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RPVCCA_CC_SR_2015_06_16_K_Draft_Enhanced_Watershed_Mgmt_Program_DocsMEMORANDUM TO: FROM: DATE: SUBJECT: 1:1=01471=113 kibr& RANCHO PALOS HONORABLE MAYOR & CITY COUNCIL MEMBERS dW MICHAEL THRONE, DIRECTOR OF PUBLIC WORKS'r3r Project Manager: JUNE 16, 2015 AUTHORIZATION TO SUBMIT DRAFT ENHANCED WATERSHED MANAGEMENT PROGRAM DOCUMENTS DOUG WILLMORE, CITY MANAGER Andy Winje, Senior EngineerAO RECOMMENDATION Authorize Staff to submit the Draft Enhanced Watershed Management Program to the Los Angeles Regional Water Quality Control Board on behalf of the Peninsula Water Management Group in accordance with the permit compliance schedule. EXECUTIVE SUMMARY The latest Municipal Separate Storm Sewer System (MS4) Permit (Permit), which addresses urban runoff and storm water quality, was adopted by the Los Angeles Regional Water Quality Control Board (Regional Board) on November 8, 2012. The Permit outlines three means of compliance, with the most robust protections afforded to permittees that adopt a so-called Enhanced Watershed Management Program (EWMP). In 2013 the City Council agreed to join other agencies having stormwater jurisdiction on the Palos Verdes Peninsula to develop an EWMP. The agencies are known as the Peninsula Watershed Management Group (Peninsula WMG). The City of Rancho Palos Verdes serves as the administrative lead for Peninsula WMG and is required by Permit regulations to submit EWMP plan documents on or prior to June 29, 2015 to remain in compliance. The group has met and worked collaboratively to prepare these documents with the assistance of technical experts hired through a Memorandum of Understanding (MOU) between the Peninsula WMG members, which was entered into for this cost- sharing purpose. The EWMP outlines activities that the City and other agencies of the Peninsula WMG will need to undertake, including general schedules and estimates of cost, both of which present challenges. The documents are being made ready for submittal by the deadline on June 28, 2015. The documents to be submitted, subject to a few minor changes, are available for review on the City's website at http://www.rpvca.gov/347/Stormwater-QuaIity-Program. 1 Authorization to Submit Draft Enhanced Watershed Management Program June 16, 2015 Page 2 of 6 The City Council has previously agreed to participate in the Peninsula WMG and has authorized the development of the group's draft EWMP. At this time, staff intends to update the Council on the group's progress and simply seeks authorization to submit the draft EWMP to the Regional Board by the June 28th deadline. BACKGROUND The Permit gives cities and agencies three pathways towards compliance: (1) compliance with the baseline Permit and its numeric water quality standards; (2) development and implementation of a watershed management program; and (3) development and implementation of an EWMP, which was selected by the Peninsula WMG. The EWMP option provides additional compliance coverage (i.e., protection against liability under the Clean Water Act) for the Permit's water quality standards so long as permittees effectively develop and implement an EWMP. The EWMP is a comprehensive assessment of the conditions of the watersheds that the City collects water from and the receiving water bodies to which it discharges. A detailed analysis of steps necessary to achieve pollution reduction goals, including identifying specific and effective treatment systems, is based on that assessment and analysis. The approach required by the Permit is much more complex than previous permit terms. It is has also been expected that costs for development and construction of the specific treatment systems will be an order of magnitude in cost higher than what agencies across LA County have been used to spending on water quality issues. For that reason, there have been several collaborative, yet still incomplete, efforts to develop funding sources for these programs. These include efforts by the County Flood Control District and the Los Angeles County Division of the California Contract Cities Association. Staff has presented information on the new Permit requirements to the City Council on several occasions. These presentations have outlined the evolution of the City's response to the Permit requirements as Staff has worked to determine the most advantageous path forward. At its June 18, 2013 meeting, the City Council authorized Staff to notify the Los Angeles Regional Water Quality Control Board (Regional Board) that the City would follow the EWMP approach in conjunction with the Peninsula WMG. A Notice of Intent was filed on June 27, 2013 with the Regional Board to signal this approach. The Regional Board approved the Notice of Intent. On August 6, 2013, the City Council approved a Memorandum of Understanding between the Peninsula WMG agencies in order to begin collaborative work on the EWMP for the new Permit requirements. Because it is the largest agency by area within the group, the City of Rancho Palos Verdes serves as the administrative lead. On October 1, 2013, the City Council awarded a contract to John L. Hunter & Associates to begin work on the EWMP documents. On June 17, 2014 the City Council directed staff to submit an EWMP Work Plan on behalf of the Peninsula WMG. The EWMP Work Plan outlined the technical process and methods to be followed to develop the EWMP itself. On two occasions (May 8, 2014 and May 6, 2015) the Peninsula WMG hosted public 2 Authorization to Submit Draft Enhanced Watershed Management Program June 16, 2015 Page 3 of 6 workshops to encourage stakeholder input on the process, intent, findings and conclusions of the EMWP. Stakeholders invited included City Council, Water Quality and Flood Protection Oversight Committee members, other governmental organization staff and officials, non-governmental organization staff, environmental organizations, community organizations and Peninsula residents. A member of the RPV City Council was present at each of these workshops along with staff from other Peninsula WMG agencies and other stakeholders (South Coast Botanic Garden, Palos Verdes Peninsula Land Conservancy, Cal Water, residents, etc.). A full list of invited stakeholders, excerpted from the EWMP document is included as Attachment A. In addition, three separate meetings were held with specific stakeholders who asked to have additional input. Two of the City's citizen committees (Water Quality and Flood Protection Oversight Committee and Infrastructure Management Advisory Committee) have also received briefings on the requirements of the Permit and the potential impacts to the City's operations and budgets. City staff posted the draft EWMP documents on the City's website on May 21, 2015 and provided notice of their availability in the weekly administrative reports on June 3rd and June 10th. A list serve message was also distributed on June 3rd for those subscribed the Storm Water Quality category. DISCUSSION Permit Requirements. The purpose of the EWMP is to achieve compliance with the Permit through identification of pollutants of concern in receiving water bodies, quantifying the pollution contributed in runoff from the Peninsula watersheds and developing watershed control measures to reduce or eliminate those contributions. Certain control measures must be undertaken by all jurisdictions and these are described in the Permit as Minimum Control Measures (MCMs). These measures are primarily non-structural in nature and are a continuation or enhancement of the specific measures the City is already undertaking. However, there are some significant additions to this list. The City must now address non-stormwater runoff more vigorously, including monitoring and potentially source tracking of dry weather flows at the City's storm drain outfalls, and a program to reduce runoff attributable to irrigation overspray. The City must also implement some standard structural control measures, including adoption of a Low Impact Development ordinance (which the City Council adopted on April 21, 2015) and a commitment to installation of full capture screens in catch basins not previously requiring a retrofit. While these MCMs require an increase in effort compared to what the City already does, the real impact to the budget will be on the Targeted Control Measures (TCMs). Lists of the new and enhanced non-structural MCMs and non-structural TCMs proposed are included in Attachment B. As the name implies, TCMs are pollutant control measures that address specific pollutants in specific watersheds. Some of these pollutant / watershed pairings have County -wide prescribed programs (known as TMDLs) to which the City is already committed. The Permit also requires the MS4 operators to identify non-structural and structural measures that will address all remaining predicted pollutant exceedances. 3 Authorization to Submit Draft Enhanced Watershed Management Program June 16, 2015 Page 4 of 6 These pollutant predictions, and the prescribed methods to control them are detailed by a computer modeling effort known as a Reasonable Assurance Analysis (RAA). The RAA mathematically tests the sufficiency of a proposed treatment system to reduce the pollutant of concern in the receiving water body. Each watershed group was required to adopt an RAA as part of the process of developing an EWMP. RAA Findings. The RAA takes into account anticipated pollution reduction across all watersheds for non-structural elements of the EMWP. It also takes into account anticipated reductions from regional projects already underway. In the case of the Peninsula watershed, these efforts did not produce enough of a reduction to avoid the need for more structural projects. RAA modelers proposed several technologically appropriate projects to meet the remaining demand for pollutant reduction. These were sited where stormwater might be treated most effectively before leaving the Peninsula watersheds. Of the three catchments in which Peninsula drainage flows, the Machado Lake watershed presents the biggest challenge to the Peninsula WMG. Because of limited real estate for treatment, geologic hazards that preclude infiltration options, and an extremely low tolerance for nutrients (primarily phosphorous) in Machado Lake, treatment solutions are limited and expensive. Two projects were identified in the RAA, at the Palos Verdes Landfill and at the Valmonte Canyon, respectively, that provide sufficient treatment. A smaller, but still significant issue exists in the watershed draining to the LA Harbor, and the RAA has identified a potential project at Eastview Park to sufficiently reduce pollutants. Fortunately, the Peninsula's contribution to pollution in the Santa Monica Bay is or can be managed by current programs or retrofitting catch basins with trash screens, so no major capital projects are required in this watershed. A map showing the location of the projects considered by the RAA followed by a summary table of those projects, excerpted from the EWMP, is included as Attachment C. Cost and Schedule Implications. The cost to implement these capital projects is difficult to estimate at this time. Rough costs for construction, permitting, engineering and project management can all be extrapolated from industry data. Further work would need to be done to determine the regulatory and political feasibility of these projects. In addition, land acquisition, legal process and financing efforts are too vague to estimate at this time. Furthermore, while the projects would be built in only one jurisdiction, they benefit others so costs should be shared. Details of cost allocations among the Peninsula agencies would have to be worked out, but they are typically founded on tributary area. Table 1, below, summarizes data from the EWMP regarding cost, schedule and tributary area for the three identified projects discussed. S1 Authorization to Submit Draft Enhanced Watershed Management Program June 16, 2015 Page 5 of 6 Table 1 — Project Data for RAA Identified Potential Projects Proposed Range of Range of Annual RPV Compliance Project Capital Cost O&M Cost Tributary Deadline Area Eastview Park $12.8M to $0.19M to $0.2 M 100% 2032 Infiltration Basin $16.6 M Palos Verdes Landfill $57.8M to $0.86M to $1.OM 38% 2018 Subsurface Wetland $86AM Valmonte Subsurface $19AM to $0.29M to $0.32M 24% 2018 Wetland $26.5M Table 1 also includes the final water quality compliance deadlines for these projects. Some of the watersheds have more urgent timelines than others. The Machado Lake watershed has a significant deadline in 2018. The LA Harbor watershed project could conceivably be pushed out to the early 2030's. Despite the Permit deadlines, there is also considerable uncertainty in the schedule, as legal challenges, new watershed information and funding mechanisms come to light. The Permit's interim and final compliance milestones for the various pollutant / waterbody combinations are shown in Attachment D, excerpted from the EWMP. Using the assumption that the costs would be allocated purely on tributary area, which may or may not be what is decided, the City's share for these projects could range between $49 million and $56 million to build over the next two decades and more than $580,000 per year to operate and maintain once they are built. But the uncertainties with these figures are as significant as the projected costs themselves and no conclusion should be drawn other than this: a large financial outlay, likely in the tens of millions of dollars over the next two decades, will be needed to implement the plans outlined in the EWMP. Adaptive Management. These proposed pollution control measures are based on modeling estimates for pollution levels, assumed treatment system performance and very limited field data to calibrate the results. The Coordinated Integrated Monitoring Program (CIMP), formerly approved by Council and currently under review by the Regional Board, will function as a data collection program and is also a part of the City's Permit response. The CIMP will begin implementation later in 2015. Additionally, progress toward the water quality objectives, reconsideration of the water quality standards by the regulatory agencies, and other new information, may justify new or modified pollution control measures. The data gathered over the next few years and the further studies into appropriate treatment solutions that will continue after the EMWP is submitted will contribute to a fine tuning process known as Adaptive Management. Through Adaptive Management, the City will periodically adjust its programs to respond to the availability of new information and actual pollutant measurements observed over time. 5 Authorization to Submit Draft Enhanced Watershed Management Program June 16, 2015 Page 6 of 6 CONCLUSION The City has committed itself to the EWMP process, including a CIMP, by earlier City Council action in accordance with Staff's recommendations. The draft EWMP identifies MCMs and TCMs that the City will need to implement in the near future to remain in compliance with the Permit. Despite likely and significant cost increases to the City and challenging schedule milestones, the City has committed to the EWMP process. Some modifications to the control measures listed in the draft document will likely occur due to review by the Regional Board and through the Adaptive Management process as better data become available. In any case, the City will be required to significantly increase its level of effort to remain in compliance with the increasingly complex demands of the newest MS4 Permit. The Permit compliance schedule requires that agencies committed to the EWMP method of compliance submit their draft document for review by June 29, 2015. Therefore, Staff recommends that City Council provide authorization to submit the posted draft EWMP, subject to minor technical and editorial changes, in accordance with the Regional Board's deadline. ENVIRONMENTAL ASSESSMENT The EWMP is a planning document that must be reviewed and approved by the Regional Board, and any implementing projects and actions would proceed only after Regional Board approval is granted. Therefore authorizing submittal of the EWMP to Regional Board is not a project for purposes of CEQA because it is not an approval of the plan. (14 Cal Code Regs. 15378(c).) Upon approval by the Regional Board, the City may undertake implementing actions which will be reviewed pursuant to CEQA as appropriate. FISCAL IMPACT Aside from the project costs estimated in the tens of millions of dollars over the next decades identified earlier in this report, Staff is still developing costs to implement the CIMP and non-structural aspects of the EWMP on an annual basis. The CIMP is expected to be approved by the Regional Board sometime this summer and monitoring work will begin within 90 days of approval. The Draft FY2015-16 Budget has an allocation of $190,000 for the CIMP program. The EWMP program is not expected to be approved until early 2016 but the Draft FY2015-16 Budget allocates $100,000 to implement the non -capital aspects of the program that will require immediate attention. These appear to be sufficient for the coming year. Better estimates of annual costs will be known after the EWMP has been approved and will be worked into future budgets. Attachments: A — Stakeholder Incorporation (page 7) B — New and Enhanced MCMs and TCMs (page 8) C — Existing and Planned Regional BMP Projects (page 10) D — Interim and Final Water Quality Compliance Milestones (page 12) rol Palos Verdes Peninsula Enhanced Watershed Management Program 3.2.4.2.4. STAKEHOLDER INCORPORATION STAKEHOLDER MEETINGS In addition to participating in the various Technical Advisory Committees and Subcommittees, the Peninsula WMG has actively encouraged stakeholder input on the Peninsula EWMP development. Two workshops were held to engage stakeholders in the Peninsula EWMP development process and solicit input. Key stakeholders were identified and invited to participate. These stakeholders include: • Key City Staff including, but not limited to, the following: o Administrators o Public Works o Stormwater Managers • City Council Members and Water Quality and Flood Protection Oversight Committee • Governmental Organizations Staff including, but not limited to, the following: o California Water Service Company (CalWater) o LA County Parks o LA County Sanitation Districts o Regional Water Quality Control Board'nu are coraiatty ix'Y'rexi t© o US EPAC"UM* .1, enc o West Basin Municipal Water District tilePaluavV'rtiesPe"'"$"�� • Non-Governmental Environmental�pord""Axed a"dnhan�a0t tYlatershed Manug�"�etxt !'rog Organizations Staff including, but not limited to the following: o California Coastal Conservancy; o Council for Watershed Health o Environment Now o Heal the Bay " o Los AngelesWaterkeeper,�;�< o Natural Resources Defense Council (NRDC)''t4=.neer+a o Palos Verdes Botanic Garden o Palos Verdes Peninsula Land Conservancy. (PVPLC) o Palos Verdes Peninsula Unified School� District o Santa Monica Bay Restoration Commission o The Nature Conservancy o Watershed Conservation Authority o Water Replenishment District of Southern California • Non-Governmental Organizations Staff including, but not limited to, the following: o LA County Parks o Palos Verdes Golf Course o Palos Verdes Peninsula News o South Coast Botanic Garden (SCBG) o Trump National Golf Club • Palos Verdes Peninsula Residents 3-50 P a g e 19 Palos Verdes Peninsula Enhanced Watershed Management Program Table 3-1: New and Enhanced Fourth Term M54 Permit Nonstructural MCMs (Participating Agencies, Excluding LACFCD) Planning and Land Development Amend development regulations to facilitate LID implementation ♦ ♦ ♦ X X j X X X Post -construction BMP tracking, inspections and enforcement ❑ ❑ ❑ X I– X X X X Industrial/Commercial Facilities j Business assistance program and BMP notification Construction Enhanced construction plan review program ❑ ❑ ❑ ♦ ❑ ❑ X X XX X X X X X X Enhanced inspection standards and BMP requirements ❑ ♦ ❑ X X X X X Increased inspection frequencies ❑ j ♦ ❑ X X X X X Enhanced staff training program ❑ 1 ♦ ❑ _ X _ _ X� _ X X X Illicit Discharge_Det_ection/Elimination j Enhanced IC/ID enforcement and written procedures ❑ ❑ ❑ X X X X X Enhanced staff/contractor training ❑ ❑ ❑ X X I X X X Public Information and Participation Stormwater resources on Agency website ❑ ❑ ❑ X X X X X Enhanced public education 0 ❑ ❑ X X XX X j Public Agency Activities -- — _-- Enhanced BMP requirements for fixed facility/field activities j ❑ ❑ ❑ X X X X X Reprioritization of catch basins and clean-out frequencies ♦ ( ♦ O X X X X X Integrated Pest Management Program ❑ O O X X X X X Enhanced measures to control infiltration from sanitary sewers ♦ O O X I X X X X Inspection and maintenance of Permittee owned treatment controls ❑ ❑ ❑ X X X X X Enhanced inspector/staff training ❑ ❑ ❑ X X X X X X–To be implemented by agency within current M54 Permit term. ♦ Primary pollutant reduction MCM – Minimum Control Measure. ❑ Secondary pollutant reduction NSWD – Nonstormwater discharge OPollutant not addressed measure. 00 1 BMP effectiveness ratings based on similar BMPs listed in Tetra Tech's CLRP for Chollas Creek Watershed in San Diego County, 2012. 3-61Page Palos Verdes Peninsula Enhanced Watershed Management Program Table 3-3: Nonstructural Targeted Control Measures (TCMs) X — Planned TCM P — Potential TCM C — Completed/implemented TCM ♦ Primary pollutant reduction ❑ Secondary pollutant reduction 0 Pollutant not addressed to BMP effectiveness ratings based on similar BMPs listed in Tetra Tech's CLRP for Chollas Creek Watershed in San Diego County, 2012. 3-171 Page BMPffea tiveress with respect to WCtPs , . Agency Pfioftty Fiallutant ; :. Sedirri nt Volume of LA,CFD Courtly; Palosvercles, ;". "Rancho Pales Rolling Hills Tafgeted;Gantroi"MEStff „ ; , , ,., Re"duction, , ; , redu ton flow fedt�ctlorti ` ' - Unincof oral scf. '. Estates Verdes Elates Planning and Land Development LID and Green Streets Staff Training ❑ ❑ N/A _ C Industrial/Commercial Facilities _❑ --- -- - — ----- __...... - --- Clean Bay Restaurant Program ♦ Q ❑ N/A P X P Downspout Disconnect Program { ❑ ❑ ♦ N/A X X P j Dry weather runoff reduction ------ ------- f Irrigation Reduction Incentives Program i ` - ♦ ♦ ♦ N/A C - _ C C - C- Public Information and Participation Targeted Outreach ♦ ♦ ♦ X X X X Horse Manure Management ♦ Q Q N/A X N/A C C Public Agency Activities Enhanced Street Sweeping ♦ ♦ Q N/A X C C Adopt Sewer System Management Plan (SSMP) ♦ Q Q N/A C C C C Increased Street Sweeping Frequency or Routes ♦ ♦ Q N/A C C Erosion Repair and Slope Stabilization Program ❑ ♦ Q N/A N/A X X X Reporting/Adaptive Management Enhanced Tracking �� ❑ ( ❑ Jurisdictional SW Management _ _❑ I Prepare guidance documents to aid in ❑ ❑ _ ❑ X i X X X X I implementation of MS4 Permit MCMs Initiatives Brake Pad Replacement Program ♦ ♦ -� Q X j X X X X j Lead Reduction Program ♦ ♦ Q X X X X X Zinc Reduction Program ♦ ♦ Q Watershed Group i Apply for grant funding for stormwater ♦ ♦ ♦ X X X X X I quality/capture projects j Ordinances Water Efficient Landscaping ♦ Q ♦ N/A C C C C Private Road and Parking Lot Sweeping ♦ ♦ j Q N/A P Green Building Ordinance ♦ ❑ ❑ N/A X Enhanced Irrigation Runoff Reduction Program ♦ ❑ ♦ N/AX X X X X — Planned TCM P — Potential TCM C — Completed/implemented TCM ♦ Primary pollutant reduction ❑ Secondary pollutant reduction 0 Pollutant not addressed to BMP effectiveness ratings based on similar BMPs listed in Tetra Tech's CLRP for Chollas Creek Watershed in San Diego County, 2012. 3-171 Page Palos Verdes Peninsula Enhanced Watershed Management Program 3.2.4.2. REGIONAL BMPS A summary of existing and planned Regional BMPs within the Peninsula EWMP area is summarized below in Error! Reference source not found. and Table 3-4. Dail? Figure 3-1: Existing, Planned, and Proposed Regional BMPs. Error! Reference source not found. 3-28 1 P a g e 10 Palos Verdes Peninsula Enhanced Watershed Management Program Table 3-4 Summary of Existing and Planned Regional BMPs Map Existing, Treatment Drainage Percent Project Name Reference jurisdiction Watershed Planned, or BMP Type Volume per Design Area to Drainage Area ID Proposed Storm Basis BMP Per San Ramon Canyon R2 RPV Santa Monica Bay Existing Diversion TBD >0.25" Unknown RPV: 100% Chandler Quarry R3 RHE Machado Lake! , Exist�ng%Plannedl`� to#iltratnn 12,7 acre e 50 -year 707 ,Acres RHE: 100 Project System feet Malaga Cove R4 PVE Santa Monica (e) Proposed Capture & TBD TBD TBD TBD Water Reuse Bav Reuse South Coast Botanic Garden R6 UA Machado Lake Planned; Various(fl TBD TBD —134 Acres(gl RHE: 24% Regional BMP Proposed UA: 76% Valmonte Re ional PVE: 19% BMP g R8 RHE Machado Lake Proposed(h( TBD TBD TBD —400 Acres(g) RPV: 24% RHE: 57% RPV -Rancho Palos Verdes; PVE-Palos Verdes Estates; RHE -Rolling Hills Estates; UA -LA County, Unincorporated (a) Percentages are based on the drainage area within the Peninsula EWMP Watershed. Agencies outside of the EWMP boundary were not taken into consideration. (b) Percentages are estimated and are subject to change. (c) Chandler Quarry is an existing regional infiltration BMP which is undergoing redevelopment. The redevelopment project is currently under construction and has been conditioned by the City to continue to preserve the hydraulic and water quality function of the existing regional BMP. (d) Based on the 50 -year design storm. (e1 A feasibility study is currently being conducted for this project. (� The South Coast Botanic Garden has planned BMPs and opportunities for proposed BMPs. (g) Maximum drainage area determined through GIS analysis. (h) Alternative BMPs may be implemented upon further analysis. 3-29 1 Page R Palos Verdes Peninsula Enhanced Watershed Management Program Table 5-2: TMDL and 303(d) WBPC Interim (1) and Final (F) Compliance Milestones. TMDL/ Compliance Dates and Milestones 303(d) Segments Constituents Goal Weather Condition 2012 12013 12014 1 2015 12016 1 2017 1 2018 12019 12020 12032120401 Abalone Cove Winter Dry 12/28 - - - - - - Bluff Cove F Santa Monica Total Coliform Compliance with Inspiration Point 12/28 Bay Beaches Fecal Coliform Total Allowable Summer Dry - - - - - Bacteria Long Point Enterococcus Exceedance Days F 12/28 Malaga Cove Portuguese Bend Wet F Santa Monica % Reduction in Bay Nearshore Trash All Trash from Wet and Dry 3/20 3/20 3/20 3/20 3/20 and Offshore Plastic Pellets 20% 40% 60% 80% 100% Debris Baseline Santa Monica Abalone Cove DDT 22128 Bay DDT Meet WLAs Wet and Dry Bluff Cove PCBs I &PCBs Machado Lake % Reduction in 3/6 3/6 3/6 3/6 3/6 All Trash Trash from Wet and Dry Trash Baseline 20% 40% 60% 80% 100% Machado Lake Chlordane Pesticides and All Dieldrin Meet WClBELs Wet and Dry _ _ 12/28 9/30 PCBs PCBs DDT I F Algae Total Nitrogen Total Machado Lake Phosphorus 3/11 9/11 All Ammonia Meet WLA Wet and Dry I F Nutrient Chlorophyll a Dissolved Oxygen Odor DDT PCBs Long Beach Inner Harbor Copper 12/28 and Greater Fish Harbor Lead 12/28 I 3/23 Meet WEA Wet and Dry LA Harbor Outer Harbor Zinc I (Mercury & F Toxics Cabrillo Marina Mercury Chlordane)' PAHs Chlordane Determine Coliform 1/30 & 6/28 7/1 1/30 12/28 12/28 6/28 303(d) Wilmington Drain Bacteria allowable Wet and Dry I I I I I F exceedance days 5-61 Page