If your site is in the Central Valley, were you one of the many that received a Notice to Comply (NTC) this year for new salinity requirements? Naturally occurring and human-influenced salt concentrations in waters and soils are a rising concern in the Central Valley of California. High levels of salts can affect water and soil quality, impair crop production, and change ecological functions of the environment. CV-SALTS (Central Valley Salinity Alternatives for Long-Term Sustainability) is a collaborative effort led by state agencies looking to find solutions to the salt problem in the Central Valley. In May 2018, the CV-SALTS group established a Salt Control Program via Resolution R5-2018-0034 (and as amended in the 2020 Resolution R5-2020-0057) to regulate salinity impacts throughout the Central Valley. The Program has initiated and will be conducting various studies and other efforts in a phased approach over the next 10-15 years to determine an effective path for long-term salinity management planning in the Central Valley.
The Program requires all Central Valley entities with National Pollutant Discharge Elimination System (NPDES) permits containing salinity requirements to decide on one of two compliance pathways within 6 months of receiving their NTC:
Pathway 1: Conservative Salinity Permitting Approach, and
Pathway 2: Alternative Salinity Permitting Approach.
While all facilities can select the Alternative Approach in Pathway 2, the Conservative Approach in Pathway 1 is reserved for facilities that meet qualifying criteria. Permittees choosing Pathway 2 must participate in the region-wide Prioritization & Optimization Study (P&O Study)—paying an annual fee to do so—and remain in compliance with permit provisions applicable to their discharge for the duration of the study. Permittees selecting Pathway 1 must be able to meet the conservative effluent limits for salts parameters, prepare a Salinity Characterization Report to demonstrate eligibility for selecting this option, and receive approval from Regional Water Quality Control Board staff. Facilities that obtain approval to take the Conservative Approach are exempt from participating in the P&O Study so long as they continue to meet Pathway 1 requirements. Salt Control Program requirements will be incorporated directly into the facility’s next NPDES permit.
If you would like to learn how Salt Control Program requirements may affect your site, or need assistance in selecting the best Pathway for your facility, contact Christine Wong at cwong@algcorp.com or at (805) 764-6019.