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Contrary to the September 9th letter, it is considered by the City and <br /> Black & Veatch that significant additional treatment facilities and/or <br /> land area will be required to consistently meet the more stringent <br /> disinfection standard. As a minimum, the addition of effluent <br /> coagulation and filtration facilities will be required. Another option <br /> would be to purchase more land so that discharges to Dredger Cut between <br /> May 15 and October 15 could be eliminated entirely. In either case, <br /> substantial additional cost would be incurred. <br /> The financing for this project has already been arranged based on the <br /> facilities described in the EIR and the Design Memo. This project is <br /> being financed by local funds, not state and federal grants or loans, and <br /> it would be extremely difficult, if not impossible, to change the <br /> financing arrangements at this late date to provide the additional <br /> treatment facilities or additional land required by the more stringent <br /> disinfection requirement. (Note: See attached Preliminary Official <br /> Statement for the Certificates of Participation being used to finance the <br /> proposed project) . <br /> Untimely Application of Proposed MPN Standard <br /> The adoption of such a stringent disinfection requirement at this late <br /> date would be untimely. The September 9th letter is the first time that <br /> the 2.2 (monthly median)/23 (daily maximum) MPN/100 mL requirement has <br /> been proposed. According to our records, the subject of a revised <br /> disinfection standard was NOT mentioned in any of the previous <br /> discussions between the City, Black & Veatch and the CVRWQCB staff. In <br /> fact, the current WDR for the White Slough facility, which was adopted in <br /> 1986, did not change the disinfection standard from the previous <br /> requirement of 23 (monthly median)/500 (daily maximum) MPN/100 mL, even <br /> though this expansion project had been discussed with the CVRWQCB staff. <br /> Disinfection was discussed in the draft EIR for the White Slough <br /> expansion project, which was published in April 1988, and no comments <br /> regarding a more stringent requirement were made by the CDOHS or CVRWQCB <br /> staff during the formal EIR review period. Even the recent <br /> recommendation of a more stringent disinfection standard by the CDOHS, <br /> which was attached to the September 9th letter, is based on direct water <br /> contact recreation, not the irrigation of food crops. Since no comments <br /> to the EIR were received, the design and financing for the project has <br /> proceeded assuming that the current total coliform requirements of 23 <br /> MPN/100 mL (monthly median) and 500 MPN/100 mL (daily maximum) would be <br /> applicable to this project. <br /> Redesign of the project to meet the proposed disinfection standards at <br /> this time would significantly delay the project. The facility is <br /> exceeding its capacity at this time. In addition, housing currently <br /> under construction will soon add 1,200 new connections. As a result, the <br /> City has in place a moratorium on any further annexations to the City. <br /> Stringent MPN Standard Not Required by Basin Plan <br /> Disinfection to an MPN of 2.2 (monthly median)/23 (daily maximum) total <br /> coliform/100 mL is NOT required by the Basin Plan. Current MPN <br /> requirements for Delta waterways in the Basin Plan are 200 fecal <br /> coliform/100 mL (geometric mean) and 400/100 mL (10 percentile) to <br /> protect recreational water uses. The current disinfection requirements <br /> for the White Slough facility are already higher than these requirements. <br /> 3 <br />