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MINUTES - 09092003 - C.18 FINAL
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111,1"..,..'.,'-'-'..''.,'......"...........................l.,'',.1.1,1..-1..1...',,'.-.I.-'."......"..."".........................'I..11'.'1,.1.,.,'-,,'..''.,......"...,"......................,...'...,1',1',,..'..'''..'.','-".,....1"" ..........................."..I..1.I,1"I.1..1',.'.,..,-','"......""..."......................,.....11'1"'-1,11,.'...-..'I,',,,.....1......"......................"....,..11l."l1,1''.'.,'..'.'.,-'.....1."...,.......................,....".11l.1"l1,.'''.'.'...- �. 4� 1. , ...-.....1.......................................,.................1............... .> — - - x �. ,..:........... �:. a �� �� � �� 1 . r � � 4 ; x Final Environmental Impact Deport forthe San Ramon Valley Recycled Water Program A joint effort of the Dublin San Ramon Services District and the East Bay Municipal Utility District State Clearinghouse No.96013028 Lead Agency. DSRSD•EBMUD Recycled Water Authority(DERWA) 7051 Dublin Boulevard Dublin, California 94568 December 1996 Contents Section Page 1 Introduction........................................................................................................................1-1 2 List of Agencies,Organizations, and Individuals Commenting onthe Draft EIR...............................................................................................................2-1 3 Comment Letters and Responses....................................................................................3-1 4 Text Revisions to the Draft EIR.......................................................................................4-1 sjcAWsFkwPP=k 0RKN131768,RYdsaAVgNAL1,c=v"T,wc SECTION 1 Introduction This Final Environmental Impact Report(Final EIR)has been prepared by the DSRSD • EBMUD Recycled Water Authority(DERWA) to respond to comments received by DERWA on the Draft Environmental Impact Report(Draft EIR)for the San Ramon Valley Recycled Water Program(State Clearinghouse No.96013028). The document has been prepared in accordance with the California Environmental Quality Act(CEQA),as amended,with DERWA acting as the Lead Agency.This document has also been prepared in accordance with DERWA's CEQA Guidelines,adopted by DERWA Resolution No. 96-3. The Draft EIR dated August 1996 was circulated from August 22 to October 21, 1996,to various Federal,State, and local agencies for their review and comment.The Draft EIR was also provided to environmental groups,to local area libraries, and was made available to members of the general public. An errata memo for the Draft EIR was issued on October 14, 1996,to address an error that occurred during binding of the EIR.Some copies of the Draft EIR contained an obsolete version of Table 1-3,the Impact/Mitigation Summary Table,this _ was corrected by issuance of the errata memo. A public workshop on the Draft EIR was held on September 11, 1996 at 7;30 p.m. at the DSRSD Administrative Offices in Dublin.Approximately 15 representatives of public agencies and members of the public were in attendance at the workshop.The DERWA Board of Directors also held a public hearing on the Draft EIR on September 30, 1996 at the San Ramon Valley Fire Protection District building in San Ramon.Approximately 10 representatives of public agencies and members of the public were in attendance at that meeting. This Final ETR contains responses to all comment letters and oral comments received on the Draft EIR Pursuant to CEQA Guidelines,this Final ETR includes a list of commenters on the Draft EIR, the comment letters and specific responses to the comments raised, and text revisions to the Draft EIR that have been made as a result of preparing the responses.This document,along with the Draft EIR issued in August 1996 and the errata memo issued in October 1996,constitute the Final EIR for the San Raman Valley Recycled Water Program. Before DERWA may approve the project,it must certify that the Final EIR adequately discloses the environmental effects of the proposed project,that the EIR has been completed in conformance with the California Environmental Quality Act(CEQA),and that the decisionlmaking body of the Lead Agency independently reviewed and considered the information contained in the EIR. sacrlUoWwpp=kWCiM131768,RW+EIMFiNAL,sectioN#.wo 1 1 SEMON 2 List of Agencies, Organizations, and Individuals Commentingon the Draft EIR Comment Letter Received From Date Written Agencies 1 Contra Costa County Community Development 8/28/86 Department 2 East Bay Regional Park District 9/12/96 3 Contra Costa County Health Services Department 10/4/96 4 City of Dublin 10/9/96 5 City of Livermore 10/9/96 _ 6 California Department of Fish and Game 10/10/96 7 California Regional Water Quality Control Board 10/10/96 8 Central Contra Costa Sanitary District 10/11/96 9 Cal/EPA 10/11/96 10 Alameda County Flood Control and Water 10/1.2/96 Conservation District--Zone 7 11 City of Pleasanton 10/14/96 12 Alameda County Water District 10/1.4/96 13 City of San Ramon 10/14/96 14 Governor's Office of Planning and Research 10/15/96 15 Alameda County Transportation Authority 10/15/96 16 Contra Costa County Public Works Department 10/16/96 17 California Department of Health Services 10/17/96 18 Town of Danville 10/21/96 Organizations 19 Crow Canyon Country Club Estates Community 10/3/96 Association,Inc. Individuals 20 Clarence L. Hoenig 9/20/96 Transcript from September 30,1996 DERWA Board of Directors 9/30/96 Public Hearing(Comment Letter#21) To assist readers of this document in finding comments and responses of particular interest to them,an EIR comment summary table is provided on the following pages. The summary table is in the same order as the list of commentors above. sjcA\JosetwPROGt44rORK\131768.RW1E]R\FiNALWO2.DOC 2.1 w �3 m c to g + 4 a ca c e a_ E E c d ni d w U a o m (D v 11> a m u 2 v w- g 0 0 ro w c� cc tl 0 u n $ ca r C $ S a� m i ai w M U TO 12 es °a cr U «. ro 06 c cu E tE> o m _ 0) LL S" O c W kij U) RS 0 L] w > _ Ca cuar ,^ ra 0 v sa Es a { CL 0 0 CL ca + 0 y 3 sn v� n. x ° 0. 0 E m m ani E a E 0- <t L w ri _ D ria CD ccc x 0 CV t'i 4 ui ip .= Cll r CV cr.F 4 * N i"S d ,6 (6 N t> 0 LLv m Eca �c w ' r,`L cl. cc UGts 0 (0j �. c m Ecc m LU E a o � �s o 20 v cin qui civ v ro o Q 3Sa - - {S C9 .0 d7 N N 911 C CL Ui d0S G> ( Gn t c i0 d Cf3 �y (6 65 Ki3 � R5 N 1l A $1 t�� id t�S 4r/) . G w LO coL' p c N cl ✓ @ 't7 G S r CG fn YJ y 'Yj .L1 ,�. 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'OR o Ilkr N ilk � a G? � � O SECTION 3 Comment Letters and Responses Comment letters and specific responses to the comments are provided in this section. Individual responses have been prepared for each distinguishable comment within a written letter or statement.Individual comments are identified by a number in the right .margin of the comment letter; the responses to comments immediately follow the comment document.The transcript from the public hearing held on September 30, 1996 is included at the end of this section.One member of the public spoke at the hearing;responses are provided to those comments. S rAQMElWPPtoclYV{0RM131768RW\E-Ifhfw \003.Doc 3 1 Community ContraCOMMENT LETTER #1Development Cost Department C�fl�� Countv Administration Building 651 Pine Street 4th Floor, North Wing t Martinez, California 94553.0095 - �r Phone; a . (510) 335-1236 T August 28, 1996 D.SRSD/EBMUD Recycled Water Authority 7051 Dublin Blvd. Dublin, CA 94568 Gentlemen: Thank you for the opportunity to review the Draft ETR on the San Ramon Valley Water Programs. We find the Draft EIR adequate to approve the project at a programmatic level. This County has long supporter)the desire and need for reclaimed water. The DEIR well reflects County General and Specific Plan policies dealing with this subject. In terms of customer service options (Figures 2-2 through 2-7), establishing a program for the broadest potential service area would appear the most logical. Obviously, only the areas currently planned and approved for growth should be included in initial phrases of such a program. However, it should be capable of expansion should the Tassajara Valley or West Dublin projects get local approval. Since Dougherty Valley is an approved project which is starting to be constructed, it needs to be)included within the selected service option;as the EIR points out this County's Specific Pian mandates such a program, if one is available. As a General Comment, many of the impacts and the mitigation measures to help limit environmental impacts are things that are of great concern and importance to the city or county having jurisdiction. For example, the visual impacts of water tanks, the regulation of pipelines crossing or within read rights-of-way, or vegetation management programs within Open Space areas are issues of intense local concern. I would request that the DERWA Beard mandate that all such mitigation measures be coordinated with the local agency prior to finalizing facilities. That could be done as either a master policy or by reformatting the individual mitigation measures in the DEIR. The DEIR should also note the need to comply with Sections 65401 and 65402 of the Government Code on referrals to local governments for the acquisition of lands and building facilities such as water tanks. D RSD/EBMUD 3-2 August 28, 1996 Page 2 If this cooperative approach is taken, the site specifics of the facilities location can readily be resolved. Sincerely yours, r James W. Cutler Assistant Director of Comprehensive Planning JWCfjb 1:jbiSg\dsrwbmd,jwc 3-3 SECTION 3 commEur LETTERS ANIS nspowes Response to Comment letter No. 1—Contra Costa County Community Development Department 1. The comment is acknowledged.It should be noted,however,that the Draft EIR provides both programmatic and project level review for DERWA Program components and customer service options. Please refer to Table 2-7 on page 2-51 of the Draft EIR for a description of the CEQA level of review provided for Program components. 2. The comment is acknowledged. As discussed in the Draft EIR,the DERWA Facilities Plan and EIR were purposefully written to provide DERWA the broadest flexibility in evaluating customer service options and Program components,and in ultimately selecting a preferred option and recycled water system configuration. Customer Service Option 1 is the only option that would supply recycled water to areas not currently planned and approved for growth.Service to Dougherty Valley is included in Customer Service Options 1 and 2.The DERWA Board will consider the information contained in the Draft EIR and the Facilities Plan,as well as comments received from agencies and the public,when it makes its decision as to which customer service option to implement. 3. The comment is acknowledged. As noted in the comment,mitigation measures are recommended for the Program to address identified environmental impacts. Pursuant to CEQA,DERMA will be preparing and adopting a mitigation monitoring program for the project. All mitigation measures identified in the DERWA EIR as applying to the approved project will be implemented as part of the project. With regard to visual impacts of storage tanks,the Draft EIR provides programmatic CEQA review for those facilities;additional project-level review of storage tanks will be performed when specific tank sites are determined.With regard to pipeline crossings or installations in roadway rights-of-way,DERWA will endeavor to comply with applicable construction and roadway improvement requirements of the local jurisdiction within which the facilities are located. 4. The comment is acknowledged. As noted in response to comment#3 above, DERWA will adopt a mitigation monitoring plan for the Program;the mitigation monitoring plan will be made available to local agencies for review after it is adopted.DERWA will endeavor to format the mitigation monitoring plan to identify the need to coordinate with local agencies. 5. The comment is acknowledged. The first paragraph on page 2-49 of the Draft EIR states that DERWA will be required to obtain appropriate permits associated with construction activities. Although not explicitly stated,compliance with all applicable Government Code sections regarding land acquisition and references to planning agencies is implied in this paragraph. b. The comment is acknowledged.DERWA intends to cooperate fully with local jurisdictions to successfully resolve facility siting issues. sjMJo86 wnoc\WORM131768AME1MMAL1t1t3 MO 3-4 10/Jt1l8K t39w1tSr:�i. 51E} btg 118U llL6L1t` SCK COMMENT LETTER #2 EGIONAL PARKS EAST SAY REGI— tNAL PARK DISTRICT E�=�:_;4iP4wi3eX September 12, :996 om;;•as Steel, w,ofw•� •,e�t Mr. Bruce Webb 0#14 fi DERWA Steering Committee ,r .w=,.. 7051 Dub •;:,-:•. .w<<:�� lin Boulevard Dublin, CA 94568 RE: Tran Horse Frail - EM San Ramon Valley Recycled Water Program Dear Mr. Webb: The E st Bay Regional Part:District has received and reviewed the subject EIR. The document dues define and address the District's concerns related to the potental impacts to the District's facility, the Tran Dorsa Regional Trail (Mitigation Measure 3.8.2). The District supports incorporation of that mitigation measure in the project. Thank you for the opportunity to review and comment on this document. Please»forward a copy of the Final EIR.to the District after it is acted on. Very truly yours, W Linda J.P. Park Planner TI 3--•5 is` t".','+ it1 'i'tt?►Tri?»•."`..iii` :i' `n',=ii=«?:i1:Ci SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No.2—East Bay Regional Parks District 1. The comment is acknowledged. 2. A copy of the Final EIR will be distributed to all agencies which submitted comments on the Draft EIR at least 10 days prior to the DERWA Board of Directors taking action on the Final EIR. sicAUmE\wrQockWORM131758.RWtEtR\F!NAL=3.DW 3'6 COMMENT LETTER #3 C » r . health Services Department ENVIRONMENTAL HEALTH 011lS 1UN Costa1111 Word Street Martinez,Callfofta 94553-1352County (510)646-2521 October 4, 19996 Bruce W. Webb, Engineering Planner DERWA 7051 Dublin Blvd. Dublin, CA 94568 RE: Draft Environmental Impact Report, San Ramon Valley Recycled Water Program Project Thank you for the opportunity to review and comment on the above referenced Draft Environmental Impact Report by DSRSD/EBMUD Recycled Water Authority (DERWA) to utilize highly treated wastewater for landscape irrigation. Following is a list of comments/concerns with the proposed project. 1. The DEIR addresses the requirement to identify and destroy public and private wells used for domestic -purposes, and create an exclusion zone. Private agricultural wells should also be included in this category, or the injected water should meet title 22 standards for potable water. 1 Private agricultural wells, though not tied into domestic lines, may be used for drinking from a hose or filling water jugs, filing a swimming pool, washing pets, washing cars, etc. The consumption or heavy contact with recycled water which may be pulled from these wells can not be monitored. 2. DERWA should require that only drip irrigation methods be utilized for landscaped irrigation. Recycled ,' water should not be flood or spray irrigated. 3. DERWA should provide an active and comprehensive educational program to schools, businesses, and residences to alert of possible health hazards, cross connection prevention, and the proper manner to use the recycled water. 4. Impact 3.1-3 discusses rising aquifer levels in terms of structural degradation and unintended recharges of shallow groundwater aquifers. It should also be noted that if the aquifer is raised to a point close to the ground surface it can come into contact with deleterious material or chemicals leading to further degradation of the aquifer. This includes nitrates and perhaps petroleum based chemicals. If you have questions please contact me at (510) 646-4.234, weekdays between 7:30 a.m. and 9:00 a.m. Sincerely, "perry L. Schraidtbauer, R.E.H.S. Senior Environmental Health Specialist AMA (10/= 3-7 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment letter No. 3—Contra Costa County Health Services Department 1. The comment is acknowledged.Title 22 does not require the closure of identified agricultural wells in the ASR zone of influence because it is assumed that these wells are used for non-potable purposes. 2. As discussed in Section 3.10 of the Draft FIR(Human Health and Safety),the recycled water provided from the DSRSD treatment plant will comply with,the stringent water quality requirements for unrestricted use under Title 22.Title 22 allows for both flood and spray irrigation,as well as drip irrigation methods. For any irrigation method,Title 22 prescribes the system configuration that must be installed to meet Title 22 requirements for the protection of public health.DERWA will comply with these requirements such that public health and safety impacts will not occur,regardless of the irrigation method chosen. It is anticipated that standard protection features for the project will limit irrigation to those times when Duman contact is limited or non- existent.In addition,special signage will be posted in areas where recycled water is used,in accordance with Title 22. 3. As noted in Mitigation Measure 3.3.2,the implementation of best irrigation management practices(BMPs)will serve to mitigate potential salinity impacts associated with use of recycled water on vegetation. BMPs will also serve to mitigate public health related concerns. A BMP publication for customer use will be prepared and public outreach programs conducted to educate and inform the public and customers about recycled water use. 4. The comrnentor notes that rising aquifer levels could bring groundwater in contact with contaminated soil,which could further degrade the aquifer.The comment is acknowledged. All injection well sites,including zones of effect,will be assessed for the presence of hazardous materials. Although none is known to be of concern., any identified hazard will be monitored for impacts from the project.By design,the project directs injected water to deep formations which are overlain by thick clay sediments;as a result,pressures are expected to increase in the injection zone near the injection well, but not near the ground surface.If shallow water levels unexpectedly rise in response to injection,and thus threaten to degrade any other aquifer sources by mobilizing hazardous constituents,corrective action will be taken by DERWA.The corrective action may include redirecting injected water to other formations or to other injection well sites. In addition,the injection project has been designed to prevent the occurrence of a shallow groundwater rise.Monitoring and field testing will occur at each well site as injection starts up,and each injection well will be designed on a case by case basis to prevent this impact from occurring.These precautions will be adequate to ensure that groundwater does not come in contact with contaminated soil as a result of this project. Please also see response to comment#22 in Comment Letter#10 from Zone 7.Zone 7 states that the mitigation measures identified to prevent impacts from shallow groundwater rise "appear reasonable". sicAWosslwpRoMORK1131788.RWT3RI,FtNul003.mc 3.8 ` COMMENT LETTER #4 CITY OF DUBLIN PO. Box 2340. Dublin. California 94568 City Offices. 100 Civic Piaza. Dublin, California 54568 October 9, 1996 Bruce Webb, DERWA Steering Committee 7051 Dublin Boulevard Dublin,CA 94568 RE: Draft Environmental Impact Report-San Ramon Valley Recycled Water Program Dear Bruce: ;Ibank you for giving us the opportunity to comment on the San Ramon Valley Recycled Water Program DraftEnvironmental Impact Report(DEIR). Overall,we support DSRSD-EBMUD Recycled Water Authority's(DERWA's)San Ramon Valley Recycled Water Program. As the DEIR indicates,the project study area includes all of the DSRSD service area,the southeastern portion of the EBMUD water service area,and areas outside,but adjacent to,each District's service area where development is either approved, or where it is presently under planning and review,and where recycled water could be utilized for irrigation purposes. Project facilities would be located in the cities of Dublin, San Ramon,and part of the Town of Danville and the city of Pleasanton. '1 The objective of this recycled water supply project is to maximize the amount of recycled water delivered in the study area to offset potable irrigation water demand,while recovering the costs. We are in support of the San Ramon Valley Recycled Water Program because of its long term environmental benefits. The region would benefit enviiroamentally from such a program because it reduces the withdrawal of potable water from fresh water resources for landscape irrigation and other uses best served by recycled water. Without this project,The DSRSD plant would continue to discharge treated wastewater to the Saul Francisco Hay. Furthermore,as specified in the DEIR on p.2-56,the Eaistern Dublin Specific Plan adopted in May of 1993 and approved by the voters in November of 1993,supports and requires the use of a recycled water distribution system in Eastern Dublin,including the use of recycled water for landscape irrigation. Ile DEIR includes an analysis of customer service options covering currently existing customers and potential customer service areas. We support the Customer Service Option l because it gists of a distribution system that would serve recycled water customers within Dublin,Eastern Dublin,Camp Parks, Dublin Housing Authority and Western Dublin,and within other adjacent cities and unincorporated areas. We would also like to make certain that the following mitigation measures of the Eastern Dublin Specific Plan Envuournmrtal.Impact Report would also be implemented through implementation of the San Ramon Valley Recycled Wetter Program: MM 3.5{12.11-Require recycled water use for landscape irrigation in accordance with DSRSD's �J Reecycled Water Policy. Administration (510)933.6650 • City Council (510)833-6695 - Finance (510)833-6640 - 8uitding inspection (510)833.6620 Code Enforcement (510)833.6620 - Engineering (510)833.6630 • Parks&Community Service (510)833-6645 Police (5 10)833-6670 - Public Works (510)933-6630 • Planning (510)8336610 3-9 MM 3.5113.0-Rqcw1W Water Distribution System. Require development within the Project (Eastern Dublin)to fiord a recycled water distribution system computer model reflecting the proposed Specific Plan land uses and verify the conceptual backbone recycled water distribution system presented on Figure 3.5-C(see attached) MM 3.5114.0-Wastewater Recycling and Reuse. Support the efforts of the Tri-Valley Water Recycling Task Force Study, DSRSD and Zone 7 to encourage wastewater recycling and reuse for Iandscape irrigation within the Eastern Dublin Specific Plan area. MM 3.5116.0-Eae y for DisRgsal DzoAgh ftvcW Water System.. The recycled water treatment system should be planned,designed and constructed for energy efficiency in operation. This would include use of energy efficient treatment systems,optimal use of storage facilities and pumping at off-peak hours. MM 3.5120.0-Require construction of the recycled water distribution system be in accordance with all applicable regulations of State Department of Health Services(DHS)and San.Francisco Ray Regional Water Quality Control Board(SFRWQQCB). i MM 3.5121.0-Re M&lod Water tore Failure. Require reservoir construction to meet all applicable standards of DSRSD and appropriate health agencies. Include adequate sods/geotechnical investigation of the proposed site to determine potential impacts to site from ( `� landslides and earthquakes. Reservoir must be designed to meet all current seismic codes. The -J reservoir site must be designed to provide for adequate site drainage. MM 3.5122.0-Require the proposed recycled water pump stations to meet all the applicable standards of DSRSD. MM 3.5123.0-Recycled water projects shall be coordinated with any salt mitigation requirements ofZone 7. Present Zone 7 study results,however,indicate the area may be in a fringe groundwater basin and recycled water would not require deminerali2ation. MM 3.5!27.0-Water&Ucft. Require the following as conditions of project approval in Eastern Dublin. - Implementation ion of DSRSD and Zone 7 findings and recommendations on uses of recycled water to amt existing water supplies. - Work with DSRSD to explore use of recycled water in Eastern Dublin through potential fiction of a recycled water distribution system. Construction of such a recycled water sysem will require approval of the use of recycled water for landscape irrigation by DSRSD, Zane 7 and the San Francisco Bay Regional Water Quality Control Board. We also highly recommend implementing the DEM!s measures mitigating all project construction impacts (i.e.noise and tcaffe:lcirculation impacts),and implementing measures mitigating all potentially significant, or significant impacts relative to aesthetics,human health and safety,noise,traffic and circulation,geology and seismicity,surdace water and drairtage,and groundwater. 2 3-10 L What reservoir capacity the City of Dublin needs to provide if the City would like to establish zero discharge for Eastern Dublin development. L 2. What reservoir capacity is required for western Dublin if the City of Dublin would like to create zero discharge capacity for western Dublin project. f 3. What is the approximate minimum size of the landscaping lot that can be used for recycled water, if you have any questions,please feel free to contact Carol Cirelli, Senior Planner at 833-6610,or for �:•�' traffickirculation related continents, Mehran Sepehri, Senior Civil Engineer,at 833-6630. S y� e, ! Eddie Pea , r. Community Development Director attachment cc: Carol Cirelli, Senior Planner Nktran Sepehri, Senior Civil.Engineer g: �rcltlaradeir 3 3-11 co Ul Z o ' Lu vccn ��`~`'lam\..�•�, .. i 1 � �`��1 f � 1 r ;�.o„_„ ,� i t .` •`} It , •..: it ' r ,�� � � iii, t.+ �„ �,f c• � .. _... ZL .• w • r` 3-12 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 4--City of Dublin 1. The comment is acknowledged.The DERWA project does not represent disposal capacity and will not replace nor increase year-round wastewater treatment plant disposal to San Francisco Bay. 2. The comment is acknowledged. 3. The comment is acknowledged. A text revision to page 2-56 of the Draft EIR,where consistency of the project with the Eastern Dublin Specific Plan is discussed,has been made to identify the Specific Plan's EIR mitigation measures whose implementation could be addressed by the San Ramon Valley Recycled Water Program. 4. The comment is acknowledged.Pursuant to CEQA,DERWA will be preparing and adopting a mitigation monitoring program for the project. All mitigation measures identified in the DERWA EIR as applying to the approved project will be implemented as part of the project. 5. Comments#5 and#6 are worded vaguely,but the questions are interpreted to generally be as follows- What size recycled water reservoirs would be needed if Eastern Dublin or Western Dublin were to be zero discharge(i.e.,LAVWMA or a LAVWMA-like project) areas? Prior analysis completed by DSRSD on other studies(Plan of Services Investigation for Tassajara Valley Property Owners Association,December 1994)indicates that approximately 0.10 acre feet of long-term storage that can be used under all conditions (24 hours/day,7 days/week)must be provided per"dwelling unit equivalent" (DUE) being provided with wastewater service.Furthermore,irrigable area equal to 9 acres must be provided per 100 DUEs to allow the stored wastewater to be used during the summer,and storm storage of approximately 67,000 gallons/DUE must also be provided to handle peak wet weather flows.The results of that study are sufficiently applicable to the questions posed in comments#5 and#6.Thus,given the need for approximately 18,500 DUE of disposal capacity to serve the Eastern Dublin Specific Plan,approximately 1,850 acre feet of long-terra storage is required together with approximately 1,7010 acres of irrigable area and approximately 12 mg of storm storage. The largest DERWA Customer Service Option provides 11.9 million gallons (36 acre feet)of reliable storage that could be used in the winter for disposal;the DERWA project provides 0 mg of storm storage. The 1992 Western Dublin Specific Plan,which called for 3,200 dwelling units,would require an additional 320 acre feet of storage.That 1992 plan was overturned by the voters,however,and there is currently no approved plan for the entire Western Dublin area. It is important to reiterate,however,that the DERWA Program is not a wastewater disposal project. 6. See response to comment#5 above. 7. Under the Title 22 regulations,there is no minimum lot size or landscaped area required .for application of recycled water. Although facility planning efforts focused on sites with potential demands of 2 acre feet/year or more, smaller demands could also be served. SJCAVOS WPHOC�WORK113176$.RMEIR\F#4AL1003.DOC 3.13 COMMENT LETTER #5 Ilk. CiTYoFLivERmoRE countTy SiWA 1s�s' Administration Budding 1983&L(vw"r.Aranaa Lira.....CA 94660.4849 (610)373.5100 October 9, 1995 Fo.(610)3734136 Mayor I cnaasii (6101373.8144 City humavor (610)3736140 City Atasrn.y Bert Michalczyk, Authority Manager (810)31"14() DSRSD-EBMLTD Recycled Water Authority(DERWA) Paz(610137"126 7051 Dublin Boulevard cltycl rit Dublin, CA 94568 (620)373.8130 riann.t•D.pa"msat Dear Mr.Michalczyk: (810)373ais0 Thank you for the opportunity to comment on the Draft Environmental Impact Report 46E911rt rsss. 1 .11AWAY .at San Ramon Valley Recycled Water Program. (510)3734450 1 (610)373.6414 The City encourages DERWA to consider implementing only customer service options >Oary 4 or 5A. We do not have concerns with either option 4 or 5A since neither has an luaus uvon"m Ars..ar appreciable effect on the main groundwater basin. We do have concerns with all of �•:�'' (610)3734800 the other options. Psr.oaa.d (610)373.3110 Fat(6193f363Once again,thank you for the opportunityto comment on your project. ph-aing Sincerely, (810)3734M PW1so D.parb"at 1110 8.UY"N lft Avanim (6101 37149W Fst(510)371-4980 Jerry peeler Pa6u.lrarim City Manager (SM 373.31170 JP/WAA:dm 3-14 SECTION 3 COMMENT LITTERS AND RESPONSES Response to Comment letter No. 5--City of Livermore 1. The comment is acknowledged.The DERIATA Board of Directors will consider the comment in deciding which customer service option to implement. JcAU08ElwaAoc\WORM131788.RN EIRFiaAzuivoc 3-15 C AYE or`,AUFORNIA.THE RESOURCES AGENCY COMMENT LETT4R #6 DEPAR'T'M97 OF FISH A45 GAME POST OFFICE BOX 47 YOUMMLLE,CALIFORNIA 945W (707)"4-VM i► October 10, 1996 Mr. Bruce Webb Dublin San Ramon Services District East Say Municipal Utilities District DERWA Recycled Water Authority 705? Dublin Boulevard Dublin, California 94568 Dear Mr. Webb. Draft Environmental Impact Report (DEIR) San Ramon Valley Recycled Water Program SCH No. -9601.3028 Department of Fish and Came personnel have reviewed the � above referenced document which proposes construction of recycled waste water distribution and storage facilities in the Contra Costa and Alameda counties in the cities of Dublin, San Ramon, Pleasanton and part of the Town of Danville. The project is being proposed and constructed by Dublin-East Bay Recycled Water Authority (DERWA) , a Joint Powers Authority formed by the Dublin San Ramon Services District and East Bay Municipal Utilities District. The project generally consists of construction and on-going (D operation of transmission pipelines, operational water storage tanks, pump stations, seasonal storage facilities, water supply facilities and distribution lines. The DEIR states that transmission and distribution pipelines will, with few exceptions, be confined to road and highway right-of-ways and be constructed in previously disturbed areas. The following comments have been categorized as Wetland, Wildlife, Vegetation comments and Water Quality comments and are based on review of the DEIR. Wetiand, Wildlife and Vegetation The Department is concerned over the potential growth- inducing impacts associated with replacing potable surface and ground water use in city parks, commercial building landscaping, 2 golf course and other facilities with recycled waste water. This would provide a significant potable water source in an area where 3-16 Mr. Bruce Webb October 10, 1996 Rage Two potable water availability is a factor which limits urban development . The DEIR should discuss and evaluate the impacts of increased urban development on biological resources within the proposed services area. The DEIR states that water storage facilities will be located in several locations which currently support ruderal vegetation or annual grassland habitat. These vegetative communities may support special-status plant and wildlife species . The DEIR proposes to mitigate temporary and permanent impacts to these species by evaluating potentially disturbed areas to determine the need for focused surveys, conducting surveys if these species are detected and mitigating appropriately. The DEIR should specify the methods which will be employed to evaluate habitat for the potential for special-status { (� species occurrence. While the potential for presence of a few species can be reliably determined by evaluating the presence and condition of key physical and biological features of a site, this method is inadequate for reliably determining presence of most species. In addition, the DEIR should require consultation with the Department to determine appropriate survey timing, scope and duration as survey methods vary with each species. Finally, the DEIR should identify and require, as performance standards, mitigation measures should surveys reveal the presence of a sensitive species and avoidance is not possible. The DEIR correctly identifies the presence of California red-legged frog (Rana aurora drayton1l) and Ban Joaquin kit fox (V'ulpes macrons mutica) with the project area. The DEIR should require consultation with the Ti. S. Fish and Wildlife Service (USFWS) if any project actions, including pipeline crossings in streams or creeks, directly or indirectly impact these species. Consultation and incidental take authorization is required under the Federal Endangered Species Act (FESA.) . The DEIR discusses crossing of several creeks within the project area by distribution and transmission pipelines. The DEIR 'should discuss proposed crossing methods and evaluate these methods based on minimizing impacts to wildlife and wetland vegetation. The DEIR should also mate the requirement for obtaining a Fish and Game Code Section 1603 streambed alteration agreement for each crossing. Waw (qua 'ty We are supportive of wastewater reclamation projects which not only reduce the volume of treated wastewaters discharged to local creeks, or the Bay, but also augment or supplant existing 3-17 Mr. Bruce Webb October 10, 1996 Page Three sources of freshwater, leaving natural flows to support fish and wildlife resources . However, the effects of salt-loading on 6 riparian systems is just as important as on landscaping and water supply issues addressed in the DEIR. The discussion of existing surface water quality within the ! study area on page. 3-19 is given inadequate attention. if insufficient data currently exists, additional data should have 7 been collected to aid in impact analysis . The implication of such a brief comment is that surface waters, since not used as a domestic water supply, are of little significance to this project . Such is not the case. The use of reclaimed wastewater alone, or in combination with potable waters for irrigation from project development, are predicted to have a significant effect upon the salt concentrations of near-surface groundwater and creek flows. Impact 3 .2 . 7 (p. 3-24) Appendix D discusses the range of salt loadings potentially moving into the streams. The effects of these changes on sensitive riparian and aquatic habitat must be addressed. The summary of Total Dissolved Solids (TDS) impacts to Creeks on page 3-28 must discuss more than effects to downstream water users, but also .the potential effects to fish, wildlife and their habitat. The effect of decreased groundwater flow to study area creeks and its passible effects on concentrations of salts in local streams should be discussed, even though it is uncertain if pumping will actually occur. Page 3-30, Mitigation 3 . 2.7 - Increased TDS in Study Area Creeks. The statement that "DERWA will mitigate for any significant impacts of increased TDS in creek that may affect the potable water supplies of ACWD. . . " ignores the biological effect 1A to aquatic residents of increases in salt, and defers discussion of means to mitigate effects until a problem is identified. This is unacceptable. Page 3-34, 3 .3 .2 Impacts - This discussion must also include an analysis of potential impacts of increases in salts within the 11 root zones of riparian vegetation, along and within the channels of study area creeks, and its effect on wildlife habitat value. 3-18 Mr. Bruce Webb October 19, 1996 Page Four If you have any questions regarding our comments, please contact Kevin Hunting, Environmental Specialist, at (707) 944--5570 ; or Carl Wilcox, Environmental. Services Supervisor, at (727) 944-5525 . Sincerely, �d Brian Hunter Regional Manager Region 3 CC: Shiela Larson U. S . Fish and Wildlife Service 3-19 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 6—California Department of Fish and Game 1. The comment is acknowledged. 2. The comment is acknowledged.Growth-inducing effects of the project on biological and other resources have been evaluated in Section 4.1 of the Draft EIR. As discussed on page 4-3 of the Draft EIR,the"freeing up"of potable water supply by implementing a water recycling project does not mean that the total water supply will be increased,or that the available water will necessarily be used for urban growth and development. The available water may be"returned"back to the environment due to increasing environmental demands,or it may provide for improved reliability in the water supply systems of each of DERWA's member districts. In essence,the recycled water will be used to serve some current and future demands which would otherwise have to be met from the present potable supply. The substitution of recycled water means that some potable water will be "freed up"for use for existing and future customers. Both EBMUD and DSRSD have accounted for this availability in existing potable water supplies in various water supply planning documents. It is not possible to specifically identify where the "freed up" potable water would be used,but it is important to remember that it has already been accounted for and does not represent an increase in the total water supply. If recycled or potable water is made available for new developments,it is because those developments will have already been evaluated through local planning and CEQA processes for their environmental implications.The approach used for this evaluation in the EIR is consistent with CEQA. 3. The methods to be employed to evaluate habitat for special status species occurrence will be determined in consultation and coordination with the appropriate resource agencies,including CDEG.Text revisions to Mitigations 3.9.1 and 3.9.2 have been made to clarify this point.Mitigation 3.9.1 does state that mitigation measures to reduce biological impacts to less than significant levels will be developed in consultation with resource agencies. In addition,storage tanks have been evaluated at a programmatic level in the EIR. Subsequent project-level environmental review will be performed for storage tank facilities. 4. The comment is acknowledged.Text revisions to Mitigations 3.9.1 and 3.9.2 have been made to specifically identify the U.S.Fish and Wildlife Service as an agency to be consulted if species protected under the Federal Endangered Species Act would be affected by project activities. 5. Crossing methods of creeks within the project area have not yet been determined,but may consist of bore-and-jack or cut-and-cover methods. Mitigation 3.9.4 on page 3-121 of the Draft EIR identifies that appropriate permits and mitigation plans will be required for these crossings.The Draft EIR does identify the requirement for Streambed Alteration Agreements for creek crossings(see third paragraph on page 3-118 of Draft EIR). 6. The comment is acknowledged.Potential effects of salt loading on riparian systems are acknowledged as a concern and have been addressed in the EIR. Discharge of groundwater to surface water was analyzed to assess any potential impact on riparian sioM bs&wpRoclWORM13476S.RW1EIR\rim Lt 003.mc 3.20 SECTION 3 COMMENT LETTERS AND RESPONSES communities.Table 3-4 and Appendix D in the Draft E1R,summarize the expected range of impact on surface water quality in study area creeps. 7. Surface water quality data for the streams potentially affected by the project are limited, but sufficient data are available to estimate the expected level of impact that may occur to these resources.Using the Draft EIR assumption that existing surface waters are 500 mg/1 or less in total dissolved solids(TDS), the range of increase in TDS is projected to be from 0 to 34 percent over buildout if potable supplies were used for irrigation. The projected increase in terms of TDS in the study area creeks would rise from the estimated 500 mg/1 to a maximum of 779 mg/1 in Tassajara Creek.Other study area creeks would experience increases considerably less than the projected upper limit. Any effect on riparian vegetation of additional salt loading of this magnitude would be expected to be negligible.Riparian plant communities established along stream courses of the inner coast range may be tolerant of increased TDS levels due to natural variation in water availability and quality. Generally,TDS levels in the small tributaries are highest in late summer and fall and decline during winter and spring due to increased surface flow from storm runoff. It would be expected that the projected TDS increase would be within the range of normal variation. 8. The approximate projected TDS increases in study area creeks attributable to the use of recycled water range from 0 to 165 mg/l.This represents further increase to in`stream. TDS concentrations after buildout with potable water use and after full implementation of the Recycled Water Program of 500 to 779 mg/l. Compared to current estimated TDS concentrations of approximately 500 mg/l,the various project options are not expected to affect fish and wildlife nor their habitat.Generally,biotic effects of salinity on freshwater organisms has been noted when the salinity is in the range of 5,000-9,000 mg/l TDS(CH2M HILL,1996,see reference to table on the next page).Small aquatic invertebrates(e.g.,Daphnia magna)may be more sensitive at lower concentrations,but studies of other freshwater invertebrates,fish,and waterfowl do not show effects until the concentrations exceed about 8,000 mg/l TDS.During certain periods,TDS concentrations in Alameda Creek can exceed 700 mg/1 due to imported water delivered through the South bay Aqueduct(USGS 1990, 1994). Adverse impacts on freshwater habitats due to increased salinity in this range have not been reported.A summary of salinity effects(in parts per thousand or 1000 mg/1)is presented in the table on the next page. s;UAJoSEtwPRoaWOFiK\131'MB,RiMEiRlFiNAL\003.coc 3-21 SECTION 3 COMMENT LETTERS AND RESPONSES Summary of Comprehensive Biotic Effects Effect Level(ppt) Level of Toxicity Medium No Effect Concern Threshold Reference Water -- -- -- _. Plants Freshwater marsh grass -- -. 10- 12 1 - Invertebrates Amphipods -- -- 22 2 Daphnia magna -- 0.3-6 6- 10 2,3,4 Hyalella azteca -- 8.0- 11 16. 19.5 5 Chironomus utahensis -- 5.5-8.9 13.3 5 Heterocypris spp. - 9.0- 11 13- 18.6 5 Fish Fathead minnow -- -= 6- 10 2,4 Striped bass -- .- 14-34 2,3 Birds Mottled duck -- 9- 18 -- 6 Mallard 9- 12 10- 15 -- 7, 8 Black duck -- -- 20 8 Peking duck -- 20 -- 7 Source: CH2M HILL,1996.NIWQP Interpretative Guidelines-Salinity.Prepared for U.S.Fish and Wildlife Service.National Irrigation Water Quality Program.April 1996. 9. Impact 3.2.9 on page 3-29 of the Draft EIR discusses the potential effects of decreased groundwater flow to study area creeks if groundwater pumping is implemented as part of the Program.However,because it is unknown at this time if groundwater pumping, without prior injection of recycled water,will actually be implemented, this impact is evaluated at a programmatic level in the EIR.If groundwater pumping is determined to be necessary for the Program,additional project-level environmental review,including consultation with CDFG if necessary,will be performed. 10. Increased TDS in study area creeks is not expected to cause significant adverse impacts to aquatic life or riparian vegetation established along these watercourses. Changes in salinity,if measurable,would occur gradually over a number of years.The incremental changes would not be expected to be large enough during any year to adversely impact resident species.Incremental increases are expected to be within the tolerance range of common aquatic organisms.DERWA will participate in the development of a salt management plan in cooperation with the Regional Water Quality Control Board,Zone 7,Alameda County Water District,and other agencies.This plan will identify appropriate mitigation measures for DERWA's pro rata share of salt loading impacts to study area creeks. DERWA will perform selected monitoring of study area creeks to detect changes in water quality.Monitoring methods to detect changes in water quality that could potentially impact biological resources would be submitted to CDFG for review and comment. 11. Generally,relatively minor increases in TDS within the range projected under the various customer service options would not be expected to adversely impact established aide UWEE WPRMkWOM131766.RMIFhF;NAi10It3.mc 3-22 SECTION 3 COMMENT LETTERS AND RESPONSES riparian vegetation of the inner coast ranges. Riparian woodlands along streams in the Central Malley have experienced substantial increases in TDS levels due to agricultural return flows entering streams. Loss or degradation of riparian systems is usually associated with much higher levels of salt leading in freshwater systems,often in association with reduced stream flow. Detrimental effects are generally observed when TDS levels exceed 2,000 mg/1 or higher.Changes of this magnitude are not predicted for the customer service options considered in the Draft EIR.Increasing TDS levels by 165 mg/l over projected TDS concentrations at buildout with use of potable water is the estimated maximum project condition,for the "worst case" conditions and the largest customer service option(Customer Service{option#1). An increase over ambient water quality conditions would not be expected to adversely impact riparian vegetation, sacAUMiAwPRrc1WOM131768.Rw1ERF fiNAL'003.noe 3.23 BTATE OF CAUFORN1A—CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY COMMENT LETTER '7 CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN FRANCISCO BAY REGION 2101 WEBSTER STREET,SUETY 500 OAKLAND,CA 54612 Tet: (510)286-1255 Fax: (510)288-138{3 OCT 0 1996 File No. 2199.9319 (VBP) Mr. Bert Michalczyk, Authority Manager DSRSD-EBMTJD Recycled Water Authority 7451 Dublin Boulevard Dublin, CA 94568 Subject: Draft Environmental Impact Report for the San Ramon Valley Recycled Nater Program, Alameda County-State Clearing House No. 96413428 Dear Mr. Michalczyk: The Regional Board has reviewed the Draft Environmental Impact Report(Draft EIS.)for the San Ramon Valley Recycled Water Program. It is this Regional Board's policy to encourage and stronglysupport water reclamation projects throughout this region. In keeping with these policies, we concur with the concepts outlined in the Draft EIR, However, the Regional Board is also responsible for protecting the duality of all the water resources in this region. Therefore, we are concerned about potential groundwater and surface water quality impacts associated with the proposed project. We have the following comments on the referenced water quality impacts: 1. Regional Board's Basin Plan policies on groundwater protection Chapter 3, Section 3.1 of the Draft Elft discusses impacts to the groundwater quality in the I fringe subbasins. It also discusses SWRCB Resolution 88-63 and beneficial uses for the fringe subbasins. Resolution 88-63, incorporated into the Basin Plan in 1981(Regional Board Carder No. 89-439), assigns Municipal and Domestic Supply designation to all waters � of the state with certain exceptions. The aquifer storage and recovery(ASR.) component of the project will probably necessitate re-designation of the groundwater beneficial uses in the Bassin Flan. 2. Effect of reclaimed water reuse in fringe subbasins One issue of concern is whether non-dernineralized recycled water(with relatively high total dissolved solids(TDS)concentrations)can be used for irrigation or aquifer storage and recovery without adverse effects on central basin groundwater quality. Recycled water irrigation in the fringe subbasins will increase the amount of salts leaching into the shallow ) aquifer. An increase in salt(TDS)levels in the fringe subbasins could result in higher TDS water moving across the basin boundary between the Fringe Subbasins and Main Basin. The 3-24 Mr. Bert Michalczyk Page Z EIR should propose a groundwater investigation program to better define salt loading pathway to the Main.Basin. Given steady increases of TDS concentrations in the central basin over last 17 years, this issue is particularly important. 3. Salt loading to the Main Basin An incremental increase in salt loading to the Main Basin would occur from the use of recycled water for irrigation in the Tassajara Valley and eastern Dublin areas of the project. One of the measures proposed by DERWA to mitigate the effects of the salt loading to the Main Basin is recharging the Basin with demineralized recycled water. We concur with this mitigation proposal provided that it is implemented in coordination with Zone 7. 4. salt loading to Alameda Creek and tributaries Salt loadings from recycled water irrigation could also impact the streams that drain the irrigated areas. These streams are all tributaries of the Alameda Creek, which is a source of recharge water for the Alameda County Water District (ACWD). ACWD has strongly i expressed its concerns about any project that will impact the Alameda Creek and tributaries. ! The Draft EIR indicates that The DSRSD-EBMtiD Recycled Water Authority will prepare a Salt Management Plan in coordination with Zone 7 or participate in Zone Ts Salt Management Plan currently under preparation. Since'gone 7 has the jurisdiction over most t of the water resources in the valley, and since different projects proposed in the valley will impact.the water resources differently, we strongly recommend a single comprehensive Salt Management Plan for the entire valley. We understand that any mitigation measures to be developed in a groundwater and surface water Salt Management Plan for the Alameda Creek watershed will be developed through consultation and coordination of involved agencies including Zone 7 and ACWD. 5. Recycled water quality Available water quality data indicate the presence of both organic and inorganic constituents of concern in the recycled water. The.Draft EIR suggests that these compounds will adversely affect the groundwater quality, since the concentrations of some compounds are higher than either MCLS or ambient levels. Any ground and surface water quality monitoring stations proposed in the Draft EIR must monitor for both organic and inorganic constituents of concern. Please be advised that any waste discharge requirements issued by the Regional Board will include appropriate recycled water quality requirements, monitoring requirements and 3-25 Mr. Bert Michalczyk Page 3 provisions based on the plans, policies, and water quality criteria of the Basin Flan and applicable State and federal regulations. If you have any questions or comments regarding this letter, please contact Vijay Patel of my staff at (510)286-4223. Sincerely, Teng-Chung Wu Chief, Surface Water Protection Division cc: AC"WD, Craig Hill Zone 7, David Lunn 3-26 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 7—California a Regional Water Quality Control Board 1. The comment is acknowledged. 2. The comment is acknowledged. Potable water supply is one of the designated beneficial uses of Fringe Basin groundwater as established in the Basin Plan adopted by the RWQCB. However,the Fringe Basin is not used as a municipal potable water supply source now,and Zone 7,DSRSD,and EBMUD do not have future plans for developing municipal supply wells in the Fringe Basin.In addition,according to current available well records,there are also only two potential potable domestic(private)wells in the Fringe Basin. As discussed in the Draft EIR,with aquifer storage and recovery(ASR)operation,the areas of the Fringe Basin where recycled water is stored would have to be restricted for potable well development. DERWA acknowledges the comment from the RWQCB that the Basin Plan may require amendment in order to allow for ASR operations.However, given the "put-and-take"nature of ASR,and the fact that DERWA"s ASR proposal is not for wastewater disposal,it is possible that a Basin Plan amendment may not be required.The need for redesignation is a matter to be determined during the permitting process.The DERWA Draft EIR addresses the impacts of ASR operation and of restricting potable use within the discrete zones of ASR influence in a project-level analysis. This EIR could support an action by the RWQCB to redesignate the affected portions of the Fringe subbasins around each ASR well. In brief,there are no impacts on current groundwater users since there are no potable groundwater wells within the projected ASR zone of influence.Non-potable groundwater uses such as landscape irrigation could continue.To mitigate the loss of access to potable groundwater, DERWA would be responsible for making an alternate potable supply available to affected property owners,as identified in Mitigation 3.1.1. If the RWQCB finds it necessary or desirable to consider redesignation of the entire Fringe subbasins)within which recycled water for ASR is proposed, then the RWQCB would serve as the Lead Agency and determine the need for and appropriate scope of any additional environmental review and CEQA processing,if necessary.The DERWA Draft EIR does not specifically analyze the impact of redesignating entire Fringe subbasins and restricting potable well development throughout. However, the environmental impacts of such an action would be similar to those already discussed in the Draft EIR and summarized above. If potable groundwater use were prohibited throughout the Fringe Basin,few,if any,current existing potable wells would require abandonment and replacement with an alternate potable water supply.Municipal potable water service is provided by either DSRSD or EBMUD to the areas within the Fringe Basin groundwater area.Thus,property owners would have an available potable water supply source in lieu of groundwater. 3. The comment is acknowledged.As noted in the Draft EIR,the TDS of recycled water and native groundwater are similar,and salt impacts to both the Fringe subbasins and the Main Basin are,therefore,considered negligible.Nonetheless,as described in Mitigation 3.1.2,DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan sjcAV)sftFP=IWOAMI31788.RVAE1R FiNAL\003,wc 3.27 SECT,ON 3 COMMENT LETTERS AND RESPONSES and in an Alameda Creek watershed plan,based on demonstrated and significant salt leading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. DERWA is committed to - development of a data collection program,and refined modeling and estimating of salt impacts,through its participation in the Technical Review Committee(TRC) formed between DERWA and ACWD in October 1996,with active participation by the RWQCB and Zone 7. DERWA is currently working with these agencies through the TRC to determine data needs and to design a monitoring program,develop a consensus approach to evaluating the collected data,and to begin developing possible mitigations for salt loading impacts. 4. The comment is acknowledged. Recharge of the Main Basin with demineralized recycled water is one of the options for mitigating salt loading impacts. Potential salt mitigation measures for impacts on the Main Basin may include,but would not be limited to,the following: • Recharge of the Main Basin with demineralized water. +. Increased conjunctive use of the Main Basin. Demineralization treatment of a portion of the recycled water to lower TITS to acceptable levels. • Purchasing additional imported water to offset potential increased salt content of the groundwater supply. Implement wellhead demineralization for groundwater wells. • Implement water treatment plant demineralization. 5. The comment is acknowledged. Please see response to comments#3 and#4 above. DERWA will implement a pro-rata share of these salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. 6. The comment is acknowledged.Ground and surface water quality monitoring will be performed based on consultation and coordination with ACWD and Zone 7,as discussed in response to comment#3 above. 7. The comment is acknowledged. DERWA will consult with the Regional Water Quality Control Board regarding permit requirements for the project. Sial\JosEiwpaoc\WOM131786.RNRE1R\FiNAL*003.00c 3.28 COMMENT LETTER #8 Central Contra Costa !unitary District 7>019 Imhoff Mace,Martinez,CA 94553 (510)27-8-9500 FAX:(5 S 0)2284624 ,°s pf C ROGERJ.DOL" October 11, 1996 GQWrWMma;tr Cheij`&VMSF )MWON L AW Cowa ti jw Ow DUDW DERWA (510)933-1434 7051 Dublin Boulevard �orcc� MURrf�r Dublin, CA 945£8 s. r� �fn,.Dumn ATTENTION: MR. BRUCE W. W€BB Ladies and Gentlemen: COMMENTS ON THE DRAFT EIR FOR THE SAN RAMON VALLEY RECYCLED WATER PROGRAM The Central Contra Costa Sanitary District (CCCSD) is a potential source of untreated wastewater for the project, as well as an affected property owner and a public service provider within the project area. As such, we have the following comments on the Draft EIR for this project. 1. The Draft EIR appears to adequately describe and discuss the DERWA and CCCSD facilities that may be needed for CCCSD to transfer untreated wastewater to DERWA. 2. The Draft EIR appears to adequately identify and propose mitigation for possible locational conflicts between the proposed project and existing and planned CCCSD facilities. 3. It should be noted that CCCSD`s participation in the project as a supplier of untreated wastewater would be subject to a discretionary policy decision of the CCCSD Board of Directors. Please send me a copy of the Final EIR when it is prepared. if you have any questions regarding these comments, please contact me at (510) 229.7255. Sincerely, Russell B. Leavitt, AICP Planning Assistant RBLlsrn h"Cled Paw 3--29 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No.8--Central Contra Costa Sanitary District 1. The comment is acknowledged. 2. The comment is acknowledged. 3. The comment is acknowledged. DERWA understands that CCCSD's participation in the project as a wastewater supplier would be subject to approval by the CCCSD Board of Directors. sicALtsAwPRWWORM13178S.RW\Elfi\Fi Ait 003.00c 3.30 3 : XT 11 1995 COMMENT LETTER #9 trete Wilson Governor State Water Mr. Bruce Webb Resources DSRSD-EBMUD Recycled Water Authority Control Board 7051 Dublin Boulevard Dublin, CA 94568 Division of Clean Water Dear Mr. Webb: Programs Mailing Address: DRAFT ENVIRONMENTAL,IMPACT REPORT(ETIs) FOR DUBLIN SAN R.AMON Pamen SERVICES DISTRICT-EAST BAY MUNICIPAL UTILITY DISTRICT RECYCLED aceCA CA Sacramento, 34244.2120 WATER AUTHORITY(DERWA) SAN R.AMON VALLEY RECYCLED WATER 2014 T street, PROGRAM- STATE REVOLVING FUND (SRF) LOAN NO. C-06-4127-110 Suite 130 (SCH# 96013428) Sacramento,CA 35914 (916)227-4480 Thank you for the opportunity to review the above document. We understand that FAX(916)227-4395 DERWA is interested in seeking an SRF loan from the State Water Resources Control Board( WR.CB) for the subject project. If this is the case,the SWRCB will be a responsible agency pursuant to the California Environmental Quality Act(CEQA)and must consider the information in the Final EIR when deciding whether to approve a loan for the project. Accordingly,please send us a copy of the Final.EIR.with comments and responses, a resolution certifying the EIR and making CEQA fundings,an adopted mitigation monitoring plan, and the Notice of Determination filed with the Governor's Office of Planning and Research when they become available. We would also appreciate - notices of any meetings or hearings scheduled regarding the document and project approval. Since the project may involve an SRF loan, which is partially funded by EPA, additional environmental documentation and review are required. Accordingly, on August 23, 1996, we distributed the ETR to federally designated agencies for a 45-day review period. Normally the review period would end on October 13, 1996;however,the U.S. Fish and Wildlife Service(FWS)was granted a 15-day extension which extends the review period to October 28, 1996. 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 an SRF loan project. Notices need to be distributed 30 days in advance with a copy sent to us. We have the following specific comments on the EIR: I. The EIR states that project level review is provided only for: (1)the ASR wells injection/extraction, (2)the SPRR.transmission alignments,(3)The Alcosta transmission alignments,(4)the pump stations(excluding pump station 1),(5)the distribution lines,and(6)the customer onsite facilities. An SRF loan can only be provided for project components that are reviewed at a project level. tx ,Recycled Paper than mission Is to preserve and enhance the quainy of California's carer resources and �t sn=re their proper allocation and efficient use for the Benefit ref present and ft wv,generaftn$. 3-3Z Mr. Bruce Webb 2 ITT - 2. On page 3-8,the EIR states that the groundwater model uses an assumption of 18 inches/year rainfall with 2.25 inches/year(13 percent)groundwater recharge. On page 3-13 the assumption used for salt leaching is 20 inches/year rainfall with 75 percent infiltration into the groundwater. Please explain this apparent discrepancy. 3. TDS impacts to creeks were determined to be potentially significant. The statement that"mitigation measures may be developed in a surface water salt management pian" does not assure that impacts will be reduced to a non- significant level. 4. The EIR needs to discuss how ASR well site FI will impact park uses located at that site. 5. Projects that involve SRF loans are subject to clearance and incidental take permits under Section 7 of the Federal Endangered Species Act,not Section 10. Under Section 7, preparation of a Habitat Conservation Flan is not rewired; however,a Biological Assessment may be required for the project. The FWS is currently reviewing the project to determine if Formal Consultation with the U.S. Environmental Protection Agency may be necessary. 6. Because no site intensive field surveys have been performed and no specific contingency mitigation measures have been proposed, impacts to biological resources,particularly to listed species, cannot be assumed to mitigated to a level of non-significance. 7. The EIR states that Growth impacts associated with freeing up potable water supplies were accounted for in previous planning documents. The EIR.needs to summarize the discussion of growth impacts in these planning documents and state what measures the documents recommended for mitigating indirect impacts associated with growth. 8. The EIR describes six project options, four alternative transmission alignments, and alternative sites for storage tank and pump station locations. The alignments and facility locations are provided only for the first project option. Since the 1 t} choice of options would influence the selection of alignments and facility locations,the alignment and location alternatives should be shown for all options. 9. The alternatives evaluation section compares only the no project alternative and the environmentally superior alternative which is described as the project as 1 proposed. The section should at least clarify which of the project options, proposed transmission alignments,and facilities locations represents the environmentally superior alternative. Recycled Paper Our mission is to preserve and enhanor the quality of California's water resaoms.and C7 emure their proper allocation and efficient use for the benefit of present and futwe generatians. 3-32 Mr. Bruce Webb 3 OCT Please call me at(916)227-4480 if you have any questions regarding the environmental review of this project. Sincerely, Wayne Hubbard Environmental Services Unit cc: State Clearinghouse 1400 Tenth Street Sacramento,CA 95814 Mr. Rich Condit Regional Water Quality Control Board San Francisco Bay legion(2) 2101 Webster Street, Suite 500 Oakland, CA 94612 t? Ricwkd Paper our m anon is to P"MV and enhance the quW14,of Cattfornia s water resmwces.and enmm their proper acltncmion and efficient use for the benefit of present and ftawv generations. 3-33 SECTm 3 COMMT LETTERS AND RESPONSES Response to Comment Letter No, 9--Cal/EPA 1. The comment is acknowledged. The requested documents will be forwarded to Calf EPA when they are completed.Notices of meetings and hearings will be sent to Cal/EPA under separate cover. 2. The comment is acknowledged. It should be noted that no comment letter from the USFWS was received by DERWA on or before October 28, 1996. In addition, DERWA held a public hearing on the Draft EIR on September 30, 1996.A notice of this public hearing was sent to Cal/EPA. 3. The comment is acknowledged. DERWA will consult with Cal/EPA regarding additional environmental review requirements when and if DERWA decides to apply for an SRF loan. 4. The assumptions about average rainfall and infiltration to the groundwater basin are slightly different due to the use of different data sources.The 20 inches/year value is based on average annual rainfall from the San Ramon station of the U.S. Department of Agriculture Soil Survey.The 18 inches/year value is based on weather station data located further south in the Livermore-Amador Valley.The groundwater recharge value of 13 percent is used on a basin-wide basis.In other words,on average across the basin, 13 percent of precipitation will end up in the groundwater basin as recharge water. This value was used as a calibration parameter in the simplified groundwater model to match observed groundwater levels.The model does not consider that the streams draining the area are gaining streams,with water seeping into streambeds and flowing out of the basin.This recharge into the streams is in addition to the 13 percent recharge to groundwater that is used in the model.The 75 percent infiltration value is a site- specific value at recycled water irrigation locations,where the majority of the vegetation is turfgrass.The turfgrass will hold much more precipitation water than other areas, resulting in reduced runoff and more infiltration to the root zone and groundwater. Turfgrass areas are also generally flat,thus further promoting infiltration over runoff. 5. The comment is acknowledged. As described in Mitigation 3.2.7 in the Draft EIR, DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. DERWA is committed to the development of a data collection program, and refined modeling and estimating of salt impacts through its participation in the Technical Review Committee(TRC) formed between DERWA and ACWD in October 1936,with active participation by the Regional Water{duality Control Board (RWQCB)and Alameda County Flood Control and Water Conservation District-Zone 7(Zone 7). DERWA is currently working with these agencies through the TRC to determine data needs and to design a monitoring program,develop a consensus approach to evaluating the collected data, and to begin developing mitigations for salt loading impacts. Modeling and other analytical approaches were developed and used in the Draft EIR to estimate the potential magnitude of salt loading impacts. As data is collected through implementation of the Program,DERWA would be able to refine its salt loading sicAUosslwt+aocSWORM131788.RMEIR1fftm\003.wc 3-34 SECTION 3 COMMENT LETTERS AND RESPONSES estimates,and evaluate the actual impacts that require mitigation,all in cooperation with the other agencies comprising the TRC.The TRC will provide a forum for DERWA and the other agencies to work out acceptable and reasonable mitigations for measured impacts. DERWA and the other agencies can also be involved in the development of the Zone 7 Salt Management Plan(currently under preparation)and an Alameda Creek watershed management plan,which will include mitigation requirements for salt contributors. 6. ASR wells typically require 2,000-2,500 square feet of area for operations after they are installed.The well area would be fenced and would be supplied with either an overhead or underground power source.The ASR well would be sited within the park so as not to disrupt park facilities or users. 7. The comment is acknowledged.Mitigations 3.9.1.,3.9.2,and 3.9.4 in the Draft EIR identify that appropriate resource agencies will be consulted for any part of the project that may affect special status species.In addition,as discussed in response to comment#2 above,the USFWS did not provide a comment letter to DERWA on the Draft EIR. 8. The comment is acknowledged. As noted in response to comment#5 above, DERWA is committed to identifying and implementing mitigation measures,including those for biological resource impacts,that will reduce impacts,at the time they are determined,to less than significant levels. 9. The comment is acknowledged. Section 15150(c)of the State CEQA Guidelines requires that if a document,or portion of a document,is incorporated by reference,the incorporated part of the referenced document shall be briefly summarized where possible,or briefly described if the data or information cannot be summarized.The "Freeing Up of Potable Water Supply"section in Section 4.1(Growth Inducing Impacts) of the Draft EIR(pages 4-1 through 4-3)incorporates by reference Chapters 1 and 13 of the EBMUD Water Supply Master Plan EIR(EDAW, 1993;SCH#89030122),and also references the fact that the DSRSD Urban Water Management Plan(DSRSD, 1996)is primarily based on the land use plans and their environmental documents that have been prepared and adopted by the local jurisdictions in DSRSD's service area. Following is a brief summary of the growth-inducing discussions from those documents. Summary ofGrowth- nducement Section from EBMUD Updated Water Supply Master Plan(WSMP)Final EIR-The Updated WSMP and EIR evaluated a range of Composite Programs that would meet EBMUD's identified need for additional water in the year 2020. All but one of the six primary Composite Programs rely on an assumption that a maximum annualized,system-wide,25 percent reduction in demand,accomplished through rationing,could be achieved in times of drought.This maximum 25 percent reduction,which would be achieved by implementing a Drought Management Program (DMP),is consistent with existing EBMUD policy that allows EBMUD to impose reasonable limits on demand to preserve supplies for future dry years. With existing conditions,the 25 percent rationing alone is not sufficient to allow EBMUD to meet its projected demand at 2020 levels of development.Four of the six :primary Composite Programs include both demand reduction measures and additional storage or supplemental supply alternatives. One Composite Program.(the Demand- side Management Composite Program)provides no additional supplies but includes sjc WosE\waptsc\WORM1317s8.RWv FIRlFimLN003.Doc 3-35 SECTION 3 COMMENT LETTERS AND RESPONSES aggressive conservation,reclamation,and a drought management program that includes a maximum annualized,system-wide 35 percent level of rationing. Another Composite Program.,developed as the Least Cost Alternative,includes supply-side measures only(the Groundwater Only Composite Program).Other Composite Programs combine demand-reduction alternatives(conservation and reclamation)and additional supply sources(groundwater storage/conjunctive use,reservoirs, supplemental supply or a combination of these components. The WSMP demand projections are based on the growth policies and expectations of various jurisdictions within EBMUD's currently defined Ultimate Service Boundary (USB). EBMUD does not expect to provide service beyond this boundary.It is important to note that the Updated WSMP does not focus on water delivery to specific locations;it focuses on the strategic implications of satisfying an estimated system-wide demand. Providing reclaimed water is one option available to satisfy this demand.The Composite Program alternatives would serve the anticipated population and economic growth within the EBMUD service area as determined by the plans and policies of local agencies. EBMUD is mandated by law(Municipal Utility District Act)to serve customers within its service area and,therefore,must also plan accordingly. The Growth-Inducement section of the Updated WSMP EIR concludes that making the EBMUD water supply more reliable and securing drought year water to support additional growth could have growth implications for the East Bay.This is true for all the composite water supply programs evaluated in the EBMUD Updated WSMP Final EIR However,the amount of water to be provided is to serve growth expected within the ultimate service boundary that is projected in the presently known plans and goals of the jurisdictions within EBMUD's service area.Therefore,the impacts of that growth should have been accounted for in the Ellis prepared by each jurisdiction as part of its planning approval process. Although it was not required,EBMUD committed to the following growth-related mitigation measures in its Updated WSMP: • EBMUD will continue to participate in efforts to improve regional planning in the Bay Area. • EBMUD will encourage local land use planning agencies and utilities to better coordinate their land use planning functions and the provision of such utility services as transportation,sewage,energy,and water. • EBMUD will encourage cities and counties to adopt general plans and zoning ordinances that favor high density development and urban in-filling,provide incentives for more housing near transit stations,and adopt growth control ordinances.Such policies will reduce the development of open space and wildlife habitat, and also help conserve energy and water resources. • EBMUD will encourage the Bay Area Air Quality Management District to adopt more stringent vehicular and stationary source air quality controls. • EBMUD will encourage the Metropolitan Transportation Commission,as well as the state and federal legislatures,to increase the availability and regional sjrA\JosEWPmc\WORK11 31768.RW\E1R\F1NAL\003.WC 3.36 SECTION 3 COMMENT LETTERS AND RESPONSES - coordination of mass transit systems,carpool and vanpool lanes,parking spaces at transit stops,etc. EBMUD will encourage local waste management and other agencies to increase the number and magnitude of recycling programs,especially programs where recyclable.materials are collected at the curbside of residences. Many of the above activities are already undertaken by EBMUD as part of its role as a responsible agency and an important provider of services in the region,regardless of EBMUD's responsibility for growth or its impacts.The details of how or when these activities are to be implemented will depend on public input and EBMUD Board actions over the next 30 years. Summary of DSRSD Urban Water Manag=gnt Plan tUWMPand Planning Documents fQr JurisdiLtions Within District's Service Area-As noted on page 4-2 of the Draft EIR, DSRSD's UW`-1\4P is based on the land use plans and their environmental documents that have been prepared and adopted by the local jurisdictions in DSRSD's service area. DSRSD was not required to prepare an environmental document for its UWMP because plans prepared under the Urban Water Management Planning Acts are exempt from CEQA. The growth inducing impacts identified in the EIRs for general and specific plans and development projects within the jurisdictions in DSRSD's service area are similar to those identified by EIRs for similar planning projects in EBMUD's service area. These impacts include impacts on traffic and transit,air pollution,loss of agricultural land and open space,water demand,wastewater disposal capacity,grading and excavation, groundwater overdraft,water quality degradation,traffic noise,energy demand increase,and change in visual character of the region.The impacts of growth are being mitigated at the program level by the jurisdictions within DSRSD's service area. It is important to remember that DSRSD does not have the authority to control land use and growth withinn its service area.The incorporated cities of Dublin and San Ramon, and Alameda and Contra Costa Counties have primary land use jurisdiction and responsibility to regulate growth through the land use planning and development approval process.The DERWA Recycled Water Program would support growth that is consistent with the local General flans and regional growth management projects. DSRSD does not have the jurisdiction or authority to implement mitigation measures for - many of the secondary effects of growth,such as increases in demands on other public services or loss of open space and agricultural land.Where the growth-inducing effects of the General Plans of jurisdictions within DSRSD's service have been identified as significant and unavoidable,the local lead agency has adopted a statement of overriding considerations for these significant unavoidable effects.The DERWA Recycled Water Program would not increase the nature,number or severity of significant effects associated with planned development. 10. The alignment and location alternatives for all options are shown in Table 2-5 in the Draft EIR,and are illustrated in Figures 2-12 through 2-15 for Customer Service Option 1. Generally,the pipeline alternatives only apply to developed areas. In future ureas,the alignments will follow future roadways,as documented in approved land use planning documents.Tank sites are covered programmatically and will be sited during saclJ:IWOM131768.RWSR\FiNAL=3.00c 3-37 SECTION$COMENT LETTERS AND RESPONSES subsequent design work. Pump station sites are dependent upon pipeline alignment. The alternatives for pipeline routes and pump station sites apply to all project options because all project options include the developed areas of Customer Service Option 4. - The optimized options and Option 5A eliminate the need for some facilities and alternatives, as shown in the figures. 11. The comment is acknowledged.Section 15126(d)(4)of the State CEQA Guidelines states that"if the environmentally superior alternative is the'no project' alternative,the EIR shall also identify an environmentally superior alternative among the other alternatives." Consistent with this CEQA guidance,Section 5.3 of the Draft EIR identifies the No Project Alternative as the environmentally superior alternative only from a short-term construction-related impact perspective.From the perspective of long-term benefits to the region and environment,the proposed San Ramon Nater Recycling Program is identified as the environmentally superior alternative.Therefore, the intent of Section 15126(d)(4) of CEQA is met in the current wording of the EIR. As noted in Section 1.3 of the Draft EIR,the principal difference among the customer service options evaluated in the EIR is the amount of water delivered and the number of customers served.These differences result in differences in transmission pipeline length,the amount of distribution pipelines,the number of tanks and pump stations needed,and whether a seasonal recycled water storage component is needed. Obviously,the larger the customer service option served,the more recycled water facilities will be required;therefore,an argument could be made that the larger the customer service option served,the greater the short-term construction-related impacts due to more required facilities. However,in reviewing Table 2-5 in the Draft EIR,it is apparent that all of the options will have some impacts regardless of which transmission alignment and facilities are selected. s,tcJl:tY,fOfSK1t3t7HH.RYV�EiFt1€ts�aL�flUS.IX3C 3-3$ . ... ....... COMMENT LETTER # 1 ( ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT 5997 PARKSIOE DRNE :'L-CASANTON.CALIFORNIA 94598-5-,77 -;G-2eCn ' 'AGE October 12, 1996 DERWA Steering Committee 7051 Dublin Blvd. Dublin, CA 94568 Attn: Bruce Webb Sub)ect: San Ramon Valley Water Recycling Program DEIR Comments Dear Mr. Webb: Zone 7 has reviewed the above referenced DEIR. Zone 7 supports increased water recycling as a means to increase the volume and reliability of this region's water supply and to reduce losses to San Francisco Bay of a potential resource. Our comments are listed below by DEIR section. These primarily concern use of the Dublin subbasin for recycled water storageirecovery and mitigation and monitoring requirements for salt loading impacts. Zone 7 recognizes the benefits of the proposed fringe basin ASR project as a means to increase local water supply. The Zone will work with DERWA and the RWQCB on the Basin Plan amendment (of groundwater beneficial uses) that appears necessary to implement this project. Overall, Zone 7 behaves that the potential salt loading impacts on the main groundwater basin from irrigation under any of the proposed alternatives can and should be fully offset by DERWA and its commitment to implement appropriately sized, Zone 7 approved, salt mitigation projects. Two important salt mitigation projects, among those being developed by the Zone's Salt Management Program (SMP), include groundwater injection of dernineralized recycled water and increased conjunctive use coupled with wellhead demineralization. Zone 7 understands that DERWA's commitment is to mitigate for the incremental salt loading from use of recycled instead of potable water. Through the SMP Zone 7 is identifying other salt mitigation measures to implement on a regional basis to achieve the SMP goal of reducing the main basin salt imbalance to zero. It is important for DERWA to refine monitoring well locations and monitoring program requirements in conjunction with Zone 7 efforts in order to improve understanding of the groundwater basin and salt transport. In particular, DERWA should work with Zone 7 to extend the main basin groundwater model to the Camp, Dublin, and Bishop subbasins, to refine project impact assessments. These activities will be incorporated into the Salt Management Plan. Zone 7 accepts the watershed based approach to addressing the increased TDS impacts on creeks and ACVVD from potable and recycled water irrigation within the watershed. DERWA should work with Zone 7 and ACWD (as the lead agency) to identify feasible and equitable rnifigations. 3-39 _ _ _ DERWA Steering Committee October 12, 1996 Page 2 SPECIFIC ZONE 7 COMMENTS ON DERWA DEIR Recycled Water Quality - p. 3-4 Table 3-1 presents a considerably more limited comparison of existing versus recycled water quality than in the Clean Water Revival DEIR discussion of the essentially identical fringe basin ASR project, particularly regarding organics. Table 3-1 shows that concentrations of several recycled water constituents may exceed ambient Dublin subbasin concentrations. Appendix C (p. 9) states that the recycled water "may exceed ambient concentrations of chloride, fluoride, nitrate, sulfate, TOS, and iron"and noted the"occasional presence of THMs, acetone, and select organic compounds." 5 The DEIR needs to provide a full discussion of this issue, in particular how the project will comply with the State Board's non-degradation policy (Resolution 68-16) and the Basin Plan TDS groundwater quality objective of"ambient or 1000 mgJL, whichever is lower." Basin Plan Table 3-7 states that "Ambient water quality condition's at a proposed project area will be determined by Zone 7 of the Alameda County Flood Control and Water Conservation District at the time the project is proposed, with the cost borne by the project proponents. Ambient conditions apply to i the water-bearing zone with the highest quality water." The recycled water quality projections (p. 3-4) state that groundwater use will likely not increase significantly, and that increased ©SRSDtPleasanton demand would likely be served by Zone 7 surface water supplies. Zone 7 is strongly considering increasing conjunctive use as a means to reduce the groundwater salt imbalance. Under this scenario, potable and hence projected f recycled water TOS concentrations could increase beyond the levels cited. Increased use of low flaw toilets and water saving devices will also tend to increased wastewater TDS. Decisions will be made during completion of the SMP regarding the amount of additional conjunctive use and groundwater pumping that will be implemented. Blending with surface water or wellhead demineralization are being considered as ways to maintain or reduce the TDS concentration in water delivered to customers under a more intensive conjunctive use program. Such efforts would correspondingly reduce recycled water TOS concentration. Compliance with Basi Plan - p. 3=8 The proposed ASR project would prevent at least some portion of the Dublin and possibly Bishop subbasin from continuing to be used for potential municipal and domestic supply. Although it appears to be an appropriate and desirable action to modify the current subbasin beneficial use designation from municipal supply to in igaltion-only, per our understanding of they Basin Pian, RWQCS Resolution No. W39, 5'I£1/RCS Resolution No. 88-63, and discussions with RWQCS staff, it does not appear possible without a Basin Plan amendment(which must then be approved by the State Board and State Office of Administrative Law). None of the exception criteria for an exemption from the municipal designation under the"Sources Policy' apply to this situation. RWQCB staff have identified the need to update groundwater beneficial uses basin by basin through the basin planning process. They are investigating 3-40 DERWA Steering Committee October 12, 1996 Page 3 alternative redesignation approaches as part of their Pilot Beneficial Use Designation Project, focusing on the San Francisco/Northern Sen Mateo County basins, preliminary results of which were presented to the RWQCB April 17, 1996. � i The DEIR statement that "Basin Plan and SWRCB policy allows the groundwater basin to be used for water reclamation purposes (because reclamation provides a beneficial effect in the conservation of a natural resource), particularly if the recycled water is withdrawn, as proposed in the P ograrn's ASR operations" appears accurate only if a Basin Plan re-designation amendment is approved. The subsequent statement that "The beneficial use of domestic water supply can be protected ! by removing existing potable wells and prohibiting future potable wells from the ASR zone of influence" needs to be qualified in that it only applies (in principle) to areas outside the ASR zone of influence. Within the ASR zone of influence, the domestic beneficial use would not be protected, and a domestic water supply would need to be imported. Finally, the statement that "operation of the ASR component of the DERWA Program would be consistent with Basin Plan and SWRCB policies" needs to be modified to reflect the need for a Basin Plan amendment. 3.1.1 Fringes Dain Water Quality Degradation impacts Zane 7 believes that the proposed ASR project for the Dublin subbasin is technically , feasible based on available information on local hydrogeology and the reconnaissance lever "conceptual numeric" groundwater flow and transport model results presented in the DEIR (Appendix C). The results allow an assessment sufficient to identify potentially significant impacts and feasible mitigation strategies. From Zone 7`s standpoint, it would beneficially increase the local non-potable water supply to implement a recycled water ASR project in the Dublin subbasin. Zone 7 has no future plans for installing wells and using the Dublin subbasin for municipal potable supply. The ASR project would convert the basin from a possible (but unlikely) municipal potable supply source to a valuable non-potable, irrigation-only supply source. The proposed project will capture for beneficial use about 1,410 AI:Y of recycled water that would otherwise be lost to San Francisco say. Additional NUgation As noted above, the project will require a Basin Plan amendment to change the subbasin beneficial use from municipal supply to irrigation. DERWA should take actions to initiate the needed amendment. It may not be feasible to convert the subbasin back to municipal i potable use, if so desired in the future, without some level of remediation and/or wellhead treatment. Zane 7 will cooperate with DERWA's efforts, but Zone 7 will not assume any responsibility for any future remediation. Zane 7 agrees with the recommendation in Appendix C that the model should be refined as the project proceeds. Zone 7 recommends that DERWA commit to a joint effort with the gone to extend the main basin Visual Modflow and MT3D model to cover the Dublin and Bishop subbasin. 1 Results of additional field tests (aquifer tests) to !setter define local aquifer properties conducted as part of further project design development should be incorporated into the expanded model 3-41 DERWA Steering Committee October 12, 1996 Page 4 to refine the design, siting, and operation of wells, the impact analysis, and proposed monitoring program. DERWA should obtain Zone Ts approval on the design and location of monitoring 12 wells, as well as the parameters measured and frequency of measurement as part of the SMP monitoring program. Zone 7 will cooperate with DERWA to identify existing wells within the ASR zone of influence. Zone 7 does not have independent authority to prohibit well construction as implied in mitigation 3.1.1. Within its service area, Zone 7 proposes to develop a new category of non-potable irrigation well permits and a cooperative permitting system involving the county health agency, water purveyor, and/or local (city or county) building inspection/permit authority responsible for Title 17 backflow prevention device enforcement. Before issuing a well permit for a well within the zone of influence of an ASIR well, Zane 7 would require the applicant to provide documentation from these other authorities that an appropriate backflow device was installed and that there were no cross connections with the potable system. 3.1.3 Increase In Salt Loading to Main Basin impacts Zone 7 agrees with the general approach taken in estimating incremental salt loading to the main basin from recycled irrigation within the DERWA project area. The majority of such ' 4 salt would flow out of the valley and not impact the main basin. Note that the specific values presented on pages 3-11 to 3-14, particularly those for Tassajara Creek, need to be updated to match the presumably more current values in Appendix D. Also, it would help clarify the discussion and evaluation of alternatives if Table 1 from Appendix D and appropriate explanatory text were included in Chapter 3. Zane 7 agrees that based on current knowledge, the most important DERWA related salt loading source is from Tassajara Creek and possibly East Dublin. The relative contributions from the upper Tassajara watershed and from the East Dublin developments should be specifically identified. Monitoring well baseline data appear adequate to support the conclusion that the ASR project 1T would not significantly increase subsurface flow and salt loading to main basin. The mass loading estimates are adequate for planning level purposes, but will need to be refined and better quantified as projects proceed. As part of the SMP, Zone 7 intends to investigate whether the incremental salt loading calculation should be static or take into account annual 1$ changes in potable and recycled water qualities. The SMP will also be identifying measures to reduce total salt loading:, not jus"he increment related to recycled water use,to comply with Zone Ts long-term goal of reducingr salt imbalance in the main basin to zero. Additional Mitigation Additional information is required to evaluate the potential for salt loading from irrigation in East Dublin. More monitoring wells and geological investigation are required to determine the extent to which irrigation will result in subsurface flow across the Camp subbasin souther boundary into the main basin, versus rising groundwater level, increased streamflow, and salt export out the valley. This issue was not assessed in the:DEIR. 3-42 DERWA Steering Committee October 12, 1996 Page 5 DERWA should commit to extending the main basin groundwater model to the Camp subbasin, compiler the necessary hydrogeological data, and reassess the impacts of East Dublin and Tassaijara Creek area irrigation on surface and subsurface flows and salt transport in cooperation j with Zone 7. ! Currently, increased conjunctive use with wellhead demineralization and demineralized recycled water recharge appear to be effective salt mitigation measures. However, both are dependent { ' on DERWAIDSRSD providing adequate brine disposal capacity. I 3.1.3 Rise In Shallow Groundwater Levels Impacts This is a potential problem area if the assumptions regarding aquitard hydraulic conductivity are overly optimistic (per discussion in Appendix C). In some areas depth to water is only three fent. however, the proposed mitigations of decreasing injection rates, increasing the number of wells, and increasing well spacing appear reasonable. Additional Mitigation To more fully evaluate the potential for unacceptable water level rises and increases in subsurface flow towards main basin, Zane 7 recommends that the first ASR well 23 constructed be operated as a demonstration project using domestic water prior to initiating recycled water injection. 3.2.7 Increased TDS in Study Area Creaks Impacts Zone 7 supports approaching the issue of salt loadings to the study area creeks from a watershed perspective. The primary impacts from DERWA recycled water irrigation and potable water irrigation are on ACWD. DERWA should work cooperatively with Zone 7 and other stakeholders, with ACWD as the lead agency, to identify equitable salt mitigation measures for sant loadings that may impact ACWD potable water supplies. Additional Mitigation DERWA should obtain Zone 7's approval on the design and location of proposed stream monitoring stations, as well as the parameters measured and frequency of measurement, in coordination with Zone 7's SNIP monitoring program. MINOR COMMENTS Dublin Subbairsin!Nater duality- p. 2-45 References are made in several places to the water quality in the Dublin subbasin as being relatively poor implying its unsuitability as a drinking water suppty. However, as shown by Zone 7 records, and as graphed in Figure 2-6 of Appendix C, recent TOS values are in the range of 400-600 mg/L. This is similar to groundwater quality in many areas of the main basin currently used for municipal potable water supply. 3--43 DERWA Steering Committee October 12, 1996 Page 6 Water Recycling Permit - p. 2-48 Under the Water Cede, the referenced Zone 7, DSRSD, and Livermore"blanket" permit is termed a master permit. Zone 7 recommends that DERWA and its member agencies work together with Zone 7 to develop uniform rules and regulations whether under a new or amended master water recycling permit. Impacts to Groundwater Quality in the Fringe Basin - p. 3-8 The modeling discussion refers to use of Micro-Fem code; Appendix C staters that Mod#low and I � MT30 were used. Surface Water Quality Degradation from Pipeline Leaks and Failures - p. 3-23 The Masten Water Recycling Permit prohibits discharger to surface waters. The system should be designed conservatively enough to prevent leeks (e.g., reinforcing, rasing, etc. at creek 8 crossings). Thank you for the opportunity to comment on the DEIR. if you have any questions, please call me or David Lunn at your convenience. Sincerely, Vincent Wong Assistant General Manager VW.DL:TH CC. Zone 7 Board Members GMAC Members kWminvlwvw�r 3--44 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 10—Alameda County Flood Control and dater Conservation District(Zone 7) 1. The comment is acknowledged. In its comment letter(Comment Letter#7 in this Final EIR),the RWQCB indicates that the Basin Plan may require amendment in order to allow for ASR operations in the Fringe subbasins. As discussed in the Draft EIR,with ASR operation,the areas of the Fringe subbasins where recycled water is stored would have to be restricted for potable well development. However,given the "put-and-take" nature of ASR,and the fact that DERWA's ASR proposal is not for wastewater disposal, it is possible that a Basin Plan amendment may not be required.The DERWA Draft EIR addresses the impacts of ASR operation and of restricting potable use within the discrete zones of ASR influence in a project--level analysis.This EIR could support an action by the RWQCB to redesignate the affected portions of the Fringe subbasins around each ASR well. In brief,there are no impacts on current groundwater users since there are no potable groundwater wells within the projected ASR zone of influence. Non-potable groundwater uses such as landscape irrigation could continue. To mitigate the loss of access to potable groundwater,an alternate potable supply available must be made available to affected property owners,as identified in Mitigation 3.1.1. If the RWQCB finds it necessary or desirable to consider redesignation of the entire Fringe subbasin(s)within which recycled wafter for ASR is proposed,then the RWQCB would serve as the Lead Agency and determine the need for and appropriate scope of any additional environmental review and CEQA processing,if necessary. 2. The comment is acknowledged. As noted in the Draft EIR,the TDS of recycled water and native groundwater are similar, and salt impacts to bath the subbasins and the Main Basin are,therefore,considered negligible.Nonetheless,as described in Mitigation 3.1.2,DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. DERWA is committed to the development of a data collection program,and refined modeling and estimating of salt impacts, through its participation in the Technical Review Committee (TRC) formed between DERWA and ACWD in October 1936,with active participation by the RWQCB and Zone 7. DERWA is currently working with these agencies through the TRC to determine data needs and to design a monitoring program,develop a consensus approach to evaluating the collected data,and to begin developing possible mitigations for salt loading impacts. The initial TRC task is to review the available information and develop requirements for additional data collection. DERWA and the other agencies will develop a consensus on the water quality parameters to be monitored and will design a program for establishing baseline data and post-project implementation data that will allow DERWA to determine the actual impacts that need to be mitigated by DERWA. After data collection has begun,an evaluation approach must be used that is agreeable to DERWA and the other agencies. This approach will be developed through the TRC.The TRC will provide a forum for DERWA and the other agencies to work out acceptable and reasonable mitigations for actual impacts.DERWA and the other agencies can also be involved in the development of the Zone 7 Salt Management Plan(currently under preparation)and sxW1c8EI,vFgod WORK\I31MR1MEIR�Ft!aat1Q lwc 3-45 SECTION 3 COMMENT LETTERS AND AESPCMeES an Alameda Creek watershed management plan,which will include mitigation requirements for salt contributors. 3. The comment is acknowledged.Modeling and other analytical approaches were developed and used in the Draft EIR to estimate the potential magnitude of salt loading impacts.As data is collected through implementation of the Program,DERWA will work with Zone 7 to extend modeling into the Camp Subbasin,refine its salt loading estimates, and evaluate the measured impacts that require mitigation, all in cooperation with the other agencies comprising the TRC.DERWA will coordinate with the TRC agencies to determine appropriate monitoring locations and protocol to support the data collection effort. 4. The comment is acknowledged;DERWA will work.with Zone 7 and ACWD to identify feasible mitigation measures.The issue of which agency would be the lead agency for these mitigation measures,would be agreed on by the affected agencies through participation in the TRC. 5. The additional data for organic constituents represented in the Clean Water Revival (CWR)Draft EIR(Table 3-2 on pages 3-22 through 3-26 of the CWR Draft EIR)is included as a new appendix(Appendix F)to the DERWA Draft EIR,and reference to this new appendix has been added as a text revision to page 3-5 of the Draft EIR.The data in the CWR water quality table is essentially equivalent to the DERWA water quality table,from a standpoint of assessing impacts,with the exception of recycled water quality data(CWR recycled water will be treated with reverse osmosis). As noted in the EIR,Zone 7 will be responsible for determining ambient groundwater quality based on up-to-date samples of the groundwater prior to project permit approval. Regarding the issue of non-degradation to the surface and groundwaters of the Alameda Creek drainage basin,DERWA believes its Program would conform to the policy statement from the RWQCB Basin Plan,and would implement a project that would remove for in-basin application as recycled water a portion of the wastewater stream from the Livermore-Amador Valley that would discharge to the San Francisco Bay.According to the Basin Plan,development of reclamation facilities is in the interest of the people of the State and,where reclamation is available,use of potable water for common area irrigation is considered an unreasonable use of the potable water supply. The Basin Plan also states that where a reclamation project is proposed, the State Water Resources Control Board(SWRCVB),RWQCB,and Department of Toxic Substances Control(DTSC)must develop discharge standards and treatment requirements for reclaimed water used for groundwater recharge,and that the Basin Plan requires updating and expansion to include constituents of concern. Additional monitoring and assessment of wastewater and ambient water quality also needs to be addressed to enforce the water quality non-degradation standards. DERWA,in its participation on the TRC with ACWD,Zone 7,and the RWQCB is pursuing these requirements of the Basin Plan in accordance with the RWQCB's policy on reclamation. If DERWA approves an ASR component to its project and moves forward with detailed engineering and permitting,then a point-by-point detailed water quality analysis and comparison with ambient groundwater would be prepared by DERWA as part of its permit package to the RWQCB for review and approval.The EIR does address the key impact areas central to compliance with these regulations.The EIR analysis does indicate that the recycled water will not be potable and,therefore,discrete areas of the sjcA\Jm€.\wPsoc\WORK\131768A MEtR1€WO03moc 3-48 SEcr ON 3 cOMMENT LETTERS AND RESPONSES aquifer will not meet one of the designated beneficial uses of the basin.The EIR also reviewed the recycled water quality in light of drinking water standards.There are relatively few parameters for which the recycled water does not meet drinking water standards.However,as this water is not intended for indirect potable recharge,it is not required to meet drinking water standards.The recycled water is only intended for unrestricted,non-potable uses and,thus,must comply with Title 22 water quality standards for such uses. A chief operating principle of the ASR component of the project is that it is a "put and take"operation,where the recycled water stored in the groundwater aquifer each year would be removed each year. As clarified in the EIR,not all the recycled water stored in the aquifer would be removed,but outside the ASR zone of influence the recycled water that does remain would occur at concentrations of less than two percent.With this level of dilution of recycled water to ambient groundwater,the affect of the recycled water on the groundwater quality outside the storage zones would be minimal. If necessary,as part of the RWQCB permitting process and to respond to the Board's non-degradation policy,DERWA could provide a discussion of project purpose and need to support the introduction of the potentially lower quality recycled water into discrete areas of the Fringe Basin aquifer. 6. The comment is acknowledged.The salt loading analysis in Appendix D of the EIR - assumes that the applied TITS is constant over time based on the levels stated in the memo. Further analyses could be performed for other TDS levels;however,given the uncertainty in future TDS levels in drinking water,particularly with techniques such as an increase in conjunctive use of the Main Basin as proposed by Zone 7,such analyses may not be warranted.TDS levels could go down if demineralization is implemented for groundwater.DERWA will monitor actions undertaken by Zone 7 and others that - could increase wastewater TITS,which could in turn affect recycled water TDS.Zone 7 and DERWA would need to evaluate such actions as part of the Salt Management Plan that is being developed to arrive at a comprehensive solution to salt management that does not unknowingly shift the salt problem from one agency to another, or from one part of the basin to another,and does not compromise integrated water resources management within the'Talley. 7. The comment is acknowledged. Please see response to comment#1 above. 8. The comment is acknowledged.The use of domestic potable wells will be prohibited in the ASR zone of influence. With regard to the need for a Basin Plan amendment,please see response to comment#1 above. 9. The comment is acknowledged. 10. The comment is acknowledged. 11. The comment is acknowledged.Please see response to comment#1 above. 12. The comment is acknowledged.It must be noted that the level of information available for the subbasins is much less than that available for the Main Basin.DERWA concurs that field testing should be incorporated into the model,and that Zone 7`s approval will be obtained for monitoring wells and parameters measured. SjcAUo561WPRocXWORK,131768.RWiEiR FiNAL\003.aoC 3-¢7 SECTION 3 COMMENT LETTERS AND RESPONSES 13. The comment is acknowledged.A text revision has been made to Mitigation 3.1.1 in the Draft EIR to describe Zone 7's intended approach to potable well restriction in ASR zones of influence. 14. The comment is acknowledged. 15. The comment is acknowledged. Text revisions have been made to pages 3=-14 and 3-15 of the EIR to make them consistent with Table 1 in Appendix D. 16. The comment is acknowledged.Identifying the relative contributions from the Tassajara and Eastern Dublin areas would be a further refinement of the salt loading analysis,but would not identify any different impacts. As noted in response to comment#3 above, DERINIA will be able to further refine its salt loading estimates through the data collection program that will be implemented as part of the Program. 17. The comment is acknowledged. 18. The comment is acknowledged. Please see responses to comments#2 and#3 above. 19. The comment is acknowledged. Please see response to comments#2 an#3 above. 20. The comment is acknowledged. Please see response to comment##3 above. 21. The comment is acknowledged.Brine disposal would increase TDS concentration of any discharge water and may impact receiving water quality,such impacts would need to be examined by the lead agency for the salt management plan as the options of that plan are evaluated. 22. The comment is acknowledged. 23. The commentor requests that the first ASR well constructed be operated as a demonstration project using domestic water prior to initiating recycled water irrigation. Running an ASR well "pilot test"with potable water first is a typical procedure with ASR operations,and DERWA will likely use this process for its ASR wells. - 24. The comment is acknowledged. Please see response to comments##2 and#3 above. 25. The comment is acknowledged.DERWA will seek Zone 7's approval on the design and location of stream monitoring stations and requirements. 26. The comment in acknowledged.TDS in the Dublin subbasin is variable,between about 200 to 52,000 ppm.The high TDS portions of the Dublin subbasin are higher than the Main Basin,and in exceedance of recommended drinking water standards. Some areas of the subbasin may contain groundwater of similar quality as found in the Main Basin. 27. The comment is acknowledged. DERWA will work with Zone 7 to address the master water recycling permit,recognizing that neither DERWA nor one of its members (EBMUD)is named on the"blanket"permit and,furthermore,that the DERWA study area extends beyond the jurisdiction of the current permit holders,as well as beyond the watershed boundaries. 28. The comment is acknowledged.The text of the Draft EIR(p.3-8)is incorrect,and has been corrected by a text revision.The final conceptual model of the subbasins was developed using Visual MODFLOW.An earlier conceptual model was developed using MicroFem,but was later supplanted by the use of Visual MODFLOW. 8jchWosctwPaocIWORK1131788.RW1E1RViNALt003.00c 3-48 SECTION 3 COMMENT LETTERS AND RESPONSES 29. Creek crossing design for pipelines will include conservative protective features that will be designed to prevent leaks from the subsurface pipeline from being undermined by creep scour or otherwise damaged.The detailed design will likely include a reinforced concrete encasement for open cut crossings and a casing pipe for trenchless crossings. SJCMJOSE\WPACO W)F K I S1768.RW\EIR\FiNAtl903.wc 3-49 COMMENT LETTER #11 CITY OF PLEA A. "SON P.O.BOX 520 PLEASANTON, CALIFORNIA 94566-0802 a MY orricla =MAW SUM October 14, 1996 CM COUNM 444AW1 CM "Acne 4"4M Bert Michalczyk cneral Manager CM CL= DER.INA 7051 Dublin Boulevard FWANCs Dublin, CA 94568 484-US3 PMONNM RE: Draft Environmental Impact Report- San Ramon Valley AU4012 Recycled Water Project crrY omen zw OLD RvRx►t.AM Dear Mr. Michalczyk: PLAN"* 4"= Please find attached the:City of Plessantods written comments on they saGOasaW40 above referenced DEM Thank you for the opportunity to comment on this DEIR. AS&A"t mmlaw ursr=tsrt "Vay'tr*yours, COSOAUNM s c s 4"4160 _ s A.Lcure sanYcc�c Director of Public Works smear xmtvzc /sb asrsaar ?.M cc: Mayor and Members of the City Council 46440% Deborah Acosta,City Manager SAIMA .Y SZWUt Steve Cure ma,Deputy Director ofUtilitie s 4"410" Peggy Purnell, Committee Humber stassr WAM s .ersx�cs Pea= AM»t.AV3L A&a 3--50 sia anwa t ereveeve c a*a r NOXNwevalla ao xs 1 a*world ex*t#c ma-V x-100 CITY OF PLEASANTON'S REVIEW OF DRAFT ENV ELOMlENTAL D IPACT REPORT FOR TRE SAN RAMON VALLEY RECYCLED WATER,PROGRAM Sponsored by DERWA State Clearinghouse No. 95013028 In several alternatives,the Draft EIR evaluates the impacts of providing recycled water to areas not yet approved for development. The Draft concludes that there is no growth inducing impact as to that alternative because such impacts will be evaluated if and when development comes to the area. That approach is contrary to CEQA. The use of recycled water to provide irrigation or for other non-potable purposes frees up potable water supplies in existing developed areas, in areas approved for development but not yet built, and for areas that could be served by the project but not yet approved for development. The specific use of this freed up water must be described, quantified and evaluated by customer service options I through 5B as part of this environmental review process. To the extent that freed up water could be used to supply future development, the growth-inducing impacts of supplying future:development with the freed up water must be addressed as part of this DER. To the extent that this freed up water is used for other purposes, the environmental impacts of these other purposes must be addressed within the DEM. Alternatively, the EIR. should simply eliminate as an option this project's providing recvcled water to areas not yet approved for development. Groundwater Quality Tmtoacts A nurnber of groundwater quality estimates, assumptions and modeling nuns were made within this DEIR to predict the environmental effects of the use: and storage of water by the DERWA Program over and in the Bishop and Dublin groundwater subbasins (fringe subbasins). The studies concluded that there would be no significant;adverse water quality impacts or influences from any component of the DERWA.Program (including the aquifer storage and recovery (ASR) component) on the blain Basin. Accordingly, no mitigation measures were unposed to protect the Bexna/Amador subbasins(the Main Basin). We found the analysis conclusory and not convincing. The benefit of anv model, assumption or estimate is how C well it can predict real life occurrences. In order to protect the Main Basin, we believe that a series of appropriately spaced water quality monitoring wells must be constructed in addition to the surface water quality monitoring stations proposed on all the major Study Area Creeks. These wells/monitoring: stations should be located between the Dublin/Camp(fattrge basin)subbasms and the Bernai/Amador subbasins(the Main Basin)as well as south of the Main Basin in the Casdewood/Sunol area on the Arroyo De La Laguna as part of the mitigation measures required prior to commencing the DERWA Program operations. Page l �/£ aJYfd isravabets'aI H0XNWSW3Id 30 AZI3'WoHA sz'vt 438-bi-130 3-51 aVt L+IF 9V The purpose of t o wells and surface runoff stations would be to confirm., calibrate and quantify independently the water quality modeling, assumptions and estimates made within the Ili.regarding subsurface and surface water salt loading to the Basin as well as to the Alameda CreelsNiles Canyon drainage area. These facilities would also be used to ascertain in real life terms the transfer of all other recycled or native water { constituents brought about by the application and storage of recycled water in the fringe basins. Moreover, to the e;ttent that these stations, or the groundwater quality monitoring wells, ids impacts to water quality in the Main Basin or tiles Canyon as a result of this program/project, specific mitigation measures should be identified, developed and included within this DEM- The DEIR also contains a number of assumptions and calculations for the assumed salt loading to the Main Basin from the Study Area creeks based upon g=natal dissolved solids (TICS) of applied irrigation water sources compared to recycled water sources. No mention is made regarding the current local and regional plans underway to decreaase the TDS of existing potable or irrigation sources (local groundwater, surface water and State Water Project Water). Depending on the outcome of these plans, this could ins the calculated salt loading amounts flowing to the Main Basin from DERWA Program operations. The eft EIR needs to discuss these plans and provide appropriate mitigation measures. Water SUVRIV Qtttians The Central Contra Costa. Sanitary District(CCCSD)water supply option would duplicate or firee up previously constructed wastewater treatment facilities by constructing duplicate facilities at the DSRSD Regional Treatment � Plant If this were to occur, the environmental impacts of this freed up capacity in the CCCSD Service Area nerds to be addressed in this DEIR. We believe the CCCSD water supply option also has significant other impacts that were: not addressed in the DEQ,.. in order to include this option in the DER as a passible water supply option, the capacity rights, expansion cost sharing, facility apportionment and changes in the wasting operation of the DSRSD Regional Trewnent plant will need to be developed and their environmental impacts analyzed. In addition, become there is no excess capacity within the existing DSRSD plant, the plaint would need to be expmulend and the environmental impacts of such expansion £'oily evaluated. All of this analysis, evaluation and apportionment would need to conform to the e�dsting agreements between the City ofPleasanton and DSRSD. DY'RaA&2gGM Facilftits with' rrt n: The DESS. does not adequately address the environmental impacts or the operational changes to the DSRSD treatment rnt plant facilities and operons as a result of the DERWA.Progr im. Additiomal persom"tel and significant operational changes will be occurring at the plant and the environmental elfercts of the=se changes were not addressed. For example, the new processes or operating parameters to the treatment operations may impact odor or other ean'virnntuenW factors, especially since the DERWA Program may use the DSRSD or LAVWMA ponds differently than atpresent. Page 2 9!b 3'�1dd t f3Zt b�ib0 t 9 O I i@#nZNW SVZla A0 AM n 3 s wona G z=b t SO-VI-130 3-52 10/14/96 In addition, the proposed pipeline routes between the existing treatment plant northerly past Interstate 580 must not only be move thoroughly analyzed for environmental impacts but also must be coordinated with current and future Caltrans plans for the Interstate 580/lmerstate 680 interchange, the existing and future platys of BART, and the existing and future pians of Pleasanton regarding the Interstate 690/Stoneridge .Drivallohnson Drive improvernents. The Draft EIR also needs to evaluate the design and construction of the DERWA Program fames within Pleasanton, including the expansion of the DSR.SD R Ronal Treatment Plant, pipeline placement and construction, and also to ensure that its design and construction are made in conformance with agreements between the City of Pleasanton and DSR.SD. rAc�a�a�ta�rx..saaa� .Page 3 S/S 3'Jtts� I8vabobe L s i a I NOZNtlSW31d AO AS I O'WONA LL'b t 98-b L-130 3-53 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 11--City of Pleasanton 1. The growth-inducement potential of the San Ramon Valley Recycled Water Program is discussed in Section 4.1 of the Draft EIR.As noted in that section, the substitution of recycled eater for some potable water in the EBMUD and DSRSD service areas would "free up," that potable water for existing and future customers. Both EBMUD and DSRSD have accounted for this availability in existing potable water supplies in various water supply planning documents.It is not possible to specifically identify where the "freed up"potable water would be used,but it is important to remember that it has already been accounted for and does not represent an increase in the total water supply. If recycled or potable water is made available for new developments,it is because those developments will have already been evaluated through local planning and CEQA processes for their environmental implications. The approach used for this evaluation in the EIR is consistent with CEQA, With regard to the commentor"s suggestion to eliminate as one of the options(i.e., Customer Service Caption#1) the provision of recycled water to areas not yet approved for development,DERWA decided to include this option in its facilities planning effort and the EIR to provide the DERWA Board of Directors the greatest flexibility possible in sizing and ultimately approving an overall project.Customer Service Caption#1 would represent the largest project,and it is the only option that would provide recycled water service to two areas outside the existing EBMUD and DSRSD service areas that could - potentially develop but,at the present time,are not approved for development.The EIR evaluates this option adequately and consistent with CEQA guidelines.The DERWA Board of Directors are the decisionmakers with regard to which customer service option to implement. Z. The comment is acknowledged.Modeling and other analytical approaches were developed and used in the Draft EIR to estimate the potential magnitude of salt loading impacts. As data is collected through implementation of the Program,DERWA would -- be able to evaluate the assumptions in the groundwater model,refine its salt loading estimates,and evaluate the measured impacts that require mitigation. DERWA will coordinate with other affected agencies to determine appropriate monitoring locations and protocol to support the data collection effort. In addition,during ASR testing and operation,monitoring wells will be installed and aquifer testing conducted to assess aquifer properties.These monitoring wells will be installed to assess the extent of injected water and determine if it is as predicted. 3. Please see response to comment#6 in Comment Letter 10.Real data will be gathered for current baseline conditions and conditions as DERWA implements its project,to evaluate the measured impacts and to develop effective mitigation measures.DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. 4. As indicated in the DERWA Facilities Plan,the CCCSD supply would only be a temporary"bridge" supply that would take advantage of currently available summertime treatment capacity at the DSRSD treatment plant. When the available &jcAWbsflwpRoc\WORM131786.RW1EIR#Ftx u\003.aoo 3-54 SECTION 3 COMMENT LETTERS AND RESPONSES capacity is taken up by service area flows,the CCCSD supply would become uneconomical(require construction of duplicate treatment facilities) and would be abandoned.No new capacity would be created at either wastewater treatment plant and,thus,no duplication would occur. 5. The comment is acknowledged.There is no creation of additional wastewater capacity at the DSRSD treatment plant as a result of the DERWA project.Please see response to comment#6 below regarding the changes that would occur to the DSRSD treatment plant. Capacity rights and cost sharing issues are not considered to be environmental issues under CEQA and,therefore,do not require a response in this Final EIR.The Facility Plan assumes that DSRSD will maintain its contractual commitment to Pleasanton. In addition,the CCCSD water supply option is addressed at a programmatic level in the Draft EIR.If this water supply option is selected by DERWA for implementation as part of the San Ramon Valley Recycled Water Program, additional project-level environmental evaluation will be conducted. 6. The primary changes that would occur at the DSRSD treatment plant to acconunodate the DERWA project would be to refurbish the existing filters and/or construct a new microfiltration facility,and construction of Pump Station No. 1. As noted in Section 2.9 of the Draft EIR,refurbishing the existing filters was provided CEQA review by DSRSD in 1994,and new microfiltration facilities, as may be needed for ASR implementation, are addressed at a programmatic level in the EIR,as is Pump Station No. 1. If new microfiltration or other improvements are required,DSRSD and/or DERWA will conduct the appropriate level of environmental review for those projects. 7. The Alameda County Transportation Authority(ALTA),which is managing the 1-580/680 direct connector project referred to in the comment,submitted a comment letter on the DERWA project; that letter is contained in this Final EIR as Comment Letter#15. Some of ACTA's comments reflect the same concern as this comment regarding the need for coordination between the DERWA project and the I-580/680 project.Please see responses to comments raised in Comment Letter#15 later in this document. 8. Please see response to comment#6 above regarding changes at the DSRSD treatment plant.The Draft EIR does evaluate pipeline facilities at a project level. Construction of DERWA facilities within the City of Pleasanton will,where applicable,be in conformance with contractual agreements between DSRSD and Pleasanton;pipelines constructed in City rights-of-way will be in conformance with City permitting requirements where applicable. sic4JosF\wPmcdWORM131789.RW\EIMF1NAL=3.Doc 3-55 0� COMMENT LETTER 12 ;r �rA�wrt���rc�rr�Nrrrr�rrx®tsr�r�r 'CJflAJ11 DIRECTORS P.O. BOX 5110 + 43885 SOUTH GRIMMER BOULEVARD, FREMONT, CALIFORNIA 94537 OFFICERS PHIL UTIC PHONE ?510) 659.1970 + FAX (5101 770.1793 • E-MAIL acwd(winfoiane.com JAMES D.BEARD President General Manager JOSEPH G.DAMAS,JR. RONALD PINO JIM GUNTHER Treasurer TEM ROLLISSON MARVELL L.HERREN District Secretary JOHN H.WEED October 14, 1996 Mr. Bert Michalczyk DSRSD-EBMUD Recycled Water Authority(DERWA) 7051 Dublin Boulevard Dublin, California 94568 Dear Mr. Michalczyk: Subject: Draft EIR for the San Ramon Valley Recycled Water Program This letter provides Alameda County Water District's comments regarding the Draft Environmental Impact Report (DEIR) for DERWA's proposed San Raman Valley Recycled Water Program (Program). As described below,Alameda County Water District (ACWD)has a strong interest in the Program, particularly as it may relate to any potential impacts on water quality in Alameda Creek. We appreciate the information provided to ACWD by DERWA staff regarding this program, and the opportunity to comment on this DEIR. Further,the recent formation of a technical review committee, consisting of staff from DERWA,ACWD and other agencies, represents a significant opportunity to maintain an ongoing dialogue on ways to monitor and mitigate the impacts of this project, as well as other anticipated projects in the Alameda Creek Watershed that could affect downstream uses. ACWD is a water retailer which provides potable water supplies to more than 71,000 customers in the Cities of Fremont, Newark, and Union City. The total population served by the District is over 286,000. ACWD receives its water supplies from three sources. The State Water Project(via the South Bay Aqueduct)provides abut 55%of the total supply. Hetch-Hetchy water is purchased from San Francisco Water Department and provides for approximately 30% of the total supply. The remaining 1510 of the supply comes from loom runoff from the Alameda Creek Watershed. This wetter is percolated into the Niles Cone groundwater basin through percolation facilities on Alameda Creek and adjacent percolation ponds. This water is subsequently recovered through ACWD's groundwater production wells. In order to provide a uniform water quality to District customers and reduce the hardness of the local groundwater supplies, water from the production wells is blended with Hetch-Hetchy water prior to being distributed to our customers. Because the proposed recycled water program is located within the upper Alameda Creek Watershed(which is a source of ACWD's local water supplies), ACWD is concerned with potential impacts that this project may have on downstream water quality. As you know, ACWD has had a long-term commitment to watershed protection and to assuring the health and safety of the water supplies on which our customers depend. 3-56 ACWD's comments regarding the DEIR are provided as general comments and specific comments, as listed below. General Comments 1. A significant concern to ACWD is the potential for increased salt loading in Alameda Creek due to this project and the cumulative salt loadings from other projects (existing and future) in the Alameda Creek Watershed. As pointed out in the DEIR, a comprehensive watershed management plan which fully addresses the issues of cumulative salt loading (and other water quality impacts) in the watershed does not exist. ACWD fully supports the / development of such a plan so that a comprehensive policy for minimizing and mitigating t� impacts to Alameda Creek can be established. The policies to be developed from this watershed management plan should apply to both this project and aril other existing and future projects within the watershed which may impact Alameda Creek water quality. The watershed plan should also ensure that there is a coordinated effort both to plan and to quantify the effects of different water uses and discharges within the watershed. 2. A distinction has been made between the Recycled Water Program and the Clean Water j Revival Project; the former being a program to increase the use of recycled water as a replacement for potable water and the latter being primarily a wastewater disposal project. If both are implemented,there is to be joint operation of shared facilities. There needs to be an explanation of how the separation between the distinct objectives of the two projects can be maintained when the actual operations of facilities are so closely intertwined. For example,will there be separate accounting for and auditing of recycled water flows? Further, what is to prevent the DERWA project from becoming increasingly wastewater disposal dominated,thus lessening the need to provide necessary LAVWMA pipeline capacity to meet the projected needs for wastewater disposal? Without adequate capacity to export wastewater, the salt management problem both within the local basin as well as in the subsurface runoff received by ACWD will be exacerbated. 3. At present the Regional Water Quality Control Board's Basin Plan for TDS in Alameda Creek at Niles Canyon is not being met. As described in the DEIR, this project will result in an additional increase in TDS in Alameda Creek beyond existing levels. However, the DEIR does not consider technically viable methods(i.e., reverse osmosis) that can be utilized to remove salts from the recycled water. As an example, the use of reverse osmosis Is currently included in the Clean Water Revival Program for disposal of recycled water into the Main Groundwater Basin in the Livermore-Amador Valley. DERWA should seriously consider the use of treatment which removes TDS, such as reverse osmosis, which will greatly ameliorate the in-basin salt loading problem and all but eliminate concerns for salt in any incidental recycle water drainage which is delivered downstream to ACWD's recharge facilities. Soeclfc Comments 4. Given the low permeability of the soils within the study area and the adjacency of application areas to drainage watercourses, there needs to be stringent monitoring and enforcement program established to ensure that application of recycled water conforms to specific { ,J requirements(not just guidelines)to minimize the potential for runoff. 2 3-57 5. ACWD is supportive of DERWA's commitment to installing water quality monitoring stations at strategic locations in the surface water system. These stations should be installed as soon as passible in order to establish baseline data. The stations should be well-maintained / and the data should be readily accessible to ACWD and other affected agencies. The development of the monitoring plan (i.e., location of the monitoring stations,the constituents to be monitored, and the timing of the sampling) should be developed in coordination with ACWD and other local and regulatory agencies. 6. ACWD is concerned that the potential for inadvertent release of recycled water into storm drains and creeks be minimized. What specific leak detection measures will be used to ensure these releases do not occur? DERWA should not rely on large leaks being "visible to the naked eye"as the means for detection, particularly where there are pipelines adjacent to or crossing storm channels and creeks. It should be noted that even in a welt-maintained potable water distribution system, unaccounted for water losses may amount to 5-10%. 7. Further explanation is needed of the biostimulatory effect of nutrients in the recycled water. it would appear that there may be a potential for nutrients in the recycled water to leach out (along with dissolved salts) and cause biologically-induced plugging of ACWD recharge facilities. In addition, discussion of potential mitigation measures should be provided. 8. Although ASR wells will be drilled to a depth of 500-feet and will inject water only into the deeper aquifer system,the potential exists for groundwater levels in the shallow groundwater system to be impacted (i.e., through vertical movement across the confining layer). The potential for increased groundwater levels in the shallow aquifer(resulting in subsurface flow to drainage courses and carrying with it elevated salt loads and groundwater contaminants) needs to be addressed. At present the groundwater monitoring program does not include monitoring of the shallow groundwater system. Monitoring of this system should also be included in the vicinity of the ASR wells. 8. in Table 1-3, Mitigation 3.2.7-Increased TDS in Creeks, there are two typos: "slay should be IS "salt"and"organization"was perhaps intended to be"organics°. Also in Table 1-3, Impact 3.2.7 is "Less Than Significant". But in the body of the report (Chapter 3,page 3-28)it is"Potentially Significant". Table 1-3 needs to be changed to also say"Potentially Significant". 10. The DER does not address the possible consequences of this project on ACWD's continuing efforts to meet current and anticipated drinking water regulations, specifically with respect to pathogens or disinfection by-product risks. Given the ongoing development of groundwater disinfection and outer rules by the EPA and DOHS, it would appear that this project may make the watershed more vulnerable to potential throats to public health and 13 safety. Please provide some discussion as to how such a project will or will not result in constraints and requirements being placed on ACWLYs use of groundwater supplies by State or federal regulatory authorities. In addition, discussion of potential mitigation measures should be provided. 11. As described under Mitigation Measure 3.3.1 (page 3-38), the use of recycled water for landscape irrigation will require that additional applications of the recycled water will be required to leach salts from the soil. This additional water application would not be required 3 3-58 if potable water supplies would be utilized. Please describe the impacts on additional Total Organic Carbon (TOC) loading in Alameda Creek from leaching from the soils due to the additional water applications. 12. Table 1-3, Mitigation 3.2.7(increased TOS in Creeks) states that mitigation will be provided for any significant impacts of increased TDS in creeks that may affect the potable water 15 supplies of ACWD. However, no specific mitigation measures are provided. The DER should provide a list of potential direct and indirect methods of mitigation for this impact. 13. Comments to Table 4 of Appendix D(Salt Loading Memorandum by Montgomery Watson) are provided on the attached mark-up of the table. These comments are also summarized below. (a). The titles need to be changed as marked. (b). The averages shown need to be better labeled. In the left-hand column, the title "Average Year Total" should be changed to say"Average TDS of Alameda CreekA. (c). The numbers shown as "Average Year Total" are straight averages, not weighted averages. Since weighted averages are used in the salt loading calculations, they should be shown instead of straight averages in this row. .� (d). The row labeled "Percent Change from Potable-only Irrigation Water at Buildout" refers to the percentage change in the recharge water. It should be made clear that this is the change in recharge water, and not the change in Alameda Creek. (e). It should be noted from which data these averages were calculated (i.e., the table should be footnoted as shown in the attached mark-up). (f). The monthly averages for existing TDS levels in Alameda Creek for average year rainfall conditions need to be revised. The ACWD data supplied to Montgomery Watson was applied incorrectly, and these averages need to be computed by correctly weighting all the data. Again, thank you for the opportunity to comment on this project. Very truly yours, Paul Pira ino , - Assistant General Manager 4 3-59 v � 4 S .0 Y �g a�li '� y .f ✓ i x t R i i M i. , M M1 i. ► i `i 6 i 9 • 1R i $+ ..i Y'^ Lr 44 • wls f4 ! a" :c- :fir et *60 ir 1 fi � �• r 3 3-60 SECT0N 3 COMMENT LEVERS AND RESPONSES Response to Comment Letter No. 12—Alameda County Water District 1. The comment is acknowledged. 2. The comment is acknowledged. 3. The comment is acknowledged.As described in Mitigation 3.2.7 in the Draft EIR, DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies.DERWA is committed to the development of a data collection program,and refined modeling and estimating of salt impacts through its participation in the Technical Review Committee (TRC) formed between DERWA and ACWD in October 1996,with active participation by the Regional Water Quality Control Beard(RWQCB)and Alameda County Flood Control and Water Conservation District-Zone 7(Zone 7).DERWA is currently working with these agencies through the TRC to determine data needs and to design a monitoring program,develop a consensus approach to evaluating the collected data, and to begin developing mitigations for salt loading impacts. Modeling and other analytical approaches were developed and used in the Draft EIR to estimate the potential magnitude of salt loading impacts. As data is collected through implementation of the Program,DERWA would be able to refine its salt loading estimates,and evaluate the actual impacts that require mitigation,all in cooperation with the other agencies comprising the TRC.The TRC will provide a forum for DERWA and the other agencies to work out acceptable and reasonable mitigations for actual impacts. DERWA and the other agencies can also be involved in the development of the Zone 7 Salt Management Plan(currently under preparation)and an Alameda Creek watershed management plan,which will include mitigation requirements for salt contributors. 4. The DSRSD Clean Water Revival(CWR)and DERVVA projects,if both are implemented, could be operated jointly because of shared facilities.Each project would be permitted separately through the RWQCB,and would be responsible for metering and accounting for their respective wastewater or recycled water flows,which are reportable to the RWQCB.A CWR Main Basin injection project could also be operated to mitigate some of the salt loading impacts caused by DERWA operations in the Tassajara Creek drainage area. Concerning the question regarding DERWA's project becoming increasingly a wastewater disposal project, DERWA is only able to distribute recycled water to customers connected to the EBMUD or DSRSD system(note: EBMUD and DSRSD will be the retailers of the recycled water to their respective customers). As new development occurs in the service area,additional recycled water customers will be connected and additional wastewater would be treated to recycled water quality and conveyed to the new customers.The irrigation season is typically from March to October in any year and,therefore,irrigation deliveries would not occur in the winter months.If aquifer storage and recovery(ASR)is adopted as a component of the DERWA project,then some wintertime flows will be injected into the Fringe Basin aquifer on an interruptible basis for later withdrawal during the summer irrigation sjcAUosE\waanciWORM131768.RWGR\FwAt.1003.Doc 3-61 SECTION 3 COMMENT LETTERS AND RESPONSES season.The ASR capacity is limited to approximately 1,500 AFY due to aquifer characteristics.This capacity will not be useful to DSRSD as a winter wastewater flow disposal option as those facilities would be configured by DERWA for the reasons listed on pages 4-5 and 4-6 of the Draft EIR(such as,but not limited to, the winter peaks in flow would far surpass the ability of the DERWA ASR facilities to inject recycled water). For this reason,a DERWA permitted and configured project could not replace any portion of the existing or planned LAVWMA capacity for disposal of peak wet weather flows. DSRSD will have to maintain and expand its ability to dispose of winter flows via the LAVWMA system,or other equally reliable system for wastewater disposal. In addition,as noted on pages 4-5 and 4-6 of the Draft EIR,the DERWA Program provides for seasonal recycled water use,not for year-round water storage/use.The provision of recycled water from the treatment plant can be interrupted at any time, thereby not providing firm wastewater disposal capacity.The DERWA Program also does not provide for storage capacity for peak wet weather flows.For these reasons and others, DERWA will not become"increasingly,"wastewater disposal,as suggested by the comment. 5. The comment is acknowledged. Use of reverse osmosis for the DERWA"s Program was not considered because of the cost it would add to the overall costs of delivering recycled water to customers for landscape irrigation use.The objective of the DERWA Program is to maximize the amount of recycled water in the study area to offset potable irrigation water demand,while recovering costs.The use of recycled water for irrigation use does not require it to be treated with reverse osmosis.The Clean Water Revival (CWR)project has a different objective,i.e.,one of using recycled water for groundwater replenishment,which does require that the wastewater be treated to drinking water standards (which can be done through reverse osmosis).Nonetheless,even though the DERWA Program does not include the use of reverse osmosis for wastewater treatment, DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented.by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. 6. As will be required by Title 22 and DERWA"s permit conditions from the RWQC$, application of recycled water to landscaped areas will be strictly controlled and monitored by groundskeepers.DERWA and/or its member agencies will provide training and guidance for proper irrigation techniques with recycled water to prevent excessive runoff. 7. The comment is acknowledged. DERWA is currently working with the Technical Review Committee(TRC)to determine appropriate locations for monitoring stations and the schedule for their installation. 8. Metering throughout the systems could be used to check the mass balance. During daytime hours when demand is low,tank levels could be monitored to determine if leakage or other losses are occurring in the system.There is no reasonable means of instantaneously identifying small leaks at buried joints other than by visual means and perhaps regular leak detection(acoustic)surveys. In addition,creek crossing design for pipelines will include conservative protective features that will be designed to prevent leaks from the subsurface pipeline from being undermined by creek scour or otherwise sYcAVoselwQaoc\WORK\131766.RN11EIR\ftNA11003,DoC 3-$2 SECTION 3 COMMENT LETTERS AND RESPONSES damaged.The detailed design will likely include a reinforced concrete encasement for open cut crossings and a casing pipe for trenchless crossings. 9. Nutrients in the recycled water will largely be used by the vegetation being irrigated in the DERWA project area.Through the irrigation management program,irrigators and DERWA will be monitoring irrigation practices to ensure that direct runoff of irrigation water is prevented.The irrigation water will percolate into the vegetation root zone, where most of the water will be taken up through evapotransporation.The nutrient load will also be largely taken up by vegetation as an added benefit of using recycled water. As the remaining irrigation water infiltrates below the root zone and into the groundwater table,some of the water will seep into creeks and streams,where again any remaining nutrient load will be taken up by vegetation bordering the creeks. Finally,as the water reaches the Alameda Creek recharge facilities,the original nutrient load will have been largely consumed upstream and any remaining nutrients will be highly diluted by other flows from the Alameda Creek drainage area.Past experience in the Los Angeles Basin,where recycled water is directly injected into aquifers or is infiltrated at spreading ponds without the benefit of nutrient removal through irrigation and uptake from upstream creek vegetation,indicates that clogging of the recharge facilities is not an issue. 10. The comment is acknowledged.Shallow monitoring wells will be installed during testing,and as part of final project,to assess potential water level and water quality impacts to see if they are as predicted. 11. The comment is acknowledged.DERWA discovered that due to an error during binding of the EIRs,some copies of the Draft EIR were circulated with an obsolete version of a portion of the summary table,Table 3-1,which included errors identified in ACWD's comments#11 and#12.ACWD received one of these copies and was issued a corrected version of the table. Due to this inaccuracy in a limited number of Draft EIR copies, DERWA notified all DEIR recipients and extended the comment period on the EIR an additional 7 days to allow time to review and respond to the corrected version. 12. The comment is acknowledged.See response to comment#11 above. 13. Please see response to comment#6 in Comment Letter#10. In addition,most of the water quality constituents remaining in tertiary-treated,non-potable recycled water that could be of concern in a drinking water supply would be removed and/or substantially reduced as the recycled water moves through its pathway.These constituents include pathogens,nutrients,and trace organic compounds. First,little recycled water would percolate from the irrigation areas to the groundwater. With proposed irrigation practices,most of the recycled water applied to the landscape would be consumed by the vegetation.Second,movement of the recycled water through the soil and into the shallow aquifer would provide natural filtering and chemical interactions that would remove constituents such as pathogens and organic compounds. Further,the recycled water would be diluted with the groundwater.If recycled water then resurfaces in local streams,additional natural physical,chemical and biological treatment would occur in the stream,thereby removing additional pollutants.For example,any remaining nutrients that may occur in recycled water would be used and thus removed by streamside and aquatic vegetation.Imported State Water Project water is discharged into the Alameda Creek system for transport to ACWD recharge areas and provides additional dilution for any recycled water reaching this creek.Finally,the surface water sjcA\JostiwasociWORK113i768.RMEIMFiNAL'D03.00c 3-63 SECTION 3 COMMENT LETTERS AND RESPMES - is then again recharged to the groundwater,moving back through an aquifer which provides additional physical and chemical treatment before groundwater extraction for mixing with imported surface water and treatment as part of ACWD's water supply. As clarified above,there are multiple points of additional water treatment and conditioning and dilution along the indirect pathway recycled water could follow downstream to ACWD's recharge area that provide multiple barriers to significant water quality effects resulting from upstream recycled water irrigation. 14. With recycled water irrigation, additional water is typically required to assist in the leaching of salts and other constituents from the vegetation root zone. Under normal climatic conditions,this is accomplished during the rainy season.Normal precipitation during the rainy seasons will provide sufficient flushing through the root zone to leach salts and prepare the root zone for the following summer irrigation seasons.Under certain drought conditions,there:might be inadequate precipitation to completely flush the salts from the root zone.When these conditions persist,one method of accomplishing the leaching is to over-irrigate with recycled water by about 2 percent for very salt tolerant species, 13 percent for salt sensitive species, and up to 30 percent for very salt sensitive species.These percentages reflect increases over the most efficient irrigation practice,which is to apply only enough water to provide for the evapotransporation requirements of the vegetation;this is an ideal practice not usually achieved by most irrigators,who normally tend to over-irrigate.Considering the percentage of sensitive to very sensitive species in the project area,the amount of over- irrigation will be small in comparison to the total applied irrigation water. The resulting additional total organic carbon(TOC)load will be small and a large percentage of the TOC load will be taken up as water passes through the root zone into the groundwater table,then seeps into the surface creeks and travels downstream. 15. The comment is acknowledged.Possible salt mitigation measures for impacts to Alameda Creek may include,but would not be limited to,the following: • Demineralization treatment of a portion of the recycled water to lower TDS to acceptable levels. • Purchasing additional imported water to offset additional salt content of the groundwater supply. • Implement wellhead demineralization for groundwater wells. • Implement water treatment plant demineralization. A text revision has been made to Mitigation 3.2.7 in the Draft EIR to identify the above list of potential methods for mitigation of TDS impacts to creeks. 16. Table 4 of Appendix D has been revised per the suggestions in this comment. A new Table 4 is included in this Final EIR as a text revision to the Draft EIR. s.rcWos€lwpwoo\',NOFAi3i768.RW\E[R\FiNALU3,00c 3.64 COMMENT LETTER #13 UZ 1 / San Ramon CITY OF SAN RAMON 2122 RAMON P o soOxX 5 s 1 t 4 4a SAN RAMON.CALIFORNIA 94583 ,5101 175.2 zoo - - FAX 15101 800.1436 October 14, 1996 DERWA Steering Committee Attn: Bruce Webb 7051 Dublin Blvd. Dublin, CA 94568 RE. San Ramon Valley Recycled Water Program- DEIR The City of San Rarnon,has the following comments regarding the above: 1. page 2-25, Figure 2-10 The City of San Ranson would Iike to have input regarding mitigating visual impacts associated with ASR Well, Storage Tank,and Pump Station facilities. `�.:✓ 2. page 2-29 Alternative Transmission pipeline alignment alternatives. While all transmission alternatives will impact the City of San Ramon,the City prefers the SPRR- Bollinger Alternative since it has the least impact on City streets of the alternatives identified. The City would like DERWA to evaluate a transmission and distribution corridor along the PG&E ROW / to Dougherty Valley. This alternative would be preferred over Old Ranch Road. Also, was the Central Contra Costa Sanitary District option of installing a reclaimed water pipeline in conjunction with their Dougherty Valley wastewater tunnel evaluated by DERWA? 3. page 2-44, Section 2.6.1,Construction Excavated material that is contaminated shall not be used for trench backfill,but shall be disposed offsite in accordance with appropriate legal requirements. The pre-positioning of large diameter pipes along the alignment during construction may be constrained by local conditions(ie traffic,roadway width,etc.). Actual construction operations shall be coordinated with the appropriate local jurisdiction as part of the encroachment permit process. CITY COUNCIL 2752320 AOMNIVIIATW2 S]NVK53i 275.2322 POUCd.2752270 LHCipv2N0NG 275-]250 CITY MANACCR:275-2330 VUBLIC SERVIC2S:273.3]i0 PAW A COMMUNITY 524VW15:]73.2390 PIANNNC:27'5.2210 CtTY C]20R•275-2250 TIILV4V RTATiON:2752210 C0MMUN4rV C0MJIU']75]300 SOWING 1NSPfCTbN:]73-]220 51NIOR C2NT2R 275]316 StOMOPMSNT:275.]2!0 3-65 4. page 2-45, first paragraph "Recycled water customers will be required to submit informal monitoring reports to DERWA and/or its member agencies. The self-monitoring program and reporting requirements may contain the following requirements: Recycled water sampling and analysis Groundwater sampling and analysis Monitoring of water reuse sites Reports to be filed with the RWQCB" page 2-48,first paragraph "With the issuance of a blanket permit. the responsibility to ensure compliance with regulations resides with the recycled water supplier and/or retailer. which establishes and regulates customer requirements and prohibitions." Based on the above statements, it is not clear as to who will be responsible for the self-monitoring program and reporting requirements. This responsibility should rest with DERWA or EBMLJD as the water supplier for San Ramon. If this responsibility should become the responsibility of the City, there are indirect impacts associated with using reclaimed water that should be addressed. 5. page 3-13,fourth paragraph The City of San Ramon and its residents view South San Ramon Creek as a resource. During FY 1996/97,funds have been authorized to prepare a greenbelt creek study to enhance South San Ramon Creek. The City is currently completing construction of a creek enhancement project within a section south of Montevideo Drive. Any impacts that result from the use of recycled water(increase salt loading,reduction in groundwater flow to the creek,etc.)shall be mitigated. 6. page 3-19,Zone AE For the SPRR alignment,please clarify if it been determined whether the transmission pipeline will be on the east or west side of South San Ramon Creek. if it is on the east side of the creek,the City has completed a hydraulic study that indicates that raising the creek levee by a few feet may take this area out of the flood zone. 7. page 3-29,Mitigation 3.2.4-Surface Water Quality Degradation from System Construction The City of San Ramon,as a permitted stormwater agency,will require a copy of the S WPPP and confirmation of its approval from the RWQCB for construction within the City. 3-66 8. page 3-30, Mitigation 3.2.7 - Increased TDS in Study Area Creeks Please provide information regarding the location of the water quality monitoring station in South San Ramon Creek. Will it be located within the City of San Ramon? If it is,the City would like to receive monitoring information. 109 9. page 3-34, second paragraph "The deleterious effects of using irrigation water with high salinity concentrations are usually seen through substantially diminished plant growth and possibly plant mortality." As a condition of using reclaimed water, DERWA or EBMUD as the water supplier shall provide for the replacement cost of dead plant material and shall provide for plant replacement during a plant warranty period following the transition to using reclaimed water. 10. page 3-37, fifth paragraph "To avoid excessive salt accumulation,more irrigation water than actually needed by the vegetation for evaportranspiration may be applied." This may have an impact on irrigation systems and will have to evaluated on an individual basis. Some irrigation systems are at their limit with respect to irrigation controller capacity and programming flexibility and water supply pipe sizing. Conversion to recycled water may require upsizing of irrigation piping or changing of controllers. This should be covered by DERWA or EBMUD as part of the retrofit cost. 11. page 3-44,Mitigation 3.4.3 - Slope Instability at Storage Tank Sites Slope Instability considerations should extend to the location of access roads to the tank sites that may cross areas of unstable slopes. 12. page 3-49, first paragraph The City and East Bay Regional Park District will be constructing a paved trail from Pine Valley Road south to the Contra Costa/Alameda County line in FY 1996197. 13. page 3-86, San Ramon Construction requirements will be determined on a case by case basis. Boring may be required at major roadway sections/crossings because of traffic disruption. Hours of construction may be limited due to peak hour commute. Closure of roadway to traffic is to be avoided. '14 Major surface improvements are currently underway for Alcosta Boulevard between 1680 and Stagecoach and on Village Parkway. 3-67 14. page 3-88,third paragraph The pipeline will be installed in an open trench in the street...." Construction requirements will be determined on a case by case basis. Boring may be required at j 5 major roadway sections/crossings because of traffic disruptions. Hours of construction may be limited due to peak hour commute. Closure of roadway to traffic will be avoided and access to property will be maintained at all times. 15. page 3.90,Mitigation 3.8.1 - Disturbance of Newly Surfaced Roads Installation of transmission and distribution piping will have a major impact on the City due to the number and sections of roadways involved. While the City has limited disturbances to newly- surfaced roads,there will be a cumulative impact that must be addressed. This cumulative impact 1fi will be dependent on the timing and location of the installation of the transmission and distribution piping system. The City is currently reviewing its street cut policy. DERWA will need to comply with the requirement in effect at the time of construction. 16. page 3-130,Mitigation,3.10.3 -Exposure to Contaminated Soil During Construction Contaminated soil encountered during construction will be disposed offsite in accordance with { �? hazardous waste laws and shall not be used for trench backfill. I 17. page 3-150, Mitigation,3.13.1,Project Construction Could Affect Air Quality Specific requirements would be specified as part of the encroachment permit. $ 18. page 4-7,.Future Utility Installations Along Pipeline Routes The amount of in-street utilities work that would be required as a result of the Recycled Water Program (transmission, distribution, and other facilities) will be substantially greater than the routine, ongoing work activities experiences by the City. As a result, there is a substantial cumulative impact associated with disruption to the City and its streets. This impact will be affected by the tuning and progression of the facilities installation. The City would work with DERWA and E13MUD to coordinate all construction activities within the City 19. In the future,the City of San Ramon may provide for landscaping along the Iron Horse Trail. If the SPRR alignment is selected,provide system flexibility for future connections. 20. Regarding Tank Site No. 1,the City has received applications from Davidon Homes for Old Ranch Estates II. 21. page 3-70,Mitigation-Land Use Chapter It appears that Tank Site No.I is located within a designated major ridge setback,within which any development'is regulated by the City's Ordinance No. 197. Further analysis should be conducted 3-68 to determine consistency with development standards set forth in this ordinance,and if inconsistency { is found,appropriate mitigation should be recommended. I .•� 22. page 3-80,Impacts-Noise Chapter lnpact 3.7.2 describes noise levels up to 90 dB at 3 meters from the pump stations and ASR well pumps. However,no other noise description is given. Is the noise continuous(i.e.,24 hours a day)? 23 Does the noise diminish as distance increases? What are the characteristics of the noise(e.g.,pitch)? 23. page 3-81,Mitigation-Noise Chapter Mitigation 3.7.2 states that pump stations will be enclosed in structures designed to minimize noise to acceptable levels. "Acceptable noise levels" should be clarified. Acceptable according to what standards? I 24. pages 3-133 through 137 - Cultural Resources Chapter Paleontological resources have been previously discovered in the vicinity of tank t1. Appropriate 25 mitigation should be noted. 25. pages 3-139 through 142-Aesthetics Chapter Impact 3.12.2 indicates that tank:t 1 does not appear to be within a major ridge setback; this should be confirmed with the San Ramon planning Department. 26. Given the proposed locations of tanks ti and t2 do not meet City standards(both on slopes greater than 20%and within ridge setbacks pursuant to the City's RCPZ map),mitigation ��► should be included that sites these tanks in locations that are consistent with City Ordinances. Thank you for the opportunity to review the DEIR. If you have any questions, please call John Harper(275-2229)or myself(2'75-2331) Sincerely, �e Fukuda City Engineer r.�s�w�sa.ta� 3-69 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Leger No. 13--City of San Ramon 1. The comment is acknowledged.DERWA facilities that are located within the City of San Ramon will obtain all required permits from.the City.In addition,the storage tanks are addressed programmatically in the EIR;therefore,additional project-specific environmental review will be required for those facilities,which will provide the City with another opportunity to provide input on visual impacts of storage tanks. 2. The comment is acknowledged.The SPRR-Bollinger alignment alternative is the recommended alignment in the Program's Facilities Plan. The PG&E power transmission line corridor and the possibility of installing a DERWA recycled water pipeline in conjunction with the CCCSD wastewater tunnel in Dougherty Valley were not evaluated because sufficient information was not available at the time of Facilities Plan preparation.These alignment options could be considered during the subsequent stages of the project,if the DERWA Board of Directors so directs.Additional environmental review for these facilities would be required. 3. The comment is acknowledged.DERWA will work closely with the City of San Ramon to coordinate construction activities within the City. 4. The comment is acknowledged. DERWA will work closely with the City of San Ramon to coordinate construction activities within the City. 5. Self-monitoring and reporting requirements will be a part of the permit from the RWQCB.The Facilities Plan includes appendices consisting of the blanket and project permits for other local reclamation projects.Generally,the recycled water producer (DERWA or the retail agencies)will be responsible for reporting and monitoring, possibly with customers being responsible for some of the monitoring and subsequent reporting to the producer,as determined by the producer. 6. The comment is acknowledged. Please see response to comment#6 in Comment Letter #10.As noted in Mitigation 3.2.7,DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda.Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. 7. The precise location of the pipeline within the former SPRR right-of-way has not yet been determined.This will be determined during the design phase of the project. DERWA will coordinate the routing with the City of San Ramon and other affected agencies. 8. The comment is acknowledged. DERWA will provide a copy of the Stormwater Pollution Prevention Plan(SWPPP)to the City of San Ramon. 9. The precise location of the monitoring station in South San Ramon Creek has not yet been determined.Water quality monitoring data will be made available to the City of San Ramon and other interested agencies. 10. The comment is acknowledged.The issue of replacement costs for vegetation are not considered "environmental"issues under CEQA and,therefore,do not require a response in this Final EIR.Nonetheless,DERWA understands that the costs associated ssaAl3osElwPRoaWORM131708.RMEIWiNAL\103.00c 3.70 SECTION 3 COMMENT LETTERS ANO RESPONSES with implementing the San Ramon Valley Recycled Water Program are important to existing and future EBMUD and DSRSD customers,and each agency will work closely with their respective customers to address cost concerns,including those related to implementation of mitigation measures. 11. The comment is acknowledged. The issue of retrofit costs for existing irrigation systems is not considered an"environmental"issue under CEQA and,therefore,does not require a response in this Final EIR.Nonetheless,DERWA understands that the costs associated with implementing the San Ramon Valley Recycled Water Program are important to existing and future EBMC.JD and DSRSD customers,and each agency will work closely with their respective customers to address cost concerns,including those related to implementation of mitigation measures. 12. The comment is acknowledged. Text revisions have been made to Impact and Mitigation 3.4.3 in the EIR to include access roads to tank sites as a slope instability concern. 13. The comment is acknowledged. A text revision to page 3-49 of the ETR has been made to identify the trail referenced in the comment. 14. The comment is acknowledged.DERWA will work closely with the City of San Ramon to coordinate construction activities within the City. 15. The comment is acknowledged.DERWA will work closely with the City of San Ramon to coordinate construction activities within the City. 16. See response to comment#14 above. Cumulative construction related impacts are discussed in Section 4.2 of the Draft EIR. 17. See response to comment#3 above. 18. See response to comment#4 above. 19. The comment is acknowledged.Cumulative construction related impacts are discussed in Section 4.2 of the Draft EIR. DERWA will work closely with the City of San Ramon to coordinate construction activities within the City. 20. The comment is acknowledged.The distribution system will be designed to provide flexibility for future connections for Iron Horse Trail landscaping. 21. The comment is acknowledged.Tank Site No. 1 is not proposed to be located within the residential portion of the proposed Old Ranch Estates II subdivision,but may be within its open space area. 22. Storage tanks are addressed programmatically in the EIR because specific sites and design criteria have not yet been determined.As noted in Mitigation 3.12.2,additional project-level environmental review will be required for storage tanks. DERWA will work with the City of San Ramon to minimize visual impacts of tanks. 23. For above-ground pump stations associated with the recycled water distribution system, typical pump motor noise would be approximately 90 dBA at 10 feet from the pump;the pump noise diminishes as distance from the pump increases. This noise level will be reduced through design of the enclosure structure to at least the levels required by the sjd&losFiwpRoclwORK\131768.Rw1EIR*iNAL\003.wc 3.71 SECTION 3 COMMENT LETTERS AND RESPONSES Contra Costa County noise ordinance.The pump noise is only generated when the pump is actually pumping recycled water through the system. For ASR wells,all well pumps would be submersible.There is essentially no noise associated with the operation of a submersible pump; therefore,there would be virtually no noise impacts associated with ASR operation. 24. "Acceptable levels"means those noise level standards established by the local jurisdictions within which the facilities would be located.A text revision to Mitigation 3.7.2 has been made to clarify this point. 25. The cultural resource analysis prepared for the EIR did not identify paleontological resources in the vicinity of tank site T1.Nonetheless,Mitigation Measure 3.11.2 provides for site reconnaissance before construction and appropriate mitigation if any cultural resources are discovered. 26. Please see response to comment#22 above. 27. Please see response to comment#22 above. sicA\J E€wpHm\WORK\131788.RW\EIRkFINAL\003.DOC 3-72 COMMENT LETTER # 14 4, taft of Caldomia 4 GOVERNOR'S OFFICE 9F PLANNING AND RESEARCH •,,r " 1T'400 TENTH STREET ��� PETE WILSONSACRAMENTO 95914 LEE GRISSOM p4RECfOR GOVERNOR October 15, 1996 BRUCE WEBB DERWA 7051 DUBLIN BOULEVARD DUBLIN, CA 94559 Subject:. DERWA RECYCLED WATER PROJECT SCH #: 96013428 Dear BRUCE WEBB: The State Clearinghouse submitted the ,above named environmental document to selected state agencies for review. The review period is closed and none of the state agencies have comments. This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please call at (916) 445-4613 if you have any questions regarding the environmental review process. when contacting the Clearinghouse in this matter, please use the eight-digit State Clearinghouse number so that we may respond promptly. Sincerely, oeANTERO A. RI"VASPLATA Chief, State Clearinghouse 3-73 yt7W 1:iW16 arms or oaarieetgii ao rvawsrees.naratmaar tatiesnMt.tree 1. rrat.oeritir San Ramon Valley RecySlad Water Program _ p,My,BSFtSD»SStdt7D Recycled Water Author=lt two", ,�Btuce Webb srrMrt�am+si 7f351 Dub lfn Boulevard b.,mgr, x.aLowi Alameda 7d.rip, 94568 s,i smart J5,10) 551-7230 x 110 ANUM.Lom 4, OXAWAlamedaa/Contre Costa w,•aityrolr.Muty,J2tl�Lq- San E�mon7 Danv le.6 at,a 40 ANEVA w. at it. etim rK., fll8 ttsackhawk pubm- rot Mata&..""'t ... . w Cit.r meerwttt ttUme roue gy, oummnityt . W"r. t. aitwAa.ai. a.ate+! 5gpk -68fl_o + 1-ivermore 0•Mea..,_ d. usiasar of creeks 7. wrm 3T 1. below 015 .. 1iGi Cs,,�„4Meta1 limn tv"ta M.._,._AM.id+CeLA11 Unit• #arm 01.__.dw Ot._._Xw rdmwt - 02. mi.rt. 0S._,..Carly Con 41.1-JCc 01._..WWQ Otan lmnf. hC96i as.___im Via 06,___mm 04.,,...,JWGri#140 05. 04.-i,praft!SII 05._„kMaatim Aer.L-o0 wem - - aiol1r„Ll 0r._$aciti0 putt 04._L+e+fttW' 34./t. 05. Ux britt am MM.m 07._C=WVity pan aat.M-_._ _._- -__-_.ampiartat_ _ _! 06,,,,,,,PA&Fm+tlawMnt 05,_1Lam+t+r Makti M, mm Aft Met 00. a 06.___„S9rt4Artsmenm ryPmi. us II4..,,.._.1t0i U.,,,.CESS 10, 0isia4ft 07.-,„lttntmy, w+Mt+t. 1 ar.dlYiaimn,NYarl 10.__Kuu 12._U M@.InCt W,etc.! 04. path 01.•__,_&mala tr.W.mtt, 'iYDt.r.,.. :1._0011%.rmawrnt 1S..-,.roue not pm 10, ocr h"ted 14.__..1'irrl[C awd 13.AWN"is Pxw0cw. L.--jothlri 1b, swt• 14._X„oeat..j,jaXQj4 Water Supply 10.staeoitM,63„ jcuare miles U.XMLJWAJ=WM unk. 12. 15. 84p4e aywt n..1t_Maar Grolier . 01.'{_jaatMW"1*ual 00.X_.3'1a.d4WtnuM# ia.�j'„Awwt CaPat,tY 14.,,ay,}msar ovpiy 02._X_�Wtoawrai Lard 03...X-..gwloOfUMCdMie M.. -Amro n..x..Mtr3rn *4%r1m IIs.L-Ur 0ality 14.-,.LatMf*wvq saw" it.,,,)(,,,lou tmwa a.,., Vaeuto 04. ,,,J,acnMra3ogiat{/aiatatl+ati 11..mJturtais it._.,.Solid Watt V._L_40 utit Ln3+tL,W 05..,...,CUMAL Lana tS.,$._".t 20.,�[.ruMirJWurdaa 21.„ „j#.matfiraatt 1.asfmMe 04. __AQWWAiC 11.: -Rioue Yen e" U.X T.*ffkCVUrwittlan U.,,L,0X"taw IW- 07.g-•Sirs smato 14..,_Admis SS._X,,Ytyrtar. 30._x_MWV4zQUAdxA.ry 11. man talpcnai rto"L a unk. RAU f unk. 7ra4 f 14. &Area has a full range of urban development including residential. commercial, office, industrial, schools, parks, ate. is. mummAnx=zat The Recycled Water Program is a recycled water supply project with the objective to maximize recycled water delivery in the study area to offset potable irrigation demands. while recovering costs. The Program includes the treatment, distribution, storage, and use of recycled water meeting Title 22 Stats requirements for landscape irrigation in the study area. Proposed users include parks, schools, golf courses, commercial areas, common areas, and roadway medians. Area creaks include So San/Ramon, Alamo, Tassajara. and Alameda Creaks. i4. Lemmas or I"mics aslaataramaw F, ,+•.s.�i t1.d nim,Au en ?t. 9„3�1.{,,_ State Clearmshouse Contact: Ms.Angel Howell Project Seat to the fonowitsg Mate Agentits (4!6)445.0613 �( Ralourm 9tatdCom sser Svcs State Review Began: Boatia; General Services COS"Comm �CAVEPA Dept,Review to Agency Coastal Coamv ARB Colorado Rvr Bd CA Wane Mgmt ad Agency Rev to SCH - \_ x Conservation �SWRCB:Gtsnta Ct fa n(A r Fish 6c Gama # _SWRCB: Delta SCH COMPLIANCE - tK K V(�,��� Delm Protection Comanimion Forestry SWRCB: Wtr Quality parts A R HP SWRCB: Wtr Rl&U Please sore SCH Number an ell Camatests Reclamation Reg.WQC8 N 96013 028 DWR Pluses forward tate comments Alrectly to the OES YtWAdlt Carrectisas [.taut Agency Bear Tramp Hoag Corrections, Aeronautics Independent Comm � _CHP _Energy Comm AQMDIAPClx (Resources` >� Caltrans M _ T7AHC Treat Pluming PUC Homing A Devel _Sante Mn Mau& Hsahb d.Welfars ^�( Stara Lands Comm Drinking H2O Tahoe Rgl Plan -Medical Went �Otha: 3-74 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Leger No. 14—Governor's Office of Planning and Research 1. This comment letter confirms that DERWA has complied with the State Clearinghouse review requirements for draft environmental documents,pursuant to CEQA.The letter indicates that none of the state agencies that received the Draft EIR for review submitted comments to the State Clearinghouse.'Therefore,no response to this letter is necessary. The State Clearinghouse will receive a copy of this Final ETR and the Notice of Determination,which will be filed with the Alameda County Clerk after the DERWA Board of Directors has certified the EIR and approved a project. s.icAWosc-lwPRoclWORMI31789_RMEIR\FiNA6003.00c 3-75 COMMENT LETTER # 15 October 15, 1996 Alameda Bruce Webb County 'kansportation DERWA Authority 7051 Dublin Boulevard Dublin, CA 94568 Dear Mr. Webb: 1401 Lakeside Drive Suite 600 Comments on D»IR for the Oakland,California San Ramon Valley Recycled Water Program 94612-4305 Telephone 510!893-3347 We thank you for giving the Authority the opportunity to review the above Facsimile document. The Authority fully supports your effort to implement a recycled f 5101893-6489 water program. E-Mail ACTA2002@aol.com We are the funding agency for the I-580/684 Direct Connector Project Keith Carson (DCP) and Caltrans is the project sponsor. The project cost is approximately Chairman $120 trillion and includes the construction of a south to east direct connector Supervisor Markvis ramp, local access ramps at Amador Plaza .Road and Village Parkway, vide-Chairman reconstruction of the off-ramp at Hopyard Road. It also includes Mayor,Union City reconstruction/realignment of local streets including Johnson Drive. Edward 1t.Campbell Supervisor Wilma Chan We have obtained environmental clearance for the project and are embarking 2 Supervisor on right-of-way acquisition and finalizing the design plans. Construction is Mayor, Hayward coward Mascheduled to start late 1997/early 1998 with completion scheduled for 2002. Mayo Nora Davis Mayor,Emeryville We are therefore concerned about any impact this program may have on the rlihu M.Harris I-580/680ro ect. In articular. the following areas should be more Mayor,Oakland p � p �; Mary V.King thoroughly addressed: Supervisor Gag Steele Section 2.5.3- Groundwater Table Vincent J.Harris The DCP includes a number of excavations and construction of major Executive Director overhead structures. The effects of a changing water table on the ..,,w. construction operation (need for grouting, additional shoring etc.) and the integrity of structures and road pavement should be addressed and appropriate mitigation measures identified. ALTA means Action 3-76 Comments on DEIR for the San Ramon "Valley Recycled Water Program Page 2 Figure 2-11 shows ASR wells F-1 and F-2 in the proximity of the DCP project. Are i( alternate sites further away from the DCP site available? I Section 2.5.4- Transmission Options The document shows that the main transmission line will commence from the DSRSD WWTP traveling in a northerly direction to go under 1-584 to serve various areas on the north side of the freeway. It also describes the various alternative alignment in/around Johnson Drive. Under the DCP project, a section of Johnson Drive from east of Alamo Creek to Hopyard `�, Road will be re-aligned and new freeway ramps at Village Parkway added. Any new pipeline, including the bore-and-jack section under 1-580, should be designed to be compatible with the final DCP configuration and/or construction phasing. In addition, any construction contract should include languages for the pipeline contractor to work around and coordinate/cooperate with the DCP contractor. Section 2.6.1- Construction The timing and phasing of the construction of the Recycled Water Program may have significant impact on the DCP project. The 95% plans for the DCP project have been completed and there is no reference to any (recycled water) pipeline or construction as no information is yet available. It is highly likely that both the DCP and the Recycled Water contractors would be working in the same area at the same time. The environmental document should address the measures necessary to avoid delay and contractual claims on the DCP contract. Section 2.7- Relationship Between D►ERWA Program and DSRSD Clean Water Revival Project The document shows that there are a number of common/similar elements between the two projects. We would therefore-like to have the opportunity to review and comment on the environmental document for tt project when it becomes available. Chapter 3.2- Surface Water and Drainage This section states that the dry weather flow in some creeks will decrease due to pumping g 3-77 Comments on DEAR for the San Ramon Valley Recycled Water Program Page 3 of groundwater. if there is recharging of groundwater during the winter months, will that lead to additional flow in creeks and other drainage facilities? If so, will that require any upgrading of such facilities? During the design of the DCP, substantial effort was made to address hydrology and potential flooding problems. We would therefore be very concerned over any project that 9 contributes to additional run-off. As the project will affect Zone 7, the Cities of Dublin, Pleasanton and Caltrans, we assume fi 0 that the DEIR has also been sent to these agencies for their review. As we described earlier in this letter, there are a number of areas where the two projects ' may potentially conflict. It will require close coordination amongst the various agencies and we look forward to working with you to achieve successful completion of our fi fi respective projects. If you have any questions on any of the above comments, please do not hesitate to call Christine Monsen or Francis Lo of this office. Sincerely, *71 nt J. Harris Executive Director cc.: Pat Pang, Caltrans Rubin Woo, Caltrans Tom W'intch, Greiner, Inc. Christine Monsen, Deputy Director Francis Lo, Transportation Engineer 3-7s SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 15—Alameda County Transportation Authority 1. The comment is acknowledged. 2. The comment is acknowledged. A sentence describing the Direct Connector Project (DCP)has been added as a text revision to the first paragraph on page 3-83 of the Draft EIR. 3. The preliminary design and sizing of the ASR component of the project is intended to minimize potential water table impacts. If potential impacts appear greater during ASR testing and/or operation of final facilities,then mitigation actions will be taken, potentially including the reduction of injection rates. 4. Alternative ASR well sites may be available.However,the sites identified in the Draft EIR were selected because they are on the most readily available public lands. If DERWA proceeds with ASR as part of the recycled water program,it will coordinate with local jurisdictions and ALTA on the siting of ASR wells F1 and F2, as appropriate. 5. The Facilities Plan prepared for the project represents a preliminary engineering effort. Final design activities will ensure that the project is designed to be compatible with the final DCP configuration and/or construction phasing. 6. The comment is acknowledged.DERWA acknowledges that it is possible that both the DCP and the recycled water project will be under construction at the same time,and both projects may be working in the same area. DERWA will coordinate to the greatest extent possible with other construction activities such that delays and contractual claims are avoided or minimized. 7. The DSRSD Clean Water Revival (CWR) Draft EIR was available for public review from September 3 to October 25, 1996. DSRSD distribution records indicated that a copy of the Draft EIR for CWR was sent to ALTA on September 3, 1996. ALTA did not submit a comment letter on the CWR EIR. 8. As noted in response to comment#3 above,the preliminary design and sizing of the project is intended to minimize potential water table impacts,including impacts to creeks. If potential impacts appear greater during ASR testing and/or operation of final facilities,then mitigation actions will be taken,potentially including the reduction of the injection rate.Upgrading or improvements to creek facilities are not anticipated with the DERWA project. 9. The comment is acknowledged.As noted in the Draft EIR,the project involves landscape irrigation with recycled water as a replacement for potable water. As such, the project will not contribute to additional run-off. 10. All local jurisdictions,including Dublin,Pleasanton,San Ramon,and Danville,received copies of the Draft EIR,along with Caltrans and Zone 7. 11. The comment is acknowledged. DERWA will coordinate closely with all affected jurisdictions and projects,during ACTA's Direct Connector Project,during final design and construction of the project. s,idYLZSE\wplio6WORK131788.RMEIR\FwAL'1003.Dm 8.79 Contra Public Works lief .COMMENT LETTER # 16 Costa 255 Glacier Drive County FAX: California 94553.4897 Milton F'ung isek enng FAX: (510)313.2333 Telephone: (510)313.2000 Patricia R. McNamee October 16, 1996 Deputy-OPerattons Maurice M. Shiu Deputy-Transportation DSRDS-ESI11 UD Recycled Water Authority S.Clifford Hansen 7051 Dublin Boulevard Deputy-Administration Dublin, CA 94568 RE: San Ramon Valley Recycled Water Program Draft Environmental Impact Report Gentlemen: We have reviewed the Draft Environmental Impact Report for the San Ramon Valley Recycled Water Program and have the following comments: We are pleased to note that, in addition to the standard damage to roadways resulting from the installation of transmission and distribution pipelines, the DEIR also recognizes that heavier than normal vehicular wheel loadings can be damaging to local streets. The latter issue, however, is not fully addressed as indicated below. Page 3-88, third bullet - The "movement of heavier vehicles would cause substantial ` damage or wear of public roadways" is considered to have a potentially significant impact. However, the impact and mitigation summary in Table 3-19, page 3-92, only discuss disturbance to newly sUdjC&d roadways. This impact and mitigation should be expanded to include disturbance to all roadways impacted by the project. Careful routing of heavy equipment transport and materials transport would help to limit the damaging effect of heavier vehicles on roadways not designed for such loadings. If you have any questions, please contact me at (510)313-2382 or Francis Lee at (510) 313-2280. Very truly yours Dwell Tunison Senior Civil Engineer Transportation Engineering LT: Lrs cc: M.Shiu,Deputy PWD Director J.8ueran,Assistant PWD Director,"transportation 3-80 SECTION 3 COMENT LETTERS AND RESPONSES Response to Comment tetter No. 16--Contra Costa County Public Works Department 1. The comment is acknowledged.Text revisions have been made to Impact 3.8.1 and Mitigation 3.8.1 on page 3-90 of the Draft EIR to address disturbance to roadway surfaces from construction-related truck traffic. SCCA1JostlwPnc\WORK\131786.RMEIR1 lf4ALU3.00c 3'81 STATE OF SAL#f # #A«-MAtFM AND WELFARE AGENCY O1 MENT LETTER # 17 DEPARTMENT OF HEALTH SERVICES 21S1 BERKELEY WAY BERKELEY, CA 9470A-1011 October 17, 1996 Mr. Bruce Webb -- - DERWA 7051 Dublin Blvd Dublin, CA 94568 Dear W. Webb: Draft Environmental Impact Report for the Sun %amon Valley Recycled Water Program State Clearinghouse leo. 96013028 Dublin San Ramon Services District/East Bay Municipal Utility District Recycled Water Authority(DERWA)-W0190001-702 The Drinking Water Field Operations Branch has reviewed the subject Draft Environmental Impact Report(DEIR.)and offers the following comments. 1. The DEIR identifies wastewater from the City of Livermore as a source of supply for the Recycled Water Program.(page -20). This source of supply also contains wastewater from Lawrence Livermore National Laboratory ,.- (LLNL)and Sandia National Laboratory. Both facilities are national energy laboratories conducting research that uses hazardous materials. Please describe the additional monitoring and controls for the LLNL and r Sandia waste streams in this source of supply. 2. The DEUL does not describe in detail the cross-connection control program for the recycled water transmission and distribution system(page 2-34). Such a program is a requirement of Section 4017 of the Health and Safety Coda,and Title 17, California Cale of Regulations(CCR.). In addition, there is no description of how DERWA will maintain cross-connection control when it is retrofitting existing irrigation systems to use recycled water. 3. The Recycled dater Program.transmission and distribution systems shall be designed, constructed,and operated ger Titles 17 and 22, CCR.(pages 244 and 45). Please be advised that the East Bay Municipal Utility District(EBMUD),an agency in DERWA, does not currently maintain a cross-connection control program that meets the requirements of Title 17, CCR.. Thus,the Department will be unable to approve 3-82 Mr. Bruce Webb October 17, 1996 Page 2 of any DERWA projects until EBMUD corrects this deficiency and the public water supply is adequately protected from backflow from recycled water. �..�.� Should you have any questions or comments, you may contact Mr. John Andrew at(510) 540-3227. Sincerely, Clifford L. Bowen, P.E. District Engineer San Francisco District Drinking Water Field Operations Branch cc: Environmental Health Department Alameda County Health Agency Environmental Health Division Contra Costa County Health Services Department Mr. Michael Wallis Director of Operations and Maintenance East Bay Municipal Utility District FO Box 24055 Oakland, CA 94623 3-83 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 17—California Department of Health Services 1. Wastewater from the City of Livermore is a potential source of supply for the DERWA Program.Wastewater flows to the City of Livermore treatment plant,which includes flows from.Lawrence Livermore National Laboratory and Sandia National Laboratory, are monitored and audited by the labs and Livermore to ensure compliance with NPDES permit requirements.Livermore has its own industrial permitting program under EPA and RWQCB requirements,and ensures that wastewater from both labs is in compliance with their individual permits.In addition,wastewater supply from. Livermore to the DERWA project is evaluated programmatically in the EIR. If Livermore supply is used for the project,additional project-level environmental review would be performed. 2. The comment is acknowledged. The cross-connection control program has not yet been developed and will be a part of the subsequent phase of the project. All service connections for the recycled water system will be subject to review by DOHS and will meet the requirements for preventing cross connections. I The comment is acknowledged. As required by Title 22,an Engineer's Report containing information on how the project complies with Titles 17 and 22,will be prepared for the project and submitted to DOHS. 4. The comment is acknowledged. EBMUD has drafted a backflow prevention program that is scheduled for approval and implementation in 1997.DERWA acknowledges that an EBMUD backflow prevention program must be in place before any DERWA facilities are constructed and operational. 6jGW0s6WPR7C1WORK1131768.11W1EIRtiFNALN003.00C 3-84 COMMENT LETTER # 18 D ; October 21, 1996 Mr. Bruce Webb DSRSD-EBMUD Recycled Water Authority (DERWA) 7051 Dublin Blvd. Dublin, CA 94568 Re: Draft Environmental Impact Report San Ramon 'Valley Recycled Water Program Dear Mr. Webb: Thank you for providing the Town the opportunity to comment on the above-referenced Draft Environmental Impact Report(DEIR). The Town of Danville submits the following comments related to the potential environmental impacts associated with the project which are discussed within the DEM, and requests that these concerns be addressed in the Final EIR. GENERAL The Town believes that the proposed recycled crater program is a valuable project for the community. However, we feel that the following comments need to be addressed in order to protect the Town's short term and long term interests related to irr�pacm potentially generated by the project. ` Many details of the proposed project, related to the actual location and design of the infrastructure, are still at a conceptual stage. Because of this, the Town assumes that additional environmental reviews will be required to evaluate potential impacts associated with the actual design and construction of the project. The Town objects to the stated user-cost of the recycled crater,which is to be the same DERWA Draft EIR 1 October 21, 199 510 La Gonda Way + Danville.California 94526.1722 (510)820-6337 3-85 as the user-cost for potable water. Given the limited uses for the water, impacts associated with the on-going use of the water on plant materials and soils, and potential infrastructure modifications necessary to accommodate the recycled water, we feel that the user-cost of recycled water should acknowledge, and be more reflective of, the on- going additional costs associated with the use of the recycled water. ENVIRONMENTAL SETTING, IMPACTS AND MITIGATION 3.3 Salinity, Soils and Vegetation 3.3.3 Mitigation NUtigat~on for impacts of recycled water on soils includes the use of 15-20 percent more water and the occasional extra heavy application of water to leach out salts from the soil. EBMI D has mandated that recycled water will be priced the same as potable water and also mandated its use where it is available and suitable for use. The proposed mitigation (extra watering) will increase the cost:of water and may require an increase in meter size in those parks where irrigation schedules are maximized. All costs associated with mitigating impacts associated with the project, which leads to an overall higher cost of irrigation, should be borne by the project applicant and not by the Town of Danville. One way to accomplish this would be to lower the cost of the water sufficiently to equal the cost of the suggested additional watering and other mitigation measures. Additional suggested mitigation includes the on-going application of gypsum to the soil. Again, the cost of this ongoing mitigation should not result in an overall higher cost to the Town. Another identified mitigation includes the replacement of some plants with more salt- tolerant plants. Our concerns with this suggestion includes the cost of the replacement. In addition, we feel gnat a survey of plat:is and landscape materials is necessary to establish a baseline to determine the extent of impacts on the landscaping. The survey should be prepared by an independent third party and who should inventory the types of plants and current conditions of the plants within the areas of the Town to be watered with the recycled water. Any necessary future replacement of plants due to damage caused by the recycled water should be paid for by the project proponent. A fund should be established to pay for future unforseen claims for the replacement of plants or modifications to existing infrastructure. DERWA Draft EIR 2 October 21, 1.99 3-86 Over-spray of recycled water could adversely effect existing pubic facilities such as drinking fountains, wading pools, and picnic areas. It is most efficient to water large areas with sprinklers which cover large areas. This will cause some over-spray even with adjustments. All costs associated with any needed modifications to existing infrastructure, as well as future costs associated with the possible modified design of - irrigation systems to avoid over- spray, should be the responsibility of the project proponent. 3.12 Aesthetics The Town is concerned with potential visual impacts associated with the development of water tanks within elevated and visible areas of Danville. The Town's General Plan contains polic*rs which cF ,uire:he preservation of hillside and ridgeline nrMs iia thsir natural form. In addition, the Town has a Major R.idgeline and Scenic Hillside Development Ordinance (see enclosure) which sets forth development standards and review and approval processes for proposed development in a scenic hillside or major ridgeline area. The project as currently proposed has not developed precise locations for the water tanks and so potential visual impacts cannot be fully evaluated at this time. ,rte Since the locations and design are not currently known, the Town reserves the right to review the proposed locations and designs of the facilities under separate Development Plan applications when the plans are developed. in addition, facilities to be sited outside the Town limit but which may be in visually prominent locations should be required to conform with Town standards related to hillside/ridgeline development. A determination regarding the consistency of the proposed development of these sites with the Town's General Flan and Major Ridgeline and Scenic hillside Development Ordinance would be made at that time. 3.8 Traffic and Construction The analysis of construction hours, noise control, traffic control and safety, and permit requirements described witnin tite DhIR are accurate. All aspects of the constcuction project to be located within Danville public streets must be coordinated with the Town and appropriate construction permits must be obtained. In addition, separate Land Use Permit applications must be approved for the establishment of construction material and equipment storage areas,if located within the Town limits. Additionally, due to the extent of the project and the size of the pipe lines, the Town will require that all public streets to be trenched be repaired to Town standards and that a new asphalt overlay for the streets be installed by the project proponent. DERWA Draft EIR 3 October 21, 199 3-87 Thank you again for this opportunity to comment on the DEIR. You may contact me at 820-1080 with any questions on this tetter: Sincerely, TOWN OF DANVILLE David T. Crampton Senior Planner en^. C. Mayor Greenberg and Town Council Members J. Calabrigo B. Welch S. Lake D. Scott IC Gailey DERWA Draft ETR 4 Ober 21, 199 3-88 3EcTION 3 cC mme r LETTERS AND RESPONSES Response to Comment Letter No. 18Town of Danville 1. The comment letter submitted by Manville is included and addressed in this Final EIR. The Final EIR will be available to all agencies who submitted comments at least 10 days prior to the DERWA Board of Directors taking action on EIR certification. 2. The comment is acknowledged. As discussed in Section 2.9 of the Draft EIR,the ETR is intended to address the San Ramon Valley Water Recycling Program at both a project and program.level.These Program components addressed at a project level would not be required to obtain additional environmental review unless there were a change in the description or location of the facility. Those components addressed at a program level, such as storage tanks and some water supply options,will require additional environmental review at such time as more details are known. 3. The issues of the cost of recycled water and costs to implement mitigation measures (e.g.,plant replacement,irrigation system retrofits)are not considered "environmental" issues under CEQA and,therefore,do not require a response in this Final EIR. Nonetheless,DERWA understands that the costs associated with implementing the San Ramon Valley Recycled Water Program are important to existing and future EBMUD and DSRSD customers,and each agency will work closely with their customers to address cost concerns,including those related to implementation of mitigation measures. 4. The comment is acknowledged.The issues of the cost of recycled water and costs to implement mitigation measures(e.g.,plant replacement,irrigation system retrofits)are not considered "environmental"issues under CEQA and, therefore,do not require a response in this Final EIR.It is not expected that many customers will have the need for additional irrigation due to recycled water, Experience with recycled water irrigation to date has not shown a significant need for increased water consumption. However, landscape irrigation is a site-specific issue and,in some cases where soils may be particularly sensitive,there may be an increased need for irrigation. In these cases, EBMUD(one of the DERWA retailers)has a provision in its non-potable water use policy that provides for a volume adjustment credit for those customers who have shown that their irrigation demand has increased due to recycled water quality. The adjustment credit will offset any increased irrigation costs.Copies of this non-potable water use policy are available from EBMUD. 5. Please see response to comment#3 above. 6. Please see response to comment#3 above. 7. Please see response to comment#3 above. 8. The comment is acknowledged. A text revision has been made to the second paragraph on page 3-139 of the Draft EIR to describe the flown of Danville's Major Ridgeline and Scenic Hillside Development Ordinance.As noted in the comment,the location and siting of the Program's storage tanks has not yet been determined,and project--specific environmental review will be required when more design work has been performed. The environmental review will require an assessment of consistency of tank locations and designs with appropriate local jurisdiction policies and standards. WkJOM-WP 1WOM131788,RMEIMFfN,L\M3.DW 3-89 SECTION 3 COMMENT LETTERS AND RESPONSES 9. The comment is acknowledged. sdcAtJOS€ivmgWWORK131766.A MEIR1m'AL\003.00c 3-30 CROW CANYON COUNTRY CLUB COMMENT LETTER # 19 ,, ', '4'' COMMUNITY,ASSOCIATION, INC 1320 El Capitan Drive Suite 390, Danville, California 94526 (510)866.8900 • FAX(510)866.8906 October 3, 1996 DERWA 7051 Dublin Blvd. Dublin, CA 94565 Attn: Bruce W. Webb The Crow Canyon Country Club Estates Community Association (CCCCECA) has received a copy of the DERWA Draft Environmental Impact Report for the San Ramon Valley Recycled Water Program. CCCCECA has not had adequate time to review and prepare comments regarding this.draft EIR. However,"the following comments are a few of the concerns which our association has, relative to the report. Several types of waterfowl have been noted on the lakes and streams in this area, which have not been identified. If time is granted for a further review of this document and extended time - is available for written comment, we will attempt to list missing species as we have seen them. The drainage for our area is into the San Ramon Creek, which flows through the valley to the north, discharging into the Delta near Martinez. This fact is omitted. Certainly the potential for salt loading and algae bloom is detrimental to the San Ramon Creek. No mitigation is identified. The report states that due to salt buildup, the users need to anticipate increased water usage by 15 to 20% over their present use of pure water. As we understand it, the present rate established for recycled water is equal to that of pure water. If that is correct, it appears that users would be overcharged for use of recycled water in lieu of pure water. We suggest that the recycled water be charged at a rate 15 to 20% lower than the rate for pure water, thus making the rate equal for the same irrigation program. Several of the options include having transmission lines or distribution lines of sizes from 6" to 20" placed in the private streets owned, controlled and maintained by the CCCCECA. These streets have recently been resurfaced at great expense to the homeowners. There was also great j 5 inconvenience to the residents of the 903 homes within our gated community during this resurfacing work. As the recycled water is intended for the use of the Crow Canyon Country 3-91 DERWA Page 2 - Club golf course, we would suggest that less impact to our residents would result if the water -� transmission and distribution lines were placed in the fairways of the golf course and not in our private streets. One of the two tank sites shown for tank 8A is located on the property of CCCCECA. It is also noted that the visual effect of a 40 to 45 foot tall, 440,000 gallon tank will have a very strong negative impact to at least 75% of our homes. We strongly suggest tanks be depressed to the ground level or that earth berms be placed in front of them to eliminate the visual impact to hom:,'iw ners. In table 2-5 (Distribution Line Locations), eleven (11) streets within the CCCCECA will be impacted by the installations. We find this to be unacceptable and will await another plan. �.=J During the grading of the CCCCECA several earthquake fault traces were identified. We need some assurance, relative to the tank placement and potential failure due to seismic movement, that our neighborhoods will not be damaged due to flooding by tank or line failure. Sincerely, Jo n Hutchins, President d of Directors 3-92 SECTION 3 COMMENT LETTERS AND RESPONSES Responses to Comment Letter No. 19—Crow Canyon County Club Estates Community Association, Inc. 1. The comment is acknowledged. The comment period for the EIR ended on October 21, 1996, and no additional letters were received (either during the official comment period or after)from the Crow Canyon Country Club Community Association. 2. The comment is acknowledged.It is possible that there are several species of waterfowl in the project area that are not identified in Section 3.9(Biological Resources) of the Draft EIR. Table 3-20 of the Draft EIR focuses on Mecial status species in the project area,and the second paragraph on page 3-107 of the EIR generally describes bird species in the area that are not on special status lists. 3. The issues associated with seepage of recycled water from the groundwater into the northerly flowing creeks in the study area are the same as those described for the southerly flowing creeks,except that for northerly flowing creeks there are no downstream water agencies that rely on groundwater or surface water from the creeks for municipal supplies.For this reason, salt loading impacts for only the southerly creeks were discussed in detail in the Draft EIR.The impacts to the northerly flowing creeks are expected to be insignificant. The increased total dissolved solids(TDS)would be of the same order of magnitude as for the southerly flowing creeks,and would have an insignificant impact on vegetation and wildlife along the creek. Increased nutrients in the irrigation water will be taken up by the vegetation being irrigated. 4. The comment is acknowledged.The issue of the cost of recycled water and costs to implement mitigation measures(e.g.,plant replacement,irrigation system retrofits) is not considered an"environmental" issue under CEQA and,therefore,does not require a response in this Final EIR. EBMUD(one of the DERWA retailers) does not expect many customers to have the need for additional irrigation due to recycled water.Experience with recycled water irrigation to date have not shown a significant need for increased water consumption. However,landscape irrigation is a site-specific issue and,in some cases where soils may be particularly sensitive,there may be an increased need for irrigation. In these cases,EBMUD has a provision in its non-potable water use policy that provides for a volume adjustment credit for those customers who have shown that their irrigation demand has increased due to recycled water quality.The adjustment credit will offset any increased irrigation costs.Copies of this non-potable water use policy are available from EBMUD. 5. The comment is acknowledged.Pipelines are normally placed within roadway rights- of-way because the land has already been disturbed,and access to the construction zone can be relatively unhindered. However,the project will be going through a more detailed design process,during which the commentor's recommendation to place pipelines in golf course fairways instead of private streets will be considered.DERWA will work with the Association to determine the most appropriate locations for distribution pipelines. 6. The comment is acknowledged. Storage tanks are addressed programmatically in the Draft EIR,and supplemental environment review will be required when specific locations and design criteria are more defined. DERWA will endeavor to design the tanks to minimize visual impacts to surrounding land uses. sicnWosetwpFtoc\wORK\131768.RMEIR1FiaAt\003,00c 3.93 SECTION 3 COMMENT LETTERS AND RESPONSES 7. The comment is acknowledged. Please see response to comment#5 above. Also,the reason that 11 streets have been identified for routing pipelines is that the connection points to Crow Canyon Country Club facilities are widespread.DER'V17A will work with the Country Club to minimize the amount of pipelines needed to serve the golf course. Possible looping in the system night limit the number of connections to 3 or 4.The connection design will determine how many streets are impacted. 8. Impact and Mitigation 3.4.5 in the Draft EIR directly address the issues of potential tank failure. As noted in the Draft EIR,the potential for tank failure is considered to be very remote.Nonetheless,comprehensive geologic and engineering studies will be performed to determine appropriate design criteria and construction methods to ensure against tank failure.A full seismic analysis will be conducted for each tank site,and the facilities will be designed to survive the design earthquake event. s cf�lsleoc1W{R3(!#8#786.EtV�lEtRlfmaAL1403. c 3-94 COMMENT LETTER #20 September 20, 1996 Mr. Bert Michalczyk DERWA Authority Manager DSRSD-EBMUD Recycled Water Authority 7051 Dublin Boulevard Dublin, CA 94568 Dear Mr. Michalezyk: I have received and read the Draft Environmental Impact Report (August, 1996) concerning tha an Ramon Valloy Fi`��y��t�� Wt1 -,O*- Thi; report has :several deficiencies which must be addressed. They are as follows: lmy&ats Section 4. 1 on Growth-Inducing Impacts falsely concludes that DERWA will not impact either population growth or the environment in the valley. Both population and groundwater environment are critical to Zone 7' s ability to provide water to valley residents. On page 4--5 the DEIR incorrectly states, "no increase in wastewater disposal capacity" because the project lacks year-round opperation. However, in the same section DERWA advocates storage in the winter and irrigation during the summer which, in reality, is equivalent to �•.J year-round opperation and therefore increased wastewater capcity. Furthermore, a careful analysis of DSRSD' s wastewater expansion plan will reveal that DERWA, when coupled with DSRSD's plans for a new 36 inch wastewater export pipeline will indeed increase disposal capacity (� and generate huge population pressures in the valley. DSRSD's proposed new pipeline will have an export capacity of 53. 5 mgd (million gallons per day) . This 53. 5 mgd when added to an existing 24. 2 mgd would bring LAVWMA' s total wastewater export capacity to 73. 7 mgd. DERWA's fully implimented 9, 334 AFY of recycled water is directly coupled to DSRSD's proposed new pipeline. In wastewater terms 9, 334 AFY is equivalent to 8. 3 mgd export capcity. DSRSD argues that the large 36 inch pipeline is necessary to take care of surface water j infiltration and. inflow (I&I) to their underground piping system ,J during wet weather. DERWA's 8. 3 mgd utilization on a year-round basis eliminates DSRSD's infiltration problem and allows the entire 53. 5 mgd of new capeity to be utilized for population growth. The growth impacts of DERWA and DSRSD's proposed new wastewater export pipeline are substantiaand detrimental to the valley. Current wastewater use profiles in the valley indicate that one mgd will support approximately 12, 040 people. Using this figure, 73. 7 mgd will support a valley population of 884, 040 people! Since new residents are expected to pay for the expansion, once the pipeline is built growth Bust occur to pay the bill. Zane 7 is not prepared to provide water for 880, 004 people! Zone 7's current $164. 5 million Water Supply Plan. for 2420 is designed to correct a future short fall of 24, 044 AF/YR and serve a population of 275, 000 not 880, 000! 3-95 DERWA should be required to rewrite Section 4. 1 on Growth-Inducing Impacts to accurately acknowledge that DERWA, in support of DSRSD' s wastewater expansion plans, does indeed impact population growth, the �.✓' environment and the availability of water. � Earthquakes Section 3. 4 can Geology and Seismicity inadequately addresses the impact of earthquakes in their contamination assessment to the water quality in our main groundwater basin. Figure 3-6 (p. 3-43) shows extensive and active fault zones in the project area. a.) In Section 3. 1 on Groundwater inadequate consideration has been given to the consequences of major fault disruptions and increased flow of recycled water south from injection wells located in the Dublin-Bishop subbasins to the Bernal portion of our Main Basin. 7 b) In Section, 3. 2 on Surface dater and Drainage inadequate consideration has been given to earthquake disruption to so called "impervious" clay layers separating South San Ramon Creek and Alamo Creek from our Main Basin. Such disruptions could also increase groundwater contamination from Ta.ssajara Creek. DERWA should be required to get a second independent analysis from experts regarding this project and the risk of earthquakes to the ground water in our Main Basin. o al Orma`ry i g Carbon (TOC) There is a total absence of TOC considerations in the DEIR. The estimated TOC levels of DSRSD recycled water is 12 - 15 mg/l. The DEIR acknowledges that significant contamination to our Main Basin will occur (even without earthquake consideration) because the "Put and Take" from injection wells are not 100% efficient. Livermore's Reverse Osmesis demonstration project is required to produce TOC concentration less than 1 mg/I before injection into our groundwater basin. DERWA recycled water reaching our Main Basin should subject to the same standard as the RO water from the Livermore Project. DERWA should be required to guaruntee Zone 7 that the TOC concentrations of DSRSD's recycled water will be less than 1 mg/l when that water reaches our Main Basin. 3-96 Transport Model ino Studies In the absence of a thorough assessment of earthquake influence on both ground and surface water flows; additional modeling studies are necessary. Without this assessment the current modeling study defining the 50% and 2% contamination contours are of little value. Additionally, the underlying assumptions for the modeling study in this DEIR are not provided thereby eliminating any possiblity for review and criticism. Because modeling is so crucial the determination of long terra impacts, DERWA should be required to conduct additional modeling studies taking earthquake impacts into account and providing the underlying assumptions for the model. Additionally, a second study should be conducted by a, qualified firm working independently of DERWA so as to insure unbiased objectivity in the analysis of risk to our ground wester basin. Respectfully, Clarence L. Hoenig 588 Tyler Avenue Livermore, CA 94550 3-97 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 20—Mr. Clarence L. Hoenig 1. Section 4.1 of the Draft EIR concludes that the DERWA project will not have significant growth inducing effects,but it does not conclude that the project will not impact the environment. Chapter 3 of the Draft EIR identifies all of the potential environmental effects of the project, and concludes that the project would have significant environmental effects unless those effects are mitigated. As discussed on page 4-1 of the Draft EIR,the potential growth-inducing effects that could be associated with the Recycled Water Program include: 1)a reduction in the amount of potable water used for municipal and private irrigation purposes,with a resulting „freeing up"of that potable water supply for other purposes; 2) the potential availability of a water resource (i.e.,recycled water for nonpotable uses)for geographic areas that have not yet been approved for growth;and 3)the perceived availability of increased wastewater disposal created by diverting wastewater flows from discharge points to the recycled water system.Pages 4-1 through 4-6 of the Draft EIR evaluate these potential growth-inducing effects of the Program and,in the Summary of Growth- Inducing Effects paragraph on page 4-6,the EIR concludes that the DERWA Program does not meet the CEQA standards for growth-inducing impacts. 2. The ASR component of the DERWA project includes temporary and interruptible underground storage of some treated wastewater in the winter,and recovery of this wastewater from storage for irrigation during the summer months.However,this does not create wastewater disposal capacity for the following reasons: • The DERWA system will not be designed with the mechanical reliability and redundancy features that would be required if the system were to operate for wastewater disposal on a 24-hour basis. • The DERWA Program provides for seasonal recycled water use,not for year- round water storage and use.The provision of recycled water from the treatment plant would be interruptible at any time. • The DERWA Program will be permitted as a recycled water irrigation project, with the possibility of using ASR for seasonal storage.The Program will not be permitted for wastewater disposal. • The DERWA recycled water will be required to.meet Title 22 water quality standards for landscape irrigation.If,for some reason.,these standards are not met,disposal capacity for this water must be maintained to allow it to be disposed of through existing or future disposal processes. • The DERWA Program will not provide for storage capacity for peak wet weather flows and periodic treatment plant shut downs. As noted on page 4-5 of the Draft EIR,this recycled water operation has no effect on the total capacity needed by the wastewater discharge pipe and treatment plant.The San Ramon Valley Recycled Water Program is not a wastewater disposal project. 3. The DSRSD proposed export pipeline project is not linked to the DERWA project,nor does the DERWA project result in an increase in wastewater disposal capacity for aJCA1d0$E1Wva001WORK1131788.RW\E1W1NA0003.D00 3-93 SECTION 3 COMMENT LETTERS 40 RESPONSES DSRD or any other agency which contributes wastewater to the project. As discussed in response to comment#2 above,DERWA is not a wastewater disposal project,nor does it create any additional wastewater disposal capacity. It is important to note that the 53.5 mgd "export capacity"of the new pipeline that is.mentioned in the comment is not quite correct;53.5 mgd is the peak wintertime hydraulic capacity,which translates into 11.4 mgd average dry weather flow(ADWF), In addition,the current capacity of - the export pipeline is 21.0 mgd,not 20.2 mgd as suggested in the comment.Thus,the total capacity of the proposed new pipeline would be 32.4 mgd ADWF,not the "73.7 mgd wastewater export capacity"described in the comment. 4. The DERWA Recycled Water Program is not"coupled to,"related to,nor contingent on DSRSD's wastewater capacity expansion studies.Delivery of any or all of the 9,330 acre- feet per year(the largest amount possible,with Customer Service Option 1)during the summer does not translate to year-round disposal capacity,for the reasons described in response to comment#2 above.Furthermore,the 9,330 acre feet of recycled water supply associated with Customer Service Option 1 is summertime supply only.As shown in Figure 2-8 of the Draft EIR(Draft EIR page 2-17),the demand for recycled water is greatest during the dry summer season,and low or non-existent during the wet winter season. 5. Please see responses to comments#2,#3,and#4 above.The population projections described in the comment are overstated and are not substantiated by fact.The DERWA EIR concludes that the Recycled Water Program will not have significant growth- inducing effects. Furthermore,DERWA is not a wastewater disposal project and,in fact, would reduce the need for potable water from Zone 7 supplies. 6. Please see responses to comments#3,#4,and#5 above. 7. Section 3.4 of the Draft EIR accurately and adequately describes the potential significant effects of seismic events on project facilities.Potential fault movement in the project area is not expected to have an effect on groundwater flow between the Fringe and Main Basins,nor is it expected to have an effect on flows from South San Ramon Creek and Alamo Creek to the Main Basin.There is no known groundwater contamination in the Tassajara Creek vicinity,so seismic disruptions would not "increase"groundwater contamination from Tassajara Creek. Impacts to Main Basin groundwater quality from the DERWA project will be measured and their significance determined as part of DERWA's mitigation and monitoring plan for its proportionate share of demonstrated salt impacts. DERWA will participate in the development of a data collection program,and refined groundwater modeling and estimating of salt impacts through its participation in a Technical Review Committee (TRC),which has been formed between DERWA and Alameda County Water District, with active participation by the Regional Water Quality Control Board and the Alameda County Flood Control and Water Conservation District-Zone 7. DERWA is currently working with these agencies through the TRC to determine data needs and to design a monitoring program,develop a consensus approach to evaluating the collected data, and to begin developing mitigations for salt loading impacts. This monitoring program will help determine measured impacts to groundwater quality in the Main Basin. In response to the suggestion to "get a second independent analysis from experts regarding this project and the risk of earthquakes to the groundwater in the Main sac WMt::*f4 1'#VORK1131T68.RAh E1RtrmAIe\003.wc 3 89 SECTION 3 COMMENT LETTERS AND RESPONSES Basin," the groundwater and geology sections in the Draft EIR were prepared by qualified hydrogeologists and geologists knowledgeable about the Livermore-Amador valley hydrogeology. A second"independent" analysis is not required under CEQA. S. With recycled water irrigation,additional water is sometimes required to assist in the leaching of salts and other constituents(such as total organic carbon or TOC)from the vegetation root zone,tinder normal climatic conditions,this is accomplished during the rainy season.Normal precipitation during the rainy seasons will provide sufficient flushing through the root zone to leach salts and prepare the root zone for the following summer irrigation seasons.It is anticipated that the amount of over--irrigation will be small in comparison to the total applied irrigation water.The resulting additional TOC lead will be small,and a large percentage of the TOC load will be taken up in the root zone before it seeps into the groundwater table or surface creeks.Through the groundwater and surface water quality monitoring that will be performed,as described in response to comment#7 above,DERWA will be able to measure its water duality impacts and implement appropriate mitigation measures. The use of reverse osmosis(RO)for the ASR component of the DERWA project was not considered because DERWA's ASR component emphasizes retrieval of the injected water,without any migration of that water to the Main.Basin.In addition,RO treatment would add to the overall costs of delivering recycled water to customers for landscape irrigation use.The objective of the DERMA project is to maximize the amount of recycled water in the study area to offset potable irrigation water demand,while recovering oasts.The use of recycled water for irrigation use does not require it to be treated with RO.The Clean Water Revival(CWR)project has a different objective,i.e., one of using recycled water for groundwater replenishment,which does require that the wastewater be treated to drinking water standards (which can be done through RO). 9. Please see response to comment#7 above.In addition,if DERWA approves an ASR. component to its project and moves forward with detailed engineering and permitting, then a point-by-point detailed water quality analysis and comparison with ambient groundwater would be prepared by DERWA as part of its permit package to the Regional Water Quality Control Board(RWQCB)for review and approval.Ongoing groundwater modeling will be required by the RWQCB during implementation of ASR. The primary assumptions used in the groundwater modeling are described in Appendix C of the Draft EIR,which includes the groundwater modeling technical memorandum. With regard to the model's assumptions about earthquake influence in ground and surface water flows,the groundwater model assumes that basin-wide groundwater levels will largely remain within their historic fluctuations and ranges and,therefore,no unusual effects from seismic activity are expected.In addition,ASR injection will take place at a depth of 500 feet or less,which is relatively shallow in comparison to the portion of the fault that could potentially be affected by injection.As noted above, ongoing groundwater monitoring and modeling will likely be required by the RWQCB as a condition of its approval of the ASR component of the DERWA Program. S,rAVMEW4 MtWClM131768,RMEIF4\F1NALM3osr 3-190 COMMENT LETTER #21 DSRSD*EBMUD RECYCLED WATER AUTHORITY (DERWA) Beard of Directors Special Meeting Minutes Monday, September 317, 1996 San Ramon Valley Fire Protection District Boardroom 1500 Bollinger Canyon Road, San Ramon, California 1 . CA TC? RD- - Chair Hansen called the ©SRSD*EBMUD Recycled Water Authority (DERWA) meeting to order at 7:35 p.m. at the San Ramon Valley Fire Protection District Boardroom. 2. R4 CALL - directors present: Chair Jeffrey Hansen, Director Cynthia Jones, Director John Coleman, Alternate Director Frank Mellon. DERWA Staff present: Bert Michalczyk, Authority Manager; Steering Committee members Robert Whitley, Bruce Webb, Jimi Yoloye; Robert Maddow, General Counsel; and Nancy Gamble, Authority Secretary. 3 PUBLIC QOMMENT - 7:37 p.m. - None received. 4. PUBLIC HE RIN A. Hold Public Hearing: Draft Environmental Impact Report (DEIR) for San Ramon Valley Recycled Program Chair Hansen briefed the Board and audience on the procedure to be followed with regard to the Public Hearing for the Draft Environmental Impact Report (DEIR). He explained that staff would give a short presentation, the Public Hearing would open, comments would be taken from the public, and then the Public Hearing would close. Mr. Michalczyk then gave a short presentation on the San Ramon Valley Recycled Water Program. He briefly provided a project overview, noted key draft EIR issues, and then explained the relationship of the DERWA project with the Dublin San Ramon Services District's Clean Water Revival project. After Mr. Michalczyk's presentation, Chair Hansen explained that the Public Hearing would allow interested and affected agencies and individuals to comment on the DEIR. The written commeni4eriod for the DEIR extends through October 14. Chair Hansen commented that DERWA will prepare responses to all comments made this evening as well as any written comments which are received. The comments and responses will be included in the Final EIR. Chair Hansen then declared Public Hearing open. 1 3-101 Meeting Spur.11 - Ms. Margaret Iracy - Ms. Tracy stated that she hes lived in Livermore for 39 years. She expressed appreciation for receiving the Draft EIR. She stated that she has not completed reading the entire document, but she did have a few questions on the Executive Summary. Ms. Tracy referred to page ES-1, which addresses Title 22 requirements. She asked if there was a definition of the current requirements. Ms. Tracy stated that she understood the Title 22 requirements have been under review for several years by the _ State. She wondered if the revisions were final. Ms. Tracy then asked about a term on page ES-4: "gross to net reduction factor of _ 30% for existing DSRSD customers." She asked that the term be explained. t 1 Ms. Tracy commented that she is concerned with the water quality in the Central Basin. She said that the quality is related a lot to the salt content. Ms. Tracy stated that she wished it would be possible to first have completion of the Zone 7 Salt Management Study, before DSRSD would proceed with either the DERWA or Cleary Water Revival project. Ms. Tracy asked what the hurry was. She asked if something can be done to try to remedy the addition of 3,000 TPY of salt without adding mare? Ms. Tracy stated that the report addresses impacts and mitigations for water quality but that monitoring seems to not be a mitigation. She stated that mitigation is to cancel out the negative effect of impact--something that you do that is positive. She said she would like to know more about the actual mitigation. She concluded by thanking the Board. Chair Hansen told Ms. Tracy that DERWA will respond to her input and questions. He then asked for any other comments. Motion by Director Coleman, Seconded by Director Jones to close the Public Hearing. _ Motion carried (4-0) by the following vote: AYES: Coleman, Jones, Mellon, Hansen NOES: None ABSENT: None Mr. Michalczyk commented that depending on the extent of the written comments received, he anticipates that the Final Elly will be made available in either November or December. 5., QA_DM .MBEE ITEM ,. Chair Hansen thanked all for attending the meeting. He said that this was a crossroads in the project and all are anxious to consider the Final EIR. He said, he believed the person in the room this evening most affected by the project is his daughter Shelby, almost 9 years old. 2 3-102 nFRWA Sp Tial Meet n Min rtes Seplember 30,1296 I ADJOURNME Chair Hansen adjourned the meeting at 8:06 p.m. Respectfully submitted, Nancy Gamble " Authority Secretary M"MxsoMScon►OfM Oft AM ON HES 114 THE OFFIM Of OO8OIE8NtiJl7 RECYCLED tYll U M1!lltli M 8 3-103 SECTION 3 COMMENT LETTERS AND RESPONSES Response to Comment Letter No. 21--Transcript from September 30, 1996 DERWA public Hearing 1. The current edition of Title 22 contains all'.Title 22 requirements.This document is scheduled for revision in the coming months. 2. The gross-to-net reduction factor is discussed on page 2-13 of the Draft EIR.Through the facilities planning effort,a maximum demand for recycled water was identified for potential recycled water customers. Because the maximum,or"gross,"demand may not be realized for a variety of reasons,the gross demand is reduced by a certain percentage to reflect the actual,or "net,"demand that is projected to occur,As an example,the maximum possible demand of 700 acre feet per year(AFY)has been identified from all existing irrigation customers served by DSRSD. Because DSRSD does not have a mandatory use policy and because some potential recycled water customers may be too far away from the system to be served economically,it is estimated that only 70 percent of the identified demand,or about 500 AFY,will ultimately be served. 3. As described in Mitigation 3.2.7 in the Draft EIR,DERWA will implement a pro-rata share of those salt reduction techniques which are identified and implemented by the Zone 7 Salt Management Plan and in an Alameda Creek watershed plan,based on demonstrated and significant salt loading that may arise from recycled water use,and that are developed through consultation and coordination with involved agencies. DERWA is committed to the development of a data collection program,and refined modeling and estimating of salt impacts through its participation in the Technical Review Committee(TRC)formed between DERWA and ACWD in October 1996,with active participation by the Regional Water Quality Control Board(RWQCB)and Alameda County Flood Control and Water Conservation District-Zone 7(Zone 7). DERWA is currently working with these agencies through the TRC to determine data needs and to design a monitoring program,develop a consensus approach to evaluating the collected data,and to develop possible.mitigations for salt loading impacts. The initial TRC task is to review the available information and develop requirements for additional data collection. DERWA and the other agencies will develop a consensus on the water quality parameters to be monitored and will design a program for establishing baseline data and post-project implementation data that will allow DERWA to determine the actual impacts that need to be mitigated by DERWA. After data collection has begun,an evaluation approach must be used that is agreeable to DERWA and the other agencies.This approach will be developed through the TRC.The TRC will provide a forum►.for DERtNA and the other agencies to work out acceptable and reasonable mitigations for actual impacts. DERWA and the other agencies can also be involved in the development of the Zone 7 Salt Management Plan(currently under preparation)and an ACWD watershed management plan,which will include mitigation requirements for salt contributors. 8JcA\JosAwPWCkW0RV31768,AWtElRlFw&'00&Doc 3-104 SECTION 4 Text Revisions to the Draft EIR Included in this section of the Final EIR are revisions to the text of the Draft EIR. All deletions are indicated with a horizontal line through the text,and all new wording is shown in shading and underlined. SXAl. SFkWPP0cWQHM131788.AY++V%--mnrtg44mc 4.1 Contents (continued) Chapter Page 3.10.2 Impacts...........................................................................................................3-127 3.10.3 Mitigation......................................................................................................3-130 3.10.4 Summary of Impacts/Mitigation for Human Health and Safety.......3-131 3.1.1. Cultural Resources .................................................................................................3-1.33 3.11.1 Existing Environmental Setting................................................................3-133 3.11..2 Impacts...........................................................................................................3-135 3.11.3 Mitigation......................................................................................................3-136 3.1.1.4 Summary of Impacts/Mitigation for Cultural Resources....................3-137 3.12 Aesthetics ................................................................................................................3-1.39 3.12.1 Existing Environmental Setting................................................................3-1.39 3.12.2 Impacts...........................................................................................................3-140 3.12.3 Mitigation......................................................................................................3-141 3.12.4 Summary of Impacts/Mitigation for Aesthetics....................................3-14.2 3.1.3 Air Quality................................................................................................................3-144 3.13.1 Existing Environmental Setting................................................................3-144 3.13.2 Impacts...........................................................................................................3-149 3.13.3 Mitigation......................................................................................................3-150 3.13.4 Summary of Impacts/Mitigation for Air Quality..................................3-151 4 CEQA-Required Impact Conclusions..................................................................................4-1 4.1 Growth-Inducing Impacts ........................................................................................4-1 4.2 Cumulative Impacts ..................................................................................................4-6 4.3 Significant Irreversible Environmental Changes and Commitment of Resources.....................................................................................................................4-11. 5 Alternatives Evaluated ..........................................................................................................5-1 .1 Approach to Alternatives Evaluation......................................................................5-1 5.2 No Project Alternative ..............................................................................................5-2 5.3 Environmentally Superior Alternative....................................................................5-2 6 CEQA Mitigation Monitoring Requirements .................................................................6-1 7 References .................................................................................................................................7-1 8 Report Preparation .................................................................................................................8-1 Appendix A. Notice of Preparation(NOP) Appendix B. Responses to NOP and Scoping Meeting Summary Notes Appendix C. Groundwater Modeling Technical Memorandum Appendix D. Salt Loading Technical Memorandum &A , endix E Distribution Line Locations *WosesNeprocNWOFIM131768.sw ,s�tinan4ocx.doc iii w ' d e-1 O v E'+ b .� Rr LF) 04 `� Lr N N N •fir 0., Ga 04 N 3 a 0, ,Q. EL H Qa Qr CL •� .. C J� c C G� r�i .� '� U 'v .�. toCo F �c 0 �IN °°.� Or- EL 600°' o ro 4) 21". a o y p o ° v i LL o .� v IN r,- < m F1 r 0. y a + •� o '� ro y 5y V iri C n y c u0.3 � y '� w u � � >' �v C_ � a ro G .0 o m ai G a b y G G N ro C t ci ` a p C U GC lb m cof ' off , c► ,�G prop � � � � ,,, L r,, -� .� N a.� � � � � C � � ,� `�"' 3 a �� E w p^� •., � 3 �, o F c ro y G O ro 9 U c�A Ji �' b ; ro F d y s cs F o G o ro bA ` ` �S ° K ani eo E � 8 tmn v ° O • 79 a 5 44+ � � ° F° a +5�++ b a c v I w o °u 0 24�2 A A -0 v 79 cc r` a, $ o c .2 cc 84, 4 o h o a ' m " a, a o Q d to ro r�.°� ,. 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U a a ca a u n O d w a g O br> a e3, a �+ r .6 "' `�y q �G � ,,•L�" i4 C1 t� _O '�' bw y G v fJ Ci tn CL tl v c — ro G v u7 mcGQj CL p 0 ego e _ 44 SCG, 3 .0 ° ° rx a ry y G o w uo sv m e a w ro o G v in � 5 E "3zC G v v G !Gq G Ul Sw u O '� t C G �G t 9 c ° w r a bpj v ti G O qui O w C X ry CC�7 W O 'i Ci Op72 'n 7 G w S b0 CS ht ' CL w nJ yw p� ty u t1 M OO �O k� G! Q G ra a m o 1 w �r C v � d � Z: • •• • R • •• •ss -• s i # • Ps< •� • f ••i i *• i ��z7��'�x�k.� Sn9'�c�� cj k»:�� a�� 4�k��Y � �:�'�`�'�' � F§la"�.�:��� .. ...k:•„s�'�`��?'��,���s�, x��....s.'���.: ���� ��?s..�..� �.�`." - •:'a`,- SAF OFA a: s � Axam, a:.. r .§ RIM s i � $ a ask NRT 4. M� 01� ,%so Asinquave!CORE R; 101 h �%asx,ws N! mw ZArr,: r ue.' x ............� T�^�^fie s ry �, P At'znl� 0 '�' kEWPO �` a N s'0.MsA 3 —` .�. 3 W -V HOW �3."� 1RA "j s e ° .,e 4 CHAPTER 2 PROJECT DESCRIPTION 4 r) ScA\JWff wPRoo1WORK\131768,F(M RNFNAL1100314PaDoe 2.57 3 ENWRONMENTAL SETTING,IMPACTS;AND WMATION 395 mg/l.Therefore,the increase in TDS concentration from potable water system to the WWTP effluent ranges from 175 to 295 mg/l.Seasonal variations will occur due to changes in the potable water source mix and seasonal variations in source water quality. If all the additional potable supply that contributes to increased flows at the DSRSD WWTP is Zone 7 surface supplies,the resulting TDS for that flow increment will be approximately 605 mg/l.This is only 6 percent greater than the existing TDS of the DSRSD WWTP recycled water of 570 mg/l.Similar small changes in other recycled water quality parameters are expected as flows increase at the DSRSD WWTP.The recycled water provided for the DBRWA Program is projected to be approximately 6803 mg/l. Table 3-1 compares the water quality of the ambient groundwater in the Dublin and Bishop subbasins,the filtered recycled water to be injected and extracted by the ASR component of the Program,water duality regulations established for rec clad water and/or use within the frin e basin,and drinkin water standards : _N3 Local Wells California Department of Water Resources (DWR)well log data for the study area contain sparse information regarding well production characteristics. Reported production rates vary from.about 10 to 8030 gpm.These are test production rates and may not reflect long- term operational rates. Available log data indicate specific capacities of about 5 to 10 gpm/ft of drawdown. Based on recent pumping tests,transmissivity is estimated at 3,2030 to 6,600 gpd/ft. of drawdown for local aquifer materials (Zone 7, 1996). Local well logs indicate irrigation as the primary use of the subbasins;there are few,if any, current local domestic users of groundwater in the subbasins.Two DWR well logs from the potential ASR well area were located that listed domestic use as the intended purpose of the well.These wells were drilled between 1955 and 1964 and are from 1703 to 570 feet deep. 3.1.2 Impacts Significance Criteria Impacts to groundwater would be considered significant if they were to substantially degrade water quality;contaminate a public water supply;substantially degrade or deplete groundwater resources; or interfere substantially with groundwater recharge. The groundwater impacts that could potentially occur with implementation of the proposed - Program generally fall into the following categories: • Impacts to groundwater quality in the Fringe Basin • Impacts to groundwater quality in the Main Basin • Impacts to groundwater levels SJCfil,OSEs WPROClWORM131768.RW\EIR\FINALi100314RE.WC 3-5 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGATION Impacts to Groundwater duality In the Fringe Basin To assess potential water quality and water level impacts associated with the project, available log data for wells in the study area were compiled,hydrogeologic cross sections of the subbasins were reviewed,and a conceptual groundwater model of the study area was developed.Bellowing is a brief description of the groundwater flow modeling effort; additional detail regarding the model is provided in Appendix C of this EIR. A conte teal numeric groundwater flow model of the study area subbasins was developed using '; MM .-.1MMU Sr.—irater irme8tigettierr in western Holland irt 19891. Micro F_m�-Hhns since beert .The model can be used to simulate steady state or transient(tune-varying)conditions,and includes a three-dimensional steady state particle tracker.The model grid is variable,allowing for accurate representation of irregular basin geornetrics,and other significant hydrologic features. The model grid was developed fallowing the outline of the subbasins as presented in California Department of Water Resources Bulletin 118-2(CDWR, 1974),titled Evaluation of Groundwater Resources:Livermore and Sunol Valleys. The model grid greatly simplifies the actual system,which results in a"conceptual"model that predicts the response of the subbasin system to aquifer storage and retrieval operations at a gross,or reconnaissance, level. In the model,the subbasin aquifer is assumed to be overlain and underlain by aquitards with average hydraulic properties of the interwoven sand/silt/clay sediments.A shallow, unconfined aquifer is assumed to be present to allow for assessment of potential impacts to the shallow unsaturated zone.The transissivity of both the deep and shallow aquifers is estimated at approximately 4,5€10 gallons per day(gpd)/foot.The model assumes the presence of constant head(spill)conditions along the fault barrier between the subbasins and the Main Basin;all other lateral boundaries are assumed to not have flow between them.The only groundwater recharge assumed in the model is aerially distributed rainfall; the model assumes rainfall recharge of 2.25 inches/year,which represents about 13 percent of the total average annual rainfall in the study area of about 18 inches/year. Because.ASR injection/extraction well sites in the Dublin subbasin would likely require a well field rather than a single well,the model assumes eight injection wells at five different injection./extraction locations.The injection scenario represents about 2.7 mgd,with a total of about 1,500 acre feet of water placed into storage over the 6-month period.It is assumed that this same volume of water is extracted over the immediately subsequent 6-month period.An injection rate of 235 gpm/well is assumed in the model. The extraction process is not 100 percent efficient and,with each annual injection,and extraction cycle,some of the filtered recycled water would remain in the groundwater.The following discussion evaluates the location and concentration of recycled water remaining in the subbasin,and the quality of the filtered recycled water in comparison to the ambient groundwater and drinking water standards. For purposes of this report, "zero" concentration of recycled water is assumed to be represented by the 2 percent concentration contour line. This assumption was made in consultations with staff of the RWQCB and DOHS. SJCNJosMwPRWWORK\1 3 1 768AMERstm100314RE.DOC 3-9 3 ENVIRONMENTAL SETTING,IMPAGTS,AND MITIGATION considered conservative for the irrigation practices used in the study area.,and results in higher TDS concentration estimates than will likely develop.Also,winter precipitation will leach salts through the root zone and into the groundwater.It is assumed that a 20 inch/ year average rainfall occurs over the study area,with a 75 percent infiltration into the groundwater. The South San Ramon Creek and Alamo Creek drainages are closed systems. For the South San Ramon Creek drainage,there will be no net long-term increase in stored groundwater because it is assumed that applied irrigation will remain stable in this largely developed area(i.e.,irrigation will not increase).For the Alamo Creek drainage,there will be an increase in groundwater levels because the area is currently undeveloped in the Dougherty Valley;however,use of recycled water will not change the groundwater levels that result from development.Similarly,groundwater flow into the two creeks will not increase due to the use of recycled water. A portion of each of these drainages is presently served potable water by EBMUD,and a portion is either presently or will be served by DSRSD with a water supply similar to the existing.Zone 7 supply.Following is the estimated recycled water use(under Option 1, the largest option)within each drainage by water utility service area: Drainage EBMUD D 1ZSD South San Ramon Creek -&AF/ r J111 AF/yr 737 A ri Alamo Creek AF/yr ter/yr Potable water TDS levels are approximately 70 g/l for the EBMUD supply,and 2-70 mg/I for the DSRSD/Zone 7 supply. Based on the analysis provided in Appendix D,the increased salt loading associated with application of recycled water for landscape irrigation within the South San Ramon Greek drainage is estimated at J=+;458 tons/year in the EBMUD water service area,and 279 tons/year in the DSRSD/Zane 7 service area,for a total loading of X17 tons/year.The increased salt loading associated with lication of recycled water for landscape zrn ation a within the Alamo Creek drainage is i 600 tons/year in the I BM`UD service area, 967 tons/year in the DSRSD/Zone 7 service area,for a total loading of 67 tons/year. Once the salt enters the creek,it either percolates into the groundwater,where the creek overlies permeable sediments,or travels downstream in the creek.The Alamo Canal conveys water from South San Ramon Creek and Alamo Creek south along 1-680 to the west of the Main Basin.The canal is underlain by impervious clay layers,effectively isolating the Main Basin from the creek.Since no percolation can occur,the salt from.the South San Ramon Creek and Alamo Creek drainages continues south to Arroyo de la Laguna and on to Alameda Creek.Therefore,no salt is added to the Main Basin from the South San Ramon and Alamo Creek drainages. Tassajara Creek.Tassajara Greek drains the area generally known as the Tassajara Valley and the eastern portion of Blackhawk.Tassajara Creek flows into Arroyo Mocho,which then flows to the Alamo Canal and into Arroyo de la Laguna.Recent,but limited,monitoring by Zone 7 indicate that a portion of Tassajara Creek,located approximately north of 1-580 and within the Camp subbasin,is a "losing"stream,with flows from the creek infiltrating into the groundwater basin at a maximum rate of approximately 1.35 cfs.In the area downstream(south)of 1-580 over the Main Basin,Tassajara Creek and Arroyo Mocho are SJCA\JOSE1WPROOlWORM131768.RVd1EIMFINAL\100314RE.DOG 3-13 3 ENVIRONMENTAL SETTING,IMPACTS,AND M1T;GA11QN "gaining strearns,"with flaw from the groundwater aquifer discharging into the creek. According to Zone 7 data,approximately 50 percent of the infiltration.flow leaving Tassajara Creek will eventually end up in the Main Basin,with the other 50 percent of infiltration flow returning to either Tassajara Creek or Arroyo Mocho. The estimate of increased salt loading to the Main Basin is based on the incremental salt loading caused by applying recycled water in lieu of potable water supplies to the proposed development in the Tassajara Creek drainage area. Similar to the South San Ramon and Alamo Creek analysis,it was assumed that 80 percent of the applied water is taken up through evapotranspiration,with the remaining 20 percent of the applied water into the groundwater aquifer. All of the applied salts are assumed to remain with the 20 percent of flow percolating through the root zone and into the groundwater system,resulting in a 5 times concentrating affect on TDS through the plant root zone. Again,this is a conservative assumption for the irrigation practices in the area.The Tassajara Creek drainage is a closed system and,at ultimate conditions,it is assumed that there is no net increase in stored groundwater and a constant groundwater flow into Tassajara Creek. Similar to the South San Ramon and.Alamo Creek analysis,winter precipitation will leach salts through the root zone and into the groundwater. The net estimated application of irrigation water in the Tassajara Creek drainage area associated with proposed developments in that drainage area is approximately to 57400 AFY.It is assumed that where recycled water is used,50 percent of the total irrigation demand is met by recycled water.Using the 20 percent leaching factor for flow to the groundwater system described above,and assuming the irrigation application occurs over approximately 7 months of the year,the resulting summertime flow in Tassajara Creek would be approximately 0 2r%cfs.This estimated flow increase in Tassajara. Creek is greater than the 1.35 cfs estimated infiltration rate from+.Tassajara Creek into the groundwater system north of 1.580,which suggests that Tassajara Creek will have an estimated as+.-2+cfs flow immediately north of 1-580,after 1.35 cfs has infiltrated belowground into the groundwater system.The flow in Arroyo Mocho will increase to i cfs,as half of the infiltration flow returns to the creek. ,; 5 AFY. The The estimated net recycled water demand in this drainage is '. ,.�,.. , incremental change in salt loading from application of recycled water can be calculated based on the differential in applied salt concentration in the in 2,405 AFY recycled water .,, mg/1 S/l at the DSRSD WWTP,les 1 assumed demand.The difference in TDS between the potable and recycled water supplies to be approximately 2�ung/1 average TDS in the Zone 7 potable water supply). The increased salt loading associated with development within the Tassajara Creek drainage and use of only potable water for landscape irrigation is estimated at AN +7990 tons/year. Long-term,all of this salt would enter Tassajara Creek through the increased groundwater discharge to the creek.The estimated flow into Tassajara Creek, assuming irrigation occurs 7 months per year,is.' cfs.When.irrigation of common areas is converted from potable to recycled water,the increased salt load is estimated to be 60475%tons/year. As previously stated,it is estimated that approximately 50 percent of the infiltrating creek flow and accompanying salt load will enter the Main Basin during the 7 months that landscape irrigation is occurring;this amounts to approximately 489 AFY. Therefore,the estimated increased salt loading to the Main Basin is estimated to be SJCIWQSE1WPROCtWORK1131768.RW1EIR\FINAL1100314RE.Doe 8-14 3 ENVIRONMENTAL SETnNG,IMPACTS,AND MITIGATION 274 tons/year.The remaining ' +,43-3 tons/year would return to Tassajara Creek and Arroyo Mocho, and would eventually flow to Alameda Creek. Summary of Main Basin Groundwater Impacts.An increase in salt loading to the Main Basin would occur only if the Tassajara Valley and Eastern Dublin areas of the proposed DERWA Program receive recycled water.If recycled water is delivered to the entire developable portion of the Tassajara Creek drainage area,as envisioned under Option 1,then the increased salt loading to the Main Basin is estimated to be approximately 274 tons per year. For the smallest option,Option 4,there would be no increase in the salt load to the Main Basin. The TDD concentration levels for flow to Alameda Creek at Niles Canyon from application of recycled water to the entire study area(under Option 1)is estimated at ape noxi mately 46+mg/l.This re resents an increase of 42 /l(or +0 ercent)over , etirrent TDS levels For Option 4,the TICS would increase to m /l,a rise of +5 m /l(or ercen0 over etnTent TICS levels: . Due to the soils present under South San Ramon Creek and Arroyo de la Laguna,no increase in salt loading will occur from application of recycled water in the South San Raman Creek and Alamo Creek drainage areas. impact 3.1.2- Increase In Salt Leading to Main Basin. An incremental increase in salt loading to the Main Basin would occur from the use of recycled water for irrigation in the Tassajara'Valley and Eastern Dublin areas of the Program. (Less than Significant) Impacts to Groundwater Levels The Dublin and Bishop subbasins have shallow aquifer zones that may locally be within 20 feet of ground surface in some areas.Modeling results indicate that ASR injection activities could cause localized mounding of water around the injection wells to a depth of about 5 feet or less. Shallow water levels will need to remain at some distance below ground surface to prevent damage to structural foundations.This possibility is considered remote for the DERWA Program based on the amount of predicted water level rise. In addition, Zone 7 data indicate that San Ramon Creek currently receives about 2.0 cfs of groundwater discharge from the Dublin subbasin,and 2.0 cfs from the Bishop subbasin.This amounts to a total of about 3,000 AFY of groundwater discharge to the local stream.This discharge reflects the current shallow water table conditions.Rising shallow water levels would tend to increase this discharge,but not to a significant degree. As discussed in Appendix C,the maximum recommended water level rise in the injection zone is about 125 feet.If this value is exceeded,the mechanical integrity of the aquifer might be compromised,overlying units fractured,and overlying aquifers unintentionally recharged with recycled water or surface discharge of water.In addition,injection at these high pressures will require that the grout seal between the well casing and formation is adequate to prevent upward flow of water along this preferential pathway.Model results indicate maximum water level rises in the aquifer due to injection will be about 105 feet; this does not exceed the maximum recommended drawup of 125 feet. SJCAWSElwPRoc\W0HM131768A ME WINAW00314RE.Doo 3-15 3 ENVIRONMENTAL SETTING,NPACTS,AND MIMATiON Impact 3.1.3—Rise in Shallow Groundwater Levels. ASR,operations could cause a rise in shallow groundwater levels resulting in potential adverse surface impacts,including potential damage to local structures;this impact is considered to be possible but remote. ASR could also cause a rise in deep water levels, potentially resulting in vertical leakage of water and unintended recharge of shallow aquifers.This impact is considered possible but unlikely. (Less than Significant) 3.1.3 Mitigation Mitigation 3.1.1--Fringe Basin Water Quality Degradation Existing potable wells within the zone of influence of ASR operations will be abandoned, and'owners/users will be provided with a replacement potable water supply. New potable well development will be restricted from.the ASR zone of influence. It is anticipated that this measure would be implemented as part of the normal jurisdiction of Zone F fbt -.__R County,and Contra Costa Coun Health De artment for wells affected in Centra Costa Coun Mitigation 3.1.2—Increase in Salt Loading to Main Basin Although the impact is less than significant,DERWA will comply with its share of salt reduction techniques such as,but not limited to,conjunctive use of the Main Basin or dernineralized recycled water recharge to the Main Basin),as they relate to demonstrated salt loadings to the Main Basin from DERWA activities,identified in Zone 7's Salt Management Plan currently under preparation.In addition,DERWA will install a water quality monitoring station in Tassajara Creek to evaluate salt loading impacts caused by the project and the effectiveness of any required mitigation measures. Mitigation 3.1.31--Rise in Shallow Groundwater Levels All non-project wells in the area surrounding the ASR zone of influence will be properly abandoned to prevent artesian flowing conditions. beep and shallow monitoring wells will be installed around the ASR wells to assess water level build-up in the aquifer. Aquifer testing will be conducted to assess the hydraulic properties of units overlying the injection zones;ASR wells will be designed in accordance with results of testing.Unacceptable water level rises can also be mitigated by decreasing injection rates,increasing the number of wells at each site,and increasing well spacing. 3.1.4 Summary of Impacts/Mitigation for Groundwater Table 3-2 provides a summary of impacts and mitigation for groundwater. The table indicates to which Program facilities and to which customer service options the specific impact and mitigation applies.The information,is presented in this format for ease of reference and comparison. A complete summary of all impacts and mitigation for all impact categories is provided in Chapter 1. SJC111JOSE1WPROCIWORK1131768.ROE1R\Fmt1100314RE.DOC 3-16 t� m i1w•.+ N4 ttS 0 ta, � r-i tl. w f: -rs a o ra � � .� � is e •� � � �� to, z4 a toy z cup E i4 U �` o S 11 ft Ix Col. a 44 ed 78 C!� O +cif G Ci i OA t� u 0 y a. � t� a ,� :� � � xt �i � � �,L1 •rte + .. a � c o _ �. o R c► a� v Qj 55 Ci 0-9 op a ,.Q •� �s�`'A' � � � '.�1a � a � '� C � Ct O tli ray n 'C�3 A R 91 rte".' � t�tl � i3"•—�. L' ��, w v-, it d1 9 W TO nz tv .40 N �+ •CS `� � � iC � � to 4) at a i~ a o tp 0 0, z5 ° SCA E amain r1 t: E r: E: i ........... ..... 3 ENVIR©NMENTALSETTING,IMPACTS,AND MITIGATION Mitigation 3.2.5—Hazardous Materials Spills during Construction Handling and storage of fuels and other flammable materials is governed by the California Occupational Safety and Health Administration(CAL/OSHA)standards for fire protection and prevention. These measures include appropriate storage of flammable liquids and prohibition of open flames within 50 feet of flammable storage areas. Construction documents will include a Substance Control Program for construction activities to reduce potentially significant impacts on water quality caused by a chemical spill.This program will require safe collection and disposal of hazardous substances generated during construction activities, and will include an Emergency Response Program to ensure quick and safe cleanup of accidental spills. Mitigation 3.2,6—Surface Water Quality Degradation from Pipeline Leaks and Failure No mitigation is required,as the impacts resulting from small pipeline leaks are not considered significant.As with a potable water system,large leaks would manifest impacts visible to the naked eye(i.e.water bubbling up from pavement).These leaks would be reported and repaired as soon as possible. Long-term impacts to surface waters are not expected to be significant due to the high quality of the recycled water. Mitigation 3.2.7—Increased TDS in Study Area Creeks DERWA will mitigate for any significant impacts of increased TDS in creeks that may affect the potable water supplies of ACWDD,rts the impacts may r4ate to demortstrated salt loadings from BERWA etetMties in the watershed.Mitigation measttres may be developed irt rt sttrince water malt mmutgernent plan ior the Alameda Creek-vvttter4ted R-tat will "LIU MEM• .': i s .: 11 IM , _ • s ! x z:',s s In addition,DERWA will install water quality monitoring stations in South San Ramon Creek, Alamo Creek,and Tassajara Creek to evaluate salt loading impacts caused by the project and the effectiveness of any required mitigation. 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C a .a +t!� G , .a„ ° 5 � 3 'fid '� rCa�au " a bb 7 'ass es `u w bb o o , a .c o 3 c�i c v _ _� " ° ?,,; alla LM w 3 c, u �c= m2s w n Sb 5EU of �i u o y a ca ° � a I o o RU M >, �.G 3 °c s a ca '00. 3 ° ° i a b " o 6 R C bo A v ro ~ v i o R bob a 'o U° b 40 .0 boy C ro c V �., L3.�.$• C c "C9 u et0"ayy a bo a b ' aro zs a to 0 .aa c ° o 14 10 0 lz •� � � w a a{ Y� a �f a ra :C �'a Ott u tp d • " rts o a~ a '�, ra eo " a CL u u m a ° V 72 I eo u E R d v . > ani 0 u u � Wau °a°.� � �- 0 cn � F c+u1 " � y.Q� � baa a, O � � '� � � � �, � yy v .0 � �-'��° p � ro `•-g' N .� ba"d. tri ,a Sr' CY C7 `p 92 , y Oa ' w hl Er O t 14 OL ° cu fl 3 C � Ew o � DA F o a d z 'v d to `� d ego � r � � �e ,� � � � � 53° '� '�•� �, rd ° w y o a U ar m" x bb CL, rd w 71 ", � '� � � � Ly •� � ° Lig V RS �i o0 ° °• c & 88 3 v bll ci ° re 0 ° 12 19 '' 2i a � r� � 0 � 'S t cc , n, or m � z. u 3 tox -a yin" G, °"mow bo rs c � p -0 -0 o LLJ "'� � g � � o � Uv, � "per•,�� �o z Ebo +may .0 C1 +�' c. � '� C Ltl 41 ° at ,° x CL C LZ ° x ' o y q� a � w �cL A 3 0 � c 0 o ru o c� a is 6 fit, y .5 Y eeL: L; --------------------------------------------------- 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGATION North of Amador Valley Boulevard,the SPRR alignment is used as a trail that parallels South San Ramon Creek.North of Alcosta Boulevard the trail remains unpaved until Pine Valley Road,where the SPRR right-of-way becomes the Iron Horse Trail,which extends ±15 miles to Walnut Creek. The Iron Horse Trail is a paved trail for pedestrian and bicycle use. From Pine Valley Road to Montevideo Drive,the trail continues to parallel South San Ramon Creek. From Montevideo,the Iron Horse Trail leaves South San Ramon Creek and continues north through San Ramon,parallel to Camino Ramon n R d t:;i ti a 'The SPRR alignment continues east at Crow Canyon Road. Studies are currently underway to evaluate the potential of implementing a light rail transportation system in the San Ramon Valley.The SPRR is being considered as one possible alignment for such a facility,but no determinations have yet been made. In addition to aboveground land uses currently existing or being considered for the SPRR, there are several underground utilities in the SPRR.These utilities include a high pressure jet fuel line,storm drains,water transmission lines,and fiber optic cable. A spur alignment to Tank site 8A would also be required,as described for the Alcosta Boulevard alignment, above. Bollinger Canyon Road as Alternative to Crow Canyon Road For both the Alcosta and the SPRR alignments,Bollinger Canyon Road is an alternative to using Crow Canyon Road. This alternative runs between Alcosta Boulevard or the SPRR right-of-way and Dougherty Road. In this alternative,the pipeline would leave Alcosta Boulevard or the SPRR right-of- way and follow Bollinger Canyon Road and its future extension east to the point where it intersects with Dougherty Road,then run north on Dougherty Road to Crow Canyon Road. From there it would continue as before on Crow Canyon Road to Blackhawk.In this alternative, the transmission line to Tank 8A would run north from Bollinger Canyon Road along Canyon Lakes Drive,cross east to Lakemont Drive,proceed north on Myrtle Beach Lane,Silver Lake Drive,Capitan Drive,and Como Way.The principal land uses along this alternative are residential and country club/golf course. Dougherty Valley Alignment.The Dougherty Valley alignment is a future transmission pipeline route for potential customers in the areas planned for development within Dougherty Valley.The Dougherty Valley alignment would be within the planned extension of Bollinger Canyon Road,the proposed Windemere Parkway and part of Dougherty Road. It runs between the SP right-of-way in Dublin and Crow Canyon Road in Danville.The transmission pipeline would be located within the road right-of-way as it is ultimately constructed. Dougherty Valley currently consist of rolling hills that are predominately used for ranching. The Dougherty Valley planning area is located on approximately 5,979 acres in an unincorporated part of south-central Contra Costa County.Development of the Dougherty Valley planning area under the approved Specific Plan would allow construction of up to 11,000 homes, along with supporting commercial,office,civic,and open space land uses. - The valley is expected to include a mixed variety of housing,from low to high density with single family homes as well as attached duplex units,interspersed among large areas of open space.Schools,parks,a golf course,potential religious facilities,and a Village Center SJCA\JOSE\WPROC\WORK\131768.RW\EIR\FINAL\100314RE.DOC 3.49 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGATION 3.7.3 Mitigation The following mitigation measures would be incorporated into the project to reduce noise impacts to a less than significant level. - Mitigation 3.7.1—Temporary Noise Level Increases from Construction Adherence to local ordinances regulating hours of construction would minimize the potential for sleep disturbance and annoyance,because heavy construction would be limited to daytime hours. All equipment would be equipped with mufflers equal or superior in noise attenuation to those provided by the manufacturer of the equipment. In addition,idling equipment would be shut off and temporary or portable acoustic barriers would be installed around stationary construction noise sources that are located in proximity to potentially sensitive noise receptors. For the ASR well drilling,all residents and sensitive receptors near the drilling locations would be notified in advance of construction.In noise-sensitive locations,such as residential neighborhoods or near parks,schools,churches,and medical facilities,well drilling would be limited to the daytime hours(8:00 a.m.to 6:00 p.m.,Monday through Saturday)and the drill rig would be acoustically shielded to the extent possible. Mitigation 3.7.2—Increased Noise Levels from Program Operations Pump stations will be either in underground vaults or aboveground structures They will be enclosed in structures designed to minimize noise to acceptable levelsf `` °N'!NN" €9 at the nearest sensitive receptor.Once enclosed, um sound baffling is l . P pump g readily achieved. 3.7.4 Summary of Impacts/Mitigation for Noise Table 3-16 provides a summary of impacts and mitigation for noise. The table indicates to which Program facilities and to which customer service options the specific impact and mitigation.applies.The information is presented in this format for ease of reference and comparison. A complete summary of all impacts and mitigation for all impact categories is provided in Chapter 1. SJONOSEMPROMORM131768.RW1EIR\FINAL1100314RF.DoC 3-81 N a H v C? H s� .w �s w 0 � to �•� � .� '� � � ~" � w �3 �� �..� o IV to bz �J y " w JS y tb G m C7 6 G �y,y �+•S9 � `�, tl � O O �! uk � N 6U� per.. .gyp, L1.•Gi10 B .y cU C1 ,C �sy 4w.• Gp aj M U G N •."rpt, y b4 ttiGC-s' " i? 6? t. .1�"CS .F+ � "t ; 13 8 `� wog •�• ' � su � � {�yU tv .-•� cyc����? ` tit G v G _ nt d S. o zn � � M ° � " i o `� oobco co 'yt 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGATION 3.8 Traffic and Circulation 3.8.1 Existing Environmental Setting Major roadways passing through the study area in a north-south direction include I-680, San Ramon Valley Boulevard,Alcosta Boulevard,Dougherty Road, and Camino Tassajara. Major east-west roadways include 1-580,Dublin Boulevard,Bollinger CanyonRoad,Crow Canyon Road, and Norris Canyon R0 ad. T Mr= Aw Figure 3-20 shows the regional traffic network. Existing daily traffic volumes on roadways in the study area are shown in Table 3-17. Transit Services Transit service in the study area is currently provided by two local transit agencies and BART Express buses.The Central Contra Costa Transit Authority(CCCTA)provides service in Central Contra Costa County,and the Livermore Amador Valley Transit Authority provides service in Alameda County. CCCTA provides local bus service to Danville and San Ramon,with service concentrated along the I-680 corridor.The primary route in the corridor,Route 1.21,mainly follows San Ramon Valley Boulevard on the western side of 1-680 and various surface streets along the eastern side of 1-680.This line extends into Alameda County,serving the Stoneridge Mall. Route 122 follows Diablo Road through Danville and Camino Tassajara Road through San Ramon,and serves the Bishop Ranch Business Park. Livermore-Amador Valley Transit Authority provides local bus service (known as WHEELS)in Dublin,Pleasanton and Livermore. Service is provided on Dougherty Road as far north as Amador Valley Boulevard. Bay Area Rapid Transit(BART)Express Bus service provides connections to BART stations. Express buses along the 1-680 corridor provide service between the San Raman,Danville, and Dublin areas and the Walnut Creek and Lafayette BART stations.This route follows San Ramon Valley Boulevard south to Dublin,through Bishop Ranch Business Park and returns the same route. Another BART Express route follows 1-680 to Crow Canyon Road to Camino Ramon and around Bollinger Canyon Road. BART is developing a new rail line and stations to connect the area.to the baywide rapid rail system. A new station is being developed along 1-580,east of 1-680. This is the Dublin- Pleasanton station.The new station is scheduled to open in late 1996 or early 1997.The Recycled Water Program will not affect the line or the stations,as the transmission facilities will pass under the rail alignment. Enke Paths and Trails There are numerous existing bicycle facilities,or bikeways,in the study area.Bicycle facilities are designated as either a Class I,Class 11,or Class III bikeway. Class I bikeways are bike paths with exclusive right-of-way and minimal cross flow by motorized vehicles. Class II bikeways are bike lanes striped within the paved areas of roadways and established for the preferential use of bicycles. Class III bikeways are bike routes on streets or sidewalks 5JO/J:\WORK\931768.RMEIR\FINAL\100314RE.DDC 3-83 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGA70N Impact 3.8.1—Disturbance of Newly Surfe el Road - Cities in the study area are implementing pavement improvements throughout their jurisdictions. The City of San Ramon has a pavement management policy which limits disturbance of newly-surfaced roads within 2 years of repaving,Dublin has a similar policy, but the time restriction is 3 years. The proposed pipeline alignment and future extensions may disturb portions of pavement that have been recently resurfaced z� ma (Potentially Significant) Impact 3.8.2—Street and Bicycle Lane Closures Bike and street lane closures (including the Iron Horse Trail) as a result of pipeline construction activities could result in temporary diversions of and impacts to traffic and circulation. Impacts could occur as a result of the extended closure of bike or traffic lanes along heavily traveled roadways,roadways that are narrow,and/or roadways for which no alternative routes are available. (Potentially Significant) Impact 3.8.3—Disruption of Transit Service Pipeline construction may impede pedestrian and/or transit access to transit stops. Although buses would generally be able to continue to use roadways during construction with minimal disruption,access to bus stops may be affected when construction crews are working in front of the stops. (Less than Significant) Impact 3.8.4—Disruption of Access to Adjacent Properties Access to properties along the construction route may be temporarily impeded due to trenching,materials, and equipment. This can be an inconvenience to some and a significant problem for others,particularly commercial business,schools,hospitals, and emergency services. (Potentially Significant) 3.3.3 Mitigation The following mitigation measures will be incorporated into the project to reduce significant impacts related to traffic and circulation to less than significant levels. Mitigation 3,8.1—Disturbance of Newly Surl°aeetl Road ' ��� r{� '" �'' DERWA or its contractor shall restore any disrupted pavement to a condition equal to that prior to construction.Individual cities'pavement resurfacing policies shall be adhered to and an effort to minimize disruption of pavement will be considered where possible. Mitigation 3.8.2—Street and Bicycle Lane Closures DERWA or its contractor shall prepare traffic management plans in accordance with local jurisdiction standards. Plans shall address bike and vehicle travel through construction zones and the use of flaggers and off-peak construction hours. Coordination with EBRPD will be necessary to maintain adequate access along the Iron Horse Trail,and at intersection crossings.Cones and/or other similar temporary traffic flow control devices would be used where necessary to establish bike and/or vehicle lanes through construction zones to protect bicyclists from construction activities and vehicle traffic,and to provide for adequate vehicle movement.Where vehicle lanes within heavily traveled roadways would SJCIJ.\WORM131768.RWIEIRIFINAL1100314RE.DOC 3-90 a i a Ocli a a a u. p .y •N y N d ..w w v U G m } y CL•8 wy �y €�Q+�i 7-''d ..3 �. d> �e�" ' y`+'YS y E+ ������ryry11 ."r.! O .L5 SLy' b, Iz ,� •5 o y �, � as 01 4 � �sa w 2 c ✓ Cao UR „ 't � •5 � sem. 'G � O �� � � � � � � C � y � 'CL j wt!'s cc ea t� cOa, � 2 '2 .� ' ! o y I ori > y 3 ° ' p u O y o _S G � � � � 5 o d ! G1 a. w Gl u c3 Gl m m m e . u y u y . Ci Ci m CS k C� a n d rts u � � bo 10 m F+ u y g a y O Cl v u lz a H v a -Z5 ,Dzi u in o ti roCL ti y C1 bDw4 C 0 .� y ed W- u O C •4! b bO 40i 0y u U b A M .W � 'b tt t"` C� •T+ y U L F '06. -00 C ttl ty 'O W „ yy ao � c ` a . LLGo s d Cy C eo O $ u y B8 a O A ri C� C �J ai r� CJ t`'i C 7�. •� ,� '� Ll. �w..�� � .Y f3+ a' � 'eC !1 CL`O O .Ci N $ V � � O O � V •� 3 � a,.c ; Fn � ic 'c..�a � � � � a. � ° ° � � <C •esy � � i U) c> y 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGAMN Several special status species are known to occur in wetlands(such as creeks and ponds) scattered throughout the vicinity of the study area (e.g.,California tiger salamander, California red-legged frog,tri-colored blackbird,and western pond turtle). Several creeks are crossed by the proposed alignments and several tank and pump sites are situated nearby wetlands resources.The exact creek crossing methodology has not been developed, but wetlands resources potentially could be lost or impacted during installation of the pipeline in existing or planned roadways,or during construction of proposed tank and pump sites. Impacts to potentially occurring special status wildlife species may be considered significant by the resources agencies. Impact 3.9.3—Loss and Disruption of Nonnative Grassland and Landscaped Vegetation It is anticipated that a narrow strip of vegetation(about 10 feet wide) adjacent to both sides of the proposed alignments would be temporarily disturbed or lost during construction. In total,this loss may be several acres;however,this habitat has low potential to support rare plant species. Therefore,this loss is not considered a significant impact. (Less than Significant) Several special status wildlife species use non-native grasslands in the study area for foraging or den or nesting habitat.Impacts to wildlife include not only the temporary disturbance or direct loss of this habitat,but also include some disruption of adjacent habitats from the proximity of human activity. However,this narrow strip of vegetation has a low habitat value due in part to the prevalence of landscaped,non-native grassland,and ruderal vegetation,and to its proximity to existing or planned roadways. Impact 3.9.4—Loss and Disruption of Wetlands Resources and Willow Riparian Woodland The proposed tank and pump sites were selected and refined in order to avoid wetland areas wherever possible. However,several creeks are crossed by the proposed alignments, and some pump sites are located in the vicinity of wetlands resources.The permanent loss of or disruption of waters of the U.S. (including wetlands)and willow riparian woodland habitat is considered a significant impact,and would be subject to mitigation and permitting requirements by the USACOE and CDpG. (Potentially Significant) 3,9.3 Mitigation The following mitigation measures will be incorporated into the project to reduce significant biological resources impacts to less than significant levels. Mitigation 3.9.1—Impacts to Potentially Occurring Rare Plants and Native Vegetation During preparation of final plans,all sites will be evaluated for the potential occurrence of rare plant species.Those sites that potentially could support rare plants will be subjected to focused rare plant surveys.These surveys will be conducted during the appropriate time of year necessary for species identification in order to determine species presence. If rare plants are encountered during focused surveys,appropriate mitigation measures that reduce the impacts to an insignificant level will be developed in coordination with the � ..=1� The specific type of mitigation would resources agencies` � F depend on the particular rare plant species found.If no rare plants are encountered during focused surveys,then it could be concluded that no significant impacts to rare plants would occur as a result of project implementation. SJC/J.IWORK1131768.RW1EfRNMAW00314RE.DCC 3.120 3 ENVIRONMENTAL SETTING,IMPACTS,AND MITIGATION Mitigation 3.9.2—Impacts to Potentially Occurring Wildlife Species of Concern After final plans are developed,all sites will be evaluated for the potential of special status wildlife species occurrence. Those sites that potentially could support special status wildlife species will be subject to preconstruction surveys.Depending on the target species, the preconstruction surveys would vary in the appropriate survey tinning and the level of effort required,and would be developed in coordination with the resources agenciesww .' COM-15M.If preconstruction surveys identify special status species presence,then appropriate mitigation measures that reduce the impacts to an insignificant level must be developed and approved by the resources agencies. If preconstruction surveys determine that no special status wildlife species occur in the study area,then it may be concluded that no significant impacts to special status wildlife species would occur as a result of project implementation. Mitigation 3.9.3—Loss and Disruption of Non-native Grassland and Landscaped Vegetation All areas along the proposed alignment disturbed by construction would be reseeded as soon as possible after construction(but before fall rains)with a grass and forb mixture to reduce erosion hazards. The goal of this reseeding effort is to provide for erosion control and not to recreate a native grassland community,therefore,hydrornulching with a non- native grass and forb mix would be appropriate. If landscaped vegetation is removed along existing roads or residences,it shall be replaced in kind at a 1:1 ratio with appropriate 3 landscaping species. All ground disturbed in the tank,pump,and ASR well sites shall also be reseeded as soon as possible (but before fall rains)with a seed and forb mix as determined appropriate on a site-specific basis by a qualified revegetation and/or erosion control specialist.Removal or disturbance of native vegetation will be avoided and minimized wherever possible. If landscaped species are removed,they shall be replaced at a 1:1 ratio with plant species typical of landscaped areas that are appropriate to the climatic and aesthetic site conditions. Mitigation 3.9.4—Loss and Disruption of Wetlands Resources and Willow Riparian Woodland Wetlands delineations and the appropriate permits will be required of any area potentially affected by project activities. Typically,these permits require mitigation plans for created wetlands and must include detailed information such as the type of wetland to be created, how it will be created,where it will be located,and a monitoring plan by which to gauge and document wetland creation success.In addition,preconstruction special status surveys for potentially occurring special status species will be required(typically no greater than 60 days before construction).The appropriate survey tinning and level of effort will be dependent upon the target species,and the specific survey protocol would be approved by the resource agencies. If special status species are encountered during the preconstruction surveys,appropriate measures to avoid impacts to these species will be developed in coordination with the resources agencies. SJCIJ:IWORK1131768.RME1R1=1NAL1100314R€.DOC 3.121 m u +M x z� C� r w a ? ro o -8 :� a w7j oosea � C' o � C� ca [y � � onS 'Gso tai V YQS CIA y a y . 04 CL G. y G Je e° tv w Cy y�( Z .C; 11 C C u s w G fa �Id e LO o � � nz , -ts C c $,ball °m°0. $ cost cis C7 op. cu 2 .4 a a bo 00 a o rs r� o y a bO° an a "' � of �sakg +mac ' •a e mm � � ��., •� •� " 'iu ", . ° GasoC tv to o 0 o �' o o 0 to 14, J sewer O� a '�i e�0 C7 `,,5." G• ' ~ •g, `� LU a5 LAY zau 't Gy r n ' « a� a r c yty b Q ifs 6 CL,4) 3 ^^ o Ow. a to o 9 3 bo zz Lu bo cr + u h .. +- ci us o at -, - o � CL ° n w o rd ' [ 2 y �` cr 10 IL E a s ci o cy a v ,oa, .2 M v N > ti r5 a G VVV ry a vi a3 CL vi °= z U yV 42 a 5b d e �t va i g1 ' f a 3 ENVIRONMENTALSEMNG,IMPACTS,AND MITIGATION 3.12 Aesthetics 3.12,1 Existing Environmental Setting The only components of the proposed project with the potential for permanent visual impacts are aboveground pump stations and tanks.The pipelines will be buried and most pump stations will be in underground structures. ASR well facilities will also be below ground surface.The visual setting for each of the pump stations and tanks varies, depending on its location in the study area.Construction of these aboveground components may be affected by municipal ordinances regarding ridgeline,hillside;or creek development. The Open Space Element of the San Ramon General Plan has a policy to retain ridgelines and hillsides steeper than 20 percent slope as open space. Structures within areas subject to the General Plan's Conservation Element are limited to a maximum height of 32 feet from the lowest to the highest points of the above ground structure.The Conservation Element prohibits structures within 100 feet(measured vertically) of the centerline of a major ridge and within 50 feet(measured vertically) of the centerline of a minor ridge. This applies to property over 500 feet in elevation,portions of which have natural gradient in excess of 10 ercent,and to ro er within 1,000 feet of a ma or or minor rid eline._ ' ` `Y1 IWOMAN z 1-584 and Tassajara Road have been designated scenic corridors by Alameda County,Tank Site T10 would be partially visible from I-580. Aboveground Tanks and Pump Stations Information on pump station and tank characteristics and their locations are listed in Tables 2-3 and 2-4 in Chapter 2,and vicinity maps are shown in Figures 3-7 through 3-17 in Section 3.5.1, Land Use. Following is a description of the visual setting of these sites. Tank.site T1 (elev. 600')is in rolling hills above residential development near Alcosta Boulevard and Old Ranch Road in San Ramon.The site is characterized by open grassland, and much of it is visible from the residential areas. Portions of the site area may also be visible from future Dougherty Valley residential developments. The site vicinity may also be used for recreational hiking by local residents. Tank site T2(elev. 760') is near the EBMUD Services Center,which has two existing,visible tanks. The site contains grass covered rolling terrain,and is adjacent to the Sycamore Valley Regional Open Space,a land bank with no access or development permitted. Tank site T2A(elev 760') is located in the open rolling hills east of the Canyon Lakes Country Club,beyond the end of Bollinger Canyon Lane and the surrounding residential area. T3,T3A,T5,T5A,T6,and T7 are located in open areas consisting primarily of grass-covered rolling hills and valleys with small drainage swales and creeks.These areas are planned for development over the next 20 years as part of the planned Dougherty Valley developments SJUJAWORMI31768.RW\EIR\F1NAL1100314RE.DOC 3-139 �, $�;3�,�}'eta;'�?�,'�:�' r�C,� �� ate. I•pl vENAO ��NN W mP h riP Cz�NTM h K t yam' �Vpf p� to p M � VNi NO��O�D_��O r;f`!N�L-� C: ��tX ON•�O�C N M�CMO� . 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ENVIRONMENTAL SETTING.MIPACPS AND MiT1GA`ZION MEASURES GROUNDWATER HYDROGECULOGY,WATER QUALITY AND PUBLIC HEALTH Table 3-3 COMPARISON OF EXISTING WATER QUALITY, PROJECTED RECYCLED WATER QUALITY AND REGULATORY STANDARDS- MAIN BASIN DISPOSAL ALTERNATIVE Ambient Main Deminoreiized Zone 7 Basin GW Recycled Drinking Water Drinking Water Master Permit Parameter Unita Quality" watert. Retc Qralityd Standardse Interim Limitst Physiertf ewarttes Color units 0 <3 4 0 15.0(S) Odor TONS 0.5 <1 4 0 3.0(S) - Turbidity NTU 0.09 0.1 3 0.08 S(S) <21 pH units 7.7 8.5 1 8.45 6.5-8.5(S) - Total Dissolved Solids mgA 420 94 1 194 500(s) Ambient or 5003 1002 Specific Conductance µmhotcm 730 0.16 5 330 900(S) - Corroslvity - 12.4 non-corroalve 11.9 non-corrosive(S) Total Coliform MPNt 0 <2.2 1 0 5%of samples ,.2.21 100 ml positive(P) Inorganle Parameters salts Ammonia-Nitrogen mgA not present9 6.1 1 no data no standard Nitrate(as N43) mgA 10 1.3 1 2.1 45(P) 453 Nitrite(as N) mgA <0.02 <1.0 1 <0.02 1.0(P) - Nitrate+Nitrite(as N) mgA 2.2 <6.8 4 0.5 10(P) Boron mgA 0.3 0.25.0.65 1,3 0.15 no standard Calcium mg/t 56 14.1 1,3 18.5 no standard Chloride mgA 51 22.8 1,3 32.0 250(S) Fluoride mgA 0.1 0.1 1,3 0.1 1.4-2.4(P) Magnesium mgA 35 0.2 1,3 9.0 no standard Potassium mgA 1.5 1.1 1,3 1.9 no standard - Sliioa mgA 22 4.3 1,3 10.9 no standard Sodium mgA 54 9.9 1,3 34.0 no standard Sulfate mgA 5o 43 1 39.0 2S0(S) - Alkalinity as CaCO3 mgA 260 4.4-9.0 3 58.0 no standard Hardness as CaCO3 mgA 290 0.5.1.8 3 67.5 no standard Metals Aluminum µgA <7 1.5 1 33.5 1,000(P) Antimony µgA <1 0.03-0.6 3 <1 6(P) Arsenic µgA 1.8 <1.0 1 1.5 50(P) Asbestos MFL non-detects' In progress* non-detect 7.0(P) Barium 991I 134 2.5 1 53.0 1.000(P) (Continued) DSRSD cry, Dram EIR(05n&%) Water revival Project 3-22 ESA 1950346 t 3. ENV'IRON14tLNNAL SET nNG.INVAC I'S AND MIITIGATION MEASURES GROUNDWATER HYDROGEOLOGY.WA'T'ER QUALITY AND PUBLIC:HEALTH Yf a TABLE 3-3 (Continued)- COMPARISON OF EXISTING WATER QUALITY, ,• PROJECTED RECYCLED WATER QUALITY AND j REGULATORY STANDARDS-MAIN BASIN DISPOSAL ALTERNATIVE Ambient Main Domineraiized Zone 7 Basin GW Recycled Drinking Water Chinking Water Master Permit Parameter Unita Clualityb Waters` Retc oualstyd Standards$ interim umitst Beryllium µgA 4.1 0.3 1 <0.1 4(P) <0.2 <0.05 1 <0.2 5(P) Cadmium µ� _ .» Chromium µgA 16 0.5 1 <0.3 50(P) Copper µgA <0.2 2.6 6 €0.2 1,300(A) Cyanide µgA non-detect 4.0 3 non-detect 200(P) - Iron µgA <0.7 7.6 1 €0.7 300(S) .� Lead µg11 <0.5 <3 1 <0.5 15(A) Manganese µgA <0.5 1.2 1 <0.5 50(s) Mercury µgA <0.2 <0.1 1 <0.2 2(P) Nickel µgA <0.5 0.5 1 <0.5 100(P) *+ Selenium µgA €1 <1.0 1 <1 50(P) Silver µcal <0.4 €1.0 1 <0.4 100(s) Thallium µgA <t <1.0 3 <1 2(P) Zinc µgA <1.8 0.1 1 <1.8 5,000(s) Qi9ln_i9 Pgra meters Total Organic Carbon m9A 0.4 0.8 1 1.9 no standard 2 MBAs(Foaming Agents mgA non-detect 0.13 4 non-detect 0.5(s) Oil and Grease mgA non-detect 0.0 4 non-detect none(5) Phenols µgA non-detect <5.0* 4 non-detect 1.0(P) 'total Trihalomethanes µgA not present' 0.4.1.4 3 56 100(P) Chforinatod .. Hydrocarbons Endrin µgA non-detect <0.025 4 non-detect 2.0(P) gamma-SHC(Lindane) µgA non-detect 0.007 2 non-detect 0.2(P) Methoxychlor µgA non-detect €4.4 4 non-detect 40.0(P) - Toxaphene µgA non-detect <0.2 2 non-detect 3.0(P) 2,3,7,8-TCDD(Dioxin) IiV non-detect in progress* non-detect 0.00003(P) - 2,4-D µ94 non-detect <8.8 4 non-detect 70.0(P) 2,4,4-TP SiNex µ9A non-detect €0.2 5 non-detect 50.0(P) �, S�+nthetics Alachlor µ9A non-detect In progress* non-detect 2.0(P) - Atrazine kr9A non-detect <1.0 5 non-detect 3.0(P) - Bentazon 99A non-detect <2 5 non-detect 18.0(P) (Continued) DSRSD Clean Draft EIR(08l28M) Water Revival Project 3-23 ESA 195034 3. EN'VIRONMFNTAL SETTING.IMPACTS AND MITIGATION MEASURES GROUNDWATER HYDROGEOLt3GY.WATER QUALITY AND PUBLIC HEALTH TABLE 3-3(Continued) COMPARISON OF EXISTING WATER QUALITY, PROJECTED RECYCLED WATER QUALITY AND REGULATORY STANDARDS- MAIN BASIN DISPOSAL ALTERNATIVE Ambient Main Dentineralized Zone 7 Basin GW Recycled Drinking Water Drinking Water Master Permit Parameter Unita Qualityb Waterc Retc oualtiyd Standardse interim l.mdst Benzo(a)pyrene µgni non-detect <0.5' S non-detect 0.2(P) ; Dalapon µgni non-detect <10 5 non-detect 200(P) Dinoseb µgel non-detect <1.0 5 non-detect 7(P) - Diquat µ91i non-detect <0.4 5 non-detect 20(P) Endothall µgil non-detect <10 5 non-detect 100(P) Benzene ggn <0,5 <1.0 2 <0.5 1 (P) Carbon tetrachloride ggtl <0,5 <0.4 4 <0.5 0.5(P) , Carboturan µg11 non-detect <6 5 non-detect 19(P) , Chlordane µg11 non-detect <0.05 2 non-detect 0,1 (P) k 1,2-Dibromo-3- µtat non-detect <0.5` 5 non-detect 0.2(P) chloropropane 1,2-Dichlorobenzene µgA non-detect 3 2 non-detect 600(P) (EPA 625) 1,4-Dichlorobenzene µg11 non-deteet 0.7 2 non-detect 5(P) (EPA 625) 1,1-Dichloroethans µget <0.5 0.2 2 <0.5 5(P) 1,2-Dichloroethane ugA <0.5 <0.5 2 <0.5 0.5(P) cis-1,2- µg11 <0.5 <1.0 4 <0.5 6(P) Dichloroethytene trans-1,2- µg1 <0.5 <1.0 4 <0.5 10(P) " Dichlomethylene 1,1-Dichioroethylene tlgll <0.5 <1.0 4 <0.5 6(P) Dichloromethane 491i <0.5 16 2 <0.5 5(P) 1,2-Dichloropropane µg11 <0.5 <1.0 2 <0.5 5(P) 1,3-Dichloropropane µg11 <0.5 <0.4 4 <0.5 0.5(P) - Dl(2-ethy1hexyl)ad1pate µg11 non-detect <5 5 non-detect 400(P) D1 2- 991i non-detect <0.5 4 non-detect 4(P) ethy9hexyl)phthalate Ethylbenzene µgn 4.5 0.5 2 <0.5 700(P) Ethylene dibromide µ9A non-detect 0.07 5 non-detect 0.05(P) Glyphosate 994 non-detect <6.0 5 non-detect 700(p) Heptachlor 991k non-detect 0.008 2 non-detect 0.01 (P) Heptachlor epoxdde µ91l non-detect 0.001 2 non-detect 0.01 (P) iexachlorobanzene t►913 non-detect <0.5 4 non-detect 1 (P) HexEachlorocycla- µ91l non-detect <10 5 non-detect 50(p) - pentadiene (Continued) DSRSD Clean Draft EfR(08128M) 1Wam Revival Pm*t 3-24 FSA 1930346 3. ENVIRONMENTAL SETTING.IMPACTS AND MITIGATION MEASURES GROUNDWATER HYDROGEOLOGY,WATER QUALITY AND PUBLIC HEALTH TABLE 3-3 (Continued) COMPARISON OF EXISTING WATER QUALITY, " PROJECTED RECYCLED WATER QUALITY AND REGULATORY STANDARDS- MAIN BASIN DISPOSAL ALTERNATIVE " Ambient Mein Demineralfaad Zone 7 Basin GW Recycled Drinking Water Drinking Water Mester Permit Parameter Unita Quaiityo waters Refr- Quatityd Standardse interim umitst w Molinate AgA non-detect <2 5 non-detect 20(P) - Monochiorobenzene µgat <0.5 <1.0 4 <0.5 70(P) - Oxamyi Agr1 non-detect <2 5 non-detect 200(P) Pentachlorophenol ligA non-detect <0.5 2 non-detect 1.0(P) - Piclorem AgA non-detect <1 5 non-detect 500(P) Polychlorinated AgA non-detect <0.20 4 non-detect 0.5(P) biphenyls(PCBs) -z Simaaine µgA non-detect 0.0 5 non-detect 4.0(P) - Styrene µgA <0.5 2.5 2 <0.5 100(P) - 1,1,2,2- µglt <0.5 <1.0 4 <0.5 1.0(P) Tetrachloroethane Y Tetrachloroethylene µgA <0.5 0.0 5 <0.5 5(P) (PCE) Thlobencarb µgat non-detect <1 5 non-detect 1.0(P) 1,2,4-Trichlorobenxene µgA <0.5 <2 5 <0.5 70(P) 1,1,1-Trichloroethane µg11 <0.5 <1 4 <0.5 200(P) - 1,1,2-Trichloroethane µgA <0.5 <1 4 <0.5 5(P) Trichloroethylene(TCE) AgA <0.5 <1 4 <0.5 5(P) - Trichlorofluoromethane AgA <0.5 <1 4 c0.5 150(P) 1,1,2-Trichloro-1,2,2- Agri <0.5 in progress* 5 <0.5 1200(P) trifluoroethane Toluene µgA <0.5 2.8 2 <0.5 150(P) ` Vinyl chloride µgA <0S <0.1 4 <0.5 0.5(P) - Xylenes(single or sum )AgA <0.5 <2.4 4 <0.5 1,750(P) of isomers) -rt RadfaactI3111V Combined Radium-226 pCIA non-detect in progress* 5 non-detect 5(P) and radium-2:28 Gross Alpha Particle pCIA 1 <1 5 non-detect 15(P) - Activity Tritium pCIA <400 <400 3 <400 20,000(P) Strontium-90 pCIA non-detect in progress* 5 non-detect 8(P) Gross Beta Particle pCiA 3 4.3 5 non-detect 50(P) . Activity Uranium pCIA non-detect In progress* 5 non-detect 20(P) x (Continued) DSRSD Clean Draft EIR(08/28/96) Water Revival Project 3-25 ESA/950346 I 3. ENVIRONMENTAL SETTING IMPACTS AND MITIGATION MEASURES GROUNDWATER HYDROGEOLOGY,WATER QUALITY AND PUBLIC HEALTH TALE 3-3(Continued) COMPARISON OF EXISTING WATER QUALITY, PROJECTED RECYCLED WATER QUALITY AND REGULATORY STANDARDS-MAIN BASIN DISPOSAL ALTERNATIVE An asterisk denotes that either the concentration of the detection limit was greater than the water quality standard or no data is available. Tests are in progress at appropriate detection limits. a Units: mgA=milligrams per liter; vigil=micrograms per liter(1 4g is equal to 111000 of a mg); MPN1100 ml.=Most Probable Number of organisms per 100 milliliters; NTU=Nephelometric Turgidity Unit; pmholcm=micromho per centimeter;TON•Threshold Odor Number.; CaCO3=Calcium b carbonate; pCil1=Picocuries per liter Derived values are the flow weighted average of data from Zone 7 Production Wells in the Bernal and Amador Subbasins and are representative of the average ambient water quality in this part of the Main Basin. Numbers preceded by<indicate that any concentration present was below the detection limit of the sample method.(e.g.<2 ggll of selenium indicates that selenium, it present,is present at less than 2 agl€concentration. The detection limit for the selenium test was 2 pgll,) Source.Zone 7 Water Agency,Water Quality Summary:March 1996,and Zone 7 staff. c Projected recycled water quality based on a combination of actual data from existing RO operations and bench-scale tests using DSRSD secondary effluent quality. Source. Separation Processes. Secondary effluent sources as follows: 1 Whitley,€3urchett&Associates,Average of values from October 7,1953,January 12,1994,and April 4,1994. Data obtained from Separation Processes, 2 Average of quarterly testing data,5 sample events,from 1985 and the first portion of 1996. 3 Data obtained from DSRSD lab May 28,1996. Single effluent sample April 1996. 4 Data obtained from DSRSD lab July 11,1998. Average of data from first six months of 1996. 5 Dublin San Ramon Services District,Fax Communication,August 7, 1996,Single effluent sample July 1996. 6 Average of monthly sample data from 1996. d Numbers used are the average of data from treated water produced by the Patterson bass and Del Valle WTPs. Source:Zone 7 Water Agency, 1295 Watlir.Quali 1 amort, February 1996. e Drinking Water Standards include primary standards,noted with(P),which are also known as maximum contaminant levels(MCL)and are legally enforceable under the Sate Drinking Water Act. Lead standard shown is the federal action level,which is non-enforceable health-based guidance number, Secondary standards, noted with(S),are aesthetic standards and are not enforceable. Action Levels,noted with(A)are enforceable under the USEPA Lead and Clipper Rule. Source: CCR Title 22,Chapter 15,Article 5, 1992. California Department of Health Services,Office Drinking Water, November 1994. f Water Reuse Requirements for the Livermore-Amador Basin, Master Permit Carder 93-159,RWQCB December 1993. RWQCB, Watrr Quality Contrgi Man U20ale-San Frangj=Bay Be io ,.lune 21,1995, Table 111-7. Water Quality Objective for the Alameda Creek Watershed Above Niles. Ambient conditions shall be determined by Zone 7 at the time the project is proposed,with the cost borne by the project proponent. g No data exists for ammonia nitrogen levels. Ammonia-nitrogen converts rapidly to nitrate,is associated with disinfection processes and organic wastes,and is generally not found in groundwater. Source:Gurpal Deoi,Zone 7 Supervising Chemist, Fax Communication,July 11, 1996 h The non-detect designation is used for chemicals which were below detection limits,but where the detection limits were not known. Detection limits for some tests may vary with each sample and sample conditions. However,Zone 7"s lab is a State Certified Lab and all detection limits are guaranteed to be below State Maximum Contaminant Levels. Source:Dennis Wang,Water Resources Engineer Trainee,Zane 7 Water Quality Laboratory, Personal Communication,August 15, 1996. r No data exists for trihalornethane levels.THMs are usually formed during chlorination of water containing naturally occurring organics. Water pumped by Zone 7 does not contain any significant amounts of THM,and therefore,testing fro this contaminant is not necessary. Source:Gurpal Deol, Zone 7 Supervising Chemist, Fax Communication,July 11, 1996 SOURCE: Compiled by Environmental Science Associates, 1996,from sources noted in table. I)SRSD Clean Draft EER(03r2&%) Water Revival Project 3-26 ESA i 95OW