COMMENT LETTER 552, FRED CORSON, PRESIDENT, DRY CREEK VALLEY ASSOCIATION
Description
INCREMENTAL RECYCLED WATER PROGRAM FINAL EIR RESPONSE TO COMMENTS COMMENT LETTER 202, JOHN SHORT, SENIOR WATER RESOURCE ENGINEER, CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD Response to Comment 202-1 Comment Summary: The comment expresses gratitude at the opportunity to comment and finds the Draft EIR to be thorough. The City appreciates the comments. Response to Comment 202-2 Comment Summary: The comment expresses support for the City’s decision to study all reasonable means of dealing with future flow increases. The City appreciates the support of the Regional Water Quality Control Board. Response to Comment 202-3 Comment Summary: The comment supports use of a combination of treatment/disposal alternatives. oard. Response to Comment 202-4 Comment Summary: The comment requests that first consideration be given to enhanced water conservation and infiltration and inflow prevention. Please refer to Master Response A – Statements of Opinion for or against a Project Alternative or Component. Response to Comment 202-5 Comment Summary: The comment expresses support for beneficial reuse alternatives such as injection into the Geysers steamfield and agriculture and urban reuse. Please refer to Master Response A – Statements of Opinion for or against a Project Alternative or Component. Response to Comment 202-6 Comment Summary: The comment states that if alternatives involving discharge to ground or surface waters are chosen, the Board ...
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| Publié par | Fuem |
| Nombre de lectures | 55 |
| Langue | English |
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S C OMMENT L ETTER 202, J OHN S HORT , S ENIOR W ATER R ESOURCE E NGINEER , C ALIFORNIA R EGIONAL W ATER QUALITY C ONTROL B OARD Response to Comment 202-1 Comment Summary: The comment expresses gratitude at the opportunity to comment and finds the Draft EIR to be thorough. The City appreciates the comments. Response to Comment 202-2 Comment Summary: The comment expresses support for the Citys decision to study all reasonable means of dealing with future flow increases. The City appreciates the support of the Regional Water Quality Control Board. Response to Comment 202-3 Comment Summary: The comment supports use of a combination of treatment/disposal alternatives. The City appreciates the support of the Regional Water Quality Control Board. Response to Comment 202-4 Comment Summary: The comment requests that first consideration be given to enhanced water conservation and infiltration and inflow prevention. Please refer to Master Response A Statements of Opinion for or against a Project Alternative or Component. Response to Comment 202-5 Comment Summary: The comment expresses support for beneficial reuse alternatives such as injection into the Geysers steamfield and agriculture and urban reuse. Please refer to Master Response A Statements of Opinion for or against a Project Alternative or Component. Response to Comment 202-6 Comment Summary: The comment states that if alternatives involving discharge to ground or surface waters are chosen, the Board will look closely at those alternatives and provides a list of some of the key issues in the letter. The City appreciates calling attention to these issues.
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S Response to Comment 202-7 Comment Summary: The comment states that surface water impacts should not be mitigated by transferring impacts to groundwater. The City agrees that significant impacts to both surface and groundwater should be avoided, if feasible. The Citys purpose for the Program, which is stated on page 1-3 of the Draft EIR, calls for treatment, reuse and disposal of wastewater in a reliable, practicable manner that provides the best use of water resources, while protecting public health and the environment. Section 4.5 of the Draft EIR evaluates impacts to groundwater, and has identified mitigation measures such as Mitigation Measure 3.3.9, Well Protection Program, to address potential impacts to groundwater. Response to Comment 202-8 Comment Summary. The comment states that the U.S. EPA has proposed to list the Laguna for nitrogen and phosphorus. If finalized, new discharges of nitrogen and phosphorus to the Laguna may be problematic. The U.S. EPA has now approved the listing of the Laguna for nitrogen and phosphorus. The final changes to the 2002 303(d) listing for the Laguna were made after the Draft EIR was written. Changes to the Draft EIR have been made to reflect the new listing of the Laguna for nitrogen and phosphorus. Please refer to Response to Comment 533-43. The Draft EIR contains an evaluation of nitrogen loads (Chapter 4.6 page 4.6-70, 71, and 75) based on the TMDL for nitrogen that has been established. Discharge will potentially be affected by establishment of other TMDLs. However, no TMDL has been established for phosphorus, so no evaluation of phosphorus loads was conducted in the EIR. Any discharge would need to comply with TMDLs when they have been established by the Regional Board. Response to Comment 202-9 Comment Summary. The comment states that since discharges to lands adjacent to waterways can have significant impacts to surface waters, the Regional Water Board has issued NPDES permits for these discharges in the past. Any proposal for these types of discharges needs to be closely evaluated for impacts to both ground and surface waters and compliance with the Basin Plan. The impacts (including compliance with the Basin Plan) of indirect discharge on groundwater and surface water were evaluated in Chapters 4.5 and 4.6, respectively, under the Indirect Discharge Components. The City of Santa Rosa, as lead agency, acknowledges on page 4.6-73 of the Draft EIR that, should the indirect discharge component be selected for implementation, further studies will be required to determine potential impacts on surface waters. See also Master Response G Program versus Project EIR Studies. Response to Comment 202-10 Comment Summary. The comment states that discharges to inland waters will need to comply with provisions of the California Toxics Rule (CTR) and that guidance for
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S implementing the CTR is contained in the Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California (Policy). The City of Santa Rosa, as lead agency, acknowledges on page 4.5-3 that discharge to inland waters will need to comply with the CTR using the guidance contained in the Policy. Please refer to Master Response C Mixing Zones and J - California Toxics Rule and Advanced Membrane Treatment. Response to Comment 202-11 Comment Summary. The comment suggests that the City consider the feasibility of metal translators, site-specific objectives and mixing zones prior to any decisions on future treatment/disposal modifications. The City appreciates the suggestion and will consider the feasibility of these Policy compliance approaches. For translators and site-specific objectives, the City will develop an Action Plan that will outline the steps necessary to study the feasibility of metal translators and site-specific objectives. This will include consultation with the Regional Board staff. For mixing zones the City is relying on efforts of the Russian River Watershed Association which is supporting the studies required by the Regional Board to facilitate their decision regarding mixing zones. Whether to allow translators, site-specific objectives and/or mixing zones will be determined by the Regional Board, and any discharge will comply with Regional Board orders. Refer to Master Response C Mixing Zones. Response to Comment 202-12 Comment Summary. The comment encourages the City to consider implementing a stronger pretreatment/source control program to address projected exceedances of toxic standards. The City periodically evaluates its pretreatment program and will continue to do so. However, as discussed in Technical Memorandum 17 (Santa Rosas Incremental Recycled Water Program Water Quality Improvement Technologies) pages 11 and 12, lowering existing local limits for industrial discharges or setting new ones could be part of an overall compliance strategy, but alone cannot meet predicted effluent limits. Therefore other alternatives are needed. For further information on pretreatment programs, see Master Response I Source Control. Response to Comment 202-13 Comment Summary. The comment states that any new or modified discharge of waste needs to be evaluated with respect to State and federal anti-degradation policy. The City of Santa Rosa agrees that this is necessary. An antidegradation evaluation will be conducted if and when a discharge alternative is selected. See Response to Comment 202-51. Response to Comment 202-14 Comment Summary. The comment states that it is disingenuous to call the Laguna Plant Upgrade, which includes an option to reduce treatment during high flows an upgr d a e
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S although the Regional Board recognizes that it is appropriate to evaluate the option of reducing treatment during high flows. The Laguna Plant Upgrade component contains two upgrade options for dealing with high flows: 1) upgrade the entire treatment plant to deal with the higher volumes or 2) upgrade only the primary and secondary portion of the treatment plant to deal with the higher flows. Thus, both options are an upgrade although one is more comprehensive than the other. Response to Comment 202-15 Comment Summary. The comment states that by including the treatment plant upgrade as a necessary component to, for example, the Indoor Water Conservation alternative, it implies that water conservation is only possible by reducing treatment levels during high flows. The comment suggests removal of the discussion of reduced high flow treatment and provision of a separate discussion of this alternative. Reducing treatment during very high flows is an optional component which is included as part of the Laguna Treatment Plant Upgrade component. It is not a necessary part of the component and is not inevitably linked to any of the alternatives, including the Indoor Water Conservation Alternative. The reduction of treatment from tertiary to secondary during very high flows has been discussed as part of the Laguna Treatment Plant Upgrade, rather than as a separate component, because the purpose of the option is to avoid constructing additional filters that would be used infrequently during wet weather only. Because of the complexity of the Program and the variety of alternatives considered, it has been necessary to structure the EIR to evaluate similar types of activities together in one component, and then combine components into alternatives. For this reason, options related to primary, secondary, or tertiary treatment are included in the Laguna Treatment Plant Upgrade component. The Treatment Plant Upgrade component is included in all alternatives including the Indoor Water Conservation Alternative, to fulfill the Program objective of expanding the capacity of the system to treat, recycle, and/or dispose of 25.9 mgd. See also Master Response E Document Organization and Response to Comment 202-16. Response to Comment 202-16 Comment Summary. The comment states that blending tertiary effluent with secondary effluent is not allowed under the Citys current permit and is prohibited in the Basin Plan. Using the assumption that it may be allowed in future NPDES permits and amendments to the Basin Plan and prioritizing alternatives based on what is at present a permit violation is inappropriate. The City of Santa Rosa agrees that although the physical impacts of use of secondary treatment have been identified, the inconsistency of the discharge of secondary effluent with the Basin Plan should have been identified. The Draft EIR is revised as follows: Page 4.6-23, Table 4.6-7:
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S
Table 4.6-7 Goals, Objectives, and Policies Surface Water Qualify Document Relevant Adopted Plan Document Numeric Evaluation Document Section Reference Policy Criteria 1 Water Quality Implementation None Discharge of municipal waste 1 and 2 Control Plan for Plan for the durin October 1 throu h Ma 14 the North Coast North Coast shall be of advanced treated Region Basin wastewater in accordance with effluent limitations contained in NPDES ermits for each affected dischar er, and shall meet a median coliform level of 2.2 mpn/100 ml.
Page 4.6-27 Narrative Criteria, the following text is added: Advanced Treated Wastewater. The discharge of municipal waste during October 1 through May 14 shall be of advanced treated wastewater in accordance with effluent limitations contained in NPDES permits for each affected discharger. Page 4.6-69, Impact 6.11.2: Discharge of Secondary Effluent. Because secondary effluent would be discharged infrequently and only when receiving water flow is high, the impact of secondary effluent on narrative criteria receiving water quality, except for the Advanced Treated Wastewater criterion discussed directly below, is considered to be less than significant. Advanced Treated Wastewater. Alternative 6A. Although the discharge of secondary effluent would not have a significant impact on receiving waters, the Basin Plan prohibits discharge of anything less than advanced treated wastewater. The discharge of secondary effluent at times of very high flows does not meet this Basin Plan criterion. Therefore, the impact of IRWP discharge to the Laguna and to the Russian River is considered to be significant for the Advanced Treated Wastewater criterion. Direct Discharge is not a component of Alternatives 1, 2, 3, 4, 5, 6C, 6D, 6E, and 7. Page 4.6-69, Impact 6.11.2: Mitigation: Advanced Treated Wastewater. Alternative 6A 3.5.11 Basin Plan Amendment for Discharge of Secondary Effluent.
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S After Mitigation: Advanced Treated Wastewater . Less than Significant: Alternative 6A Mitigation measure 3.5.11 requires a Basin Plan amendment to allow discharge of secondary effluent during times of high flows. Approval of a Basin Plan Amendment would bring the secondary discharge option into consistency with the Basin Plan, thereby removing the significant impact.
Page 4.6-83 Table 4.6-27:
Table 4.6-27
Summary of Significant Impacts and Mitigation Measures -Surface Water Quality Level of Impact Significance Mitigation Measure Direct Discharge 6.11.1. The Direct Discharge Alt 6A and 6B -z No mitigation identified for cyanide component may cause an exceedence of numeric-based criteria. Alt 6B -~ 3.5.3. Adjust pH and D.O in Recycled Water Prior to Discharge to the Russian River - 3.5.5 Provide Riparian Habitat in the Alt 6B ~ Russian River Watershed 6.11.2. The Direct Discharge Alt 6A -z~ 3.5.7 Laguna Biostimulation com o cause an exceedence Reduction p nent may of narrative based criteria. Alt 6A and 6B -~ 3.5.10 Exception to Allow Discharge Exceeding One Percent of Receiving Water Flow Alt 6A -~ 3.5.11 Basin Plan Amendment for Discharge of Secondary Effluent 6.11.4. The Direct Discharge Alt 6A -~ 3.5.4. Reduce N Loads to Laguna de component may result of non- Santa Rosa attainment of established TMDLs Page 3-95, Mitigation Measure 3.5.11 is added:
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S 3.5.11 Basin Plan Amendment to Allow Discharge of Secondary Effluent The City of Santa Rosa shall request a Basin Plan Amendment to allow discharge of secondary effluent during times of high flows. Impacts Mitigated and Mitigation Level Impacts Mitigated Level of Significance after Mitigation 6.11.2. The direct discharge component Less than Significant may cause narrative water quality criteria to be exceeded. Alternative : 6A Implementing Agency : North Coast Regional Water Quality Control Board Timing: Start: Prior to discharge of secondary effluent. Complete: Prior to discharge of secondary effluent. Monitoring Agency : City of Santa Rosa Validation : Not applicable.
Response to Comment 202-17 Comment Summary. The comment states that I&I reduction should be considered as the environmentally superior alternative since it directly helps reduce the volume of wastewater to be treated which can help to reduce plant bypass violations during periods of high precipitation. See Master Response A Statements of Opinion for or against a Program Alternative or Component. The Draft EIR identifies Combination of Alternatives 5 as the environmentally superior alternative. This combination consists of Indoor Water Conservation plus Direct Discharge. (See Draft EIR, p. 6-42.) This alternative does not include as a component I&I Reduction due to the environmental impacts associated with replacing pipelines. The commentors preference for this alternative is noted and will be provided to the City for its consideration. Response to Comment 202-18 Comment Summary: The comment expresses support for an aggressive I&I program, which may avert the need for other capital expenditure projects. Please refer to Master Response A Statements of Opinion for or against a Project Alternative or Component.
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S Response to Comment 202-19 Comment Summary: The comment states that I&I is a necessary maintenance item that should be expanded as a means to meet a need and avoid constructing other project alternatives. Please refer to Master Response A Statements of Opinion for or against a Project Alternative or Component. Response to Comment 202-20 Comment Summary: The comment states that the Draft EIR should recognize that I&I reduction reduces the potential for groundwater contamination from leaking sewer lines. The comment is correct that I&I reduction can reduce the potential for groundwater contamination. The Draft EIR is revised as follows: Page is 4.5-31, the second paragraph under Impact 5.3.1, 5.3.3, and 5.3.4: Continued use of the sewer pipes will be the same as the existing conditions, and therefore have no adverse impact on groundwater. The reduction in leakage from the collection system will reduce the potential from groundwater contamination from sewage leaking out of the system. Response to Comment 202-21 Comment Summary: The comment states that the noise and seismic impacts relating to the construction of the Geysers pipeline should not be included as a factor in considering whether the No Project Alternative would be the Environmentally Superior Alternative since it was addressed in the Long-Term EIR. The EIR states Alternative 7, the No Project Alternative, is not the Environmentally Superior Alternative, and provides several supporting reasons. The primary reason is that Alternative 7, the No Project Alternative, has greater adverse impacts than Alternative 1, Indoor Water Conservation. Alternative 7 continues to discharge to the Laguna and does not provide mitigation. Due to this continued discharge to the Laguna, the No Project Alternative would have the following impacts: biostimulatory substances, pH, dissolved oxygen, exceedences of California Toxics Rule (CTR) standards for cyanide, copper, lead, gamma-BHC, and endosulfan II. The No Project alternative also has significant impacts to public services, in that wastewater treatment and disposal capacity would be limited and would not accommodate the growth projected in the Subregional System members General Plans. The impacts of the Geysers pipeline (i.e. noise and induced seismicity) represent what should reasonably be expected to occur based on existing plans and infrastructure (CEQA Guidelines, § 15126.6(d)). They are therefore impacts that will occur under the No Project Alternative. Indeed, because the project is imminent, the Geysers and its impacts are part of the anticipated setting for all projects. Therefore, the commentor is correct that noise and
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S induced seismicity are not impacts which would preclude Alternative 7 from being selected as the Environmentally Superior Alternative if they were the only impacts associated with this Alternative. This statement (page 6-41) will be deleted. The Draft EIR is revised as follows: Page 6-41, fifth paragraph, last sentence: The No Project Alternative also has significant impacts to public services, in that wastewater treatment and disposal capacity would be limited and would not accommodate the growth projected in the Subregional System members General Plans. And finally, the No Project Alternative has both significant noise and induced seismicity impacts relative to the existing baseline environmental conditions in July 2002, because at that time the Geysers Recharge Project had not yet become operative. Response to Comment 202-22 Comment Summary: The comment states that the Laguna Plant upgrades cause unavoidable significant impacts on transportation, noise, air quality and cultural resources, but questions how the treatment plant, which is located over one mile from concentrated populations, could create permanent adverse impacts. Draft EIR Section 4.10 Transportation, page 4.10-11 identifies the transportation impacts of the Treatment Plant Upgrade as less than significant. Section 4.11 Air Quality, page 4.11-20 identifies significant unavoidable impacts from odors and greenhouse gas emissions. Odor impacts may be experienced at the nearest sensitive receptor, which may be a single residence, and greenhouse gas impacts are not related to the presence of nearby population concentrations. Section 4.12 Noise, page 4.12-36 shows that countywide noise ambient standards are exceeded. These impacts are not dependent on the presence of population concentrations. Ambient noise standards apply everywhere in the county and a sensitive receptor could be a single residence. Section 4.13 Cultural Resources and Paleontology, page 4.13-23 states that there could be impacts to unknown resources that may be discovered during project implementation. These impacts are not related to the presence of population concentrations, but could occur wherever the resource is present within the impact area. Response to Comment 202-23 Comment Summary: The commentor is concerned that I&I is the only alternative where pipelines are vulnerable to ground rupture. There are no major faults in the immediate vicinity of the Laguna Plant. Response to Comment 202-24 Comment Summary: The comment asks what provisions are proposed for loss of groundwater due to groundwater contamination, which is cited as a cumulative impact of the project.
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S As noted on page 4.5-54 of the Draft EIR, IRWP impacts are localized, and impacts to wells will be fully mitigated. If other proposed reservoirs (either for recycled water or potable water) were to cause cumulative impacts, no further feasible mitigation has been identified. If a project requiring reservoirs is selected, the City of Santa Rosa intends to site and design reservoirs to avoid groundwater impacts to the extent feasible. As noted in Technical Memorandum 6, in Appendix N.2 of the Draft EIR, reservoir siting and configuration will consider watershed/drainage impacts, which would include potential effects on groundwater. Facilities would be sited to minimize impacts to the extent feasible. Also, as noted on page 2-54 of the Project Description of the Draft EIR, Storage facilities may require lining. The potential for significant cumulative impacts was identified because reservoir locations are unknown, and thus full characterization of the existing setting or potential for cumulative effects with other projects is not possible. The potential for cumulative impacts is not great, but identification of the impact as significant was nevertheless deemed appropriate. Although there may be cumulative impacts with other projects, the impacts of the IRWP would be mitigated to the extent feasible. Response to Comment 202-25 The comment requests additional information on how I&I pipe replacement through existing backfill could impact cultural resources. Impacts to cultural resources from implementation of the I&I component are discussed under Draft EIR Section 4.13 Cultural Resources, Impacts 4.13.1 through 4.13.4 beginning on page 4.13-27. The analysis states that: Replacement or repair of pipes, laterals, and manholes represents a substantial ground disturbing activity that has the potential to impact buried prehistoric and historic resources and to impact historic architectural resources. Disturbance of historical archaeological resources is particularly likely because many pipes, laterals, and manholes targeted for repair or replacement are within the oldest developed areas of Santa Rosa, Sebastopol, Rohnert Park, and Cotati. These areas are likely to contain sensitive historical archaeological resources. The analysis concludes that this is a potentially significant impact. The City of Santa Rosa agrees that little potential exists for adverse impacts in already disturbed areas, such as in existing backfilled pipeline excavations and other infrastructure sites. However, since the I&I infrastructure has yet to be designed, it is unknown whether replacement of existing underground facilities will also require new excavation in areas not previously disturbed by the construction of water facilities. In these areas, particularly in the older developed areas of the region, there exists the potential for the presence of historical archaeological resources. Given this uncertainty, a potentially significant impact has been assumed and appropriate mitigation recommended. Response to Comment 202-26 The Regional Water Board supports the increased use of recycled water to irrigate private, public and municipal lands. The Board supports the widespread reuse of water as opposed to the apparent focus on specific geographical areas.
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S The City of Santa Rosa does not understand the reference to focus on specific geographical areas, because the Agricultural Irrigation component covers approximately 35,000 acres 60,000. Please refer to Master Response A Opinions for or against a Program Alternative. Response to Comment 202-27 Comment Summary: The use of recycled water for wine grapes has drawn some scrutiny by some Alexander Valley and Dry Creek Valley residents. We understand that these areas are being included in this document since they have not been studied previously. Furthermore, we understand that agricultural application to watersheds south of Santa Rosa have been previously studied and therefore do not need to be included in this document. The comment is correct regarding the agricultural areas studied. Use of recycled water on crops is evaluated in Chapter 4.2, Agriculture, in the Draft EIR and elaborated upon in Response to Comment 202-29 below. Response to Comment 202-28 Comment Summary: The Regional Board has been questioned frequently about the safety of recycled water for agricultural reuse. Pharmaceuticals, hormones, caffeine and endocrine disruptors may be present in recycled water and, although their potential health impact on humans is not understood, medical community is concerned about the presence of these compounds in products grown with recycled water. The comment requests that the EIR address the potential impacts of these compounds. The Draft EIR discusses endocrine disruptors, pharmaceutically active compounds and other xenobiotics and their possible human health effects on pages 4.7-15 through 4.7-17 and in Appendix I.2 of the Draft EIR. However, as the commentor notes, their potential impact on human health is not well understood and thus, while acknowledging that they may be present at very low concentrations in recycled water, the City of Santa Rosa concludes that at this time inadequate information is available on which to base a significance criteria for these compounds under any of the potential exposure scenarios, including agricultural reuse. Response to Comment 202-29 Comment Summary: The comment asks what provisions are in place to ensure that vineyard owners in the Alexander and Dry Creek valleys would be willing to use recycled water in place of potable water supplies, and are there foreseeable difficulties in inducing vineyard owners to enter into recycled water supply contracts? Detailed program requirements regarding how recycled water made available for agricultural use under the IRWP would be marketed, priced and contracted have not been determined. These would be subject to future negotiation as part of specific projects. Those considerations would be part of later, more detailed analyses of future projects proposed for implementation under the IRWP, as described in the City policy regarding Agricultural and Urban Recycled Water Reuse (July 2002). Draft EIR Section 2 Project Description, page 2-46 contains the following provision which is germane to the comment: The Subregional System may acquire land that will be used for
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