SITE INFORMATION AND CORRESPONDENCE

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Bruce Coleman - 2 - 15 October 2004 Two of the alternatives include the use of"scalping"facilities that only treat the liquid portion of the wastewater and require solids treatment at another(probably the Crossroads)treatment facility. The proponent should note that the new wastestream to the Crossroads facility would constitute a material change in the character of the wastewater delivered to the facility and therefore would require update of WDRs Order No. 5-01-251. Application of treated wastewater to public landscaping, road medians, commercial landscaping, sports fields, etc. is briefly described in the DEIR. Wastewater applied in this manner must meet the conditions of Title 22 of the California Code of Regulations. In addition,wastewater must be applied in a manner that minimizes the possibility of runoff. Application of wastewater in medians or land areas such as parks equipped with stormwater drains can be problematic because control of the wastewater is required. Management provisions can be designed to minimize discharge of treated wastewater to surface water bodies through storm drain systems. The DEIR states storage ponds will be constructed with 10 to 12 feet high berms above the surrounding elevation. Although information on the off-site storage/application areas does not identify specific areas, shallow groundwater in the Lathrop area may require ponds to be lined to protect groundwater quality. Measures to protect the liners from damage from high groundwater conditions may also be needed. A permit from the Department of Water Resources Division of Dam Safety may be required for the storage ponds if it exceeds certain limits set by the Department of Water Resources. Further information on regulation of dams is available at http://d`amsafety.water.ca.gov/. California Water Code Section 6025.5 (a)may provide an exemption from the requirements if certain requirements are met. Review of the pond design is not included in the list of permits that is provided in Section 1.4 of the DEIR. Use of the wastewater for irrigation as described in the DEIR may require additional wastewater storage facilities or redundant treatment facilities because Title 22 Section 60304 requires backup measures if treatment fails.- Section 4.8.1 includes a description of the regulatory background. The discussion should identify the beneficial uses of groundwater listed in the Basin Plan. The Basin Plan defines all groundwater in the region to posses, at a minimum,the following beneficial uses: municipal and domestic water supply, agricultural supply, industrial service supply,and industrial process supply. If degradation of groundwater quality is allowed,it must be consistent with State Water Resources Control Board Resolution 68-16 (the Antidegradation Policy). There is no groundwater quality information presented in the DEIR. Groundwater monitoring will be required upgradient and downgradient of all land application and/or wastewater storage areas; a regional approach to groundwater monitoring may be acceptable. However, wastewater storage areas will require site-specific groundwater monitoring networks. Groundwater monitoring should be performed to characterize the background groundwater quality at the site. Inadequate groundwater monitoring data may result in delays evaluating the Report of Waste Discharge (RWD)while the groundwater quality is characterized. w:wwnakons. xwqaw.uw,wwmiuew.mto¢m.,,�x on a.mv