COMMENT LETTER 552, FRED CORSON, PRESIDENT, DRY CREEK VALLEY ASSOCIATION

Kristine Gaspar

Description

INCREMENTAL RECYCLED WATER PROGRAM FINAL EIR RESPONSE TO COMMENTS COMMENT LETTER 300, CHRIS DEGABRIELE, GENERAL MANAGER, NORTH MARIN WATER DISTRICT Response to Comment 300-1 Comment Summary: The comment states that NMWD has reviewed the Draft EIR and expresses gratitude at the opportunity to comment. Additionally, the commentor understands that the Draft EIR is programmatic. The City appreciates the comments. The commentor is correct that the Draft EIR is programmatic. Response to Comment 300-2 Comment Summary: The comment encourages expansion of urban and agricultural recycled water use to an even greater area, and advocates regional cooperation in developing recycled water programs. The Sonoma County Water Agency is interested in cooperating with waste dischargers to convey even more recycled water to urban and agricultural water users and offset diversion from the Russian River. Please refer to Master Response A – Statements of Opinion for or against a Program Alternative or Component. Actions of the Sonoma County Water Agency, as defined in their ndRussian River Action Plan, 2 Edition (March 2003), that may have a cumulative impact with regard to the IRWP have been included in the list of cumulative projects in Appendix D. Response to Comment 300-3 Comment Summary: The comment asks why avoided potable water costs were not included. Cost analysis is not required under CEQA. The data to develop avoided potable water costs were ...

Informations

• Publié par: Tapav
• Nombre de lectures: 23
• Langue: English

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Response to Comment 300-1

Comment Summary: The comment states that NMWD has reviewed the Draft EIR and

expresses gratitude at the opportunity to comment. Additionally, the commentor understands

that the Draft EIR is programmatic.

The City appreciates the comments.

The commentor is correct that the Draft EIR is

programmatic.

Response to Comment 300-2

Comment Summary: The comment encourages expansion of urban and agricultural recycled

water use to an even greater area, and advocates regional cooperation in developing

recycled water programs. The Sonoma County Water Agency is interested in cooperating

with waste dischargers to convey even more recycled water to urban and agricultural water

users and offset diversion from the Russian River.

Please refer to Master Response A – Statements of Opinion for or against a Program

Alternative or Component. Actions of the Sonoma County Water Agency, as defined in their

Russian River Action Plan, 2

nd

Edition (March 2003), that may have a cumulative impact

with regard to the IRWP have been included in the list of cumulative projects in Appendix D.

Response to Comment 300-3

Comment Summary: The comment asks why avoided potable water costs were not included.

Cost analysis is not required under CEQA. The data to develop avoided potable water costs

were unavailable at the time the Draft EIR was written. These costs will be developed and

included in an economics analysis, as part of the IRWP Master Plan currently in being

developed.

Response to Comment 300-4

Comment Summary: The comment expresses concern about direct discharge to the Russian

River and strongly suggests that the City commit to additional treatment for any direct

discharge because water quality thresholds will continue to become more stringent.

The Draft EIR has acknowledged that discharge will be subject to future regulatory

requirements. Page 1-2 of the Draft EIR states that “regulatory requirements applicable to

recycled water discharge into the Russian River and its tributaries have increased since the

Geysers Recharge Project was selected, and additional regulatory requirements are

anticipated.” As noted on page 2-71 of the Draft EIR, “In order to meet the requirements of

the California Toxics Rule (CTR) for discharge to surface waters, all of the Discharge

options may include advanced membrane treatment to the extent needed to comply with

CTR.” Please refer to Master Response A – Statements of Opinion for or against a Program

Alternative or Component.

OCTOBER 20, 2003

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PAGE 300-1

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Response to Comment 300-5

Comment Summary: The comment expresses concern about discharge above the SCWA

collectors and states that they have requested that DHS make a conclusive determination

about whether a discharge would result in the requirement for treatment of SCWA water

supply. The comment further states that Santa Rosa should pay for any additional treatment

that might be required.

The City of Santa Rosa has consulted with the Department of Health Services (DHS) and to

date (October 2003) there has been no determination from DHS regarding the requirements

for additional treatment should the City discharge above the Sonoma County Water Agency’s

(SCWA) collectors.

The City does not agree that the discharge of recycled water would trigger additional

treatment requirements based on our findings presented in Appendix I.1 (Human Health Risk

Assessment) of the Draft EIR. In addition, only one of the five SCWA intakes is considered

by the DHS to be under the direct influence of surface water and thus subject to the Surface

Water Treatment Rule (SWTR) and any Final Enhanced SWTR.

The four other water

agency intakes and District wells are considered by the Department to be not under the direct

influence of surface water according to the SWTR. The DHS considers the “not under the

direct influence” status of the Water Agency intakes to be subject to periodic review because

of the potential that the filtration characteristics of River sediments may change or the quality

of the River would be degraded. In addition, the SCWA is constructing a 6

th

collector.

Construction is expected to be complete in 2004 and at that time will be tested to ascertain

whether DHS will consider it to be under the direct influence of surface waters.

Response to Comment 300-6

Comment Summary.

The comment quotes a section of the Draft EIR concerning

methodology for evaluating potential health impacts from recycled water. It then points out

that an inconsistency exists between Table 4.7-5 and Table 4.6-21 in that copper, lead,

nickel, and zinc are all showing an increase from pre- and post-geysers recharge baselines.

The apparent inconsistency is due to differences in what each of the tables is presenting.

Table 4.7-5 presents the concentrations of constituents in fresh, undiluted recycled water,

comparing data collected between 1988 and 1995 to data collected 1997 to 2002. Table 4.6-

21 presents the estimated concentrations of constituents in the Russian River with varying

percentages of recycled water.

These estimates are calculated using both the ambient

concentration of constituents and the recent (1997 to 2002) concentration in recycled water.

Response to Comment 300-7

Comment Summary: The comments states that Chapter 4.7 of the Draft EIR references only

current Maximum Contaminant Levels, that regulatory requirements are becoming more

stringent and that a comparison to Public Health Goals plus a sensitivity analysis based on

the assumptions and variables used in the evaluation should be provided.

Public Health Goals (PHGs) are required for drinking water contaminants for which there

already is a primary drinking water standard (maximum contaminant level, or MCL) as well

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as for any newly regulated contaminants.

The Office of Environmental Health Hazard

Assessment has adopted PHGs for 46 chemicals in the last two years.

PHGs are

concentrations of chemicals in drinking water that are not anticipated to produce adverse

health effects after lifetime exposure. They are to be based on risk assessments conducted

using "most current principles, practices, and methods used by public health professionals"

and certain public health criteria. PHGs are solely health-based; the evaluations provide

health related information to the California Department of Health Services for consideration

of updating state Maximum Contaminant Levels (MCLs) on the basis of the most recent

toxicity data and risk assessment methods. As such, PHGs are advisory, and information on

PHGs may or may not result in changes in MCLs. MCLs are thus the appropriate parameter

to use as criteria for the IRWP EIR.

Response to Comment 300-8

Comment Summary: The comment states that a discussion in Chapter 4.6 of the Draft EIR of

the anti-degradation policies of the EPA and State Water Resources Control Board supports

the commentor’s request for a Department of Health Services determination regarding water

treatment of SCWA water that might be required as a result of increased discharges to the

Russian River.

Please refer to Response to Comment 300-5.

Response to Comment 300-9

Comment Summary. The comment quotes a section of the Draft EIR that summarizes Policy

RC-3E of the Sonoma County General Plan and states the belief that direct and indirect

discharge would not comply with these policies, pointing out that direct and indirect

discharge alternatives are considered to have a significant impact in the Draft EIR.

The Draft EIR includes Policy RC-3E in its discussion of relevant Goals, Objectives and

Policies on Page 4.6-23 and directs the reader to the evaluation of criteria 1-4 of the Water

Quality Section. The City of Santa Rosa agrees that direct and indirect discharge alternatives

may not comply with these policies as well as some of the other alternatives. However, this

Draft EIR presents and evaluates a variety of alternatives. These alternatives were picked to

meet the mandate for a reasonable range of alternatives that could feasibly achieve the

Program Objectives. These alternatives were also specifically defined in such a way that

they would allow for the evaluation of the maximum range of potential environmental

impacts of any Program that the City may ultimately select. The Draft EIR identifies Indoor

Water Conservation as the environmentally superior alternative (Chapter 1 page 22).

Response to Comment 300-10

Comment Summary. The comment quotes the Draft EIR as stating some constituents do not

meet their respective CTR criteria. The comment further states that the project description

includes advanced membrane treatment (AMT) as needed to avoid exceeding CTR criteria

but says that the Subregional System has not committed to AMT.

The City is committed to AMT as needed to avoid exceedences of CTR criteria in the

receiving water if an alternative is selected that requires discharge. As noted on page 2-71 of

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the Draft EIR, “In order to meet the requirements of the California Toxics Rule (CTR) for

discharge to surface waters, all of the Discharge options may include advanced membrane

treatment to the extent needed to comply with CTR.” The commentor is correct that no

commitments regarding AMT or any other component has been made, and cannot be made

until this EIR is certified.

Response to Comment 300-11

Comment Summary. The comment states that it appears that constituents in the Russian

River will increase from the pre- and post-geysers recharge baseline which is contrary to

antidegradation policies. The comment also states that the Draft EIR lists impact 6.12.1 as

significant because indirect discharge will exceed numeric criteria for constituents.

Some (not all) constituents are predicted to increase from the pre- and post-geysers recharge

baselines with the IRWP.

However, in the Draft EIR, the significance of impacts was

evaluated assuming no dilution for receiving waters.

Whether or not the increase in

constituents in the Russian River constitutes significant degradation will be determined in an

Antidegradation Analysis to be conducted after a project is selected.

The City agrees that the Draft EIR lists impact 6.12.1 as significant because indirect

discharge will exceed numeric criteria for some constituents after mitigation, specifically

cyanide.

Response to Comment 300-12

The comment suggests that alternatives for discharge above the SCWA collectors not be

considered further because of the cost and time required to perfect discharge alternatives.

Please refer to Master Response A – Statements of Opinion for or against a Program

Alternative or Component.

Response to Comment 300-13

Comment Summary: The comment is the comment letter submitted September 27, 1998 for

the Santa Rosa Subregional Long-Term Wastewater Project Draft Environmental Impact

Report/Environmental Impact Statement (Long-Term EIR).

This comment letter was numbered 18 in the Long-Term EIR and the response to the

comments presented in the letter can be found in Volume 20 on pages 6.3-295 through 6.3-

299.