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HomeMy WebLinkAboutAgenda Report - August 19, 1992of 4� AGENrP TITLE: Consider Certificatioil rt the white `..►ouch Wate+ PWlut.ion Cortrol Facility Expansiar, Supplercrrtal Finai tnvironmentiaP :cnpact Report MEETING DATE: August 19. 1992 PREPARED BY: Community Developnrer,t. Director RECOMMENDED ACTION: That the City Council determine the gapplemental Final Environmental Impact Report ( SFE I R) for U h ite Slough Water Pollution Control Facility Expahsion prepared by E I P Associates i s adequate and Lerti fy the document. BACKGROUND INFORMATION: The purpose of this document is to revise and supplement the June 1988 Environmental Impact Report: (Elft) for the White Slough Water Pollution Control Faci' ty Plant Expansion. The preparation of this Supplemental E!R was required becait— rflw information became available since the certification of the original EIR. rew information regards the relationship between receiving water quality and the V`4PCF performance. Specifically. the project description of the original EIR assumed the expanded facility would be capable of producing domestic effluent havinp 10 milligrams/liter (mg/L) or less biochemical oxyqen demand (BOO) and total suspended solids (TSS) more than 90 percent of the time. FINDINGS: The project considered in the original EIR involved thie expansion of the VHF ir= an average dry, weather flow capacity of 6.2 million gallons per day (MGD) to 8.5 MGD (an increase of 2.3 MGD. or a 37% increase in capacity). together with improvements to the wastewater irrigation and sludge handling systems. The proposed action under consideration in the Supplemental EIR i s the same as considered i n the original EIR with one exception: the June 1988 EIR assumed the expanded WSWPCF would routinely produce an effluent quality of 10 mg/L ROD & TSS. The supplemental EIR examined the environmental effects that would result from VGAF F production of an effluent with 30 mg/L BOD & T5; from 16 October to 31 MBY, and 20 mg/L from 01 June through 15 Oct. The proposed action would result in an increase in the mass emission of BOD 6 TSS into the recefving waters. as compared to the existing conditions; however the dissolved oxygen (DO) levels in the receiving waters are expected to be maintained above standards currently established by the Regional Uater Quality Control Board. Water quality monitoring wculd be included, and no treated effluent would be discharged when DO levels fall below established standards. The City has begun preparing an additional 275 acres of recently purchased land to receive treated effluent to ensure adequate reuse/disposal capacity. As considered in the original EIR, the buildup of heavy metals i n the soil would occur slowly as a result of the land reuse/disposal of effluent, but with the existing pretreatment program. effluent disposal could occur for about 200 years before the buildup reached levels where additional land disposal would be prohibited. y APPROVED. — • +- =�'�`— --- — — i�J T1I0MAS A PETERSON, Certification of White SIour, h Witer Pnl,ution Conirr:l Facility Fxpansiors SuDplemental Final ETR August 19, 1992 Page two Summary of Er{vironmental Effects - ProDosed Actions See attached Table 5-1 and 5-2. 1 Findinq 1. The City of Lodi finds that the supplemental Final EIR has been completed Tr compliance with CEQA; 2. The Supplemental Final EIR has been presented to the City Courkil and has been reviewed and considered prior to its approval; and 3. The City of Lodi will adopt the required mitigation measureis to reduce all significant, or potentially significant environmental impacts to a less than significant level. Mitigation measures include: a. Additional water quality monitoring of the receiving waters will be conducted to provide complete data as to when ambient conbitions are such that DO levels should fall below 5.0 mg/1. When such conditions are present, WSWPCF effluent would be diverted to storage facilities or land application. b. Because disposal capacity is considered to be marginally adequate to accommodate extended perfods of irrigation when discharge is prohibited. the City of Lodi shall prepare an additional 275 acres of land for effluent appl icat ion. c. Continue with the City's existing pretreatment program of industrial wastewater discharge to remove heavy metals with an rmphasis on zinc. Attached is a copy of the Supplemental Final Environmental Impact Rlrt. FUNDING: None required. C- S s . schroe Wmmunity Development Director Prepared by David Morimoto, Sr. Planner JBS/DSM/cg Attachments CCCD92.19/TXTD.01C TABLE S. I SIJMMARYOF ENVIRONMENTAL FFFECYS . PROPOSED ACTION Significance Before ■ Impact Mitigation Mitigation Measures The proposed action would result in an increased m ass Additional wa i c r quality monitoring should tre conducted to emission of pollutants, as compared to existing provide better data as to when ambient conditions arc such conditions. S that DO levels could fill belu w 5,0 m&/I. When such mndltions are present, WSWPCFeffluent would bedivcrted far land application. The proposed action w+ouki increase the amount of S Because disr{owl rapacity is considered to be margi;tally treated effluent diverted to alternative disposal or storage adequate to accommodale extended perk),Js ofirrfgaJon when facilities. dis harae is prahibited, the City of Lull shall prepare an i' additional 275 acres of land for e((luent application. w TU proposed anion would result in the xmumt;iatlon of S As 4deftdrtd in the original EIR, ebebuild-up ofbeavymrta' heavy melab in the balls ofcroplands being irrigated with in the disposal area soils would tx mMgoted by eanunuiP treated effluent. and strengthening the City's existinj industrial prctrc-at�- requireme-ms, with an emphasis on zinc rcmoval. S • sirdbcw LS a L s Ow Smit B - BeaelkW SU =; S*dbc nr Unw4okbbie Sign i cancc After Mitigation LS LS t%1 j as ti = C �O S-4 c w s 5 I9_44 1 1 ss S-4 EIP Associates July 1992 NMte Slough � Water Pollution Control Facility Supplemental Final Environmental Impact Report SUPPLEMENTAL FINAL ENVIRONMENTAL IMPACT REPORT WHITE SLOUGH WATER POLLUTION CONTROL FACTL! Y EXPANSION SC11 * 87072105 Prepared For: City of Lodi,ifinAa Prepared E�(: EIP Aumiatcs 601 Montgomery St., Suitc 500 San Francisco. CA 94111 July 27. 1992 TABLEOFCONTENTS SUMMARY S.1 Introduction S.2 Project Undcr Review S.3 Summary of Environmental Impacts 5.4 Unavoidable Significant Impacts 1. INTRODUCTION 1.1 Purpose of the Supplemental EIR 1.2 Proposed Project Under Review 1.3 Environmental RCview Process 1.4 Changes to the SDEIR Resulting Fran Public Comments 2 COMMENTS AND RESPONSES 2 1 List of Commcntors on the SDEIR 2.2 Comments and Responses LIST OF FIGURES 1. Predicted Maximum Impact of BOD Loading on DO Concentration at A LIST OF TABLES S-1 Summary of Environmental Effects - Proposed Action S-2 Summary cf Environmental Effects - Alternative Action I- Original and Revised Seasonal Averages EMS S-1 S -t 5-2 S-5 2-1 2-1 2-7 5.3 S-4 2-5 SUMMARY S.1 INTRODUCTION 2is documnt is a Supplemental Final Environmental Impact Rcpo-rt (SEER) that has boon prcparrd in aceordanm with the California Environmental Quality Act (CEQA) cf 1710. The purpose cf this document is to mNiisc and supplement the original EMR for the White Slough Water y Pollution Control Facility (WSWPCF) Expansion (State Clearinghouse Numbtr 87072105). The pnparation of this SFEIR is required under CEQA because new information has bccaomc available since the ccrtilfcatian of the original EIR The new information is in regards to the relationship bctw,e,en existing roceMng water quality and the WSWFCF performance, This SFEIR will be used by California Regional Water Quality Control Burd. Central Valley Rc&h (RWQCB) in its consideration of rcrised Waste Di Summary i • Supplemental Draft EIR (SDEIR) was circulated for public review during the s`pring of 1592. The SDEIR examined the environmental effects that would result from WSWPC5 production of an effluent with ail mg/l BOD and TSS from 160ctobcr to 31 ?stay, and 20 mg/1 from ilk June through 15 October. As an alternative to the proposed action, the effluent limitationscontaincd in the original EIR could ■ be implemented. These limitations arc 10rngA BOD and TSS, year-round ("Ionil) treatment'). It should be noted that these performance standards are currently considered unrc-alistic bcc.ause the WSWPCF achieves these perforrnaut lcvch infrcq"ntly. Please refer to Chapter 2 of the April 1992 SDEIR fora more complete description of the proposrd action and its alternative, I S.3 SUMMARY OF ENVIRONMENTAL I M PACTS The pro posed action and its a l l c rn a t i,�•e were a n a lye as to their effects on htdrokly and wa t c r quality, soils. and land use. These are the only environmental elements that would be aflwcd by the proposed action. While aquatic life could be adversely of ected, water quality standards are established to protect beneficial uses, including aquatic habitat. For the rc=Mrg water. a dimKtd oxygen (DO) concentration of 5.0 mgA has ban established; thus. the project was anabzed tts to its c f leets on water quality bcca use it was ass u mcd that as long as water quality standards arc met, aquatic life would be protected also, A summary of the potential cn-virontr}crttal impacts are presented in Tabk S -I for the proposed action and in Tabk S-2 for the alternative action, and discussed below. S.3.1 PROPOSED ACTION The proposed action would result in an increase in the mass emission of BOi and TSS into the receiving water body, as co m p a red to the existing conditions: h ow$vc r, the DO icw e 6 in the Noce m ng water are expected to be maintained. Water quality monitoring would be included, and no treated effluent would be discharged when DO levels could fall below the established standards. Existing land disposal rapacity is considered marginally adequate to dispose of effluent during periods discharge would be prohibited: the City of Codi has begun preparing an additional 275 acres of land to receive treated efllucrtt to ensure adequate disposal capacity. As ronsidcmd in the original EIR, the buildup of heavy metals in the veil would occur slowly as a result of the land disposal of diluent, 91198 s•2 TABLE S• i SUMMARY OF ENVIRONMENTAL EFFECTS. PROPJSED ACTION Significance Before I mpact Mitigation Mitigation K2asures The proposal action would result in an increased m e -mission of pollutants, xs compared to exB(ing wnditions. The proposed action would incrcasc the amount of t rea t cd c M u c n t diverted to alternative d is you I k`t storage facilities. The proposal action vrould result in the a=umul.ation of h cavy m e to Ls in the sobs of cro p la nds being irrigated with treated effluent. S = slowfima LS s Lac tho SU = Soma" Uowx*b bk Additional A -a t o quality monitoring should be co nd u c t cl to provide better data as to when ambient conditions are such S that D4 k—*V s could fall below 5.0 MSA. W h c n such conditions arc present, WSWPCFti'Tlucnt would be diverted for land application. S d is persa 1 capacity ix co ns I d c r ed to be marginally adequate to 4=mmod2tt=tnd0d psriods ofirrigaiion when discharge is prohibited. the City of l.od l shall p r c pa r c an additional 275 acres of land for effluent application. S res Idc-Virkd inthc original El R, thebuild-upofhcavy metals in the. disposal arc soils would be mitiga.tcd by continuing and strengtbening the City's existing Industrial pretreatment requirements, with a n e m p h.as Is on zinc removal. Significance After Mitigation LS LS LS TABLE S-2 SUMMARY OF ENVIRONMENTAL EFFECTS, ALTERNATIVE ACTION lmpact The alternative actlon would result in a decreased mass emission of pollutants, as canpaxeci to the txisling conditions. The alternative ac6ort wauid result in the aaxlcraccd accumulation of henry metals in the roils of croplands being irrigated with treated cMuc:r% Implementation of the •ltetttative action would result in an lncrustd land area for eMucnt d`ssposai, S LS s 1,MtkWSWdftWA B s Beath w SU S0llierrat Uartrali 3 HP Significance S i g n i f i ca n Qe 13et'0rc Aftcr Mitigation Wigation Measures Mitigation B Done required or recommended. B S As i d e n t i rod in t h e original E l R, the build-up of h ca �y metals LS in the disposaI area soils would be mitIgatad by continuing and strengthening the City's cxi-siing industrial pretreatment rquircment. with an emphasis on zinc rem oa I, S The City of LOW would be r cq e 1 red t o ob i a l n approximately l.S 1,600 arcs of additional agricultural lands with which to dispose of ik greater effluent volume, Summary but with a pretreatment program. effluent dispo%al could occur for about 2Aflycar.-+xfore the buildup reached Ievch whcrc additional land dispcxal would Nx: prohibited. S'39 ALTERNATIVE ACTION The alternative action would result in a reduction in the ma s e m rss io n c E B OBD and TSS to t Nuc receiving water body. as compared to the existing conditions this vmuld have a N}c"ricial chat on water quality. However. t h e increasingly stringent e fit urn t discharge limitations would mq u it -e that substantiallymore c M u c n t be d ivc rt cd to land d 4 pose I than prescn t l occurs. Th c' a ty of (nodi wou W therefore be required to purchase additional larrdt to allow for the in=Ltcd land disposal requirements. As co ns i d c r cd in the original EIIL the buildup of heavy metals in the soil would occur slowly as a result of the land disposal cEeffluent, but with a prctre-atment program, cfOuent dapo:sal could occur for up to 500 yearn cr more before the buildup reached )Cuda whcrc addit anal land disposal would be prohibited, This is becausc most of the metals a n contained in the sl od M which would be casentialIy the 3-srne volume for each alttmstiYe, but would b,C spread &-er a Vwa land area for the alternative a-ction, SA UNAVOIDABLE SIGNIFICANT IMPACTS 5.41 PROPOSED A CTt O N There would be no unavoidable significant impacts ascoc i a t exp with the proox-cd action. The projected increase in the mas loading cf pollutants isnot—ted tormult in theviolat�on cfwatcr quality standards. however, water quality monitoring would be included. and the treated effluent would be diverted for storage and/or c ro p irrigation if r c c e M n g wa t e r quality wv rs to be threatened. No additional lands would need to be obtained to p rovid c adequate land d 4 p o l capability. SA2 ALTERNATIVE AC ON Then would be m unavoidable significant impacts am<xiatcd with the altemativy; action, Ho*trytt, additional lands would need to be obtained by t h c � ty cC Lod i to provide ad c� ua t e land diispoW capability to accommodate the increasingly stringent discharge limitations. 91198 s-5 1. INTRODUCTION 1.1 PURPOSE OF T1 E SUPPLEMENTAL EIR The purpose ofthisdocument is torcvise andsuppicment the Exwimnmental impki Report (EIR) for the White Slough Water Pollution Control Facility (WSWPCF) Expansion (State Caring?ousc Numbcr 87072105). This Supplemental Final EIR (SFEIR) has t�,--cn prcpamd in uxordantc with the California Environmental Quality Act of 19?0 (CEQA). 7rc preparation of ilhis Supplemzntal EIR is rc-quircd under CEQA Guideline Sec-tlon 15162 and 15163, bccaw4 'ndw information of substantial importance to the proJW has b>c o availabl-c" sinec the oertill�ntion cf the original EIR, The new information i in regards to the relationship between r—r+ing water quality and the WS WPCF pe rformanoo. Specil'tcal ly, the Project Description of the original EIR assu need that the expanded facility would be capable cf producing domcslic diluent having 10 milll&nms4i1cx (me) or less b i oc h e m i ca 1 oggcn demand (BOD) and total suspended so I its (TSS) mo rc than 90 pace n t of the time ('10/10 tmatmont' '. Atter sr ,cral months cf operation, the crpc7ctcd lm stnt in the quality cf the c M ue n t originally p red iet cd for the expanded facility has not been fully real lzzd, and therefore this Sup,plemmal EIR is rcquirrd to examine the cn-vironment8l Ic#'!'eas that cvuid rc-sult from the expanded WSWPCI~ capacity with less than the originally antitipatcd treatment cttcicnry. With rcgard to Final EiRs, CEQAstatcs a Final EIR should rnraist of the Draft SIR (ora rcvWm cf the Draft): comments a d r=mmcndations receivedon the Draft EIR a list cfpersom orpWn- tions and public agercics commenting on the Draft EIR; the rcaponscs tosigniF=nt environmental points r a iscd in the r vw c -,w process; and any o t he r informationd cc m -e -d r a ry by the Lzd Agency. 1.2 PROPOSED PROJECT UNDER REVIEW The project ccomidcrcd in the original EIR involved the expansion of the WSWPCIFfrom an Avcmge dry wcathcr now capacity of 6.2 million gallons per day (MGD) to 8.5 MGD (an increaso of 23 91198 1.1 1. Introduction MGD or ;i 37 percent increase: ir, capacity}, together with improvemcnts to the waitewatcr irrigation and sludge handling sN-,tcros. The prorxc sed project under consideration in this Supplcmcntal E1R is the same as that comidered in the original EIR with one exception: the original SIR assumed that the expanded WSWPCF Wctuld routinely produce an effluent quality of 10 mg/1 BOD and TSS. This Supplcmcntal E I R assumes that the WSWPCF would produce an diluent with 30 *gll BOD and TSS from 16 October to 31 May. and 20 mg11 from 1 June through 15 Octoi,cr. The project evaluated in the original EIR assessed the increased capacity of the plant and increased efficiency and reliability ofthc treatment prod on different environmcntai factors, With most of the expansion of the plant completed there has been only a marginal improvement in eftMuent quality. The RWOCB is responsible for sating and enforcing WDRs for the WSWPCF. If WDRS were adopted based on the anticipated cfltcicnc[= assumed in the original EIR (i.e.011011€0 treatment`). the projected cMucnt characteristics would be different fkat thost cxzmined in tk original EIR. For example, because the plant would not achirvc this levrcl of trcotmcnt u often as assumed in the original EIR. discharge cf the cMucnt to the r= Mng waters would be rc-du)� and i"rcascd storage capacities, 14nd disposal andfor crop irrigation would be roquired. Thc-m we no substantiyc changa to the physical cornponcnts cf the project as do senbcd in the original EIIR The project operational charattcr-i Ikz an: the ont changes that v-mw)d rc--suit from the limitations imposed by effluent standards. 1.3 ENVIRONMENTAL RmEW PROCESS The onvirori"ntal rcvic-w process began with the issuance of a Notkcc cf Prepsr6tion (NOP}, The NOP was distributed in September, 1991 to a mailing list of kcal and state gcrrc� as wcU as concerned citizens. no purpose of an NOP is to notify individuals and public 3genc-k3 that the environmental revi nv process i s ccs m m c n c i n g for a particular p m j cc t, and to solicit input for t he K*pc of analysis to be covered in the EIR. A Supplemental Draft EIR (SDEIR) was published and circculatcd for rcv�icw attd comment by the public and other inicrestcd parties, agencies, and organizations for a 45 -day rcvierri period, fmmApril 24. 1992 to June 12. 1992. Ncw that public review has t,,ecn compietcd, this Supplcmcntal Final EIR (SFEIR) has bcen prcpnrcd in response to written comments rccciti,c l during the public review period, A total of 1,m) comment letters ire recce hW on the SDEIR; these comment letters and the respomcs tothem arc presenicd in Chopter 2 of thk d((cumen t. Certification of the SFE IR will thcn 91198 1-? I Introduction he considered by the City of bull's City Council. Thc City Council will he respoisihlc for ccrtif}ting that ncc SFEIR has been co�mpieted in compliance with CEOA and that the eniironmentai cffccts were considcrcd prior to their decision to approve. rc%uc or rc)cct a specific pro)e ct alternative, 1A CI1ANGE.S TO Tl IE SDEIR RESULTING FROM T11E PUBLIC CONS11SE;NT% The focus ofthc SDEIR was to predict the impact of an increased BOD loading on the DO kvcb in the receiving waters of White Slough the impactanatysis concluded that the impactwould be less than significant because receiving water quality standards would be maintained. Howevcr, thcrc remains uncertainties in the impact prediction clue to the effects cf other outside factors on DO levels. Therefore, an expansion of water quality monitoring activities was recommendedto pravide for improved predictive capabilities, and effluent would continue to be diverted for irrigation during periods when receiving waters contained low DO levels or when the cffluent did not meet the required BOD Icvcts. The impact analysis was reevaluated for this SFEIR to account for different summer and winter periods. but this reevaluation led to a ksscr impact prediction: therefore, the impact prediction contained in the SDEIR was used bccausc it provided for a more coramativc impact assessment. The only change in impact analysis that occurred as a result of the public comrknt on the SDEIR was with regard to the adequacy c£ the City's irrigation capacity. TTfc adequacy cf this capacity has bcen changed from being considcrcd adequate in being considered math nally ddequstc. The City cf Lodi has therefore begun the process eE upgrading an additional 275 acres of agricultural land to allow for expanded effluent irrigation demands, The City is presently studying the types of facflitk:s that will be necessary to alkny for effluent irrigation on these lands. and funding for these facilities has been included in the City's capital improvement budget. 1. Draft Environmental Impact Rcport, Whitc Slough Watcr Pollutio6 Control Facility Expansion. City of Lodi, April 1988; pg 3-12 91198 1-3 2. COMMENTS AND RESPONSES 2.1 LIST OF COMNIE-NTORS ON THE SDEIR A total of two comment letters wcrc mccived on the SDEIR one from the Calitomia Repocwl Water Quality Control Board Central Valley Region, and one from the State Water Resources Control Board. Division of Qcan water Programs. Both cf these comment letters, and r sporam to them, are presented bclow. 22 COMMENTS AND RESPONSES The comment Icttcrs rccchcd on the SDEIR ace contained in this section. Thd commenu are bracketed, and arc followed by a summary of the comment and mspoom to these dommentL 91198 2-1 LETTER 1 -ATE Of CALPFOphi• CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION _ 30"1 ROUTIER ROAD $u1TE A ^ 1 SACRAk#ENTO CA 95827-3098 awONE wat 367 5800 rAx irbr J61 5686 13 Y 5 Hay 1992 Hr. David Friedland EIP Associates 601 Montgomery Street, Suite 500 San Francisco. CA 94111 DRAFT =VLEIWAL EIR, WHITE SLOUGH NATER rrKWION COUROL SM JDA" COwry 1 7 =£7£yyts3A .o•�,ne 6 I reviewed the draft Supplemental EIR, dated 22 April 1992. by EIP Associates. The EIR is being prepared to address water quality impacts from discharging increased pollutant loads (800 end Suspended Solids) into Dredger Cut, Bishop Cut, and White Slough. 1 have the following comments: 1. The EIR uses data from the Technical Report (TR) entitlid, 'Receiving �•1 Water Impacts Qf Treated baste Discharges from White Slough Water Pollution Control Facility', dated January 1992. The TR defined the sn r and winter seasons as follows: Summer: 1 April to 31 October Minter: I November to 31 lurch The EIR defined sumer to be 1 June to 15 October and winter to be 16 October to 31 May, decreasing the zi ■ r period when Lowe stringent treatment standards would be in effect. However, the data from the TR were not representative of the time of year as defined in the EIR, and cannot be considered valid for the sii r and winter time periods defined in the EIR. The Board will use the strmmmer/winter schedule as defined in the TR in renewed Waste Discharge Requirements, as they were the basis for analysis of the environmental impacts of the discharge. The final EIR should correct its summer/winter definitions to that of the TR. 2. The supplemental EIR states that the land disposal capadlty is 1.2 considered adequate to dispose of effluent durino periods when discharge would be prohibited. whereas the Ip. stated the capacity was mmfn;lly adequate. The Board is requiring the City to take the necessary steps to prepare the additional 250 acres for wastewater applications. Mitigation Measure 3.2.32 should be modified to take this into account. 3. The TR was not conclusive that receiving water impacts will not occur 1.3 from the increased BOO lording. The Board determined that the City must continue to study the impacts of the discharge on the receiving water 2-2 Hr. David Friedland during both discharge and non -discharge periods. The EIR! should recognize this. Please incorporate rry comnents into the final supplemental EIR facility expansion. PATRICIA LEARY Associate Engineer PHL;pl cc; Mr. Fran Foarkas, City of Lodi, Lodi 2-3 or the _2 - COMMENT LL-ffER I • CALIFO RMA REGIONAL WATER QUALITY CO3-4TROL KOAR1l 1-1 Commcntor notes a diffcrencc bLiween the: dates uscd to define "suritrner- Arid "winter" periods in the SDEIR and the January 1992 Technical Report (TR), and states that the RWQCB will use the summertmnter schedule as dclincd in the TR for the rcncwcd Wastc Discharge Requirements. The dates used in the SDEIR were: Summer. 01 June to I S October (4.5 months) I Winter: 16 October to 31 May (7.5 months) The dates used for the water quality analysis in the January1992 Technical Rere Wert: Summer 01 April to 31 October (7 months) Winter: 01 November to 31 March (5 months) The seven monthsused in the TR to define the 'summer' season were not chosct to dcftnc the time periodwhen the revisal WDR: would be applied; rather. they wcrc selected for two reasons. First, these dates completely bracket a time period that is "typical. for the dry and warm summer lima Cf the year (as opposed to the wct and cold "winter" period). Therefore, any conclusions regarding water qualityimpacts based on the total periodwould be expected to applyto anygivcn periodwithin the total period. Second. using these data simplified the analysis olwater quality and WSWPCF performance data. which have been entered into the computerized database by whole calendar months. For these reasoM several alternative time periods could have been selected for the analysis, including the dates used in the SDEIR. In the RWQCB's comment on the SDEIR, it was stated that the RWQCB intchdcd to change the "summer" and'Mntcr time periods in the City's revised WDR.s to the longer "summer. period used in the Technical Repxt. The WDRs ate more stringent for the dry, summer scason than Iorthe wet, winter season. Based on this stated intention, the water quality data have been reevaluated to estimate the impact of treated effluent discharge on receiving water discharge wing the summer reason defined in the SDEIR. 'ihc results of this reevaluation arc summarized in the following paragraphs. The original and revised seasonal averages for various plant operating and water quality data are presented inTable 1 below. Note that there tvcry little diffcrencc between the original and revised "winter"periods; the values arccsaentially the same within normal statistical variations. Howcm, the diffcrcnccs are greater for the revised 'summer' period. While the average flows arc similar. the average effluent BOD concentration is approximately 18 perccnt higher for the revised period. This resultant higher BOD loading would have a correspondinglygr"tcr impact on the receiving water DO at both monitoring stations R-2 and R-3. 91198 24 Sonyre» Wbkky, Buttkil A Atiodasm 1w. 91198 2.5 TABLE I ORIGINAL AND REVISED SEASONAL AVERAGES Summer Averaac S%Vkmenw Wintcr Averace SHFPF� Tcdmkal Drat Techakal Draft Report EIR Report EIR Annual Parameter (4/1 - 10/31) (6(1 - 10/15] (1111 - "U (10116 - 5/31) A!rera� Flow, msd 62 6.3 6.0 61 61 BOD, mg/L 28.2 33.4 26.3 24.6 27 BOD load, IDRd 1,514 1.314 1,357 1,.249 1,423 DO at R-2 9.1 83 9.7 9.7 9.5 DO at R-3 9.4 a9 10.8 19A 103 Sonyre» Wbkky, Buttkil A Atiodasm 1w. 91198 2.5 The magnitude of this impact at monitoring station R•'. can be seen when the ruti..%W avcragcs arc plotted on Figure I. together with the original estimate of impact as pres-cntcd in Figure 4 of the April 1992 SDEIR. In Figure 1, the original impact line represent -s the miximum measured difference in DO txtween White Slough and R-2 during the 24-hour diurnal test period on September 11, 1991. On that day, the avcragc DO difference aver the 24-hour periodwas 0.9 mgrl. and the maximum dillcrcncc was 20 m.yi. The BOD loading during the period was 7M lb/day, In plotting the rcviaed impact line on Figure 1, the a�Tragc BOD loading during the rcwts.cd time perio-d is equal to 1.814 lblday, 2jis additional BOD loading lo}vcrcd the DO at R-2 from an average of 9.1 mg4 to 83 mg/l, or an additional 0.8 mgA. Adding this to the 0.9 mg/1 average impact m=um -d during the 24-hour diurnal test results in a revisal avcragc impact of 1.7 mg/l at monitoring station R-2 7hc rcy�A maximum impact. by direct proportion. would be (1.7 mV)/(0.9 mg11) x (2,0 mg/1) = 3.8 mgil. Now that using the shorter 'summfir' time period actually results in a lower estimate of DO impact on the receiving waters than was presented in the SDEIR Therefore, for the purpcac of DO impact assessment for this Supplemental EIR. the original data will be used to provide a marc cans-ervative assessment of receiving water impact. 1-2 The commcntor notes that the SDEIR states that the land disposal capacity was considered adquatc to dispose ofcMucnt when discharge was prohibited, when -cu the TR statod that capacity was marginally adquatc. Commentor there notes that the RWQCB is requiring the City to prcparc the additional 250 acres of land for cfl7ucnt dispoul. Comment noted, Mitigation Measure 3,2..3.2 has been modifrod to rc-ad '8ecaus6 e1hpasst cagscity° is co ns idcred to be marginally adquatc to actio m macs a t c cxt c ndcd periods of i rri ga tion when discharge is prohibited. the City cf Lodi shall prcparc an additional 775 a-cr= Mand for cMucnt application.' Please note that the actual acreage purchased by the City and being prcpared for irrigation is 275 acres rather than 250 acres, The City of Lodi is presently preparing the 275 acres cf land to r=c m tmaied atliwmt when discharge is prohibited. The City is presently studying the ,spcc-ific facilities (such as pip --lints and canal.) that will be ncccssnry to supply treated diluent to thane lands for imgation. and funding has been allocated in the City's capital improvement budget, 1-3 Commentor states that the TR was trot mmlusivc in assuring that reee*ng wxtcr impacts would not occur, and states that the City must continue to study the impacts of eMucrtt discharge on receiving water quality. The EIR authors acknowledge that a degree cf uncertainty casts regarding I the prcdketian d reccMng water DO levels as a functionof cMuent B 0 D this uncertainty and the nWh A undo-rukcn to reach a satisfactory prediction is d=r-ibcd on pages 3.1 through 3-12 cf the SDEIR Besides cfRucnt BOD, a number of factors affect DO levels in the receiving water. imluding waterflow rate and tcrnperaturc, algae respiration and upstream BOD loadings. While the potential impact that would result from the expanded plant has been judged to K lees than significant hccausc the best available data predict that the receiving water DO standard cf 5.0 mg/1 would he maintained, Mitigation Mcasurc 3,23-I states that additional water quality monitoring should be conducted bccawc of the number of variables involved in actual DO levels, as described above and in Chapter 3 of the SDEIR. 91198 2-6 C4 a cn z 0 P z w U oz G S z 0 0 a a �a 0 0 a a a A a Pa LETTER 2 IMAe STATE WATER RESOURCES CONTROL BOARD DIVISION OF CLEAN WATER PROGRAMS 2014 T STREET SUITE 13() = .. P 0 BOX944212 SACRAMENTO CA 94244.2120 (916) i39-4417 = (916) 739-2300 FAX r = By Mr. David Friedland A 0 4 WZ EIP Associates 601 Montgomery Street, Suite 500 San Francisco, CA 94111 Dear Mr. Friendland: SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT REPORT (SOEIR) -- CITY OF LODI (CITY), WHITE SLOUGH WATER POLLUTION CONTROL FACILITY EXPANSION (SCHO 92042098) Thank you for the opportunity to review the above document. The State Water Resources Control Board. Division of Clean Water Programs (State Water Board), is responsible for administrating iow interest loans for wastewater treatment plants under the State Revolving Fund Loan Program (SRF) and grants under the Small Community Grants Program (SCG). If the City will be seeking one of these loans or grants, the State Water Board will be a responsible agency under CEQA, and will use the final EIR when making a decision on whether to issue the loan. If this is the case, you should provide ua with any draft environmental documents prepared for the project as soon as they become available. In addition, we would also appreciate notices of any meetings or hearings scheduled regarding the environmental aspects of the project. Specific comments follow. If the project is to involve a SRF loan, which is partially funded by EPA, additional environmental documentation and review will be required. For SRF loans, we are required to consult directly with agencies responsible for implementing federal environmental laws. Please provide us with ten (10) copies of the original EIR prepared for the White Slob h and circulated under State Clearinghouse No. 87072105 as well as ten ( 10) copies of the SDEIR so that m may initiate federal consultation. In addition, while CEQA itself does not require formal public hearings at any stage of the environmental review process, at least one hearing is required for a SRF loan project. Notices need to be discributea 30 dayys in advance. A copy of the notice and summary of the public review should be sent to the State Water Board with any loan application. _ 2-1 2-2 2. Under Impact 3.4.4-1, pages 3-15, it is stated that if this a`fternative were 2-3 selected, an additional 1.600 acres of land would be required. Has the location of these lands been identified and if so, were potential environmental impacts associated with this alternative discussed in the original EIR? z -e Mr. David Friedland -2- .UN 0 4'1992 3. Was a records search and an archaeological site survey conducted for the project? If this was not done. the City should request a records search for thepro]'ect's impact area. The following address is provided to assist you in completing this requirement. Hs. Elizabeth Greathouse, Coordinator Central California Information Center California State University, Stanislaus Turlock, CA 95380 1209) 667-3307 209) 667-3333 FAX If you require further assistance in this matter, please call me at (916) 739-4417. Sin rely, J L. Pope Environmental Services Unit cc: State Clearinghouse 1400 Tenth Street Sacramento, CA 95814 California Regional Water Quality Control Board Central Valley Region (5) 3443 Routier Road Sacramento, CA 95827-3098 2-9 1.24 COMMENT LETFER 2 - CALIFORNIA STATE WATER RESOURCES CONTROL BOARD DIVISION OF CLEAN WATER PROGRAMS -1 Commentor notes that if the City of Lodi is contemplating a loan or gran from the State Water Board. the Water Board would be a responsible agency under CEQA Comment noted: the City of Lodi is not seeking loam or grants from the State Water Board. and as such there is no reason for the Stale Board to act as a responsible agency. 2-2 Commentor states that if a loan from the State Board is involved, additional environmental review would be required. including public hearings. Comment noted: because no loan is being sought by the City of TVR the additional environmental rcvievw requirements are not applicable to the project as presently proposed, 2-3 Commentor notes that the implementation cf the alternative actionwould ne�cssitate the use of an additional 1,600 acres of land for use for effluent disposal. and questions whether the impacts associated with this alternative were addres, c in the original EIR. While the location of the 1,600 acres of land that would be needed forthis altematiy� have not been spcciF=lt identiFved, amuch larger area ofsuitable agricultural lands exist in the region-, and itwould be considered feasibleto site a project cf this magnitude. Existing agricultural lands supporting field crops, alfalfa orpasture would besubject to cropping limitations. and cropping patterns could change. Other impacts identified are potentially reduced demand for fertilizers, and decreased ability to respond quickly to changing market demands. However. these were identified as economic impacts, and the City of M i could be required to financially com pensate farmers for their losses. 2-4 Commentor questions whether an archival search and archeological field survey were conducted for the original EIR. 11 An archival cultural resources investigation was conducted for the original EIR at4 concluded that there was a potential for cultural resources to be located near the project site because the area was historically inhabited by Native American Indians. However, previous earthmoving activities have altered the ground surface in the area, and the impacts were therefore considered less than significant. No additional cultural resources investigations were conducted for the preparation of this Supplemental EIR because no additional ground disturbance was being proposed. only modified Waste Discharge Requirements. 91198 2-10