HomeMy WebLinkAboutMINUTES - 05201997 - C81 Contra
TO: BOARD OF SUPERVISORS WJIa
FROM: WATER COMMITTEE C U*
SUPERVISOR GAYLE B. UILKEMA, CHAIR
SUPERVISOR JOE CANCIAMILLA
DATE: May 20, 1997
SUBJECT: REPORT FROM WATER COMMITTEE ON SAN LUIS DRAIN ISSUES
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
1)AUTHORIZE Chair to sign letters to the U.S. Bureau of Reclamation and the San Luis-Delta Mendota Water
Authority opposing renegotiation of provisions of the Use Agreement for the Grasslands Bypass to increase
discharges of selenium to the San Joaquin River.
2)AUTHORIZE the expenditure of a maximum of$15,000 of Water Agency funds ($10,000 initially, plus an
additional $5,000 if necessary) to support a cooperatively-funded U.S. Geological Survey study of the
selenium impacts of a completed San Luis Drain.
REASONS FOR RECOMMENDATIONS
Grasslands Bypass Letters: Contra Costa County has a history of interest in the Grasslands Bypass
Project, including on-going litigation and numerous letters of concern. After six months of Grasslands
Bypass operation, it has become clear that not all parties involved in the project interpret the selenium
discharge targets in the same way. Though these targets are based on past monitoring data which
measured total selenium discharge from all sources, some have argued that the targets should only
pertain to selenium originating from regular agricultural activity and should not include selenium from
creeks or rain-generated farm runoff. Contra Costa County has previously expressed concern with the
inadequacy of the selenium targets to protect water quality downstream of the project. These
concerns were based on the insufficient assurance provided by discharge "targets" as well as the
likelihood that the altered drainage flow pathway would increase selenium transport to the San Joaquin
River. Any reinterpretation or renegotiation of the selenium targets described in the Grasslands Bypass
CONTINUED ON ATTACHMENT: X YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR X RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S):
Su visor Gayle ilkema, Chair per isor Joe Canciamilla
ACTION OF BOARD ON May 20, 1997 APPROVED AS RECOMMENDED X OTHER
VOTE OF SUPERVISORS
X UNANIMOUS (ABSENT District III I HEREBY CERTIFY THAT THIS IS A TRUE
AYES: NOES: . AND CORRECT COPY OF AN ACTION
ABSENT: District IIIABSTAIN: TAKEN AND ENTERED ON THE MINUTES
OF THE BOARD OF SUPERVISORS
ON THE DATE SHOWN.
Contact: John Kopchik (510) 335-1227
cc: Community Development Department ATTESTED May 20, 1997
County Counsel, Diana Silver PHIL BATCHELOR, CLERK OF THE
Auditor-Controller - BOARD OF SUPERVISORS AND
Building Inspection/CDD, David Joslin COUNTY ADMINISTRATOR
BY: , DEPUTY
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Board Order
Water Committee
Report from Water Committee on San Luis Drain Issues
May 20, 1997
- Page 2 -
REASONS FOR RECOMMENDATIONS (CON'D)
Use Agreement to exempt some types of selenium discharge would: enable selenium discharges to the
San Joaquin River to exceed pre-project levels without penalty of any kind; weaken the termination
provisions of the project and allow continued operation even when discharges exceed pre-project levels
by more than 20%; and aggravate existing concerns of Contra Costa County with this project.
Attachments: 1) April 30 staff report with additional background on this matter; 2) text of letters
II. Selenium Study: The U.S. Geological Survey ("USGS") has proposed a study of the selenium
impacts of a completed San Luis Drain Project. The study would build on existing knowledge of
selenium chemistry and its biological interactions to assess potential impacts to fish and wildlife caused
by additional discharge of selenium to the Delta by the proposed San Luis Drain. The overall cost of
the entire study is estimated to be $50,000. The U.S. Environmental Protection Agency and the
Contra Costa Water District will consider providing portions of the necessary funding.
As a litigant in the Sumner Peck case (which relates to the extension of the Drain to the Delta), as a
historical opponent to extension of the Drain to the Delta, and as a county with a significant interest
in maintaining all beneficial uses of the Delta, the County (and its Water Agency) could benefit from
the completion of the selenium study proposed by the USGS.
Attachments: 1) April 2 staff report with additional background on this matter; 2) USGS Study Proposal
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Contra Costa County Water Agency
Date: April 30, 1997
To: Board of Supervisors Water Committee
Supervisor Gayle B. Uilkema, Chair
Supervisor Joe Canciamilla
From: John Kopchik, Water Agency Staff
-
Re: Grasslands Bypass selenium discharges
As you know, Contra Costa County has a history of interest in the Grasslands Bypass Project,
including on-going litigation and numerous letters. Most recently,the Board of Supervisors issued
a letter to the U.S. Bureau of Reclamation (owners of the San Luis Drain/Grasslands Bypass) and
to the San Luis Delta-Mendota Water Authority (representatives of the farmers who use the
Grasslands Bypass) expressing concern with the operation of the project during rain storms this
January. During the storm,drainage water was mingled with creek flows and discharged in a manner
which makes selenium monitoring difficult. The January storm event, and the drainers' plans to
operate the Bypass in a similar manner during future storms, created some controversy and lead to
a number of meetings on the subject. As a result of these discussions, it has become clear that the
drainers have a different interpretation of the selenium discharge targets (which they agreed to up-
front and which are supposed to be a key feature of this project)than most others who have read the
document.
One expressed intent of the Grasslands Bypass Project is to ensure that water quality in the San
Joaquin River is no worse with the project than it was without it, and the selenium discharge targets
were intended to ensure this (the County has disputed the concept that "targets" can "ensure"
anything,but that is a separate issue). The specific targets were determined by averaging 11 years
of monitoring data on total selenium discharge to the river prior to project initiation. This data on
total selenium discharge includes not only selenium originating from agricultural drainage activities,
but also selenium originating from creeks and rainfall. The drainer's assert that the selenium targets
apply only to selenium from drainage activities, not to other sources of selenium. If the drainers'
interpretation is accepted--and there is some indication that they would like to formalize this
understanding--then it would be possible for total selenium discharges to the San Joaquin River to
significantly exceed pre-project discharges without penalty or repercussion of any kind.
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1
The Board of Supervisors Contra ����
County Administration BuildingCOSta Cou ty�'n'�r
651 Pine Street, Room 106 (5io)336-19M
Martinez,California 94553-1293 C O u n ty
Jim Ropers,1st DisUict
Gayle B.Uilkama,2nd District
--\Donne Garber,3rd District •:l;•% /�_
(lark DeSsulnier,4th District M: --
Joe Canciamilla,5th District
oSrAcootiT' �
May 20, 1997
Mr. Roger Patterson,Regional Director (same letter to Dan Nelson, SLDMWA)
United States Bureau of Reclamation
2800 Cottage Way
Sacramento, CA 95825
Re: Reinterpretation or renegotiation of the selenium discharge targets for the Grasslands
Bypass Project
Dear Mr. Patterson:
As you know, Contra Costa County has a history of interest in the Grasslands Bypass Project,
including on-going litigation and numerous letters of concern. After six months of Grasslands
Bypass operation, it has become clear that not all parties involved in the project interpret the
selenium discharge targets in the same way. Though these targets are based on past monitoring data
which measured total selenium discharge from all sources, some have argued that the targets should
only pertain to selenium originating from regular agricultural activity and should not include
selenium from creeks or rain-generated farm runoff. Contra Costa County has previously expressed
concern with the inadequacy of the selenium targets to protect water quality downstream of the
project. These concerns were based on the insufficient assurance provided by discharge "targets"
as well as the likelihood that the altered drainage flow pathway would increase selenium transport
to the San Joaquin River. Any reinterpretation or renegotiation of the selenium targets described in
the Grasslands Bypass Use Agreement to exempt some types of selenium discharge would: enable
selenium discharges to the San Joaquin River to exceed pre-project levels without penalty of any
kind; weaken the termination provisions of the project and allow continued operation even when
discharges exceed pre-project levels by more than 20%; and aggravate existing concerns of Contra
Costa County with this project.
Thank you for accepting the comments of Contra Costa County and the Contra Costa County Water
Agency on this matter. If you have any questions,please contact John Kopchik at (510) 335-1227.
Sincerely,
Mark DeSaulnier
Chair, Contra Costa County Board of Supervisors
Ex-officio Chair, Contra Costa County Water Agency
cc: Laurens Silver,Esq. MD/X H:\\Jkopc-01d1gbreneg.1et
Contra Costa County Water Agency
Date: April 2, 1997
To: Roberta Goulart, Executive Officer
From: John Kopchik S__
Re: Report on Proposed Selenium Study for April 7 Water Committee Meeting
The U.S. Geological Survey("USGS")has proposed a study of the selenium impacts of a completed
San Luis Drain Project. The Environmental Defense Fund has worked closely with the USGS and
with staff at the County Water Agency, Contra Costa Water District, the U.S. Environmental
Protection Agency, and other agencies to coordinate the initiation and refinement of this proposal
and to explore possible sources of funding. The overall cost of the entire study is estimated to be
$50,000. A copy of the proposal is attached.
Overview: The study proposed by the USGS would build on existing knowledge of selenium
chemistry and its biological interactions to assess potential impacts to fish and wildlife caused by
extension of the San Luis Drain to the Delta. A range of-possible selenium discharges from the
proposed Drain would be evaluated by modeling: 1) the behavior of this selenium in the water
column (where it travels, how it dilutes, and how it changes chemically [selenium can be either
dissolved or suspended and can also change its molecular structure--some forms of selenium are
more harmful than others); 2)the absorption of selenium by plankton and other microorganisms; 3)
the accumulation of selenium in clams caused by the consumption of plankton (and, to a lesser
degree, by the direct absorption of selenium in the water); 4) the accumulation of selenium in key
species of fish and wildlife which prey on the clams; 5) the adverse impacts, if any, to these key
species of fish and wildlife caused by the predicted level of selenium accumulation. Current
concentrations of selenium in estuary are considered a baseline condition to which selenium from
the proposed Drain would be added.
Products: The proposal submitted by the USGS divides the project into three phases with one or
more products and a cost estimate designated for each. Phase 1 has an estimated cost of$12,000
and would include a short written paper to explain the proposed methodology in detail, to describe
the background literature which has been assembled,and to work through one example of the model
(a representative drain discharge would be evaluated using representative assumptions in the five
modeling steps described above). Phase 2 has an estimated cost of$22,000 (including $5000 to
support peer review of the study by a scientific advisory panel) and would include data collection
and analysis, development of model parameters,oral presentation on the model and its projections,
and a written copy of the data and graphics used in the oral presentation. Phase 3 has an estimated
cost of$16,000 and would include a detailed, final written report documenting all aspects of the
study. An optional fourth phase could involve the development or evaluation of proposals for
additional studies to narrow the uncertainties in the model projections.
Relation to the interests of the County: As a litigant in the Sumner Peck case(which relates to the
extension of the Drain to the Delta), as a historical opponent to extension of the Drain to the Delta,
and as a county with a significant interest in maintaining all beneficial uses of the Delta, the County
(and its Water Agency) could benefit from the completion of the selenium study proposed by the
USGS. The County and its Agency have previously sponsored a study of potential impacts of the
San Luis Drain(Metcalf and Eddy Engineers completed a comprehensive study in 1964 which we
continue to use),but this study predated Kesterson and awareness of the selenium threat. As a result
of evolving scientific understanding,the fate of the San Luis Drain is probably linked more closely
with selenium than with any other environmental impact.
Westlands Water District has hired a team of scientists to evaluate the Drain's selenium impacts,and
in their testimony before the State Water Resources Control Board last year, the scientists argued
that selenium impacts would be small because the large quantities of water in the Delta would dilute
selenium and result in low selenium concentrations. The USGS study will examine the assumptions
that underlie this finding(namely,that selenium concentration is a reliable indicator of impact--parts
of the Delta are already declared selenium hot spots [for fishing/hunting] with hazardous levels of
selenium in fish and birds despite water concentrations are extremely low) and will help ensure that
the environmental impacts of the proposed Drain are accurately identified.
The results of the proposed USGS study may also have some indirect implications for more general
water quality issues,in particular, the appropriateness of regulating bioaccumulating substances like
selenium by concentration rather than by mass discharge. Such insights could effect not only the
regulation of the San Luis Drain,but also the regulation of many agricultural discharges (including
those from the Grasslands Bypass--another object of County litigation) and many industrial
discharges (including the selenium discharges of oil refineries in the County).
Potential funding sources: EPA staff have already requested $30,000 to support this project.
Contra Costa Water District may consider contributing $10,000.
Recommendation: For the reasons outlined at the top of this page, staff recommends that the
County provide financial support to this project. Board members could consider a contribution of
$10,000 to cover the likely funding shortfall, or could also consider providing up to $15,000 (one
third of the cost of the project not including the costs of the peer review process [this expense may
be born more appropriately by a federal agency]), as a contingency measure in the event that the
EPA is unable to contribute the full $30,000. Staff recommends that the Board allocate $15,000 to
the study to provide for this contingency.
I hope this information is helpful. Please call me at 335-1227 if you have any questions.
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EFk'ECTS OF SELENIUM DISCHARGES INTO SAN FRANCISCO BAY
FROM THE PROPOSED SAN LUIS DRAIN:BIOACCUMULA110N AND
BIOEFFECTS AT UPPER AND LOWER IDM OF DISCHARGE.
Samuel N.Luoma 3/5/97
Theresa S.Presser
US geological Survey.MS 465
345 Middlefield Road,Menlo Park,CA 94025
OBJECTIVE
Understanding the biotransfer and bioaccunmlation of selenium is essential to ievatuating the fate
and Impact of proposed changes in se3enium discharges to the San Francisco estuary. The study
desenbed here will use existing knowledge to model the biotransfer of selenium to clams(as
Indicator species)and then to predators,such as waterfowl and fish,in order to assess potential
adverse impacts on the predators. Siotransfer will be determined far different scenarios for
selenium meas discharge to Suisun Bay,using as one example the selenium loading proposed
through the extension of the San Luis Drain to an outfall now Chipps Island.
BACKGROUND
During the next few years,federal and state agemci=may be required to evaluate prWsals and
discharge permits that could significantly change selenium inputs to the San ltraneisco estuary,
particularly in Suisun Bay.'These proposab may tnclude,for example,an extension of the San
Luis Drain to the estuary to convey subsurface agricultural drainage ftm the west side of the San
Joaquin Valley,a renewal of the agreement to allow the epdsting portion of the San Luis brain to
oonvey subsurface agricultural drainage to a San Joaquin River tributary(coincident with
changes in flow patterns of the lower San Joaquin River)and sefinemmu to the xite-specific
selenium water quality standard for the estuary. Each of these proposals would ultimately require
that a decision be made concerning tate acceptable level of Wenlum discharge to the estuary.
The purpose of this study is to provide iusiglu into the scientific questions that will Vise as a
result of these proposals,particularly with respect to the substantial additional discharge loads
than may be involved, To this end,aro will use the results of existing monitoring prograrns and
peas-reviewed research to help answer the following questions for the nmthern portion of the San
Francisco estuary:First,will the animals in the estuary be protected frum advemc effocts if dw
only limit placed on discharge is the Sugg numerical water quality stauderd for selenium?
Second,what method can be used to relate into the estuary(arid the
resulting average concentrations of selenium in die estuary)to effeo4a an animals in the estuarine
food web?Tbdrd,what ranges of load limits on selenium discharges(arid corrasponding ranges of
selenium concontrations in the estuary)vmuld avoid adverse effects on%ese consumers?And
finally,what targeted studies would most effectively narrow limits of confidence for the
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prediction of effects? In the process of helping to answer these questions,the results of
considerable receut research and field data that apply specifically W the Sae Frawwm estuary
will be assembled and analyzed in a fbr=we think will be usefW to decision-makers in other
federal and state agencies.
The reason that these questions are relevant scientifically is that standard approaches to assessing
the effects of mass emissions of trace elements have important deflclenetes. In the case of the
proposal to extend the San Luis Drain to Suisun Bay,for example, simple dilution models are
employed to calculate concentrations of selenium that will rerun From projected mass emissions
Into the bay. Then those concentrations are matched against nume doal water quality standards.
One source of uncertainty robe wt in this prooedure is the dilution model itself, Coneaat models
may ootWder the dilution water available,but they Have not fnily c onsidstefd tie complexities of
(1)biological reactions of selenium and(2)the estuary as a bioprodactive reooiving water
(Presser at al, 1996,presser and Pipe,in press). In particular,existing models do not account for
Oc effects of(1)the different distributions of the selenium load between dissolved(water-borne)
selenium and particulate(food borne)$actions of the eleameut,although such fractionation will
be an important characteristic of the emissions,(2)the different reside=nce times of particular
phases and species of selenium under different flow regimes,(3)the different e%posure times of
organisms to the distributed selenium load,grid(4)the historical background mass load existing
in the estuary.
Anodw major source of uncertainty is that tau BPA standards(upon which the currmitly
applicable standards are based)were derived from water-only,short-term exposures of surrogate
species,combined with the limited field data on food chain exposure that was available at the
time. Recent studies show that selenium is efficiently transferred in North Sea Francisco Bay
Cincluding Suisun Bay)via selenium uptake from solution by phytoplankton,biotransformation.
to organo-selenium within the plant oells,biosocumulation of the orgtrno-selenium from
suspended food by bivalves and uptake via food by predator species that ingest the bivalves
(Luoma at a1, 1992;Luoma et a1,1996). Bioaccumulation models show that direct transfer of
selcalum from solution to animals such as flab and bivalves is a vcay small proportion(<$Vo)of
the exposure these animals receive in the ecosystem his a result,traditional toxicity tests can be
misleading if they determine toxicity only via direct water-borne exposures;uptake of dissolved
selenium is not a eigaifleant pathway of biotransfer to animals in North Bay. Moreover,bwause
selenium concentrations are magnified at every step of food web transfer,upper trophic level
spocies are probably the species moat vulnerable to adverse effects from selenium contaminatim
effects on these species are not considered in die traditional toxicity tests. Analyses in 1986-
1990(Calif.Fish and Game,Selenium Verification Studies)showed that the animals with the
highest selenium conomtratiaons from Suisun and San Pablo Bays all ingested bli►atves as a major
component of ftir diet (watcfffowl such as scoter and scaup;bottom feeding fish including
sturgeon and flounder;dungeness crab). Thus the specific bioaccunulation pathway from
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phytoplankton to bivalves to predators is not only ef5eietl%h may be the most important route of
selenium transfer to upper trophic levels is the North Bay ecosystem. In abort,cwWrable
research undertaken since 1987 indi:catos that a selenium standard derived primarily from food
web Mosm would be most w1evant to actual conditions in the estuary.
Uncertainties about how partitioning(distribWan beCcvm particles and solution)and speciation
(e.g.different oxidation states)affect the bioavailability and bioegocts of selenium has limited
the use of multiple pathway approaches in setting etvirowneotal standards. In recent years,
however,pathway bloaccumulstion modals have been&-veloped that allow ooneideration of
biotransfer from different types ofprdculatee and different s wwdon regimes(Lwma et al,
1992;Luome and Fisher,in press).Ile models and acoompanymg experimental mudies have
helped resolve some long-standing questions about selenium bioavailability. Although the
experimental data are not yet available for all species,enough knowledge exists tn allow s1w
specific"range-fin&W modeling efforts of selenium Otte,from spe6atiou tluough
bioacctunulation,for Suisun Bay and North San Frnnoieco Say.
Building upon these significant advances in seiendfie understanding,here we propose an
alternative approach to assossing etffocfr ofmasa emission levels of selenium into San Francisco
Bey.The approach involves using existing knowledge,that includes empirical observations from
the Bay and models.to Gomvert proposed mass wnissions.to concentrations in receiving waters,
under several scenarios. Bioeccumulation in lower trophio level consurner organisms(bivalves)
will be projected fk+om a blely range of concentration,partitioning and speciation seenarios using
pathway bioaccumulation models. Concentrations in a flew key predators will be predicted Brom
correlations with bivalve tissue concentrations of selenium derived from the existing literature.
Because relationships betwcan tissue oottcentradons and adverse effects are relatively well
constrained for selenium in wildlife,predictions of tissue residues in,waterfowl and fish should
provide a fust order estimate of potential adverse eftots of selenium mass emissions.
SCOPE
Eight factors must be considered in scenarios designed to estimate the range of seletuvm
bloaccumulation by wildlife from projected mass loadings of selenium to Sen Francisco Bay:
I.For the discharge:
L mass loadings;
b,diasolvedfpartic�ulatc fractionation of rho load.
2.In the receiving waarr:
a.resulting eoncentrstions in reeciving waters,suspended particulate material and
sediments at a given mass discharge;
b.partitioning between dissolved and particulate forme;
c.speciation within both dissolved and particulate forns;
d.bioaccurnulation by bivalves via both dissolved and particulate pathways under
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different concentration,partitioning and speciation regimts;
e.biotrausfer of selenium from bivalves to key predators;
L projection of adverse effects of selaoium that will result from the projected biotransfer.
Models and at least some data are available to project feasible ranges for each of their factors in
San Francisco Day,using the example of the loadings from*e proposed Sim i uls Drain. It is
possible to project the range ofbjoaoeumutated selediurn concentrations that could occur from
the moot optimistic to ills least optimistic Scenarios with rgprd to dilution,portitioaing,
speciation and bioavailability.While we will leave the decision about'safe"levels of selenium
discharge to our regulatory parbm,this approach should allow a more realistic estimation of the
range of risks to wildlife that cobld result from various selenium discharges. Uncertainties exist
in all aspects of the exluf ng data,that is why this is proposed as a range-finding exercise. An
important part of the study will be to de#tne the higbwt pdorities for additional study in order to
narrow unca%aWties. Once applied to selentum as an example,the study might provide a model
for evaluating other discharges to the estuary. It should also provide information awful for site-
specific selenium criteria and an example of how to evaluate mass emissions of otter elements.
APPROACH
PRESENT CONDITIONS:Any discharges from the Sat Luis Drain will add selenium to an
existing condition. Existing conditions in North San Fra wisco Bay are relatively well Imown
(better thaw for other trace elements)for selenium concentrations,partitioning,speaiadon and
bioaccumulation,based upon a number of studies published since 1989(Cutter, 1988;Johns et
a1, 1989;Luoma et a1, 1992;Luoma et a%1996). Existing conditions will be employed as the
baseline to which additional discharges are added and aspects of the existing eoa tions will be
employed to project some scenarios. Scenarios for changes in existing conditions eventually
could be added to the projections.
PROJECTION OP MASS LOADINGS: A projection of mass loadings from the Thain will be
calculated from testimony already provided by Westlands Water District,Ibis projection will be
used as the basis for constructing four realistic ScetariAs across the range of possibilities.
Eventually, scenarios might include efteou ofhotors each as cbanging delta inflows to the Day,
changing inputs from the San Joaquin River or occasional sediment resuspension from the drain.
PARTITIONING VV THE DISCSARGE. The mass emiaaions will,be constructed ftm several
feasible disaolvvd/particula%partitioning scenarIoL For example.suspended load scenarlos
might range from 0 mg/t suspended particulate to- 00 mg/L A Mange of feasible concentrations
in suspended particulates can be constructed from available data.
CONCENT 27ONS I1V JWCEIVI74►G WATERS: Projections$+oro dilution models may be
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used as cru basis for prediedng resultant oonoentrations m reeving waters. An additional
.acanario can be constructed employing dilutions observed in the field at existing levels of
selenium discharges(fat example from the refineries)to Suisun Bay.under diff;Brent flow
regimes.
PARTWOAWVG AND SPECL4770NIN•d?ECF.I7?1!'G WATERS:Scenarios forpartMotAng
between particulate and dissolved forms in receiving wags will be estimated from obseevations
ofpartitioning in discharges,and from the range of partitioning behaviors observed in the Suisun
Bay under different flow conditions.Scenarios for speciation between seleoate,setenitc and -
organo-selmium in solution will be sadmated based upon behavior and kinetics in the bey,as
will speciation between inorganic and organo-selenium fa=associated with particulate
aiaterial.s_
PAOJECTION OF BED SEDIMPM 2NTW CTION.A range of scenarios estimating how
sediments might accumulate selenium could be oonstrmcted from historical ba ftround
concentrations of selenium in North San Francisco Bay bottom sediments,from natural
background concentrations for this specific site, and fbom sedimentary selenium wumulation in
other areas exposod to flowing selenfuam-cmieW agdoulturxl drainage water.
BIOACCVMVL4TIO?V- Biowcumulation will be calculated for three of the p e&rninant
bivalves in North Bay(the clams Corbicula flumfnea,Poi4mocorbula amwVPwis and Macoma
balthica)udag generic coefficients and a simple pathway bioaacumulation r4del(see Luoma et
al(1992)and Wang at al(1996). Species-specific data are available to model bioaccumulation
in M. balrhica. TU model will be adjusted for species-specific uptake for the othet species
based upon field bioaccumulation comparisons and known aspects of the bcha-v for of earl
animal.
MODEL PROJEC77ONS. The above scenarios will result in several hundred model
projections. One presentation of the data will incWc plotting elm*%of model outcomes as a
ftmetion of the variables of interest(k wlinv.pardtitming,speciation)'m simple two dimensional
plots,in order to illustrate the influences of the different scenarios.
PROJECTIONS TO UPPER TROPWClAVIilS: Empirical data is available to relate
tissue concentrations of selenium in bivalves to tissues residues in at least two species of
waterfowl and fish tinatonod by selenium in San Francisco Day. Such correlation data u W be
employed to predict upper trophic level exposures uodar ditfervA discharge scenarios. Only
those upper t o*o level species most vulnerable to selenium 000ntamination will be considered,
iaitiany.
PROJECTIONS OFADMRSE EFFECTS: Existing data that relate tissue residues in wildlife
to efforts,and existing information about effects on local species.will be employed to estimate
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sad describe any impacts or lade of imperils on the most vulnerable species in the em ary.
MUNT INCA.MS'ORYPAN.BL.•USO3S requests that a small science advisory oommittee be
oomstitutcd that would include a variety of knowledgeabla scientists,primarily ftom odw federal
agencies.The'role of the committee would be to provide feedback to USQS on the technical And
scientific camponems of the study,such as the conceptual model,selection of parameters for
different wanarlos,and the like.(Please Dobe that input on Haase strictly technical and scientific.
issues will not be solicited directly fram non-federal fimdars once the scope of work for this
otudy has been agreed upon.) USGS will select committee members following eomdtation with
titndere and other appropriate agencies and irtstwtudcrns.
PRODUCTS
The study will be comprised of three phases,with products and milestones produced at the end of
each phase.
PJUSE L The first phase of the study will provide a short(-C10 pages)smitten paper. The goal of
the intrtAuctory paper is to explain in detail.but in understandable krama,the supporting basis for
the proposed approach for evaluating selenium discharges to the unuary. The supporting
literature will be assembled and described,and the approach proposed above a ill be contrasted to
the approach employed to derive the existing selenium criteria. The paper wilt also work through
one example in order to broadly validate the modeling approach. A&awetioal discbarge will be
evaluated that represents one scenario relating to the currently-proposad disobarge from the San
Luis Drain;outcomes of that discharge will be calculated in the bioacsumulation curd affects
terms described above;and predictions will be evaluated relative to available held data. 'Me
draft paper will be submitted to the scientific advisory panel for review prior to proN iding the
MW paper to die furriers. Estimated cost:S 12.000. Timeline:Within two moaths of when
Amding is procured
PX�iSE Il. In the second study phase appropriate data will be assembled,lirt'dts to the feasibility
of the modeling approach will be evaluated and a range of fowible values will be developed for
each of the eight parameters. Projections of selenium bioaccumulation(bivalves and two upper
trophic level species)will then be determined You three end-member somarios(high exposure,
intermediate exposure and low exposure)fur each of the parameters descn'bed above(several
hundred projections). As a mWpolat product,the range of values chosen in each factor will be
sumrmarited and presented to the science advisory committee for cotmments about whether the
choices are appropriate(do the choices of wmarim cover bosses flat are feasible or of
reasonable likelr'lnood?). As a final product for phase U,choices of scenarios,discussion of most
J&ely scenarios,Justification of values choses,and projections will be pramted orally to
the science advisory committee,the fimders,and then to othar interestod parties as deer W
appropriate. A limited data report will be developed to include only ju"cstions for the
6
9I/LO 'd 0£908990191 'ON M tiZ:60 INJ L6-10-M
0/0E/e7 10:53 041E 329 4538 USGS KMW PARx WUU6
9
parameters chosen fbt the prq{ections,tables ofprojeeted outcomes and a bard-copy of
interpretive graphics employed in the oral prose xtatiom Estimated vest:$22,000;includes
$5000 for travel for science adviarnz.Timeline:6 months after phase.;mid-point product-3
months. '
PHASE III. The tbird phase wM biclude a detailed And written report desen'bing the outcomes of
the study in terms of bioaecumulation risks to the species considered,a detailed discussion of the
supporting literature,a discussion of the highest priority sdditioaal studies that are needed to
naaow uncertainties in projections(including stets of limiting pathway%of selenium
biouvmler). H justified the study could discuss study needs end general applications of the
approach in regulating mass discharges of tutee elements. 'this study will be publiabod as an
USGS Open File Report,and Also as an open literature publication,if justified. Some
modifications to the scenarios and lirther modoling of a limited scope could be inoluded in this
&W report(possible examples include anilyde of alternative pathways,changing existing
conditions,wider range of biogeochemical possibilities,more detailed hydrodynamic influences
on dilution,effects of changing deka intlows). Estimated cost:$16,000. 'Timeline: 3 months
aft phase U.
PHASE IV.The final phase could involve development of proposals(or evaluation of proposals)
far studies that would narrow the uncertainties in the projomions. The scope,activities and costs
of this phase can be planned is collaboration with the science advisars and the fuudets.
REFERENCES
CUTTER,G.A.,1989,The estuarine behavior of selenium in San Francisoo Bay.FAftu rine,
Coastal and Shelf Science,v.28,p. 13-34.
JOHNS,C.E,LUOMA,S.N.AND ELROD,V., 1988,Selenium accumulation in band is
bivalves and fine sediments of San Francisco Bay,the Sacramento-San Joaquin Delta,and
selected tributaries:Estuarine,Coastal and Shelf Science,v.27,p.381-396.
LUOMA, S.N.&N.S.FISHER Uncertainties in assessing contaminant exposure fi-om
sediments:$ioavail"ty. In Ecologies]Risk Assessment of Contamimated Sediments,Edited
by Q.Biddiager&T.Dillon,SETAC Press,Pensacola,FL,in press.
LUOMA,S.N..C.JOHNS,N.S.FISHER,N.A.S'IMMERG,R 8 OPX%C ND&J.
REINF'ELDER, 1992. De urination of selenium bioavailability to a benthic bivalve from
particulate and solute pathways.Envimn.ScL Tet hnol.,Vol.26,pp.485491.
LUOMA,S.N.,R.UNVII.LE,0.Cti11'Mk B-0.LEE,C.BROWN,1996.Diatribution,fate
and effects of selenium and related ceauaminants in North San Preacisco BayNelta and its
7
er ion 'i noonocon)ci nm vN.j
.rrta c��an t tt� ►a_i n_uu�.i
03/06/97 10;64 0415 329 4534 USGS WLA) YAKK
1W uud
benthic food web.Progress Repoat for CaL RegL Water Q,ul.Control Bd,Oakland,CA,60pp.
PRESSER,T.S.AND D.Z.PIPER,(in press).Mass belmme approach to selenium cycling
through the San Joaquin VaU y,sources to river to bsy,In The Envirnnmemal Chmustry of
Salcniun%(R.A.Epgmg&W.T.F=a*5nUW,eds).Marcel Dekker,New Yotk.
PRESSER,T.S.,M.A.SYLVESTER,N.B.DUBROVSKY AND R.J.HOFFMAN, 1996.
Review of the tar mUnd Bypass Cbsmel Mothoring Program,U.S.Geological Survey Admin
Rept.USGS,Menlo Park.
WANG,W-J{.,N.S.FISHER&S.N.LUOMA,1996,Kinetin tWeminatiom of trace element
bioacc))mulation in the mussel,Mytilu9 edulis. Mar.Ecol.Prog.Ser.,Vol 140,pp. 41-114.
8
91/60 'd DE909390191 ON m Q� 92:60 INJ L6-L0-mvw
The Board of SupervisorsCentra Phil Batchelor
Clerk o`the Board
Costa and County Administration Building Administrator
651 Pine Street, Room 106 (510)335-1900
Martinez, California 94553-1293 County
Jim Rogers,1 st District
Gayle B.Uilkema,2nd District Se L
Donna Gerber,3rd District
Mark DeSaulnier,4th District
Joe Canciamilla,5th District nE
9•. t'4
Sr'9 COUN'�
May 20, 1997
Mr. Daniel Nelson, Executive Director
San Luis &Delta-Mendota Water Authority
P.O. Box 2157
Los Banos, CA 93635
Re: Reinterpretation or renegotiation of the selenium discharge targets for the Grasslands
Bypass Project
Dear Mr. Nelson:
As you know, Contra Costa County has a history of interest in the Grasslands Bypass Project,
including on-going litigation and numerous letters of concern. After six months of Grasslands Bypass
operation, it has become clear that not all parties involved in the project interpret the selenium
discharge targets in the same way. Though these targets are based on past monitoring data which
measured total selenium discharge from all sources, some have argued that the targets should only
pertain to selenium originating from regular agricultural activity and should not include selenium from
creeks or rain-generated farm runoff. Contra Costa County has previously expressed concern with
the inadequacy of the selenium targets to protect water quality downstream of the project. These
concerns were based on the insufficient assurance provided by discharge "targets" as well as the
likelihood that the altered drainage flow pathway would increase selenium transport to the San
Joaquin River. Any reinterpretation or renegotiation of the selenium targets described in the
Grasslands Bypass Use Agreement to exempt some types of selenium discharge would: enable
selenium discharges to the San Joaquin River to exceed pre-project levels without penalty of any kind;
weaken the termination provisions of the project and allow continued operation even when discharges
exceed pre-project levels by more than 20%;and aggravate existing concerns of Contra Costa County
with this project.
Thank you for accepting the comments of Contra Costa County and the Contra Costa County Water
Agency on this matter. If you have any questions, please contact John Kopchik at (510) 335-1227,
Sincerely,
Mark DeSaulnier
Chair, Contra Costa County Board of Supervisors
Ex-officio Chair, Contra Costa County Water Agency
cc: Laurens Silver, Esq. MD/JK H:\\jkopc-old\gbreneg2.let
The Board of SupervisorsContra Phil Batchelor
Clerk of the Board
and
County,Administration Building Costa County Administrator
651 Pine Street, Room 106 (510)335-1900
Martinez, California 94553-1293 County
Jim Rogers,1st District
Gayle B.Uilkema,2nd District sE L
Donna Gerber,3rd District
Mark DeSaulnier,4th District
Joe Canciamilia,5th District o s
ST'q COUNT
May 20, 1997
Mr. Roger Patterson, Regional Director
United States Bureau of Reclamation
2800 Cottage Way
Sacramento, CA 95825
Re: Reinterpretation or renegotiation of the selenium discharge targets for the Grasslands
Bypass Project
Dear Mr. Patterson:
As you know, Contra Costa County has a history of interest in the Grasslands Bypass Project,
including on-going litigation and numerous letters of concern. After six months of Grasslands Bypass
operation, it has become clear that not all parties involved in the project interpret the selenium
discharge targets in the same way. Though these targets are based on past monitoring data which
measured total selenium discharge from all sources, some have argued that the targets should only
pertain to selenium originating from regular agricultural activity and should not include selenium from
creeks or rain-generated farm runoff. Contra Costa County has previously expressed concern with
the inadequacy of the selenium targets to protect water quality downstream of the project. These
concerns were based on the insufficient assurance provided by discharge "targets" as well as the
likelihood that the altered drainage flow pathway would increase selenium transport to the San
Joaquin River. Any reinterpretation or renegotiation of the selenium targets described in the
Grasslands Bypass Use Agreement to exempt some types of selenium discharge would: enable
selenium discharges to the San Joaquin River to exceed pre-project levels without penalty of any kind;
weaken the termination provisions of the project and allow continued operation even when discharges
exceed pre-project levels by more than 20%; and aggravate existing concerns of Contra Costa County
with this project.
Thank you for accepting the comments of Contra Costa County and the Contra Costa County Water
Agency on this matter. If you have any questions, please contact John Kopchik at (510) 335-1227.
Sincerely,
Mark DeSaulnier
Chair, Contra Costa County Board of Supervisors
Ex-officio Chair, Contra Costa County Water Agency
cc: Laurens Silver,Esq. MD/JK H:\ykopo-o 4breneg.►et