SITE INFORMATION AND CORRESPONDENCE

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Deanna Walsh • - 2 - • 8 October 2002 5 Mossdale Landing Draft EIR 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 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. 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. Draft Environmental Impact Report—Mitieation Measures Table 2.1, Summary of Impact and Mitigation Measures, Item No. 4.4-c states, "...because of the depth to potable groundwater(150 feet)the application of recycled water would not result in the percolation of pollutants to potable groundwater." It should be noted that the beneficial uses of shallow groundwater must also be protected. Because of the shallow depth to groundwater in the conceptually described land application areas, it is likely that additional treatment, storage, and application procedures will be required to protect groundwater quality. Table 2.1, Summary of Impact and Mitigation Measures, Item No. 4.8-f states, "...implementation of the mitigation measure identified in the Master Plan EIR, with the exception of odor impacts, which would be significant and unavoidable." WDRs for a wastewater treatment plant will not allow generation of nuisance odors. WDRs will contain a Discharge Specification stating objectionable odors originating at the facility shall not be perceivable beyond the limits of the property owned by the Discharger. Table 2.1, Summary of Impact and Mitigation Measures, Item No. 4.8-h states, "Project build out would result in an incremental increase in project wastewater requiring disposal. However, insufficient areas would exist at the project site to dispose of this additional wastewater, and no offsite land disposal site or river discharges have been identified. Therefore a significant impact would occur." For mitigation measures, the DEIR assumes build out would be delayed, reserving 20 acres of storage pond area and 34 acres of land application areas for wastewater use. Because an RWD has not been submitted, it is unknown if that amount of storage and land application area is sufficient. The alternative mitigation measure identified is river disposal, which may not be an available option due to the existing impaired condition of the receiving water. Groundwater Characterization The groundwater information presented in the DEIR is incomplete and will need to be supplemented with additional information 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 will be landscaped 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 while the groundwater quality is characterized. Additional comments on the groundwater report supplied in the DEIR are provided below: • The 11 July 2002, Revised Report, Summary of Groundwater Studies, Terry and Adjacent Properties, prepared by Kleinfelder Inc., contained in Volume II Appendix F, states in Section 5, "It V:San_loaquin_Noni5 StaMObrienT roject Files\SitesMx,Conti tate Cle nghouse\%Ish092302,doc