall be prepared by the Department of Fish and Game or
a contractor to • the Department selected jointly by the Coastal
Commission, the County and the Department of Fish and Game.
The Restoration Plan shall be completed and submitted to the
Commission for review and approval as part of the "Land Use Plan
confirmation" prior to Phase III LCP Local Implementation Program.
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The Restoration Plan shall meet the following criteria: ..
a) Development of at least 915 acres of fully functioning, top
quality wetlands providing high biological productivity and
habitat diversity; specifically, the creation of a mix of
tidal muted tidal and nontidal (brackish, fresh and
hypersaline) wetlands;
b) Restoration of 86 acres of Environmentally Sensitive Habitat
Area as specified in the Land Allocation policy.
c) Low capital and operation costs;
d) Whenever possible, consistent with restoration and resource
protection needs, mutual compatibility with public and
private development, including present and future oil
. operations; '
e) High predictability of success; ,
f) Protection and/or restoration of endangered species habitat;
g) Assurance of quality water of sufficient quality to provide
. for maximum productivity .in the wetlands; and
h) Protection of the wetlands from 'any impacts emanating from
the marina, commercial ,,.and residential areas.
(2) The Linear Park,' which includes a variety of ESHAs, shall be
designed to maximize wildlife values while still meeting public
access needs.
(3) The' Plan shall provide for:
a) Adequate legal and institutional arrangements and a
financing plan for the successful establishment, operation,
maintenance and protection of all wetlands, ESHAs, and
necessary water supplies.
b) The funding of all operation and maintenance costs.
c) Specific criteria, in terms of species composition,
diversity and population density, with which to determine
the completion and success of ESHA and wetland restoration.
d) A monitoring program to assure that all Restoration Plan
provisions are complied with.
e) Specifications for the buffers necessary on lands adjacent
to the restored wetlands consistent with the LUP Buffer
policies.
f) The design of the wetlands to maximize aesthetic appeal to
developed areas consistent with resource protection.
T
g) Specific measures to ensure that high quality, fully
functional restored wetlands can be established in a manner
compatible with continued oil operations.
3. Add-the.following policy. (p. III-20): The Restoration Plan shall be ,
entirely o siste�t with and adequate to carry out- the Phasing
policies of the LUP.
4. Add the following policy. (p. III-20): The owners of, or agents for,.
private Tan ss—wit—Fin t e bolsa UhlCa Planning Area shall fund the
wetland and Environmentally Sensitive Habitat restoration activities
set forth in the Commission approved Restoration Plan. Upon
completion of enhancement and restoration activities, these parties
shall transfer sufficient funds to an endowment or other mechanism to
assure the management and protection of the Wetland and
Environmentally , Sensitive Habitat • Areas. The fund amount and.;.
financing mechanisms shall be specified in the Restoration Plan.
Contributions may also be made by the public; by government agencies
and by other parties interested in restoration, preservation and
interpretation of these natural resources.
PHASING ,
5. Add the following policy to•Section.°III,.Part•2: Phasing Program:
A detailed Phasing Program shall be prepared prior to submission of the
Implementation Program. The Phasing Program shall include a precise
description of the kinds, locations and intensities of uses at each
phase of development, and a schedule of the restoration and mitigation
actions prerequisite to each element of development. The Program
shall be consistent with the LUP's Phasing policies below.
6. Modify. Policy•6• (p III-21)•to• read: Phasing Policies.
(a) . There shall be no net loss of wetland or Environmentally
Sensitive Habitat (ESH) at any time. Specifically, the area of
functioning wetlands- and ESH in the Planning Area shall at no
time be permitted to be less than 852 acres and 86 acres
respectively, as specified in the Land Allocation Policy.
(b) No portion of the habitat of any endangered species, including
the Belding Savannah Sparrow, shall be disturbed for development
until an equivalent area of fully functioning replacement habitat
has been established and its maintenance assured.
(c) New development shall be permitted in the Planning area only
after the Restoration Plan has been reviewed and approved by the
Commission and all other applicable Plan policies have been met.
(d) Development grading in the lowlands shall be perm tted only after
a proportionate amount of high quality wetlands aXd Eviron-
'mentally Sensitive Habitat Area has been restored, found to •be ,
fully functioning by the Department of Fish and Game, and
conveyed to the management agency identified in the Restoration
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Plan. The proportion of restored wetland to proposed development
shall be one and a half acres to one until 852 acres of wetland
are restored, and thereafter one to one until all 915 acres of
wetlands are restored.
(e) Where wetland acreage above 852 acres is to be restored but land
within the designated wetland area is unavailable, due to oil
operations for example, interim on- or off-site restoration may
be accomplished with the former being of higher priority. If.
interim off-site restoration is chosen, it shall be completed
only if:
i r 2 acres shall be restored for each acre lost;
ii) at the earliest feasible opportunity, but in no case later
than the final phase of development, the restoration shall
be completed on-site; and '
iii) the area off-site shall be permanently protected as
wetlands.
(f) The eucalyptus grove, Warner Avenue Pond and other sensitive
habitats of the Bolsa Mesa shall be recreated within the Planning
Area and/or the Linear Park and shall be fully functibning prior
to new development on the Mesa;
(g) Title to all lands designated for wetlands or Environmentally
Sensitive Habitat Area in the lowlands shall be conveyed to an
agency or organization acceptable to the Executive Director of
the Commission prior to any new development in the Planning
Area.
BUFFERS
7. Modify Policy• 10 (p" III-21) as follows:
(a) Buffer areas shall be established to protect wildlife habitat.
The buffers in the Central Wetland shall be a minimum of 100 feet
in width measured from the edge ,of the wetland or environmentally
sensitive habitat to any adjacent development. The buffer
area shall be fenced and heavily vegetated. The buffers adjacent
to the "Edwards Thumb" area, the Mixing Basin and Flood Control
Channel , the Riparian Canyon, and the Outer Bolsa Bay wetlands,
may be varied from this standard if the Restoration Plan approved
by the Coastal Commission demonstrates,- based on experimental
evidence, that lesser or greater widths are necessary to
establish fully functional buffers.
(b) Buffer Study: The buffer study may be completed as .part of the
Restoration Plan. A work plan for the study shall be submitted
to the Executive Director of the Commission for review and
approval in consultation with the County and the Department of
Fish and Game. The Study shall be performed to meet the ,
"Criteria for Establishing Buffer Areas" of the Wetlands'
Guidelines as shown in Exhibit 3.
All wetland and ESHA areas shall be designed to prevent physical
intrusion, except where access designed consistent with "resource
protection needs is provided in the Restoration Plan for the
fallowing:
a) to provide visitor proximity to the wetlands and ESHA; and
b) to accommodate oil-related activities.
C. PUBLIC ACCESS
Modify. Orange• County LUP. Policies: Coastal .Access, p III-31
1. Modify Policy. l. (p. III-31) as- follows:
Access shall be provided:
a) to and along all shorelines between the restored wetlands and new
residential and commercial development.
b) to and along the entire marina, except in areas posing health and
safety risks, and
c) to and between recreation and access nodes within the residential
and commercial area.
A specific access plan consistent with Exhibit 2 shall be included
with the Implementation :Program for Commission review and approval .
2. Delete Policy 20. and substitute:
The maximum public recreation and access,including opportunities for
public waterway viewing, fishing, small boat launching and passive
recreation such as picnicking, shall be established within areas of
new residential and commercial development consistent with the Public
Access Area Concepts, Exhibits B3 through B 13, Balsa Chica LCP Land
Use Plan- Supplementary. information. (Dec. 1983).
. 3. Policy•4 (p III-32): Delete
4. Policy 5 (p III-32): Delete
5. Add the. followin olicy. (p• III-33): Any new alignment of Pacific
o�ast ig way shall provide pedestrian and cyclist corridors in both
directions of travel.
6. Add the following.,to- Policy 10:
Access to provide viewing and educational opportunities shall be
provided on the perimeter of the wetland as specified in the wetland
Restoration Plan. Access shall be designed with DFG and. consistent
with resource protection.
' • -11-
7. Policy 16 (p. I1I-33): Delete.
Orange County LUP- Policies: - -Transportation Policies,.pp. III-27
8. Add the following policies:
PCH and the Cross Gap Connector Policies:
a) Exhibit 1 shows the recommended location of the PCH reroute under
Alternative 1. Exhibit 1 also shows a corridor for the location
of the cross-gap arterial road and connections thereto.
b) A detailed plan for the alignment of PCH and the cross gap
connection that is . the feasible, least environmentally damaging
alternative shall be prepared in cooperation with the HCP parties
in consultation with the City of Huntington Beach and local .:..
neighborhood groups, and included for Commission review and
approval in the Implementation Program.
c) Talbert and Graham shall be kept as cul-de-sacs unless more
detailed planning and traffic engineering studies indicate that
their connection with the cross-gap road is essential.
d) With only Pacific Coast Highway (PCH) rerouting, ,the former PCH
Right of Way shall be available for use in expanding and
restoring beach recreation and coastal dune and wetland habitat.
Any relocation or change to PCH shall not cause a net reduction
in the area of useable beach, environmentally sensitive habitats
or the 915 acres of wetland to be restored.
9. Policy•Up, 111-27)• Delete reference to Pacific Coast Highway
widening in this policy and elsewhere that it appears.
10. The Coastal Access Concept Plan, Exhibit' 35, and all exhibits derived
therefrom shall be modified to reflect the access modifications.
D. RECREATION AND.VISITOR-SERVING, FACILITIES-AND-RECREATIONAL-BOATING
Orange. County LUP Recreation. Policies,. Section. III,•Part. 5 (p- III-35)
1. Add to Policy-8 (p. III-37) .as follows
Any marina shall provide land sufficient to accommodate storage for at
least 400 dry stored boats, 10 lanes of launching ramps, and related
necessary facilities including hoists, stacking and staging areas to
provide for maximum public access to and use of coastal waters.
2. Delete Policy.l3 (p. III-37) and- substitute:
Any ocean entrance plan shall provide for no net loss of sand at Bolsa
Chica State Beach.
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E. HAZARDS
1. Modify County Geology. Policy 1,. (p. III-15) •to-add:
Fault zones and areas of soil liquefication potential and ground
subsidence, as indicated in the "Preliminary Evaluations" of the Bolsa
Ch.ica Local Coastal Program (Jan. 1984) prepared by Woodward Clyde
consultants and concurred in by the State Division of Mines and
Geology shall be delineated on the LUP map.
2. Add the following to Policy 3 (p• III-15):
Habitable structures shall be set back at least 50 feet from active
fault zones.
Navigation channels and structure's for human occupancy shall be.:.
located outside of areas of liquefiable soils unless specific
mitigation measures to avoid liquefaction hazards are approved by the
Division of Mines and Geology and are submitted for Commission review ,
and approval with the Implementation Program. Unless the Division of
Mines and Geology specifies alternative standards, mitigation measures
such as soil densification shall be sufficient to withstand a
repeatable bedrock acceleration of 0.65g.
3.- Add the following to•Groundwater Po>licy.l,,. (p. III-17):
Specific measures to minimize the potential for groundwater intrusion
shall be approved by the Department of Water Resources and submitted
for Commission review and approval with the Implementation Program.
F. SCENIC AND VISUAL RESOURCES
Orange. County. LCP Policies: - .Land form, pp. III-14
1. Modify. Policy_ 1 (p III-14)as follows:
Revegetation and landscaping treatments shall be included in all
development to maintain and enhance the vegetated character of the
Bolsa Chica and Huntington Mesa bluffs. Any reroute of, or new bridge
along PCH shall be designed to enhance the scenic character of the
Bolsa Mesa and the coastline.
The existing Department of Fish and Game scenic and interpretive
overlook on the Bolsa Mesa shall be replaced in new development.
G. PUBLIC.WORKS
Orange County-LCP•Policies: • . Public.Works, pp.- III-40
1. Modify Policy- 1. (p- III-40)•to- read:
(a) A specific plan shall be prepared designating locations of
utilities for all new development proposed in the Land Use Plana
This utility plan shall be submitted for review and approval of
the Commission as part of the Implementation Program.
(b) Utilities shall be located outside of the wetland and
Fnvirnnmentally Sensitive Habitat Areas unless there is no other
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feasible less environmentally damaging alternative. Mitigation
measures shall be provided to minimize adverse environmental
effects of any utilities located in these areas, including
utilities directly related to petroleum production, marsh
restoration and maintenance, flood and water quality control and
coastal dependent industrial uses.
(c) Consistent with sound engineering and design practices, utilities
shall generally be located in road system rights-of-way or, where
necessary or feasible, in open space areas not directly related
to wildlife habitat.
Ocean Entrance
2. Policy 10 (p III-411 -Revise.as follows:
P
(a) Any ocean entrance to Bolsa Chica, including any related
structures such as groins, breakwaters or channels shall be
permitted only if the Commission reviews such entrance and finds
that it is the least environmentally damaging feasible
alternative; that it will have no significant adverse- impact on
sand supply, beach profile or recreation values of any of the
beaches in the area; and that an effective program of
- institutional and financing arrangements adequate to mitigate or
eliminate any anticipated or unanticipated impacts has been
established and funded.
(b) A detailed analysis of the alternative plans for an ocean
entrance and channel system, including both non-navigable and
navigable options, shall be submitted for the Commission's review
and approval at the Land Use Plan Confirmation stage prior to
submission of Implementation Program.
The analysis shall address all alternatives to determine the
least
damaging feasible alternative. The analysis shall detail the
environmental and recreation impacts of all alternatives;
describe the proposed mitigation measures; and detail the costs
and financing for construction maintenance, and operation of each
alternative and its associated mitigation measures.
Land Use Plan Alternatives 1 and 2 as described herein shall be
included as explicit alternative plans in the Corps of Engineers
Sunset Harbor Study to receive complete analysis and review equal
to any other alternative considered. '
P (c) Ocean Entrance Policies:
Any plan for an ocean entrance shall meet at least the following
criteria:
(1) The entrance plan shall protect and maintain the area's
beaches and shall not increase downcoast or upcoast erosion; .
specifically, the plan shall provide for no net loss of
sandy beach available for recreational use from the Anaheim
Bay Breakwater to the Huntington Beach pier.
(2) The plan shall. specifically identify the area of existing
beach required for sand by-pass operations, and the means to
provide useable replacement recreational beach.
(3) The plan shall fully protect existing swimming, surfing and
beach enjoyment opportunities. The plan shall not require
the installation of a groin field to stabilize the beaches
.upcoast or downcoast of the proposed entrance.
(4) The plan shall avoid the risk of seawater intrusion into the
fresh water aquifer landward of the Newport-Inglewood fault
zone.
(5) Any ocean entrance and channels to Huntington Harbor and the
visitor-serving marina romplex shown in the Land Use Plan.:..
(see Exhibit 1) shall be subject to detailed hydrologic
analysis according to U.S. Army Corps of Engineers (COE)
methodology.
(6) Any entrance shall minimize operation and maintenance costs
and maximize capital cost-effectiveness; and
(7) Any entrance design shall mitigate adverse effects, if any,
on the wetlands.
(8) Any navigable entrance shall be at least 8 feet deep at mean
low water, with the width dependent on proposed boat use
(between- 400 and 600 feet at the surface);
(9) Any navigable entrance shall be designed so as to allow an
operator to accept responsibility within accepted liability
parameters.
(d) Huntington Harbor connection.
A navigable Huntington Harbor connection may be both technically
and economically feasible and should be considered for inclusion
in the LCP, provided that:
(1) prior to the LUP confirmation, the Coastal Commission
approves a complete financing program and a mitigation plan,
prepared by the proponents of the connection, for any
wetland-associated impacts of the connection. - .
(2) if a navigable connection is to be built, it must be the
• least environmentally damaging channel feasible.
3. Revise. Policy- 11: ' . (p• III-41) as•follows:
A financing, operation and maintenance plan for any ocean entrance and
navigation channels shall be established in the Public Facilities
Management and Financing Plan, and submitted for Commission review and
approval with the Implementation Program. The Plan shall :
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i
(a) Detail the _costs of the ocean entrance alternatives and all
mitigation measures.
(b) Provide for monitoring of the beaches for the life of the project
after completion of any ocean entrance and related structures-to
identify any beach impacts.
(c) Specify an impact mitigation program establishing financial and
institutional arrangements that will assure adequate funding to
eliminate any impacts that may arise- during the life of the
project.
4. Add to. Policy•13. (p- III-41) as- follows:
Prior to the certification of the LCP, the Conservancy, the County and
the Metropolitan. Water District (JMWD) should work together with other : .
affected parties to identify appropriate locations for a potential
alternative development site to meet MWD's goals and, through the
project implementation agreement, described in Policy 22 below,
incorporate the necessary land financing measures to ensure an
equitable development.
5. Policy 22 (p III-42a) Revise as follows:
22. Prior to approval of any land division and/or any development of
the subject property, a Phase III Bolsa Chica Public Facilities
Management and Financing -Plan .(M&FP) providing finalized,
contractural detail for Items 11 and 15 (a through e), above,
shall be submitted for the approval of the Planning Commission,
and the Board of Supervisors and the Coastal Commission. The
Phase III MVP shall contain contractural arrangements for the
phasing, funding, construction operation and maintenance for all
facilities as identified in Items 11_and 15 (a), above.
Orange County LCP- Polic-ie_s __Tidal Hydrology, -pp. III-17
6. Add- to- the_beginning. of. Policy. 2. (p- III-17): "consistent with wetland
restoration needs..."
7. Delete Policy. 3 (p• III-17)
8. Revise the-first line of. Policy 4. (p III-17)to read: "Any ocean
entrance channel system shall e ...
H. ENERGY "
Orange County LCP. Policies: Energy Facilities, pp III-45
1. Modify Policy 1 (p III-45) to read:
The oil field operator shall operate the field consistent with
PRC section 30232 and shall consolidate operations. consistent
with PRC section 30262.
A detailed Energy Facilities Plan shall be submitted for review
and approval as part of the Implementation Plan indicating both a
short-term plan for immediate wetland restoration and a Tong-term
plan compatible with the ultimate phase out of energy production
facilities. The short-term plan shall indicate: oil and gas
wells proposed for secondary or tertiary recovery requiring new
injection wells and new roads or pads necessary for such
activities; and costs and phasing to remove obsolete well
facilities and roads and to install facilities necessary to
implement the Restoration Plan.
2. Modify Policy 10 (p III-46) -to read: As oil production is phased
out the operator shall remove oil facilities, roads and pads in a
manner which promotes and is consistent with the Restoration
Plan.
I. ARCHAEOLOGY
Orange County LCP Policies: - Cultural . Resources, pp. III-25
1. Add to-Policy-1 (p III-25) . the following:
Appropriate mitigation measures for archaeological site Ora-83 as
specified in Coastal Permit 5-83-984, including possible
preservation of all or part of the site, shall be incorporated
into the LCP.
For other sites, if archaeological resources are disclosed during
any construction phase of the project, all activity which could
damage or destroy these resources shall be temporarily suspended
until the site has been examined by a qualified archaeologist and
mitigation measures have been developed to address the impacts of
the project on archaeological resources. Such mitigation
measures shall be reviewed by - the State Office of Historic
Preservation and approved by the Executive Director of the
Commission.
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FINDINGS
RELEVANT. COASTAL.ACT.POLICIES
Section 30108.5 of the Coastal Act provides that Land Use Plans must be suffi-
ciently detailed to indicate the kinds, location and intensity of land uses, the
applicable resource protection -,and development policies and, where necessary, a
listing of implementing actions. -
Section 30231 of the Coastal Act provides that the biological productivity and
the quality of wetlands appropriate to maintain optimum populations of marine
organisms and for the protection of human health shall be maintained and where
feasible, restored through, among other means, minimizing adverse effects of
wastewater discharges and entrainment, controlling runoff, preventing depletion
of ground water supplies and substantial interference with surface water"flow
encouraging waste water reclamation and maintaining natural vegetation buffer.;.
areas that protect riparian habitats.
Section 30233(a) of the Coastal Act provides that the diking, filling, or
dredging of wetlands shall be permitted in accordance with other applicable
provisions of this division, where there is no feasible less environmentally
damaging alternative.
Section 30411(b) of the Coastal Act provides that the Department of Fish and
Game may study degraded wetlands and identify, those which can most feasibly be
restored in conjunction with a boating facility.
Section 30260 of the Coastal Act provides that** coastal-dependent industrial
facilities such as seawater desalting facilities and oil and gas field op-
erations shall be encouraged to locate within existing sites , such as that
currently owned by the Metropolitan Water District (MWD), and that operated by
Aminoil , providing that adverse environmental effects are mitigated to the
maximum extent feasible.
The Findings for denial of the LUP are hereby incorporated in full into these
findings.
A. LAND USE. PLAN-AND-MAP
The suggested modifications take the basic approach of accepting the concepts
for a Land Use Plan developed by the County and the HCP process, and specifying
policies that would prevent or fully mitigate any impacts such a Plan might
have. In effect, the modifications thus attempt to create the least
environmentally damaging feasible alternative plan. In some cases, however, the
uncertainty about such impacts and the feasibilty of their mitigation is so
great that additional information must be developed before a final- determination
can be made on whether the policies of the Act have been met.
One of the principal areas of uncertainty is whether a navigable ocean entrance
could be constructed, financed, and maintained in a way that it would not have
impacts unacceptable under the Coastal Act. The policies suggested this report
are intended to prevent or fully mitigate such impacts. By fully complying with
these policies a navigable ocean entrance could be considered the least
environmentally damaging alternative. But the studies which would allow the
Commission to determine whether such an alternative is feasible have not been
completed.
Therefore the Commission is taking the unusual approach of adopting a Land Use
Plan with two alternatives for an ocean entrance - one navigable,"one not. At a
later point, the "Land Use Confirmation" stage, when the results of the ocean
entrance feasibility analysis and the intrinsically related Restoration Plan
called for in the modifications are available, the Commission would determine
whether the ocean entrance plan met the policies of the Land Use Plan and the
Coastal Act.
Alternative, Procedures-Considered-by. the- Commission
In recommending modifications which would establish a new two-step LUP review
and approval process, the Commission has considered several options including
(1) full certification as submitted; (2) certification with provisions for
withdrawal of the LUP at the Phase III Implementation stage if the navigable
entrance cannot be shown to feasibly meet LUP policies; and (3) withholding LUP
approval until more information is available. to make the determinations required.;:.
under the Act.
(1) Full Certification. This option would require the Commission to find that
Alternative 1, and specifically the navigable ocean entrance, is the least
environmentally damaging feasible alternative. This option is generally favored
by Signal Landmark. However throughout both the Land Use Plan and the Habitat
Conservation Plan processes, the determination of the environmental effects and
feasibility -e-f- the navigable ocean entrance; alternative was deferred to the
Corps of Engineers process. Both the LUP and the' HCP rely on the forthcoming
Corps of Engineers feasibility study to provide . the information to make the
determination of the best alternative. But that study has yet to be completed,
and subjected to the public hearing process. The Commission has a specific
charge to make the finding that the LUP incorporates the least environmentally
damaging alternative, and it cannot make that finding without a thorough
analysis of alternatives.
The Corps' 1983 Progress Report indicates that a navigable alternative is
possible, but the report specifically declines to conclude that that alternative
is the least environmentally damaging feasible alternative. In fact, as noted
in the denial findings, the Corps concludes:
Considerin the relative impacts of the six concept plans [included in
the report, it is not possible to identify with certainty any plan
which is environmentally superior at this time. Further studies
are necessary in order to weight various environmental factors
and to determine the nature of impacts on these factors.
The Commission requires sufficient data to make the least damaging feasible
determination. The Commission can agree with County's choice of the Corps to do
this work. But until this work is done in a manner sufficient to support the
required analysis, the Commission cannot make its determination as to the least
damaging alternative, and therefore cannot fully certify the Plan as submitted.
(2) Certification with .Possible Withdrawal. In the staff discussion on the
proposed modifications, the County has in ormally suggested language as a
substitute for specifying alternatives in the Land Use Plan.-
If the letter and intent of these standards cannot be
fully satisfied via designs and feasible mitigation
_19-
measures identified and developed during the LCP Phase._III/
Specific Plan and the Corps of Engineers Sunset Harbor
Study e. . , Technical Studies, EIS/EIR), the County shall
withdraw its plan from the Coastal Commission. Any Plan -
resubmitted by the County must be entirely consistent with „
the above-referenced standards in order to be deemed
certifiable by the Commission.
Adopting this.. option would have many of the failings discussed in
connection with the first option. As a practical -consideration it would
tend to focus attention on the navigable alternative, and could lead to
insufficient effort to evaluate other alternatives which, with adequate
study, could prove less environmentally damaging. Specifying at least one
alternative which appears to entail less environmental risk is one way the
Commission can be sure the Corps study or any similar evaluation will yield
the information necessary to make the .determination required by PRC 30233.. .-
Having such an alternative would provide the Commission a clear way out of
the dilemma that might ensue if the feasibility study of the design and
financing of the navigable entrance were to reveal that the mitigations
necessary to meet the policies of the modified LUP were too technically
difficult, too expensive, and/or too difficult to finance.
Also this option would make it more likely that the Commission would be
faced with arguments that it must accept somewhat less than full compliance
with the LUP alternatives because there Was no viable alternative. Finally,
under this option, if the studies resulted in withdrawal of the LUP, the
costly and time-consuming process ofLUP preparation and approval would
have to be begun again.
(3) Withholding. LUP - Modifications. This approach would eliminate the
possibility of certification until substantially more information is
available. Given the inadequacy of available information, this approach
would certainly be consistent with a conservative interpretation of the
Act.
However, simply denying the LUP might do little to give the County guidance
about what kind of Plan would be certifiable. To avoid this predicament
the Commission might give the County some form of concept approval that
would avoid the legal requirements of an. LUP approval. However, both the
County and the major landowners have expressed their keen desire to see
some form of Commission commitment to a Land Use Plan sufficient to warrant
their further investment in the studies necessary to finalize the LCP.
LUP Confirmation-Process.
The-Commission has considered each of the above options and determined that
each has unacceptable shortcomings. Instead, the Commission adopts a new
procedure for approval -of this LUP, as set forth in the suggested
modifications. This process is desigr+ed to be responsive to the unusual
environmental and planning constraints of the Bolsa Chica Subarea as well
as the Coastal Act's procedural and substantive requirements for LUP
certification.
Information now before the Commission indicates that an LUP involving a
non-navigable ocean entrance to a Bolsa Chica marina (Alternative 2) would
be approvable as consistent with Sections 30233, 30240, and 30411 of the
Coastal
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Act. However, the County has submitted a plan with a navigable ocean entrance
(Alternative 1),. The county and major landowners contend- that this alternative
also can be carried out consistent with the Coastal Act. As they acknowledge,
-- however, costly and lengthy studies will be needed to demonstrate whether
and how- it can be done.
In order to provide impetus for these studies, the County and landowners
look to the Commission for commitment to Alternative 1, should it, be proven
consistent with the Coastal Act. The Commission, on the other hand, is
concerned that irf the forthcoming study process, attention be given to
identification of the environmentally best means of implementing
Alternative 1, should it be the ultimate choice. If it is not the choice,
the Comnissi.on prefers to minimize the need for renewed planning and review
efforts at the County and State levels.
Thus the Commission adopts suggested modifications which, if incorporated.;_•
into the LUP, would result in certification of a plan containing both • =-
Alternatives 1 and 2. By adopting these suggested "modifications, the
County will agree to participate after certification in an LUP confirmation ,
review by the Commission. At that time, the Corps study, the Restoration
Plan, and other relevant information will be submitted. to the Commission
and form the basis of a new evaluation of Alternative 1 in light of
standards stated in the suggested modifications. The certification of
Alternative 1 will be confirmed (and alternative 2 no longer deemed
certified) only if it fully. satisfies all of the following criteria:
(a) a navigable ocean entrance would have no significant adverse
effects and would conform with Public Works Policy 10;
(b) The Restoration Plan can be accomplished as provided in the
modified LUP; and
(c) The navigable ocean entrance is consistent with all other
policies of the modified LUP and with the Coastal Act.
If it does not satisfy all of these criteria, Alternative 1 will no longer
be deemed certified and Alternative 2 will be the certified LUP.
The LUP confirmation process is separate -from the Phase III Implementation,
including any specific plan to be adopted by the County. The Commission
expects that it will not be possible to develop certain provisions of the
LCP Implementation until the choice between Alternatives 1 and 2 is final .
Therefore, the LUP confirmation review must be conducted separate from the
Implementation Ordinance review and sufficiently prior to it to allow
accommodation of the Implementation provisions to the final LUP choice.
Because the confirmation of one alternative to the exclusion of the other
involves identification of kinds, location, and intensity of land uses,
this LUP confirmation process is an extension of the LUP review process
established by the Coastal Act. Thus the LUP confirmation will be carried
out consistent with the procedural provisions of Section 30512(c) of the
Coastal Act and Article 11 of the Commission's regulations . (Title 14,
Administrative Code). This will include preparation and circulation of a
staff report and recommendation, public
-hearing, and vote by the Commission on whether Alternative 1- fully satisfies the
specified criteria. Affirmation must be by a majority of appointed
Commissioners.
Land Use Plan Map
The Land Use Plan provides for the following features:
° 915 acres--of restored wetlands within the 1,292 acre historic wetland
delineated in the DFG wetland determination. The precise mix of
habitats to be created in this area would be defined in the
Restoration Plan recommended by modification.
° 86 acres of specified Environmentally Sensitive Habitat area, exclusive
of the restored wetland, to replace kind for kind the areas that would
be eliminated by the development.-permitted under the plan. The.:.
location of these areas would also be specified in the Restoration
Plan.
O A Linear Park on the Huntington Beach Mesa, 57 acres of which is
within the Planning Area.
° A 75 acre Marina with associated commercial. In Alternative 1 the
marina would be located approximately at the seaward, terminus of the
present Warner-Garfield Flood Channel (Exhibit 1(a). In Alternative
2 it would be located in the low lying portion of the Bolsa Chica Mesa
as shown in Exhibit 1 (b). Th6 modifications specify certain key
public boating and visitor serving facilities that the marina complex
would have to include. The land allocation to these uses is
consistent with the Analysis of Demand found in the County's
Supplementary Information (Enclosures B. pg. C-5).
° A .navigable connection to Huntington Harbor. The allocation of land
to this connection is sufficient to provide a workable channel as
described in the supplementary information provided by the
Conservancy.
° The balance of the area would be taken up in residential uses of
varying density, the necessary buffers for the wetlands and ESH areas,
roads and other public facilities.
The , principal difference between Alternative 1 of the modified Land Use
Plan and Alternative 2 is that the ocean entrance in Alternative 1 is
navigable, whereas the entrance in Alternative 2 ,is not. -Alternative 2
would also provide for the designation of a portion of the Metropolitan
Water District Lands as Coastal Dependent Industry/wetland.
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Modification A 3 -is necessary because the policies suggested in these
mo i ications, operate in an integrated and interdependent fashion. The LUP
contains a myriad of policies subject to various interpretations. Rather than
belabor each of these, and each of its possible interpretations, the
modifications are established as controlling. It also should be noted that the
Denial of the Land Use Plan denied the entire policy sections rather than
individual policies. The Denial Findings are hereby incorporated in full.
Modification. .A (4) : .Land.Allocation. Policy
As indicated in the Commission's findings of Substantial Issue (April 8,
1982) , and Denial (Nov. 15 1984) the Department of Fish and Game has
completed wetland studies of Bolsa Chica. In its April 16, 1982 submittal
to the Commission the Department found that there are 686 acres of
degraded, but viably functioning wetland and 384 acres of restorable
historic wetland in the Bolsa Chica study .area as defined in -that report..,,.-
Excluding the area contained in the State Ecological Reserve these figures
are 616 and 384 respectively. The Department further found pursuant to
Section 30411 that while the 616 acres of existing wetlands are not ;
severely degraded, if one considers the degraded wetland ecosystem as a
whole, including the 384 acres of restorable former wetlands, that this
comprises a 1,000 acre severely degraded wetland system which is in need of
major restoration. The Commission notes that portions of the Department's
study area are located outside of the jurisdiction of the County of Orange,
and therefore the acreage figures within the Bolsa Chica LUP area differ
slightly from the above. However, in its substantial issue determination,
the Commission found that the Bolsa, Chica Area required action as an
integrated unit. Consequently the Planning Area discussed herein includes
the entire wetland system identified by the Department.
Exhibit 4 summarizes the Department's findings on the breakdown of the
lands within the lowlands. Generally, only those uses specified in Section
30233 of the Coastal Act are allowed within a wetland. However, since Bolsa
Chica constitutes a 1000 acre "severely degraded wetland system in need of
major restoration", other uses can be considered pursuant to section 30411.
The table prepared by the Department of Fish and Game (Exhibit 5)
illustrates that were it not for this finding little to no urban
development would be allowed. Section 30411 specifically allows
construction of a boating facility on 25% of a severely degraded wetland if
. the remaining 75% is restored. Section' 30411 (b)(3) also requires that
consideration be iven to "whether there are other feasible ways to achieve
such [restoration values". In Section VIII. D. of the wetland guidelines,
the Commission interpreted this language to allow consideration of uses
other than boating facilities if such uses are "other, more feasible ways
to achieve such values". ,
It Appears that residential development on remedial fill would be one such
"other feasible way to achieve such values", and may be allowed under
Section 30233 and 30411 if such development could also be found to be the
least environmentally damaging alternative. The Commission- finds that a
Land Use Plan and accompanying policies to protect resources as set out in
these suggested modifications in their entirety meets these requirements.
The obligation of such development under the Act is to assure that the wetlands
in fact are restored as a result. The modifications deal with this
obligation in two regards; the amount of wetlands, and the adequacy of
their restoration.
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The debate over how much wetland should be restored at ffolsa- Chica has been
intense. As noted above the Department of Fish and Game has determined the
area to be a wetland system. _ During the Habitat Conservation Plan process,
the Department of Fish and Game re-examined their determination of the
amount -of wetland that is required to be restored pursuant to PRC 30411.
In the "Department of Fish and Game Statement on State Coastal Conservancy
Habitat. Conservation Plan (HCP) for Bolsa Chica" (see Enclosure C, Appendix
A), the Department states:
We...have determined that all of the 268 acres of wetlands in the
state-owned Ecological Reserve may be considered as part of the
severely degraded wetland system of Bolsa Chica in conjunction with
the other areas of the system. Also, we have elected to delete 50
acres of feasibi.ly restorable wetlands from the wetland acreage
computation because these acres were also found to be Environmentally
Sensitive Habitat (ESH) in accordance with Section 30240. Therefore,
these acres must be included for protection pursuant to this
section of the Coastal Act.
Thus, in accordance with these amended provisions, the Department
finds that a total of 913.5 acres of the severely degraded wetland
system must be restored in the Bolsa Chica area in order to allow
development to proceed in accordance with Section 30411 of the Coastal
Act. The principle parities to the SB 429 effort agreed to' a total of
915 wetland acres. In addition, 865 of Environmentally Sensitive
Habitat must also be protected within the study area.
This determination represents a compromise to a long standing dispute. The
Commission concurs in this compromise.
B. WETLANDS.AND. ENVIRONMENTALLY.SENSITIVE.NABITAT.RESTORATION
The modifications for wetland and ESH restoration provide for the
development of a specific Restoration Plan for the design, construction,
operation and maintenance of the enhancement of habitat as Bolsa. The
Restoration Plan is especially necessary because of the difficult site
conditions of the areas designated for restoration (in the midst of an
active oil field, in the flood control channel and mixing basin, and in an
artificially created canyon perched at the upper ends of tidal influence).
Since urban development in the wetland system is only permitted because it
is the means of restoring the wetland, those who propose development are
required by the modifications to pay for all costs associated with
restoration. The acreage of wetland to be restored ,would ultimately be 915
acres as discussed above and in the Denial Findings. Additionally the
modifications require that 86 acres of other environmentally sensitive
habitat areas also be recreated and/or restored in site. In order to
assure full functioning of the wetlands and other habitats, adequate
buffers are required to protect these sensitive areas from the impacts of
the intense urban uses planned adjacent to them.
County Policies 3 and 4, (p III-20 and 21) provide that a marsh
restoration, operation and maintenance plan shall be designed by- a
Technical Advisory Committee and developed in accordance with the Bolsa
Chica Public Facilities Management and Finance Plan, Phase II. Policy 6,
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(p III 21) provides for the project to be phased so that marsh restoration
proceeds along with other project developments in the lowland.
Section 30231 of the Coastal Act provides that the biological productivity
And quality of wetlands be maintained and where feasible, restored.
Section 30233 provides that diking and filling in wetlands shall maintain
or enhance the functional capacity of the wetland. It is necessary to
modify the County's policy in order to insure that allowable* fill and
development on. the fill does not occur without the restoration required
under Section 30411. The suggested modifications provide that there be no
loss in wetland or environmentally sensitive habitat at any time. This
modification insures that no fill may be placed prior to the restoration of
acreage which would offset or mitigate the lost wetland acreage and, as
noted in the findings for denial, achieves consistency with Sections .30231
and 30233 regarding maintenance of biological productivity and functional
wetland capacity.
Modification 7: Policy 10 (p. III-21) provides that buffer areas shall be
establish a to protect wildlife habitat. Section 30231 of the Coastal Act
provides for the maintenance of natural vegetation buffer areas to protect
riparian habitats while Section 30240(6) provides for development in areas
adjacent to environmentally sensitive habitat ares to be sited and designed
to prevent impacts which would significantly degrade such areas. As noted
in the findings for denial , (Commission Permit Historyi Exhibit B, in
Appeal No. 349-79, Huntington Beach Co., Seacliff IV), a residential
project on the Huntington Beach bluffs was conditioned to provide a
continuous buffer area i.n excess of 100 meters between the project and the
Bolsa Chica wetland. In the Ballona LUP, a comparable situation to Bolsa,
the Commission provided for: 100 foot buffers with an additional 50 foot
structural setback.This was necessary in order to find the project
consistent with Sections 30231 and 30240 of the Coastal Act.
In addition, the scenic and visual qualities of the marsh should not be
walled off from public enjoyment by residential development. Section 30251
of the Act provides that such qualities be protected as a public resource
and that development shall be sited to protect views to and along scenic
coastal areas, (Catalina Island is immediately adjacent to Bolsa Chica and
is often visible). Given the above constraints, the placement of a 100'
buffer next to the wetland, separated by .a fence, with a continuous heavily
vegetated lateral pedestrian path and bike path paralleling the shoreline
will afford the necessary resource protection since intrusion from noise
and lights would be minimized by the vegetation. Residential development
would be placed outside the buffer zone, thus achieving consistency with
Sections 30231 and 30240 of the Act.
C. PUBLIC.ACCESS
Section 30210 of the Coastal Act provides that maximum. access shall be
provided for all the people consistent with public safety . needs and the
need to protect public rights, rights of property owners and natural
resource areas from overuse.
Section 30211. of the Coastal Act requires that new development not inter-
fere with the public's right of access to the sea. Section 30212(a)
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provides that public access from the nearest- public roadway to the shore-
line and along the coast shall be provided in new development projects
except where it is (1) inconsistent with public safety or the protection of
fragile coastal resources or (2) adequate access -exists.. nearby. Section
30252 of the Coastal Act provides for the provision of transit with pew
development.
Modifications 1 and 2 call for access along through the development all
along the marsh a ge, the ocean shoreline and the marina (except where,
there are valid safety concerns due to dangerous machinery). In the inland
waterway system, access would be provided along the immediate waterfront in
the high density areas, and at recreation and access nodes placed throughout
the developed area. The nodes in the low and medium density areas would be
linked by a continuous trail system along the roads behind the waterfront
homes. A Linear Park corridor along any cross-gap connector would link the
whole system to Regional Park. The Commission finds this access system_:.
consistent with section 30212(a). (See Exhibit 2)
This policy modification must also be delineated on the Coastal Access ,
Concept Plan, Exhibit 35, and all exhibits derived therefrom in order to
demonstrate consistency with LCP Regulation 00042, Public Access Component
which calls for the delineation of specific geographic areas proposed for
direct physical access to coastal water areas.
Policy 14 (p III47), provides that alternative forms of transportation
with an emphasis on public forms, shall 6e encouraged. The Commission is
not modifying this policy with understanding that new development will
maintain and enhance access to the coast by providing adequate parking
facilities or providing a substitute means of serving the development with
public transportation. Modification G. 1.(c)(1) to LUP Policy 10 (Ocean
Entrance) provides that the ocean entrance plan fully protect existing
swimming, surfing and beach enjoyment opportunities. This modification
requires that any beach parking that might be eliminated by an ocean
entrance will be replaced or mitigated by public transportation such as
park-and-ride shuttles to the beach area. Testimony by the State
Department of Parks and Recreation at the June 18, 1982 public hearing
indicated that the Bolsa Chica State Beach currently serves over 3,000,000
people annually with the beach operating at approximately 25% under
capacity due to lack of adequate parking..
Modification 8: PCH. Reroute and Cross Gap
This modification provides policies to control the location of PCH and the
cross gap connector. This issue was the subject of intense debate through
the HCP process. The "mini-reroute" solution for the location of PCH with
Alternative 1 was one of the more creative ideas to emerge from this
proe,ess. The modification and Land Use Plan map provide for a corridor in
which the cross gap connector would be located. This corridor, as shown in
Exhibit 1 extends from 200 feet to 950 feet away from the property line of
the nearest houses. The Commission leaves the decision of where precisely
to locate the cross gap road and any connection to the marina, in local
hands. The proposal modification are consistent with the resolution on the
subject submitted by the City of Huntington Beach, which has Bolsa Chica .
within its sphere of influence (Exhibit 6).
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D. RECREATION.AND.VISITOR-SERVING. FACILITIES.AND. RECREATIONAL•BOATING
Section 30213 requires provision of lower cost visitor-serving facilities.
-- - - Section 30222 lends priority to visitor-serving commercial recreation on
suitable, private lands while Section 30223 provides for the reservation ,of
upland recreational support areas. Section 30224 provides, in part, that
recreational boating shall be encouraged by developing dry storage areas
increasing public launching facilities and providing for new boating
facilities in areas dredged from dry land.
Modification 1: The supplementary information submitted by the County
confirms the market demand for 550 overnight units and visitor serving
boating facilities. This modification addresses the needs confirmed in
those studies.
Modification D-2: provides that there be no net loss of beach area as a
resu t of t e ocean entrance. As the findings for denial indicate, the
three-mile long Bolsa Chica State Beach serves approximately 2,000,000
visitors per year. Testimony by the State Department of Parks and -
Recreation at the June 18, 1982 public hearing increased this estimate to
3,000,000 visitors and indicated that the Beach is . operating at
approximately 25 percent under capacity due to lack of adequate parking.
As the findings for denial further indicate, Section 30211 of the Coastal
Act provides that development shall not interfere with the public's right
of access to the sea where acquired through use or legislative—
authorization which are both applicable in this case.
A non-navigable, rip-rapped ocean entrance could much more easily meet the
intent of Section 30211 than, a navigable entrance since the channel would
be much narrower, and would be shallow enough to encourage wading and
swimming during much of the year. Indeed, the shallow water and offshore
bar might well enhance the recreational value of the beach for children and
swimmers. The Modification. G-2 for the Ocean Entrance more thoroughly
addresses this issue.
F. HAZARDS
Section 30108.5 of the Coastal .Act defines land use plan to mean the
relevant portion of a local government's General Plan which is
sufficiently detailed to indicate the kinds, location, and intensity of
land uses, the applicable development policies and, where necessary, a list
of implementing actions. Section 30253 of the Coastal Act provides that
new development shall minimize risk to life and property in areas of high
geologic hazard.
The County has completed additional geotechnical studies on the questions
raised in the substantial issue determination. Those studies are currently
being reviewed by the California Division of Mines and Geology.
The modifications provide that the criteria established by the Division
for mitigation of hazard be incorporated in specific studies prior to
Implementation. Both alternatives of the Plan generally avoid placing
structures in. the fault zone, allocating that area to boat channels -or
wildlife habitat.
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As noted in the findings for denial , the economic implications of
geotechnical hazards are of great concern as well , not only because.
substantial public investment or liability may be involved but also
because the fundamental wetland restoration policy question in Bolsa Chica
rests on the issue of. feasibility. Under the Coastal Act, development-in
wetlands is only allowed if there is no feasible, less environmentally
damaging alternative (30233a), and where the remainder of the wetland is
restored (30233(a)(3) and 30411). Although hazard mitigation may be
possible through such techniques as soil densification, addition of
overburden, tying back bulkhead sheet pilings, unit foundation pilings, and
mat foundations in addition to structural setbacks, the project's economic
feasibility may also be severely undermined or altered. This potential
dramatic change in the economic feasibility of the project is a risk the
proponents of development have chosen to take. It cannot be permitted to
affect the amount required of any development proposed in, the lowland
wetland system or ESH areas. The Commission finds that the detailed.:
analysis of feasibility of hazard mitigation can be deferred only because -- -
the Modification Sections A and B in their entirety provide adequate
safeguards that the restoration required by the Act will be accomplished.
F. SCENIC AND. VISUAL- RESOURCES
Section. 30251 of the Coastal Act requires protection and enhancement of
visual qualities to and along coastal areas and where feasible, 'is visually
degraded areas. Section 30253 provides :that new development shall minimize
risk to life and property in areas of high geologic hazard and shall not
require the construction of protective devices that would substantially
alter the natural landforms along bluffs.
Modification G (LUP Policy 1, p. III-14) provides that the character of
the Bolsa ica and Huntington Mesa bluffs .shall be maintained and
enhanced. This policy does not provide an adequate level of specificity to
protect the panoramic view of coastal beaches, wetlands, and bluffs.
As noted in the findings for denial , structural setbacks of 100 meters have
been required for the Seacliff IV development on the Huntington Beach Mesa
in prior Commission permit action. Structural setbacks varying from 25 to
100 feet depending on bluff heights (10 to 50 feet) are adequate for the
Bolsa Chica Land Use Plan to provide.. protection given the relatively
degraded state of the entire bluff system and the desirability of
transferring as much development as possible out the lowland to the upland
Bolsa Chica Mesa. The State Department of Fish and Game Scenic Overlook
requires special preservation and enhancement due to its historically
strategic viewing location, (the former "Gun Club" site) as does the inland
side of Outer Bolsa Bay due to its immediate visdhl proximity to Pacific
Coast Highway and the Bay itself. Thus, policies providing mechanisms such
as structural setbacks and revegetation are suggested modifications
necessary to achieve consistency with Sections 30251 and 30253 of the
Coastal Act.
Section 30251 also provides for protection of scenic and visual qualities
to and along the ocean and scenic coastal areas. As noted in' the findings
for denial , the Bolsa Chica segment is one of the last portions of the .
Orange County coastline which possesses a strong visual connection between
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the ocean and wetland environments. Any bridges constructed over a new
navigable, non-navigable or other ocean entrance system must preserve that
visual character as much as possible.
G. PUBLIC•WORKS
Section 30108.5 of the Coastal Act provides that Land Use Plans must be
sufficiently detailed to indicate the kinds, location and intensity of land
uses, the applicable resource protection and development policies and,
where necessary, at listing of implementing actions.
Section 30231 of the Coastal Act provides that the biological productivity
and the quality of wetlands appropriate to maintain optimum populations of
marine organisms and the the protection of human health shall be maintained
and where feasible, restored. through, among other means, minimizing adverse
effects of wastewater discharges and entrainment, controlling runoff,.::
preventing depletion of groundwater supplies and substantial interference
with surface water flow encouraging waste water reclamation and maintaining
natural vegetation buffer areas that protect riparian habitats.
Section 30233(a) of the Coastal Act provides that the diking, filling, of
dredging of wetlands shall be permitted in accordance with other applicable
provisions of this division, where there is no feasible less environmental-
ly damaging alternatives.
Section 30260 of the Coastal Act provides that coastal-dependent industrial
facilities such as seawater desalting facilities shall be encouraged to
locate within existing sites such as that currently owned by the.Metropoli-
tan Water District (MWD) , providing that adverse environmental effects are
mitigated to the maximum extent feasible.
In the County plan as submitted, the Public Works policies are among the
most important because they allow uses within wetlands that have been
identified in the Commission's findings for denials as raising major and
fundamental issues. The Section of policies in the County plan allows
public utilities, navigable channels, flood control facilities, and a new
navigable ocean entrance. Under the proposed policies, many decisions
regarding the location of facilities would be deferred until later stages
of planning. Finally, land owned by the Metropolitan Water District that
, may be needed for public utility purposes has been designated for a marina,
despite the objections of MWO. These problems have led to the specific
modifications which are now analyzed.
Modification G-1 provides that a specific plan for utilities shall be
submitted or review as part of Phase III. As the .findings for denial
indicate, neither plans nor specific policies for the size and location of
major utility System reaches such as sewers are indicated in the LUP. Such
a denial of fundamental decisions is inconsistent with Section 30108.5 of
the Coastal Act. The modification to require a policy controlling the
location of major utilities is therefore necessary to achieve consistency
with Section 30108.5 of the Act. This policy must indicate that reaches
shall not be planned through wetlands or other environmentally sensitive
habitat areas. in order to achieve consistency with Section 30233(a) which ,
permits such activities only where there is no feasible less
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environmentally damaging alternative. Since it is feasible .to place utili-
ties, such as sewers, below proposed streets, no dredging or fil-ling of
wetlands beyond the allowable would appear necessary.
Ocean Entrance
Modification G-2 provides specific policies for the design of any ocean
entrance and nels to Huntington Harbor and the visitor-serving marina
complex. A non-navigable entrance would significantly reduce the problems
involved in dealing with sand transport and Shoreline processes. The
findings of consistency for an ocean entrance are extensively reviewed in
Section 1 (Land Use) above and in the denial findings. Those findings are
incorporated here.
Huntington.Harbor Connection
The question of a navigable connection with Huntington Harbor was another
subject of great debate during the HCP process. Both alternatives of the
Land Use Plan proposed in the modifications contain an enhanced water ,
quality connection. Alternative 1 provides for a connection to the new
navigable entrance. The land allocated to this connection is ,outside the
existing outer Bolsa Bay wetland, except for a small portion directly at
the entrance to Huntington Harbor, and is wide enough to accommodate a
120-foot channel and a buffer to protect the existing wetlands of Outher
Bolsa. The policy language of the modification is derived from the HCP
supplemental information submitted by the Conservancy. It reflects their
conclusion on financing that: '
no sin le mechanism for funding the connection (estimated at $18
millio'I was advanced (although a range were discussed in County
financial documents (Draft Report on HCP issues, p 15 - see Enclosure
D).
It may in fact be concluded that when the costs, and financing impacts
of such a connection are fully identified, the connection will appear less
attractive. The Modification, however, keeps the door open to an appropriately
designed connection.
Modification -G-4 provides that the County of Orange cooperate with the
etropo itan ater District of Southern California, to ensure compatibility
between MWD's prospective transmission corridor uses and to find an
alternative site.
Section 30260 of the Coastal Act provides that coastal-dependent industrial
facilities such as seawater desalting facilities 'shall be encouraged to
locate within existing sites such as that currently owned by the The
Metropolitan Water District of Southern California (MWD), providing that
adverse environmental effects are mitigated to the maximum extend feasible.
As noted in the findings for denial , MWD has indicated that its
"Transmission Corridor" parcel of land within the Land Use Plan area may be
utilized to connect seawater intake facilities located on an offshore
Tidelands Grant to facilities located on its nearby "switchyard" parcel of
land (outside of the Land Use Plan area in the City of Huntington Beach),
Because portions of the MWD "transmission corridor" parcel are wetlands or
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environmentally sensitive habitat, adverse environmental impacts would have
to be mitigated. If that is done, some uses on the MWD Parcel would be
compatible with resource protection and enhancement. Alternative 2 limits
MWD's options less than Alternative 1. MWD's wetlands obligation is met by
locating. on its property a portion of a sedimentation/mixing basin designed
to provide wetland habitat consistent with the Restoration Plan.
Modification G-5 provides that prior to any land division a specific Public
Facilities Management and Financing Plan (MAFP) will be prepared to provide
secure .contractural arrangements for the phasing, funding, constructing,
operation and maintenance for key project elements. These include the
identification of all facilities, services and land area involved and all
other public project and marina capital projects; costs and preliminary
funding for all facilities, services, land and public project and marina
capital projects; a plan for funding the costs identified in the Phase I
MAFP, including identifying specific .sources, methods and reasonable....-,-
possibilities of securing such amounts. This Plan essentially provides
development agreement. In the absence of a demonstration of feasibility
for the project elements at the Land Use Plan stage as required by sections
30108.5, 30233, and 30411 as discussed above, the specific agreements to
phasing and assurances of implementation of plan policies at the
implementation stage.
Modifications G - 6, 7 and 8 are necessary for consistency 'with other
modifications.
H. ENERGY
Section 30260 of the Coastal .Act provides that where new or expanded energy
facilities are proposed in wetlands, maximum feasible mitigation shall be
provided to minimize adverse environmental effects. Section 30233 of the
Act permits energy and coastal-dependent industrial facilities to be sited
in wetlands only if this is the feasible, least environmentally damaging
alternative, where feasible mitigation measures such as consolidation of
facilities and site restoration upon abandonment are provided to minimize
adverse environmental effects and the functional capacity of the wetland is
maintained or enhanced. Section 30231 of the Coastal Act provides that the
biological productivity and the quality of wetlands appropriate to maintain
optimum populations of marine organisms. and for the protection of human
health shall be maintained and where feasible, restored through, among
other means, minimizing adverse effects of wastewater discharges and
entrainment, controlling runoff, preventing depletion of ground water
supplies and substantial interference with surface water flow, encouraging
wastewater reclamation and maintaining natural vegetation, and buffer areas
that protect riparian habitats. '
Modifications H- -- 1- and 2 provide for planning to facilitate consolidation
of facilities an site restoration upon abandonment. Given the extremely
high cost of oil and gas well consolidation, the LUP as modified would
provide for the less costly solution of berming and access road
consolidation combined with redistribution of water sources via culverts.
i"
The Restoration Plan proposed in these modifications would specify measures
that would enable the coastal dependent industrial land use of- energy
production to co-exist with the preservation, restoration and enhancement
of the wetland use.
It may in fact prove possible that the water levels in the cells between
the roads could be limited to -1.5 feet MS1 consistent with restoration
needs. However, as noted in the findings for substantial issue on the HCP,
it is inappropriate to so limit the Restoration Plan at this time. Any
adverse effects on the oil field operator could be part of the negotiations
between the proponents of development and Aminoilduring the development of
the Restoration Plan.
I. ARCHAEOLOGY
Section 30244 of the Coastal Act establishes a mandate to protect archae
ological resources as identified by the State Historic Preservation Officer • • -
and mitigate the impacts of development upon them. As noted in the find-
ings for denial , the Commission adopted Archaeological Guidelines on
December 16, 1981 establishing priorities for mitigation measures and
placed prohibition of development over such resources at the top of the
order of preference. The Guidelines adopted also call for a Peer Review
Statement including input from at least three qualified archaeologists and
consultation with affected Native Americans. Section -30108.5 of the
Coastal Act defines Land Use Plan to be an element sufficiently detailed to
indicate the kinds, location, and intensity 'of land use, the applicable
resource protection and development policies and, where necessary, a
listing of implementing actions.
The proposed modifications incorporate the provisions of the Guidelines
pertaining to discovery of any known sites, and the specific provisions
of the Commission approved permit for work at ORA-83.
During the joint County/Commission staff review of ORA-82 which was also
noted in the denial findings, an error in the alignment of the Coastal Zone
boundary as shown in the County Plan was noted. Since the Coastal Zone
runs along the Huntington Beach Bluffs and not along Edwards Street as
shown in the County's Plan, ORA-82 does not lie within the Coastal Zone and
cannot be the subject of suggested modificcations for this Land Use Plan.
ALTERNATIVE LAND USE PLAN Bolsa Chica
Ilunlinglon Beach Central Park
ILLUSTRATION A Navigable Entrance
Jf
3600 A°/a •l3asin - .�. i-:,' .1; "if; ?.
wr to to no COASTAL ZONE BDY. _. .-3
-•-•-�-++- LCP SEGMENT BOY. \ --- RO CO
f
Cross Gap
03
•__ -_�' �=•7�"...'�.. •:`•:-..-i ;.,` .;�� N
. ty
-
•�_
Riparian Area ;;; .`: a► _:,:.:� :,,1.� °,
i
JL
Huntington Harbour . : A:-,,.. �. '' :•... .:_.: .,� _ '.�.:
Huntington Harbour � :=r.y-'• '• _ •• -• ___ .. - -
Connection _ �:_' _- - ;.^.x: .: _- ':; :=.:� • ._ ' �.��� Pam.?�
v
.A
.... n..:. win.,. '�•.•\ _ _ - -
- - L w ar
•.bp�r.:�olsa�•�iy _..- _ � = 4-"• aclflC• Coast119h
• Park 1301sa Chico State Park -
BOISa Chico State
EXHIBIT N0. 1A LEGEND
Wetland Connection LOW DENSITY RESIDENTIAL MARIIIA COMMERCIAL
• Channel
MED. DENSITY RESIDENTIAL MARS11/0PEN SPACE
s ., 1111314 'DENSITY RESIDENTIAL E , LINEAR PARK/OPEN SPAC
ALTERNATIVE LAND USE PLAN Bolsa Chica
r�
Nunlinglon Beach Central Park
ILLUSTRATION 2 a Non-Navigable Entrance ��►^♦�
ID
Vj
i G
0 3110 °4s
bx ."-'
41
O
mw wo m r COASTAL ZONE BDY.
��•- LCP SEGMENT BDY. -
Corr1 °i
- Crosg GOPSr
yx. .
_
'otrtop�t•l3ti. lire- " s - :- '. �•�:¢� . :�
Huntington Harbour
-seacIlIt IV
JL
-.
n' _-w�'.. ::.a. . :'j. _�,.Q.._1 1.. ` � _ _.w_w--_w_+/t:s..—t.•::A.•-w"�-`•': w-- ,� r"
•. -•� •- -• '.--. . .- ��'-:w - _ -F�J: � ':_--% p- hwa -.•• �' _ i� yam.
Bolsa Chica State Park Bolsa Chico Stale Pork
EXHIBIT NO. 113 LEGEND
LOW DENSITY RESIDENTIAL �IIARINA COIIPIERCIAL
i1 i`. NEO. DENSITY RESIDENTIAL MARSI1/0PEtl SPACE
N :t' * .
IIIGII DENSITY RESIDENTIAL i LINEAR PARK/DPUI SPACI
ACCESS PLAN Bolsa Chica Ilunlinglon Denc,l Cenlrn, Park
♦ Dike/Pedestrian Trail ���1^�1
.• Equestrian trail Linear Park /Cross Gap Corridor cad �• "Edwards Thumb"
(See full-size map for detail) J +
.��
�C] Access Node41
Q�� •;• .
A .. . ..A• . - '
E T �c� r \ 9 ; • :,j .x'+ ii_� i i ■ N i,w 'Y` 7
No gown aw COASTAL ZONE BDY. :: c. J 1•. _ "'-` '
o- LCP SEGMENT DDY. -:.. y 3, .,1 �� .1r •It 1 C)
10
......:.... . . .
Huntington Harbourme
. ♦ \�.. _ }..... "., _•-_ — ___ AA '- �? eaclif( 11
its _ -• ..: —
is
_.. „". _ ._._ ',';.. ^' = f�acUlc CoesT•111 hwa •.•.....,., .. � !:,f4:.7`•� -_
♦ _-�;�.. - .. •.,:F �- - ■�iGa�w.iiwGiwi yin.■..................:...:i...=---
:�i i i i ■ Bolsa CI lica State Park _
agopark - ---�-� --- ----------M---�---~
Bolsa Chk;a Slate w _
�. ..._ .........
EXHIBIT NO. LEGEND
—PP6103AT19H tier ® LOW DENSITY RESIDENTIAL MARINA COHMERCIAL
MED. DENSITY RESIDENTIAL NlIRSII/OPEN SPACE
HIGH DENSITY RESIDENTIAL. ;: f�l` LINEAR PARK/OPEN SPAC
3. Criteria for Establishiac Buffer Areas
A buffer area provides essential open space between the development-and the
environmentally sensitive habitat area. The evistance of this open space
ensures that the ty_x and scale of development proposed will not sigm;'icantly
degrade the habitat area (as required by Section 30240). -Therefore, development
allowed in a buffer area is Limited to access paths, fences necessary im to protect
the habitat area, and s4m4ar uses which have either beneficial effects or at
least no siccificant adverse effects on the enviz-onmentally sensitive habitat
area. A buff er -area is not itseL` a par•_ of the envi=-oamentaly secs it ive
habitat area, but a "buffer" or "screen" that protects the habitat area from
adverze enviroaaental impacts caused by the development.
A bu area should be estabLshed :or each development adjacent to
environmentally sensitive habitat areas based on the standards enumerated below.
'^he width of a butter area will vary dependiag.upon the analysis. The butter
area should be a -4�— of 100 feet for small projects on !arts (such
as one single family home or one cc=ercial office building) unless the
applicant can demonstrate that 100 feet is unnecessary to protect the resources
of the habitat area. ' the project involves substantial i=provements or
Inc--eased huaan impacts, such .as a subdivision, a march wider buffer area should
be recuiraed. For this reason the guid.eLlne does not recc=end a u:i_orm width.
The appropriate width will vary with the analysis based upon the stands:s.
For a wetland, the buffer area should be measured from the laaeWard edge of
the wetland (apoerd;lx 0) . For a stream or river, the buffer area should x
measured landward from the landward edge of riparian vesetation or from .the top
edge of the bank (e.g. , in eh-'=-1 *wed s'�r eams). Maps and supplemea—i-I
iaf`.ormation may be recurred to deta ;ne Wiese bci:nca:ies. Standards for
dete=J=4ng the appropriate width of the buffer area are as follows:
1. Eiolocical si=lti cance of adjacent Lands. lands adjacent to a
wetland, stream, or riparian habitat area vary in the c'.eg:ee to •.sn
they are functionally related to these habitat areas. That is,
functional relationships may eac.st if species associated with such
areas spend a significant poron of their Le cycle on adjacent
lands. The degree of sign=ficanes wnid depend upon the hahi:at
req i.r ements of the species in he habitat a_-ea (e.g. , nesting,
`.eedisg, breeding or resting) . This determination requires the
expertise of an ecologist, wildlife Biologist, orytholog=st or
botanist who is familiar With the particular type of. habitat iavoLved.
Where a sigai.ficint fuactioaal. relationship exists, the -land
supporting this relationship should also be considered to be part of
the euvirortmeatally sensitive habitat area, and the buffer area should
b =e measured f the edge of these lands and be- sufficiently wide to
ptoter these faactional relationships. ',.here no sip ificant
funetioaal reLationshioa exist, the buffer should be extended farm the
edge of the wecland, st_esm or rizariaa habitat ( for example) whic!2 is
adjacent to the proposed develooment (as ooposed to the adjacent area
which is significantly related ec Logica.Lly).
Z. Sensitivity of species to disturbance. The width. of the. buffer
are= would be based, is part, on the distance necessary to ensure
that the most sensitive species_ of plants and animals will Act- be
disturbed significantly by the peimittted development. Such a
determination should be based on the following:
a. Nesting,. feeding, breeding, resting or other habitat
requirements of both resident and migratory fish and wildlife
species.
b.. Aa assessment of the short-tee and Ion
g=cer= adaotibility of
various species.ta human disturbance.'
3.. Susceptibility of parcel to erosion. The widt:z of the buffer
area should be based, 4a pa-., on an assessment of the slope, "sails,
impervious surface coverage, runoff characte^slits, and veg+!ta::ve
cover of the parcel and to what degree the development will change
the potential for erosion. A sufficient buffer to allow for the
interception, of any additional material eroded as. a result of the
proposed development should be. provided.
4. Use of natural topog:apaic `eatures to locate development. Rills
and blu==s adjacent to environmentally sensitive habitat areas should
be.used, where feasible, to buffer habitat. areas. Where otherwise
pet fitted, development. should be located on the sides of hills away
from. environmentally sensitive habitat"areas: Similarly, blur: faces.
should not be developed, but should be included in the bu_L°er area..
5. Use- of existing- cultural features to locate buffer zones.
Cultural :eatures, (e.g., roads and a;-ices) snould be used, where.
feasible, to buffer habitat areas. Where feasible, development
should. be located on the side- of" roads, dikes, i.=igatioa Canals,
food control channels, etc. , away fi-.= the environmentally sensitive
habitat area.
6. Lot canfieuration and location of existIncz develo=ent. where an
existing subdivision or other. development is largely built-out and
the buildings are a uniform distance from a habitat area, at least
that same distance will be required as a bu�!-er area for any new
development permitted. However, if that distance is less than
100 feet, additional mitigation meant:,:es (e.g. , planting of native
vegetation which grows locally) should be provided to ensue
additional protection. Where development is proposed is an area
which is largely undeveloped, the widest and most protective buffer
area feasible should be refired.
7. Tyne and scale of development pr000sed. The type and scale of
the proposed development will, to a large degree, detex-mine the s'"-e
of the buffer area necessary to protect the en-ri=onaeat.ally sessi rive
habitat area. For example, due to domestic pets, human use and
vandalism, residential developments may not be as commatible as lion-
industrial developmen_s adjacent to wetlands, and zsav ;—.erefore
require wader buffer areas. &cwever, such"evaLiatioas should be made
on a case-Ly--case basis depending upon the resources involved, and
the type and density of development on adjacent lands.
• ��� t err �{.
• TABLE I
Other Vacant Property Within
Class _ — State Ecologit the Study Area as Shorn on
the Reserve the -Iccomnan in(i- ,l Total
I [. Historic. Wetland 276 acres 1 ,016 acres 1 ,292 acres
A. lion-degraded Wetland 166 acres 0 acres 166 acres
B. Degraded but viably functioning 70 acres 616 acres
wetland - major restoration not 686 acres
required..
documented high and 70 acres
at least at least
moderate habitat value to 430 acres 550 acres
wetland-associated avifauna.
2. Providing low value for wetland- 0 acres at most at most
associated avifauna and areas not 136 acres 13E acres
yet thoroughly evaluated.
C. Severely degraded historic wetlands no 40 acres 400 acres 4"O acres
longer viably functioning as wetlands,
and major restoration required.
a�. 1 . Below 5 ft contour 32 acres 384 acres 416 acres
2. Above 5 ft contour- 8 acres 16 acres 24 acres
II . Historic Upland 13 acres 19 acres 32 acres
s
MEND
TIOIl0A1f YArf�N Ij��: l••`;I��i;,/:�• I. .'t•, •r�� �Jp.
L I°RACKI!M VAR114 .��� ••• f •,• •� �,f. ./t ,_1 � - CI ',�• .
—• 1 r1011•TfOAI IRMA 600110 �•. '�i�'�'•" r •rI' •a•`, , �• 1' ,• p'1!'r\%�� t/
t •1Cltl[w [ It L •;.• y :� -..'-t.•A.i• , .•I. •r.`.. ,,�. -1 ,• ,-%t) _ � f 1
It
UNVCV-CTA►10 ILA10 �, . •� ~ 1I�Il ::Ci'li •1 ',�../• ,ar•rr'• .n, .1. '`�•" �.% • ter�A \• •a.
• 1017TUR000 � - ,•• �•• .�'. .��•;•: ":1 'r' .�� 7,-,.,', •..:•:' :��:�...1• _ � \-•�/r•'� \�1': �7i�-••�� •1,•'/
1--J '�� � '' � . ,'i.,,'.p ' :• !i ; . • •.' ..••1• i , f.• �_�• •r' �C9/�°"�\�1!fr ��.•c\ "�;;r 1f�'r � �1'.•1�:• • 'f. `a-� ., t ..•�:'.•./: •� .,r,•.f •a•� .1 I r ° ' r I r /' (J' \�C , ° 1 f•�•1 !r 1:r _ r r;•
• :. �,�,_...:..`• ;. !: 'iti%ri• `i � •, -`� r elf 1 �'�'��i�+c��.�\� \,/„t' °, `` �\ �l_� \o�'l��'r��• \(
WA 1• \ N.-
�� t ,a • f~ �` `\ '�..'•�: �+ 1•.,.� 7 .-,�'[ lid y'�!':f'1
^�� a.' .I _. ` //,/ , ,J 1 -�f `'• A`\�� :/�it 7 ° •,� [ . �. t. Ct.
� •��`� \ ��//.� �'[«,/. /. � � ; ,l' _ r a:•'\•_._ ,]_ `.- •`` •_�;' f•'•1 ,�i�/�y-�--_ ,�,itJ�' , �:i1N/� • :Wyly,• :_ .
,,� �.''/./1 j •, /• 1,., /'�:� ;r I._>'. •��� �•-�'\ 1 `f.'�-,,� :�.J •i'�I ./"' - '�•e '�• 1't t'�•�1:�--� �j 1J ,\r,✓�', .••.: r•
\ •/ •.• _ :_ 1j;:1_,i.l;r� _.•�l �:'.l.i ,� ='•:,:. '.., f•:.<�v'"1:=_ , i %ti`.� �� 11
/�\ 1 it •`..•r3 1 1 <'1'•�1I "r• , J - r.I° i • ��•' � � ==L�,..11` l�� �ti�� .° - ���
� `-1 � •itiC 1 _-���• - l •• ,��. ;' A� - -•- a �'!r_/•t-_ •^_ �_`_.�_:.:_ 1 t.� C�� '��\.�<"'" `r�j•
�!.ih♦f • , • . 1'`,r f Tj t t f: .� A,1313
\\
............
01 .
IN
C2neralized M.2;2 of Major Habit C OASTAL
Habitat Tykes
COLSA CHICA ao-.• �•b•M.,«. •.s••..•..••.• . . m, • °•t •y LN
:'•�� ..^T i!!eC fren Fo:sa Chica 5u;p:e-enta! sl—,!%
Ftrrl-PF 1 - t ,
J
acreage- fi-jur---.:; for r�:st,lt-duion and r4l-vclopmerlt
ilt tho below:
Table I - The- Sy:A--om A.pprnach
1,;,-Llz-r-.d I'Zoetoration
A. Within the . State-owned Ecological Res erv-
1 . Existing ,Wetland . . . . . . . . . 236 acres
2 . 1-Zestcrable :ton-wetland . . . . . . . 32 acres
3 . Tot-al wetland pnzzible . . 268 acre.
B. None-State Land Outside Reserve
1 . Existing 6-,Je'%"*lant'L . . . . . . . . . . 616 acres
2 . Restorable Nor.-wetland . - . - ' * ' * 3P,4- acres
3 . Total area of the wetland system. . 1000 acres
4 . Total to be restored-0 . 75 x 1000
[From Coastal Act Section 30,111
b( 2 ) and b( 3 ) --1 . . . . . . . . . . . 7-I#0 acres
C . Overall Nutland Acreage to be Peztored
1 . Vllithin Reserve . . . . . . . . . . 268 acreS( i . e . 236 + 32 )
2 . OuLside Reserve . . . . . . 750 acres ( i . e. 1000 x 0 . 7
3 . Grand Total of wetland to b-'e
provided. . . . . . . . . . . . . . . 1018 acres
Potential .. . .. . . . . . . 250 acres
Table 11 No SysLetn ,'%pproach
r.luf-1 a nd Fes-t-oration
. .1
A. Within the State-owned Ecological Reserve
1 . Existing wetland . . . . . . . . . . 236 acres
2 . Restcrable non-wetland . . . . . . . 32 acres
3 . Total to be restored . . . . . . . . 268 acre3
Non-�7- 'Cate Lands Outside the Ecological Re--7,er-ve
1 . Existinq Wetland . . . . . . * . 610' acres
2 . Restorable non-wetland with little,
if any, development potential . . . . 384 acres
3 . Total area ;. . . . 1000 acres
Total which may be rL-Ztorc(j given
no development within 1000 acre area 0 acresA
11 Development . . . . . . . . . . . . . . . . . 0 acresh
•11'1'o adopt a po:3iti(--,n other than it zyst(-,m approach consistent with
Co.--i�Lal Act Section "50.111 results in no rcquireinont for restoration.
,atY,--:--r , . simPIy protection of the 616 acres of wetland outside the
Ecolorjicz-il Reserve would be required by the Coastlal Act .
AddiL.Ionally, becatize of the fragmented anti largely linear nature of
non—,;-tland areas ( i .e . roads and fill 1).--ids ) within the 1000 acre area
-i(Iont'if ! P(I ' the poteri'Lial for developritent is nil given the preclusicn
of or, w tJ1 e)ci :;L-irvT Arcas .
10
Al 0V C 11984 -1
CALIFORNIA
RESOLUTION NO. 5454 COASTAL COMMISSION
A RESOLUTION OF THE CITY OF HUNTINGTON
BEACH ADOPTING CONDITIONS OF APPROVAL
FOR THE BOLSA CHICA LAND USE PLAN
WHEREAS, it has taken many years study to prepare a General
Land Use Plan for the Bolsa Chica; and
Numerous parties, both public and private, have made
contributions to said plan; and
The city staff has diligently studied all alternatives so
as to best serve the long term interests of the citizens of
this area.
NOW, THEREFORE, BE IT RESOLVED: t
Bolsa Chica Avenue shall be extended to Garfield Avenue at
the minimum width necessary to safely and efficiently handle
traffic , preferably 80 feet, and shall be designed to encourage
southbound traffic to utilize Warner Avenue enroute to Pacific
`oast Highway. The extension of Bolsa Chia avenue shall
connect with a new connecting street to Pacific Coast Highway
and such connecting street shall, in turn, be connected to
Warner. Avenue. In a similar manner, Garfield Avenue shall have
a connecting street via an extension of .Edwards and 38th Street
with Pacific Coast Highway. The extension of Bolsa Chica
Street to Garfield Avenue shall allow the tie-in of Springdale,
Talbert, and Graham.
Sufficient distance shall be provided ( a minimum- of 800
feet) between the Bolsa Chica Street extension and existing
residential properties in order to complete the local street
syst-ems through cul-de-sacs and, in addition, to allow for
proper development of low density residential properties which
would border the Bolsa Chica -Street extension and be compatible
with existing development . All street construction shall be
performed under standard City of Huntington Beach development
requirements, as depicted in Exhibit A.
a
Any reroute of Pacific Coast Highway shall be limited to
the "mini reroute" and shall provide for adequate - and
satisfactory access for the city' s Warner Street Fire Station.
The City of Huntington Beach shall have no financial obligation '
for any Pacific Coast Highway reroute.
A navigable connection between Huntington Harbour and the
Bolsa Chica Marina is favored to allow for needed improvement
of water quality in Huntington Harbour and as an alternate
boating outlet. This alternate outlet is needed due to
possible limitations on the use of Anaheim Bay, which is
primarily for the U.S. Navy Weaporis • Station. The City of
Huntington Beach shall not have any significant financial
obligations through general funds for such navigable connection.
Any ocean cut of the Bolsa Chita State Beach should be done
only after comprehensive modeling to determine the impacts on
the sandy beach. Only under designs which predict no or
minimal effects does the city favor such ocean cut. Ways and
means should be required 'also ' to provide for the financing of
any required sand replenishment program. The City of
Huntington Beach shall have no financial obligation for any
ocean cut or channel maintenance.
All land uses within the Bolsa Chita shall be compatible
with existing development and appropriate transitions of zones
shall be provided adjacent to all existing zones . Due regard
shall be given to topographic features and seismic conditions
as well as for utility services.
The City of Huntington Beach favors optimizing wetlands
restoration and open-space development, but expresses concern
with regard to the viability of some of the wetlands area shown
in the extreme northeastern tip of the Bolsa Chica. Special
attention should be directed toward this area so as not to '
create nuisances for existing residential development as the
result of odors, insects, etc. All wetlands restoration shall
be within the bounds of the project area.
2.
PASSED AND ADOPTED by the City Council of the City of
Huntington Beach at a regular meeting thereof held on
the day of 1984.
Mayor
ATTEST : APPROVED AS TO FORM:
City Clerk City Attorney
REVIEWED AND APPROVED: INIS�7 EDND APPROVED:
/ 71;1' 0�4r
City -Adm-inistratojK Director of Public works
R
3 .
13.
call
s PSEi5�D1=1JT1Al_
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P�5�GC'J�tfti4L �� �j
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i
U "
WrfLAl4f)...�o..� ...-..._ ....,.,. «�- «.K-.—. �- ..._, �P�GIF'IL CIF_-i(� 1.11C'�I-IbY/-jy
-----T�-
w+M...•���Zrr aY a�r�.r r
�.14M6AQ�.dCw.rr i.irr:M�'rANfK4l_�..� . � ! rr0
J+w.ra•� r+W'7'wr'"'+r`rwti�f7�f.a.r:
mow.-�.�.w..•..•-�. �.-..+..�....�..�.,,�..r,rr,.........�,,.,...w.y w..�.. ,s�"
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LSAL'OP'%SFII 'e% A
STRINGFELLOW BRIEFING
ORANGE COUNTY
BOARD OF SUPERVISORS
DECEMBER 19, 1984 .
I . OVERVIEW: HAZARDOUS WASTE
MANAGEMENT IN SOUTHERN
CALIFORNIA
II . STRINGFELLOW
A. BACKGROUND
B. INTERIM TREATMENT PROGRAM
C. FUTURE.,�,ACTIONS
III . CONCLUSIONS
I. OVERVIEW: HAZARDOUS""
WASTE
MANAGEMENT IN SOUTHERN
CALIFORNIA
A. GENERATORS
B. TREATMENT, STORAGE
AND DISPOSAL
Co .-SUPERFUND SITES
Il. STRINUFELLOW
A. BACKGROUND
1. Site History
. - .,. ,
2. Site Activities
o Interim Abatement Prog ram
o Stabilization Measures
o Ground Water Extraction
and Disposal
o Fast .Track - Feasibility Study
o Long Term Remedial
Investigation and
. Feasibility Stud
Y
o Ground ,Water Monitoring
3. Community Involvement
B. INTERIM TREATMENT PROGRAM
1. Treatment Process
2. Public Review
o Intergovernmental Review
o Public Comment Period
- o Briefings
3. Impacts on Orange County
o Volume
o Concentration
... o Quantity
co FUTURE AG,,. IONS
o Long Term Cleanup
o Public Involvement
ui. CONCWSIONS
o Need for.. Cooperation.
among political jurisdictions
in Sou thern California
o Need for accurate
and timely information
o ...,,Opportunity for public
involvement
VOLUME [=
300
,l t•
250
230 MGD F4,
200
150
100
60 MGD
50
0.187 MGD
0 a
Ocean Discharge Fountain Valley Stringfellow
CONCENTRATION _4
a
14.6 2.13
13.4 :
Of
10.3
0.58 0.58
a,
0.3 0.024
I oil
t Standsd Perm%e1 Pem'� bil Study at dsd ' f mob►� Study z*
Stan Pam` per
Epp,-w ppC 1n Stinco . Treat° Epp,Tre CsppC 1r String Sreat
k
Metals (mg/1) Total Toxic Organics (mg/1) `a
4 ,
QUANTITY
1850 {
Not Measured '
161 0.9
0.5 0.037
Dtve el Pee
CSD�snfel Peetabil Stu YCSSrngt ratabilStu y string
Metals (lb/day) Total Toxic Organics Qb/day)
d
03 PAR]S(N C P (SDOC AND EPA DLSCIIUCH SDAN UM
TO Pik PC SED STRDIGEEUM DISCIIAM CCNOZ' MbS
SATi+PA '-
EpR2 Permit Limits »
MMLJ Pretreatment Standards for Stringfellow at Pilot Treatment Study
Industrial Use Ordinance for New Electrcpdater Peak Daily Discharge Highest Encountered &MM CF MaMM A4
Maxima Allowable Sources Maxiaam Mwdmm Allowable Concentration in Primary Drinking
Concentration (mg/1)** Omoentration (mg/1) CcTnoentratiorn (mg/1) Treated GrouT ater ur.1a Water Standards (mg/1)
Arsenic 2.0 N.S.* 2.0 0.043 0.05
C*miun 1.0 0.69 0.064 0.018 0.010
Chromium 2.0 2.77 2.0 0.005 0.05
Ocrper 3.0 3.38 3.0 0.08 N.S.
Lead 2.0 0.69 0.58 0.005 0.05
°,
mercury 0.03 N.S. 0.03 0.0066 0.002
Nickel `10:0." 3.98 3.51 0.16 N.S.
Silver 5.0 0.43 0.43 0.02 0.05
Zinc 10.0 2.61 0.7 0.034 N.S.
(Total) 5.0 1.2 1.2 Not Tested N.S.
Total Tcodc Organics 0.48 2.13 0.58 0.024 0.335
*N.S. - Not Specified
**mg/1 - (milligrams per,lltqr) is equivalent to parts per million
1. Effective July 1, 1983. The CSDOC industrial control ordinance entitled "Regulations for Use of Districts Sewerage Facilities" provides for the
enforcement of EPA Industrial Categorical Pretreatment Standards when they become effective. C5MC enforces the standards that are most restrictive.;
2. Federal Register, July 15, 1983, pp. 32463-32487. These standards became effective April 27, 1984 for non-integrated facilities and June 30, 1984 :s
for integrated facilities.
3. EPA Hazardous Site Oorntros Division "Final Test Program Summary Report, Stringfellow Site, August 27, 1984%
4. ..California State Department of Health Services, Sanitary Engirmering Branch, Primary Drinking Water Standards, June, 1963.
,4-0, 2,4,5-0, silvex and 7UW s.2
5. This value is sun of limits for ed ocy rin, lindane, methcchlor, to�thehe, .
• i7
COMPARISON OF CSDOC RAW SEWAGE QUALITY
TO
EXPECTED STRINGFELLOW DISCHARGE QUALITY
CSDOC Average Raw Permit Limit Discharge Quality for B
Sewage Quality* for Stringfellow at Peak Stringfellow Based on EPA
July 183 -June 184 ( lbs/day) Daily Discharge ( lbs/day) Treatability Study ( lbs/day)
F.
Arsenic 9 .6 3.1 0 .067
',admium 40 0 .1 0.028
Chromium 260 3.1 <0.008
Copper 700 4.7 0.125
Lead 170 0.9 <0 .008
Mercury 1.2 0.05 0.010
Nickel 140 5.5 0.250
•a
Silver 40 0 .7 0.031
Zinc 500 1.1 0 .053
7yanide (Total) 100A 2.0 Not Tested
Total Toxic Organics ** 0.9 0.037
A. Estimated
B. "Final Test Program Summary Report, Stringfellow Site, August 27 , 1984" ,
prepared by CH2M Hill for EPA.
J>
* Weighted average of Fountain Valley & Huntington Beach plant influent. '!
** not measured
STRINGFELLOW SCHEDULE
FAST TRACK-RELATED TARGET DATES
EPA Briefs CSDOC (Blake Anderson) February 15 ,1984
Anderson Briefs CSDOC Executive Committee February 29
Executive Committee Briefs Bd.of Directors March 14
EPA Briefs RWQCB/SAWPA/Orange County Health March 29
Dept. & Orange County Water District
EPA Briefs US Army Corps of Engineers April 5
EPA Briefs Chino Basin Municipal Water Dist. April- 11
Review of Fast Track Final Draftl April 16 - May 4
EPA Briefs LA County Sanitation District April 17
Intergov. Review of Fast Track Final Draft2 April 12 - May 22
Notification for Public Comment on Final May 9 - 20
Fast Track3
Final Fast Track Reportl May 18
Public Comment period on Final Fast Track May 21 - June 8
l mailed directly to Stringfellow Advisory Committee,
DOHS, USAGE, OC Health Dept. , OC Water Dist. , CSDOC,
SAWPA, CSDLAC, RWQCB, City of LA Sanitation District,
CBMWD and others
2 sent to DOHS, CHP, Air Resources Board, Cal Trans, RWQCB,
Solid Waste Management Board, Dept. of Food & Ag. , Dept. of
Fish & Game , OSHA, Office of Emergency Services
3 advertised three times in the LA Times, the Riverside Press
Enterprise and the Santa Ana Register; available in three
Riverside libraries, one LA library and one Garden Grove
library
jecember 12, 1984
BRIEFING PAPER.
STRINGFELLOW HAZARDOUS WASTE SITE
ISSUE
• WTiat is the status of clean-up of the Stringfellow hazardous
waste site under CERCLA?
SIGNIFICANCE TO AGENCY
Major. Stringfellow is on the National Priorities List as
California's highest priority site. The site has received
a great deal of local and national attention.
CURRENT EPA POSITION
The State of California and EPA are pursuing site clean-up
under a cooperative agreement as litigation continues.
BACKGROUND
The Stringfellow site is located in Riverside County, .California,
approximately one mile north of the community of Glen Avon
(population 10,000) . The site was operated by the Stringfellow
Quarry Company as a permitted hazardous waste facility from
1956 until 1972. Approximately 34 million gallons of hazardous
wastes, including acid and caustic wastes, solvents and heavy
metals, were disposed of in evaporation ponds at the site.
Groundwater beneath the site enters the Chino Basin regional
groundwater system which provides a domestic drinking water
supply for approximately 40,000 potentially affected residents.
In 1969 and 1978, heavy rains caused the disposal ponds to
overflow; overflows extended into Glen Avon. Again in 1980,
heavy rains threatened overflow of the ponds. Emergency response
actions were taken to prevent overflow. More than 10 million
gallons of liquids were removed by the Federal Regional Response
Team and the USCG Pacific Strike Team.
In 1980 and 1981 , the Regional Water Quality Control Board imple-
mented an Interim Abatement Program which included removal of all
surface liquids, partial neutralization and capping of the wastes,.
installation of a gravel drain and a network of extraction, inter-
ceptor and monitoring wells on-site and downgradient of the site,
construction of a clay core barrier dam and leachate collection
system.
In July 1982, EPA completed an intensive responsible party
investigation which identified over 200 potentially responsible
parties. Based on this evidence, EPA decided to pursue
enforcement.
-2-
In August and September, 1982, EPA sent Notice Letters to
appoximately 293 generators, transporters, and owner/operators
informing them of their potential liability for site cleanup
under CERCLA.
In April , 1983, the United States and the State of California
filed a civil suit against the major responsible parties in
the the United States District Court. Settlement negotiations
have been unsuccessful.
In May 1983, contaminated liquid was discovered surfacing
several hundred yards downgradient of the site. DOHS requested
EPA assistance for containment action. The ,following activities
were performed: installation of a french drain, improvement of
drainage channels, installation of a spring box and pump barrels
upgradient of the site to collect and divert uncontaminated
groundwater around the site.
From April, 1983 through September and November, 1983, EPA's
contactor, Ecology and Environment (E & E) , conducted monthly
groundwater sampling of extraction, interception, monitoring
and private wells. In addition, E & E conducted an electro-
magnetic conductivity survey and installed additional monitor-
ing wells.
In June 1983, DOHS submitted a cooperative agreement application.
A $2.8 million cooperative agreement was awarded in July, 1983,
and a $7. 1 million amendment was awarded in December, 1983.
Activities funded include initial remedial measufes, interim
source control, interim off-site control, an 18 month remedial
investigation/feasibility study (RI/FS) and reimbursement for. .
past activities.
At the request of DOHS, EPA initiated a Fast Track RI/FS in
September, 1983. This study was conducted to identify and
evaluate methods for management and disposal of contaminated
groundwater collected from on-site and downgradient wells.
The recommended alternative will be implemented during the 3
to 5 year period prior to completion of the full-scale RI/FS
and implementation of the final remedy. EPA's contractor,
CH2M Hill, completed the study in May, 1984, and a Record of
Decision for the recommended alternative was signed by Lee
Thomas in July, 1984. The interim measure entails installa-
tion of an on-site pretreatment system for extracted ground-
water. The tre.atment. process consists of lime precipitation
for heavy metals removal followed by granular activated carbon
treatment for organics removal. Pretreatment will be followed
by discharge to a publicly owned treatment works system and
sludge will be disposed of at a Class I facility.
In May, 1984, analytical work performed by the National Enforce-
ment Investigation Center revealed the presence of radiation in
Stringfellow groundwater samples. To follow-up on these findings,
DOHS has conducted sampling of upgradient, on-site, downgradient
is
-3-
and Glen Avon community wells to determine the extent and
source of contamination. As a precautionary measure, DOHS
has been providing bottled water to Glen Avon households
since June, 1984.
In June and July, 1984, CH2M Hill conducted treatability
studies on Stringfellow water to verify the capability of the
. recommended pretreatment system, and a pilot pumping test to
determine the long-term pumping rate required to effectively
intercept contaminated groundwater moving through the mid-
canyon area.
In September, 1984, EPA awarded a $2.07 million cooperative
agreement amendment to DOHS. Activities funded include:
design and construction of the pretreatment plant, site prepar-
ation, and additional groundwater monitoring under the RI/FS.
CURRENT STATUS
Since October, 1984 , contaminated groundwater has been extracted
and disposed of at the Casmalia Resources, Inc. Class I disposal
facility at a rate of approximately 315,000 gallons per week.
Under contract to DOHS, the Santa Ana Watershed Project
Authority (SAWPA) is managing implementation of the pretreat-
ment plant. James Montgomery Engineers performed the design
and will provide construction management. The equipment,
installation and carbon supply contracts have been awarded and
a partial Notice to Proceed was authorized by DOHS on Novem-
ber 29 , 1984. According to SAWPA's schedule, the pretreatment
plant will be on-line in February, 1985.
Results of the radiation analyses indicate that uranium is
present in elevated concentrations near the 'site and in some
community wells. Additional testing is being conducted to
determine whether the radiation is from naturally occurring
sources. The Department of Health Services plans to issue a
report on their findings in January, 1985. The State is
currently providing bottled water to 386 households.
The full-scale RI/FS was startedin March, 1984 and is currently
scheduled to be completed in December, 1985. The RI/FS is
designed to identify and evaluate alternatives for final site
closure. The study focuses on three geographical areas: .
upgradient of the site, on-site and downgradient of the site.
Among other tasks, the RI/FS contractor, JRB Associates, is
currently developing a routine monitoring program, preparing
a workplan for the on-site and upgradient investigations and
is installing monitoring and extraction wells in the mid-canyon
and lower canyon areas. The target completion date for
installation of the mid-canyon wells is January, 1985. With
`�ty�:. -k-�-tom: �( ✓'tii - ..: . .. .. . ..r-
-4-
the installation of the mid-canyon wells, full interception
of contamination moving through the alluvium in the mid-canyon
area may be achieved.
Analysis of groundwater samples taken from a new well south
of the freeway (FC-lA2 ) has revealed TCE contamination at
240-344 ppb. This is the first time that chemical analysis
has revealed contamination at this level south of the freeway.
Additional geophysical studies will be conducted and monitoring
wells will be installed during the RI/FS to determine the
areal and vertical extent of contamination.
To date, no contamination related to the disposal site has been
detected in any of the Glen Avon private wells included in
EPA's and DOHS ' monitoring programs. Community wells will
continue to be monitored throughout the RI/FS.
On December 7, 1984, EPA awarded a $3.70 million cooperative
agreement amendment to DOHS. Funding was provided for the
RI/FS, initial remedial measures and construction of the
pretreatment plant.
M•1
FIGURE 2
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My q • • fly ":l
Sources Final Fast-'luck tiaaedial Irnrestigatiosl Feeaibility Study,
NOW: IN-188 not ahorin May le, 1984, Prepared by cH2m Hill
1
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United States Region 9 Arizona
Em•' nmental Protection 215 Fremont Stree' California
Ag San Francisco, Cf 05 Nevada
Pacific Islands
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MRA
N1%W S FACT SHEET
qu ,
STRINGFELLOW GROUNDWATER
EXTRACTION AND PRETREATMENT
NOVEMBER 9 , 1984
In order to control the movement of contamin-
ated groundwater from the Stringfellow site down
through the canyon, contaminated groundwater has
been extracted from wells at the site and disposed
of at a Class I hazardous waste facility since
November, 1982 . At present , approximately 315 ,000
gallons of contaminated groundwater per week are
extracted and disposed.
For the purpose of finding a more cost-effec-
tive alternative for the management and disposal
of the contaminated groundwater, EPA conducted
a Fast Track Remedial Investigation/Feasibility
Study. The study, completed in May 1984 , . recom-
mended installing a pretreatment system onsite.
The pretreatment system would treat contaminated
groundwater using lime precipitation for heavy
metals removal followed by granular activated
carbon treatment for organics removal . The
treated water could then be discharged into an
industrial sewer for conveyance to a wastewater
treatment plant for final treatment and disposal .
In June and July 1984 , EPA conducted treat-
ability studies which verified that the recommended
pretreatment system could treat the contaminated
groundwater to meet stringent pretreatment require-
ments prior to disposal to an industrial sewer.
Plans are now underway to provide an effective
pretreatment plant at the Stringfellow site on
an .interim basis until the full-scale Remedial
Investigation/Feasibility Study, currently being
conducted by the California Department of Health
Services, is completed and a comprehensive cleanup
strategy for the site is implemented.
As -part of the study, EPA also studied the
extraction well system located in the mid-canyon
area to determine how efficiently the wells are
able to extract contaminated groundwater and how
effectively the wells capture groundwater flowing
through the alluvium in the mid-canyon area.
-more-
. •._'Y.f . .rA"•',.r. .v _e:<'>.4•,'... , _ _ _ . <iL... .. .. .e . . . . ...
-2-
The studies showed that interceptor wells #2 and #3 and
monitoring well #19B ( indicated as IW-2 , IW-3 , and MW-19 on
the map) can be used to intercept 90 to 95 percent of the
contaminants moving through the alluvium in the mid-canyon
area. The studies also recommended installing additional
extraction wells in the mid-canyon area to extend the "zone of
capture" so contaminants moving through the mid-canyon area
are fully intercepted .
s�
—'•G APPELIXMM CANYai
(IW-2) • � — ETMR BOUZkW
!W 19) O•(IW-3) , aSr1E Ex1AACTICN WENS
//�� • DaMMT MIW M7YCH WE31S
O Ptxosm MIfY'ANYO7 Taus
The California Department of Health Services is currently
preparing for the installation of additional extraction and
monitoring wells in the mid-canyon and lower canyon area .
These wells are expected to be in place early in 1985 .
This fact sheet is intended to provide a brief summary of
the pretreatment system and groundwater extraction plans
for the mid-canyon area. Copies of the complete reports are
available for review at the following public repositories :
Stringfellow Information Central Riverside
Center Public Library
9009 Mission Boulevard 3581 7th Street
Glen Avon, CA 92509 Riverside , CA 92501
( 714 ) 681-4321 ( 714 ) 787-7201
Glen Avon Branch Library Robidoux Branch Library
9010 Mission Boulevard 5763 Tilton Avenue
Riverside, CA 92509 Riverside , CA 92509
( 714 ) 685-8121 ( 714) 682-5485
Report titles include:
Test Program Summary Report , August 27 , 1984
Fast Track Remedial Investigation/Feasibility Study
May 18 , 1984
y... r
RE: AGENDA ITEM #12�_, lX 11/14/84. '.
SUPPLEMENTAL INFORMATION
ON REQUEST OF DOHS/SAWPA TO DISPOSE
OF PRETREATED STRINGFELLOW WASTES
TO DISTRICTS SEWERAGE SYSTEM
California Environmental Quality Act
The 1978 State Legislature passed Senate Bill 1130, which was signed into
law as Chapter 784 of the 1978. Statutes as an urgency measure effective
September 18, 1978. Section 6 of that Chapter provided an appropriation to be
expended solely for the purpose of abating threatened conditions of nuisance and
pollution caused by the Stringfellow Quarry Class I Hazardous Waste -Disposal
Site. Section 7 of the Statute provided that the State Water Resources Control
Board may perform any act, if necessary, to implement the provisions of the
Statute. Based upon these provisions, the SWRCB, together with SAWPA and the
State Department of Health Services, have undertaken a program for study and
remedial action relating to the hazardous waste removal from the Stringfellow
site.
Assembly Bill No. 26 was adopted by the Legislature and signed into law by
the Governor as chapter 1302 of the 1982 Statutes, which became operative, in
relevant part, on January 1, 1983. Chapter 1302 added an uncodified law to
specifically provide that the State Department of Health Services shall have the
responsibility for conducting the permanent .closure and maintenance of the
Stringfellow site, and in any emergency, as that term is defined, all activities
of the SWRLC—. and the State DOHS or any other State agency, department or
commission .incidental to the site closure maintenance shall be exempt from the
requirements of the California Environmental Quality Act (CEQA).
Based on these two Statutes, SAWPA and the State DOHS, as the administrative
agency, have entered into contracts for the removal of the hazardous waste and
have made the determination that no comprehensive environmental assessment and
report is required because of the express legislative finding that the activity
is exempt. The Executive Officer of the Regional Water Quality Control Board,
Mr. James Anderson, and the Manager of SAWPA, are of the opinion that this
exemption applies comprehensively to all facets of the operation, including the
discharge of the treated waste into the CSDOC Santa Ana River Interceptor for
transport to the Districts' Treatment Plants for. additional treatment And-final
disposal .
Environmental Protection Agency' s (EPA) Record of Decision
In July, 1984, the USEPA filed a record of decision in compliance with the
National Environmental Policy Act (NEPA) that states, in part, that based on the
results of the Fast Track Remedial Investigation/Feasibility Study, the Toxics
and Waste Management Division recommends installation of an onsite pretreatment
plant for removal of heavy metal and organic contaminants, followed by discharge
f
t-d' a local Publicly Owned Treatment Works (POTW) system. Sludge from the
treatment process will be deposited at a Class I facility. This alternative
will be implemented during the three to five year interim period prior to
completion of the full-scale RI-FS and implementation of the final remedy. ' Of
the alternatives evaluated, this alternative is the lowest cost and provides the
greatest protection to public health, welfare and the environment.
The record of decision goes on to note that the operator of a regional
interceptor (SAWPA) must obtain concurrence from the receptor POTW (CSDOC) for
all industrial wastes admitted into its system. . CSDOC may deny a permit for
discharge that it believes could adversely affect the operation of its treatment
plant, or which could affect compliance with its NPDES permit requirements.' The
burden of establishing that no adverse effects will result falls upon the waste
generator (DOHS SAWPA) :
The final draft and the final report on the proposal were available for
public review and comment to three Riverside County public libraries. The final '
report was also distributed to public libraries in Los An9eles and Orange
County; availability of the report was noticed in the Los Angeles Times, .the
Riverside Press Enterprise, and the Santa Ana Register.
Further Environmental Considerations
The District' s Regulations for Use of Districts ' Sewerage Facilities
(Industrial Waste Ordinance) , adopted and enforced by the Boards of Directors,
impose stringent limitations on industrial dischargers to provide ongoing
protection of the environment and the public health and safety.
It is the General Counsel ' s opinion that while the CEQA exemption is very
broadly worded and thus is subject to a liberal interpretation that would allow
every aspect of this operation, including the discharge to the CSDOC facilities
and system, to be exempt from the CEQA requirements, that the District, in its
own right, could either undertake its own environmental assessment or require
the SAWPA management to do likewise.
' 1.
SUPERVISOR, FIRST DISTRICT
1� aT ;pz � ROGER R . STANTON
ORANGE COUNTY BOARD OF SUPERVISORS
'- ORANGE COUNTY HALL OF ADMINISTRATION
10 CIVIC CENTER PLAZA,SANTA ANA,CALIFORNIA 92701
PHONE 834-3110 (AREA CODE 714)
December 19, 1984
Honorable Board of Supervisors
County of Orange
Hall of Administration
Santa Ana, CA 92701
Honorable Board Members:
As you know, the Orange, County Sanitation Districts approved a plan to
discharge wastewater from the Stringfellow toxic dump site into the Orange
County sewer system. The proposed plan seems to have originated with the
Environmental Protection Agency, (EPA) and the California State Department of
Health Services (DOHS) . The plan has the enthusiastic support of the Santa Ana
Watershed Project Authority (SAWPA) for reasons not fully made public.
Before listing the serious questions that have been raised by the proposed
project, I will attempt to outline the history of how Orange County became
aware of the plan. While Orange County is now apparently an integral part of
the proposal, neither the citizens of Orange County or their elected
representatives were properly included in the decision making process by EPA,
DOHS, or SAWPA. The following brief chronology of events has been pieced
together based on the best information available.
September 14, 1983 - The Orange County Sanitation Districts (OCSD) boards
received an oral briefing on a series of articles on a SAWPA in local
newspapers during the preceeding three days. This was not an agendized
item. The directors were told that the OCSD Chief Engineer, Ray Lewis,
had denied a SAWPA request to discharge Stringfellow wastes into the
Orange County system in a letter dated July 11, 1983. The matter was
presented as a information item with no Board action required in light of
the staff denial of SAWPA's request.
February 29, 1984 - The new OCSD Chief Engineer, Blake Anderson, informed
the OCSD Executive Committee that both EPA and DOHS were still studying
the Stringfellow issue. However, the OCSD staff indicated that they still
would not consider the proposal. This again, was not an agendized item.
September 26, 1984 - For the first time the OCSD staff agendized the
Stringfellow issue for discussion by the OCSD Executive Committee. The
staff answered several questions and agreed to seek answers to others.
SANTA ANA—.FOUNTAIN VALLEY—WESTMINSTER—GARDEN GROVE—MIDWAY CITY
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Page 2
December 19, 1984
October 24, 1984 - The Executive Committee continued its discussion of the
SAWPA proposal. The Committee agreed to recommend consideration of the
SAWPA proposal to the OCSD Board of Directors at their November 14th
meeting.
October 31, 1984 - Supervisor Stanton sent a letter to the OCSD General
Manager, Wayne Sylvester, requesting that OCSD demand that the State DOHS
prepare a full Environmental Impact Report (EIR) on the SAWPA proposal.
November 14, 1984 - In a meeting of the Joint Boards the OCSD directors
vote down a motion (by Supervisor Stanton) calling for a full EIR prior to
any consideration of approving the SAWPA discharge request. An
alternative motion to approve the proposal and request a concurrent
"Environmental Impact Review" was approved.
November 21, 1984 - The Orange County Board of Supervisors approved the
request by Supervisors Stanton and Nestande to ask DOHS to prepare a
complete EIR on the proposed Stringfellow cleanup project prior to the
start up of the project.
December 3, 1984 - Supervisor Stanton and Supervisor Nestande meet with
Ray Lewis (now a SAWPA consultant) , Charles White (DOHS) , Brian Ullensvang
(EPA) , Wayne Sylvester, and Dick Edgar (OCSD Board Chairman) to discuss
the Stringfellow Proposal. EPA and DOHS representatives expressed no
willingness to conduct full EIR or to consider alternative plans. They
did agree that the project could continue over a 20 year period although a
shorter (approximately 3 year) period had been mentioned to the OCSD
directors at their November 14th meeting. They also indicated that the
"public" was involved in Riverside County. At Supervisor Nestande's
insistence they admitted that no public hearings had-been held on the
project in Riverside County (and certainly not in Orange 'County) . The
meeting raised more questions than it answered.
December 12, 1984 - At the next meeting of the Joint Boards the OCSD
directors voted down Supervisor Stanton's motion to rescind the action of
November 14th and delay further consideration until a full EIR is completed.
Before and during the December 12th meeting, additional disturbing questions
about this proposed project surfaced.
Question #1 - Why does SAWPA have such a strong interest in this particular
project? Of course SAWPA is (and should be) concerned about water quality.
But other Stringfellow cleanup alternatives seem worthy of consideration.
SAWPA's strong opposition to a full EIR and the consideration of alternative
plans suggests a vested interest in this project. Could this be due to the
fact that SAWPA will be charging more than their cost for their efforts in the
proposed project.
Prior to the December 12th OCSD Board meeting one SAWPA Board member confided
to me that the profit that SAWPA will make off this project will enable SAWPA
to finance the extension of the Santa Ana River Interceptor (SARI) sewer line.
The extension of this line could create new development opportunities in the
Inland Empire which would compete with Orange County -- and Orange County would
be left treating the wastes these projects would create.
"°�"ii`1'.'�i.' .�t' .%ws:"'m, _ Y':..'r.`:�'�( _r:v,•° rii.
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Page 3
December 19, 1984
At the December 12th Orange County Sanitation District meeting I asked SAWPA
Executive Director Andrew Schlange to confirm or deny this. He first attempted
to dodge the question by saying that the projet that SAWPA would make over a
3 year period was not enough to extend the lines. I then pointed out that on
December 3rd an EPA representative said that this so-called interim solution
would cover a 3 to 5 year period. The EPA representative also confirmed to
Supervisor Nestande and me that the "interim" solution would likely be the
basis for a long-term solution thereby extending this proposed plan (and Orange
County's involvement) over a 20 year period. When I cited this in pressing
Schlange for an answer. He refused to deny that it was SAWPA's intent to use
their profit from this project to extend the lines. It seems clear then, that
SAWPA's strong financial motivation is to support the proposed project. If an
alternative solution is selected, SAWPA would stand to lose a new source of
funds. Obviously, this is one motive for SAWPA not supporting the preparation
of an EIR, which would require the consideration of alternative solutions and
cleanup plans which might not involve SAWPA. Questions on this point yet to be
addressed are:
A. By how much will SAWPA profit form the proposed plan? (Figures to
date have been sketchy and conflicting.)
B. What are the financing plans to extend the Santa Ana River
Interceptor line and how would the loss of Stringfellow Project funds
affect the financing of the extension of these lines?
C. If the (SARI) sewer line is extended, does that promote further
business and industrial development in the Riverside area which would
compete with Orange County? Also, would that increase the burden on
the Orange County Sanitation District plants, thereby forcing
expansion of those plants to treat the additional waste generated
from new developments in Riverside.
D. If the SARI line is extended, how much would this increase the
probability that EPA and DOHS would select a variation of the interim
project as a long term "solution"? Isn't a long term "solution"
where pretreated Stringfellow waste water is piped directly into the
SARI line instead of trucked to it a strong possibility, thereby
committing OCSD to treating Stringfellow waste water for decades?
E. If the (SARI) sewer line is not extended, would it be more likely
that Riverside would construct another treatment plant to treat their
own wastes?
Question #2: - What is the ultimate disposition of the Stringfellow waste
water? Is it the ocean or could it end up in Orange County's ground water
table? During the December 12th OCSD Board meeting Newport Beach Councilmember
Hart asked if the Stringfellow waste would be treated at the Fountain Valley
plant before discharge into the ocean. Councilmember Hart asked if the waste
water would bypass the Fountain Valley plant. OCSD Chief Engineer Blake
Anderson replied very clearly that the Stringfellow waste water would not
bypass the Fountain Valley plant and would, in fact, be treated there.
That fact raised a very disturbing question. I then asked Mr. Anderson if the
line that would carry Stringfellow waste was the same line from which Water
Factory 21 obtains its supply of waste water to be injected into the Orange
County's water table after desalination? He acknowledged that fact.
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Page 4
December 19, 1984
Thus, the ultimate disposal of the Stringfellow waste water may not be solely
the ocean, but may be through the Orange County Water District's injection
wells along Ellis Avenue in Fountain Valley and Huntington Beach.
If the line carrying Stringfellow wastes is bypassed around the Fountain Valley
plant, then Water Factory 21 would be forced to use the discharge from other
lines that contain evidently more solid matter. Therefore, the question must
be raised, will Stringfellow waste water be injected into Orange County's water
table through Water Factory 21? If not, that is, if the Stringfellow waste
water bypasses the Fountain Valley plant, then will Water Factory 21 find it
necessary to use the less desirable (higher solid content) discharge from other
lines for its injection process? Either way, it seems a major sacrifice must
be made.
The OCSD Chief Engineer's reply to Councilmember Hart's question on December
12th directly contradicts the Orange County Water District letter to OCSD dated
July 23, 1984, which states "It is our understanding that any (Stringfellow)
contaminated ground water . . . will probably be diverted around the Orange County
Sanitation District's Treatment Plant No. 1 (the Fountain Valley plant) , since
that line (the SARI line) contains other high TDS (total dissolved solids)
waste waters, making it less usable for reclamation." This also contradicts
DOHS representative Charles White's statement to Supervisor Nestande and me on
December 3rd when he said that DOHS "never contemplated putting it (reclaimed
Stringfellow waste water) into ground water." I strongly believe that Orange
County's ground water table should not accept any unknown trace hazardous
materials which may be present in Stringfellow waste waters after tertiary
treatment at Water Factory 21.
Question #3 - Are there alternatives to the present proposed Stringfellow waste
water "cleanup" project involving Orange County? The answer is definitely yes.
The EPA representative that met with Supervisor Nestande and me on December 3rd
admitted that there are alternatives. Given that other alternatives could be
considered, why is there such reluctance to publicly consider them? SAWPA's
stake in the proposed project is one answer. There are others, perhaps, whose
support of the proposed project and opposition to alternatives is fixed. To
approve alternative approaches which may yield a much more effective solution
to the problem faced by the citizens of Riverside County is inexcusable.
Certainly the citizens of Orange County and Riverside County deserve better.
At the December 12th meeting of the OCSD I argued for the rejection of further
consideration of SAWPA's proposal until a full EIR was prepared. This in
necessary for the protection of Orange County citizens and vital to the
citizens of all affected counties to insure that the best solution is selected
as quickly as possible.
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Page 5
December 19, 1984
I have serious doubts that the current EPA/DOHS/SAWPA proposal is the most
effective possible. Some of the several alternatives that a full EIR could
explore are as follows:
a. Extend the retaining wall just south of the Stringfellow site to
prevent hazardous materials from seeping around it. This alternative
could be considered in combination with the construction of a second
retaining wall as a second line of defense against seepage. This is
probably not a good long-term solution since ground water will still
flow into the toxic soils.
b. Construct a barrier wall north of the site to divert the clean ground
water from flowing through the toxic soils at the site. This could
be considered in combination with the construction of a series of
wells to collect clean ground water before it enters the site and use
this clean ground water for local municipal purposes in Riverside/San
Bernardino counties.
C. In combination with alternatives (a) and/or (b) above, excavate the
hazardous soils from the Stringfellow site, and dispose of it as in
the McColl site cleanup. This is likely to be the most expensive
alternative. However, it is the most positive way to insure an
effective solution. The toxic soils must be removed to prevent
contamination of ground water in that area and beyond. There is no
justification for delaying this excavation. Band aid approaches such
as the current proposal can only be of interest to those who have a
financial interest in long-term studies and projects, not to those
who want the problem effectively solved now.
d. If EPA and DOHS insist on using the proposed methodology of
pretreatment and discharge into a publicly owned sewer treatment
facility, there is an alternative to Orange County. That alternative
would be to truck the pre-treated waste water to the beginning of the
Los Angeles County County Sanitation District's line. The Los
Angeles line runs in the vicinity of the Stringfellow site according
to one source. If this was done, there would be a guarantee that the
intended destination of the waste water is the ocean not the ground
water table because the Los Angeles system apparently does not have
the water reclamation capability that Orange County has in Water
Factory 21.
In sum, it is strongly urged that the Orange County Board of Supervisors take
every step possible to insure full public disclosure and participation and to
seek the immediate consideration of alternative solutions by EPA and DOHS.
Presently, this Board's options are limited. I respectfully request that this
Board seek to effect a change in direction regarding the proposed Stringfellow
Page 6
December 19, 1984
project at the highest level of state and federal government. As an immediate
step, this Board may consider legal action and/or the scheduling of a formal
public hearing.
Recommendations:
1. Direct Chairman Wieder to send a second letter to the California
Department of Health Services (DOHS) requesting the preparation of a full
Environmental Impact Report (EIR) before Stringfellow hazardous waste
water is discharged into the Orange County sewer system.
2. In the event that the DOHS responds negatively (or fails to respond) to
the Chairman's request by the end of the second week of January 1985,
direct Supervisors Stanton and Nestande to co-chair a public information
forum to be scheduled approximately 45 days from now.
Res ectfully submitted,
Roger R. Stanton
Supervisor, First District
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SAC'ftAMENTO ADDRESS CHAIHMAN, ASSEMBLY PUBLIC
Sl"ATE CAPITOL Q EMPLOYEES AND RETIREMENT '1*
SACRAMENTO,CALIFORNIA 95814 COMJOMITTEE
(916)445-7454 ���jjj CHAIRMAN. INT LEGISLATIVE
I ffo
� � CAUCUS ON PORTS AND
1 �is t a NAVIGATION
ABROADSI OFFICE CHAIRMAN,SLATE TEACHERS'
245•,., BROADWAY,SUI iE 3O0 RETIREMENT SYSTEM TASK FORCE
LONG BEACH,CALIFORNIA 90802
(213)590-5009 —`; MEMBER:
ASSEMBLY REVENUE AND
(213)590-5300 ` • TAXATION COMMITTEE
ASSEMBLY WAYS AND MEANS
638 SO. BEACON STREET,SUITE 307 t j ,Lr,a COMMITTEE
SAN PEDRO,CALIFORNIA 90731 ASSEMBLY WAYS AND MEANS
(213)548-7991 SUBCOMMITTEE ON COMPENSATION
AND RETIREMENT
DAVE ELDER JOINT COMMITTEE ON
PUBLIC PENSION FUND
ASSEMBLYMAN, FIFTY-SEVENTH DISTRICT INVESTMENTS
REPRESENTING LONG BEACH,SAN PEDRO,WILMINGTON SELECT COMMITTEE ON
INTERNATIONAL TRADE,
INVESTMENT AND TOURISM
COMMISSION FOR '
August 3 , 1984 ECONOMIC DEVELOPMENT
fir,
Honorable Jack Kelly, Mayor
and Members of the City Council JJ
City of Huntington Beach
2000 Main Street
Huntington Beach, California 92648
Dear Mayor Kelly and
Members of the City Council:
7,B "3966 makes it possible to clean up toxic waste sites promptly
and at no :significant cost to local agencies.
Knowing of your particular concern relative to toxic waste
abatement, I have enclosed a copy of my AB 3966 . This measure
allows the Community Redevelopment Law of California to be used
in cleaning up toxic waste sites.
Basically, this is how cleanup would work under AB 3966 :
1. A city or county would form or enlarge a redevelopment
area pursuant to the Community Redevelopment Law.
2 . It would sell bonds and the proceeds from the bond sale
would be used to finance the clean up of toxic waste
sites.
3. As a result of cleaning up the site , property values in
the project-area vicinity would increase.
4 . The increased property values within the redevelopment
area (tax increment) would generate more property tax
revenues which wculd' be dedicated by law to paying off
the bonds.
Page 2
From the above, you can see that the benefited properties would
pay for the cleanup , but only through the process of having to
pay increased property taxes which would only result if the
values actually increased.
If the bill is of interest to you, please indicate your support
for this measure by contacting my Sacramento office and sending a
letter of support from your agency in order that it may- be noted
when the bill is heard in the Senate Finance Committee on August
13 , 1984 .
Your timely response will greatly enhance the possible passage of
AB 3966.
Sind ely,
ELDER
Assemblyman, 57th District
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Enclosure