SITE INFORMATION AND CORRESPONDENCE

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Bruce Coleman • -2 - • 25 November 2002 ~ River Islands at Lathrop SDEIR adversely affected. water discharge and therefore subject to NPDES permit requirements. Item 4.11-c, Demand for Wastewater Treatment Regional Board staff has been informed that the Capacity during Phase la and Phase 1. WRP#1 (Crossroads plant)will not accept the Development and operation of the WRP #1 Phase wastewater. The DSEIR must address this apparent 1 Expansion Project would be required to provide contradiction. In addition, WRP #1 does not treat the River Islands project with adequate treatment wastewater to the level described in the DSEIR. cg_aci during Phase la and Phase 1. _ Item 4.114,Demand for Recycled Water Because no specific information on storage areas is Storage and Disposal Capacity during Phase la provided in the DSEIR, this statement is impossible and Phase 1. Adequate storage and disposal areas to evaluate. are available to accommodate the quantity of treated wastewater to be generated by the project during Phase 1 a and Phase 1. _ Item 4.11-g,Demand for Recycled Water The mitigation measure states elements of Phase 2 Storage and Disposal Capacity for Phase 2. project development should not commence until ...insufficient area would exist at the project site to storage and disposal capacity is provided and dispose of this additional recycled water, and no assumes surface water disposal will be available. It offsite land disposal sites have been identified. should be noted that river disposal might not be an There is not sufficient existing recycled water available option due to the existing impaired disposal capacity and there would not be sufficient condition of the receiving water. capacity on the project site. Information on depth to groundwater was not provided in the DSEIR but it is likely to be shallow in the vicinity of the River Island project. No information on the planned pond construction was provided so it is impossible to determine if liners will be required and if a permit from the Department of Water Resources Division of Dam Safety may be required for the storage pond(s). Review of the pond design is not included in the list of permits that is provided in Section 1.4.2 of the DSEIR. 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 DSEIR with the exception of the depth to groundwater data summarized in Section 4.7.2; the information will be required for the Report of Waste Discharge (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 Report of Waste Discharge while the groundwater quality is characterized. V tSm Joaquin NonlT to ObdimTMmject Rilm\Muo COn Mc Clemmghou a\Cohn 112202.doc