SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Ramon Batista • - 3 - 11 February 2003 DEIR Phase 1 Expansion application, such application may not be allowed. In Table 3-2, which identifies wastewater storage areas, Site 7 described as "LOF Back 40"refers to an area where wastewater is already applied. The area is described in WDRs Order No. 5-01-114 and is presently used for Pilkington North America's industrial wastewater and stormwater application. The same area cannot be listed in two WDRs. Please clarify the use of such areas and an evaluation of the potential for contaminants to exist in proposed areas. Section 3.6.2 states the purple pipe requirement for recycled water, "...does not apply to water delivered for agricultural use." The basis for this statement is unknown but can be clarified when the Title 22 Recycled Water Engineering Report is submitted. Section 4.6.3 Environmental Impacts, describes runoff from land application areas as not significant. Discharge of wastewater to surface water bodies without the proper permits can result in the Regional Board taking enforcement actions, including imposition of administrative civil liabilities. The Title 22 Recycled Water Engineering Report must adequately address the runoff issue. Section 4.6.3 Environmental Impacts, describes a water balance prepared to estimate the amount of land needed for wastewater application. The water balance was not included in the DEIR; it will be required as part of the RWD. The amount of land needed for wastewater application will be evaluated by reviewing the assumptions in the water balance and the characteristics of the land application areas. The water balance must use the 100-year return annual total return period distributed monthly in accordance with historical patterns as the precipitation amount. Section 4.6.3 Environmental Impacts, states, "...even the direct discharge of tertiary-treated wastewater to the San Joaquin River associated with full build out of the WRPs proposed under the Master Plan would result in a less-than-significant impact on surface water quality." This statement is not supported and should be removed from the final EIR. 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. In addition, storage of wastewater in ponds after treatment will likely result in measurable total coliform organisms possibly requiring secondary disinfection prior to land application. Groundwater Characterization No information on groundwater quality is provided in the DEIR; the information will be required for the RWD. Groundwater monitoring will be required upgradient and downgradient of all land application and/or wastewater storage areas. Because of the number of land application areas that may be included in the project, 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 RWD while the groundwater quality is characterized. The following discussion provides information on permits required by the Regional Water Board for the project. V:\Sen_Joe uin Nonl5\Statt\ObHen nJoa uin\Mix.Cons mte Clmnnghouse\Detisu Feb 1003.do