COF.Y UNIVERSITY OF CALIFORNIA, DAVIS

UNIVERSITY OF CALIFORNIA, DAVIS
TEL: (707) 875-2211
FAX: (707) 875-2009, 875-2089
E-MAIL: [email protected]
http://www-brnl.ucdavis.edu
COF.Y
BODEGA MARINE LABORATORY
P.O. BOX 247
2099 WESTSillE ROAD
BODEGA BAY, CALIFORNIA 94923-0247
31 January2005
CatherineE. Kuhlman, Executive Officer
North CoastRegionalWater Quality Control Board
5550 SkylaneBoulevard, Suite A
SantaRosa,California 95403
Dear Ms. Kuhlman
This letter accompanies application forms for renewal of the NPDES discharge permit for the
Bodega Marine Laboratory's seawater system outfall. The outfall discharges into the Bodega
Marine Life Refuge ASBS, a situation prohibited by provisions of the Ocean Plan. Therefore we
are requesting the assistance of the North Coast Regional Water Quality Control Board in
requesting from the State Board an exception to this provision.
For this seawater system exception request, we will follow the format of requirements set forth in
the letter to Peter G. Connors from Celeste CantU dated October 18, 2004 (Appendix A). The
survey of ASBS discharge sites completed during 2003 (Discharges Into State Water Quality
Protection Areas, July 2003) also identified 6 discharge sites of stormwaterrunoff from manmade structures, and we will address those discharges and our management practices for
stormwater runoff before we address the seawater discharge.
Stormwater Discharges
Since we received the survey results identifying stormwater discharges into the ASBS, we met
with John Short of the RWQCB to determine best management practices and engineering
modifications to eliminate detrimental effects on water quality in the ASBS. We have removed
two discharge outlets, rerouting one of these to a rock-filled underground dry well, repaired a
leak, and modified our management practices to minimize parking lot contaminants entering the
freshwater wetland that drains into the ocean. With these changes we will have no dry-season
discharges from any of these stormwater locations. Except for three very small, local areas
where sheet flow is exposed to weathered concrete or wood, all wet weather stormwater will be
processed through a vegetated wetland prior to release. We will address each of the stormwater
discharge sites identified in the survey report, by SAMPLEID number (see map, Appendix B).
SAMPLEID BODOO9
This dischargesite is the wood and sandstairway,ending on a concretestep and retaining wall,
that provides accessto the sandybeachof HorseshoeCove. It hasbeenin place sincethe 1960s
Each stepis a weatheredredwoodboardholding back the sand-filled step. It gatherswater only
from the immediate areaof the steps,and its porous constructionresults in almost no surface
flow down the steps. The redwood and concretehave beenin place for many years and are
unlikely to contribute to any deteriorationof water quality.
SAMPLEID BODOIO
This site is a natural seepin the coastalbluff. When the marine lab was constructedin the 1960s,
a small concretecatch basin and grate were installed in the grasslandon the bluff abovethe seep
to gather natural drainagefrom the grasslandand direct it to the seepunderground,to reducethe
risk of surfaceerosion. With the areanow coveredwith vegetation,we have examinedthe basin
and grate during the winter 2004-2005rains and have concludedthat they are no longer
necessary.We will seal and fill the drain and remove the grate during summer2005. There is
no anthropogenicinput to this seep.
SAMPLEID BODO!!
This dischargesite is the weatheredconcreteand wood pumphouseand stairs for the intake end
of our seawatersystem. It doesnot drain any areabeyondthe surfaceof the concretestructure.
It has freshwatersurfaceflow only when raining. It has a minor flow of seawater(approx. 1.5
gallons per minute, gpm) that is overflow from monitoring instrumentsinside the pumphouse,
measuringsalinity and temperatureof the intake seawater. This seawaterhaspassedthrough the
intake lines and pump to the instrument sensorsand back by gravity flow to the intertidal rocks.
It has not been treatedor exposedto any pollutants.
A similar concretestructureof wood and weatheredconcreteis part of the seawatersystem
outfall (SAMPLEill BODOO8),and also drains only the immediate structure,with runoff only
when raining.
SAMPLEill BODO!3
This site is an inactive drain, originally a seawaterdischargefrom sometanks in the Laboratory.
The seawaterwas redirectedto the main outfall during the 1980s,and this drain was sealedat its
upper end. We have now plugged it also at its lower end, and have removed the pipe that was
visible on the beach.
SAMPLEID BODO14
This areaof vegetatedgravel road and concreteboatrampprovides accessto HorseshoeCove
Beach for trailerable small boats and diving gear. It is used about 12 times per year on average.
To minimize the potential for pollution from vehicles on the boatramp,we have thesepolicies:
1. Vehicles may not use the boat ramp if they were leaking any fluids where they were
parked last.
2. Vehicles and boatsmay not be rinsed or washedon the boatramp.
2
Our occasionalinspectionsof the concreteboatramphave not found any indication of oil or
grease,so this areais as clean as the other weatheredconcretestructureson the site.
There is also a small (80 squarefeet) air sampling laboratory near the boatramp. Signs are
postedprohibiting any disposalor external use of soapor other contaminants. Currently there is
plumbing for both freshwaterand seawaterto the location of this laboratory, but there are no taps
in the laboratory, and theseare not neededfor the air samplingprojects.
SAMPLEffi BODO16
This dischargesite is our only significant stormwaterdrain, a culvert pipe and concretetrough
emptying onto the sandsof HorseshoeCove Beach. Water flowing through this systemcomes
from a natural freshwaterwetland approximately220 feet from the beach. Rainwater falling on
the buildings, road and parking lots runs by sheetflow to the surroundingvegetatedgrasslands.
The native soil varies from sandyloam to loamy sand. During heavy rains, someof this water
runs off the parking areasand driveway through vegetationthat surroundsthe parking areasand
driveway, eventually entering the freshwaterwetland. It then moves through the wetland to the
downstreamend where the culvert and trough carry it to the beach.
We have adoptedthesemanagementpracticesto minimize the potential for pollution in the
wetland:
1 We ask BML staff and studentsto make certain their cars do not have oil leaks.
Washing of private vehicles is prohibited at BML. Statevehicles and boatsmay be
rinsed only, without soap,in two designatedareas.
3,
No chemicals,including fertilizers, can be used in areaswhere they might wash from
parking lots or Laboratory groundsinto the wetland.
In addition to theserules governing runoff, we do not allow dogs or other pets on the Reserve
surroundingthe Laboratory, and we do not keep any mammals,either marine or terrestrial, on
the premisesfor research.
SAMPLEID BODO!?
This terra cotta pipe, installed when the Laboratory was built in the 1960s,drained a small
service and parking areanear the Laboratory. As we investigatedthis dischargewe discovered
that it also containeda trickle of seawaterfrom a leaking seawatertank fitting. We repaired the
tank leak so that seawaternow only entersthe main oceanoutfall line, and we have reengineeredthe stormwaterdrain from the serviceand parking areaso that it is directed into a
rock-filled undergrounddry well. Thesetwo changeshave stoppedall flows from this pipe to
the ASBS, and we have sealedthe old pipe at its lower end.
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Seawater Discharge
Outline headingscorrespondto the requestedinformation in the letter from CelesteCantU.
1. The requestletter
a. Information about the discharge
Organization:
BodegaMarine Laboratory
University of Califonia Davis
PO Box 247
BodegaBay, CA 94923
Contact:
Dr. Dennis Thoney, AssociateDirector, 707-875-2005
Dr. PeterConnors,ReserveManager, 707-875-2020
Ms. Kitty Brown, Laboratory Manager, 707-875-2006
FAX 707-875-2009
NPDES Pemlit Number: CAOO24333
b. OceanPlanProvisions
This exception is required by sectionsIll.E.I and Ill.H.2 of the OceanPlan.
c. Rationalefor the exception
The marine programsof the University of California at BodegaMarine Laboratory dependon the
flowing seawatersystemto provide a laboratory habitat to maintain marine fishes, invertebrates
and algaeunder natural conditions. Theseprogramsservethe public interest in severalways.
1 Research: BML is amongthe major marine researchinstitutions in the country. Its
scientistsare investigating population dynamicsof marine invertebratesand fishes,
fisheries management,fish health, aquaculture,invertebratediseases,introduced species
effects, nearshoreoceanography,physiology, developmentalbiology, genetics,
endocrinology of marine invertebrates,ecological processesand community dynamics of
invertebratesand algae,captive breeding and conservationbiology of endangered
species,and many other topics. Thesestudiesbenefit agencies,industry and the general
public by solving problems,providing managementguidance,and expandingour
understandingof nearshoremarine systems. The University of California, the Stateof
California, and various funding and regulatory agenciesof the federal, state,and county
governmentshave investedtens of millions of dollars over the years in facilities and
programsto supportthis research. The National ScienceFoundationhas twice provided
major funding for improvementsand upgradesto BML's flowing seawatersystem,
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recognizing that this systemprovides a resourceof national significance for marine
scientistsat UC and for scientistsfrom other institutions who visit BML to conduct
research. In 2003, 110 scientistsusedBML's seawatersystem.
2 Teaching: BML's seawatersystemis usedin almost all our undergraduateclassesin
marine science(253 studentsin 2003) and is essentialto most of the marine science
graduatestudentsconducting their thesisresearchat BML (66 graduatestudentsin 2003).
To train the next generationof marine scientists,BML must maintain its seawatersystem.
3. Public education: Although BML is not a public aquarium,approximately 12,000public
visitors (K-12 to adult) per year visit the Laboratory for guided tours to learn about the
scienceconductedhere. They observelocal fishes and invertebratesin severaldisplays
and experimentalanimals in wet labs, all maintainedas healthy organismsin the flowing
seawatersystem. Educatingthe public to the problems that confront the Stateand the
Nation in maintaining healthy marine ecosystemsalong our coastis of great importance.
4.
Monitoring the ocean: BML's flowing seawatersystemis part of the Laboratory's
coastaloceanobservingnode. Seawateris pumped from the intake in HorseshoeCove to
the intake pumphousewhere automatedsystemsmeasuresalinity and temperature. We
will install a fluorometer to measurechlorophyll in the ambient seawaterwithin the next
5 months. Thesedata are stored,summarized,and usedto support researchat BML as
well as forming a node of a statewidemonitoring network. The stateand federal
governmentshave been investing money in networks of oceanmonitoring systemssuch
as the BML systemas a necessarystep in gatheringthe data neededto guide management
of the oceanand its fisheries.
d. Exceptionwill not compromiseprotection:
The best evidencethat this seawatersystemoutfall will not compromiseprotection of the ocean
waters for beneficial usesis the continuedexcellent health of the oceanecosystemsurrounding
the outfall. The seawatersystemoutfall hasbeenin this location since the 1980s,and the
communities of marine algaeand invertebratesat the outfall location and elsewherein the ASBS
are diverse,robust, and healthy.
Marine ecologistsrepresentingat least 8 different universities and stateagencieshave continued
to set up experimentsand conduct studiesin the vicinity of the outfall becausethey are
convinced that the dischargeis not affecting the communitiesor ecological processesthat they
wish to study. A large coast-widemonitoring project coordinatedby marine ecologistsfrom
Oregon StateUniversity (PISCO, Partnershipfor Interdisciplinary Studiesof CoastalOceans
http://www.piscoweb.org/what/index.html)selectedthe rocky intertidal site adjacentto the
outfall as one of their monitoring sitesbecauseof the healthy, representativecommunity at the
site. Their data show that speciesrichnessin the low intertidal at Bodegais higher than at any
other of the 10 locations sampledin California.
Two UCD ecologists(Dr. Jay Stachowicz,Dr. Matt Bracken) have establishedexperimentaland
control plots very close to the outfall as part of an ecological study that covers a large part of the
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rocky intertidal bench in the BodegaMarine Life Refuge ASBS. They selectedsitesnear and far
from the outfall, convinced that the outfall was unlikely to affect this ecosystem. Their
subsequentdetailed monitoring showsthis to be the case. We include thesemonitoring results in
the next section.
The population of harbor sealsusing a haulout adjacentto the outfall has grown steadily over the
years of outfall use. Shorebirdpopulations on the rocks have remainedsteadyat the site since
the 1970s. All theseobservationsand databolster the conclusion that granting an exception for
this seawaterdischargewill not compromiseprotection of coastalwaters.
e. Information for an environmentalanalysis
1. Existing environmentalconditions
We have two data setstaken during 2004-05 that comparecommunities of marine algae and
invertebratesat the outfall site with communitiesat sites more distant from the outfall. Both
demonstratethat the dischargehasnot negatively affected the environment at the discharge
site. The data setsare for different tidal levels, from the mid-intertidal bench to the low
intertidal surgechannel. The topography surroundingthe outfall is not a gradual or
continuous slope toward the subtidal zone. The outfall dischargeswater into the bottom of a
narrow and deep surgechannelthat bisectsthe surroundingintertidal bench. During most
tide and wave conditions, water from the outfall mixes with waves in the surge channeland
flows out over the surroundingbench. The prevailing wave and current conditions carry the
dischargewater mainly to the southeast,toward the plots we are monitoring in the midintertidal.
We do not have monitoring data for the subtidal regions beyond the outfall, but we are
confident they would show the sameabsenceof outfall effects if we were able to work in that
area. We think the intertidal sampling is more appropriateat our outfall site for these
reasons: First and foremost, the subtidal environmentnear the outfall is an unsafeareafor
divers to attemptto collect data. The areawas chosenfor the outfall becauseof the highenergy mixing provided by the strong wavescombinedwith the surgechanneltopography.
Beyond the surgechannelthe topographycontinuesas an irregular mix of granite boulders,
columns and tables. Our campusDiving Safety Officer, Henry Fastenau,deemsthe areaan
unsafe location, dangerousfor diving on almost every day of the year. To move farther away
to find safe diving would take us too far away from the outfall for the data to be meaningful.
Second,becauseof the local topographyat the site, a comparisonof mid-intertidal habitats
will be more scientifically meaningful becausethe habitat is repeatedfrequently throughout
the BodegaMarine Life Refuge ASBS, and is easily accessiblefor detailed ecological
sampling. To assesseffects of the outfall discharge,we must be able to samplewith suitable
replication within a habitat type. The low surgechannelhabitat is less common on the
Refuge, and different surgechannelsdiffer in important topographic factors such as depth,
width, and orientation to the waves. Statistically and biologically significant comparisonsare
more difficult to obtain in surgechannelhabitat.
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Accordingly, we have sampleda variety of community parameters,with ample replication, in
the mid-intertidal zone of the rocky benches,and have sampledspeciesrichnessin all zones
down to the low intertidal zone of three surgechannels.
a. Mid-intertidal sampling (data of Dr. Jay Stachowiczand Dr. Matt Bracken, July 2004):
In a comparisonof invertebrateand algal communitieswithin one-meterdiameter
circular plots (8 plots near the outfall, meandistanceof 20m from outfall; comparedto 10
plots, meandistanceof 4lm from outfall), there were no significant differencesin any of
12 speciesand community measures.For eachmeasure,probability p-values are given in
parentheses,with p<0.05 necessaryfor significance at the 95% level (seeAppendix C,
part II for sampling protocols).
Invertebraterichness(p=0.73)
Invertebratediversity (p=0.07)* (diversity slightly higher near the outfall)
Total algal cover (p=0.29)
Pelvetiopsis cover (p=0.41)
Endocladia cover (p=0.31)
Mastocarpus cover (p=0.75)
Cladophora cover (p=0.99)
Bare space(p=0.49)
Mussel (Mytilus) cover (p=0.70)
Primary Mytilus cover (=musselsas a substratefor algae) (p=0.79)
Limpet (mostly Lottia) abundances(p=0.64)
Littorina snail abundance(p=0.07)* (Littorina slightly more common away from outfall)
b.
c.
Surge channel sampling (data of Dr. ChristopherHarley and Ms. JennaShinen,January
2005): In a comparisonof total speciesrichnessfrom high intertidal to near-subtidalon
10m sectionsof the walls of three surgechannels(the outfall surgechanneland two
comparisonchannelsA and B, 25m and 10m from the outfall surge channel), species
richnesswas higher in the surgechannelthan in either of the other channels. Species
richnesswas recordedas 31 in the surgechannel,32 in channelA and 29 in channelB
(seeAppendix C, part I for specieslists and comparisons). Becausemeaningful
replication is not possible in this comparison,and becausethe results may vary with
season,we do not considerthis result statistically significant, but it clearly suggeststhat
the outfall has not had any negativeeffects on speciesrichness.
Photographic evidence: We can supply photos of the healthy communities of marine
algae and invertebratesat the site of the outfall to further indicate the absenceof negative
effects of the discharge. We include one suchphoto taken during December2004 in the
low subtidal of the surgechannelat the underwaterdischargepoint (Appendix D).
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Potential environmentalimpacts
Q.
Volumeand seasonalcharacteristics: We monitor flow at two central points within the
seawatersystem,after the water haspassedthrough the clarifier but before it is
distributed to end-userlaboratories. We have attemptedto measureflow also at the
7
outfall, but difficulties of measuringflow in partially full pipes causedus to remove the
flow meter at that site. Dischargeflow rate at the oceanoutfall is approximately the same
as the centrally measuredflow rate, but it can differ from time to time if any of these
three circumstancesapplies:
(1) Dischargerate will be less when other marine laboratoriesand public aquaria,
becauseof the excellent water quality at our site, withdraw seawaterfrom our
systeminto tanker trucks for transportto their facilities. This difference is barely
measurable,amounting to lessthan 10,000gallons per month, or less than 0.1%
of total flow.
(2) Dischargewill be higher when raw (unfiltered) seawateris shuntedaroundthe
clarifier directly to a laboratory. This occursonly part of the time, and may
amount to anywherefrom 0 to 15% of total flow. If raw seawateris diverted in
the future at a rate above 5% of total flow, we will install a separateflow meter to
measurethis diversion, and will include it in total flow.
(3) Dischargewill be higher when the salmonresearchprogram is adding low salinity
water to the discharge. This eventmay occur either when the program is
transitioning fish through the smoltification processfrom fresh to saltwater,or
when salmon are held in the Fish PathologyLaboratory for studiesof diseases.
Smoltification periods are infrequent (maximum of21 daysper year), during
which fish are held in tanks with gradually increasingsalinity. We mix water
from our own well (not chlorinated, and slightly saline at 3ppt) with seawaterin a
semi-closedsystem,with makeupwater at a maximum rate of 5 gallons per
minute (gpm). Mixing proportions are set and controlled by the computer
monitoring and control systemto achievethe desiredsalinities. Total freshwater
addedto the seawaterflow during theseshort periods varies up to a maximum of
1% of total flow.
When salmonare held in the Fish PathologyLaboratory in low salinity water, all
effluent must passthrough the chlorination-dechlorinationsystem(describedin
next section and in Appendix F). Theseoccurrencescan require up to a
maximum of2l gpm of3ppt water (almost fresh), contributing a maximum of 4%
to our discharge. This flow could lower the dischargesalinity by slightly more
than 1ppt, within the normal range of salinities of the ambient oceanwater in the
ASBS (31 to 34ppt). The contribution of low salinity water only reachedthis
maximum level of2lgpm during one 10-dayperiod in 2004; at other times it has
rangedbetween0 and 16 gpm.
Flow data (seeAppendix E) averaged0.74 million gallons per day (mgd) over the past
year. Our pumping systemis capableof pumping up to 1.5 mgd, but we operatewell
below this limit. Our existing permit is for 3.0 mgd, but we will requestrenewal at a
lower limit of 2.0 mgd, which still allows for upgradesto pumping equipment. The
sourceis our dual-pipe intake line that draws water from within HorseshoeCove adjacent
to the Laboratory (SAMPLEID BODO12). Flow doesnot fluctuate dramatically with
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seasonbecausemost of our laboratory systemsrequire fairly constantflow to maintain
organisms,but an influx of visiting scientistsand studentsduring summermonths usually
contributesto an increaseof about 20% during summer. There is no stormwatermingled
with the seawaterdischarge.
b. Chemical constituents: We currently monitor chlorine residual in the outfall line
continuously as part of our chlorination-dechlorinationsystemfor the seawaterflowing
through two pathology labs. Additional information about this systemis included in
Appendix F as part of the seawatersystemdescription. Becausethesetwo labs work on
issuesof fish health and invertebratehealth, they sometimeshold diseasedanimals. The
California DepartmentofFish and GamePathogenContainmentFacility at BML
representsthe only approvedquarantineand holding facility for known or potentially
diseasedshellfish in California. Researchincludes speciesof importanceto commercial
and sport fisheries and also endangeredspeciessuchas the white abalone. The Fish
Health Laboratory focuseson speciesthat include two stateand federally-listed salmonid
species,the winter-run Chinook and the Coho.
To preclude the escapeof any diseasemicroorganisms,all eft1uentfrom thesetwo labs is
treatedwith chlorine for 2 hours contact time, accordingto requirementsset by the Dept.
of Fish and Game. The systemis computer-controlled,with chlorine concentration
sensorsand alarms at three points. Alarms activatebackup systemswhen chlorine
concentrationfalls outside desiredparameters,and an automatedservice telephones
Physical Plant staff at work or at home at all hours. Staff can make adjustmentsto the
systemfrom home via internet hookup. Chlorine concentrationin the treatmentsystemis
controlled between 12 and 15 ppm currently, a range of valuesthat is conservativelyhigh
to insure sterilization of the effluent from the pathology laboratories. We are evaluating
whether theselevels can safely be lowered for different pathogensto reducethe total
amount of chlorine used.
After the two-hour retention and prior to dischargeto the ocean,chlorinated seawater
from the pathology laboratoriesis exposedto gaseoussulfur dioxide as a dechlorination
process. Chlorine residual is then measuredby sensorin the dischargeas part of the
continuous,computer-controlledmonitoring systemat BML. Chlorine hasbeen reported
as not detectedon 99.4% of days over the past 5 years,with a detection limit of 0.1ppm
as set by standardlaboratory titration methods. This dechlorination systemhas beenvery
reliable since we installed it 5 years ago, with very few readingsabove the limit. Most of
thesereadingshave occurredwhen the chlorine sensorneededc.leaningor when BML
staff were working on the system. Weare planning to install another sensoras a backup
to the final sensornear the dischargepoint.
The chlorination-dechlorinationsystemdoesnot apply to the full BML discharge. The
two pathology labs have a maximum flow of 80 gpm combined,approximately15% of
the total flow. Actual flow is usually much lessthan this limit. The remaining 85+% of
the flow through BML doesnot passthrough the chlorination system.
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We are developing plans for one additional laboratory systemthat will require chlorine
treatmentand dechlorination prior to releaseof seawater. This new laboratory system
will be dedicatedto researchwith invasive marine species,and will be the only
laboratory in California capableof safely addressingthis important issue. Depending on
the speciesinvolved, chlorine concentrationmay be higher than in the pathology
laboratory treatment,but flow rateswill be less. The total amount of chlorine used will
probably rangeup to the amount currently usedin the pathology laboratory treatment
system. The new invasive speciestreatmentsystemwill be separatefrom and
independentof the existing treatmentsystem,with all effluent chlorinated and then
dechlorinatedprior to joining the main seawaterdischargefor the final chlorine sensor
measurement.
We do not currently monitor any other chemicals. We ask the assistanceof the RWQCB
in determining what set of measurementsin addition to chlorine are appropriatefor this
outfall. We note that most of the Table B constituentshave no way of entering our
seawatersystemlines if they were not presentalready in the intake seawater. We do not
permit addition of chemicalsinto seawaterin any part of the Laboratory. If a researcher
requestsuse ofa chemical in seawater,the requestwill only be approvedif the researchis
done in a closed systemand the seawateris later disposedof offsite. We do not use any
chemicalsfor treatmentof diseaseor parasitesother than the chlorine systemin the two
pathology labs. Parasitetreatmentis accomplishedwith immersion of fishes in
freshwaterthat is dischargedinto our septic system. If chemotherapeutics(e.g.,
antibiotics) are neededin the future, they will be used only in closed systems,with
disposal of the seawateroffsite.
c. Physical constituents: We monitor suspendedsolids, settleablesolids, and pH in both
intake and dischargelines (Appendix E). Suspendedsolids numbersvary seasonally,
with high turbidity during winter storm months and lower turbidity during summerand
fall. Settleablesolids numbersare usually below detectionlimits. Values for both
parametersin effluent water approximatethe values in influent water in all months.
Values for pH range from 7.8 to 8.2 and are similar in both influent and effluent
seawater. We also monitor temperatureand salinity, and will soon add chlorophyll
concentration,in the intake water at the intake pumphouse.
d. Indicator bacteria: We do not monitor any bacterial concentrations. We do not have any
marine mammalsin our Laboratory and thereforeno sourceof coliform bacteria. All
human waste systemsare on the separateseptic system. We requestthe assistanceof the
RWQCB in determining what indicator bacteriameasurementsare relevant to our
situation.
e. Toxicity o/the discharge: We have not done any standardtoxicity measurementsof our
dischargeseawater. To a very real extent, our entire Laboratory is a toxicity study, with
different researchprojects holding adult, juvenile, and embryonic fish, marine
invertebratesand larvae. We have daily checksof all systemsby our Aquatic Resources
Group staff and periodic inspectionsby the UC Davis Animal Care and Use Committee.
Weare proud of our excellent record of maintenanceof animals in our tanks without any
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adverseeffects from water quality other than occasionaltemporary problems associated
with mechanicalfunctions (clogged intakes,lines, and valves, or power failures). Many
of our fishes and invertebratesremain in our systemfor a year or more before they are
releasedback into the ocean. We currently have somefishes and invertebratesthat have
been in our tanks for 10 years without any ill effects.
iii. Management
practices
The Laboratory seawatersystemis describedin Appendix F. It is one of the most
sophisticated,computer-controlledseawatersystemsat any University marine laboratory,
with monitoring points throughout the systemconnectingsensorsfor temperature,
salinity, flow rate, pressure,and chlorine concentrationto a central computer system,
monitored both within the Laboratory and at the homesof Physical Plant staff. Sensors
are set with alarm levels for various parameters,and will automatically activate backup
systemsand contact staff at the lab or at home.
Physical Plant staff and Aquatic Resourcesstaff run daily checksof the systemand the
animals held in seawatertanks. All setupsof tanks and animals must be done by the staff
of thesetwo support groups. New researchprojects by visiting scientistsare reviewed by
the Laboratory Director for approval.
Projects involving exotic speciesor California speciescollected at other sites are given
particularly close scrutiny to avoid introduction of non-native species,parasites,or
diseases. Only one exotic speciesis currently held at BML, the Maine lobster, Homarus
americanus. Dr. Ernest Changhas investigatedthe endocrinology of this speciessince
the 1970s,in a laboratory setting that makesescapeof animals very unlikely. We have
never found any wild lobstersanywherein the BodegaMarine Life Refuge ASBS. We
ask Dr. JamesMoore of the Dept ofFish and Game,a residentresearcherat BML, to
review and adviseus on any projects that proposeholding exotic speciesat BML, and
theseprojects require the approval of the Dept ofFish and Game. Dr. Moore also has
monitored shellfish near the outfall for the presenceof an exotic sabellid worm that has
been found elsewherein California, and he hasnot found it here.
Any projects working with diseasesor parasitesof fishes and marine invertebratesin our
seawatersystemare confmed to the two pathology wet labs. All seawatereffluent from
thesetwo areasis treatedwith chlorine as describedabove. Accidental escapeof disease
organismsfrom theselabs via researchpersonnelis controlled by a disinfectant foot bath
that all researchersmust passthrough before entering and leaving theselabs.
We will add somebackup and a check on the accuracyof the final chlorine readingsby
installing a secondchlorine sensorat the outfall. We believe that most of the positive
readingsobtainedsince installing the new dechlorination system5 years ago (11 positive
readingsin 5 years; seeHistorical compliance,section 3 and Appendix G) have been
faulty sensorproblems. A secondsensorwill give us a check on accuracyand a backup
when a sensorneedscleaning. We also will install a continuoustemperaturesensorat the
discharge. Both of thesesensoradditions will be installed by end of June2005.
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iv. Alternativesto thedischarge
1. Abandon the BML flowing seawatersystem. The seawatersystemis the heart of the
BodegaMarine Laboratory. Researchersand studentsmust be able to bring marine
organismsinto laboratoriesfor study, confident that they can provide the necessary
environmentalrequirementsfor eachspecies. The University of California, the State,the
National ScienceFoundationand severalother agencieshave investedtens of millions of
dollars in the Laboratory, and more than a million dollars in developmentof the seawater
systembecauseof the importanceof the researchand teachingprogramsat the site.
Abandoning the seawatersystemwould be a terrible waste. Becauseof the detriment to
the University's programsof marine scienceresearch,teaching,public educationand
monitoring, this option is not favored.
2. Re-engineerthe systemto a closedsystem. A closedsystemwould fail to meet the
scientific needsof the University's programs. Scientistscome to BML becausethey
know they can hold animals in natural seawater. For somespecies,scientistsneedraw,
unfiltered seawaterto provide planktonic food sourceseven while the organismsare held
in the Laboratory. A flowing systemcan provide this, but a closed systemcannot.
Closed systemshave other problems that make them difficult to scaleup to the size of the
BML system,and all closedsystemsrequire someamount of new makeupwater
continually or periodically introduced into the system,with a continuing requirement for
discharges. In cities thesedischargescan go to a public sewersystem. At BML, there is
no public systemavailable, and saltwatercannotbe dischargedinto our septic system.
Becauseof thesepractical problems and the detriment to the University's programsof
marine scienceresearch,teaching,and monitoring, this option is not favored.
3. Move the discharge point more than 1000 feet offshore, beyond the ASBS boundary.
This would be a major undertaking,and would causesignificant damageto the intertidal
and subtidal habitatsand communitiesthrough which the extendedpipeline would pass.
Large amountsof concretewould have to be poured on native habitats to anchor the
extendedpipeline through the high energy environmentfrom the intertidal zone to the
offshore location. Paying for this major constructionproject would require funding far in
excessof the BML budget, and would divert UC funds from other beneficial programs.
Becauseof the major negative impact on the habitatsand biota of the ASBS, and the cost
of implementation,this alternative is not favored.
4. Continue the discharge at thepresent location. This alternative provides the best
support for the usesdescribedabovein marine scienceresearch,teaching,public
educationand oceanmonitoring. The results of the ecological monitoring presented
aboveindicate that there are no negative effects of the current discharge. Becausethis
alternative supportsall the positive impacts of the systemand has no negative impacts on
the habitats and biota of the ASBS, it is the preferred alternative.
12
2. CompletedstandardNPDESapplication and associatedforms (attached).
3. Historical compliancewith NPDESpermit conditions(attached,AppendixG).
If there are questionsabout any of the information in this letter and application, pleasecontact
either of us, or Kitty Brown. We look forward to working closely with the Regional Board to
provide all the information neededto requestan OceanPlan exception for our seawater
discharge.
Sincerely,
l)-~~.~-
DennIS
Th oney,
t\."~y'\
C
~
)J
(~:~:t:A::
Peter G. Connors, Reserve Manager
AA ssociate
~-~'"l_.'~'---'"1
D .
Dir.d;;;
13