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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. 3 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, 4 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 5 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. 6 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). 11 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 8 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. 9 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 10 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. 11 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