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Ramon Batista • -2 - • 11 February 2003 DEIR Phase 1 Expansion DEIR STATEMENT COMMENT Impact 4.2-b: Long Term Odor Impacts. The WDRs adopted for the proposed facility will item states, "The proposed project would result require odor control at the wastewater treatment in increased odor generating potential associated plant, all storage ponds,piping, and land with the operation wastewater conveyance application areas. The RWD must address the facilities and WRP-1 that could affect existing issue of odor control for all treatment, storage, and and planned nearby residential areas." application areas. Impact 4.6-b: Recycled Water Effects on WDRs adopted for the proposed facility will Groundwater Quality. The item states require groundwater monitoring of the first "...because the depth to potable groundwater is encountered saturated interval. Consistent with substantial (75 feet or more), the storage and the Antidegradation Policy, shallow groundwater application of recycled water would not result in quality must be protected. Groundwater the percolation of pollutants to potable monitoring wells will be required at storage and/or groundwater..." land application areas and the Monitoring and Reporting Program will require quarterly monitoring of groundwater quality. It is also noted that the fist saturated interval is likely to be less than 10 feet in some of the proposed land application areas or storage ponds. Impact 4.6-c: Potential for Violation of Surface Wastewater storage ponds must be sized to Water Quality Standards. The item states, "The provide storage for the wastewater and other project storage facilities would be sized to inflow. For the amount of rainfall to be used in the accommodate sufficient inflow to minimize the water balance, the City must use the 100-year potential of their overtopping. return annual total rainfall amount distributed monthly in accordance with normal year distribution. The water balance must also take into account any management provision of the storage pond such as described in Impact 4.8-a Vector Production, which states some water may be maintained in ponds. Additional Comments Section 3.4.2 describes expanding the wastewater treatment system in four phases over a ten-year period. If the City submits an RWD for each phase, substantial work will be required by Regional Board staff when resources are already reduced. Submitting multiple RWDs for incremental increases may result in WDRs preparation delays. The City should prepare an RWD that will describe the wastewater treatment system in no more than two phases. The WDRs can be structured to allow additional flow rates and land application areas only after submittal of technical reports and approval of the Executive Officer. Figure 3.4, Table 3.2, Table 3.3, Table 4.4-1, and Table 4.4-2 identify the wastewater storage and application areas. Some of these sites may not be suitable or may not be available for wastewater application. Table 3-3 identifies land application sites; Site Nos. 14, 15, 16, and 17 are described as "Simplot"but if contaminants exist in the proposed areas that could be mobilized by wastewater VASan_l0,uin Non l SSutAObnennSankapinMn,Co Suse Cleesi house� afista Feb 10 03.d=