Posted by: Deirdre Des Jardins | May 7, 2018

WaterFix: Construction Noise Impacts

Save the California Delta Alliance explains how noise impacts of the WaterFix project construction on the towns of Hood and Clarksburg are underestimated in the CEQA environmental documents.

Save the California Delta Alliance (STCDA)

In this blog, I’ll report on the findings from the Water Board Hearings about the noise impacts from the tunnel construction on the small communities in the North.

The towns of Hood and Clarksburg are in the middle of the massive tunnel project. That is where the pumping station will be located.

An expert sound witness hired by Save the California Delta Alliance to testify in the Water Board Permit Hearings about the WaterFix (Delta Tunnel) permits, reviewed the WaterFix Noise Chapter and found that, in his opinion, the calculations for sound used by the DWR are incorrect. Walter Salter testified that, ‘Construction noise levels are likely underestimated in some areas, by as much as 10 dB to 15 dB or more…” He found that, “Construction noise (pile driving, blasting, and trucking activities) is expected to significantly interfere with the activities at certain recreational facilities or businesses available for community…

View original post 204 more words

At 5:00 pm on May 1, 2018, the Clerk of the Board for the Santa Clara Valley District published the Delta Conveyance Design and Construction Joint Powers Agreement  for the construction of the WaterFix project facilities. The Delta Conveyance Joint Powers Agreement states that the Board shall consist of “up to five (5) Directors and five (5) Alternative Directors, with each pair appointed by and representing the following Members or class of Members:”

i. Metropolitan Water District of Southern California (State Water Project)

ii. Kern County Water Agency

iii. Santa Clara Valley Water District

iv. State Water Project contractor, selected by otherwise non-represented State Water Project contractors.

v. Metropolitan Water District of Southern California (Non State Water Project capacity)

The Joint Powers Agreement specifies that “the number of Directors may be expanded to seven (7) Directors and seven (7) Alternative Directors if, at any point after the execution of this Agreement, there are three or more CVP contractors, other than Santa Clara Valley Water District, that desire to become Members. The Delta Conveyance Joint Powers Agreement provides that for the first two years, the Construction JPA president will be the Director appointed by Santa Clara Valley Water District, and the Construction JPA vice president shall be the Director appointed by Metropolitan Water District.

The Joint Powers Agreement attempts to indemnify the member agencies, and the JPA officers, agents, and employees, from liability for any activities conducted under the Joint Powers agreement. The Joint Powers Agreement further provides that the JPA will defend the member agencies against “any claim, cause of action, liability, or damage resulting therefrom.”

The Joint Powers Agreement states that the JPA “may purchase such insurance as the Board may deem appropriate,” but does not require the JPA to do so. It is unclear if the current WaterFix tunnel design is even insurable, because the WaterFix design process has not met tunneling industry standards for risk management. The second edition of the International Code of Practice for Tunneling was drafted by the International Tunnelling Insurance Group in 2012, and adapted for the United States as the Guidelines for Improved Risk Management on Tunnel and Underground Construction Projects in the United States Of America. The Guidelines were drafted by the Underground Construction Association of the Society of Mining, Metallurgy, and Exploration. According to a description in Tunneling Business Magazine, “The Guidelines recommend a detailed process for doing a risk assessment, and for developing a list of mitigations… The Guidelines reflects the consensus of a wide variety of industry experts and other professionals involved in the tunnel and underground construction industry in the United States.”

The UCA-SME Guidelines state:

The importance of any risk depends not only on the likelihood that something may go wrong, but, if it does occur, how severe the consequence may be. The process of risk management—including risk assessment, characterization, and response, as well as elimination, mitigation, avoidance, transference, or acceptance—is required to identify and clarify ownership of risks and should detail clearly and concisely how the risks are to be allocated, controlled, mitigated, and managed. (underlining added.)

But the Delta Conveyance Joint Powers Agreement denies any ownership of risks by the water agencies constructing the project.  The WaterFix 2015 Final Draft Conceptual Engineering Report also does not clearly identify project risks, and defers risk mitigation to future engineering design.

1 Jones tract levee breach, 2004

As reported by California Water Research, in addition to the risks of tunneling under Delta levees, the seismic design criteria for the WaterFix tunnel lining has yet to be set, and there is no assessment of the performance of the tunnel lining in a maximum considered earthquake. An examination of the 2015 WaterFix Final Draft Conceptual Engineering Report shows that a majority of the tunnel contractors did not want to design the tunnel lining segments, because they did not want the liability.

As also reported by California Water Research, neither Metropolitan Water District nor the Department of Water Resources have made efforts to determine the exact location of abandoned gas wells in the tunnel alignment, although this was recommended in 2010 by an independent review panel. Although the International Code of Practice for Tunneling requires a design checking procedure, no such procedure has been specified for the WaterFix tunnel design process, and it is unclear if the preliminary or final design will have independent review.

The indemnification language in the JPA agreement may not actually indemnify Metropolitan Water District, Santa Clara Valley Water District, Kern County Water Agency, or the State Water Contractors from liability for any claims arising from the WaterFix tunnel design and construction. In Tucker Land Co. v. State of California 2001)1114 Cal. App. 4th 1191, the 2nd District appellate court reviewed Chapter 21 of the Government Code,Tort Liability Under Agreements Between Public Entities, and associated Law Revision Commission opinions. The court concluded “these sections make clear that the Legislature intended that member entities of a JPA be liable for the torts of the JPA.”

Posted by: Deirdre Des Jardins | April 30, 2018

WaterFix tunnel construction: gas wells

The WaterFix/Delta tunnels go through the West Thornton – Walnut Grove and River Island gas fields, just east of the Rio Vista gas field, the largest natural gas field in California.  The map below, a closeup from the map on page 155 the WaterFix 2015 Final Draft Conceptual Engineering Report, shows the high density of gas fields and gas wells in the Delta tunnel alignment near Walnut Grove. The purple shaded areas are gas fields, and the purple dots are gas wells – either producing or abandoned.


gas field map

The 2010 internal DHCCP engineering document for the Delta tunnels discusses precautions recommended by an Independent Review Committee, which were never publicly disclosed by DWR or MWD:

Proposed Tunnel Alignment Revision

The Outside Reviewers recommended the tunnel alignment avoid any active or idle gas wells and minimize intersection with plugged wells due to the potential for damage to the wells by the tunnel boring machines during mining operations.

The 2010 internal DHCCP engineering document also states that the Independent Review Committee recommended the following:

  • Participate in the DOGGR Well Review Program;
  • Obtain permits for any well work (active or abandoned);
  • Given that well coordinates on DOGGR website are not necessarily accurate, conduct a survey to determine their exact location;
  • Avoid all wells to the extent practical; avoid tunneling over wells;
  • Given that DOGGR makes no guarantee that wells are properly abandoned or will not leak after abandonment, address each proximate well specifically;
  • DWR has neither designed nor constructed a project that passes through a gas field or near existing gas wells, either active or abandoned. Accordingly, and as recommended by the Outside Reviewers, engage the services of a petroleum engineering consultant with experience in the installation and abandonment of gas wells (ideally one familiar with the Delta and its gas wells and fields) to advise the DWR and the DHCCP.

MWD has since taken over the WaterFix tunnel engineering, and appears not to have implemented any of these recommendations.

The only mitigation for gas well risk that MWD’s engineers are proposing in the WaterFix Conceptual Engineering Report is to “identify the minimum allowable distance between wells and tunnel excavation” with a future study. The 2015 Conceptual Engineering Report also states that “it is anticipated that the State of California Division of Occupational Safety and Health (Cal/OSHA) may classify the tunnels as ‘potentially gassy.'”

North Delta Cares presented testimony in the WaterFix Water Right Change Petition Hearing by Mark Pruner, who is on the Board of Directors for the Clarksburg Fire Protection District.    Pruner testified on cross-examination that DWR had never discussed the gas well risk with the Clarksburg Fire Protection District, nor disclosed the recommendations of the 2010 Independent Review Committee on tunneling through a gas field.  Pruner testified that the Clarksburg Fire Protection District would have commented that DWR must follow the recommendations of the Independent Review Committee.

DWR’s attorneys objected to the entire line of questioning.

Metropolitan Water District has a disastrous history with tunneling through strata with methane gas. The worst tunneling accident in California history occurred in 1971 during MWD’s boring of the 22′ Sylmar tunnel to Castaic reservoir with a tunnel boring machine.    The Sylmar tunnel was known to go through strata with oil and gas.    As documented by in an engineering journal article by Richard J. Proctor, former Chief Geologist for MWD:

(1) The MWD geologic report, given with the Specifications to all bidders, warned of the possibility of encountering oil and/or gas in the western part of the tunnel route. This warning was based on: (a) producing oil fields in the region; (b) oil and tar seeps in the area; (c) the presence of Pico Formation sandstone in the western part of the tunnel route—a known source-rock of oil; (d) the presence of oil and gas in two nearby tunnels—the L.A. Department of Water and Power’s Newhall Tunnel in 1912, and the MWD’s Balboa Tunnel in 1967; (e) the crossing of the Santa Susana fault, which acts as an oil trap in the nearby Cascade Oil Field.

(2) Several months before the explosion, the contractor posted a notice that stated ”Expect explosive gas ahead.”

There were other factors listed in the article by Proctor.   Lockheed was the low bidder on the tunnel construction contract, and was trying to finish the tunnel quickly to get a bonus from Metropolitan Water District for early completion.  Workers on the tunnel were not adequately trained.  When workers smelled gas, the supervisor stopped work briefly, but then kept going, and did not implement all the recommended precautions.   The day of the fatal explosion, they had to stop work 35 times. Firefighters worked under extremely hazardous conditions in the smoky, water filled tunnel for the next two days, extinguishing fires and searching for workers.

After the fatal explosion, construction was halted for 2 years while MWD, Lockeheed, and OSHA figured out how to proceed safely.   Lockheed also filed a breach of contract suit against MWD for not warning of the real danger of encountering gas during tunnel boring.

1 The Sylmar Tunnel Disaster, June 23, 1971 Source: Los Angeles Firemen’s Relief Association

There was a 54-week criminal trial against the tunnel contractor, resulting in the highest municipal fines and some of the greatest civil damages awards of its time. After the longest municipal court trial in U.S. history, Lockheed Shipbuilding & Construction Co., a subsidiary of Lockheed Aircraft, was found guilty of gross negligence and violating state safety laws, and fined $106,250.  Lockheed was also forced to pay $9.3 million in civil judgments.

MWD dedicated a plaque to the 17 workers who were killed in the explosion in December of 2013.  But MWD appears not to have connected the dots with the need to follow the recommended precautions for tunneling through the Rio Vista gas field for the WaterFix project.

Corrected re: Rio Vista gas field 4/30.

Posted by: Deirdre Des Jardins | March 31, 2018

WaterFix: Sac River bypass flows not determined, exempt from export limits

One of the major issues in the State Water Resources Control Board’s hearing on the WaterFix Change in Point of Diversion is the proposal to exempt the new North Delta diversions from the Board’s export limits for the State Water Project and Central Valley Project. The export limits are part of the State Water Resources Control Board’s 2006 Bay-Delta Water Quality Control Plan Table 3 requirements, which set standards to protect fish and wildlife. The 2006 Bay-Delta WQCP export limits basically limit total Delta exports to 35% of total Delta inflow from February to June, and 65% from July to January. (There is an exception for dry Februaries.) The export limits were originally proposed in 1995 by the water users to provide “substantial protection” to fish in the Delta.

The Department of Water Resources and Metropolitan Water District are now proposing that the State Water Resources Control Board exempt the new North Delta diversions from the export limits in the 2006 WQCP. If the North Delta diversions are exempt from the export limits, the Water Board’s only required bypass flows for the Sacramento River will essentially be the minimum Delta outflows, or the minimum to maintain salinity standards in the Delta.

The modeling for the proposed WaterFix operations does not show severe impacts from ending the export limits, and from the Board not requiring any bypass flows in the WaterFix permit. The reason is that the WaterFix modeling assumes very protective bypass criteria that are proposed to be triggered by the presence of outmigrating Winter and Spring Run Chinook salmon. But the National Marine Fisheries Service 2017 Biological Opinion for the WaterFix notes that all of the operational criteria are subject to change, stating,

Some of the criteria identified in the PA may have substantial water supply effects while providing limited ability to minimize effects to species. As a result, operational criteria identified in the CWF PA may be modified, relaxed or removed and may no longer apply to an operation with CWF, while other operational criteria, not currently identified in this CWF consultation or those already identified may be included or modified. Therefore, the operational criteria that are described in the CWF BA and in this Opinion are likely to change between now and when CWF becomes operational. (p. 16, underlining added.)

Chapter 3 of the WaterFix Final EIR/EIS also notes that the operations analyzed in the Final EIR/EIS are only “modeling assumptions,” stating:

While the analysis for Alternative 4A in the resource chapters utilizes H3+ modeling results, actual operations will ultimately depend on the results of the adaptive management program. (p. 3-262.)

Thus the initial operational criteria that are ultimately adopted for the WaterFix may be far less protective than what is analyzed in the Final EIR/EIS and Reclamation’s Biological Assessment.

An even larger long-term issue is what happens if the endangered Winter and/or Spring Run Chinook salmon go extinct because of climate change and/or the new diversions. Would the Water Board then step in and require minimum bypass flows on the Sacramento River to protect unlisted fish, boating, minimum water levels for agricultural diversions, and other beneficial uses in the Delta?

Sacramento — Part 2 of the State Water Resources Control Board’s Hearing on the WaterFix Water Right Change Petition (aka Delta tunnels) has been ongoing since February 22, 2018.  On March 14,15, and 16, 2018, the County of San Joaquin, the San Joaquin County Flood Control and Water Conservation District, Local Agencies of the North Delta, and the South and Central Delta Water Agencies presented testimony by a geotechnical engineer and the principal engineer for many of the Reclamation Districts in the Delta. The engineers testified on the inadequacy of the preliminary engineering for the Delta tunnels, and the resulting risks to the project, and to people and property in the Delta.

The engineers’ testimony showed that MWD and DWR have been dissembling about the Delta tunnels being a “fix” for a maximum earthquake in the Delta, as analyzed in the 2008 Delta Risk Management Strategy report. The Delta tunnels are not currently being designed to withstand a maximum earthquake in the Delta, as defined by the American Society of Civil Engineers and required by the California Building Code for above ground buildings and structures.  The expert testimony also raised very real concerns that inadequate structural design of the Delta tunnel lining could not only result in the Delta tunnel lining leaking in an earthquake, but actually increase the risks of the levees failing, if the problems with the current Conceptual Design of the Delta tunnels are not addressed.

1Effects of Maximum Considered Earthquake on blind fault in the Delta, according to Delta Risk Management Strategy

Fail to plan, plan to fail

Josef Tootle is the Principal Geotechnical Engineer with ENGEO Incorporated, and has 20 years of experience with projects in the Delta.  Tootle testified that the geotechnical borings done to date for the Delta tunnels are completely inadequate, even for the preliminary engineering. Tootle also testified that failing to have adequate geotechnical exploration could lead to delays in the project, needing to relocate the tunnel alignment, or, if the errors weren’t dealt with in the preliminary design, potential injury to life or property in the Delta if the tunnel lining failed due to seismic or structural stresses.

Josef Tootle’s concern about the impacts of the tunnel lining leaking under critical structures was corroborated by testimony of Chris Neudeck, principal at Kjelsen, Sinnock and Nuedeck. Neudeck is the the District engineer and Local Agency Representative for 26 of the Reclamation Districts in the Delta. Neudeck expressed concern not only for the impacts of tunnel lining leakage on the Delta levees, but also about risks of tunnel boring under the levees. Neudeck testified that the tunneling under the levees would need to be done very carefully and monitored very closely. But MWD and DWR have not set any standards for tunnel boring, deferring determination of allowable settlement and monitoring procedures to future engineering. Neudeck testified that DWR has never discussed risk management while tunneling under the levees with the Reclamation Districts.

Tom Williams, a PhD geologist who has consulted on tunnel and pipeline projects all over the world, raised similar concerns about the feasibility of the Delta tunnel conceptual design, and the risk to levees from the tunnel construction and operation in testimony in Part 1 of the WaterFix hearing.

Why DWR’s proposed mitigation may be meaningless

The “Avoidance and Mitigation Measures” in the WaterFix Final EIS/EIS state that DWR has committed to designing the Delta tunnels according to applicable codes and standards.   Chapter 9 of the WaterFix Final EIR/EIS, on Geology and Seismicity states: Regulatory Design Codes and Standards for Project Structures

State and federal design codes and standards will regulate construction of the many structures that are part of the proposed project. These codes and standards establish minimum design and construction requirements, including design and construction of concrete and steel structures, levees, tunnels, pipelines, canals, buildings, bridges and pumping stations. (p. 31.)

But cross-examination in the WaterFix Hearing showed that above ground building codes don’t necessarily apply to deep underground structures, and DWR’s own adopted standards include no objective criteria. Josef Tootle affirmed the following on cross-examination by California Water Research:

  1. Above ground buildings and structures in California are designed to withstand a “Maximum Considered Earthquake,” without collapsing.   A Maximum Considered Earthquake is defined by the American Society of Civil Engineers (ASCE) as an earthquake with a probability of 2% in 50 years, or 1 in 2,475 years.
  2. The ASCE standards may not apply to the tunnels.  (DWR’s attorneys previously claimed they do not.)
  3. DWR’s 2015 WaterFix Final Draft Conceptual Engineering Report shows the Delta tunnels are being designed to withstand a 5% in 50 year earthquake (1 in 1,000 years), which has weaker ground shaking than the Maximum Considered Earthquake.
  4. DWR’s 2010 internal, unreleased preliminary engineering report showed that the tunnel lining joints could “de-stress” in a 5% in 50 year earthquake, causing a temporary increase in leakage.

California Water Research asked Mr. Tootle if he was the Geotechnical engineer on a tunnel project, and the preliminary seismic structural analysis showed that tunnel joints could “de-stress” and leak in an earthquake, would he want to see further analysis?   He said yes. (The Delta tunnel Final Draft Conceptual Engineering Report does not disclose any seismic structural analysis, but states that MWD’s and DWR’s engineers are now assuming that seismic forces would fall off by 50% with depth. The assumption was contradicted by seismic data.)

DWR is promising to address the seismic issues with the Delta tunnels in future preliminary design, but is not proposing to release the future preliminary design documents for review by stakeholders. Instead, DWR is proposing to rely on “applicable codes and standards” to ensure that the tunnel lining has an adequate design.

But the standards listed in section include DWR’s Seismic Loading Criteria Report, issued by DWR in 2012.   The standards in DWR’s 2012 Seismic Loading Criteria report are no standards at all.  This is what the Seismic Loading Report has to say about pipelines and tunnels:

Section 3.2.2 Pipelines

Similar to SWP canals, little documentation exists regarding the seismic loading criteria used in the design of existing pipelines including the recently designed pipelines. DWR does not currently use any analytical model to predict the behavior of buried pipelines during earthquake occurrences. This is partly because earthquake loads may not be a concern for pipelines below the ground surface. Furthermore, AWWA manuals do not explicitly include seismic loading criteria for water pipelines. (p. 16.)

[note – Water supply pipelines DO fail in earthquakes.]

Section 3.2.3 Tunnels

The seismic loading criteria that were used in the design of existing SWP tunnels also have not been found. Many references, including the “Seismic Design of Tunnels – A Simple State-of-the-Art Design Approach” monograph (Jaw-Nan Wang and Parson Brinckerhoff, 1993) discuss the seismic loading criteria that could be used for tunnels. (p. 18)

Josef Tootle confirmed that these sections of the SLC report indicate that DWR could not locate seismic design criteria for any of the existing SWP pipelines or tunnels, and that the sections did not appear to set any criteria for the design of pipelines or tunnels. California Water research also cross-examined Josef Tootle about the foreward to DWR’s Seismic Loading Criteria report.  It states:

These guidelines are a suggested starting point, but do not take the place of the design engineer’s judgment and additional information available for a particular project site. Each design engineer should have the knowledge, experience, and insight into the importance of their facility to select the appropriate seismic design load and subsequently to apply that load in an appropriate manner to the structure. Similarly, this report does not prescribe the procedure or process of analyzing the structure. Again, this is design engineer’s responsibility to select the method of analyses that best suit the complexity, criticality, and importance of the facility. (p. 3)

Josef Tootle thought that the Seismic Loading Criteria report should set minimum standards, which it does not.   It is unclear what DWR’s commitment to build the Delta tunnels to “applicable codes and standards” actually means.  Given the failure by DWR set any clear, objective engineering criteria for the Delta tunnels, there a very real risk that cost-cutting by the water contractors who are paying for the project could compromise both long-term performance and public safety.

California Water Research has filed a Public Records Act request to the State Water Resources Control Board, requesting that the Board disclose Ex Parte communications with the Governor’s office and the Natural Resources Agency to the WaterFix Hearing parties.   Communications regarding the WaterFix hearing, or permit terms for the State Water Project and Central Valley Project, are requested.

California Water Research’s principal, Deirdre Des Jardins, stated, “the issue of providing increased flows to restore the Sacramento Delta estuary has become extremely politicized.  The Board’s WaterFix Water Right Change Petition hearing is a quasi-judicial process and there needs to be better transparency.”

California Water Research has also moved for a continuance of the WaterFix hearing until the documents are produced and any Ex Parte issues that are uncovered are resolved. The motion, filed in the WaterFix Hearing, states in part,

California Water Research recently ran across the February 11, 2016 Hearing Officers ruling that communications about any issues concerning the WaterFix” relevant to the Phase 2 update of the Bay-Delta planning process would be consistent with the Ex Parte rule:

We acknowledge the concerns raised by some of the parties regarding how application of the prohibition against ex parte communications in this proceeding could restrict otherwise permissible communications in the Bay-Delta planning process. At this time, it is not clear to what extent, if any, issues concerning the WaterFix will be relevant in the larger planning process. If this becomes a problem as Phase 2 progresses, the State Water Board will reach out to stakeholders and parties and determine the best way to allow any necessary open dialogue in the planning arena consistent with the ex parte rule applicable to the WaterFix hearing. (February 11, 2016 Hearing ruling, p. 5, underlining added.)

While the Phase 2 Bay-Delta Water Quality Control Plan update (“Phase 2 update”) is not considering the WaterFix, the Phase 2 update is considering amendment of the permits of the SWP and CVP, which has significant overlap with the Board’s consideration of adoption of “appropriate Delta flow criteria” in the WaterFix Water Right Change Petition hearing (“WaterFix hearing”.)

The State Water Resources Control Board has not, to date, reached out to WaterFix hearing parties and stakeholders to “determine the best way to allow any necessary open dialogue in the planning arena consistent with the ex parte rule applicable to the WaterFix hearing,” nor has the Board disclosed any Ex Parte communications regarding proposed permit terms for the SWP and CVP to the WaterFix hearing parties. Ex Parte issues regarding parallel processes should be addressed and resolved before the WaterFix hearing proceeds.

To allow WaterFix hearing parties the chance to resolve any Ex Parte issues that are uncovered, California Water Research hereby moves that the Hearing Officers continue the hearing until Ex Parte correspondence and documents in the attached document, “Public Records Act request for Ex Parte communications by other agencies” is produced. (This continuance motion is moot if the stay requested by Save the California Delta Alliance and Sacramento County et. al. is granted.)

Posted by: Deirdre Des Jardins | October 8, 2017

WaterFix tunnel lining could leak in a large earthquake in the Delta

The construction of two forty foot diameter tunnels in soft soils consisting of sedimentary layers of sand and peat is a significant engineering challenge. Given the large diameter of the tunnels, the amount of water they will be carrying, and the sedimentary deposits surrounding the tunnels, significant preliminary engineering is required to document that the proposed conceptual design will have sufficient structural integrity to protect the WaterFix tunnels, the water supply, and structures and people on the surface.

1 Sand and silt deposits go down 1,000s  of feet in the Delta     Source: Unruh 2009

California Water Research did an extensive review of the WaterFix tunnel design with Tom Williams, an expert who has consulted on large tunnel and pipeline projects around the world. An examination of DWR’s preliminary engineering documents showed not only that the preliminary engineering is insufficient, but also that cost-cutting could compromise both the lifetime of the WaterFix tunnels and their ability to withstand a large earthquake in the Delta. The Validation Complaint for the WaterFix also has a clause requiring the State Water Project Contractors to pay the WaterFix revenue bond costs whether or not the WaterFix project is completed or maintained in repair. (DWR 2017, p. 10.) This does not exactly inspire confidence.

Tunnel lining design

The WaterFix tunnel lining is proposed to be built out of large segmented concrete pipes. This segmented design, with no inner liner, was chosen on the basis of cost and time to construct, not on strength. (DWR 2010a, p. 9.)

Tunnel segments Source: DWR 2010

A preliminary engineering analysis by the Department of Water Resources showed that the tunnel lining joints could leak in a maximum earthquake in the Delta. (DWR 2010, p. 4-13. ) DWR’s engineers recommended that the option of a second steel liner be kept until the feasibility of the single-pass design was proven. (DWR 2010, p. 10-1. ) A second steel liner would significantly raise the cost of the tunnels and was not kept as an option. Instead the seismic source assumptions in the published WaterFix Conceptual Engineering Report were weakened to a 5% in 50 year event. (DWR 2015b, p. 31.) Seismic source assumptions for the liquefaction analysis were weakened to a 10% in 50 year event. (DWR 2015b, p. 49.) These weakened assumptions mean that the preliminary engineering does not even consider whether the WaterFix tunnels would be repairable after a maximum earthquake in the Delta.

Settlement could also cause the tunnel lining segments to move relative to one another, opening up gaps at the circumferential joints over time. This has caused a shortened expected lifetime for tunnels in deep sedimentary soils in Shanghai. (Xu et. al. 2011.)  Leaks also progressively increase the forces pulling the tunnel segments apart (Yoo 2016.)  The preliminary WaterFix tunnel design does not provide any criteria for maximum differential settlement of the tunnel segments under long term operations. East Bay MUD commented on the tunnel design in 2015, stating:

Long-term degradation of segmental concrete lining may result in failure of the lining. In the event that the tunnel lining fails and results in a tunnel collapse or blowout, a collapse during operations would result in major ground movement extending to the ground surface and potentially sinkholes or blowout.

This potential leakage is of particular concern where the tunnels pass under important structures, including Delta island levees and channels, the Stockton Deep Water Shipping Channel, the Mokelumne aqueduct, and natural gas and other product and services pipelines. Failure under a levee or channel could result in catastrophic flooding, endangering human life. The Final Draft WaterFix Conceptual Engineering Report does not indicate an inspection, monitoring, and remediation program and does not discuss contingencies, controls, and recovery following indication and evidence of leakage of the tunnel lining.

An honest assessment of the benefits of the WaterFix tunnels would disclose the vulnerability of the proposed tunnel lining design to settlement and seismic forces, and provide a long-term inspection, monitoring, and remediation plan for leakage and movement. An honest assessment would also analyze and disclose the expected time to repair the tunnel lining in a maximum earthquake.


Department of Water Resources, 2017, Complaint for Validation. Available at

Department of Water Resources, 2015a, Final Draft Agreement Regarding Construction of Conveyance Project between the Department Of Water Resources and the Conveyance Project Coordination Agency. Available at

Department of Water Resources, 2015b, Final Draft Conceptual Engineering Report for the Modified Pipeline/Tunnel Option (MPTO). Available at

Department of Water Resources, 2010, Draft Report Of the Initial Analysis & Optimization of the Pipeline/Tunnel Option. Available at

Unruh, Jeffrey, and Hitchcock, Christopher, 2009, Characterization of Potential Seismic Sources in the Sacramento-San Joaquin Delta, California. Available at

Williams, Clyde Thomas, 2017, Testimony for WaterFix Change Petition Hearing. Available at

Yoo, Chungsik, 2016, Effect of water leakage in tunnel lining on structural performance of lining in subsea tunnels, Marine Georesources & Geotechnology Vol. 35 , Iss. 3.   Available at

Xu, Yeshuang & Ma, L & Shen, Shui-Long, 2011, Influential factors on development of land subsidence with process of urbanization in Shanghai. Yantu Lixue/Rock and Soil Mechanics. 32. 578-582. Available at

Posted by: Deirdre Des Jardins | June 26, 2017

WaterFix Dual Conveyance Operations Permit Deferred

Tunnel map

In a major change from the draft Biological Opinion, most of the Final Biological Opinion by the U.S. Fish and Wildlife Service is programmatic only.   No Incidental Take Permit for operations of the State Water Project and Central Valley Project under Dual Conveyance has been issued. The cover letter does state that the U.S. Fish and Wildlife Service has concluded that the project is unlikely to modify critical habitat.

DFW application status unclear

The change also makes the status of the application by the Department of Water Resources to the California Department of Fish and Wildlife for an Incidental Take Permit under the California Endangered Species Act is unclear, since that application relied on the proposed operations in the Draft Biological Assessment.

Much of the testimony for the WaterFix Change Petition assumed the proposed operations in the Draft Biological Assessment. The Department of Water Resources and the U.S. Bureau of Reclamation had indicated in the WaterFix Change Petition hearing that the “H3+” operations scenario analyzed in the Biological Assessment was going to be close to the approved operations.

Many WaterFix actions need further analysis

This is from the cover letter by the US. FWS:

The following activities requiring future Federal approvals and therefore addressed programmatically are:

(1) construction of the NDD and associated structures;

(2) construction of the HORG;

(3) construction of the CCWD settlement agreement facilities;

(4) operations of new and existing CVP and SWP water facilities under dual conveyance;

(5) future maintenance;

(5) future monitoring; [duplicate number in letter]

(6) compensatory mitigation associated with construction of the NDD, HORG, and CCWD settlement agreement facilities; and

(7) the CWF Adaptive Management Program.


In order to ensure that future actions developed for the CWF are consistent with this analysis, Reclamation and DWR have proposed a framework consisting of Guiding Principles that are analyzed as part of this BiOp. One or more subsequent consultations will be needed to address activities associated with future approvals. No Incidental Take Statement is included for activities addressed programmatically because those subsequent consultations will address incidental take associated with those activities.

Construction related permits issued

The cover letter lists activities that were fully analyzed for the Biological Opinion. They are entirely construction related.

The following activities analyzed as a standard consultation are:

(1) construction of the tunnels;

(2) expansions and other modifications of Clifton Court Forebay;

(3) associated infrastructure;

(4) geotechnical explorations,

(5) compensatory mitigation associated with construction except the North Delta Diversions (NDD), Head of Old River Gate (HORG), and Contra Costa Water District (CCWD) settlement agreement facilities; and

(6) specific construction-related conservation measures including preconstruction surveys for listed terrestrial species.

The reasons for the change to a programmatic opinion for the long term operations of the WaterFix project unclear, but the change allows the Bureau of Reclamation significant latitude to change the proposed operations that were analyzed in the Draft Biological Opinion, and that were worked out with the U.S. Fish and Wildlife Service and National Marine Fisheries Service under the Obama administration.


Posted by: Deirdre Des Jardins | May 7, 2017

Full San Luis Endangers 200,000 people — more coverage

Alex Breitler of the Stockton Record published the results on his inquiry into safety issues with San Joaquin Valley dams:  The state of our dams.

In the article, Deirdre Des Jardins of California Water Research points out that people’s lives are being endangered by filling the seismically challenged San Luis reservoir.   The 2 million acre foot reservoir needs a restriction of at least 50 feet to be safe in a large earthquake.

Breitler quotes the Bureau of Reclamation as saying that a reservoir restriction at San Luis would “be a massive issue for water users.”   Presumably this includes the very, very, VERY sorry Department of Water Resources that has been publicly apologizing to Oroville residents.   The Bureau declined to disclose the probability of a large earthquake in the area.


San Luis Reservoir

Posted by: Deirdre Des Jardins | April 22, 2017

Scientific integrity in DWR’s engineering: sea level rise

The WaterFix tunnel design assumes 18 inches of sea level rise by Late Long Term (2065.)  All structures, including tunnel intakes, tunnel shafts, the Intermediate Forebay, and the new parts of Clifton Court Forebay are being designed to withstand sea level rise of 18 inches. Simulated operations also consider salinity intrusion with a maximum of 18 inches of sea level rise.   Simulations by the U.S. Army Corps of Engineers show severe salinity intrusion with 1.68 meters (5.5 feet) of sea level rise, which could be reached by the end of this century.

Max salinity intrusion with 1.68 m sea level rise                U.S. Army Corps of Engineers

The Department of Water Resources’ assumptions about sea level rise date back to 2009. By 2013, when the first BDCP Draft Environmental Impact Report / Enviromental Impact Statement (EIR/EIS) came out, it was clear that the sea level rise estimates were obsolete. But the Department of Water Resources was reluctant to analyze higher values of sea level rise, stating in the Draft EIR/EIS that “the modeling analysis for BDCP had been designed and performed.” (Chapter 29, p. 13.)  Doing a new analysis would also have been quite expensive.

In a 2014 review, the Delta Independent Science Board was harshly critical:

The potential effects of climate change and sea-level rise are underestimated. . . . The potential direct effects of climate change and sea-level rise on the effectiveness of actions, including operations involving new water conveyance facilities, are not adequately considered. . . . We believe this is dangerously unrealistic.

DWR responded to the Delta ISB’s review, stating that “the scope of an EIR/EIS is to consider the effects of the project on the environment, and not the environment on the project.”

What could go wrong?

Jones Tract Flood 2004

Jones Tract Flood, 2004.      Source:  CA Water Blog

 The graph below shows projections of sea level rise by the U.S. Army Corps of Engineers and NOAA Climate Change Center, compared with the WaterFix tunnel design estimate of 18 inches, and the maximum operating range of 33 inches proposed under the new Delta plan amendments.  Under the high rate of sea level rise, the maximum operating range is exceeded around 2060-2070.

SLR w tunnels2

Sea level rise at Golden Gate — U.S. Army Corps and NOAA

Changing the sea level rise requirements in the Delta Reform Act

The Delta Reform Act required that the WaterFix EIR/EIS have a
comprehensive analysis of operations under sea level rise of up to 55 inches. (Section 85032(b)(2).)

The Delta Stewardship Council is proposing to amend the Delta Plan to only require that the EIR/EIS consider sea level rise of 20 inches at 2070, and the operations with up to 33 inches of by 2100.    These are derived from mean projections from the now obsolete 2012 report by the National Research Council.

The Department of Water Resources quietly disclosed the risks of underestimating sea level rise in a new paragraph in an unrelated chapter of the Final EIR/EIS:

• Underestimating sea level rise in the project design will result in harmful realized impacts such as flooding. Harmful impacts are more likely to occur if the project design is based upon a low projection of sea level rise and less likely if higher estimates of sea level rise are used. In situations with high consequences (high impacts and/or low adaptive capacity), using a low sea level rise value involves a higher degree of risk. (Examples of harmful impacts that might result from underestimating sea level rise include damage to infrastructure, contamination of water supplies due to saltwater intrusion, and inundation of marsh restoration projects located too low relative to the tides). (Chapter 9, section

The Ocean Protection Council’s Science Advisory Team Working Group just released a new risk report for sea level rise.    The highest sea level rise is projected for the highest greenhouse gas emissions.   For the current climate change models, possible scenarios are called “Representative Concentration Pathways.”   The highest Representative Concentration Pathway is RCP 8.5.    For the RCP 8.5 scenario, there is a 28% chance that sea level rise at the Golden Gate will exceed 3 feet by 2100, and an 8% chance it will exceed 4 feet.   Thus DWR’s use of sea level rise estimates of 18 inches for the WaterFix tunnels could result in a useful lifetime of less than 50 years for the project.

Sea level rise exceedance at the Golden Gate under highest GHG concentration pathway (RCP 8.5)

There is still significant uncertainty about catastrophic effects of climate change.    But these graphs show that using unrealistic assumptions for the $17 billion WaterFix project could result in severe and unanalyzed impacts on the project.


Griggs, G, Árvai, J, Cayan, D, DeConto, R, Fox, J, Fricker, HA, Kopp, RE, Tebaldi, C, Whiteman, EA (California Ocean Protection Council Science Advisory Team Working Group). Rising Seas in California: An Update on Sea-Level Rise Science. California Ocean Science Trust. 2017. Available at

National Research Council, Sea-Level Rise for the Coasts of California, Oregon, and Washington: Past, Present, and Future. Washington, DC: The National Academies Press. 2012. Available at

Parris, A., P. Bromirski, V. Burkett, D. Cayan, M. Culver, J. Hall, R. Horton, K. Knuuti, R. Moss, J. Obeysekera, A. Sallenger. Global Sea Level Rise Scenarios for the US National Climate Assessment. 2012. Available at

Sweet, W.V., R.E. Kopp, C.P. Weaver, J. Obeysekera, R.M. Horton, E.R. Thieler and CZ. NOAA Technical Report NOS CO-OPS 083, Global and Regional Sea Level Rise Scenarios for the United States. 2017. Available at

U.S. Army Corps of Engineers, Sea Level Change Calculator. 2015. Available at

Delta Independent Science Board, Review of the Draft EIR/EIS for the Bay Delta Conservation Plan. 2014. Available at

Bay Delta Conservation Plan Public Draft EIR/EIS, Chapter 29 — Climate Change. 2013. Available at

WaterFix Final EIR/EIS, Volume IChapter 9 – Geology and Seismicity. 2016. Available at

California Water Research, Comments on Water Supply and Water Quality Modelling in the WaterFix RDEIR/SDEIS. 2015. Available at

Chris Clarke, New Sea Level Rise Study Calls Delta Tunnels Into Doubt, KCET. April 2016. Available at

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