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City of Palo Alto
City Manager's Report
HONORABLE CITY COUNCIL
C1TI' MANAGER DEPARTMENT: PUBLIC WORKS
APiUL24, 1m CMR:217:9S
WASTEWATER RECLAMADON PROGRAM -FINDINGS
and RECOMMENDADONS
Ibis stiff repon requests thaI Council certify the Wasu:wa!l:r Reclamation Envirorunental
Impact Report (EIR). but suspend !he implementation of !he projects included ill the EIIt
It aL.w requests !hal Cooncil adopt. new Reclamation poo..--y.
bt view of !be wxenalnties will> respect 10 the need for additiooal reclamation. it is
recomIllended that !be e.;sdng reclaimed Il'lIler prcg.-.un DOt be expanded at !his time.
Pu!ure evaluation of !be individu2I projects in !be EIR. wooJd be triggered I:y the condi!ioos
outlined in Ibe Reclamation Policy of lIDs repon. The Planning Commission has laken
publk comments and reviewed and approved the draft ErR as adequate under CEQA.
CMR:.541:93, Oclober 21, 1993. referred the wastewater reclamation program 10 the
Utiliiies Advisory . Coouni"sion (U AC)· for study and recommendations. The
recommendation and !be Reclamation Policy ha ye been reviewed and approved by !be
UAC. Staff will bring back indhiduaJ pro.ie>cts for review by the UAC and C<>UllCll if and
wben an evaluation is ttiggered.
BECOMMENDADONS
Staff recommeilds that CooJncil:
I. CerUfy that the fu>.al Environmental Impact Report (ElR) has been =p1.1ed In
cOmpliance ,.1\h CEQA. and that iI reflects Ibe Independent judgment of 1M
Cooocil.
2. Suspend impIemelllation of any of the projects studied in the EIF~ and instead adopt
~ Reclamatioo Policy whick includes CODliJiuation of !be existing reclaimed water
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program and monitoring of the coodirion.< that would trigger the future eva.luatlon
of the proje<:ts studied in the ElR.
3. Di=t that at such time .. staff believes that conditions .;tis! which would trigger
further evaluation of the projects, slJlff will submlt sucb illfonnation 10 the Utilities
Advisory Commission for its review and r<=lll!Ilelldations p<lor 1D submittal of the
mat1er 10 the Council.
4. D'.rea staff 10 inform the U AC, and initiate the appropriate evaluations on any such
triggered project, and submit the evaluations fOr re.iew by the UAC and Council.
PQUCY IMPUCATIONS
The CiIy is finnIy rornmitted to prQ(eC! the environment. nsing the IIlO5! "iable and CCSl
effective approach. 1be Reclamation Policy is • new policy whicb embod'" tbis
commitmenL The Reclamation Policy is consisteDL with the Watershed Management
approach which calls Xl< the re-(.OOSidenOOn of waler quality SlaIIdards, p<lor 10 individual
project decisioos. where the ,uter quali!)' sta"da.'"<Is are faclorS in the decision making
procESs. The Reclamation Policy enumerates the conditions that would trigger furure
evaluation of !he iodividu.al projects included in the ElR.
The RecJaro.ationFo1icy is consistent wiIh the State policy, the Basin Plan fOr the Bay Area
communities, and Palo Alto's Cootprehensive Plan. Adoption of the Reclamation Polk,.
woo]d allow !he City 10 monitor and initial<: fulJ.lre evaluations as needed.
JOOiLlrtIyE Sl1MM.ARY
This staff report provides !he policy recommendations on the Program. The Program
pI.anning was initialed by the Regional Water Quality Control Pian! (R.WQCP) as a
requiremenl of !he partner cities 10 serve two objecliv",,:
I. To reduce metals discbarge 10 the Bay in <>rder to meet t,ie mass limit of the
RWQCP discbarge permit, and
2. To supplement !he water supply.
In 1994, the RWQCP mel the permitud mass limits as a result of the =mbined efforts of
sou.-ce control, in-pIant reduction. and the existing recl>marion. However. the R WQCP
<;aDIlOt gu.arantee f'JlJ.lre compfJaD<:e Xl< 1' .. 0 reasons. Fl1St. the permit limits are being re
evaluated and may change. Serond,!he RWQCP operated under very favorable Iow-tlow
<:Onditions ;" 1994. whicb mliy <bang. in the future. TherefOre. it is necessary 10 keep !he
rel:lamatlon program expansloo as an option for future re-<:valuation-
AooIber factor 10 consider is the ooncentratioo funit, which is aloo in the RWQCP permit.
Reclamation red'Jceo; ocly the mass dh;cbarge and will not reduc;" the discharge
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concentration. The c:oocentntion limil is also being re-evaluated at !his lime. More
information will be a".~.ble in the future for !be evaluation on the need for additional
reclamation. From the Wastew1!ter discbarge perspective, 00 finther reclamation p:oject
is recommended at !his lime, but iI is ne<:esSal)' 10 establish a policy which will enable
reclamation as an option for future permit compliance if reeded.
From the water supply pelSpective, curren! water demand is below the Cil)'" supply
capacily. The Utilities Departmenllniegrated Resource Plan identifled recl.amatioo as one
of several &Iternalives Ie supplement the future "'aler supply. AJ'.hough future demand
may exceed !he Ciiy's supply, l recelll martet survey does DO( indicate substanr:ial demand
for reclaimed water. Therefore. 110 reclamation project is recommended at !his time.
However. the City should include reclamation as an option for future waler supply
evarualkln.
The proposed Reclamation Policy sets the following guldefmes:
I . The RWQCP will maintaln the curreIJI reciamation p:ojects (Shoreline Park, Greer
Park. Palo Alto Golf Course. and ",ater !rUCk hydrants).
2. Evaluation of the projects covered in !be EIR coo!d.be mggered by the {Qj)owing
cooditions :
• Changes in the RWQCP discharge permit requirements
• Increased mass Ioad"mg 10 It .. It WQCP
• ~ by partner ageneies or OIher kx:aI agencies
• Availability of r.:dera! or other funds
• Supply side issues
JISCAI, IMPACT
The Program poses 00 fiscal impact 10 the CUffelll fiscal year siD<e 00 project is
recommended for irnplemenlation at !his time. The fJSCai impac:ts of the Program ... -ill be
addressed when, and if. a p:oject under the Progr".m is submitted for approval in the
future.
ENl'IBONMD.'TAI. AS$FSSMENT
All. envlroomental imp&ct repo;t (ElR) was prepared in OCCOfdance with CEQA. The Em
found llQ un-mitigable impact. The Utilities Advisory CooImission has reviewed and
rommented on the draft E1R. A public l.earing was held on December 14, 1994 before
the Planning Commission. The Planning Commission bas taken public commerus, and
reviewed and approved the draft EIR as adequate under CEQA. A copy of the tran.<c11pt
of the pu!>Iic bearing is altaCbed 10 !his staff repon.. The final EIJt. is also being submitted
COOCUITeIl!Iy 10 Council for certification.
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AUACBMENTS Transcript 0( Il!e Dec. H. 1994 public bearing
Fin31 Wasllowaler Reclzmatlon ElR
PREPARED BY: William D. Mila. Manager. Water Qua1ky Control i'Lm!
DEi'ARTMENTHEADREVIEW:-'::!A=:,...l~_J_. _~ _____ _
CITY MANAGER APPROVAL:: __ ~~~~~~~ ............. ,\-__ _
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City of Palo Alto
City Manager's Report
SVIUECT: RWQCP WasteWU6 R ... lamatioo Program -F1DdIngs and
Recommendations
BF.C(lMMENOATIONS
Staff ~ that Council:
I. ~ die final Env!romnenlaI Impact .Report (ElR) has been completed in
eompliance willi CEQA. and that it reflects die iDdepenIlenI: judgment 0( !he
Qlcmcil.
2. SuspeOO impIemenIalion of any 0( die projectl; srudie<I in the EIR, and m.tead adopt
• RllclamaOOn Policy which incluQes COIIliDuation of the existing reclaimed waler
program and monitoring of the condition> that would trigger the lilIure evaJua!ion
0( die projects SIlIdied in die EIR.
3. ou.u that at such time as staff believes that conditions e.'<isI whicll would trigger
fuitbCr cvalua!ioo of die projects. staff will submit such iDfonnatlon \0 the Utilities
Adviscxy Commission for iIs review and recommendatioos prior 10 submittal o(!he
matter 10 the CounciL
4. Direct slall 10 iDf<xm !he UAC and initiate die appropriate evaluations on !he
trigger project and submit !he evlih!alioos for review by !he UAC and Council.
BACKGROUND
The ~Iamation Program (Program) planning was initioted by die Regional Water Quality
C<XIIroI Plant (RWQCP) as I requirement 0( !he partner cities !O serve CWo oojectives:
I. To reduce meIaIs discbarge 10 !he Bay in order \0 meet !he mass limit 0( !he
RWQCP discbaIge permit require!llen!. and
2. :ro supplemenI the water supply.
The RWQCP discharge permit contains • mass limit and • CO!lC<Ontration limit on each
po!lutml. Amoog!he pollutants. the RWQCP has !he greatest difficWty in meeting !he
permit limits for C<lpper. The RWQCP reduces iIs metals discharge through !he combin<d
dJons of SOW<:e <:OIIIroI. in-plant reduction. and reclamation. Source COD1rol reduces the
coDl:elllration and, consequently, the mass of die metals in !he influent !O the pIaDL In-
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pIaDl reduction ~ the roncentration and the mass prior 10 discharge; bowever, the
r;:duction efficiency is deperdent on Ihe loading of the p\anl. Reclamation <livens the p1.an!
discIlarge for reuse and, benu, reduces the mass; bul this has 00 effect on the discharge
coocentration,
In I~, the RWQCP met the mas. limit lOr ropper as a result 0( the combined efforts 0(
source =01, in-pIanI: reduction and nisting reclamation projects. However, the
RWQCPamootguaranlee fillurerompliance for two reasons, F~ the permit limilS are
being re.:evaluated, and future requirements are 001 yet certain. Second. the R WQCP
operated under ,try fovorable conditions in 1994 -near record low flow. and,
coosequently, al a record high. in-pl.nt reduction efficiency. These favorable CO!l<fitions
may change in the future, The City neals 10 ensure !hat reclamation projects are avail.ble
as an optioo f<x future compliance,
To meet the coocentr.tion flillil, the RWQCP launched. very aggressive source control
program. In 1994. the RWQCP achie-;oo • record high in-plaut me!als w.!uction
efficiency. Despite these efforts, the RWQCP has not been able 10 meet the copper
coocentratioo limit. The RWQCP confimJes 10 seek alternatives !hat will reduce the copper
coocentration. For as loog as the coocentration limit is more stringeD! than the mass limit,
odd'lliooal reclamation ... oold 001 ensare full compliance, However, the coocentration limil
is' also being re-.evWted at !his time. More infonnation will be .V3.l1.ble in the fu\ll.~ for
the evaluation 0( tbe """" lOr additional reclamation, From the discharge perspective,
furtbe£ reclamation prvjects are 00( recommended at this time, It is recommended that the
proposed policy be adopted to enumerate !he conditions that would trigger furore re
evaIuation.
From !he water oupp!y perspective. the City', water demand is currently below its SIlrply
capacity. 1'be Utilities DeparttneIllconducted a study 10 evaluate supply·side and demand
side alternatives lOr the future water S'Jppl)'. The stud)', titled the In\egrated Resource
Plan, idenfified reclamation as one of ... -vera! alternathes 10 supplement future water
supply. AIthoogh iI is an!lcipaled !hal future waler supply ",,11 be limited and more costly,
a recent marli:et SlirVey does not indicale substantial demand foc reclaimed water. Ilene<:,
00 project is recommended at !his time. However, future w-.der supply requirementS may
trigger further evaluation of reclamation projects in the Ptograrn, Th.: CiI:y should iIlclude
reclamation as an opIion for future water supply evaluation.
?OUCY IMPLICATIONS
The City is firmly committed 10 protect the environmeill using the most viable and cost
effective approach. The Reclom.ation Policy is • new policy which embodies this
commitment. The Reclamation Policy is coosistont with the Watershed ManagWlent
approach which calls for me re-consideration of Wale!' qualiIy standards, prior 10 individual
project decisions wbere me water quaf1lY sundards are faclors in the deci.,ion making
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process. TIle Rectamalion Policy enumerates the rooditions that would trigger future
evaluation of the individual projects indudcd in the EIR.
The Reclamation Policy is coosis1enl with the State policy, 11' .. Basin Plan b the Bay Area
communities, and Palo Alro', C<>mprebensive l'lan. AOOprlon of the Reclamation Policy
would allow the City to monitor and initiate future evaluations as needed.
DJSC1FiIDN
There ue five condition.. thaI ,.'ould trigger future evaluation to implerue!ll the projects
WIder tbe Progr3m, They are:
I, Changes in tbe RWQCP dlscbarge permit requiremeDls
The Regiooal Water Quality Coolro! Board (Regional Boon!) issues the RWQCP
• discharge permit which sets !he rIJllits on the PIanI's discharge. The permit
includes a lOla! annual mass limit for each metal, as ,,'en as a cooc<:utration limit.
The Regional Board b"" been directed by the State Board to reconsider the lim.11s.
using !he besl scienti.'ic information in eslalllisbing the basis of !he limits. The
Regiollal Beard is in !he process of revisi.'g tile limits on copper dischar~e,
AI this time, it is uncertain wbat the copper m •• s and concentration limits will be,
The R WQCP cootinues 10 seek new source control opportunities. but bas not fowld
sufficient new control measures 10 bring the RWQCP to rompfl3.JlC<: with tbe
curretlI copper concentratioo limit requiremellt. Therefore. RWQCP pelSOD!lel are
wocking cooperatively 10 ensure llIat the permit funits are re-evaJuated by the
Regioo.al Board,
Discussioos ",id> the Regional Board baye been initiated in <>rder 1<> establish
re.asooable roncentratioo and mass permit limits !bat COIl be met and are responsive
to the enviIonmeotal Deeds. A leiter from Mayor Simitian to tbe Chair of the
RegiooaI Board reinforced !he City's r~ !bat tbe permit [units be =i<lered.
The City is urging !he Board 10 utiliu tbe methodology recently used for New York
Harbor, wbich resulted in.an increase in the aw-rfunits for tbe City of New York
and surrounding commllIlities. When !he Regional Board's re..,vaJuation is
complete, and at the CO!lC1usioo of the permit negotiation, more information wiIl be
a"lUlable to determine whether :odi:!itional reclamation projects will be needed to
meet' the ultimate mass permit limit. At !bat tim<, the individual reclamation
projects wiIl be ~aluated in Jigbl of the outcome of the negotiatiolL
2, Increased mass IoaOmg 10 the RWQCP
The PIanI·s metals d;>eharge is influenc<:d by !be flow, the concenlration, and the
removal efficiency through the P1.wt. The current flow tb""'gb tl' .. P1a!11 is near
record low (23 rogel). Because of the low flow, !be RWQCP is able to acbieve
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record high remoV1ll efficie!lCy. Efficiency is Iypically inversely proportional 10
flo",. In addition 10 decreasing removal effic.ie!lCies, high flo""s also bring more
po!1uIants 10 the plant Therefore, if the flow through the planl inc,,~ in the
furure,lbe mass loading"\llCJllld increase. The RWQCP is permi~ for 39 mgd and
is obligated III !he Partner ddes III trut up 10 39 mgd without permit rioIalioos.
3. Requests from partner agencies or other local agencies
The citiN 0( MetJlo Park and Mountaln VieW have both expressed their desire for
reclaimed water. The Cily 0( Menlo Park has conducted its market survey and is
evaluating the ecooomics of the Program !bat woold benefi! Menlo Park. It is
possible thaI a =Wmed water project which benefits a partner agency would
presem 00, or very little, tman..."'iaI impact 10 !he City.
4. Availability 0( kderal 0< other funds
Implementation 0( aD !he projeclllunder the Program is estimated 10 increase the
City's wastewater rale by approximately 11 percent and the waler nte by 3 perceOl.
Currently, there are 00 federal grant 1'.mds available for recLunatiou projects.
However, • proposed bill in the Cocgress would provide 55 percell! kderal fund"mg
for recl2mation projects from !he federal govemmeilL The first 0( Palo Alto's foot
reclamation projects is inclu&d in Ibis proposed bill. If this funding becomes
available, !he economic impact !O !he Cily wouid be reduced by bali.
S. Water supply issnes
From !he perspective of !he waler utility. the valae of recWmed water is delennlned
by COOlparing it 10 waler from the wholesale supplier and 10 other supply-side and
demand-side optioos This analysis requires making assumptioos about such !bings
as !he likelihood of drought. projected wholesale water costs and availabilily, and
an} additiooa1 cost3 required for the. implementatiou of reclaimed water. Even if
the water utilit"i paid the same rate for reclaimed water as it pays San Francisco
Waler DepartmeOl (SfWD) for potable water, this acrounrs for less !ban 25 percent
o(t'>e IOta! reclamation project cooiS. Theufore, in order for water supply issues
10 drive a reconsideration of r",,!aimed water. things wouk! have ;0 change
markedly. This section lists those issues whick may lead 10 increases in !he valae
of reclaimed water from • water supply perspective.
a. Water supply availability shortages
The City', main water SUJlPlier, !he SFWD, may be ~ 10 reduce its "safe f.elll"
estimate for its S)lstem. due 10 unfavorable outcomes in • number of cases before
regulatory revie .... now aoo in the future. These cases include FERC relicensing of
\he Don PedrQ Dam. Stile Water Resources Cootrol Board revIew of water rights
fo!Iov,ing !he Bay·DeIla accord, aoo any oI!!er review 0( water rights 0< obligations
of WlIWr "iverlers. AJrhoogh SFWD would acl 10 purchase water 10 meet its
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obligations and the needs vt its wholesale CIlSlOI!leC$, if is conceivable !bat the price
at the water would be extremely blgh and even competitive with re<:lamatiolL
Short-term water sborU.ges such as those due !O lack of precipitation 0< runoff, as
experienced in the past. are al"" likely in the future. Jo. more severe 0< longer term
sboctage !ban the 1986-1992 period is p"'sible and may lead 10 a higher value k>r
l'ecTaimedwate;, wbleh is always ava..tlable regardless at drought cooditions.
!), Regulatory or legislative initiative
Regulldocs ()[ Iegislaton may require the !ISO at reclaimed water !Or certain end uses
lIS a coodition atllSing water, ret.ain!ng water rights 0< maintaining diversion
Cacilities. Under !his scenario, ecooomic justification from • water supply
perspective WooJd be superfluous.
c. Advanced treatmelll k>r potable reuse
Regula!on are <:oostantly updating the "'olter quality requirements at reclaimeJ
water and designating appropriate end uses for waters of various qualities. At the
same time, advances are being made in treatmelll technologies and costs.
UlUmately, reclaim<d water could be celtiflOd for d"1Ie.."i poIable teU-<e. In that
eventuality. • separate pipeline woold 00( be required and the ecooomi<:s of
reclaimed water ma, be favorable.
In v'.ew at the uncertainties with respect 10 the objectives of the Program, the following
policies are recommended as a road map 10 the future implementation of the Program.
I. The RWQCP will maintain the existing reclamation efforts. Although additional
recLama.tion projects are no( recommended al tbls time. the existing reclamation
projects are vital 10 the RWQCP's abmty in meeting the curreDl mass di.<;e!Jarge
limit requirement. Any reduction in L'Ie RWQCP's efforts 10 redoce metals
discharge will be viewed unfavorably by the Regional Board and the envirooment.al
groups. If the existing reclaimed water system requires repair 0< reptacement, the
repair or replacement would be done in light of the Program re'lllirements.
II. Future evaluation at the projects onder the Program cooId be triggered
by any 0( the following coOOitions:
I. The City will evaluate the reclamation projects ",hen the Regional Board
completes its re-evaluation of the disc!Jarge limits. and at the conclusion of
the permit negotiation,
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2. The City WJlI evaluate the in<fividual projects if the mas. loading 10 !he
RWQCP in<:tea.<;ei sull-stantiall.y in the future.
3. The City wI ev.uuate an individual project, if a request with an attractive
financial arrangement is made by ranner agencies or oIhcr JocaI agencies for
• re<:lamafion project.
4. The City will evaluate individual reclamation projects if federal or olher
funding becomes available .
.s. The City will evaluate indMduaI reclamatioc projects in the even! o! •
severe or long-term water supply shot1age.
6. The City wiI1 evaluate individual reclamation projects if regulators mandate
the use of reclaimed water.
7_ The City will evaluate furJler use of reclaimed water if reclaimed waler
quality becomes suitable for direct potable use.
AlTEllNJt.ID"F,S
From the wastew;;ter side, the RWQCP rooonues 10 search for source COO!rol alternatives.
So far, additional soorce COO!roI measures have not been identified that would ensure
compIlance. COO>'trUCtion of addiliooal trealmeIl( process at the RWQCP does not appeM
10 be an acceptable alternative from • cost perspective or an environmental prOlecfion
perspective. Fwtber discussion o! alternatives is included in the Envirorunentallmpact
Report.
From the water supply side, the City bas many alternatives 10 reclamation. 'The 1993
Integrated Resource Plan identified the various alternatives.
flSCAJ.IMPACI
The Program poses 00 fis(:aJ impact 10 the curren! fiscal year. sin<"" no project is
~ for implementation at this fune. 'The impacls ollhe individual projects wtll
be addressed ""hen and if • project is submitted for approval in the future.
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..... en>iroomeoraI impact report (EIR) was prepared in accordance with CEQA. 'The ElR
found no un-mitigable impact. 'The Utilities Advisory Commission bas reviewed and
commented 00 the draft ElR. A public beari.ng was beld on December 14, 1994 befure
the Planning Commjssion. The Planning Commission bas laken puNic comments,
reviewed, and approved the draft ElR as adequate uncler CEQA. The final ElR is being
submitted coocurrenlly 10 Council fur certification.
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j Sl'EPS roJ I OWING APPROVAL
Upon adopQoo of Ibo: reclamation policy. staff will monitor the trigger events. Staff will
report \0 1he UAC and Council the ocarrrence of any eve!ll !bar ,,"'ouId necessitale the
. enluation 0( 1he rtclamation projec!(s). and request UAC review and Cooncil approval
prior \0 implementation 0( any project.
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