Regional Water Board Comments on Malibu's Groundwater Injection Plan

The city of Malibu has proposed injecting up to 347,000 gallons of reclaimed water per day into the ground as part of the Civic Center Wastewater Treatment Plant.

The Regional Water Quality Control Board offered comments last week on the city of Malibu's plan to inject nearly 350,000 gallon of reclaimed water per day into the gorund in the Civic Center.

The plan is part of the planned Civic Center Wastewater Treatment Plant.

Under a Memorandum of Understanding with the Regional Water Quality Board (RWQB), the city is required to meet strict timelines to ensure that progress is being made on the design and construction of the sewer. The MOU requires commercial properties in the Civic Center Prohibition Area be connected to a centralized wastewater treatment facility by Nov. 15, 2015.

In a letter dated Jan. 16, the RWQB wrote that the city's submital of the "Recycled Use and Storage Study," "Results of Phase 1 Work: Exploratory Test Well Drilling for Malibu Injection Project" and "The Conceptual Groundwater Injection Plan" showed the city is serious about meeting the milestones for the construction of the plant.

The RWQB asked for several technical questions to be addressed.

To read the full comments on the reports, click on the PDF document to the right.

hellwood January 21, 2013 at 02:58 AM
shouldn't we be focusing on preserving and protecting ground water? sweeping the mud under the rug is going to do damage in more ways than one.
Wendi Werner January 21, 2013 at 03:28 AM
This is not working out so well in other areas. Last year Hawaii asked the EPA to give them more time because the Staph infections in the ocean are on the rise and the corral is being killed. The waters from the ocean Vs. injection do not mix and cause many marine problems. Not to mention, seismic activities could be a serious challenge on a fault. http://www6.miami.edu/netzerowaterdorm/FWEAUCFinalReport.pdf http://scholarspace.manoa.hawaii.edu/bitstream/handle/10125/927/v39n2-230-240.pdf?sequence=1
Hans Laetz January 21, 2013 at 04:58 PM
The City of Malibu has just been set up for failure. The Water Board says: "great injection plan, you (almost) proved you can shove that much water into the ground at Legacy Park. Now, Malibu, please explain why the project we ordered you to do is such a dangerous concept." You see, the water experts at the Water Board at some point decided the best way for Malibu to get rid of 26,457,340 tons of clean water is to inject it into the dirt, to flow to the sea at Legacy Park. The city obeyed and spent $4 million and change to begin that project. Then, some loudmouths pointed out the obvious lunacy of injecting 24,457,340 tons of water into the top of an active earthquake fault, in a known liquefaction danger zone. So, now the Water Board says, "you did good Malibu, and proved that our order to you would function insofar as injectingwater into the soil. Now, what about these issues: -- Your plan relies on the water being confined to a subterranenan layer. But you have not defined or confirmed those layers exist. Do that. -- You only pumped your preferred disposal well for 15 hours, instead of 72 like the others. Why? Do it again. -- You provided no data to support your estimates of the soil's abilities to absorb the water. Where is it? -- You estimate that the layer can absorb incoming water at twice the rate that it excreted pumped water. Where on earth did you get that estimate, and is it valid? [MORE]
Hans Laetz January 21, 2013 at 05:13 PM
More "technical issues" for the City to provide to the Water Board: -- Your study proposes "Well 3" as the best place to inject the water, but did not explain why or present enough evidence to support that. Do it. -- Your study shows underground water levels that are different than what your test logs show. Why? -- You said this worked at Goleta. How is Goleta similar or different to Malibu? -- You say the water will be confined by "confined conditions." Information should include details about the depth, thickness and extent of these supposed confined conditions. -- You assume the water levels will not change, but you are going to dump water in there. How will that change the water levels? -- You assume your water will be the only inflow to the "confined area." How do you know water from the hillsides or upstream will not flow in? Discuss. -- Explain why you did not consider the likelihood that your geologic assumptions, based on very limited data, might be wrong. -- What happens if there is a series of big storms, and the water levels change? -- How did tidal ups and downs affect your observation wells, when you did your tests? -- What is the time amount between water entering your injection well, and its arrival in either the Malibu Lagoon or Pacific Ocean? [MORE]
Hans Laetz January 21, 2013 at 05:43 PM
And, here's the big one: "Include an evaluation ofthe seismic impact caused by injecting substantial amounts of wastewater to underground aquifer. The discussion shall be specific for different geological formation, locations in the Civic Center, and scenarios, including liquefaction, fault plane lubrication, subsidence, artesian conditions, and structural integrity." In other words, WHY DID YOU IGNORE THE MALIBU COASTAL FAULT? The Water Board just ordered Malibu to reverse course. The city should immediately order a study on alternative water uses. Every drop of that precious water should be used, locally, for some sort of beneficial use. Injecting water into the top of an earthquake fault, in a known liquefaction zone, without studying the consequences? Perfectly safe, says the city's contract engineers. OK, says the city council. Three comment letters to the Water Board (from me, Heal The Bay and Joan Lavine) put the Water Board on notice that they originally screwed up, badly. To its credit, the Water Board now wants these earthquake and liquefaction issues studied, before we go any further on this dangerous, wasteful injection scheme. The city should cut bait, now, and find some alternatives.
Ed January 21, 2013 at 09:36 PM
The masses should understand that this was heal the bay and bay keepers doing in the first place. They are the ones who forced this, and they should be held to some responsibility also.
J. Flo January 21, 2013 at 09:40 PM
Great job, Hans!
Wendi Werner January 21, 2013 at 10:12 PM
http://pubs.usgs.gov/bul/1951/report.pdf Read up
Wendi Werner January 21, 2013 at 10:46 PM
You must not forget the letter written by Sally Benjamin. Part of her letter states: The lower osmotic pressure of the treated effluent in relation higher osmolality of the ocean will not mix readily. The discusses the chloride, sulfate and dissolved solids as well carbonates that the treated injected effluent will dilute the fresh ·w8ter underground. There will be an osmotic gradient between the t'eated effluent and the fresh water also between the now diluted fresh w ter to the ocean. No discussion occurs regarding these gradients or of sodium; treated water to fresh water and now diluted fTesh water to lhe ocean. The spreadsheet shows that the treated effluent sodium levels 'kill have 119 units while the injection wells (fresh water) range fro 490 - 1100 units. From the spreadsheet we lcan1 that the treated c lluent water has a considerably lower osmotic pressure, par-ticularl ' well MW03, than the fresh water where the effluent will be inject d. An assumption can be made that gradient will be larger when comp ed to the ocean; diluted fresh water to ocean water. The discussion ne~ds to continue with an analysis of the diluted fresh water to the ocean. These two waters (diluted fresh water and the ocean) coming together won't "blend/mix" for a period of time and/or distance due to the o motic gradient.
Cece Stein January 22, 2013 at 03:33 AM
We are currently injecting untreated sewage into the ground now. Every one else sends it to Hyperion, why don't we?
Paul Grisanti January 22, 2013 at 08:33 PM
Cece, It is apparent that you do not understand septic systems. We are not "currently injecting untreated sewage into the ground". Hyperion is a great option if you can build huge pump stations and pipes to carry the sewage through the known slide areas in the Big Rock Area safely. Hyperion doesn't treat the sewage to get it as clean as the city of Malibu has agreed to do and is still operating a direct ocean outfall. Other than that, Hyperion is a great option.
hellwood January 22, 2013 at 08:50 PM
...and Hyperion was never an option
Hans Laetz January 22, 2013 at 09:15 PM
Paul and Hell are right. Myriad reasons that Hyperion (or a mini-Hype) would be a bad idea, not the least of which is that most of Malibu functions just fine with energy-efficient, low-tech organic sewage digesters AKA septic tanks or OWTS. Groundwater samples in nearly all of the city are NOT full of human crud. Sewage mains break. Pumps fail. When that happens, beaches close. When a septic fails, there is a small spill and big stink. Industrial, large-scale sewage disposal is mandatory where dense population or unusual local conditions make small-scale disposal precluded. Like LA or Trancas Canyon. They have sewers. And, the real truth is, the lack of a sewage system has been used as a choke on development. If there were a sewer on PCH, greater Malibu would have 450,000 people. Do you think having a sewage main under Latigo Canyon Road at the landslides would be a good idea?
hellwood January 22, 2013 at 11:49 PM
how much of the pharmaceuticals and hormones in the 350,000 gallons of sewage (per day) won't be effectively removed during the treatment process before it is injected into the ground water?
Cece Stein January 23, 2013 at 12:05 AM
Agreed, we have really bad faulting geologies for sewer pipes but leech field percolations from septics are not considered clean treated water oozing into our aquifers and groundwater either. There is a reason amonia levels are high deep in the sands between beachfront properties and the ocean. With Hyperion bound sewer pipes being out of the question for the obvious reasons, it would be better to have the water disinfected into title 22 before being put into the ground, but can the Civic Center handle that much without negative consequences( ? ). What are the alternatives to deep well injection? Any solution must be tied to no growth or very slow policy in the service area.
Wendi Werner January 23, 2013 at 05:10 AM
Read what this is doing to Maui http://dontinject.org/?page_id=15
marie January 23, 2013 at 05:51 AM
Thanks for the link Wendi. At this rate, injections into our fault may just equate to some beachfront houses becoming the next polluted, dead reef.
Cece Stein January 23, 2013 at 04:21 PM
http://www.independent.com/news/2011/feb/26/enviros-sue-over-septic-system-rules/ A direct quote from the link above: "Hillary Hauser, Heal the Ocean’s executive director, pointed specifically to Rincon Point as an area of concern, noting that improperly treated discharge from a cluster of septic systems in the area has and continues to make surfers and beach-goers sick. “DNAtests conducted by our organization confirmed the presence of human waste in the Rincon Lagoon,” Hauser said in a statement. “There are many places in California where septic systems do not belong, where similar leaching occurs daily.” Rainy weather, like the kind hitting the South Coast this weekend, only exacerbates the issue, said Hauser, as pollutants are flushed from properties in higher concentrations.California is one of only two states in the country that doesn’t have set ways to monitor on-site wastewater treatment systems, the discharges of which have often been proven to contain pollutants like parasites, bacteria, toxic compounds, and heavy metals."
Wendi Werner January 24, 2013 at 01:10 AM
Spoke with my friend who works there today. Confirmed that the homes are hooking up to the sewer treatment facility, as they should. So, since we do not have that, are you saying that we should shove the water into the ground where it will return to the restored lagoon?
Cece Stein January 24, 2013 at 01:46 AM
At least it will be treated before it gets there!
Cece Stein January 24, 2013 at 01:47 AM
But we are open to other alternatives i.e.: destinations. : )
Cece Stein January 24, 2013 at 05:55 PM
Hellwood, lets pose your question about pharmaceuticals and hormones but in conjunction with our septic systems. Our current systems ALSO do not effectively remove human waste bacteria and viruses, house hold cleansers, laundry phosphate, drano and a host of other toxic ingredients from leching into our soils with direct hydraulic connections to our waterways. From what we understand, the TREATED water will be injected into wells far far below the surface hydraulics of our current septic disposal and that of the Lagoon.
hellwood January 24, 2013 at 07:51 PM
cece, im more concerned about the potential of the high concentration forcing its way through whatever path of least resistance it finds(...back up to the surface? ...to the underground streams that flow to the lagoon? ...to the colony? ...and eventually everywhere). we are talking about roughly a million gallons every 3 days forced down the same hole. the high concentrations of antibiotics could be a recipe for drug resistant bacteria and viruses. another flaw in the injection plan is that it is analogous to indefinitely slowly pumping up a tire and hoping there is a leak big enough release the building pressure. sure, the civic center may not blow, but the millions of gallons have to go somewhere, and it wont just magically disappear. the area is already saturated, and adding more water just creates a real liquefaction danger in the event of an earthquake. I could go on and on all day.
hellwood January 24, 2013 at 08:06 PM
...so people can relate, its about 12-14 swimming pools / day
Hans Laetz January 24, 2013 at 08:16 PM
Cece, you assume that the treated water would be injected far below the surface hydraulics. The Water Board does not share that assumption. If this were the plains of Kansas, and the aquitards and gravel beds were uniform, there would be effective barriers to prevent the treated water from mounding up around the injection well. But we have mountains and subterranean historic canyons and debris fields. Clay and gravel beds cannot be assumed to be even layers. Plus, there is an active fault bisecting the field. Faults cause discontinuities and pulverize geologic structures that would otherwise be water-tight. Injecting water (even at low pressures and at low depths) into a fault opens up all sorts of possibilities for the water up, down, sideways. Not to mention, water will alter the seismicity of the fault itself. The Water Board has just told the city it has to prove that the aquitard will function as the city hopes, and channel the wastewater out to sea. Extensive, expensive testing will be required. There is no guarantee this scheme will work, in fact, it is likely that it will not. Can the City and Board GUARANTEE that the injection scheme will not effect the dynamics of the fault? The answer is no, under no circumstance can such a statement be scientifically valid. So, will the public accept an injection plan that cannot guarantee it will not add to earthquake or liquefaction dangers all along the Malibu coast? I say no. What do you say?
Cece Stein January 24, 2013 at 08:28 PM
You mean the same amount that is now currently leeching into the flood plain now? But maybe we are missing something? We would be taking all of the household and commercial waste that is now leeching into the ground untreated, disinfecting it and putting it back into the ground. So unless we are importing water to put into the injection wells, where do end up putting more into the water tables than we are now with septics. You bring up a good point that we are putting 12 -14 swimming pools a day of untreated waste into the ground now and some of the shallow geologies have sprung leaks.
Hans Laetz January 24, 2013 at 09:10 PM
You miss the point. The groundwater basin at downtown Malibu is oversaturated and polluted. The city's plan addresses the pollution, but not the oversaturation. In fact, it may add to the oversaturation. The Water Board just told the City that. Plus, the City's plan would concentrate all the water in one place, 50 yards south of the Malibu Coastal Fault, and inject it down to the bedrock, where the fault stresses begin The Water Board just told the city to look at alternative disposal sites NOW, before it gets a permit. The city wants a permit to inject first, then do a costly EIR to look at the dangers and alternatives. We could have saved at least $2 million by looking at the disposal alternatives FIRST. We can save several millions more by looking for alternative places to use this clean water NOW. It is important to remember we are looking at two different issues: the sewage collection/treatment, and the DISPOSAL of the cleaned water. That's what has the Water Board, Heal The Bay and me so concerned.
Cece Stein January 24, 2013 at 10:10 PM
But isn't part of the current "oversatuaration" of the ground water a result of household and commercial leech fields draining into the Civic Center/ Colony flood plain ? By all means if there is a better alternative to dispose of the treated water rather than replacing " swimming pools " of septic waste into the ground ,it should be explored . You mentioned creating a Steelhead stream above Corral but what about storing it in a lined artificial pond to be used for irrigation or fire fighting needs .Pepperdine does a pretty good job of recycling its reclaimed water .


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