HomeMy WebLinkAboutAgenda Report - August 20, 2008 E-09AGENDA ITEM EVII
CITY OF LODI
COUNCIL COMMUNICATION
TM
AGENDA TITLE: Adopt Resolution Authorizing an Additional Task Order for West Yost &
Associates to Provide Permit Assistance and Prepare Various Studies
Required by the City's Wastewater Discharge Permit and Appropriating
Funds ($400,000)
MEETING DATE: August 20,2008
PREPARED BY: Public Works Director
RECOMMENDED ACTION: Adopt a resolution authorizing an additionaltask orderfor West Yost
& Associates to provide permit assistance and prepare various
studies required by the City's wastewater discharge permit (Permit)
issued by the State Central Valley Regional Water Quality Control
Board (Board) and appropriating funds as shown below.
BACKGROUND INFORMATION: The City's new wastewater discharge permit includes requirementsfor
a number of studies to be conducted and plans or reports to be
developed on various aspects of the City's wastewater treatment
operations. On December 19, 2007, Council authorized West Yost &
Associates to proceed with preparing work plans for various studies required by the Permit. The work
reflected in the attached proposal includes studies that build upon those Permit -required work plans
authorized by Council last December and recently approved by the Board, along with assistance in
meeting permit compliance requirements.
The City's wastewater consultant, West Yost & Associates, has furnished the City with a combined
proposal to respond to the Permit requirements for FY 08/09, including assisting City staff in regulatory
program management.
The following includes a brief description of the Permit -required tasks for FY 08/09; a more detailed
description is included in the attached proposal (Exhibit A).
Task 1: Project Management— This task includes overall project coordination and principal engineer
oversight of the work products. ($22,300)
Task 2: State Board Petition Support — The City's Permit has been petitioned by the California
Sportfishing Protection Alliance. This task includes assistance during a Board evidentiary hearing likely
to be held this fall and, if appropriate, preparing a response to any State Order issued. ($32,100)
Task 3: San Joaquin Valley Air Pollution Control District Biosolids Rule Compliance — Provides
assistance in obtaining a variance to Biosolids Operations Rule 4565. ($9,900)
APPROVED:
BI ' , City Manager
K:tiWPtPROJECTSISEWERffSWPCRCWYA TaskOrders PemritAssist.doc
0811412008
Adopt Resolution Authorizing an Additional Task Order for West Yost & Associates to Provide Permit
Assistance and Prepare Various Studies Required by the City's Wastewater Discharge Permit and
Appropriating Funds ($400,000)
August 20, 2008
Page 2
Task 4: Regulatory Program Management — Includes meetings and coordination efforts with the Board
regarding permitting issues. This task also involves guidance related to new regulatory requirements
associated with the current permit. ($46,200)
Task 5: Land Application Monitoring Coordination — This task includes coordinating development of the
City's monthly land application reports and the costs associated with the Permit -required agronomist's
review and certification. ($31,400)
Task 6: Compliance Studies —This task includes efforts needed to complete the Board -required
Corrective Action/Method of Compliance Work Plan, Pollution Prevention Plan and Treatment Feasibility
Study. These studies are required of all dischargers that receive permit compliance schedules for new
effluent limitations. ($24,800)
Task 7: Toxicity Reduction Evaluation (TRE) —Though not expected, this task is to respond to a Board -
required TRE in the event of a toxicity exceedence. TRE's are very time sensitive and require an
intricate series of steps that are dependent on the outcome of initial findings. If a TRE is not needed, the
budget for this item will not be expended. ($68,400)
Task 8: Title 22 Engineering Report — This task includes implementation of the Title 22 Work Plan
approved in June 2008 and includes documentation of the City's recycledwater uses and operations, UV
system validation, review and documentation of Northern California Power Agency (NCPA)facilities (the
City supplies NCPA non -contact cooling water) and coordination with the Departmentof Public Health.
Title 22 Reports are required for all treatment plants that supply recycledwater for other than agricultural
purposes. ($75,000)
Task 9: Wintertime Irrigation Management Plan — Since approximately one-half of the City's land
application areas are located within the 100-yearflood plain of the Delta, this plan is required to minimize
potential for winter flooding events to wash out biosolidsfrom the land application areas to the Delta.
($4,800)
Task 10: Temperature Study — This task includes implementation of the Temperature Study Work Plan
approved in June 2008. The purpose of this Permit -required study is to establish receiving water
temperature limitations that are protective of the beneficial uses (specifically, aquatic life uses) identified
for the receiving water (Dredger Cut). ($12,200)
Task 11: Industrial Influent Characterization Study — This task includes implementation of the Industrial
Characterization Work Plan approved in June 2008. This Permit -required study is intended to
characterize the wastewater influent collected by the industrial sewer system over a two-year period
through quarterly influent monitoring. The majority of the costs associated with this study are laboratory
related. ($13,100)
Task 12: Pond Freeboard Evaluation Study — This Permit -required study is intended to evaluate the
stability of the storage pond berms and to identify if a need exists to implement mitigation or control
measures that may be necessary to prevent undesirable risks associated with berm failure or
overtopping. ($6,600)
K:\WP\PROJECTS\SEWER\WSWPCRCWYA—TaskOrders—PermitAssist.doc 08/07/2008
Adopt Resolution Authorizing an Additional Task Order for West Yost & Associates to Provide Permit
Assistance and Prepare Various Studies Required by the City's Wastewater Discharge Permit and
Appropriating Funds ($400,000)
August 20,2008
Page 3
Task 13: Salinity Evaluation and Minimization Plan —This task includes implementation of the Salinity
Evaluation and Minimization Plan that is required of all municipal dischargers of one million gallons per
day or larger in the Central Valley and is intended to identify sources of salinity in the City's domestic and
industrial effluent. ($10,000)
Task 14: Background Groundwater Quality and Degradation Assessment Study —This Permit -required
study will be implemented in accordance with the Background Monitoring Well Work Plan approved in
June 2008 and is intended to establish local background groundwater conditions in an effort to quantify
the threat to groundwater quality associated with the City's land application practices. (58,500)
FISCAL IMPACT: The estimated cost for this work is $365,300. Staff suggests a contingency
amount of approximately 10% to account for unforeseen issues for a total
of $400,000. The studies' monitoring efforts are required in the City's
Permit and non-performance would subject the City to significant fines.
FUNDING AVAILABLE: The requested appropriation of $400,000 from the Wastewater fund will be
split between operating and capital funds:
Operating (170) $ 290,000
Capital (172) 110,000
5400.000
Budget Manager
A"
F. Wally Sofidelin
Public Works Director
FWSICSIpmf
Attachment
KIWPIPROJECTSISEWERIWSWPCFICWYA TaskOrders_PermitAssist.doc 08/07/2008
WEST YOST
hft
ASSOCIATES
Consulting Eagihccrs
August 5,2008
Mr. Charles E. Swimley, Jr.
Water Services Manager
City of Lodi
1331 South Ham Lane
Lodi CA 95242
SUBJECT: Proposal for Engineering Services —NPDES Permit Assistance for
Fiscal Year 2008/2009
Dear Mr. Swimley:
Exhibit A
West Yost Associates (WYA) appreciates the opportunity to present to you this letter proposal for
engineering services related to ongoing assistance to the City of Lodi (City) in meeting the
NPDES permit compliance requirements for the Lodi Water Pollution Control Facility (WPCF).
The Regional Water Quality Control Board (Regional Board) adopted the final NPDES permit and
associated Time Schedule Order (TSO) for the City's WPCF on September 14, 2007. The scope of
work presented in this proposal includes the development of the NPDES permitting submittals
that are anticipated to he needed beginning in September 2008 and continuing through the end of
the July 2009 (hereinafter referred to as Fiscal Year 2008/2009, or FY 08/09).
Note that this scope does not cover any efforts pertaining to the completion of the Organic Loading
Study. This effort was presented under a separate scope of work, and is expected to be funded under a
different contract as the efforts outlined in this letter. In addition, it has been assumed that the City
staff will complete all of the necessary monitoring needed to achieve the objectives of the tasks
outlined in the Scope of Work section, and that the City will contract directly with a certified
laboratory for the completion of any necessary analytical efforts (with the exception of the monitoring
and analytical work needed for UV system validation). Under the Regulatory Program Management
task, WYA will provide support for coordinating these efforts with other regulatory needs.
SCOPE OF WORK
The following are the detailed engineering service tasks related to ongoing assistance to the City
in meeting the NPDES permit compliance requirements for the Lodi WPCF. These tasks include
the following:
• Task 1: Project Management
• Task 2: State Board Petition Support
• Task 3: SJVAPCD Biosolids Rule Compliance
• Task 4: Regulatory Program Management
131 A SMY Circe, Soft 100 Santa Rosa. Caff mfa 95401 Piww 747 543.8505 Fax 707 5434M email: mall0westpast.com
Mr, Charles E. Swimley Jr.
August 5,2008
Page 2
• Task 5: Land Application Monitoring Coordination
• Task 6: Compliance Studies (Method of Compliance Work Plan,
Pollution Prevention Plan and Treatment Feasibility Study)
• Task 7: Toxicity Reduction Evaluation
• Task 8: Title 22 Report
• Task 9: Wintertime Irrigation Management Plan
• Task 10: Temperature Study
• Task 11: Industrial Influent Characterization Study
• Task 12: Pond Freeboard Study
• Task 13: Salinity Evaluation and Minimization Plan
• Task 14: Groundwater Background Analysis
Task 1. Project Management
Task l includes project management -related activities including general project coordination. In
addition, to ensure continued achievement of consistently high quality work products, and in
accordance with the WYA Quality Assurance/Quality Control (QA/QC) policy, a WYA staff
member at the Principal Engineer level or higher will review progress and significant work products.
Brief descriptions of services performed under this task will be included on monthly invoices.
The efforts needed during FY 08/09 under this task can only be estimated at this time, and the
associated fee estimate presented in this letter proposal are based on WYA's knowledge of the
City's current permitting concerns. If the proposed budget is not expended in the timeframe
anticipated for this scope of services, it can be directed toward the completion of other efforts.
Task 2. State Board Petition Support
This task includes support efforts needed to suppon the City in the event of a State Water
Resources Control Board (SWRCB) action regarding the petition filed by the California Sports
Fisheries Alliance. These efforts may include:
• Review Draft SWRCB Order and prepare written comments;
• Prepare for and represent the City at Workshop/hearing before the SWRCB;
• Prepare comments on a revised draft order (if any); and
• Prepare for and Represent the City at the Final Hearing before the SWRCB (if any).
The actual level of effort necessary and the ultimate deliverables are uncertain. Therefore, a
nominal fee has been assumed for this task. All work will be performed on a time and material
basis. Monthly invoices will detail the efforts and costs. However, depending on the level of
effort required, a scope and budget amendment may be necessary in the future. Sumach Simmons
and Dunn (SSD) will also continue provide suppon services related to these efforts.
West Yon Associates SAn1\Cl1odiUp
Mr. Charles E. Swimley Jr.
August 5,2008
Page 3
Deliverable; Written connnent letter. that provides the City'.s response to the State Board
Order.
Tasks 3. SJVAPCDBiosolids Rule Compliance
In March 2007, the San Joaquin Valley Air Pollution Control District (SJVAPCD) adopted
Biosolids Operation Rule 4565. This rule requires that the implement additional controls for
Volatile Organic Carbon (VOC) emissions from the City's biosolids land application practices.
The City will not be able to comply with the SJVAPCD Biosolids Operation Rule. Therefore, the
City will need to work with SJVAPCD staff to identify a compliance strategy and timeline that
can be incorporated into a temporary variance.
The purpose of this task to provide assistance to the City, as needed, to obtain a variance to the
San Joaquin Valley Air Pollution Control District (SJVAPCD) Biosolids Operation Rule 4565.
Additional efforts are assumed to not be needed at this time. The actual level of effort is
uncertain. Therefore, a nominal fee has been assumed for this task. All work will be performed on
a time and material basis. Monthly invoices will detail the efforts and costs. However, depending
on the level of effort required, a scope and budget amendment may be necessary in the future.
Deliverable: SJVAPCD Variance Request Document.
Task 4. Regulatory Program Management
WYA anticipates that the City will continue to require ongoing assistance related to
understanding general regulatory compliance issues and implementing the measures needed to
achieve compliance. It is difficult to predict the level of effort needed for this task. Assistance
under this task is anticipated fo include one or more of the following items:
1. Working with City staff to understand the permit compliance requirements;
2. Maintaining and updating the attached implementation schedule for the compliance
measures;
3. Developing of presentations for City staff, Council, and/or other consultants to the
City outlining the regulatory compliance concerns;
4. Reviewing permits and other regulatory guidance documents issued by the Regional
Board and SWRCB that would be applicable to the W PCF
5. Providing assistance to the City. as needed, for developing responses to Regional
Board requests:
6. Providing assistance in developing semi-annual permit compliance progress reports
(Due February 1,2008 and August 1, 2009);
7. Coordinating efforts between all the studies and other planning -related issues;
8. Helping the City to develop monitoring programs;
9. Completing analyses of regularly collected monitoring data to identify potential future
regulatory concerns;
West Yost Associates sAnAeModAlp
Mr. Charles E. Swimley Jr.
August 5,2008
Page 4
10. Providing support to the City and the PCP Cannery in completion of the Land
Discharge Organic Loading Study and other food processing waste disposal issues:
and/or
11. Attending and preparing for meetings to discuss the results of such activities
outlined above.
All of the specific work efforts and deliverables under this task cannot reasonably be determined
at this time, and the associated fee estimate presented in this letter proposal air, based on WYA's
knowledge of the City's current permitting concerns. All work will be performed on a time and
material basis, and monthly invoices will detail the efforts and costs. Depending on the level of
effort required, a scope and budget amendment may he necessary in the future. Moreover, if the
estimated fee is not expended in the timeframe anticipated for this scope of services, it may be
directed toward the completion of other efforts. These tasks may also require support from our
sub -consultants SSD and RBI, and a small budget has also been assumed for these efforts.
It will be critical that the City's regulatory compliance efforts are completed in coordination with
Regional Board staff and other regulatory authorities. It is imperative that these agencies are in
agreement with the study approach and the type and amount of information to be obtained from
the study. Therefore, this task also involves the participation of WYA staff and our
subconsultants, as needed, in meetings with the appropriate regulatory agency staff. Meetings are
currently anticipated as follows:
• September 2008 to discuss the approach for the Treatment Feasibility Study Work
Plan, the Salinity Evaluation and Minimization Plan, and the Pond Freeboard
Evaluation Study;
•
January/February 2009 to discuss the Organic Loading Study Results and identify
appropriate permit modifications; and
• Jt€ne/J u I y 2009 to discuss the results of Year 1 monitoring for the Industrial Influent
Characterization Study, the Pollution Prevention Plan, the Temperature Study and the
Groundwater Background monitoring; the recommended Year 2 monitoring for these
studies (if any): and the approach for the Treatment Feasibility Study and the
Verification of Permit Compliance/Request for Flow Increase.
Other coordination meetings are also anticipated to be required.
Deliverable: Up to five meetings with the City, the Regional Board and/or other
regulatory authorities regarding the acceptability of the proposed Work Plans and
other regulatory matters. February 2009 Semi -Annual Progress Report (Temperature
Study, Industriallttflueru Characterization Study, Background Groundwater Qualit,
and Degradation Assessment). August 2009 Semi Annual Progress Report (Pollcction
Prevention Plan, Corrective Action Plan).
West Yost Amusciales sAnkklc dit
Mr. Charles E. Swimley Jr
August 5,2008
Page 5
Task 5. Land Application Monitoring Coordination
The new NPDES permit requires that the City significantly increase the level of monitoring for
the land application area site. In addition, the City must employ the efforts of a certified
agronomist in the completion of the land management monthly and annual reports. This task
involves providing the following items related to these efforts:
• Support with development of the August, September, and October monthly land
management monitoring reports. (It is assumed that WYA will need to provide
minimal support during the 2009 irrigation season);
• Review the 2008 data and help with development of the required 2008 Annual
Cropping and Irrigation Report;
• Efforts completed by Lew Baumhach (WITS) for oversight, review, and approval of
the August. September, and October monthly land management reports and the annual
land management report. (Based on discussions with City staff, it is assumed that the
City will contract directly rdth WFSduring the 2009 irrigation season.); and
• Coordination with City staff and tenant farmers regarding collection of required
monitoring data during the 2008 irrigation season.
Deliverables: PDF copies qF rhe August, September rind October niontl¢ly land
manage=ment reports. A MS EXCEL version of the 2008 Spreadsheet Management
Tool, with all data incorporated. A MS EXCEL version of the 2009 Spreudsheei
Management Tool for use by the City. The 2008 Annual Lana Managentent Report
with approval by Lery Baumbach from WFS.
Task 6. Compliance Studies
The following compliance studies are required under the new NPDES permit:
• Corrective Action Plan/Method of Compliance Work Plan
• Pollution Prevention Plan
• Treatment Feasibility Study
This task includes the efforts that will need to be completed for these studies during FY 08/09.
Subtask 6.1. Corrective Action Plan/Method of Compliance Work Plan
WYA completed the Method of Compliance Work Plan (MOC Work Plan) in April 2008.
Approval of the MOC Work Plan was provided by the Regional Board in a letter dated
June 26,2008. Implementation of the Work Plan requires support that will be provided under the
Regulatory Program Management Task (Task 4), including the submittal of an Annual Progress
Report on August 1, 2008, which will detail the progress that has been made toward achieving
compliance. Therefore, this subtask is complete is will not require additional scope or budget
(now or in the future).
West Yost Associates &Amk1)odjUp
Mr. Charles E. Swim -ley Jr
August 5,2008
Page 6
Subtask 6.2. Pollution Prevention Plan
Pollution Prevention Plans (PPPs) are required for all dischargers that receive permit compliance
schedules for new effluent limitations. Therefore, the City is required to develop a PPP for mercury,
aluminum, chlorodibmmomethane, dichlorohmmomethane, manganese nitrate and nitrite.
WYA completed the Pollution Prevention Plan Work Plan (PPP Work Plan) on behalf of the City
in April 2008. Comments on the PPP Work Plan were received on July 9, 2008. In this letter, the
Regional Board requested that the City submit an Initial Manganese PPP Study, in accordance
with the requirements of the City's TSO. In addition, the Regional Board requested an addendum
to the PPP Work Plan, providing the completion date for the City's current upgrade projects. This
information has recently been provided and approval of the PPP Work Plan and the Initial
Manganese PPP Study is anticipated by September 2008.
The PPP Work Plan calls for monitoring of the City's municipal water supply, the discharges
from specific industrial and commercial dischargers and the WPCF influent. The sampling
parameters and frequency are also provided in the PPP Work Plan. WYA anticipates that the City
staff will complete all of the sample collection efforts required under the PPP Work Plan during
FY 08/09. WYA also assumes that the City will contract directly with the analytical laboratory
for the sample analysis.
WYA efforts during the PPP implementation Phase I (FY 08/09) will include review of the data
collected under the PPP Work Plan. It is anticipated that such data will he provided to WYA as it
becomes available from the laboratory.
WYA will also provide recommendations for additional efforts that should he completed during
Phase II (FY 09/10). As discussed in the PPP Work Plan, the additional PPP recommendations
will he included in the August 2009 Progress Report, which will he provided under the
Regulatory Program Management Task (Task 4). In addition, WYA will participate in a meeting
with Regional Board staff to discuss the results of the FY 08/09 monitoring and the
recommendations for FY 09/10 monitoring. This effort will also be provided under the
Regulatory Program Management Task (Task 4) .
Finally, the Initial Manganese PPP Study calls for the development of a community pamphlet that
details the water quality issues associated with self -regenerating water softeners. WYA will
develop the technical information needed for this effort. In addition. WYA graphical design staff
will develop an electronic version of the pamphlet, which will then he submitted to the City for
production and distribution. WYA will coordinate, as needed, with the City's designated
production staff to ensure the electronic version is compatible with their needs.
Deth,ciables: Electronic t,es-sion of the Setf-Regenerating Water Softener Pamphlet.
West Yost Associates sAin\e11odA1p
Mr. Charles E. Swimley Jr.
August 5, 2008
Page 7
Task 6.3 Treatment Feasibility Study
The NPDES permit requires that the City submit a Work Plan for the completion of a Treatment
Feasibility Study (TFS) within one year of the effective date of the permit (or by
November 3,2008). The purpose of the TFS Work Plan is to describe the efforts that will be
completed by the City to examining the feasibility, costs and benefits of different treatment
options that may he required to remove aluminum, ammonia, chlorodibromomethane, and
dichlorobrornomethane from the discharge. A TFS is required for all dischargers that receive
permit compliance schedules for new effluent limitations.
This subtagk involves the completion of the TFS Work Plan. Note that the City is in the process
of constructing the facilities needed to meet the effluent limitations in question, and compliance
should be achievable by early 2009. Therefore, the TFS Work Plan will outline the monitoring
that will be completed by the City once these upgrades are complete to verify that the compliance
objectives have been met. Note that this monitoring will also be used to support the City's request
for a flow increase to 8.5 million gallons per day.
Note that the NPDES permit provides the City with a two yew timeline to complete the TFS from
when the TFS Work Plan is approved by the Executive Officer. The support required by the City
to complete the activities outlined in the TFS Work Plan cannot be reasonably identified at this
time. Therefore, this task does not currently include any additional efforts needed for completion
of the TFS. However, WYA will provide the City with a scope and budget for providing support
to the City for the completion of the TFS along with the Draft TFS Work Plan.
Delit,erubles: Treatrnient Feasibility Study WorkPlan.
Task 7. Toxicity Reduction Evaluation
RBI, in association with WYA, completed the Toxicity Reduction Evaluation Work Plan (TRE
Work Plan) in January 2008. Approval of the TRE Work Plan was provided by the Regional
Board in a letter dated June 26, 2008. Implementation of the TRE Work Plan will only be
required should the WPCF exceed the TRE trigger outlined in the NPDES permit. This
requirement is applies to all NPDES dischargers. As detailed in the TRE Work Plan, the major
items that may need to be included under a TRE are as follows:
• Whole Effluent Toxicity Testing Bioassay Evaluation;
• Information and Data Acquisition;
• Facility Operations and Performance Evaluation;
• Preparation of a Final TRE Action Plan;
• Toxicity Identification Evaluation (TIEs);
• Toxicity Source Evaluation and Control; and/or
• Preparation of a TRE Report.
Wesi Yost Associates s:VnkvVtxfitip
Mr. Charles E. Swimley Jr.
August 5,2008
Page 8
The efforts needed during FY 08/09 are based on the assumption that the City will need to
implement a Toxicity Reduction Evaluation (TRE) as presented in the TRE Work Plan. However,
if the City's monitoring does not demonstrate toxicity in the WPCF effluent, a TRE will not he
necessary. If the fee estimate outlined in this letter proposal is not expended in the timeframe
anticipated for this scope of services, they can be directed toward the completion of future efforts.
On the other hand, the amount of services needed to complete a TRE cannot be accurately
predicted at this time because the amount of effort needed for key steps in the process, and even
the sequential steps in the process itself, are largely dictated by the outcome of the bioassays and
the Toxicity Identification Evaluations (TIEs) and having the TIE be effective in identifying the
constituent causing the toxicity that then needs to be controlled. These outcomes cannot be known
at this time. The amount of services needed for facility operations and performance evaluation
will is also dependent upon the amount of this task completed by City, which will likely be
dependant on the timing and frequency of the toxicity exceedances. Therefore, this scope of work
for this task is limited to the budget allocated in this letter proposal. In the event that a TRE
requires services beyond that scoped and budgeted herein. WYA would, upon request, submit a
separate proposal for additional services. The budget also assumes that the City will contract
directly with the bioassay laboratory for all TRE bioassay and TIE work.
In addition, because TREs are an intricate series of steps and assessments over time, with the
exact nature of activities in latter tasks largely dictated by the outcome and findings in the initial
tasks, the proper and efficient conducting of a TRE requires extensive technical oversight,
coordination, and direction. Therefore. this task provides budget for such services as well as
miscellaneous services provided during the TRE process not specifically covered under other the
specific TRE items listed above.
Given their expertise, RBI would serve as the technical lead for this work. However, WYA will
provide support and coordination in completing these efforts. Coordination meetings required
over the next twelve months in support of completing this task will be covered under the
Regulatory Program Management Task (Task 4) described above.
Task S. Title 22 Engineering Report
WYA completed the Title 22 Engineering Report Work Plan (Title 22 Work Plan) in April 2008,
The purpose of the Title 22 Report is to document the City's current recycled water uses and
operations. The recycled water uses at the WPCF include irrigation on City -owned property,
supply water for the Northern California Power Agency (NCPA) power plant, and supply water
for the San Joaquin County Mosquito and Vector Control District (SJCM&VCD) fish rearing
ponds. A Title 22 Report, prepared in accordance with the information listed in Department of
Public Health (DPH) March 2001 document "Guidelinesfor the Preparation cf an Engineering
Report _ for the Production, Distribution, and Use of Recycled Water" is required for all
wastewater treatment facilities that supply recycled water.
Approval of the Title 22 Work Plan was provided by the Regional Board in a letter dated
June 18,2008. The implementation phase of the Title 22 Work Plan will need to be completed
during FY 08/09, and development of the Title 22 Report will occur during FY 09/10.
Implementation of the Title 22 Work Plan during FY 08/09 will include the following items:
West Yost Associates sAmlcUodA1p
Mr. Charles E. Swimley Jr.
August 5,2008
Page 9
UV System Validation
• Review of Northern California Power Authority (NCPA) Facilities
• Coordination with Department of Public Health (DPH)
8.1 UV System Validation
This task covers the following items:
• Preparation of the UV Validation test protocol;
• Design of the experimental set up;
• Testing of electrical components, controls, and alarms;
• Instrumentation calibration;
• Conducting the bioassay checkpoint test (including sample collection and analytical
work); and
• Preparation of the summary test report.
Given their expertise in this area, Carollo Engineers (Carollo) will take the lead in the
performance of the commission testing of the City's UV disinfection system in general
accordance with the NWRI UV Guidelines (2003).All equipment required to conduct the various
tests will be provided by Carollo and/or WYA.
One, knowledgeable WPCF staff will need to be available on site during the days of testing to
provide required wastewater flows through the system, ensure proper dosing, and manually
operate the UV system when needed. Approximately 20 hours of staff time is assumed to he
needed over a period of three days.
Deliverables: UV Validation Testing Protocol Document and UV Validation Testing
Report of Results.
8.2 Review of NCPA Facilities
This task involves the development of the documentation needed for the Title 22 Report to
demonstrate that the appropriate steps have been taken by NCPA to ensure protection of public and
employees, and that cross -connection controJ procedures are in place at the NCPA recycled water use
facility. The supporting documentation required to establish these objectives are listed below:
• Description of the type of systems using the recycled water, including potential for
employee or public exposure, and the mitigative measures to be employed;
• Maps and/or plans showing the location of the transmission facilities and the
distribution system layout. This should include the location of all potable water,
recycled water and sewer lines within the NCPA facility;
West Veld Mmxiatm %Am\L\1odA1p
Mr. Charles E. Swimley Jr.
August 5,2008
Page 10
Description of cross connection control procedures and policies in the NCPA areas
where both potable and recycled water lines exist. This includes the cross -connection
control employed at the NCPA's recycled water treatment facility prior to use in the
cooling towers. It is assumed that the NCPA facility does not meet the Title 22
definition of implementing a "dual plumbed system", therefore, Sections 60314
through 60316 of the DPH Recycled Water Criteria do not apply to this facility;
• Description of training received by NCPA employees with regard to complying with
the recycled water criteria; and
• Description of the periodic inspection carried out at the NCPA, including
identification of the locations where problems are most likely to occur.
It has been assumed that WYA will need to participate in one meeting with the City and NCPA
staff, and that one site -visit to the NCPA facility will be needed to complete this task. It is also
assumed that NCPA will provide access to the documentation listed above during the site visit.
WYA will review the documentation provided by NCPA to determine that all necessary
components are included. It is also assumed that some additional follow-up efforts will be needed
to discuss and verify the documentation provided by NCPA.
8.3 Coordination with Det?artment of Public Health
The City is proposing the following two activities that are site-specific to the WPCF that will
require DPH approval:
Provide "undisinfected secondary" effluent to the SJCM&VCD fish rearing ponds.
The DPH Title 22 Guidelines require the use of "disinfected tertiary" water in
impoundments where the public has access. Because the fish rearing ponds are located
on City -owned property, the City is requesting that DPH allow the use of
"undisinfected secondary" effluent at this facility. Allowance for this type of operation
would provide cost savings to the City.
• Provide "disinfected secondary" effluent to the NCPA Power Plant when the water is
being used as boiler feed water. The City will need to demonstrate that this standard
can be reliably met when the UV system is operated at a lower dosage than what is
needed to meet the "disinfected tertiary" standard. Allowance for such operations
could provide cost savings to the City.
WYA will prepare for, and participate in, up to two (2) meetings with DPH staff regarding the
above activities. The U V Validation testing will also be discussed at these meetings.
The first meeting will be conducted early in the Title 22 Work Plan implementation stages to
obtain initial comments from DPH staff regarding the proposed operations. WYA anticipates that
DPH staff will provide guidance at this meeting regarding the type of documentation needed to
support the proposed actions. (Note that if documentation is needed for the NCPA facility that is
not currently listed under subtasl< 8.2, WYA will also work with the City and NCPA to obtain and
review such documentation.)
West Yost Associates 0111" 11odiVp
Mr. Charles E. Swimley Jr,
August 5,2008
Page 11
A follow-up meeting will be held once the documentation requested by DPH has been developed.
If at either of these meetings DPH staff indicates that support of the proposed operations is not
likely, the City may elect to modify the proposed Title 22 compliance approach. The scope and
budget for this task may he reduced pending such a decision.
Deliverables: Up to nvo meetings with the City and DPH regarding the City's site-specific
Title 22 Compliance requirenterrts.
Task 9. Wintertime Irrigation Management Plan
WYA completed the Wintertime Irrigation Management Plan Work Plan (WIMP Work Plan) in
April 2008. Conditional approval of the WIMP Work Plan was provided by the Regional Board
in a letter dated June 19,2008. As required under the City's NPDES permit, the City must submit
the WINP by December 19, 2008. This document must describe the actions that will he taken by
the City to minimize potential water quality impacts during flooding events that would cause
washout of wastewater or biosolids from the land application area. This requirement was included
in the City's permit because approximately half of the City's land application areas are located
within the 100 -year floodplain for the Sacramento -San Joaquin Rivers Delta.
Deliverable: Wintertime Irrigation Management Plan
Task 10. Temperature Study
RBI, in association with WYA, completed the Temperature Study Work Plan for the White
Slough WPCF Effluent and Downstream Water Bodies (Temperature Study Work Plan) in April
2008. Approval of the Temperature Study Work Plan was provided by the Regional Board in a
letter dated June 26,2008. The implementation phase of the Temperature Study Work Plan began
on July 22, 2008. Given their expertise in this area, RBI will continue to serve as the technical
lead for this work. WYA will provide support and coordination efforts during the completion of
this study.
The purpose of the Temperature Study is to define what future objectives should be applied to the
receiving water with respect to temperature. The City was required to do this study because direct
enforcement of the Thermal Plan cannot be applied to the City's receiving waters. The
Temperature Study Work Plan GdUs for continuous monitoring of the temperature of the City's
receiving and the WPCF effluent for a period of twelve months. WYA anticipates that the City
staff will complete all of the data collection efforts required under the Temperature Study Work
Plan during FY 08/09, including the purchase of monitoring equipment.
The scope of work for WYA/RBI efforts during the Temperature implementation phase (FY 08/09)
include review of the data collected. It is anticipated that the City will download the temperature data
on aweekly basis and this data will be provided to WYA/R$1 on a monthly basis.
West Yog Associates sAmk¢UodiUp
Mr. Charles E. Swimley Jr.
August 5,2008
Page 12
In addition, WYA/RBI will also participate in up to two (2) meetings with the City and/or
Regional Board staff to discuss the results of the FY 08/09 monitoring and the recommendations
for development of the Temperature Study Report. The City must also submit a Progress Report
on February 1, 2009 detailing the status of the Temperature Study. Assistance will be provided by
the WYA/RBI team for these efforts under the Regulatory Program Management Task (Task 4).
Task 11. Industrial Influent Characterization Study
WYA completed the Industrial Influent Characterization Study Work Plan (Industrial
Characterization Work Plan) in April 2008. The goal of the study is to identify any potential
groundwater Contamination issues, if any, from discharges of the untreated industrial wastewater
to the City's agricultural fields. Based upon the results of this study, the City's permit may he
reopened to include/modify effluent limitations, land application specifications, or to provide
additional requirements.
Approval of the Industrial Characterization Work Plan was provided by the Regional Board in a
letter dated June 26, 2008. In accordance with the City's permit, the Industrial Characterization
Work Plan calls for monitoring of the City's industrial wastewater on a quarterly basis to
characterize the wastewater influent collected by its industrial sewer system. The sampling
parameters and monitoring details are provided in the Industrial Characterization Work Plan.
WYA anticipates that the City staff will complete all of the sample collection efforts required
under the Industrial Characterization Work Plan during FY 08/09. WYA also assumes that the
City will contract directly with the analytical laboratory for the sample analysis.
In accordance with the City's NPDES permit, the Industrial Characterization will occur over a
two-year period. The scope of work for WYA efforts during the first year (1~Y 08/09) include
review of the data collected (it is anticipated that such data will he provided to WYA as it
becomes available from the laboratory). WYA will also provide a Technical Memorandum
summarizing the results of the first year of monitoring and recommendations for additional
sampling that should he completed during the second year of monitoring (FY 09/10). As
discussed in the Industrial Characterization Work Plan, the additional Industrial Characterization
recommendations will be provided by July 1, 2009.
The City will also need to submit a Progress Report on February 1, 2009, which will be provided
under the Regulatory Program Management Task (Task 4). In addition, WYA will participate in a
meeting with Regional Board staff to discuss the results of the FY 08/09 monitoring and the
recommendations for FY 09/10 monitoring. This effort will also be provided under the
Regulatory Program Management Task (Task 4).
Delh,eruble: Technical Memorandum suntntarizing the results cf the first year monitoring
and providing recontmendationsfor monitoring during the second year.
West Yost Associates sAmkllodNv
Mr. Charles E. Swimley Jr.
August 5, 2008
Page 13
Task 12. Pond Freeboard Evaluation Study
The NPDES permit requires that the City submit a Pond Freeboard Evaluation Study Work Plan
(Pond Freeboard Work Plan) that describes the actions the City will take to evaluate the stability
of the pond berms, the risk for undesirable reactions caused by berm failure or pond overtopping,
the need to implement mitigation or control measures necessary to prevent undesirable risk, and
also shall determine an adequate freeboard that prevents undesirable risks. The Pond Freeboard
Evaluation Study Work Plan must he submitted to the Regional Board within twelve months of
the effective date of the permit, or by November 2, 2008.
The City was required to complete this study in lieu of receiving a requirement in the NPDES
permit to maintain a 2 -foot freeboard in the ponds at all times. Therefore, based upon the results
of €hi.s study, the permit may be reopened to include additional requirements with respect to the
freeboard in the ponds.
WYA will develop the Pond Freeboard Work Plan in accordance with the permit requirements.
As part of the development of the Pond Freehoard Work Plan, WYA will identify a geotechnical
engineer that can evaluate the stability of the pond berms.
Following the Executive Office approval of this Work Plan, the City will need to complete
several actions over a two-year period to develop the Pond Freeboard Evaluation Study. The
support required by the City to complete these activities cannot be reasonably identified at this
time. Therefore, this task does not currently include any additional efforts needed for completion
of the Pond Freeboard Evaluation Study. However, WYA will provide the City with a scope and
budget for completion of the Pond Freeboard Evaluation Study along with the Draft Pond
Freeboard Work Plan.
Delit,erable,s: Pond Freeboard Emluation Study Work Plan.
Task 13. Salinity Evaluation and Minimization Plan
The NPDES permit requires that the City submit a Salinity Evaluation and Minimization Plan that
identifies the sources of salinity in the W FCF domestic and industrial influent. These plans are
required for all municipal dischargers of 1 million gallons per day or larger in the Central Valley
per the guidance documents developed by the Regional Board in 2007. The Salinity Evaluation
and Minimization Plan must be submitted within twelve months of the effective date of the
permit, or by November 2,2008.
WYA will develop the Salinity Evaluation and Minimization Plan in accordance with the permit
requirements. Data collected during the first quarter monitoring under the PPP will be used to
develop this Plan.
West YUat Associates SAM\L\IOdNP
Mr. Charles E, Swimley Jr.
August 5,2008
Page 14
Following Executive Office approval of the Salinity Evaluation and Minimization Plan, the City
must provide annual reports (first one is due on August 1, 2009) demonstrating reasonable
progress in the reduction of salinity in its discharge to Dredger Cut and the Agricultural Fields.
These reduction measures may include source control, mineralization reduction, chemical
addition reductions, changing to water supplies with lower salinity, and limiting the salt load from
domestic and industrial dischargers. The support required by the City to complete this progress
report will not occur during FY 08/09. Therefore, this task does not currently include any
additional efforts needed for completion of the Annual Report. However. WYA has provided the
City with an estimated budget for completion this effort.
Deli►,erables: Salintih• Evaluation and Minimization Plan.
Task 14. Background Groundwater Quality and Degradation Assessment Study
WYA completed the revised Background Monitoring Well Installation Work Plan (Monitoring
Well Work Plan) in May 2008. This Monitoring Well Work Plan identified the approximate
locations and construction details for three new monitoring wells to evaluate background nitrate
concentrations and electrical conductance (EC) levels near the WPCF. The Regional Board
approved this Work Plan on June 4, 2008. In accordance with the Monitoring Well Work Plan,
the monitoring wells will be installed during the last week of August 2008 (and therefore will not
be completed under this scope of services).
WYA will develop a well completion report in accordance with applicable Department of
Water Resources, Regional Board, and San Joaquin County Department of Environmental
Heath requirements.
The wells will need to be monitored on a quarterly basis in accordance with the Monitoring and
Reporting Program included in the City's permit. WYA anticipates that the City staff will
complete all of the sample collection efforts required during FY 08/09. WYA also assumes that
the City will contract directly with the analytical laboratory for the sample analysis.
WYA will provide review of the data collected (it is anticipated that such data will be provided to
WYA as it becomes available from the laboratory). WYA will also assist rhe City in the
development of a Progress Report due on February 1, 2009. In needed, WYA will participate in a
meeting with Regional Board staff to discuss the results of the FY 08/09 monitoring and the
recommendations for FY 09/10 monitoring. These efforts will be provided under the Regulatory
Program Management Task (Task 4).
Following the installation of the background monitoring wells, the City will need to complete
background monitoring to develop the. data needed to complete the Background Groundwater
Quality and Degradation Study Report (due to the Regional Board by August 1, 2010). The
support required by the City to complete the Background Groundwater Quality and Degradation
Study Report cannot be reasonably identified at this time. Therefore, this task does not currently
include these efforts. However, WYA has provided the City with an estimated budget for the total
effort needed to complete the Background Groundwater Quality and Degradation Study Report.
Delii,erables: Background Monitoring Well Completion: Report,
Wei( Yos( 4:1m1r1#MNp
Mr. Charles E. Swimley Jr.
August 5,2008
Page 15
PROJECT BUDGET
The total fee for the scope of work described above is estimated to be $365,300. A summary of the
project costs by task is shown in the attached Table 1, and a detailed breakdown is also attached.
WYA will perform all work on an hourly basis at standard company charge rates, and will not exceed
the estimated cost without written authorization. If additional budget is required to complete work
identified herein, WYA will request City authorization prior to exceeding the budget.
SCHEDULE
Work will begin upon notice to proceed from City, and will be completed by August 1, 2009. A
detailed schedule showing all of the permit compliance activities has recently been provided by the
City and will he maintained by WYA throughout the duration of this contract. WYA and our sub -
consultants will provide additional services related to the studies needed under the renewed permit,
subject to mutually agreeable adjustments to the scope, authorized budget, and schedule.
WYA appreciates the opportunity to provide additional permitting services to the City. Please
contact me if you have any questions or need additional information.
Sincerely,
7th
Y ST ASSOCIATES
arvn E.
Senior Engi
KEG:n€np
cc: Wally Sandelin, City of Lodi
Del Kerlin, City of Lodi
West Yost Associates s:lmkeModNp
Mr. Charles E. Swimley Ir
August 1, 2008
Page 16
Table 1. Estimated Fee for FY 08/09 Permit Implementation Support
Task
Task 1. Project Management
WYA Fee
Estimate,
dollars
$14,100
Subconsultants
Total
Estimates!
Fee,
dollars
$ 22,300
Technical
Support
Budget
(RBI),
dollars
$ 8,200
Legal
Support
Budget
(SSD),
dollars
-
Technical
Support
Budget
(WFS),
dollars
-
Technical
Support
Budget
UV
Validation,
dollars
-
Biological
Analysis
UV
Validation,
dollars
-
Task 2. State Board Support
$18,800
-
$13,300
-
-
-
$ 32,100
Task 3. SIVAPCD Biosolids Rule Compliance
$9,900
-
-
-
-
$ 9,900
Task 4. Regulatory Program Management
$34,800
$ 5,900
$5,500
-
-
-
$ 46,200
Task 5. Land Application Monitoring Coordination
$16,000
-
$15,400
-
-
$ 31,400
Task 6: Compliance Studies
$24,800
-
-
-
-
-
$ 24,800
Task 7: Toxicity Reduction Evaluation
$14,400
$54,000
-
-
-
-
$ 68,400
Task 8: Title 22 Report
$17,500
-
-
-
$ 44,000
$ 13,500
$ 75,000
Task 9: Wintertime Irrigation Management Plan
$4,800
-
-
-
-
-
$ 4,800
Task 10: Temperature Study
$2,000
$10,200
-
-
-
-
$ 12,200
Task 11: Industrial Influent Characterization Study
$13,100
-
$ 13,100
Task 12: Pond Freeboard Study
$6,600
-
-
-
-
-
$ 6,600
Task 13: Salinity Evaluation and Minimization Plan
$10,000
-
-
-
-
$ 10,000
Task 14: Background Groundwater Analysis
Totals
$8,500
$195,300
-
$78,300
-
1$18,800
-
$15,400
-
$44,000
-
$13,500
$ 81500
$365,300
Wes[ Yost Asmiciates s:lmlrllixlillP
PROPOSED BUDGET for CITY OF LODI
PROJECT: REGULATORYASSISTANCE-PRELIMNARYDRAFT
815/2008
Task r SJVAPCD Coordination
3.01 Meetings 8 8 $ 1,256 $ 63 $ $ 200 $ 1,519
3.02 Ongoing Coordination 24 34 $ 399 $ - $ 8,383
Subtotal, Task 3 (hours) 0 32 0 0 34
�5�8�$7,98�4���
Subtotal, Task 3 ($) $ $ 5,024$ - $ - $ 4,216, $ 462 $ $ 200 $ 9,902
Task r Regulatory Program Management
5.01 Spreadsheet Tool Update
0$
-
$
- $ -
4.01 General Support
4
40
24
68
$
10,056
$
503
$ 4,400
$
14,959
4.02 Status Reports (Aug. and Feb.)
2
40
60
102
$
14,120
$
706
$ -
$
14,826
4.03 Meetings (5)
4
40
10,145
44$
3 48 0
7,080
$
354
$ 7,024 $
2,000 $
16,458
Subtotal, Task 4 (hours)
10
120 0
0 84
214
0
0
$ $
1,136
$ I $ 1,000 $
24,846
Subtotal, Task 4 ($)
$ 2,000 $
18,840 $
$ $ 10,416
$
31,256 $
$ $
1,563
$ 11,424 $
2,000 $
46,242
Task r Land Application Area Monitoring and Coordination
5.01 Spreadsheet Tool Update
0$
-
$
- $ -
$
-
5.02 Annual Reports
2 24 12 40 78
$ 10,196
$
510 $ 2,112
$
12,818
5.03 Data Collection Support
0
$ -
$
- $ 13,313
$
13,313
5.04 Monthly Report Support (April 08 - April 09)
32 32
$ 5,024
$
251 $ -
$
5,275
Subtotal, Task 5 (hours)
2 56 0 12 40 110
0
0
10,145
Subtotal, Task 6 (hours)
3 48 0
Subtotal, Task 5 ($)
$ 400 $ 8,792 $ - $ 1,068 $ 4,960
$ 15,220 $
$ $
761 $ 15,425 $
- $
31,406
Task r Regulatory Compliance Studies
6.01 Self -Regenerating Water Softener Pollution Prevention Pamphlet
1 8
24 32
65
$
7,560
$
378
$ $ 1,000
6.02 Pollution Prevention Plan Implementation Support
16
24
40
$
5,488
$
274
$
6.03 Treatment Feasibility Study Work Plan/Scope
2 24
6 40
72
$
9,662
$
483
$ $
10,145
Subtotal, Task 6 (hours)
3 48 0
30 96
177
0
0
Subtotal, Task 6 ($)
$ 600 $ 7,536 $
- $ 2,670 $ 11,904
$
22,710 $
$ $
1,136
$ I $ 1,000 $
24,846
C:\Documents and Settings\kgies\Desktop\Fee for Lodi_PhasellAs
1 of 3
W E 5 i Y p 5 i
A 5 5 0 C I A T E 3
Conni?", F. sy, nrrn
PROPOSED BUDGET for CITY OF LODI
PROJECT: REGULATORYASSISTANCE-PRELIMNARYDRAFT
8/5/2008
Task :r Title 22 Engineering Report
11.01 Implementation
8 24 32 $ 4,232 $ 212 $ $ 4,444
11.02 Phase II Recommendations TM
2 16 4 40 8 $ 411 $ - $ 8,639
Subtotal, Task 11 (hours)
2 24 0 4 64 0 0
1��$12,460
Subtotal, Task 11 ($)
8.01 UV Validation
2 32
34
$
5,424
$
271
$ 57,530
$63,225
8.02 NCPA Site Review
24
40 64
$
8,728
$
436
$
$
9,164
8.03 DPH Coordination
16
16
$
2,512
$
126
$
Subtotal, Task 8 (hours)
2 72 0
0 40 114
0
0
Subtotal, Task 8 ($)
$ 400 $ 11,304 $
$ $ 4,960
$
16,664 $
$ $
833
1 $ 57,530 $
$
75,027
$ 49,120
$ $ 49,120 1 $ $ $
Task 11.0 Industrial Influent Characterization Study
11.01 Implementation
8 24 32 $ 4,232 $ 212 $ $ 4,444
11.02 Phase II Recommendations TM
2 16 4 40 8 $ 411 $ - $ 8,639
Subtotal, Task 11 (hours)
2 24 0 4 64 0 0
1��$12,460
Subtotal, Task 11 ($)
$ 400 $ 3,768 $ $ 356 $ 7,936 $ $ $ 623 1 $ $ $ 13,083
C:\Documents and Settings\kgies\Desktop\Fee for Lodi_PhasellAs
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',MF Si Y 0 5 T
r.55 n:- in•F 5
Estimated Staff Hours and Budget
West Yost Associates P/VP SE/SS PE/PS
$200 $157 $174
PROJECT: Regulatory Assistance - Preliminary Draft BGW/JDP KEG KLL
Task 14.0 Groundwater Monitoring Background Assessment
Labor Drafting Modeling Costs Sub. 1 Sub.2 Sub.3 Sub.4 Sub.5
ADMIV ESII Hours Fee Hours Fee Hours Fee Routine Sub. Other Total SSD RBI WFS UVV BIO
$89 $124 $ 25 $ 25 ODC w/ markup Direct Costs
BM 5% 10%
IN IIII:�iL:�i
A RESOLUTION OF THE LODI CITY COUNCIL
AUTHORIZING ADDITIONAL TASK ORDER WITH
WEST YOST &ASSOCIATES TO PROVIDE PERMIT
ASSISTANCE AND PREPARE VARIOUS STUDIES
REQUIRED BY THE CITY'S WASTEWATER DISCHARGE
PERMITAND FURTHER APPROPRIATING FUNDS
WHEREAS, the City's new wastewater discharge permit includes requirements
for a number of studies to be conducted and plans or reports to be developed on various
aspects of the City's wastewater treatment operations: and
WHEREAS, on December 19,2007, Council authorized West Yost &Associates to
proceed with preparingwork plansfor various studies required bythe Permit: and
WHEREAS, West Yost & Associates has furnished the City with a combined
proposal to respond to the Permit requirements for fiscal year 2008-09, including
assisting City staff in regulatory program management: and
WHEREAS, the studies' monitoring efforts are required in the City's Permit and
non-performancewould subject the City to significant fines; and
WHEREAS, the estimated cost for this work is $365,300, and staff suggests a
contingency amount of approximately 10% to accountfor unforeseen issues for a total of
$400,000.
NOW, THEREFORE, BE IT RESOLVED that the Lodi City Council does hereby
authorize an additional task order with West Yost & Associates, of Davis, California, to
provide permit assistance and prepare various studies required by the City's wastewater
discharge permit issued by the State Central Valley Regional Water Quality Control
Board: and
BE IT FURTHER RESOLVED that funds in the amount of $400,000 be
appropriated from the Wastewater Fund for this project.
Dated: August 20, 2008
hereby certify that Resolution No. 2008-161 was passed and adopted by the
City Council of the City of Lodi in a regular meeting held August 20, 2008, by the
following vote:
AYES: COUNCIL MEMBERS — Hansen. Hitchcock, Johnson, Katzakian,
and Mayor Mounce
NOES: COUNCIL MEMBERS— None
ABSENT: COUNCIL MEMBERS— None
ABSTAIN: COUNCIL MEMBERS— Nonedt��
RANDI JOHL
City Clerk
2008-161