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Home My WebLink AboutMINUTES - 11302004 - C35 TO: BOARD OF SUPERVISORS,AS GOVERNING Contra BOARD OF THE FLOOD CONTROL & WATER '.. ,� CONSERVATION DISTRICT Costa FROM: MAURICE M. SHIU, CHIEF ENGINEER a_ County DATE: November 30,2004 SUBJECT: ADOPT the previously certified City of Brentwood Environmental Impact Report (EIR) for the Wastewater Treatment Plant Expansion Project for the purpose of conducting real property transactions in compliance with the California Environmental Quality Act, Brentwood area. [SCH 980120581 (District III), Project No. 7571-6D8322 SPECIFIC REQUESTS)OR RECOMIvIERII}A3It31+2(S) BACKGROUND A14I €USTIRCATION RECOMMENDED ACTION: ADOPT the previously certified City of Brentwood Environmental Impact Report (EIR) for the Brentwood Wastewater Treatment Plant Expansion project for the purpose of conducting real property transactions associated with the project in compliance with the California Environmental Quality Act (the custodian of which is the Community Development Director who is located at 651 Pine Street,Martinez); and ADOPT staff findings associated with each potentially significant effect of the project as outlined in the attached Findings. a Continued on Attachment: ® SIGNATURE: kOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE �I"PROVE OTHER SIGNATURE( r ACTION OF B AgD ON NOVEMBER 30, 2004' APPROVED A *COMMENDED OTHER [J VOTE OF SUPERVISORS I hereby certify that this is a true and correct copy of an action xx UNANIMOUS(ABSENT NONE taken and entered on the minutes of the Board.of Supervisors on AYES: NOES: the date shown. ABSENT: ABSTAIN: TT.sr NOVEMBER 30 2004 G:1CrrpData\EngSvclEnvlro1BO12004\(I 1-30-04)CEQA-Bwtwd Wastewtr EIR.doc ATTESTED: s Ong.Div: Public Works(Eaviro) JOHN SWEETEN,Clerk of the Board of supervisors and County Attachment Administrator Contact: Leigh Chavez,Environmental cc: E.Kuevor,CAO Auditor-Controller Community Development-D.Kelly By ,Deputy Public Works Department: T.Torras-Enviro M,Consolacion-FC C.Pitta-Sandoval-RP SUBJECT. ADOPT the previously certified City of Brentwood Environmental Impact Report(ETR)for the Wastewater Treatment Plant Expansion Project for the purpose of conducting real property transactions in compliance with the California Environmental Quality Act,Brentwood area. [SCH 98012058)(District 111), Project No. 7571-6D8322 DATE: November 30,2004 PAGE; 2 of 2 RECOMMENDED ACTION. FIND based upon the evidence outlined in the City of Brentwood EIR that the potentially significant impacts are within the jurisdiction of and are the responsibility of the City of Brentwood and not Contra Costa County and the City of Brentwood has adopted mitigation measures that substantially lessen the significant impacts of the project as identified in the EIR, and FIND that the real property transaction necessary to accommodate the project will not cause a significant impact; and DIRECT the Director of Community Development to file a Notice of Determination with the County Clerk, and AUTHORIZE the Chief Engineer to arrange for payment of a$25 fee to Community Development Department for processing, and a 25 fee to the County Clerk for filing of the Notice of Determination. FISCAL IMPACT: There is no impact to the County General Fund or the Contra Costa County Flood Control and Water Conservation District. REASONS FOR RECOMMENDATIONS AND BACKGROUND: In 2002,the City of Brentwood expanded its existing wastewater treatment plant facility to accommodate the rapid development of its urban areas. These improvements have been constructed. The purpose of the proposed project is to allow the Contra Costa County Flood Control and. Water Conservation District to conduct real property transactions with the City of Brentwood for the improvements installed at Marsh Creek for the City of Brentwood's Wastewater Treatment Plant, in order to maintain and operate the facility. The transactions are being done under Flood Control Permit#605-00. The City of Brentwood (City) prepared an Environmental Impact Report for the Wastewater Treatment Plant Expansion on June 26, 1998. In February 1999,the City published Findings for the project. On March 8, 1999,the City of Brentwood filed the Notice of Determination. Contra Costa County is adopting the EIR in order to conduct real property transactions necessary to accommodate the project. A copy of the EIR is on file with the Public Works Department and the Clerk of the Board. The County has made Findings on those potentially significant impacts that may result from the operation of the Wastewater Treatment Plant Expansion and granting of an easement to the City of Brentwood. CONSEQUENCES OF NEGATIVE ACTION: Delay in adopting the document will result in an inability to conduct the real property transfers to the City of Brentwood. CALIFORNIA ENVIRONMENTAL QUALITY ACT NOTICE OF DETERMINATION CONTRA COSTA COUNTY COMMUNITY DEVELOPMENT DEPARTMENT 651 PINE STREET 4TH FLOOR NORTH WING MARTINEZ,CALIFORNIA 94553-0095 Telephone: (925)313-2296 Contact Person: Cece Sellgren, Environmental Planner Common Name(if any),Location,and Project Description City of Brentwood Wastewater Treatment Plant Expansion with Discharge into Marsh Creek. In 2002, the City of Brentwood expanded its existing wastewater treatment plant facility to accommodate the rapid development of its urban areas. These improvements have been constructed. The purpose of the proposed project is to allow the Contra Costa County Flood Control and Water Conservation District to conduct real property transactions with the City of Brentwood for the improvements installed at Marsh Creek for the City of Brentwood's Wastewater Treatment Plant,in order to maintain and operate the facility. The City of Brentwood(City)prepared an Environmental impact Report for the Wastewater Treatment Plant Expansion on June 26, 1998. In February 1999, the City published Findings for the project. On March 8, 1999; the City of Brentwood filed the Notice of Determination. Contra Costa County is adopting the previously certified EIR in order to conduct real property transactions necessary to accommodate the project. The County has prepared Findings for those potentially significant impacts that may result from the operation of the wastewater treatment plant and granting of the easement to the City of Brentwood. Pursuant to the provisions of the California Environmental Quality Act: ( ) An Environmental Impact Report was prepared and certified (SCH# ) (X} The Project was encompassed by an Environmental Impact Report previously prepared for the Brentwood Wastewater Treatment Plant Expansion (SCH#98012058). ( } A Negative Declaration ()was prepared ( } Copies of the record of project approval and the final EIR may be examined at the office of the Contra Costa County Public Works Department. (X) The Project will not have a significant environmental effect with mitigation measures incorporated in the City of Brentwood's FEIR. ( ) The Project will have a significant environmental effect. ( ) Mitigation measures were made a condition of approval of the project. ( ) A statement of overriding considerations was adopted as part of the original EIR. (X) Findings were adopted pursuant to Section 15091 of the State CEQA Guidelines. Date: By: Community Development Department Representative AFFIDAVIT OF FILING AND POSTING I declare that on I received and posted this notice as required by California Public Resources Code Section 21152(c). said notice will retrain posted for 30 days from the filing date. Signature Title Receipt Applicant: Department of Fish and Game Fees Due Public works Department EIR-$856 Total Due: $50 255 Glacier Drive Neg.Dec.-$1,250 Total Paid $ Martinez,CA 94553 DeMinimis Findings-$0 Attn:Trina Torres X County Clerk-$50 Receipt#: tt GAGrpDatMEngSvc\ENVIROIFlocd ControfflMd WastewaterTreatment Plant Expans-Adopt EIR\CEQAWOD.doc CALIFORNIA ENVIRONMENTAL QUALITY ACT NOTICE OF DETERMINATION CONTRA COSTA COUNTY COMMUNITY DEVELOPMENT DEPARTMENT 651 PINE STREET 4TH FLOOR NORTH WING MARTINEZ,CALIFORNIA 94553-0095 Telephone: (925)313-2298 Contact Person: Cece Sellgren, Environmental Planner Common Name(if any),Location,and Project Description City of Brentwood Wastewater Treatment Plant Expansion with Discharge into Marsh Creek. In 2002, the City of Brentwood expanded its existing wastewater treatment plant facility to accommodate the rapid development of its urban areas. These improvements have been constructed. The purpose of the proposed project is to allow the Contra Costa County Flood Control and Water Conservation District to conduct real property transactions with the City of Brentwood for the improvements installed at Marsh Creek for the City of Brentwood's Wastewater Treatment Plant, in order to maintain and operate the facility. The City of Brentwood(City)prepared an Environmental Impact Report for the Wastewater Treatment Plant Expansion on June 28, 1998. In February 1999, the City published Findings for the project. On March 8, 1999; the City of Brentwood filed the Notice of Determination. Contra Costa County is adopting the previously certified EIR in order to conduct real property transactions necessary to accommodate the project. The County has prepared Findings for those potentially significant impacts that may result from the operation of the wastewater treatment plant and granting of the easement to the City of Brentwood. Pursuant to the provisions of the California Environmental Quality Act: { } An Environmental Impact Report was prepared and certified (SCH# } (X) The Project was encompassed by an Environmental Impact Report previously prepared for the Brentwood Wastewater Treatment Plant Expansion (SCH#98012058). { } A Negative Declaration ()was prepared ( ) Copies of the record of project approval and the final EIR may be examined at the office of the Contra Costa County Public Works Department. (X) The Project will not have a significant environmental effect with mitigation measures incorporated in the City of Brentwood's FEIR. ( ) The Project will have a significant environmental effect. { } Mitigation measures were made a condition of approval of the project. ( ) A statement of overriding considerations was adopted as part of the original EIR. {X} Findings were adopted pursuant to Section 15091 of the State CEQA Guidelines, Date: By: Community Development Department Representative AFFIDAVIT OF FILING AND POSTING I declare that on I received and posted this notice as required by California Public Resources Code Section 21152(c). Said notice will remain posted for 30 days from the filing date. Signature Title Receipt# Applicant: Department of fish and Gam_a Fees Due Public Works Department EIR-$850 Total Due: $50 255 Glacier Drive Neg.Dec.-$1,250 Total Paid $ Martinez,CA 94553 DeMinimis Findings-$0 Attn:Trina Torres X County Cleric-$50 Receipt#: tt G:1GrpDatalEngSvclENVIROIFlood ControMmd WastewaterTreatment Plant Expans-Adopt EIRICEOXNOD.doc CONTRA COSTA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT FINDINGS for the: City of Brentwood WASTEWATER TREATMENT PLANT EXPANSION.PROJECT November 30, 2004 The project impacts listed below were identified in the City of Brentwood Wastewater Treatment plant Expansion with Discharge to Marsh Creek EIR. Staff from the environmental group at Contra Costa Flood Control and Nater Conservation.District has reviewed the impacts relative to the actions the District will take (i.e., easements and other real property transactions) that are associated with the improvements installed at Marsh Creek, for the City of Brentwood's'Wastewater Treatment Plant Expansion project. According to CEQA, a responsible agency has responsibility for mitigating or avoiding only the direct or indirect environmental effects of those parts of the project, which it decides to carry out, finance, or approve. Further, the responsible agency must make the findings required by Section 15091 (Findings) for each significant effect of the project and must make the findings in Section 15903 (Statement of Overriding Considerations) if necessary. The District's findings regarding potentially significant impacts related to issuance of flood control easements and conducting real property transactions are located at the end of each section below. This analysis only specifically addresses those potentially significant impacts associated with portions of the project the District will authorize. There are a number of potentially significant impacts associated with the City of Brentwood Wastewater Treatment Plant Expansion Project; however, those impacts are in the jurisdiction of and the responsibility of the City of Brentwood as the Lead Agency. The improvements analyzed by the City of Brentwood's EIR.were constructed and have been in use since September 2002. Following are Contra Costa County's Findings pursuant to Section 15091 of CEQA regarding potentially significant project impacts associated with the Flood Control and Water Conservation District'sreal property transactions necessary for the City of Brentwood Wastewater Treatment Plant Expansion. AESTHETICS: District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant aesthetic impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant aesthetic impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. AGRICULTURAL RESOURCES: District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant agricultural resources impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant agricultural resources impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. G:\GrpData\EngSvc\ENVIIIO\Flood Control\Bwtd WastewaterTreatment Plant Expans-Adopt EIR\F'indings-FC.doc (Page 1 of 4) AIR QUALITY Impact: INCREASE IN ODOR COMPLAUNTS Mitigation identified in EIR; Mitigation Measure E-3. Maintain an easement around Waste Water Treatment Plant (WWTP) boundaries to prevent urban encroachment to reduce odor complaints. Mitigation Measure E-4. Evaluate odor control measures before construction begins on each project phase. District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control District's (District) property to the City of Brentwood (City) in support of the operation of the facility. There are no potentially significant air quality impacts associated with the District's issuance of easements or other real property transactions for this project. All potentially significant air quality impacts associated with the project are the responsibility of the City as the CEQA Lead Agency. The City will be responsible for ensuring urban encroachment is prevented. In addition, the City will ensure odor control measures are evaluated before construction begins. These mitigation measures adopted by the Lead Agency should mitigate any potential air quality impacts associated with the District's real property transactions. BIOLOGICAL RESOURCES; District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant biological impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant biological impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. CULTURAL RESOURCES District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant cultural resources impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant cultural resources impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. HAZARDS AND HAZARDOUS MATERIALS: District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant hazards and hazardous materials resources impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant hazards and hazardous materials impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. G:\GtpData\EngSvc\ENVIRQ\Flood Control\Bwtd WastewaterTreatment Plant Expans-Adopt EIR\Findings-FC.doc (Page 2 of 4) HYDROLOGY AND WATER QUALITY: Impact:DEGRADATION OF WATER QUALITY IN MARSH CREEK Mitigation Identified in EIR; Mitigation will be enforced by the City of Brentwood; Mitigation Measure A-1. Design and operate the Waste Water Treatment Plant (WWTP) to meet National Pollutant Discharge Elimination System (NPDES)permit limit for priority pollutant. IV itization Measure A-2. Implement source control program. District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control District (District) property by the City of Brentwood (City) in support the operation of the facility. Damage occurring on or to District property is addressed in the Real Property Easement. The facility has already been constructed. All potentially significant hydrology and water quality impacts associated with the City of Brentwood Wastewater Treatment Plant Expansion Project are the responsibility of the City as the CEQA Lead Agency. The City will be responsible for ensuring the WWTP meeting NPDES permit requirements are implemented. In addition, the City will ensure a source control program is implemented. These mitigation measures adopted by the Lead Agency should mitigate any potential hydrology and water quality impacts associated with the District's real property transactions. PUBLIC HEALTH District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant public health impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant health impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. LAND USE,NOISE,AND ENERGY& PUBLIC SERVICES Impact: INCREASE IN CTAS AND ELECTRICITY CONSUMPTION Mitigation Identified in EIR: Mitigation Measure F-1. Coordinate with Pacific Gas and Electric Company to assess incremental electrical services during the pre-design phase. District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control District (District) property to the City of Brentwood (City) in support of the operation of the facility. There are no potentially significant land use, noise, and energy, and public services impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant land use, noise, and energy, and public services impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. The City will be responsible for ensuring that Pacific Gas and Electric is contacted to assess incremental electrical services. This mitigation measure adopted by the Lead Agency should mitigate any potential energy impacts associated with the District's real property transactions G:\GrpData\EngSvc\ENVIRO\Flood Control\Bwtd wastewaterTreatment Plant Expans-Adopt EIR\Findings-FC.doc (Page 3 of 4) MINERAL RESOURCES District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. '.Where are no potentially significant mineral resources impacts associated with the District's issuance of easements or ether real property transactions for this project. The facility has already been constructed. All potentially significant mineral resources impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. POPULATION AND HOUSING District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant population and housing impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant population and housing impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. RECREATION District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant recreation impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant recreation impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. TRANSPORTATION/TRAFFIC District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant transportation/traffic impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant transportation/traffic impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. UTILITIES AND SERVICE SYSTEMS District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant utilities and service systems impacts associated with the District's issuance of easements or other real property transactions for this project. The facility has already been constructed. All potentially significant utilities and service systems impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. MANDATORY FINDINGS OF SIGNIFICANCE District Findings: The purpose of this findings document is to address issuance of easements onto Flood Control property to the City of Brentwood in support of the operation of the facility. There are no potentially significant impacts associated with the District's issuance of easements or other real property transactions for this project. Damage occurring on or to District property as a result of operation of the wastewater treatment plant will be addressed in the Real Property Easement being issued to the City of Brentwood. The facility has already been constructed. All potentially significant mandatory findings of significance impacts associated with the project are the responsibility of the City of Brentwood as the CEQA Lead Agency. G:\Grpbata\Engsvc\ENVIRO\Elood Control\Bwtd WastewaterTreatment Plant Expans-Adopt EIRTindings-FC.doe (Page 4 of 4) Notice of Determination To: Office of Planning and Research City of Brentwood 1440 Tenth Street,Room 121 From: (Public Agency) Public Services Deparnent Sacramento,CA 95814 708 Third Street,Brentwood, CA 94513 (Address) [� County Clerk County of Subject: Piling of Notice of Determination in compliance with Section 21108 or 21152 of the Public Resources Code. Project`title City of Brentwood Wastewater Treatment Plant Expansion with Discharge to Marsh Creek EIR State Clearinghouse Number Lead Agency Area Code/Telephone/Extension (If submitted to Clearinghouse) Contact Person 98012058 John Stevenson (925)634-6940 " Project Location(include county) City of Brentwood's existing wastewater treatment plant,325 Sunset Road,Brentwood,CA,Contra Costa County Project Description: The proposed project includes three principal components: • a four-phase expansion and upgrade of the City's existing wastewater treatment facilities and construction of a new facility to increase flow from 1.8 to 10 million gallons per day, •direct discharge of treated effluent to Marsh Creek,and •expansion of the biosolids handling facilities to allow disposal to land or landfill. This is to advise that City of Brentwood has approved the above described project on IE Lead Agency R Responsible Agency February 9, 1999 and has trade the following determinations regarding the above described project: (Date) 1. The project(E]will E]will not)have a significant effect on the environment. 2. An Environmental Impact Report was prepared for this project pursuant to the provisions of CEQA. [�A Negative Declaration was prepared for this project pursuant to the provisions of CEQA. 3. Mitigation measures(0 were [:]were not)made a condition of the approval ofthe.project. 4. A statement of Overriding Considerations(❑was E]was not)adopted for this project. 5.Findings( were r-1 were not)made pursuant to the provisions of CEQA. This is to certify that the final EIR with comments and responses and record of project approval is available to the General Public Brentwood Public Services Department,708 Third Street,Brentwood,CA,and Brentwood r 751 Third Street Brentwood.CA Sign urs(Public Agency) iJczts tls Nt - te received for filing at OPR: Revised October 1989 REQUEST FOR COUNCIL ACTION November 24, 1998 DATE ITEM NUMBER ORIGINATING CITY MANAGER'S DEPARTMENT AGENDA ITEM REVIEW Engineering Certifying the EIR for the Wastewater J. Stevenson Treatment Plant Expansion with Discharge to Marsh Creek and adopting the.Mitigated Negative Declaration for the Conveyance of Raw Sewage to Ironhouse Sanitary District PREVIOUS ACTIONS: Council approved the Initial StudyiNegative Declaration for the Short Term Wastewater Improvement Project (No. 59201) at the meeting of February 24, 1998. A public hearing was subsequently held at the meeting of July 28, 1998 to hear comments on the "Draft Environmental Impact Report for the City of Brentwood Wastewater Treatment Plant Expansion with Discharge to Marsh Creek". RECOMMENDED COUNCIL ACTION: Passage of Resolution No. 98-&certifying the EIR for the Wastewater Treatment Plant Expansion with Discharge to Marsh Creek and Resolution No. 98-_L207 adopting the Mitigated Negative Declaration for the Conveyance of Raw Sewage to Ironhouse Sanitary District COMMENTS: In accordance with Section 15073 of the State CEQA Guidelines, a Mitigated Negative Declaration was prepared to address the potential environmental effects for the City of Brentwood Raw Sewage Conveyance to Ironhouse Sanitary District and circulated for public review for 30 days. During the same period a Draft Environmental Impact Report for the City of Brentwood Wastewater Treatment Plant Expansion with Discharge to Marsh Creek (EIR) was circulated. Written comments regarding the EIR were accepted through August 10, 1998. The Final Environmental Impact Report for the Wastewater Treatment Plant Expansion with Discharge to Marsh Creek addresses comments that have been received on the draft EIR. The proposed project would be located at the site of the existing Wastewater Treatment Plant. It is planned to produce tertiary treated and disinfected effluent for discharge into Marsh Creek. Potential impacts have been identified and mitigation measures have been recommended in the EIR that would reduce the potential impacts to a less than significant level. q , Staff Report EIR- Wastewater Treatment plant Expansion Page 2 The Mitigated Negative Declaration was prepared as a parallel environmental review for consideration of raw sewage conveyance to Ironhouse Sanitary District for treatment. This alternative would require Ironhouse Sanitary District and the City to work together to expand the existing Ironhouse wastewater treatment plant. Ultimately, an additional disposal pipeline would have to be constructed parallel to the existing pipeline to provide capacity for the combined wastewater flows. The Mitigated Negative Declaration has determined that this alternative will also have less than significant effect on the environment. The alternatives for long term sewage treatment will be brought before the Council at the next regularly scheduled meeting in a Public Hearing. At that time a staff report with recommendation(s) will be presented for consideration by the Council. 1ES.kw Attachments: I. Resolution No. 98- 2. Resolution No. 98-tj C 3. Environmental Impact Report for the City of Brentwood Wastewater Treatment Plant Expansion with Discharge to Marsh Creek 4. Notice of Mitigated Negative Declaration for City of Brentwood Raw Sewage Conveyance to Ironhouse Sanitary District 5. Initial Study/Mitigated Negative Declaration for the City of Brentwood Raw Sewage Conveyance to Ironhouse Sanitary District RESOLCI" ON NO."-209 A RESOLUTION OF TME CM COUNCIL OF THE CITY OF BRENTWOOD C;ER,TUN N'G THE ENVIRONMENTAL TACT REPORT FOR TTS WASTEWATER'f EATUU NT PLANT EXPANSION WrM DISCHARGE TO MARSH CREEK WHEREAS, in accordance with the California Environmental Quality Act ("CEQA:") a Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIi) for the Wastewater Treatment Plant Expansion With Discharge To Marsh Creek project was published and distributed to local,state, and federal agencies and to all interested parties. Comments received in response to the NOP were included in the DEM WHEREAS , public scoping meetings were conducted and a Draft EIR for the Project was completed and circulated for public review and cornrnent in accordance with CLQA; WHEREAS, a public hearing on the Draft ETR was properly notices and conducted by the City an July 28, 1998; i WHEREAS, the Response to Comments together with the THEIR, constitutes the Final Environnuntal Impact Report ("F'EIR") and the FEIR document was released for agency and public review on May 20, 1998. WHEREAS, the City has reviewed and considered the verbal and written information provided by those testifying, as well as the information provided in the FEIR, staff reports and supporting documentation. The FE7R reflects the independent judgment and analysis, Now,Therefore,the City Coundl of the City of Brentwood finds as follows: 1. That the Final. Environmental Impact Report ("FEW) has been prepared, publicized, circulated and reviewed in accordance with the California Enviz'or=tental Quality Act (Cal. Pub. Res. Code sections 21000 et seer,, "+:EQA.") and the State C E A guidelines (Cal. Code Regs, Title 17, sections 15000 et seq., "C'EQA Guidelines"), 2. That the FEI R constitutes an adequate, accurate, objective and complete Environmental Impact Report in compliance with all applicable legal standards. I That the FEIR.contains a reasonable range of alternatives and provides sufficient information about each alternative to allow meaningful evaluation, analysts,, and comparison with the proposed project. The FETR contains the findings 4 required by CEQA Guidelines Section 15MI which will become part of the project approval,if and when the Council decides to approve the project. 4. That the responses to comments provide clarification to the informa- tion contained in the UE€R and do not describe (1) a new substaatiarl environmental impact resulting from the Project or from a new mitigation measure; .(2) a substantial increase in an environmental impact, or (3) a feasible Project alternative or mitigation measure that clearly would lessen the environmental impacts of the Project that has not been adopte+ci. Therefore, recirculation is not required. {CEQA Guidelines 150)88.5.). 5. The City hereby certifies the FM as complete, adequate and in compliance with. CEA and state and local guidelines; and if the project is later a p��ved by the Council, a Notice of Determination shall be filed with the County 6. The City is the custodian of the administrative . record, including all CEQA documents and`the other background documents and materials, which constitute the record of the proceedings upon which the City's decision to certify the FEM is based. The administrative mord is located. at City Hall. a PASSED AND AWPTED 17415 24'day of November, 1998,by the following votes: Ayes. t znc lrebber Petxovich, Guise, Kidd, 1zPoland and Mayr Morrill. Noes: Nome Absent: Nme Abstain: Nome Approved John M ' , mayor IV ATTEST: Donna J. loge City RESOLLMON NC?.98-no A RESOLD ON OF THE CITY COUNCIL OF THE CITY OF BRENTWOOD ADOPTING THE WnGATED NEGATIVE DECLARATION FOR THE CITY OF BRENTWOOD RA''t1' SEWAGE CONVEYANCE TO IRONHOUSE SANITARY DISTRICT WHEREAS, in accordance with the California Environmental Quality Act ("CEQA") a Notice of Intent to prepare a Mitigated Negative Declaration (N2,D) for the The City Of Brentwood Raw Sewage Conveyance To Ironhouse Sanitary District project and an Initial Study relating thereto was published and distributed to local, state, and federal agencies and to all interested parties. Comments received in response to the Initial Study were included in the MND; WHEREAS , the MIND for the project was completed and circulated for public review and comment in accordance with CEQA, WHEREAS, the City has reviewed and considered the verbal and written information provided by those testifying, as well as the information provided in the MND, staff reports and supporting documentation. The MND reflects the independent judgment and analysis. Now,Therefore,the City Council of the City of Brentwood finds as follows: 1. That the Mitigated Negative Declaration ("MND") has been prepared, publicized, circulated and reviewed in accordance with the California Environmental Quantity Act (Cal. Pub. lies. Cade sections 21000 et seq., "CEQA") and the State CEQA guidelines (Cal, Code Reqs, 'Title 17, sections 15000 et seq., "CEQA Guidelines"). 2. That the MND and the whole record before the City dernonstrate that there is no substantial evidence that the project will have a! significant effect on the environment and that the MND constitutes an adequate, accurate, objective and complete environmental analysis in compliance with all, applicable legal standards. 3. The City hereby adopts the MND as complete, adequate and in compliance with CEQA and state and local guidelines; and if the project is later approved by the Council, a Notice of Determination shall be filed with the County Clerk. b. The City is the custodian of the administrative rei:Qrd, including all CBQA documents and the other background documents and materials, which constitute the record of the proceedings upon which the City's decision to certify the MND is based. The administrative record is luted at City Hall. 11124!9$ t PASSED AND ADOPTED THIS 24*1 day of November, 1918, by the foUowing votes: Ayes: cm=i1maTbers Petrovich, QAse, Kidd, Mc.Poland and Mayor Morrill Noes: None Absent: None Abstain: Ione Approved john rril . Mayor ATTEST: Donna J. R.oge ,City 9fry i E ,,., 2 :xtaie NOTICE OF MITIGATED NEGATIVE DECLARATION PROJECT TITLE: City of Brentwood Raw Sewage Conveyance to Ironhouse Sanitary District PROJECT PROPONENT:City of Brentwood,Public Services Department LEAD AGENCY: City of Brentwood PROJECT LOCATION: The City of Brentwood(City)is located in Contra Costa County,California approximately 50 miles'east of San Francisco and 50 miles southwest of Sacramento. The project site is located at the City's existing wastewater treatment plant(WW'IT)north of Sunset Road and extends north to the Ironhouse Sanitary District(ISD or District)W-WTP located northeast of Oakley. PROTECT DESCRIPTION: The City proposes in this initial study/mitigated negative declaration to expand its wastewater capacity by conveyance of up to 10 million gallons per day (mgd) of raw sewage to ISD. This proposed project would meet the City's long-term wastewater treatment and disposal needs through 2062 or until the City had a population of 100,000. The project includes construction of a new raw sewage pump station on the City's existing WWTP property and conveyance of raw sewage from its VvVTP to ISD's proposed WWTP using a 30-inch forcemain. The forcemain would extend generally north from the City's WWTP following surface streets to the ISD WWT?located northeast of Oakley. In accordance with a future agreement between the City and ISH sewage would be treated at a proposed expanded TSD facility, and reclaimed water (effluent) would be used for crop i Tigaticn on Jersey Island northeast of ISI>'s proposed WWTP. The project would also involve constriction of a new 30-inch diameter disposal pipeline f:om the proposed ISD WWTP to Jersey Island. The project would require construction of wastewater facilities by ISD that would handle the combined average dry-weather flow of 18 mgd from the City and ISD. These facilities would serve the City's needs through 2062 or until the City had a fixture population of 100,000. ENVIRONMENTAL DETERMINATION: The City of Brentwood has determined that the above project will have no significant effect on the environment and is therefore exempt from the requirement to prepare an EIR The determination is based on the attached initial study and the following findings: a) The project will not degrade environmental quality, substantially reduce habitat, cause a wildlife population to drop below self-sustaining levels, reduce the number or range of special-status species, or eliminate important examples of California history or prehistory. b) The project does not have the potential to achieve short-term goals to the disadvantage of long-term environmental goals. C) The project will not significantly contribute to cumulative impacts. d) The project will not have substantial adverse effects on human beings resulting from environmental impacts. e) No substantial evidence exists that the project will have a negative or adverse effect on the environment. j) This project is consistent with all applicable City and Contra Costa County plans and policies. g} This mitigated negative declaration reflects the independent judgment of the lead agency. ENVIRONMENTAL CONTROL MEASURES: In making its findings, the City has incorporated the following measures into its project design to ensure that no significant impacts would result from the proposed.action: 0 Implement Erosion and Sediment Control Plan, ■ Provide Levee Protection, ■ Ensure Effluent/Sludge Application and Monitoring Program is implemented by ISD, x Implement Dust Control Procedures, W Implement Traffic Control Measures, ■ Minimize Exposure to Excessive Noise, Identify and Avoid Underground Utilities, * Conduct Special-Status Species Preconstruction Surveys, ■ Avoid Sensitive Biological Resources During Critical The Periods, +� Confine In-Water Work to Low-Flow Periods, ■ Avoid Emergent Vegetation, ■ Minimize Channel Sedimentation, • Comply with Streambed Alteration,Agreement Requirements,and Avoid Disruption of Unknown Archaeological Sites. A complete description of these project design measures is provided in Chapter 2,"Project Description",of the attached Initial Study. The mitigation monitoring program will provide all of the necessary details to ensure acceptable implementation of the environmental control measures. PUBLIC REVIEW: In accordance with Section 15073 of the State CEQA Guidelines, this mitigated negative declaration was circulated for public review for 30 days. Written comments were submitted on the document through August 10, 1998. / Environmental Determination made by: Stevenson,Ciry ngineer { (BP WODD :_4-NT FINDINGS OF FACT FOR THY- CITY HECITY OF BRENTWOOD WASTEWATER TREATMENT PLANT EXPANSION WITH DISCHARGE TO MARSH CREEK PROJECT Lead Agency: City of Brentwood Public Works Department 708 Third Street Brentwood, CA 94513 Contact: John Stevenson (925) 534-6920 Environmental Consultant: Jones & Stokes Associates, Inc. 2600 V Street, Suite 100 Sacramento, CA 95814-1914 Contact: Steve Centerwall (916) 737-3000 February 1999 Section 1. Introduction and Purpose The City of Brentwood (City) is proposing to adopt the City's wastewater treatment plant expansion with discharge to Marsh Creek project. The City has prepared and certified an environmental impact report (EIR) for the project that satisfies the requirements of the California Environmental Quality Act(CEQA). In that EIR,the City has identified certain significant adverse impacts that could result from the adoption and implementation of the project. This document presents findings that must be made by the City before the project can be adopted.to comply with the requirements of Section 21081 of CEQA and Section 15091 of the State CEQA Guidelines, Under CEQA, the City, as lead agency, is required to make written findings explaining haw it has dealt with each alternative and each significant environmental impact identified in the draft EIR. The City may find: ■ that changes or alterations have been required in or incorporated into the project to avoid or substantially reduce the significant environmental effects identified in the EIR; • that such changes or alterations are within the purview and jurisdiction of another public agency and have been or should be adopted by that agency; or • that specific economic, social, or other considerations make infeasible the mitigation measures or project alternatives identified in the EIR. Each of these findings must be supported by substantial evidence in the administrative record. This findings document is divided into three sections, including this introduction. Section 2 presents findings on the feasibility of project alternatives considered in the EIR. Section 3 presents significant impacts of the proposed project that were identified in the EIR, the findings for those impacts and mitigation measures, and the rationale for those findings. The draft and final EIRs that were prepared for the project are incorporated into this document by reference, and the reader is referred to those documents for detailed information on impacts, mitigation measures, and alternatives. Copies of the documents are available for review at the offices of the City's Public Service Department (708 Third Street, Brentwood, CA 94513). City of Brennvood Wastewater Treatment Plant Expansion Findings of Fact with Discharge to Marsh Creek Project 1 February 1999 Section 2. Findings on Project Alternatives Considered in the Drat Environmental Impact Report In addition to evaluating the proposed project, the draft EIR contained detailed evaluations of two alternatives: Alternative 1, the No-Project Alternative, and Alternative 2, Raw Sewage Conveyance to Ironhouse Sanitary District. These alternatives are discussed below. The City finds that adoption of either of these two alternatives would be infeasible for the reasons presented below. ALTERNATIVE 1. NO-PROJECT ALTERNATIVE Under the No-Project Alternative, no improvements to the City's existing WWTP beyond the existing conditions described in the EIR would occur. Therefore, the City would take no action to improve or expand the WWTP beyond its current permitted capacity of 1.8 million gallons per day (mgd) (2.2 mgd rated capacity). Finding: Infeasible The City finds that the No-Project Alternative is infeasible for the following reasons: • it is not consistent with the City's General Plan policy to expand wastewater treatment facilities to accommodate existing and future development, • growth in Brentwood according to the general plan would be partially constrained by limited WWTP capacity, and • new development proposals awaiting City approval would require that the project proponents obtain costly wastewater treatment and disposal services from an alternative source. ALTERNATIVE 2. RAW SEWAGE CONVEYANCE TO IRONHOUSE SANITARY DISTRICT Under this alternative, the City would construct a raw sewage pump station on the existing WWTP site and an underground 30-inch force main from its WWTP to lronhouse Sanitary District's City of Brennvood Waste+vater Treatment Plant Expansion Findings of Fact with Discharge to Marsh Creek Project 2 February 1999 (ISD's) new WWTP site. The force main would be constructed east of the existing WWTP and would extend approximately 2,500 feet to Sellers Avenue. The pipeline would be extended north within Sellers Avenue right-of-way approximately 11,000 feet, crossing the Atchison, Topeka & Santa Fe Railroad (AT&SF) tracks to the intersection with Cypress Road and then approximately 5,000 feet west to another AT&SF crossing. West of the second railroad crossing, the pipeline would be attached to the Cypress Road bridge across Marsh Creek approximately 400 feet to its western bank. The pipeline would then proceed approximately 2,400 feet north along a dirt access road that runs parallel to the west bank of the creek to the Contra Costa Canal. The pipeline would be constructed under the canal, extend west on ISD property, and then extend north approximately 3,200 feet to ISD's new WWTP site. The total pipeline length would be approximately 4.6 miles. Conveyance of 10 mgd of raw sewage to ISD would require the district, under agreement with the City,to expand the ISD WWTP northeast of Oakley to a total of 18 mgd. To accommodate expanded treatment capacity needed for ultimate combined ISD/City wastewater flows,an additional 7,300-foot-long, 30-inch-diameter disposal pipeline to Jersey Island would be constructed parallel to ISD's existing disposal pipeline. The City's facilities plan indicates that this pipeline could be bored and jacked under or trenched across Dutch Slough. Finding: Infeasible Although the final EIR indicated that Alternative 2 is feasible from a technical and cost perspective, and although the final EIR has found no environmental impacts that could not be reduced to less-than-significant levels,the City finds that Alternative 2 is infeasible for the following reasons: • the City would not have a representative on the ISD Board of Directors; • the possibility exists that the City and ISD would not be able to agree on a long-term service contract; • the City's ability to provide reclaimed water cost-effectively would be reduced; • the City's level of control over facility expansion would be reduced; g the City's ability to enter into cooperative agreements with private industry could be reduced; • regulatory constraints related to crossing Marsh Creek,Dutch Slough,the Contra Costa Canal, and the AT&SF railroad tracks; and • loss of jobs resulting from closing the City's existing WWTP. City of Brentwood Wastewater.Treatment Plant Expansion Findings of Fact with Discharge to Marsh Creek Project February 1999 Section 3. Findings for Significant Impacts of the Project The City hereby makes the following findings for each significant impact of the project. HYDROLOGY AND WATER QUALITY Impact; Degradation of Water Quality in Marsh Creek The City finds that discharge of treated effluent to Marsh Creek could contribute to increased concentrations of priority pollutants, such as trace metals and organic compounds, in the creek. These pollutants could be toxic to aquatic organisms. This impact is considered significant. Mitigation Measures Identified in the EIR The EIR identifies the following mitigation measures to mitigate this impact to a less-than- significant level: a Mitigation Measure A-1. Design and operate the WWTP to meet National Pollutant Discharge Elimination System (NPDES) permit limits for priority pollutants. The WWTP shall be designed to meet NPDES permit limits for priority pollutants imposed by the regional water quality control board (RWQCB). When and if the California Toxics Rule is adopted and appropriate permit limits are included in the NPDES permit, the WWTP effluent shall also be treated as required to comply with applicable numeric criteria for priority pollutants. Treatment processes would be implemented and operated accordingly to help ensure compliance with NPDES permit limits. The WWTP operator would monitor performance of the treatment system to optimize and enhance processes that increase removal efficiency for trace metals and organic compounds. a Mitigation Measure A-2. Implement source control program. The City would implement a source control program to reduce concentrations of these pollutants in WWTP influent, in consultation with the RWQCB. Source control would target pollutants that are present at levels that exceed the discharge limits and commercial and industrial facilities that are known to have discharges containing the pollutants in question. City of Brentwood Wastewater Treatment Plant Expansion Findings of Fact With Discharge to Marsh Creek Project 4 February 1999 Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measures A-1 and A-2 and will design and operate the W WTP to meet NPDES permit limits for priority pollutants and require that a source control program be implemented. BIOLOGICAL RESOURCES Impact: Potential Loss of Nesting Habitat for Raptors The City finds that development of the proposed WWTP facilities would result in the conversion of approximately 1-5 acres of ruderal-annual grassland habitat, which may lead to the loss of nesting habitat for raptors such as the American kestrel and northern harrier. These raptors are protected by California Fish and Game Code Section 35133.5. This impact is considered significant. Mitigation Measure identified in the FIR The ElR identifies the following mitigation measure to mitigate this impact to a less-than- significant level: a Mitigation Measure C-1. Conduct a preconstruction survey for nesting raptors before construction begins and, if needed, establish a buffer area around active raptor nests. The City shall conduct a preconstruction survey for nesting raptors(white- tailed kite, northern harrier,American kestrel,and great horned owl) on the project site if construction activities will take place between March 1 and August 15. The survey shall be conducted by a qualified biologist during the same calendar year when the proposed activity is planned to begin, to determine if nesting birds of prey would be affected. if phased construction procedures are planned for the proposed activity, the results of the survey shall be valid only for the season when it is conducted. Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measure C-1 and will require that preconstruction surveys be conducted and, if necessary, buffer areas around active raptor nests be established. City of Brentwood Wastewater Treatment Plant Expansion Findings of Fact with Discharge to UarsA Creek Project 5 February 1999 Impact. Potential Mortality of Burrowing Owls or Loss of Foraging Habitat The City finds that implementation of the proposed project could eliminate one or more burrowing owl pairs or unpaired resident owls on the project site and would likely eliminate approximately 1-5 acres of foraging habitat. This impact is considered significant. Mitigation Measures Identified in the EIR The EIR identifies the following mitigation measures to mitigate this impact to a less-than- significant level: ■ Mitigation Measure C-2. Comply with California Department of Fish and Game (DFG) mitigation guidelines (for construction activities between February 1 and August 31). Mitigation for impacts on burrowing owls during the breeding season shall follow the mitigation guidelines outlined in the DFG Staff Report on Burrowing Owl Mitigation. The City, in consultation with DFG, shall retain a qualified biologist to conduct a preconstruction survey during the breeding season (approximately February I through August 31) of the proposed project site during the same calendar year when construction is planned to begin. The surveys will document whether burrowing owls are nesting on or directly adjacent to any proposed project areas. Because phased construction is planned for the proposed project, the results of the breeding-season survey shall be valid only for the season when the survey is conducted. ■ Mitigation Measure C-3. Conduct a preconstruction survey for burrowing owls outside the breeding season before construction begins (for construction activities between September 1 and January 31). The City, in consultation with DFG, shall retain a qualified biologist to conduct a preconstruction survey outside the breeding season (approximately September I through January 31) on the proposed project site during the same calendar year when construction is planned to begin. The surveys will document whether burrowing owls are,using the area during the nonbreeding season on or directly adjacent to any portion of the project area. Because phased construction is planned for the proposed project,the results of the nonbreeding-season survey shall be valid only for the season when it is conducted. Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measures C-2 and C-3. The City finds that it is feasible to comply with DFG burrowing owl mitigation guidelines for construction activities that occur between February 1 and August 31 and to conduct preconstruction surveys for burrowing owls outside the breeding season for construction activities that occur between September I and January 31. City of Brvnnvood Wastewater Treatment Plant Expansion Findings of Fact with Discharge to Marsh Creek Project 6 February 1999 PUBLIC HEALTH Impact: Incidental Exposure of Workers and the Environment to Unknown Hazardous 'Wastes during Construction Construction of the proposed project could result in the incidental exposure of workers and the environment to hazardous wastes. Although this impact is considered unlikely,it is nonetheless considered significant because unidentified hazardous wastes could be encountered during construction, resulting in a potential health hazard. Mitigation Measures Identified in the EIR The EIR identifies the following mitigation measure to mitigate this impact to a less-than- significant level: ■ Mitigation Measure D-1. Stop work in the area and assess contamination if hazardous materials are encountered. If hazardous wastes are encountered during construction,work in the area shall stop and the City shall asses the nature and extent of the contamination and determine if remediation is necessary. If additional remediation is necessary,the City would prepare a site remediation plan and a health and safety plan. The City would then retain a qualified contractor to clean up the waste in accordance with those plans and applicable state and federal regulations. Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measure L-1 and will require that construction activities will stop if hazardous materials are encountered and the situation will be assessed. AIR QUALITY Impact: Increase in PM10 Emissions from Construction Vehicle Exhaust and Grading Activity Construction activities associated with the WWTP would result in a significant increase in particulate matter 10 microns or less in diameter (PM 10) and emissions from construction vehicle exhaust and grading activity. This impact is considered significant. City of Brentwood Wcsieivaier Treatment Rant Expansion Findings of Fact with Discharge to Marsh Creek Project 7 February 1999 Mitigation Measures Identified in the EIR The EIR identifies the following mitigation measures to mitigate this impact to a less-than- significant level: ■ Mitigation Measure E-I. Implement dust control measures. The City will implement the following basic control measures to control dust emissions: a. Vater all active construction areas daily, or as required. b. Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least 2 feet of freeboard. c. Pave,apply water daily to,or apply (nontoxic)soil stabilizers on,all unpaved access roads, parking areas, and staging areas at construction sites. d. Sweep(with water sweepers)all paved access roads,parking areas,and staging areas at construction sites, as needed. e. Sweep streets (with water sweepers) if soil is visible on adjacent public streets, as needed. f. Hydroseed or apply (nontoxic) soil stabilizers to inactive construction areas (previously graded areas that will be inactive for 10 days or more), g. Enclose, cover, water twice daily to, or apply (nontoxic) soil binders to exposed stockpiles (dirt and sand). h. Limit traffic speeds on unpaved roads to 15 mph. i. Install sandbags or other erosion control measures to prevent silt runoff to public roadways. j. Replant vegetation in disturbed areas as quickly as possible. a Mitigation Measure E-2. Implement measures to reduce construction-related emissions. The City will implement the following control measures to reduce construction-related emissions: a. Minimize idling time for construction equipment (e.g., a maximum of 5 minutes). b. Maintain properly tuned equipment. City of Brennvood Wastewater Treatment Plant Expansion Findings of Fact wiih Discharge to Morsh Creek Project 8 February 1999 Finding: Mitigation Feasible and Required The City finds it is feasible to adopt Mitigation Measures E-I and E-2 and will require dust control measures and measures to reduce construction-related emissions to be implemented. Impact: Increase in Odor Complaints Expansion of the WWTP could result in an increase in odor complaints by adjacent landowners. This impact is considered significant. Mitigation Measures Identified in the EIR I The EIR identifies the following mitigation measures to mitigate this impact to a less-than- significant level: •- a Mitigation Measure E-3. Maintain an easement around WWTP boundaries. The City shall strive to maintain a minimum 30£1-foot easement/buffer around the plant boundaries to prevent urban encroachment of residential housing into the most odor- intensive area surrounding the plant. Such an easement/buffer would reduce the possibility of odor complaints by limiting the number of potentially sensitive receptors present within 300 feet of the plant's boundaries. a Mitigation Measure E-4. Evaluate odor control measures before construction begins on each project phase. The need for odor control measures should be evaluated before construction begins on each of the four project phases. If operation of the plant during any phase results in an increase in confirmed odor complaints that exceeds the amount allowed by the Bay Area Air Quality Management District(BAAQMD)permit (five per month), the City should identify and resolve the source of the complaint and incorporate appropriate odor control measures into the project. Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measures E-3 and E-4 and will require an easement to be maintained around the WWTP boundaries and to evaluate odor control measures before construction begins on each project phase. City of Brentwood Wastewater Treatment Plant Expansion Findings of Fact with D;scharge<o Marsh Creek Project 9 February 1999 LAND USE, NOISE, AND ENERGY Impact: Increase in Gas and Electricity Consumption Expansion of the WWTP would result in an increase in fuel and electricity consumption. This impact is considered significant. Mitigation Measure Identified in the EIR The EIR identifies the following mitigation measure to mitigate this impact to a less-than- significant ess-than- signi cantlevel: a Mitigation Measure F-1. Coordinate with Pacific Gas and Electric Company. The City will coordinate with Pacific Gas and Electric Company (PG&E) during the predesign for each phase of the project to allow PG&E adequate time to assess the incremental electrical service requirements of the project. Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measure F-I and will coordinate with PG&E during the predesign phase for each phase of the project to allow PG&E adequate time to assess the incremental electrical service requirements of the project. CULTURAL RESOURCES Impact: Damage to Currently Unknown Cultural Resources Construction or operation of the WWTP could result in the discovery of previously unknown cultural resources. This impact is considered significant. Mitigation Measure Identified in EIR The EIR identifies the following mitigation measure to mitigate this impact to a less-than- significant leve,I;„, . 'A Mitigation Measure H-1. Stopwork in the area if cultural resources are unearthed. If buried cultural materials are unearthed during project construction,work must halt in the vicinity of the find until a qualified archaeologist can assess its significance. If City of 8rennvood Wastewater Treatment Plant Expansion Findings of Fact with Discharge to Marsh Creek Project 10 February 1999 human remains are unearthed during construction,no further disturbance shall occur until the County Coroner has made the necessary findings regarding origin and disposition as required by California Public Resources Code Section 5097.98. Finding: Mitigation Feasible and Required The City finds that it is feasible to adopt Mitigation Measure H-1 and will require that work will be stopped in the area if cultural resources are unearthed. Cit}'of Brentwood Wastewater Treatment Plant Expansion Findings of Fact with Discharge to Marsh Creek Project February 1999 ENV{RtNMNT,4E:. .CMPACT REPCtRT FOR 'T:HE CfTY.,OF BRENTWOOD. WASTEWATER.TREATMENT.'PLANT EXPANSION., WITH DISCHARGE :TC7. .MARSH •:QREEK` (STATE,CLEARkN.CE-OUSE NC3: 9,80 1' 2058) ;Cry of. rentwood Nu jic'Worlcs-Qepartment' 7178 Third Strey 'Brentwood,-CA 94 I ontact}.'Thorn Ptead;:Public,Services Fluector 92S/b34-7098 _. ENVlROti1ME(NrAL CQNSULTANr! . Jones& CotCeS Associaees, IIIc. 2600'.V_Streef;51�t . 1(}0 Sacramento, CA .95.81$-1914.`., •:Cbnfa�.t:,SfevoCenterwa.tl., _ 91,i/737-300 : j JUNE 26;`7,998 � 4 Table of Contents Page Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-1 Chapter 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 PURPOSE OF THE EIR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 PUBLIC INVOLVEMENT PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 SCOPE OF THE EIR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 TERMINOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3 MITIGATION MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 ORGANIZATION OF THE EIR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 Chapter 2. Project Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 LOCATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 SURROUNDING LAND USES . . _ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 EXISTING WASTEWATER TREATMENT FACILITIES . . . . . . . . . . . . . . . . . . . . . 2-1 Short-Term Facility Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 NEED FOR LONG-TERM FACILITY IMPROVEMENTS . . . . . . . . . . . . . . . . . . . . 2-5 PROJECT OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 PROJECTED FLOW AND EFFLUENT QUALITY . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 California Toxics Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7 Title 22 Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7 PROPOSED PROJECT FACILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9 Expansion and Upgrade of Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9 Discharge of Effluent to Marsh Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11 Expansion of Biosolids Handling Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11 PROJECT PHASING AND IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11 ALTERNATIVES TO THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . 2-12 APPROVALS AND SPECIAL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13 Chapter 3. Environmental Setting, Impacts, and Mitigation Measures . . . . . . . . . . . . . . 3-1 Chapter 3A. Hydrology and Water Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-I SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-1 Surface Water Hydrology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-1 Groundwater Hydrology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-3 Surface Water Quality . . . . . . . . . . . . . . . . . . . . . . . . I . . . . . . . . . . . . 3A-3 Effluent Quality at the Existing Wastewater Treatment Plant . . . . . . . . . . . . 3A-5 Groundwater Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-9 i Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-1 I IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-17 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-17 Hydrologic Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . 3A-17 Water Quality Impacts and Mitigation Measures 3A-19 Chapter 3B. Geology, Soils, and Seismicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313-1 SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3B-1 General Topography and Geologic Structures . . . . . . . . . . . . . . . .. . . . . . . . . . 313-1 Soil Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3B-2 IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313-2 Significance Criteria . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313-2 Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313-3 Chapter 3C. Biological Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-I SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-1 Habitat Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-2 Special-Status Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-3 IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . 3C-15 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-15 Chapter 3D. Public Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3D-1 SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3D-1 Public Health . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . 3D-1 Public Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3D-2 Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3D-3 IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . 3D-5 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3D-5 Impacts and Mitigation Measures . . . . . . . . . . . . . . . 3D-5 Chapter 3E. Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-1 SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..3E-1 Regional Topography and Climate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-1 Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-1 Existing Air Quality Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-4 IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-6 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-6 Conformity Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-7 Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-7 Chapter 3F. Land Use,Noise, and Energy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-1 SET-TING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-1 LandUse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-1 Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-1 Energy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ 3F-2 Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-2 ii .............................. ....................................................... ............................... ....................................................''I'', , IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-3 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-3 Land Use Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-4 Noise Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-5 Energy Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3F-6 Chapter 3G. Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3G-1 SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3G-1 Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3G-I IMPACTS OF THE PROPOSED PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3G-2 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3G-2 Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3G-2 Chapter 3H. Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 311-1 SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-1 Prehistoric Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 311-1 Ethnographic Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 311-2 Historical Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-3 Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-5 METHODS AND RESULTS OF ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-6 Prefield Research . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I . . . . . . . . . . . . . . 311-6 Native American Consultation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 311-7 Field Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-7 Known Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-7 IMPACTS AND MITIGATION MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-9 Significance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 311-9 Chapter 4. Other CEQA-Required Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES . . . . . . . . . . . . . 4-1 SIGNIFICANT AND UNAVOIDABLE IMPACTS . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 GROWTH-INDUCING IMPACTS . . . . . . . . . . . . . . . . . . I . . . . . . . . . . . . . . . . . . . . . 4-2 Relationship of the Proposed Project to Growth . . . . . . . . . . . . . . . . . . . . . . . . 4-2 Growth-Inducement Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4 CUMULATIVE IMPACTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . 4-5 Requirements for Cumulative Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . 4-5 Projection Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 Buildout Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 Approach to Cumulative Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 Impacts and Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7 Chapter 5. Alternatives Analysis . . . . . . . . . . . . . . . . . . . . . . . . _ . . . . . . . . . . . . . . . . 5-1 CEQA REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 ALTERNATIVES ADDRESSED IN THE EIR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 Wastewater Treatment and Disposal Alternatives Considered and Rejected 5-2 Wastewater Treatment and Disposal Alternatives Considered and Evaluated 5-3 iii ALTERNATIVES ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6 Alternative 1. No Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6 Alternative 2. Raw Sewage Conveyance to ISD . . . . . . . . . . . . . . . . . . . . . . . . 5-7 Environmentally Superior Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-19 Chapter 6. Citations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 PRINTED REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 PERSONAL COMMUNICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-5 Chapter 7. List of Preparers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1 Appendix A. Notice of Preparation Appendix B. National Pollutant Discharge Elimination System Permit Appendix C. Hydraulic, Dissolved Oxygen, and Electrical Conductivity Analysis for Brentwood Wastewater Treatment Plant iv ........................................................... ...................... List of Figures_ Figure Page 2-1 Regional Location of Brentwood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 2-2 Existing Treatment Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2-3 Proposed Treatment Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10 3A-I Project Site and Location of Major Surface Water Resources . . . . . . . . . . . . . . . . . 3A-2 3A-2 Existing Wastewater Treatment Facilities and Water Quality Sampling Sites . . . . . 3A-5 3H-1 Cultural Resources Survey Coverage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3H-8 5-1 Alternative 2: Raw Sewage Conveyance to ISD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4 v List of Tables Table Page ES-I Summary of Impacts and Mitigation Measures for the Marsh Creek WWTPProject . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-4 2-1 Anticipated Discharge Requirements for the City of Brentwood Marsh Creek WWTP Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8 3A-1 Summary of Conventional Parameters in Marsh Creek . . . . . . . . . . . . . . . . . . . . . . . 3A-6 3A-2 NPDES Permit Limits for BOD and Total Suspended Solids for the Brentwood WWTP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ 3A-8 3A-3 Sample Results(gg/l) for Priority Pollutants in City of Brentwood WWTP Groundwater Extraction System Effluent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-10 3A-4 Anticipated NPDES Permit Limits for the Proposed Brentwood WWTP . . . . . . . . 3A-13 3A-5 Proposed California Toxics Rule Water Quality Limits (ugll) from the City of Brentwood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3A-14 3C-1 Special-Status Plants Potentially Occurring on the Marsh Creek WWTP Project Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-5 3C-2 Special-Status Fish and Wildlife Species with Potential to Occur in the Marsh Creek WWTP Project Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3C-7 3E-1 Ambient Air Quality Standards Applicable in California . . . . . . . . . . . . . . . . . . . . 3E-3 3E-2 Summary of Ozone and PM10 Monitoring Data . . . . . . . . . . . . . . . . . . . . . . . . . . 3E-5 List of Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-21 vi .................................................. ...... Executive Summary i INTRODUCTION This executive summary for the draft environmental impact report (EIR) for the City of Brentwood's(City's) wastewater treatment plant(WWTP)project briefly describes the objectives of and alternatives to the proposed project. Known areas of controversy and issues to be resolved in this EIR are summarized. A summary table is provided that identifies impacts of the proposed project and mitigation measures that would reduce significant impacts to a less-than-significant level. PROJECT OBJEC'T'IVES The City's WWTP project has been designed to meet needs for increased long-term wastewater treatment and disposal capacity anticipated by the City and the California Regional Water Quality Control Board, Central Valley Region (RWQCB). The objectives of the proposed project are to: E provide the necessary treatment and effluent disposal capacity to meet the demands of growth that has already been evaluated and approved under the general plan, a provide cost-effective and reliable wastewater treatment and disposal facilities, ■ locate and operate the proposed new facilities in a manner that will minimize adverse environmental effects, and ■ maintain compliance with National Pollutant Discharge Elimination System permit requirements of the RWQCB and protect water quality and public health. ALTERNATIVES .EVALUATED IN THE EIR This draft FIR includes an analysis of the proposed project, one action alternative, and the No-Project Alternative. Descriptions of each of the alternatives is provided below. Refer to Chapter 5 "Alternatives Analysis", for a detailed evaluation of alternatives. City of Brentwood WWTP Project Executive Summary Draft EIR June?6, 1998 ES-1 Proposed Project The proposed project would be located at the site of the existing WWTP. The proposed WWTP would be designed to produce filtered secondary effluent to meet the appropriate standards for discharge to Marsh Creek and(possibly) for reclamation. These facilities would be constructed in the same area now occupied by the existing facilities, and the existing facilities (e.g., disposal ponds, emergency holding pond, and sludge storage area)would be removed. Treatment facilities currently in use would be incorporated into the proposed facilities. i The proposed project includes three principal components: ■ a four-phase expansion and upgrade of the City's existing wastewater treatment facilities and construction of new facilities to increase flow from 1.8 to 10 million gallons per day (mgd), ■ direct discharge of treated effluent into Marsh Creek, and ■ expansion of the biosolids handling facilities to allow disposal to land or landfill. Alternative 1. No-Project Alternative The No-Project Alternative is defined as no improvements to the City's existing WWTP beyond the existing conditions described in this EIR. Under this alternative, the City would take no action to improve or expand the WWTP beyond its current permitted capacity of 1.8 mgd (2.2 mgd rated capacity). i Alternative 2. Raw Sewage Conveyance to Ironhouse Sanitary District Under Alternative 2, the City would construct a raw sewage pump station on the existing WWTP site and an underground 30-inch force main from its WWTP to Ironhouse Sanitary District's (ISD's) new WWTP site. Total pipeline length would be approximately 4.6 miles. Conveyance of 10 mgd of raw sewage to ISD would require ISD and the City, under a contract service agreement, to expand the ISD WWTP, located northeast of Oakley, to a total of 18 mgd. Expansion of the ISD WWTP to serve both ISD and the City would operate under ISD's current expansion plan for 8 mgd until approximately 2017. Beyond 2017, combined ISD/Brentwood wastewater flows (provided the annual growth rate remains constant) are projected to be approximately 18 mgd in 2062,which is beyond the planning horizon for both the City's and .ISD's facilities plans. To accommodate expanded treatment capacity needed for ultimate combined City of Brentwood WW!P Project Executive Summary Draft EIR ES-2 June 26, 1998 i ISD/City wastewater flows, an additional 7,300-foot-long, 30-inch-diameter disposal pipeline to Jersey Island would be constructed parallel to ISD°s existing disposal pipeline. The City has also incorporated environmental control measures into its Alternative 2 design that would eliminate or reduce to acceptable levels all of the possible environmental effects. 1 KNOWN AREAS OF CONTROVERSY i Section 15123 of the State CEQA Guidelines requires that the summary of an EIR must identify areas of controversy known to the lead agency, including issues raised by public agencies and the public. No known areas of controversy have been identified regarding the proposed project as part of the Notice of Preparation process. ISSUES TO UE RESOLVED i Section 15:123 of the State CEQA. Guidelines requires that the summary of an EIR must identify issues to be resolved, including the choice among alternatives and whether or how to mitigate significant effects of the proposed project. For the proposed project,the primary issue to be resolved is design of the new WWTP to meet surface water discharge requirements in Marsh Creek. The City is also conducting a parallel environmental review for conveyance of raw sewage to the Ironhouse Sanitary District. The results of these processes will be used to decide which long- ,i term alternative to implement. SUMMARY OF IMPACTS OF THE PROPOSED PROJECT i Table E -I present the impacts of the proposed project as analyzed in the draft EIR, identifies the level of significance of each impact before mitigation, recommends mitigation.measures, and identifies the level of significance after mitigation for each impact. City of Brem wood WWTP Project larectitive Summary Draft EIR .lune 26, 1998 ES-3 cj t �s 42 rr CL cr a. rn w U G» ai a" O O w W tU aU C C C cq C C ea a c ° G z 7 w Z cz 64 O o of V U V U U ao c m cc mco c 4k rn �, v, h C uSOn vii c� > ..0 v m A) nu u 0 7i ' Jj owl, c 4- 0 m bj Q, t N tz of O 4.. bt} CU C7 y .j ¢ O :+^.'C7 y U Cd, O icC. .� U O O O '✓ c0 .,C �` U CP cia c,�.. CZ U O > w TId ctl cS cz t7 :� C C ¢ w LZ 4 G ^'"°' Cd a� bto a r �' y .G C. � � L "b `�.' C c., .G ^' ✓� U'1 C rn CL V � C1 C r > N C wvUr chi y '•Ur' :n O X 'd1 ice.. 2 U O I ES-4 i �r y lu v An a 1 Cd G Y CC q> to L!} ry yy L � y d t3 C 7 _ so Cs• 0 v LnL L 4 e � 4., v _ � .00 tz.:: ata cz oD _bA u0 C/5 � � in •v' � `� V1 Yl N U L ylu.e y fJ t C SG O 4 b4 b ~ U In 4 L Cid 4", 41 C o D y bD D z y t5 v 73 "1 `� tC •G ca tn 6. qD p y Ca.,o .FJ .e �7, L cn vs � U �•• sn cn N v',. rn ,fj u -c� n. F C c,.. p Cs ccs sd.. „ y cLG ed,, •coq .Q ,1,,. d r d C D... 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[ Or N U C1 czCd U y y y t $ x cc chi c`3i ar as Ce m cd 4u" LIZ a�o _ oco t-lo co V7 rG N N Vi N N 'N 'U^ O L [C R7 u C O _ N 7 7 CSU N N h N N V1 N yj T u° i C � •� ctl A O 3G y a1 itY eif u�j -d 3 ,r •,.., ymj O N v E N � bD U U U W o 0 v d n o c o o cc Q O 4, O y d! U N U u .T. u U u .,�.� .U.. U !U t.. T L y C L U y'~j dl tg O S�. ; u'. O 'a ni O G u O �_ y 2 �4 3 o v m = Cl._ - o-� n er . c v5 'C O C7 .- N O 65 O 1T '� (� � w � •Zi% d�,Y o � T 6t O p U U G .; yUj U C CJ twCL '� O v •6 Or O •W Cc, ES-7 i I I r 1 City of Brentwood W'WTP Project Executive Summary Draft EIK ES-8 June 19, 1998 Chapter 1. Introduction This environmental impact report(EIR) assesses the potential environmental effects of the proposed expansion of the wastewater treatment plant (WWTP)for the City of Brentwood (City). The City proposes to expand wastewater treatment from 1.8 to 10 million gallons per day (mgd) (in four phases) and discharge treated effluent to Marsh Creek. As required by Section 15161 of the California.Environmental Quality Act of 1970(CEQA),as amended,this EIR examines the expected individual and cumulative impacts of the proposed project. This ETR also identifies mitigation measures to minimize potential adverse impacts, and it evaluates reasonable alternatives to the proposed project, including the No-Project Alternative. The City is the lead agency for the project evaluated in this EIR and, as such, is responsible for certifying the EIR and approving the project. i PURPOSE OF THE EIR The City has prepared this EIR to serve several purposes: 9 satisfy the requirements of CEQA; B inform the general public, local residents,and responsible and interested public agencies of possible environmental impacts of the proposed project, mitigation measures to avoid or minimize those impacts, and alternatives to the proposed project; and inform decision makers of the environmental consequences of the project to aid them in deciding whether to approve the project. As described in the State CEQA Guidelines, a public agency that proposes to implement a project is charged with the duty to avoid or minimize environmental damage where feasible. In discharging this duty, the public agency has an obligation to balance a variety of economic, environmental, and social objectives (Section 15021 of the State CEQA Guidelines). The EIR is a public information document that is used to publicly disclose significant effects of a proposed project on the environment and indicate the manner in which those significant effects can be avoided or mitigated; identify any unavoidable adverse impacts that cannot be mitigated; and identify reasonable and feasible alternatives to the project that would eliminate any significant adverse effects or reduce the impacts to a less-than-significant level. The EIR also must disclose City of Brentwood W6P7P Project Chapter!, Introduction ©raft 8YR June 26, 1998 1-1 growth-inducing impacts; effects found not to be significant; and significant cumulative impacts of all past, present, and reasonably anticipated future projects. PUBLIC INVOLVEMENT PROCESS Three key periods during the preparation of the EIR allow agencies and the public the opportunity to participate in the environmental review process: H Scoping comment period—The City distributed a notice of preparation (NOP) of an EIR on December 19, 1997,to identify issues of concern regarding the scope and content of the EIR. The NOP and comment letters are provided in Appendix A. ■ Draft EIR comment period—The City is circulating this draft EIR and will conduct a public hearing to present the results of the draft EIR and solicit comments. The purpose of the meeting is to provide agencies and the public with opportunities to comment on or express concerns regarding the contents of the draft EIR. Those comments will then be addressed in the final EIR. ■ Final EIR—The City will present responses to comments in the final EIR and will hold a public hearing before certifying the final EIR and approving the project. Agencies and the public can provide additional comments on issues raised in the document during the hearing. SCOPE OF THE EIR The State CEQA Guidelines allow a lead agency to forego initial environmental review of I a proposed project if it determines that an EIR is clearly required (Section 15060[c]). The City, as lead agency, has already determined through previous studies that the proposed project has the potential to significantly impact several types of environmental resources. Therefore.an initial study i checklist has not been prepared for the proposed project. i Through the process of preparing previous studies, and as a result of comments received on the NOP, the City determined that the following topics should be analyzed in this EIR: ■ hydrology and water quality; s geology and soils; ■ biological resources; • public health and safety; ■ air quality; +� land use, noise, and energy; R transportation; and T City of Brentwood WWTP Project Chapter 1. Introduction Draft EIR I-2 June 26, 1998 j a cultural resources. i TERMINOLOGY This EIR uses a variety of terms to describe the level of significance of impacts identified during the course of the environmental analysis. The following are definitions of terms used in this j EIR: ■ A less-than-significant impact is considered to cause no substantial adverse effect on the environment and requires no mitigation measures. i n A significant impact is considered to cause a substantial adverse effect on the environment but can be reduced to a less-than-significant level by implementing mitigation measures. j ■ A significant unavoidable impact is considered to cause a substantial adverse effect on i the environment for which no feasible mitigation measures are available to reduce the impact to a less-than-significant level. i a A beneficial impact is considered to cause a positive change in the environment. ' The EIR also recommends mitigation measures to reduce impacts of the project. Section 15370 of the Mate CEQA Guidelines defines mitigation as follows: a. avoiding the impact altogether by not taking a certain action or parts of an action; { b. minimizing impacts by limiting the degree or magnitude of the action and its implementation, c. rectifying the impact by repairing, rehabilitating, or restoring the impacted environment; d. reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and e. compensating for the impact by replacing or providing substitute resources or environments. City of Brentwood WWTP Project Chapter 1. Introduction Draft EIR .Tune 26, 1998 1-3 MITIGATION MONITORING CEQA requires that when a public agency makes a finding based on an EIR, it must adopt a reporting or monitoring program for those measures that it has adopted or made conditions of the project approval to mitigate or avoid significant effects on the environment(Pub. Res. Code Section 210$1.6). The reporting or monitoring program must be designed to ensure compliance during project implementation. i The mitigation monitoring program for the proposed project will be prepared and made available for review with the final EIR. The mitigation monitoring program will be considered by the City, along with the EIR on the proposed project, when making a decision to approve the proposed project. i ORGANIZATION OF THE EIR The draft EIR is organized into the following chapters: ■ Chapter 1,"Introduction",provides an introduction to and overview of the intended uses of the EIR and the review and certification process. ■ Chapter 2,"Project Description",provides a detailed description of the project,including location,background information,project objectives,projected flaw and effluent quality, proposed project facilities,and approvals and special requirements that are necessary for the proposed project. ■ Chapter 3, "Environmental Setting, Impacts, and Mitigation Measures", contains analyses of project-specific resources identified during the NOP process. Each resource topic area describes the environmental and regulatory setting of the project with regard to that particular topic, standards of significance, methods used to evaluate impacts, and recommended mitigation measures to reduce any significant impacts to a less-than- significant level. ■ Chapter 4, "Other CEQA-Required Analyses", provides discussions required by CEQA regarding impacts that would result from implementation of the proposed project, including possible growth-inducing impacts, cumulative impacts, significant and unavoidable impacts, and significant irreversible environmental changes. ■ Chapter S,"Alternatives Analysis",describes the alternatives to the proposed project and their associated environmental impacts. City of Brentwood WWTP Project Chapter 1. Introduction Draft EIR 1-4 June 16, 1998 i I 1 0 Chapter 6, "Citations", provides information on printed references and personal communications used in preparing the EIR. ■ Chapter 7,"List of Preparers", lists the individuals involved in preparing this EIR. a A foldout list of acronyms and abbreviations is provided Between the chapters and appendices to assist the reader. In addition, several appendices are included at the end of this report: a Appendix A, "Notice of Preparation",contains the NOP and associated comment letters for this project. i ■ Appendix B,"National Pollutant Discharge Elimination System Permit",contains a copy of the permit issued in March 1996. by the California Regional Water Quality Control Board, Central Valley Region(RWQCB). ■ Appendix C, "Hydraulic, Dissolved Oxygen, and Electrical Conductivity Analysis for E Brentwood Wastewater Treatment flan",contains technical information used to prepare Chapter 3A, "Hydrology and Water Quality" City of Brentwood WWTP Project Chapter 1. Introduction Draft EIR .June?G, 1998 I-5 City of Brentwood WWTP Project Chapter 1. Introduction Draft EIR June 2 6, 1998 1-6 ............................... .................... ................................. . . ............................... . ...................I........ ..................... ....... I I Chapter 2. ]Project Description LOCATION The City of Brentwood is located in the Sacramento-San Joaquin River Delta area on the western edge of the San Joaquin Valley, approximately 50 miles east of San Francisco in Contra Costa County (Figure 2-1). Brentwood was historically an agricultural community and approxi- mately 60% of the presently incorporated area consists of agricultural fields and vacant land. Approximately 29%of the incorporated area is single-family residences. Commercial development ! in Brentwood is concentrated downtown in a traditional-style central business district. i The project area is located in the northeast portion of the Brentwood planning area north of Sunset Road and east of Marsh Creek. Communities near Brentwood are Antioch to the northwest, unincorporated Oakley to the north, Discovery Bay to the east, and Byron to the southeast. SURROUNDING LAND USES The site of the existing City WWTP is currently designated as Public Facilities on the general plan land use map and is being used in accordance with the general plan and zoning ordinance. The primary land uses in the project area are Sunset Park (a recreational area with baseball fields, picnicking facilities, and open space areas), an apple orchard to the southwest, Marsh Creek to the north and west, a solid waste transfer facility to the southeast, an agricultural drainage canal east of the waste facility, and an agricultural processing area to the southeast on the other side of the canal. EXISTING WASTEWATER TREATMENT FACILITIES i The existing WWTP is located on approximately 70 acres of land owned by the City and abuts Marsh Creek(Figure 2-2). The treatment plant was designed to accommodate an average dry- weather flow of 1.8 mgd and a peak wet-weather flow of 5 mgd. The existing facility was constructed in 1973 and consists of influent screw pumps, screens, secondary treatment processes using two oxidation ditches, secondary clarifiers, aerobic sludge digestion areas, and sludge-drying beds with effluent disposal to nine percolation ponds covering approximately 18 acres. A groundwater extraction system around the perimeter of the site consists of monitoring wells and a discharge pipeline that collects a portion of the infiltrated secondary City of Brentwood WWTP Project Chapter 2. Project Description Draft EIR June 26, 1998 2-1 S i 1 r• I i I r�4 \ I 1 1 ' ` w 680 x i a 4WD'•�` s'�" ?:`T 780 � Flrver � � W Be sPR pp D'h: add•. .s�""` .*rw°`rs' .-,�t.} 4 . .: s? Q Concord Oakley /1 f 6 ��'s`'Cr 4 80 Brentwood r, 24 O Walnut Creek E c rom Rd. � 4 i p Byron .�$ �� Ciifion \ Court 3't',' Fnreaay 680 <:�-N�: ta \ GortC Go• a Dublin 580 0 Livermore I 0 5 Miles + I Figure 2-1 QaA Jones&Stokes Associates Inc. ' Regional Location of Brentwood 2-2 i E-2 Discharge to Marsh Creek t � 1 t � E Creek Groundwater .' •_- __-_-____--__- :___-_- Extraction- -i j System 1 #J f t #6 ! #11 t #4 ! t Emergency ! Disposal 1 #3 Existing Disposal #7 Pond 1 i VVV #2 Ponds t E t t # # 1 #12 it Emergency 1 Existing WWTP Disposal I Facilities #9 Pond 12"Culvert 1 E ]existing t ✓✓' Sludge t t rt; 11 Molding Pond #10 1 ' Disposal s t ' Emergency Pond 1 Molding Pond t i t E-1 Discharge l to Marsh Creek t ------_-__-�-------_---+ ---------------_--- ---------------------------1 Property Line i #13 Disposal Solid Pond Waste N Facility Landscape Berm d 175 350 - - _ - - - Scale in Feet - - - Sunset Park a i Jones&Stokes Associates, Inc. Figure 2-2 Existing 'Treatment Facilities 2-3 effluent from the disposal ponds,mixes it with groundwater,and discharges the combined water into ; Marsh Creek under a National Pollutant Discharge Elimination System (NPDES)permit from the Central Valley RWQCB. No effluent is discharged directly to surface water. Short-Term Facility Improvements Because of recent operational changes at the WWTP, the City and RWQCB has become I concerned about the current and future capacity of the facility. Specifically, increasing concern exists regarding percolation rates in the effluent percolation ponds, potential Marsh Creek bank failure and bank instability, and soil subsidence around oxidation ditch 1. On August 28, 1996, the I RWQCB issued a letter that required the City to submit a technical report assessing the capacity of the effluent percolation ponds and the structural integrity of the treatment facilities. A report prepared in October 1996 rated the current effluent disposal capacity at 1.4 mgd. Based on this information, the City implemented the following improvements to increase effluent disposal capacity at the WWTP: 1 ■ secondary effluent is discharged during emergency situations to an area south of disposal pond 9; ■ groundwater is pumped from new and existing groundwater monitoring wells to reduce groundwater levels and thereby enhance the performance of the effluent disposal ponds; and ■ a groundwater extraction system was installed between disposal pond 6 and Marsh Creek, which allows the City to make full use of disposal pond 6 while reducing the potential for bank instability along Marsh Creek. j With growth expected to continue in the city and surrounding area and the solution to the long-term wastewater treatment and disposal capacity shortage not anticipated to be completed until ' 2001, interim improvements were necessary to increase disposal capacity and address immediate RWQCB concerns. The interim improvements selected by the City were construction and operation of two new infiltration/percolation ponds for disposal of treated effluent. These ponds, which were j constructed south of the existing WWTP facilities on property currently owned by the City (Figure 2-2), provide approximately 0.4 mgd of additional effluent disposal capacity, which is adequate to serve existing development. The new disposal ponds began operating in March 1998. With the effluent disposal improvements and the provision of two additional effluent percolation ponds,the City's total effluent disposal capacity is estimated at 2.2 mgd. An initial study/negative declaration for construction and operation of the two effluent percolation ponds was approved on February 24, 1998 (Jones & Stokes Associates 1998a). i J City of Brentwood WWTP Project Chapter 2. Project Description !. Draft EIR 2-4 lune 26, 199E i As a result of heavy rainfall during January and February 1998, the City found it necessary to also construct two smaller emergency disposal ponds east of the existing ponds. The City now has 13 effluent disposal ponds covering approximately 32 acres. NEED FOR LONG-TERM FACILITY IMPROVEMENTS The population of Brentwood has grown consistently since the city was incorporated in 1948. This population growth led to the need, in 1983, to update the City's general plan. The population has continued to grow rapidly since 1983, and growth pressures have required the continued expansion of services provided by the City's public works department, including wastewater treatment capacity. Montgomery Watson prepared a wastewater facilities plan to address Brentwood's short-term " and long-term needs for increased wastewater treatment capacity (Montgomery Watson 1997x). According to the facilities plan,the population in 1997 was approximately 11,800. The Association of Bay Area Governments projected that in 2010 Brentwood would have a population of approximately 43,0100 (City of Brentwood 1993). The facilities plan accounted for the estimated population beyond 2020,which is expected to be approximately 100,000. However,the general plan analyzed population growth only to 2010, which is estimated to be 79,574. The impacts of the additional potential growth that would be accommodated by the proposed project are addressed in detail in Chapter 4, "Other CEQA-Required Analyses". , Expansion of the existing WWTP to accommodate growth was addressed in the facilities plan prepared by Montgomery Watson. That plan summarized the results of a comprehensive study to develop and evaluate wastewater treatment and disposal alternatives for the City's WWTP. Lang-term planning efforts recommended in the facilities plan included the following: a conducting environmental analyses for selected alternatives (see "Alternatives to the Proposed Project" below), a assessing the feasibility of a contract service agreement with staff and board members of Ironhouse Sanitary District(ISD), a reviewing and updating the Sewer Enterprise 5-Year Plan and Rate Study, and a submitting a final version of the facilities plan to the California State eater Resources Control Board (SWRCB) for review and comment (required if the City decides to participate in the State Revolving Fund [SRF] Loan Program). City oj'Brentwood WWTP Project Chapter 2. Project Description Graft Elft June 26, 1998 2-J PROJECT OBJECTIVES The Marsh Creek project has been designed to meet needs perceived by the City and the RWQCB for increased long-term wastewater treatment and disposal capacity. The objectives of the proposed project are to: ■ provide the necessary treatment and effluent disposal capacity to meet the demands of growth that has already been evaluated and approved under the general plan, ■ provide cost-effective and reliable wastewater treatment and disposal facilities, ■ locate and operate the proposed new facilities in a manner that will minimize adverse environmental effects, and ■ maintain compliance with NPDES permit requirements of the RWQCB and protect water quality and public health. { 1 PROJECTED FLOW AND EFFLUENT QUALITY i The City's population is projected to grow to 100,000 well after 2017(Montgomery Watson 1997a). Based on this projected population growth, treatment capacity for 10 mgd of wastewater will be needed. This has been designated as the ultimate design flow for the proposed WWTP. The current NPDES permit(included in Appendix B) for the Brentwood WWTP specifies that effluent must be treated to meet a monthly average of 5 milligrams per liter(mg/1) for biological oxygen demand(BOD)and 30 mg/1 for suspended solids. The existing WWTP has consistently met current permit requirements and has routinely produced effluent with low levels of BOD and suspended solids. I Influent quality to the existing treatment plant has been fairly consistent. The composition ' is not expected to change significantly in the future because the anticipated land uses of new development are similar to existing uses. The City anticipates fixture increases in non-residential j development, including light industrial uses. On the basis of historical data gathered from January 1991 to February 1997, influent levels of 175 mg/l for BOD and 195 mg/l for suspended solids have been assumed for the design of future treatment facilities. Based on information obtained from plant staff, a peaking factor of 2 for average dry-weather flow to peak wet-weather flow has been assumed for design of the proposed facilities. Direct discharge of treated effluent to Marsh Creek, which is the disposal method proposed for this project, would require a higher level of treatment than is provided by the current facilities. Effluent would be required to be a disinfected filtered, secondary effluent(also known as disinfected tertiary effluent), with no more than 10 mg/l of BOD and suspended solids remaining, and I City of Brentwood WWTP Project Chapter 2. Project Description � Draft EIR 2-6 .hone 26, 1998 I I t disinfected to produce a total coliform count of 23 (most probable number of coliform organisms [MPN])per 100 milliliters (MPN/100 ml). Dissolved oxygen and electrical conductivity are also parameters of concern. Studies have been conducted to evaluate the potential effects of the proposed discharge on these characteristics of Marsh Creek.. The anticipated wastewater discharge requirements for the proposed project are presented in Table 2-1. Allowable dissolved oxygen concentrations are currently regulated under the NPDES permit;electrical conductivity is required by the NPDES permit to be monitored,but no limits have been set by the RWQCB. i California Toxics Rule The U.S. Environmental Protection Agency (EPA) recently proposed new ambient water quality criteria for priority pollutants in California,known as the California Toxics Rule, pursuant to Section 303(c)(2)(B) of the Clean Water Act. This rule would fill the gap in regulations created by the overturning of the 1992 Inland Surface Water flan and Enclosed Bay and Estuary Plans (IS�VP/EBEP). The SWRCB has also proposed new rules for implementing the criteria established by the California Toxics Rule in conjunction with California's complementary water quality criteria, which were established in the ISWP/EBEP(California State Water Resources Control Board 1997). These plans are scheduled for readoption in 1998 and will constitute the governing water quality criteria for priority water pollutants in California. Effluent discharged to Marsh Creek would potentially need to meet the requirements of the California Toxics Rule,if that rule is adopted by the EPA and SWRCB. Title 22 Requirements i The City is interested in producing effluent suitable for unrestricted reuse in reclamation projects. The City has already installed distribution pipelines for reclaimed effluent in city streets to accommodate future reclamation projects. This would require that the effluent meet the requirements set forth in Title 22, Division 4 of the California Code of Regulations, which are currently being revised. At this time, these standards require disinfection of effluent to a level of 2.2 MPN/100 ml for coliform bacteria for unrestricted reuse of the wastewater. To meet this requirement,the contact time in the chlorine contact basin would be increased from 30 minutes (the time required to meet the 23 MPN/1001 standard for effluent discharge to Marsh Creek) to approximately 2 hours (Skrel pers. comm.). i E i City of Brcntwood dWTP Project Chapter 2, Pro Pct Description Draft EIR June 26, 199£ Table 2-1. Anticipated Discharge Requirements for the City of Brentwood Marsh Creek WWTP Project Constituent Discharge Requirement Effluent Requirements Biological oxygen demand 10 mg/I Suspended solids 10 mg/l Settleable matter 0.1 mg/l Oil and grease 10 mg/I Total residual chlorine 0.0 mg/l Total coliform bacteria - Methylene blue active substance 1.0 mg/I Turbidity -- pH b.5-8.5 Dissolved oxygen 5.0 mg/l Ammonia Level that provides no effluent toxicity(in mg/I) Bioassays Yes Priority pollutants Yes` Receiving Water Requirements pH Shall not alter normal ambient pH of receiving water by more than 0,5 unit Turbidity No increase more than 10%above background Ievels(in NTU) Dissolved oxygen 5.0 rng/l, or no further decrease if upstream levels are less than 5.0 mg/l Note: mg/l =milligrams per liter,ml =milliliter,MPN=most probable number,NTU=nephelometric turbidity units. g Central Valley Regional Water Quality Control Board staff are currently reviewing appropriate disinfection level required for direct discharge to Marsh Creek. Effluent used for reclamation will meet the requirements set forth in Title 22, Division 4 of the California Code of Regulations. b Survival of test organisms shall be minimum one bioassay-70%;median any three or more bioassays-90%. Must also meet metal limits in the California Toxics Rule, if it is adopted. Source:Montgomery Watson 1997a. 2-8 i ( PROPOSED PROJECT FACILITIES ( The proposed new facilities would be located at the site of the existing WWTP. The site layout for the new oxidation ditch treatment facilities is shown in Figure 2-3. The proposed WWTP would be designed to produce a disinfected, filtered secondary effluent to meet the appropriate standards for discharge to Marsh Creek and potentially for reclamation. These facilities would be constructed in the same area that the existing facilities now occupy, and the existing facilities (e.g., disposal ponds, emergency holding pond, and sludge storage area)would be removed. Treatment facilities currently in use would be incorporated into the proposed facilities. The proposed project comprises three principal components. i N a four-phase expansion and upgrade of the City's existing wastewater treatment facilities and construction of new facilities to increase flow from 1.8 mgd to 10 mgd, a direct discharge of treated effluent into Marsh Creek, and 0 expansion of the biosolids handling facilities to allow disposal to land or landfill. i Expansion and Upgrade of Facilities I The proposed oxidation ditch treatment system (also called the treatment "train") would consist of influent pumps, screens, oxidation ditches, secondary clarifiers, tertiary filtration, disinfection, and sludge handling facilities. The oxidation ditch process would be an extended- aeration, activated-sludge system that would combine raw sewage with return sludge and oxygen in an oxidation ditch. From the oxidation ditch, wastewater would flow to final secondary clarifiers. The clarifiers would separate the clear liquid and heavier solids of the activated sludge mixture, returning the sludge to the oxidation ditch and discharging the clear liquid (e.g., effluent)to tertiary filters and disinfection facilities and reaeration.facilities. The effluent must be disinfected before being discharged. The disinfection process, using { wither liquid sodium hypochlorite/sodium bisulfite or ultraviolet light, will kill most of the bacteria and pathogens (disease-causing microorganisms) that remain after the tertiary treatment process. Sodium hypochlorite is liquid chlorine, given adequate contact time, it destroys the cell walls of bacteria and viruses and has also been shown effective in pathogen destruction. Ultraviolet light disinfects by penetrating the cell structure of bacteria and other organisms, interfering with the DNA replication process and thereby preventing the reproduction of those organisms. City of Brentwood#3'WTP Project Chapter 1. Project Description Draft EIR June 26, 1998 ... ................... -. ..._..-.... ._..., ------_-----_I __._._ Ate+......_„_..._._..._..._..._....._..�. - 'i 3s r ' ..•-' ------�•----"..._„_,„.. ..__........ -----. _GEEK__._._,.--- / ,r ... is K '; CHLORINE PpVO "�. CONTACT BASINS { I 'j�?•i �u �(� i i EXISTING D!SPCSK POND i6 t is 015RDSK EX POND r7 ........�.__�__ ': EXISTING DISPOSALSLJDGE PCMDS — EIEDS \. NOAKS .... ., ` t _ �..,, SPUTTIER EXISTING DISPOSAL POND rB TEpitARY "✓ i oasm i AER681C I'll i=OXIDAP.ON: it DIGEStSIRS i t: D17CN i i ._•---�._•. STTF�AW i ................r. X I I c DARY CuW.F.ERS •'�: \Pf.ANT S:"JT'i`p STpUC1VR£-� �SECiON TIONS ,9JIlD1,i CNA:NiINKfENCE •, Y. .. ••EXLS.ING - '. .- SYS,i •�\ EKSY'NG Df5PO5AL PCNC rs F / •.._.._. CUp1PERs UFT STATION J'if 1` NEADWORKs /' �: $'. g3�a r- #\ '•� INFLUENT / PUMP STATION /, �'C? A.', �` 'Kq y£ '.: f• / / ' `• ' OXIDATION DITCHES D ADMINISITTATNDN SOLOING BUILDRiG / SLUDGE \\ OUSTING MAINTENANCE i OXIDATKW 6UfID1NG f WCH 12 ;r � E&STIYG.EM£A ENCYH!?LDINGr'1:N4..._.... ..._............ ........................ .... ............................. ._............,.........._...... Legend .}A F Phase t (see note t) Phase 2 Phase 3 c 7s 150 Phase 4 Fee: j I Note: Phase', includes operating existing NMrTP at 0.8 to 1.8 MGD with effluent disposal to existing percolation ponds. Jones&Stokes Associates, Inc. Figure 2-3 Proposed Treatment Facilities 2-10 Discharge of Effluent to Marsh Creek I Effluent would be discharged to Marsh Creek in the vicinity of the current E-2 discharge. A pipeline from the disinfection facilities to a concrete outfall structure would be constructed on the banks of Marsh Creek. Appropriate velocity dissipation and bank stabilization measures would be j built into and around the structure. i Expansion of Sludge Handling Facilities i I Sludge handling would consist of mechanical dewatering and post-sludge drying beds. Sludge disposal would involve either land application or deposition in a landfill and would meet applicable EPA regulations(e.g.,40 CFR Part 503). Flexibility would be provided to allow the City to use the existing aerobic digester and one or both of the existing oxidation ditches for digestion of the sludge at the new facilities before dewatering. PROJECT PHASING AND IMPLEMENTATION J Construction of the proposed facilities would occur in four phases, each of which would increase the capacity of the WWTP by 2.5 mgd(Figure 2-3). Upon completion of Phase 1 facilities, the City would have treatment capacity of 3.3-4.3 mgd. In addition to the first of four new 2.5-mgd treatment trains being constructed, the existing facilities would be operated to treat up to 1.8 mgd for continued disposal to percolation ponds b, 7, 8, and 13 (Figure 2-3 and 3A-2). Upon completion of Phase 4 facilities, the City would have a new WVdTP with a capacity of 10 mgd and several of the existing facilities would be abandoned, leaving only those facilities that would be converted for use as aerobic digesters. Over the course of construction, the sludge-drying beds and secondary clarifiers would be abandoned, and these facilities could be removed during or after construction. The existing groundwater extraction system would be left in place and could be used during continued operation of disposal ponds. The proposed schedule for project implementation indicates that the environmental documentation would be completed by fall 1998. The predesign, design, and bidding processes would be completed by summer 1999. Construction for each 2.5-mgd phase is anticipated to require 1.5-2 years and will begin in 1999. Construction of the final phases of the proposed project would be dependent on acti.iai rate of growth, and scheduling would be determined accordingly. City of Brentwood TVWTP Project Chapter 2. Project Description Draft EIR June 26, 1998 2-11 ALTERNATIVES TO THE PROPOSED PROJECT The wastewater facilities plan(Montgomery Watson 1997a) identified seven alternatives to address Brentwood's long-term wastewater treatment and disposal needs: ■ Alternative I--Surface Discharge into Marsh Creek, ■ Alternative 2---Surface Discharge into Indian Slough via East Contra Costa Irrigation District Main Canal, j • Alternative 3—Land Disposal (Onsite and Offsite), ■ Alternative 4--Urban Reclamation, ■ Alternative 5---Agricultural Reclamation, J • Alternative 6—Conveyance of Raw Sewage to Ironhouse Sanitary District, and ■ Alternative 7—Conveyance of Secondary Effluent to Ironhouse Sanitary District. The evaluation conducted in the facilities plan rated Alternative I---Surface Discharge into Marsh Creek and Alternative 6--Conveyance of Raw Sewage to Ironhouse Sanitary District as essentially equal alternatives with regard to cost and noneconomic considerations. The ISD facilities are located in Oakley, north of Brentwood. In October 1994, ISD completed the final EIR for the Ironhouse Sanitary District Wastewater Facilities Plan & Delta Environment Science Center (Ironhouse Sanitary District 1994). That EIR described expansion of current ISD wastewater facilities from 2.3 mgd to 8.0 mgd. Based on the evaluation in the Facilities Plan, the City has elected to carry forward for environmental review the proposed project addressed in this draft EIR (Alternative 1) while j simultaneously conducting further evaluation of and environmental documentation for a project to convey raw sewage to ISD (Alternative 6). The alternatives evaluated in this EIR are presented and analyzed in Chapter 5. j To evaluate the alternative of sending raw sewage to ISD, an initial study/mitigated negative declaration has been prepared and is being circulated for public comment(Jones&Stokes Associates 1998b). Once the environmental documentation for the ISD project is completed, the City will evaluate the public and agency comments and reevaluate the status of that project while continuing to monitor the environmental review process for the Marsh Creek project (beginning with this document). Based on the severity of environmental issues that are identified, the necessary mitigation requirements, the estimated cost, and other technical factors, the City will make a final decision on which project to implement to provide its long-term wastewater capacity. Chy of Brentwood WWTP Project Chapter 2. Project Description Draft EIR 2-12 .lune 25, 1998 i I 1 I 1 I 1 APPROVALS AND SPECIAL REQUIREMENTS I The proposed project will be reviewed by various federal, state, and local agencies that will use this draft EIR. to evaluate the compliance of the project with regulatory requirements. The following agencies and actions are expected to be involved in project approval and implementation: j a The RWt}CB will decide whether to issue a new NPDES permit because the proposed project would discharge treated effluent directly to Marsh Creek. ■ The SWRCB will consider granting an NPDES permit for construction-related pollutant discharges in stormwater because the project would result in disturbance of more than S acres of land. 1 The Bay Area Air Quality Management District(BAAQMD)will review the project for conformance with its regulations and revise the existing air quality permit accordingly because modifications to the existing WWTP are proposed. ■ The California Department of Fish and Game(DFG)will review the project to determine whether it could adversely affect fish or wildlife habitat. In addition, a streambed alteration agreement under Section 1601 of the California Fish and Gane Code may be required because construction of the discharge structure would involve work in the streambank of Marsh Creek and activities that alter flow, bed, channel, or banks of streams are regulated by DFG. ■ The U.S. Array Corps of Engineers(Corps)will review the project to determine whether it would adversely affect waters of the United States (e.g., Marsh Creek); activities subject to Corps jurisdiction may be addressed under the nationwide permitting program (Nationwide Permit 7) because of the construction of the discharge structure to Marsh Creek. ■ The SWRCB will review the project because the City anticipates obtaining funds to build the project through the SRF Loan Program. This would involve compliance with requirements of the federal Endangered Species Act, conformance with BAAQMD air quality requirements, and Section 106 of the National Historic Preservation Act, However, analyses in this EIR have determined that the proposed project is consistent with these requirements for the following reasons: - no federally listed species would be affected by the proposed project, - the project's air quality emissions would be less than the BAAQMD de minimis thresholds, and City of Brentwood W KTP Project Chapter Z. Project Description Daft EIR June 26, 1998 2-13 no significant cultural resources would be affected by the proposed project. Information supporting these conclusions is presented in Chapters 3C, 3E, and 314, respectively. City of Brentwood W97P Project Chapter 2. Project Description Draft EIR 2-14 June 26, 1998 .............................................. ................................. i f 1 Chapter 3. Environmental Setting, Impacts, and i - Mitigation Measures i 1 I i i i I 1 I i City of Brentwood WVTP Project Chapter 3. Environmental.Setting,impacts, Draft EIR and Mitigation Measures 3-1 June 26, 1998 City of Brentwood WTP Project Chapter 3. Environmental Setting,Impacts, Draft EIR and Mitigation Measures June 26, 1998 3-2 .................................... ................................. i I Chapter 3.A,. Hydrology and Water Quality I This chapter describes the hydrologic and water quality characteristics associated with the City of Brentwood WWTP and Marsh Creek. Major factors that affect the hydrology and water quality in Marsh Creek are offsite agricultural drainage, urban stormwater runoff and drainage, permitted commercial and industrial discharges, and permitted discharges from.the City's existing i WWTP. This chapter also addresses impacts of the proposed project on hydrology and water quality and proposes measures to reduce any significant impacts to a less-than-significant level. More detailed information on the analyses presented in this chapter is provided in Appendix C. SETTING Surface Water Hydrology I Brentwood is located on a generally level alluvial plain that extends northeast from the Diablo Range and makes up a portion of the Central Valley and western extent of the Sacramento- San Joaquin River Delta(Delta). The area lies within the Mediterranean subtropical climate zone and is typical of central California with cool, wet winters and hot, dry summers. Rainfall averages 12 inches per year, primarily during November through April. The predominant surface water feature in the Brentwood area is Marsh Creek, a small stream that flows from Marsh Creek Reservoir in the Diablo Range eastward through the city. Sand Creek is tributary to Marsh Creek with its confluence located approximately 1.5 Hailes upstream of the existing WWTP. The Marsh Creek channel then heads north past the facility to the Delta at Big Break, approximately 3.6 miles north(Figure 3A-1). The channel is approximately 10-20 feet wide near the WWTP. Major surface water features in the Delta near Brentwood are Dutch Slough and Rock Slough. The Contra Costa Water District(CCWD) canal conveys water from bock Slough and crosses under Marsh Creek through a siphon approximately 3 miles north of the WWTP. The drainage area of the Marsh Creek watershed is approximately 81 square miles upstream of the treatment plant site. No routinely collected flow measurements are available from which to estimate the normal dry-period flow (Carlson pers. comm.); although streamflow in the creek is generally low during most of the summer, the stream is rarely dry during that period(Gaston pers. comm.). Sources of flow in summer are upstream reservoir releases, agricultural return flow, and urban drainage from the Brentwood area. City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft F#R June 26, 1498 3A-1 hI V Jersey Island £ „ L^y. aF f y tr{7 r�i Iouse �y Sanitary District Contra r- - ------„. Costa I CD Oakley 4 ' Cypress I Road V � i Brentwoo(� WWTP I N i { 0 2,000 4,0001 sunset i Scale in Feet F— i� To Brentwood ff Ir Figure 3AY1 Jones&Stokes Associates, Inc. C ELQMProject Site and Location of Major Surface Water Resources 3A-2 1 J The city has undergone several damaging floods associated with high flows in Marsh Creek (The Planning Center 1.993). The Contra Costa County Flood Control and Water Conservation District(FCWCD) is responsible for constructing and maintaining flood control facilities on Marsh Creek. The Marsh Creek channel is formed by a series of berms and levees constructed adjacent to the main creek channel near the WWTP and extending downstream. Within the project area, the 104-year floodplain as designated by Federal Emergency Management Agency(FEMA)is contained within the banks of the constructed channel. However, extensive tracts of low-lying land surrounding the project area are identified as being within the FEMA-designated 100-year floodplain,particularly north of the WWTP near Big Break. The 100-year floodflow in Marsh Creek 1 is estimated to be approximately 2,322 cubic feet per second (cfs) (Boucher pers. comm.). Marsh Creek is a free-flowing waterway near the existing WWTP. The terminal 0.5-0.75 mile of the stream channel(where it connects with Big Break) is approximately 50-70 feet wide, and the depth of the water is influenced by daily tidal action. Tides have a strong influence on the movement of water through the Delta,with an average daily tidal range of approximately 3 feet near Big Break. Under the normal range of flows in Marsh Creek, daily changes in tidal elevation probably cause the direction of flow in lower Marsh Creek to change. I Groundwater Hydrology i The project area overlies silty and clayey sediments formed from alluvial deposits that originated through the erosion of sedimentary rocks in the Diablo Range and fluvial deposits laid down in the Delta. Large amounts of sand were deposited in the area of Sand Hill in the northwest region of Brentwood. Groundwater in the project region is typically shallow, with depths of approximately 10-30 feet below ground surface(The Planning Center 1993). The principal source of domestic drinking water for Brentwood is from groundwater, although the City has recently implemented an interim surface water supply pipeline connection using water leased from the Contra Costa Water District. The City is also pursuing long-term options for surface water supply. Agricultural water is provided by East Contra Costa Irrigation District (ECOID) through an extensive channel system. The source of irrigation water is Indian Slough. Local use of groundwater for domestic drinking water is extensive; therefore, maintaining i and protecting groundwater quality is an important consideration for City planning and alternatives a analysis. Surface Water Quality The quality of surface water in Marsh Creek is primarily influenced by physical and chemical characteristics of the watershed, hydrologic and climatic factors, and urban and agricultural discharges. During summer flow conditions in a small stream such as Marsh Creek, the water Ci Brentwood WWTP Project City o 1 J " Chapter 3A. Hydrology and Water Quality ©raft EIR June 1b, 1998 3A-3 quality characteristics of most importance to aquatic life are temperature, dissolved oxygen, turbidity, pathogenic bacteria, un-ionized ammonia, biostimulatory nutrients (e.g., nitrogen and phosphorus), and nuisance algae growth. During winter, streamflow is much higher and is influenced more by stormwater runoff and associated pollutants,such as eroded soil,oils and grease from automobiles and paved areas, nutrients from agricultural fields and livestock boarding areas, and organic litter(e.g., leaves and grass clippings). Water quality in Marsh Creek is monitored monthly by the WWTP staff at the sampling sites shown in Figure 3A-2, as required by the existing NPDES permit(Appendix B). This monitoring is the principal source of data for characterizing water quality conditions in Marsh Creek. Table 3A-I shows annual minimum, average (or mean), and maximum concentrations of water quality constituents that were routinely measured in Marsh Creek at site R-1 upstream of the WWTP from March 1991 to December 1997. The data indicate that water in Marsh Creek is generally suitable for the designated beneficial uses identified in the Water Quality Control Plan (Basin Plan) (California Regional Water Quality Control Board, Central Valley Region 1995). The water generally has neutral pH values (annual means of 6.7 and 7.2 for the two years of available data) and moderate electrical conductivity (EC) levels (annual means of 530-1,120 microsiemens per centimeter [p.S/cm]); EC is representative of the total content of dissolved ions. One measurement for mineral hardness was taken in May 1997, with a reading of 470 mg/l as calcium carbonate(CaCO3)that indicates moderately hard water. High levels of turbidity (annual means of 37.6 and 119 nephelometric turbidity units [NTU])have been measured during winter, indicating that substantial quantities of sediment are entering the waterway upstream during the wet season. Dissolved oxygen (DO) is an important water quality parameter for maintaining habitat conditions suitable for aquatic organisms. DO levels are typically reduced as the temperature increases,and biological processes (e.g., respiration by aquatic plants, oxidation of organic matter by microorganisms) also can reduce DO levels. Based on a historic average measurement of 7.7 i mg/l, DO levels in Marsh Creek are generally adequate to support aquatic organisms. Occasionally, however, DO levels have dropped below 5.0 mg/l (the lower limit allowed by RWQCB regulations to prevent stress to aquatic organisms) upstream of the WWTP discharge. Water temperature-is not measured by the WWTP staff;however,the relatively small amount of shade in the constructed flood control channel near the WWTP implies that temperatures probably rise during summer, making it difficult at times to maintain high DO levels and provide high-quality fish habitat. High levels of total coliform bacteria(e.g.,more than 1,600 MPN/100 ml)also indicate that some fecal waste is being contributed upstream of the WWTP discharge from sources such as urban runoff, onsite residential septic systems, or runoff from areas containing livestock. i i I City of Brentwood W117P Project Chapter 3A. Hydrology and Water Quality Draft EIR June 26, 1998 3A-4 1 R-4 R-2 (before {since March 1996} March 1896) -----_---_ R-3 -- E-2 Discharge (since March 1986) to Marsh Greek Creek 1 Groundwater E i 0 , Extraction 11 System 1 t t i t E #6 it 1 1 Emergency 1 Disposal j #3 \ Existing Disposal #7 Pond 1 #2 Ponds t 00,10 I t #8 s 80 #12 Emergency t Disposal j 1 #9 fond S 12"Culvert 1 0 Existing 1 Sludge # Existing WWTP (�`� Holding 1 1' f=acilities 1�....,J Pend #10 s E _ Disposal 1 H-2 Pond E (since Emergency March Holding # !886} Pond # w E-1 Discharge t to Marsh Cree ------------------ -------------- R-1 _____ ______i -____-__-. _ ,.._______ Property Line N #18 Solid Disposal j Pond Waste Facility r 0 175 350 Scale in Feet Legend Berm 0 Monitoring Well F Sunset Park i Jones& Stokes Associates,Inc. Figure 3A-2 Existing Wastewater Treatment Facilities and Water (;duality Sampling Sites 3A-5 i ! I 4g ' n Ic, � 1 63 � r C C v z � 4 W ! ' CT � � y M _ C A i v a 6 � � v ; r' 1 m to O w•� O '� -- � b CE iwZF o a V o'i u 3A-6 i Effluent Quality at the Existing Wastewater'Treatment Plant Effluent from the existing WWTP is discharged to percolation ponds. A perimeter groundwater extraction system was installed in 1988; this consists of monitoring wells and a discharge pipeline that collects a portion of the infiltrated secondary effluent from the percolation ponds and groundwater and discharges the water into Marsh Creek at two locations (E-1 and E-2 in Figure 3A-2). Most of the discharge is currently routed to location E-2 on Marsh Creek. Several agricultural or storm drains also discharge to the creek between E-I and E-2. The average discharge rate from the groundwater extraction system to Marsh Creek varies throughout the year depending on the amount of rainfall, ranging from a low of 0.25 mgd to approximately 0.6 mgd(equivalent to I 0.39-0.93 efs) (California Regional Water Quality Control Board, Central Valley Region 1996). Conventional Pollutants Discharges from the groundwater extraction system are monitored daily for flow volume; weekly for DO- and monthly for BOH suspended solids, EC, pH, and total coliform bacteria. In response to requests made by the RWQCB in 1996, the effects of WWTP discharges from the groundwater extraction system on DO levels and EC in Marsh Creek were evaluated(Montgomery Watson 1997c). Since March 1996, samples have been collected at two new monitoring stations (R-3 and R-4 in Figure 3A-2) to reduce the influence of other drainage discharges to Marsh Creek that are located between previously established sampling locations R-I and R-2. Discharge from the groundwater extraction system has consistently maintained a good compliance record with current NPDES permit limits (California Regional Water Quality Control Board, Central Valley Region 1996). Dissolved Oxygen. The current NPDES permit for dissolved oxygen contains the following requirements: ■ The discharge shall not contain less than 5.0 mg/l of DO. The discharge shall not cause the DO concentration to fall below 5.0 mg/l in the receiving water. The current NPDES permit identified three samples that were below the 5.0-mg/l effluent limit from the period December 1993 to September I995, but these low levels did not cause a water quality violation in the receiving water. Since September 1995, the City has consistently met the NPDES requirement of not less than 5.0 mg/1 in the effluent discharge. The average effluent DO for the period March 1996 to December 1997 was 5.3 mg/l. Although the City's discharge is a combination of infiltrated effluent and groundwater, which has a typical DO of 0-2 mg/l, the discharge flows through a series of manholes before its disposal in Marsh Creek. The configuration of these manholes provides re-aeration of the water in the extraction pipe system. City of Brentwood WWTP Project Chapter 3A. Hydrology and mater Quality Draft EIR June.26, 1998 3A-7 The current NPDES permit indicates that before March 1996, DO concentrations in Marsh Creek decreased between upstream and downstream monitoring points for receiving water. For the period March 1996 to December 1997, the DO was lower downstream than upstream 45% of the time. For both periods,however,the decrease did not cause a water quality objective to be exceeded. Total Coliform Bacteria,BOD,and Total Suspended Solids. The current NPDES permit j for total coliform bacteria requires that the effluent meet a monthly median and daily maximum of 23 MPN/100 ml (most probable number per 100 millimeters)and 500 MPN/1170 ml,respectively. � The current NPDES permit limits for BOD and total suspended solids are shown in Table 3A-2. Because the percolation of treated effluent into the ground effectively filters out these constituents as it passes through the soil substrate,the City has consistently met these permit limits. I Table 3A-2. NPDES Permit Limits for BOD and Total Suspended Solids for the Brentwood WWTP Monthly Weekly Daily Constituent Unit Average Average Maximum i BOD mg/l 5 10 20 lb/day 75 150 300 Total suspended solids mg/l 30 45 50 lbs/day 450 676 751 i Electrical Conductivity. The current NPDES permit does not have any numerical EC limits that must be met for the effluent or receiving water; however, the City is currently required to monitor the EC levels in the discharge and receiving water. The average effluent EC for the period March 1996 to February 1997 was a moderate 1,640 pS/cm. For the period March 1996 to December 1997,the EC was higher downstream than upstream 41% of the time. pH. The current NPDES permit for pH states that"The discharge shall not cause the normal ambient pH to fall below 6.5, nor exceed 8.5 in the receiving water." From March 1996 to December 1997,the average pH of the effluent was 6.8{near the lower permit limit of 65-8.5}. The j slightly acidic conditions of the effluent are normal for percolated water, where soil ion-exchange reactions reduce the water's acid-buffering capacity and uptake of soil carbon dioxide causes the solution to be weakly acidic. In addition, nitrification of wastewater at the WWTP reduces the alkalinity, which subsequently tends to lower pH in the effluent. i City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft EIR Jane 26, 1998 3A-8 i 1 Priority Pollutants Priority pollutants are water quality constituents or parameters of concern because of their potential toxicity to aquatic life. The P.WQC$ has required the City to monitor these pollutants. An Effluent and Receiving Water Quality Assessment (ERQWA) was prepared that evaluated effluent concentrations of several EPA-designated priority pollutants, including trace metals and two organic pesticides(Montgomery Watson 1997b). Measured values from 13 months of sampling for these priority pollutants are shown in Table 3A-3. Most trace metals were not detected or were detected relatively infrequently at low levels (e.g., arsenic, cadmium, and selenium.). The trace metals that were determined to approach or exceed a proposed regulatory criterion were lead and thallium. Copper, nickel, and zinc were detected frequently at levels below regulatory criteria. The a source of lead has not been determined; thallium is believed to enter the groundwater through pesticides that are applied to fields adjacent to the WWTP groundwater extraction. system. The organic pesticides chlorpyrifos and diazinon were not detected at their respective analytical detection limits. Effluent Toxicity Whole-effluent toxicity tests were conducted in 1996 and 1997. The results of one test for reproduction of the invertebrate Daphnia were lower than the results of the control test but were inconclusive as to their toxicity, and one test indicated reduced growth in the algae selenstrum. All tests conducted with fathead minnow passed survival criteria. Groundwater Quality ! The quality of shallow groundwater is largely dependent on the quantity and quality of surface water that percolates into the ground and the subsequent chemical interactions that take place with the soils and bedrock within the saturated aquifer layers. Factors that affect the susceptibility of shallow groundwater to contamination include the type of soil and water-bearing materials, permeability of the soil to surface water infiltration, location of pollutant sources, and depth to the aquifer. Potential sources of shallow groundwater contamination include agricultural application of fertilizers and pesticides, hazardous material spills from industrial and commercial processes, septic tank leachate, infiltration of contaminated urban stormwater runoff,and disposal of municipal wastewater. The water quality of local wells that the City uses for municipal supply is variable depending on the well used. The principal wells used have moderately elevated levels of mineral hardness (280-580 mgll as CaCO3) and associated total dissolved solids (630-1,090 g/1) (The Planning Center 1993). Nitrates are typically elevated, and some wells have been removed from service as a result of nitrate levels that would exceed regulatory drinking water standards. EC of the local groundwater averages approximately 750 pOcm(Montgomery Watson 1997c). City of Brert:vood 4'WrrP Project Chapter 3A. Hydrology and Water Quality Draft EIR June 26, 1998 3A-9 r, V) 00 00 CIA to cr+ O C5 Ci CN C, CI\ z z z z z z z z z z z z z z z C4 C� CA z z Z z z M z 6 z 13 r 21 C7, z z z z z O CL Un Z z pz zN Qz z z z a az z ZZZZZZ ZZ — zzt-. z rn ti z z z z z z 7- z z z 7- 7- z y 22 z z z z N Z z z z z z z 7 z z 0 In C; C> 0 C) C) O O C Oh lD C4 U U v 3A-10 ....................................... ............................... j The groundwater quality near the WWTP has been monitored at several wells within and outside the perimeter of the Vv WTP groundwater extraction system. Samples are analyzed monthly for EC and pH and quarterly for nitrates and total coliform bacteria.. The average EC in the wells for the period March 1996 to February 1997 ranged from 1,110 to 1,600 p6/cm (Montgomery Watson 1997c),which is slightly less than WWTP effluent values and higher than average levels in Marsh Creek. f Regulatory Framework Floodplain Management FCWCD, the local agency responsible for flood control in the project area, maintains all flood control facilities and the structural beans and levees along Marsh Creek. The proposed project would require an encroachment permit from FCWCD for the construction of the effluent outfall structure to discharge treated wastewater to Marsh Creek. The encroachment permit would include review by FCWCD of the proposed construction and operation of the outfall structure to assess the potential for the structure to impede flood conveyance or the quantity of effluent contributed to the channel. Water Quality Control Plan The Central Valley RWQCB has primary authority for implementing SWRCB policy and ensuring that water quality and designated beneficial uses of water resources are protected from potential adverse impacts of development in the project area. Narrative and numerical water quality objectives are established in the RW QCB's water quality control plan for the Sacramento and San Joaquin River Basins (or Basin Plan) to protect established beneficial uses of surface water and groundwater(California Regional Water Quality Control Board, Central Valley Region 1995). The RWQCB implements the Basin flan by imposing waste discharge requirements (WDRs) for discharges such as those of the proposed project under the NPDES permit and CEQA processes. Marsh Creek has designated beneficial uses for contact and noncontact recreation. Numerical and narrative objectives for surface water quality provided in the Basin Plan would be applicable to the proposed WWTP project and the discharge of treated wastewater to Marsh Creep. The principal water quality objective for recreation is to maintain low levels of potentially pathogenic organisms in discharges;this objective is regulated through numerical WDRs for total coliform bacteria counts. NPDES Permits for WWTP Discharges WWTPs that discharge to surface waters are regulated through the National Pollutant Discharge Elimination System(NPDES)permitting process that is mandated under the federal Clean City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft E1R June i 6, 1998 3A-11 i Water Act (40 CFR). The NPDES permit process for treatment plants typically involves establishing, for the effluent and the receiving water body, concentration criteria for various chemical, physical, and biological parameters such as flow, temperature, pH, BOD, DO, total coliform bacteria, total suspended solids, total settleable matter, turbidity, residual chlorine, ammonia, and other compounds of specific concern. The permit can also specify limits on the total quantity or mass of a pollutant allowable in the discharge over a defined period. For compliance } purposes, the NPDES permit requires the discharger to perform water quality monitoring for compounds with established permit limits and submit monitoring reports. Table 3A-4 shows the NPDES discharge limits that are anticipated to be imposed on the proposed project. Ambient Water Quality Criteria for Priority Pollutants The RWQCB will eventually be required to incorporate additional limits for priority pollutants into WDRs and NPDES permits for discharges of WWTP effluent to surface waters. These limits will most likely be based on EPA's recently proposed California Toxics Rule. The rule was developed in accordance with Section 303(c)(2)(B) of the federal Clean Water Act (Federal Register Volume 62,No. 150; August 5, 1997)to fill the gap in regulation created by the overturning of the 1992 California ISWP/EBEP. The SWRCB subsequently issued a Draft Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California and accompanying Functional Equivalent Document(California State Water Resources Control Board 1997) that identifies the proposed rules for integrating the California Toxics Rule criteria into the ISWP/EBEP. The water quality criteria in the ISWP/EBEP will govern regulation of priority toxic pollutants in California. Following adoption of the California Toxics Rule, the ISWP/EBEP, or both, wastewater discharges and NPDES-permitted facilities will be required to comply with the new standards for priority pollutants. Given the designated recreational beneficial uses for Marsh Creek, the NPDES limits for priority pollutants would most likely be based on ambient water quality criteria for the protection of human health and aquatic life as proposed in the California Toxics Rule. Table 3A-5 shows numerical objectives for trace metals and organic pesticides currently proposed under the California Toxics Rule. Numerical criteria are established for water quality constituents to protect aquatic organisms and humans from acute and chronic toxicity caused by ingestion of water or organisms in contact with the water. By definition, the criteria represent "the highest concentration of a j substance in water which does not present a significant risk to the aquatic organisms in the water and their uses". i National Pretreatment Program i EPA created the National Pretreatment Program and first issued pretreatment regulations in November 1973. Following amendment of the Clean Water Act, the regulations were revised in June 1978 and again in January 1981. The purpose of the program is to regulate the discharge of toxic pollutants or unusually large amounts of conventional pollutants (e.g., BOD and suspended f City of Brentwood W6i'TP Project Chapter 3A. Hydrology and Water Quality Draft EIR June 26, 1998 3A-12 f i Table 3A-4. Anticipated NPLES Permit Limits for the Proposed Brentwood WWTP Effluent Discharge Limitations Effluent Marsh Creek Constituents Units Limits Limits BOD,5-day mg/L 10 - Total suspended solids mg/L 10 - Settleable matter ml/L. 0.1 -v Oil and grease mg/L 10 -- Total coliform bacteria MPN/100 ml 23 23 Methylene blue active mg/L 1.0 -- substances Turbidity NTU -- < 10%increase over background i PH Standard 6.5 to 8.5 <0.5 change from background Dissolved oxygen mg/L 5.0 5.0 or no further decrease below background Ammonia(N) mg/L No effluent toxicity -- i Chlorine(residual) mg/L 0.0 Temperature °C -- <5 °C change from background Chronic toxicity bioassay -- To be determined to be determined i i 3A-13 Table 3A-5.Proposed California Toxics Rule Water Quality Limits(}ig/1)from the City of Brentwood Human Health for Consumption of Freshwater Aquatic Life Protection 1-Hour Average 4-Day Average Constituents Water and organisms Organisms Only (CMC)- (CCC). Inorganic Compounds- Antimony 14 4,300 Arsenic -- -- 340 150 Berylium Cadimium --b 4.3 2.2 Chromium -.b _b 550 180 Chromium VI 16 11 Copper 1,300 __ 13 9 Lead 65 2.5 Mercury {3.05 0.051 1.4 0.77 Nickel 610 4,600 470 52 Selenium --b --b 5 -' t Silver -- __ 3,4 -- Thallium 1,7 6.3 Zinc -- -- 120 120 Organic Compounds i Chlorpyrfos Diazinon i Notes: Ail concentrations stated in units of micrograms per liter(Yg/1). --=not applicable. CMC=criteria maximum concentration;CCC=criteria continuous concentration. b EPA does not promulgate human health criteria; however,permit authorities would include these objectives in NPDES permits using the state's existing narrative criteria for toxics. New rule for selenium based on relative fraction of total selenium present as selenate and selenite. Source: Proposed California Toxics Rule(federal Register,Vol.62 No. 150,August 5, 1997). i 3A-14 i solids)to municipal sanitary sewers and the associated WWTPs. Any treatment plant with a design flow of 5 mgd or more must implement a pretreatment program. Pretreatment programs are known as source control programs by many sanitation agencies because of their essential intent to reduce and control sources of toxic pollutants. Toxic pollutants can include a wide variety of compounds, but the terra generally refers to heavy metals, volatile organic compounds, pesticides, and other chlorinated organic compounds. The goal of the source control program is to protect receiving water quality and the environment from the effects of these discharges because of their potential to pass through the treatment process while receiving only minimal treatment, if any, at the treatment facility. The following objectives form the basis of a typical pretreatment program.: i 9 identify pollutants that could upset or bypass the treatment process, a develop discharge limitations for nondomestic discharges(local limits), K identify nondomestic discharge sources, and U develop a nondomestic monitoring program to enforce local limits. Development of a source control program includes the development of narrative and. numerical local discharge limits applicable to industries and other businesses discharging to the sewer system. Narrative limits are general statements prohibiting or restricting a particular discharge, whereas numeric limits are values that a facility discharge to the sewer cannot exceed. Numeric lirnits are maximum allowable concentrations from any discharge source that are calculated for each pollutant of concern to prevent exceedances of applicable ambient water quality criteria mandated by EPA or the RWQCB Water Quality Control flan for priority pollutants,and to prevent violations of federal and state sludge disposal regulations. These local limits specify the allowable flow and concentration for each pollutant of concern that can be discharged to the WWTP. NPDES Stormwater Discharge Permits The RWQCB also grants and implements NPDES permits for stormwater discharges that are associated with specific construction and industrial activities. An NPDES general construction activity permit is required for projects that disturb more than 5 acres of land. The permit requires the development of an approved erosion control plan, a storrnwater pollution prevention plan (SWPPP)that describes temporary and permanent best management practices that must be employed to control and minimize runoff of pollutants, and self-monitoring and reporting of water quality during the construction.period. This permit would be required for the proposed WWTP. Title 22 Water Reclamation Criteria The California Department of Health Services (DHS) has primary responsibility for protecting public health and implementing provisions of Title 22, Division 4, Chapter 3 of the City of Brentwood WW7`P Project Chapter.3A. Hydrology and Water Quality Draft EIR June 26, 1998 3A-15 California Code of Regulations. Title 22 provisions exist to protect human health from potential exposure to pathogens from projects involving water reclamation and reuse of waters. The DHS criteria include numerical limitations and requirements affecting the water application (e.g., irrigation, landscaping,recreational impoundments); treatment methods; monitoring and analysis; and engineering design,operation, maintenance, and reliability of facilities. Requirements imposed under Title 22 are incorporated into waste discharge permits administered by the RWQCB. For discharges to surface waters that may involve body-contact recreation, Title 22 provisions will eventually require that levels of total coliform bacteria in WWTP effluent not exceed a 7-day median value of 2.21b1PN/100 ml or a 30-day median value of 23 MPN/100 ml. The 7-day median value is 23 MPN/100 ml if the effluent is restricted to uses such as irrigation of pasture for milking animals, landscape irrigation (e.g., for golf courses, cemeteries, and freeways), and landscape impoundments. s i Biosolids Disposal The disposal of biosolids is regulated by various federal, state, and local agencies. Federal regulations for wastewater sludge disposal under 40 CPR Part 503 are implemented by the RWQCB through limits in the waste discharge requirements for the NPDES pen-nit. The State of California also bases disposal limits on guidelines for land application of biosolids (California Department of Health Services 1983). The federal regulations are intended to promote beneficial use of biosolids while protecting public health and the environment;these regulations apply to biosolids that will be used for land application or surface disposal or incinerated. Disposal of biosolids in landfills is still regulated by 40 CFR Part 258 and requires chemical tests to determine the suitability of the material for disposal at a given landfill. I The federal regulations are self-implementing in that they define quality standards, monitoring and reporting procedures, and other operational and maintenance requirements that are enforceable without permits. The regulations provide guidelines for land application, disposal and j storage, and incineration of biosolids. The reduction level of pathogens and vector attraction and concentrations of trace metals determine the type of biosolids produced(designated as Class A or B) and the associated allowable uses of those biosolids for land application. Biosolids are further characterized by the concentration of metals in the final treated product. i Only Class A biosolids are acceptable for land application uses that may involve immediate human exposure to the product. Class A biosolids can be distributed for uses such as soil and garden amendments for nurseries, playing fields, golf courses, and residential gardens. Class B biosolids are restricted to certain land application methods that limit access and human exposure to the site. i City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft EIR June 26, 1998 3A-16 i 1 IMPACTS OF THE PROPOSED PROJECT l Significance Criteria The criteria used to evaluate the impacts of the proposed project are based on information provided in the State CEQA Guidelines; other federal and local laws, regulations,and policies; and professional judgment. The proposed project would result in a significant impact on Hydrology and water quality if it would; a result in substantial changes in absorption rates, drainage patterns, or the rate and amount of surface runoff that cause existing drainage capacity to be exceeded; a substantially interfere with groundwater recharge; or a substantially degrade surface water or groundwater quality because of increased j sediments,erosion, and contaminants generated by construction or operation of the project. Because of the type of project, the following additional significance criteria have been identified. An impact was also considered significant if the project would result in an exceedance of: r water quality objectives contained in the RW QCB s Basin Plan for surface waters and groundwater or ■ anticipated ambient water quality criteria for EPA priority pollutants that could be used in future WDRs of an NP SES permit. Several types of impacts evaluated.for the proposed project could be considered beneficial under appropriate circumstances. Alterations to the hydraulic characteristics of the watercourses were considered beneficial if the alterations would reduce the extent or severity of flooding from existing or projected future conditions. Improvement(or prevention of degradation)of water quality was also considered a beneficial impact. Hydrologic Impacts and .Mitigation Measures Impact. Construction and operation of the proposed WWTP could slightly reduce viable floodplain storage or floodflow conveyance capacity. This impact is considered less than significant. City of Brentwood PY4 7'P Project Chapter 3A. Hydrology and Water Quahry Draft EIR June 26, 1998 3A-17 A review of FEMA-provided floodplain information indicates that the existing WWTP is not located within the 100-year floodplain of Marsh Creek. The treatment facilities for the proposed WWTP would be constructed in the same area and therefore would not be within the 104-year floodplain; the project would result in no loss of viable floodplain storage capacity or adverse effects on downstream landowners. Installation of a new outfall structure for discharge of the WWTP effluent would be constructed in the Marsh Creek channel and 100-year floodplain,however. The outfall structure would consist of a culvert and concrete outfall installed along one side of the stream bank. Because the structure would not protrude into the stream channel, conveyance of floodflows in the channel would not be reduced. Construction within the channel would require an encroachment permit from FCWCD to ensure that proposed facilities do not interfere with floodflow capacities of the channel. Additionally,the City would be required to obtain a nationwide permit for outfall facilities from the Corps and a streambed alteration agreement from DFG. These permits contain conditions that would ensure that potential flooding and hydrologic effects are minimized or eliminated. These permits are discussed in greater detail under the discussion of water quality impacts below. At full buildout and full operational capacity of the WWTP facilities, the maximum average dry-weather discharge of treated effluent to Marsh Creek would be 10 mgd(15.5 cfs)and peak wet- weather flow would be 20 mgd (31 cfs). The treatment plant would be designed to allow gravity flow of the peak effluent discharge during floodflows in Marsh Creek. The peak rate of effluent discharge would be approximately 1.4%of the 100-year floodflow of 2,3.22 cfs. The effect of the � peak discharge on the elevation of floodflows in Marsh Creek was evaluated with modeling results prepared by the FCWCD(Boucher pers. comm.). The methods used and results of the analysis are presented in Appendix C. The results indicate that the peak effluent discharge would increase the depth of the 100-year floodflow by less than 0.1 foot. Because the discharge would not contribute measurably to normal floodflows,the effect on the severity or extent of downstream flooding would be minimal. During periods (estimated as lasting approximately 6-12 hours) when peak floodflows are occurring in Marsh Creek,the discharge of effluent to the stream may need to be curtailed(Williams pers. comm.). The City and FCWCD would develop the specific operational criteria for detaining i effluent discharges during peak floodflows. If required,the City would monitor stage(water level) in Marsh Creek, cease discharge of effluent to the stream, and provide sufficient reserve storage capacity onsite for effluent until the peak flow in the stream has passed. The FCWCD has recently completed plans to eliminate flooding of Marsh Creek upstream of the Highway 4 crossing. The FCWCD now plans to review channel conditions downstream of the Highway 4 crossing. If this review reveals no flooding potential or the FCWCD implements channel improvements to eliminate flooding, storage of effluent may not be required. This impact is considered less than significant. ' I Mitigation Measure No mitigation is required. City of Brentwood WWTP Project Chapter 3R. Hydrology and Water Quality Draft EIR June 25, 1998 3A-18 J 1 � I ! Impact: Discharge of treated effluent could result in minor changes to the hydrologic characteristics and aquatic habitat of Marsh Creek. This impact is considered less than significant. The average dry-weather discharge of 10 mgd (15.5 efs) of treated effluent would change the existing hydrologic characteristics of Marsh Creek and could affect aquatic flora and faunal habitat within the stream.channel. Potential changes were evaluated with the standard equation for normal flow in a trapezoidal channel using measurements and channel characteristics provided by FCWCD (Boucher Pers. comm.) (Appendix C). Assuming worst-case conditions (no flow in the channel), the discharge of 15.5 efs would result in a flow that is approximately 0.9 foot deep with a velocity of 1.56 feetper second in the channel, which is 10 feet wide. These calculations are considered conservative because the stream normally contains some flow and the channel is generally wider than 10 feet. Increases in water depth would be smaller when flow is present(e.g.,0.6-0.7 foot),and smaller yet in areas downstream where,the channel is wider than 10 feet. This small increase in water depth and velocity would not cause adverse hydrologic effects because flow in the channel varies routinely as a result of variations in base streamflow, irrigation return flows, urban runoff, and existing WWTP effluent discharges. The effects of these variations would be negligible in the tidally affected lower reaches of Marsh r Creek near Big Break, where daily tidal action already causes water levels in the channel to vary. This impact is considered less than significant. Mitigation Measure No mitigation is required. Nater Quality Impacts and Mitigation .Measures Impact. Construction of WWTP facilities and effluent outfall structures could result in Marsh Creek water quality effects. This impact is considered less than significant. Construction activities required to expand the WWTP facilities would disturb soil, expose areas to erosion, and require the use of equipment and materials that could release harmful substances such as petroleum products and concrete into the aquatic environment. Potential impacts could result from soil erosion, sedimentation in Marsh Creek, and hazardous material spills during construction. The proposed project could cause temporary discharges of soil and sediment directly into the creek or into stormwater runoff that then enters the creep. Soil and associated contaminants that enter stream channels can increase turbidity, stimulate the growth of arae, impair aquatic habitat because of sedimentation, and introduce compounds that are toxic to aquatic organisms. City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft EIR June Z6, 1998 3A-19 'E An NPDES stormwater discharge permit for general construction activity from the RWQCB would be required for the project because an area of more than 5 acres would be disturbed. The NPDES permit requires development of an SWPPP that identifies best management practices to control erosion and runoff of contaminated stormwater from the construction site. In addition,the City would include provisions in construction contracts requiring the general contractor to obtain and implement provisions of several permitting processes that are designed to control construction-related pollution and impairment of aquatic habitat. The selected contractor would obtain and implement provisions of Section 404 Nationwide Permit 7 from the Corps for construction of the outfall structure within Marsh Creek and the associated Section 401 water quality certification or waiver from the RWQCB. For all construction within Marsh Creek, the contractor would also obtain and implement provisions of a DFG streabed alteration agreement to prevent adverse effects on aquatic habitat and resident species. The City would periodically monitor the site to ensure that erosion and sediment control measures are being implemented during construction. The City would also conduct a field inspection following construction and before the rainy season to ensure that vegetation has become established and other erosion control measures have been installed according to permit conditions. The City would implement all of the measures discussed above. Therefore., this impact is considered less than significant. Mitigation Measure a No mitigation is required. Impact: Discharge of conventional pollutants in treated effluent could result in degradation of water quality in Marsh Creek. This impact is considered less than significant. 4 Direct discharge of treated effluent to Marsh Creek could impair ambient surface water quality by altering various characteristics or constituents, such as temperature; pH; turbidity; and levels of residual chlorine,pathogenic organisms, nutrients that are biostimulatory to aquatic algae and submerged vegetation, and potentially toxic substances such as un-ionized ammonia. Increases or changes in the level of these constituents in the proposed WWTP discharge could degrade water quality and reduce the quality of habitat for aquatic organisms. i The treatment facilities would be designed to meet relevant restrictions for effluent and receiving water discharge imposed by the RWQCB under a new NPDES permit. The WWTP would have sufficient treatment facilities and capacity to meet the discharge limits established as a performance criterion and would be required to meet any new or revised standards that may be established in the future. The proposed WWTP would be designed to EPA Class I reliability standards, and specifically would be designed to meet the anticipated NPDES permit limits listed i Ciro of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft R!R June 26, 1998 3A-20 i i in Table 3A-4. The City would implement monitoring procedures for influent, effluent, and receiving water quality according to provisions of the NPDES permit. i Temperature. Thermal conditions in Marsh Creek may either increase or decrease downstream of the discharge compared to background levels. October and November are the most critical periods because creekflows are low and stream temperatures are lower due to the onset of fall weather. However,the effluent would generally be warmer than the stream,and the anticipated NPDES permit limit of a temperature increase of less than 5'F could be violated. Based on limited temperature data collected in the creek and for the discharge, it is anticipated the discharge will not exceed the NPDES receiving water temperature limits. In the future, if temperature becomes an issue, the effluent could be routed through emergency storage ponds or a beneficial-use wetland to decrease temperature. This potential impact is considered less than significant. i p1l.During low-flow periods in Marsh Creek,the effluent discharge could alter the normal ambient pH of the receiving water more than 0.5 units,which is the anticipated future NPDES permit limit. The City's current NPDES permit noted that recorded pH levels in the receiving water typically improved between the upstream and downstream monitoring points indicating that the discharge may enhance the quality of the receiving water with respect to pH. The effluent pH from the proposed wastewater treatment facilities is expected to remain between 6.5 and 7.1 as a result of the nitrification process. In the future, if pH alteration in the stream becomes an issue pH adjustment facilities could be added at the WWTP. Therefore, there will be no significant impact on the receiving water pH from the discharge. Turbidity,BOD,Total Suspended Solids, and Total Coliform Bacteria. The proposed WWTP design would produce an effluent with turbidity of less than 2 NTU and BOD and total suspended solids of less than 10 mg/l. The effluent would be disinfected to reduce pathogenic organisms to comply with limits set in the NPDES permit. The method of disinfection would be the use of ultraviolet light or sodium hypochlorite for chlorination followed by sodium bisulfate for dechlorination. Discharges of residual chlorine from the use of sodium hypochlorite could be toxic to aquatic organisms, and pathogenic bacteria could impair beneficial uses of the receiving water for contact-based recreation. The potential for adverse effects would be avoided because the proposed WWTP would include facilities to fully dechlorinate the effluent, so that no residual chlorine would be discharged to the creek. The disinfection facilities will be provided with continuous monitoring to ensure a zero chlorine residual. Ammonia Toxicity. Contributions to Marsh Creek of un-ionized ammonia, a highly toxic nitrogen compound, could be directly toxic to sensitive fish species. Concentrations of un-ionized ammonia in the receiving water are determined primarily on effluent ammonia levels and pH levels of the effluent and creek; the fraction of ammonia that is un-ionized increases as pH values rise. Ammonia will be maintained at low levels (e.g., 1 mg/1) in the effluent because the proposed V/1vVTP will be designed and operated to provide complete oxidation of nitrogen compounds (i.e., City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft EIR June 16, 1998 3A-21 i nitrification)to nontoxic forms such as nitrates and organic nitrogen. The operation of the WWTP and the quality of the resulting effluent would be monitored routinely to control the nitrification process and prevent increases in un-ionized ammonia. Biostimulatory Nutrients. Effluent discharges of nitrogen and phosphorus compounds may stimulate additional growth of aquatic algae and submergent vegetation in Marsh Creek. The potential for nuisance growth conditions is directly related to the residence time of the water and ability for photosynthetic organisms to absorb the nutrients and be converted to plant biomass. However,the relatively short segment of stream downstream of the WWTP (3.6 miles)would result in a short time of travel for the discharge before mixing with waters of Dutch Slough and Big Break in the Delta. Assuming a conservative condition of slow streamflow (< 0.5 foot per second), the travel time would be approximately 11 hours, and thereby have a small potential for stimulating { nuisance growth. i Biostimulatory effects in Dutch Slough and the Big Break would also be negligible because the total load of nutrients from the proposed WWTP effluent would be small relative to the large volume of water where mixing would occur. In addition, the daily tidal exchange of water in the Delta would contribute to rapid mixing of constituents, thereby reducing the potential for biostimulation of algae. Because the City would implement the design and operational requirements for treatment facilities described above, this impact is considered less than significant. Mitigation Measure i No mitigation is required. i Impact: Reductions in dissolved oxygen levels and increases in electrical conductivity could result in minor reductions in water quality of Marsh Creek. This impact is considered less than significant. Direct discharge of treated effluent to Marsh Creek could reduce levels of ambient DO and increase EC. Such changes can degrade the quality of habitat and adversely affect aquatic organisms. DO concentrations above 5.0 mg/l are considered the minimum level for maintaining the quality of habitat for desirable species of fish and aquatic invertebrates. Increases in EC, if sufficient in magnitude, can cause corresponding changes in the types of aquatic vegetation and organisms present in a water body (e.g., from freshwater to brackish water forms). The RWQCB has expressed concern regarding changes in levels of DO and EC in Marsh Creek being associated with discharges from the existing WWTP because of these adverse effects. Therefore, analyses were performed to estimate DO and EC conditions in Marsh Creek that would M result from discharge of effluent from the proposed WWTP during the summer dry period (May City of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft EIR June 26, 1998 3A-22 i through.October). Summer was assumed to be representative of the worst-case conditions because sensitive aquatic organisms are typically exposed to greater physical and metabolic stress when water is warm and strearnflow is minimal. A detailed discussion of the methods used and the results of the DO and EC analysis is presented in Appendix C. Dissolved Oxygen. Assumptions used for the DO analysis included zero background strearnflow and a high-average summer water temperature of 24°C and winter temperature of 12'C. Initial effluent DO values were set to equal the historical 1991-1997 creek DO for the summer(7.74 I mg/1) and winter (8.88 mg/1)periods, assuming that the effluent would be aerated with a cascade aerator system.. Initial DO deficits were then calculated from assumed effluent DO and stream temperature. The analysis indicated that DO would reach a minimum in the reach of stream j approximately 2-3 miles below the discharge point but would remain above .5.0 mg/l, which is the established water quality objective in the Basin Plan and NPDES permit for the existing WWTP. The cascade aerator would be operated as needed to ensure that the effluent contains a minimum DO of 5 mg/l. Therefore,potential impacts associated with DO would be less than significant. Electrical Conductivity. Effects of the proposed discharge on EC were evaluated with conservative assumptions of sumer low-flow conditions and estimated values of future EC levels in the effluent. The historical EC level in Marsh Creek indicates no trend of increasing values. Therefore,the summer period(May through October)average EC from 1996 and 1997 monitoring data of 885 4S/cm was assumed to be similar and representative of background EC levels under future conditions. It is expected that future EC levels in the influent to the WWTP will be considerably lower than current conditions because the City will be increasing their use of surface water supplies that have lower EC levels than the groundwater currently used. The source of this future surface water is anticipated to come from the Delta. Based on information obtained from Contra Costa Water District's 1997 Annual Water Quality Report,the total dissolved solids of rave water taken from the Delta ranged from 170 to 389 g/I with an average of 267 g/, which equates to an approximate average EC of 411 µS/cm. The EC in the surface water is considerably lower than the levels in groundwater(770 mg/1)currently being used by Brentwood. The projected annual use of surface water in the future is 22,800 acre-feet and well water will constitute approximately 3,800 acre-feet of the supply. Therefore,the EC of the future water supply was estimated from the City's projected ratio of use between surface and well water and the existing EC levels in the two water sources. Projected future EC in the influent and effluent for the proposed WWTP was then calculated by multiplying the source water EC by a coefficient to account for the increase in EC that occurs as water is used for domestic consumption. Domestic use generally increases the EC levels due to the introduction of wastes. The existing consumptive use factor of approximately 1.37 was calculated from existing well water and. WWTP effluent EC values and then applied to the future source water EC to derive a future average effluent EC of 705 VS/cm. Based on the future 10-mgd discharge volume, low streamflow discharge, and estimated future effluent EC values, a mass balance equation indicated that EC in Marsh Creek downstream of the discharge would not change substantially. Under the worst-case stream habitat conditions of zero background streamflow in Marsh Creek, the fixture projected Marsh Creek EC levels would decrease by 57%compared to the existing EC levels. With increasing background stream flow rates City of Brentwood WWTP Project Chapter 3.4. Hydrology and Water duality Draft EIR June 26, 1998 3A-23 up to approximately 10 efs, the decrease from the exisitng condition would stabilize to approximately 15%. At extremely high-flow rates, the small effluent discharge does not significantly change stream EC levels. Because Marsh Creek EC levels will decrease in the future with the additional use of a surface water supply with low EC, this impact is considered beneficial. Mitigation Measure No mitigation is required. Impact: Discharge of priority pollutants in treated effluent could result in degradation of water quality in Marsh Creek. This impact is considered significant. The discharge of treated effluent to Marsh Creek could contribute to the creek priority pollutants, such as trace metals and organic compounds, that could be toxic to aquatic organisms. The recently proposed California Toxics Rule is expected to be adopted in 1998, and a requirement could be included in the NPDES permit for the proposed project to meet the rule's strict limits for concentrations of priority pollutants in effluent. Recent analysis of selected priority pollutants in effluent from the existing WWTP indicates that the effluent has low levels of most of the pollutants that could be regulated under that proposed regulation. Individual samples of effluent approached or exceeded the anticipated limits for lead and thallium. The values for lead indicate no pattern of routinely elevated levels, and the thallium is believed to originate with the use of agricultural pesticides in orchards adjacent to the WWTP's groundwater extraction system. Because project compliance with proposed pollutant criteria is uncertain, this impact is considered significant. Implementation of the source control program and design and operation of treatment processes, described below,would reduce this impact to a less-than-significant level. Mitigation Measure A-1: Design and operate the WWTP to meet NPDES permit limits for priority pollutants. The WWTP shall be designed to meet NPDES permit limits for priority pollutants imposed by the RWQCB. When and if the California Toxics Rule is adopted and appropriate permit limits are included in the NPDES permit,the WWTP effluent shall also be treated as required to comply with applicable numeric criteria for priority pollutants. Treatment processes would be implemented and operated accordingly to help ensure compliance with NPDES permit limits. The WWTP operator would monitor performance of the treatment system to optimize and enhance processes that increase removal efficiency for trace metals and organic compounds Mitigation Measure A-2: Implement source control program. The City would implement a source control program to reduce concentrations of these pollutants in WWTP influent, in consultation with the RWQCB. Source control would target pollutants that are present at levels that exceed the discharge limits and commercial and industrial facilities that are known to have discharges containing the pollutants in question. Cfty of Brentwood WWTP Project Chapter 3A. Hydrology and Water Quality Draft Elft June 2S, 1998 3A-24 ................ i Monitoring Requirements. The City and the WWTP operator would implement monitoring procedures for influent, effluent, and receiving water quality in accordance with the provisions of a new NPDES permit issued by the RWQCB. i t City of Brentwood ff'ffTP Project Chapter 3A. Hydrology and Water Quality Draft EIR June 26, 1995 3A-25 ............. ti City ofBrentivood"f7P Project Chapter 3A. HydrGlogy and Water Quality Draft EIR June 26, 1998 3A-26 ............................ ............................. ................ ........................................ I r I i Chapter 3B. Geology, Soils, and Seismicity i Thi s chapter describes the geology, soils, and seismicity associated with the project site; addresses impacts of the proposed project on geology,soils, and seismicity; and proposes measures to reduce any significant impacts to a less-than-significant level. SETTING General Topography and Geologic Structures Brentwood is located at the northwestern end of the San Joaquin River Valley along the border of the Coast Ranges and Great Valley Provinces of California. Topography in the Brentwood area consists of gently rolling hills, with generally level terrain near the project area. The deeper structure underlying the project area consists of marine sediments of the Great Valley sequence that were deposited when the Central Valley was an inland sea(The Planning Center 1993). Surface deposits in the project area are relatively young alluvial deposits that were distributed by floodwaters of the major streams and rivers in the area.. The Brentwood area is subject to seismic activity from several local and regional earthquake faults. The major regional faults are the San Andreas , approximately 45 miles west of Brentwood; the Hayward,approximately 27 miles west;and the Calaveras, approximately 1.8 miles southwest. Other regional faults include the Greenville and Concord-Green Valley faults, approximately 14 and. 25 miles west and southwest of the city, respectively. Local faults include the Antioch-Davis, Brentwood-Sherman island, and Midland faults. These faults generally traverse the area trending north-south. The.Brentwood-Sherman Island and Antioch-Davis faults are approximately 2 and 4 miles west of the project area, respectively. The most recently recorded seismic activity linked with these faults occurred on the Antioch-Davis fault in 1889. The Midland fault is approximately 5 miles east of the project area. In April 1982, two earthquakes occurred in the Vacaville-Winters area that were postulated to be associated with the Midland fault. The Brentwood area is subject to ground shaking from any of these potentially active faults. Effects of ground shaking are typically most pronounced on larger commercial structures, roadways, and utility lines. The City currently enforces adherence to the 1994 edition of the Uniform Building Code, which require that buildings and other structures meet minimum seismic safety standards. City of Brentwood W47P Project Chapter 35. Geology,Sails,and Seismicity Draft FIR lune 1t5, 1998 38-1 t Another potential effect of faulting in the area is liquefaction. Liquefaction is the loss of shear strength resulting from excess pressure created in fine-grained, saturated soils during a seismic event. The potential for liquefaction in the Brentwood area is considered low. However,the existing ) wastewater disposal and percolation ponds contribute to locally elevated groundwater levels that increase the saturation of underlying soils. ,l Land subsidence is a general lowering of ground surface elevations resulting from groundwater removal,oil and gas extraction,and oxidation of peat deposits,and it can cause damage to structures. No record of damage resulting from subsidence has been identified in the Brentwood I area. Suit Resources Large areas surrounding Brentwood and the project area are considered prime farmlands in the City of Brentwood General flan (City of Brentwood 1993). Soils in the Brentwood area are generally classified as clays and clay loams. The predominant soil series in the project area are Capay and Sacramento clays and Rincon clay-loams (U.S. Soil Conservation Service 1977). The Capay and Sacramento series are considered to have high shrink-swell potential and high corrosivity potential to uncoated steel. Previous geotechnical studies conducted at the existing W'WTP site found that surface soils were dominated by fine unconsolidated sands (Skrel pers. comm.). Expansive clays were not found in the soil borings analyzed previously, and the widely distributed } sands would probably reduce the degree of corrosivity and shrink-swell potential of any clay deposits that are present. f 1 Important soil characteristics with regard to the proposed project include slope stability, 4 potential for wind- and water-induced soil erosion, corrosiveness of the soil, and presence of expansive(i.e., susceptible to shrinking and swelling)clays. Damage to building foundations and structures can result from the corrosion and physical stresses exerted by expansive clays or corrosive soils. V IMPACTS OF THE PROPOSED PROJECT I Significance Criteria i According to State CEQA Guidelines Appendix G; other federal and local laws, regulations, and olicies• and professional judgment, the proposed project would result in a significant impact on geology and soils if it would: ■ expose people or structures to major geologic hazards, City of Brentwood WJ+TP Project Chapter 3B. Geology,Soils,and Seismicity Draft EIR 3B-2 June 26, 1998 i 1 I i I a cause substantial changes in the physical environment through the alteration of the topography or by adversely affecting a unique geologic resource, a result in conversion of a substantial amount of prime farmland,or 1 ■ cause substantial erasion or siltation. i I ` 1 Impacts and Mitigation Measures I Impact: Construction activities for the Proposed W-WTP(e.g.,excavation,grading,and filling) could result in erasion, changes in topography, and unstable soil conditions. This impact is considered less than significant. � E Construction of the proposed treatment plant facilities would disturb a large area over several years and, therefore, has the potential to result in substantial erosion during winter storm events. Because Marsh Creek is near the construction site, this possibility of erosion could lead to an increased risk of sedimentation in the stream channel. f The impact is considered less than significant because the City would require selected construction contractors to obtain and implement provisions of several permits that would prevent problems associated with erosion and sedimentation. These pem-lits include an NPDES stormwater discharge permit for general construction activity issued be the RWQCB, a streambed alteration. agreement issued by Dl"G, and a Section 404 nationwide permit issued by the Corps for outfall structures and all construction work that is required within Marsh Creek. The City shall also conduct a postconstruction field inspection before the rainy season to ensure that vegetation has became established and other erosion control measures have been installed according to permit conditions. (Refer to Chapter 3A for additional information regarding the various permit requirements.) Mitigation Measure No mitigation is required. { Impact: Seismic events could result in structural damage to the proposed W'WTP facilities. This impact is considered less than significant. The faults near the project area have long-term potential for seismic activity, which poses a risk to structures in the area of damage and release of untreated wastewater to the environment. The impact is considered less than significant because the City would require the facility to be designed to withstand the maximum credible earthquake and would construct structures in accordance with Uniform Building Code requirements, which include earthquake safety standards. Geotechnical investigations would be performed to evaluate soils onsite and determine the appropriate City of Brentwood WWTP Project Chapter 3B. Geology,Soils,and Seismicity ➢rn,ft EIR Ane 26, 1998 3B_3 construction practices needed for the facilities. The long-term risk of liquefaction from seismic activity would decrease because of the eventual discontinuation of treated effluent disposal into percolation ponds. Mitigation Measure No mitigation is required. Impact: Structural damage to the proposed WWTP facilities could occur as a result of long- term stress from expansive or corrosive soils or land subsidence. This impact is considered less than significant. Soils in the project area are classified as having corrosive and shrink-swell characteristics. Long-term exposure of WWTP structures to these soils could result in damage to concrete foundations and underground pipes and conduits. The impact is considered less than significant because the City would hire a professional corrosion consultant to evaluate the potential for corrosion at the building site and recommend appropriate preventive measures. Facilities would be constructed using appropriate noncorrosible materials. Results of the geotechnical study would be used to determine appropriate measures to withstand stresses caused by expansive clays, if they are found to be present at the building site. Mitigation Measure No mitigation is required. City of Brentwoo�_Y_Wff7P Project Chapter 3B. Geology,Soils,and Seismicity Draft EIR 3B-4 dune 26, 1998 ....................... .............................. ............................... ......... ................. ................................. 1 Chapter 3C. Biological Resources The general study area, for this analysis includes the existing WWTP site, the immediate vicinity of Marsh Creek, and the downstream reach of Marsh Creek to near its confluence with Big Break. Biological resources in the project area were evaluated by collecting background information (i.e., reviewing pertinent environmental documents [Jones & Stokes Associates 1998a, 1998b], contacting individuals knowledgeable about biological resources in the study area) and conducting field surveys. Reconnaissance-levet field surveys were conducted on May 2, 1997, and January 18, 1998. wring the surveys, data was recorded on data sheets and maps by walking and driving the j project site. Specific attention was given to sensitive resources that could be affected by the proposedproject, such as wetlands, sensitive habitats, and areas with potential to support special- status species. SETTING The project area is located in the Californian Floristic Province (Hickman 1993) in northwestern San Joaquin Valley. Habitat types in the project area include annual grassland and some ruderal habitat on the WWTP site,along with areas of marsh and riparian habitats along Marsh Creek that increase as the creek approaches Big Break(see Figure 3A-1). Marsh Creek is the primary biological resource and habitat in the project area. Urban development and agriculture have encroached on the creek's banks within the city limits, and water quality has been affected by urban and agricultural runoff and discharge of treated.effluent. Marsh Creek is tidally influenced at Big Break south of Jersey Island, and resulting salinity changes vary with the magnitude and timing of the tides and freshwater outflows. No riparian vegetation and little bank vegetation is found near the proposed outfall structure. Farther downstream, some riparian vegetation is present and overall habitat conditions improve, especially at the confluence of Marsh ! Creek and Big Break. The flow and water quality in Marsh Creek are described in Chapter 3A, "Hydrology and Water Quality" Marsh Creek probably supports native and introduced fish species that are typically more tolerant of warm water and fluctuating DO levels. Resident species include warinwater game fish such as largemouth bass, black crappie, brown bullhead, and sunfish. Habitat types and special- status species that may occur there are described below. Cit., of Brentwood W07P Project Chapter 3C. Biological Resources Draft EIR June 26, 1998 3C-1 Habitat Types 1 The habitat types in the project area can be described as ruderal-annual grassland; riparian, freshwater-brackish marsh,and open water as defined by the Wildlife Habitat.Relationship(WHR) system. This system defines habitats based on the composition and structure of the dominant vegetation of specific area and provides generalized information pertaining to wildlife value and use of these habitat types. Riparian Habitat i Riparian habitat is associated with the levee bank along the lower portion of Marsh Creek near its confluence with Big Break. Riparian habitat occurs only on the west side of the levee road north of Marsh Creek Bridge (Figure 3A-1). Common species in riparian habitat are willows, cattails,toles, blue elderberry, white alder, button bush, blackberries, and California rose. Riparian habitat provides cover and nesting opportunities for a diverse group of wildlife species. Several species of wintering and migratory birds,including white-crowned sparrow,yellow- rumped warbler, and fox sparrow,use the riparian vegetation for foraging and cover while moving along their migration route or wintering in the area. The thick riparian vegetation also provides cover for mammals, including striped skunks, Audubon cottontail, western harvest mice, Norway rats,and deer mice. In riparian areas that retain water into the spring and summer,Pacific tree frogs are abundant. i Freshwater-Brackish Marsh Freshwater-brackish marsh habitat occurs along the margins of Marsh Creek. Little, if any, freshwater marsh habitat is found along Marsh Creek between the existing WWTP outfall and the Marsh Creek.Bridge east of ISD's facilities, approximately 0.25 mile south of Big Break. In these i locations, cattail "islands" form narrow bands (approximately 30 feet long and 5 feet wide) along the creek margin. North of the bridge and east of ISD's facilities, marsh vegetation appears to be tidally influenced. The channel increases in width(to about 30 feet wide),and bulrushes and cattails form a monoculture along the creekbank,whereas an occasional willow or tobacco tree grows among the Bermuda grass-covered bank;these trees are isolated and less than 10 feet tall. Wildlife species using the freshwater-brackish marsh habitat in Marsh Creek are limited j because the habitat encompasses only a narrow band for a relatively short distance. The emergent marsh habitat(cattails and bulrushes)is used by breeding birds, including song sparrows, common yellowthroats,marsh wrens,and red-winged blackbirds. River otters also forage in areas where open water is deep enough for free swimming. City of Brentivood Ft RTP Project Chapter 3C. Biological Resources Draft EIR 3C-2 June 26, 1998 i Ruderal-annual Grassland Ruderal-annual grassland occurs in small patches at the WWTP site and along Marsh. Creek levee hanks. Common plant species are wild oats,bromes, fescue, rye, foxtails, mustards, filarees, and yellow star-thistle. i Wildlife use of ruderal-annual grassland is limited because the area is small and frequently disturbed during maintenance activities for the WWTP. ,Although the diversity of wildlife is ! minimal,those species that are present in the area are abundant. Mammals, including house mice, California meadow mice, black-tailed hare, and 13otta's pocket gopher, are common in grassland areas. Bird species also using grassland areas include savannah sparrows,western meadowlarks,and mourning cloves. Common reptiles include western fence lizard and Pacific gopher snake. .Additionally,Norway rats, deer mice,Brewer's blackbirds,swallows,and European starlings occur in and around structures. Raptors (birds of prey) are also common in ruderal-annual grassland. Where trees occasionally occur in the ruderal-annual grassland, other wildlife species, particularly birds, are common because the structure of the branches provides perch sites and a food source. Open Water Pond Several open water ponds used to dispose of treated effluent are located on the WWTP site. For the most part,bare ground surrounds the ponds. Depending on the time of year,these ponds vary in depth(from less than 1 foot to 4 feet); they are used by various species of water birds. Killdeer and American pipets forage along the edge of the ponds,and several gull species forage and loaf in the ponds. In addition.,waterfowl and shorebirds{including mallards,green-winged teal,dowitchers, and yellowlegs}forage and rest in the ponds. i Special-Status Species i Special-status species are plants and animals that are legally protected under the..-California and federal Endangered Species Acts and other regulations, as well as species that are considered sufficiently rare by the scientific community to qualify for such listing. Special-status plants and animals include the following categories: • species listed or proposed for listing as threatened or endangered under the federal Endangered.Species Act{50 CFR 1.7.12 [listed plants], 50 CFR 17.11 [listed animals], and various notices in the Federal Register [proposed species]); ■ species that are candidates for possible future listing as threatened or endangered under the federal Endangered Species Act(61 FR 40: 7596-7613, February 28, 1996); City of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EIR 3C-3) , June 26, 195'8 e species listed or proposed for listing by the State of California as threatened or endangered under the California Endangered Species Act(14 CCR 670.5); ■ species that meet the definitions of rare or endangered under CEQA (State CEQA Guidelines, Section 15380); • plants listed as rare or endangered under the California Native Plant Protection Act(Cal, ` Fish and Game Code, Section 1900 et seq.); i ■ plants considered by the California Native Plant Society (CLAPS)to be"rare,threatened, or endangered in California" (Lists I B and 2 in Skinner and Pavlik 1994), and plants about which more information is needed to determine their status and plants of limited j distribution (Lists 3 and 4 in Skinner and Pavlik 1994), which may be included as special-status species on the basis of local significance or recent biological information; i 1 ■ animal species of special concern to DFG (Remsen 1978 [birds], Williams 1986 [mammals], and Jennings and Hayes 1994 [amphibians and reptiles]); and ■ animals fully protected in California(Cal. Fish and Game Code, Section 3511 [birds], 4700 [mammals], and 5050 [reptiles and amphibians]). Special-Status Plants i Table 3C-I lists the special-status plant species that could occur in the general vicinity of the project area. This plant list was compiled based on information in DFG's Natural Diversity Data Base(NDDB)(Natural Diversity Data Base 1997)and the CLAPS Inventory of Rare and Endangered ' Vascular Plants of California(Skinner and Pavlik 1994). None of the special-status plant species that occur in grassland habitats are expected to occur on the WWTP site because vegetation at the project site consists of ruderal-annual grassland vegetation rather than relict, natural grassland, and the site is regularly disturbed during maintenance activities for the treatment plant. Additionally, none of the special-status plants that occur in marsh habitats are expected to occur because Marsh Creek has been altered extensively by channelization and flood control maintenance. If any of these species were present, increases in depth and velocity from the proposed discharge would have little effect on them or their habitat. Special-Status Fish and Wildlife A total of 28 special-status fish and wildlife species have the potential to odor in the vicinity of the project area(Table 3C-2). The following 12 special-status species are discussed because they could occur in the general study area or the habitat types they are known to use are present at the project site: valley elderberry longhorn beetle(VELE), western pond turtle, northern harrier, white- tailed kite, burrowing owl, loggerhead shrike,tricolored blackbird, San Joaquin pocket mouse, San l Joaquin kit fox, American badger, Delta smelt, and Sacramento splittail. City of Brentwood WWTP Project Chapter 3C. 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No suitable breeding habitat is present in the affected area for the following special-status species: vernal pool fairy shrimp, curve-foot hygrotus diving beetle, Molestan blister beetle, California tiger salamander,giant garter snake,golden eagle, short-eared owl, black rail,pallid bat, and Townsend's western big-eared bat. The following species are visitors that do not breed in the project area. sharp-shinned hawk, Cooper's hawk, ferruginous hawk, prairie falcon, little willow flycatcher, and yellow warbler. Valley Elderberry Longhorn Beetle. The VELB (a3mocerus californicus dimorphus) is a species federally listed as threatened; it feeds and breeds on elderberry shrubs throughout lowland California. Elderberry shrubs are known to occur along Marsh Creek.. However, the elderberry shrubs are located outside of the creek channel,on the opposite side of the levee road that runs along the creek., and would not be affected by project activities. Western Pond Turtle. The western pond turtle (Clemmys marmorata) is a federal species of concern and a state species of special concern. The western pond turtle occurs throughout California in ponds, marshes, rivers, and.irrigation canals with muddy or rocky bottoms and emergent vegetation. No pond turtles were observed during surveys, and project activities would potentially increase the amount of ponded water in the creek creating more habitat than currently exists. Northern Harrier. The northern harrier (Circus cyaneus) is a state species of special concern. Northern harriers are residents throughout lowlands in California. Northern harriers construct their nests on the ground in tall vegetative cover(e.g., grasslands;meadows,and marshes). They are known to nest in the region; but potential nesting habitat is limited because most of the project area is disturbed. No northern harriers were observed on the project site during field surveys. White-Tailed Kite. The white-tailed kite (Elanus leucurus) is fully protected species under the California Fish and Game Code. White-tailed kites nest and winter throughout the lowlands of California. Nests are constructed in trees, often in riparian corridors, and a few white-tailed kites are known to nest in the region . White-tailed kites were not observed during field surveys on the project site. t Western Burrowing Owl. The western burrowing owl (.tlthene cunicularia hypugea) is a federal species of concern and a state species of special concern. Burrowing owl nests are also protected by California Fish and Game Code Section 3503.5. Potential burrowing owl habitat (ruderal-annual grassland)occurs on the WWTP site and several burrowing owls are known to occur there also. luring the reconnaissance-level field surveys,two burrowing owls were observed on the WWTP site near the emergency holding pond. Loggerhead Shrike. The loggerhead shrike is a state species of special. concern. Loggerhead shrikes are relatively common in lowland California and prefer open habitat with scattered shrubs and trees for nesting. Loggerhead shrikes were not observed in the project area during surveys but suitable habitat is present on the WWTP site. City of Brentwood WWTP Project Cnapler 3C. Biological Resources Draft EIR Jure 26, 1998 3C-13 Tricolored Blackbird. The tricolored blackbird(Agelaius tricolor)is a federal species of concern and a state species of special concern. Tricolored blackbirds breed and winter in California and nest primarily in scattered locations in the Central Valley. They typically nest in colonies in emergent marsh vegetation or upland sites, including blackberries and grain crops. Statewide surveys (Reedy and Hamilton 1997) found no nesting colonies of tricolored blackbirds near the project area. However,tricolored blackbirds were occasionally observed during winter in the region, and suitable foraging and resting habitat is present,especially in ruderal-annual grassland and marsh ' habitat. The tricolored blackbird was not observed during field surveys. I San Joaquin Pocket Mouse. The San Joaquin pocket mouse is a federal species of concern. Historically,the pocket mouse occurred throughout the Central Valley,but now it occurs principally along the east side of the San Joaquin Valley in grassland and oak savanna. The ruderal-annual grassland on the WWTP site may provide some low-quality habitat for the speck's. i San Joaquin Kit Fox. The San Joaquin kit fox(Vulpes macrotic mutica)is federally listed l as endangered and state listed as threatened. The San Joaquin kit fox occurs principally in the San Joaquin Valley and foothills. The species uses a variety of habitats for burrowing and foraging, including saltbush scrub, grassland, oak savanna, and rangeland. Although no surveys were conducted for the species, the project site is within the range of 4 the kit fox and ruderal-annual grassland habitat occurs on the project site. Habitat on the project site and immediately surrounding area is not suitable for the San Joaquin kit fox, however, even though kit fox are known to use ruderal-annual grassland. The closest recorded kit fox sighting was 7 miles south of the project area near the Byron Hot Springs (Larson pers. comm.). The ruderal-annual grassland habitat on the site is fragmented and disturbed, and the habitat types surrounding the project area are mostly unsuitable (row crops, grain, orchard, and residential areas). Additionally, the project site is fenced, limiting access to the site, and regular maintenance of the WWTP (e.g., driving, disking, and foot travel)further reduces the possibility that the site would be used by the kit fox. American Badger. The American badger (Taxidae taxus) is a state species of special concern. American badgers occur throughout California in open areas with loose soil. Badgers were not observed during surveys but suitable habitat is present in the general study area. Delta Smelt. Delta smelt(Hypomesus transpacificus) is federally listed and state listed as threatened. The species is found mainly in the waters of the Delta and Suisun Bay. Delta smelt are small (usually less than 3.5 inches long),plankton-feeding fish,that live for only 1 year. Adults and older juveniles live principally in shallow water or near the surface in deeper water, where they feed on zooplankton, particularly copepods(Eurytemora affinis, Pseudodiaptomus forbesi, and others) (Moyle et al. 1992). Mysids (Neomysis mercedis), cladocerans, and amphipods may be important food items, depending on prey availability and the size of the smelt. Delta smelt are not known to occur in the vicinity of the proposed outfall facility. Delta smelt generally spawn in fresh water (Wang 1991). Spawning is believed to take place primarily in shallow edgewaters and river areas under tidal influence with moderate to fast velocities i i City of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EIR 3C-14 June 26, 1998 I (Wang 1991, California Department of Water Resources and U.S. Bureau of Reclamation 1994). The delta smelt population is concentrated in the estuary west of the confluence of the Sacramento and San Joaquin Rivers in high-outflow years and in the Delta in low-outflow years (Stevens et al. 1990,Moyle et al. 1992). Delta smelt are found at salinities of 0-14 parts per thousand(ppt) (Moyle et al. 1992),but they are most abundant at salinity levels between approximately 0.45 and 4.40 ppt (California Department of Water Resources and U.S. Bureau of Reclamation 1994). There is no evidence that salinity has a direct effect on adult delta smelt, but freshwater flow patterns may influence spawning migration. Sacramento Splittail. Sacramento splittail (Pogonichthys maerolepidotus) is proposed for listing as threatened under the federal Endangered Species Act and is a state species of special concern. The fish are large (greater than 30 centimeters long) cyprinids endemic to the lakes and rivers of the Central Valley of California(Moyle and Herbold 1989). Sacramento splittail are most abundant in Suisun Bay, Suisun Marsh, and the Sacramento-San Joaquin Delta. j i Sacramento splittail are freshwater fish capable of tolerating moderate levels of salinity (10-18 ppt). These fish typically spawn from March through May when water temperatures are i between 9°C and 20°C(Moyle 1976, sang 1986). Larval Sacramento splittail are commonly found in the shallow, weedy areas where spawning occurs. The larvae eventually move into deeper, open water habitats of Suisun and San Pablo Bays as they grow and become juveniles (Wang 1986). IMPACTS OF THE PROPOSED PROJECT Significance Criteria Significance criteria for this analysis were established on the basis of Appendix G of the State CEQA Guidelines and professional judgment. The proposed project would have a significant impact on biological resources if it would. 8 substantially reduce the extent or value of fish or wildlife habitat, a have potential to eliminate a plant or animal community, or e reduce the overall population or range of a special-status species. Impact: Construction of the effluent outfall could result in the loss or modification of wetlands or other waters of the united States that are under the jurisdiction of the Corps and/or DFO. This potential impact is considered less than significant. Construction of the effluent outfall could result in the loss of modification of wetlands or other waters of the United States that are under jurisdiction of the Corps and/or DFG. Wetlands typically provide important wildlife and fisheries habitat; however, because of the limited amount of vegetation and the degradation of the site resulting from channelization of Marsh Creek, few City of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EIR June 26, 1998 3C-15 i wildlife and fish species occur at the effluent outfall. As described in Chapter 3A, an NPDES ! stormwater discharge permit for general construction activity from the RWQCB would be required for the proposed project because more than 5 acres would be disturbed. The NPDES permit requires development of an SWPPP that identifies best management practices to control erosion and runoff of contaminated stormwater from the construction site. 3 Additionally, the City would include provisions in construction contracts requiring the general contractor to obtain and implement several permits to control construction-related pollution and impairment of aquatic habitat. The selected contractor would obtain and implement provisions of Nationwide Permit 7 from the Corps(under Section 404 of the Clean Water Act) for construction of the outfall structure and the associated Section 401 water quality certification or waiver from the RWQCB. Additionally, for all construction within Marsh Creek, the contractor would obtain and I implement the provisions of a DFG streambed alteration agreement to prevent adverse effects on aquatic habitat and resident species. Because of the limited amount of habitat at Marsh Creek and the additional permits that would be required before construction begins to protect aquatic habitat at the project site,this impact is considered less than significant. Mitigation Measure No mitigation is required. Impact. Development of the proposed WWTP facilities would result in the conversion of approximately 1-5 acres of ruderal-annual grassland habitat, which may lead to the toss of potential foraging habitat for the white-tailed trite, northern harrier, tricolored blackbird, loggerhead shrike, San Joaquin pocket mouse, and American badger and wildlife habitat for resident and migratory wildlife species. This impact is considered less than significant. As stated in the setting section, few species use the ruderal-annual grassland habitat on the project area for food,nesting, and cover. The loss of approximately 1-5 acres of this habitat would not result in a substantial adverse change in the abundance of these species. Foraging habitat for the above-referenced species does not currently limit their populations in the project region. Suitable foraging habitat is present throughout the region, and the temporary and permanent loss of the ruderal-annual grassland on the project site would not cause a substantial decline in populations of any of these species. Only one special-status species,the burrowing owl, is known to occur on the project site and may be adversely affected by project construction(please see discussion below). Other special-status species(Tables 3C-1 and 3C-2)that are known to occur in the region or use habitat types similar to those found on the project site would not be affected from project construction because the specific habitat requirements for these species are'not present on the project site, or the proposed project would not adversely affect the species. City of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EIR 3C-16 ,lune 26. 1998 Mitigation Measure No mitigation is required. l } Impact: Development of the proposed WWTP facilities would result in the conversion of approximately 1-5 acres of ruderal-annual grassland habitat, which may lead to the loss of nesting habitat for raptors. This impact is considered significant. Although the WWTP site is extremely disturbed and most raptors are unlikely to nest in the area because of the amount of disturbance, habitat is present in portions of the ruderal-annual grassland habitat and isolated trees for species such as the northern harrier and American kestrel. The northern harrier is a ground nester, and the American kestrel nests in cavities in trunks of isolated trees such as those on or immediately adjacent to the WWTP site. Implementation of the proposed project could adversely affect these nesting raptors; { therefore, this impact is considered significant. Such potential effects on nesting raptors could be a violation of California Fish and Game Code Section 3503.5, and DFG also considers these effects significant. Implementation of the following mitigation measure would reduce this impact to a less- than-significant level. i Mitigation Measure Mitigation Measure C-1: Conduct a preconstruction survey for nesting raptors before construction begins. The City shall conduct a preconstruction survey for nesting raptors (white- tailed kite, northern harrier, American kestrel, and great-horned owl) on the project site if construction activities will take place between March I and August 15. The survey shall be i conducted by a qualified biologist during the same calendar year when the proposed activity is planned to begin, to determine if nesting birds of prey would be affected. If phased construction procedures are planned for the proposed activity,the results of the survey shall be valid only for the season when it is conducted. i If the survey does not identify any nesting raptor species within the area affected by the proposed activity,then no further mitigation would be required. Should any nesting raptor species be found, however,the following procedures shall be implemented to comply with California Fish and Game Code Section 3503.5: a Identify a buffer area around active raptor nests until the young have fledged or the raptors are no longer attempting to nest. The size of the buffer area will be determined based on consultation with DFG. No furthermeasures are required once the young have fledged or if construction in the potential nesting area will occur after August 15. i City of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EJR June 16, /998 3C-17 Impact: Development of the proposed WWTP facilities would result in the conversion of approximately 1-5 acres of ruderal-annual grassland habitat, which may lead to the direct i mortality of burrowing owls or loss of foraging habitat. This impact is considered significant. Implementation of the proposed project could eliminate one or more burrowing owl pairs or unpaired resident owls on the project site and would likely eliminate approximately 1-5 acres of foraging habitat. Because burrowing owls are using several areas on the project site,the owls would likely be harmed or displaced during construction of the project and would be left without breeding and foraging habitat. DFG considers this impact to be a violation of the Migratory Bird Treaty Act I and California Fish and Game Code. This is also considered a significant impact because the burrowing owl is a. DFG species of special concern and a federal species of concern. The City is evaluating actions that may be included to enhance the overall environmental benefits of the proposed project. 'These actions are preliminary and conceptual at this time and include: i • creation of a recreational trail system on the WWTP Site connecting Sunset Park with the existing Fast Bay Regional Parks District trails; • specific areas set aside for burrowing;owl habitat; a wildlife interpretive areas; and r ■ enhancement of the remaining ponds (5 and 6) or creation of one or more additional ponds near the remaining ponds, which would also include provisions for avoiding or creating burrowing owl habitat. These options will be developed further and evaluated by the City and its consultants and would be considered during preconstruction surveys (described below) and consultation with DFG. Implementation of the following mitigation measures would reduce this impact to a less-than- significant level. Mitigation Measures The mitigation measures to reduce this impact to a less-than-significant level are presented below according to the time of year in which construction would occur. i Mitigation Measures for Construction Activities between February 1 and August 31. Implementation of the following mitigation measures would reduce impacts on burrowing owls to a less-than-significant level if surveys indicate that burrowing owls could be affected by development of the WWTP facilities during the breeding season. i Mitigation Measure C-2: Comply with DFG mitigation guidelines. Mitigation for impacts on burrowing owls during the breeding season shall follow the mitigation guidelines outlined in the DFG Staff Report on Burrowing Owl Mitigation(California Department of Fish and Game 1995). The City, in consultation with DFG, shall retain a qualified biologist to conduct a I Croy of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EIR 3C-18 June 26, 1998 I preconstruction survey during the breeding season(approximately February I through August 31) of the proposed project site during the same calendar year when construction is planned to begin. The surveys will document whether burrowing owls are nesting on or directly adjacent to any proposed project areas. Because phased construction is planned for the proposed project,the results of the breeding-season survey shall be valid only for the season when the survey is conducted. If burrowing owls are found during the breeding-season survey,the City,in consultation with DFG, shall avoid all burrowing owl nest sites that could otherwise be disturbed by project construction during the breeding season or while the nest is occupied by adults or young. Avoidance shall include the establishment of a nondisturbance buffer zone around the nest sites up to 250 feet in diameter. Construction may occur during the breeding season if a qualified biologist monitors the nest site and determines that the nest site is no longer used by burrowing owls. The buffer zone shall be delineated by highly visible temporary construction fencing. Mitigation measures are negotiated with DFG and may also include permanently protecting foraging and burrowing owl habitat onsite or offsite through land acquisition or participation in a land bank or land tract purchase. Additionally, the construction of two artificial burrows may be required for each occupied burrow lost or rendered unsuitable as a result of construction activities. If burrowing owls are not observed during the breeding-season survey, the City shall consult j with DFG to determine whether any mitigation measures are needed for any permanent loss of foraging habitat. Mitigation Measures for Construction Activities between September 1 and January 31. Implementation of the following mitigation measures would reduce impacts on burrowing owls to j a less-than-significant level if surveys indicate that burrowing owls could be affected by development of the WWTP facilities during the nonbreeding season: Mitigation Measure C-3: Conduct a preconstruction survey for burrowing owls outside the breeding season before construction begins. The City, in consultation with DFG, shall retain a qualified biologist to conduct a preconstruction survey outside the breeding season(approximately September I through January 31) on the proposed project site during the same calendar year when J construction is planned to begin. The surveys will document whether burrowing owls are using the area during the nonbreeding season on or directly adjacent to any portion of the project area. Because phased construction is planned for the proposed project, the results of the nonbreeding- season survey shall be valid only for the season when it is conducted. If burrowing owls are found daring the nonbreeding-season surveys, the City can avoid impacts on owls or passively relocate the owls. Avoidance shall include the establishment of 160- foot-diameter nondisturbance buffer zone around the nest sites. The buffer zone shaII be delineated by highly visible temporary construction fencing. If burrowing owls cannot be avoided, the City shall conduct passive relocation by installing one-way doors in suitable burrow entrances in areas where construction will occur. The burrows can then be excavated to prevent reoccupation by owls after the one-way doors have been installed and monitored for I week. City of Brentwood WH'I`P Project Chapter 3C„ Biological Resources Draft.EIR .lune 2G, 1998 3C-19 Mitigation for displacing burrowing owls during the nonbreeding season and altering burrowing owl habitat should follow the mitigation guidelines outlined in the DFG Staff Report on Burrowing Owl Mitigation(California Department of Fish and Game 1995). Mitigation measures are negotiated with DFG and may include permanently protecting foraging and burrowing owl habitat onsite or offsite through land acquisition or participation in a land bank or land tract purchase. Additionally,the construction of two artificial burrows may be required for each occupied burrow lost or rendered unsuitable as a result of construction activities. i J Impact: The proposed project would increase the amount and slightly affect the quality of water discharged to Marsh Creek,which could affect special-status fish species. This impact is considered less than significant. Sacramento splittail and delta smelt could potentially occur near the mouth of Marsh Creek where it flows into Big Break, although neither species has been recorded there. It is unlikely that these species occur in the area of the proposed outfall structure. The increased flows may change the water temperature and salinity in the creek. These changes are expected to be slight, however, because smelt and splittail survive in variable water temperatures and salinity regimes,these changes should have a minimal effect on these species. The potential impact of the proposed project on water quality for these parameters is considered less than significant (see discussion in Chapter 3A, } "Hydrology and Water Quality") Mitigation Measure No mitigation is required. t I City of Brentwood WWTP Project Chapter 3C. Biological Resources Draft EIR 3C-20 June 26, f 998 Chapter 3D. Public Health and Safety This chapter focuses on public health issues relating to the proposed project; including the potential presence of pathogenic (i.e., disease-causing) organisms in treated effluent,the potential for increased mosquito populations, and public safety issues associated with the presence of hazardous materials required for onsite activities. SETTING i Public Health i I This section addresses several public health issues that relate to the proposed project: i concerns about pathogens in treated wastewater, control of mosquitoes as a disease vector,and odors related to operation of the WWTP facilities. Pathogens in Treated Wastewater Treated wastewater is commonly discharged to streams and rivers throughout California and is also used for a wide range of activities,including irrigation, industrial processes, and groundwater recharge. Although wastewater can contain pathogenic organisms,regulations require that treatment processes remove most of these organisms to protect public health. Advanced secondary treatment of municipal wastewater typically results in the removal of i more than. 99.99% of pathogenic organisms (e.g., viruses, bacteria, and parasites) (Yates 1993). Because 140% removal cannot be guaranteed even with a high level of treatment, however, there is a slight risk of public health effects from exposure to treated wastewater. Risk of infection from such exposure depends on many factors, including the efficiency of the treatment processes being used and the survival rate of the pathogen in effluent, soil, or air. In particular, sunlight is effective in removing or deactivating microorganisms in reclaimed water that has been applied to soil or plant surfaces. Viruses in wastewater have been of particular concern because of their ability to survive disinfection by chlorination, their low infectious dose, and their minute size. The results of numerous studies and observations from existing discharges and reclamation projects have indicated that,in general,treated wastewater that meets NPDES permit requirements (described in Chapter 2)does not present a public health risk. The beneficial uses of Marsh Creek do not include its use as a source of drinking water. The proposed W WTP facilities for the City City of Brentwood WWTP Project Chapter 3D. Public Health and Safety Draft EIR June 76, 1998 3D-1 would provide a disinfected, filtered secondary effluent;at that level of treatment, regulations would permit the effluent to be discharged to Marsh Creek in accordance with Title 22 requirements. Mosquitoes Mosquitoes are known to reproduce in areas with standing water and under similar conditions that can enhance breeding activity; this includes wastewater treatment facilities such as ponds with edge or shallow-water habitat. Mosquitoes in California can carry malaria and the virus for western j equine encephalitis, and an unmitigated increase in mosquito populations would pose a public health threat. The project area is under the jurisdiction of the Contra Costa County Mosquito and Vector Control District (CCCMVD). The City is currently coordinating efforts with the CCMVCD to ensure that mosquito populations in the project area are minimized. Mosquito control efforts that i are already underway at the WWTP and would continue at the proposed WWTP include weed control and vegetation management, inspections of the disposal ponds, and biological control measures such as stocking ponds with mosquitofish(Garnbusia afnis) (Parsons pers. comm.). The proposed WWTP facilities would not include any new features that would cause an increase in mosquito populations, and a substantial portion of the existing disposal ponds would be removed under the proposed project. i Odors Although no public health issues are known to be associated with odors from the existing WWTP, odors are considered a nuisance and are regulated by the $AAQMD as described below under"Regulatory Framework". Public Safety I 1 This section addresses the potential effects on public safety associated with the storage and use of hazardous materials at the WWTP as a part of routine operations, as well as the minimal I potential for the presence of hazardous waste from previous activities on the WWTP site. 3 Hazardous Materials Some of the chemicals required for normal operation of treatment processes at a wastewater treatment facility are considered hazardous under federal and state regulations. Hazardous materials, as defined in Title 26 of the California Code of Regulations, are substances with certain chemical and physical properties that could pose a substantial hazard to human health or the environment if managed irnproperly. The chemicals present at the WWTP are used in small quantities in the i City of Brentwood WWTP Project Chapter 3D. Public Health and Safety Draj EIR 3D-2 .lune 26, 79998 _.. . _..__.................... treatment processes and are generally considered safe for workers and the public under these conditions. However,acute exposure resulting from an accidental release or spill could pose a public health hazard to workers and the surrounding community. Only very small amounts of hazardous materials are used at the existing WWTP because chlorination and dechlorination are not required under the existing NPDES permit. The principal hazardous materials that may be used at the proposed WWTP are liquid chlorine (sodium hypochlorite, 12.5% solution), sodium bisulfite (25% solution for dechlorination), alum, and miscellaneous petroleum products(e.g., gasoline, diesel fuel,and oil). 4f these, liquid chlorine and sodium bisulfate pose a public health concern because both chemicals are considered hazardous by EPA, which has strict requirements that must be adhered to regarding their handling, storage, and i use. These chemicals would be regulated under the existing Emergency Response and Contingency Plan(ERCP),which would be amended to reflect these changes in WWTP operations(Gaston Pers. comm.). 1 i Potential Presence of Hazardous 'Waste The existing WWTP generates very small amounts of hazardous waste in the form of used oil,antifreeze,and excess laboratory chemicals. These materials are regularly removed by a licensed hauler. However,as with any property in a developing area that has a long history of human activity, wastes from past activities that were not documented and are unknown could be present onsite. No j known or suspected hazardous waste exists on the existing WWTP site, and no record exists of hazardous materials spills or accidents or the presence of hazardous wastes. The general plan EIR (The Planning Center 1993)does not identify any significant hazards on the site or in the immediate vicinity. i Regulatory Framework i In California, most regulatory requirements relating to wastewater treatment facilities are under the jurisdiction of the RWQCB and DHS. These regulations address three main areas of concern: waste discharge requirements,the disinfection process, and hazardous materials. Waste Discharge Requirements i The RWQCB is responsible for evaluating discharges of treated effluent and issuing waste discharge requirements that are contained in NPDES permits. The permit and associated WDfis specify the conditions under which individual treatment plants can dispose of treated effluent, including long-term compliance schedules and monitoring for water quality improvement. The existing NPDES permit for the City was issued in 1996 and describes the discharge and monitoring conditions for WWTP operations, the groundwater extraction system, and the discharge of groundwater to Marsh Creek(Appendix B). City of Brentwood WWTP Project Chapter 3D. Public health and Safety Draft FIR L}-3 June 26, 199& Disinfection DHS is responsible for enforcing criteria contained in Title 22, Division 4 of the California Code of Regulations,which specifies the level and degree of treatment required for disinfection of pathogenic organisms to ensure that no undue risks to public health result. Title 22 also establishes treatment processes, reliability, and water quality required for the distribution and use of treated effluent for reclamation purposes. These requirements,which are currently being revised by DHS, are intended to protect public health by limiting potential exposure to pathogenic organisms and potential public health effects associated with treated effluent. Hazardous Materials 1 The storage, use, and handling of hazardous materials and wastes are regulated by various federal and state laws that are intended to protect public health and the environment. EPA is the federal agency responsible for enacting and enforcing regulations regarding hazardous materials (40 CFR). These regulations contain specific guidelines for determining whether a substance is a hazardous material or waste, based on the source or properties of the material; the regulations also provide other information about how to handle such materials. EPA has delegated much of its authority to individual states that have adequate regulatory I programs in place. The California Environmental Protection Agency Department of Toxic Substances Control enforces hazardous material and waste regulations in cooperation with EPA. Depending on the circumstances, agencies such as the RWQCB and the BAAQMD may become involved. The Contra Costa County Health Services Division/Hazardous Materials Section (CCCHSD) oversees hazardous material and waste generation activities for facilities owned by the I City. The existing WWTP has been designated as the lowest level of hazardous waste generator by the CCCHSD. Business Plan. California's Hazardous Materials Release Response Plans and Inventory Law of 1985 (the Business flan Act) requires any facility that handles more than 500 pounds of hazardous materials per year to prepare a business plan for emergency response to an actual or potential release of a hazardous material. The business plan must include the following information: • details of the facility, including a map and operational information; e ars inventory of hazardous materials onsite; and I ® an emergency response plan that contains: - procedures for immediate notification of the administering agency and local emergency rescue personnel in the event of an actual or potential accident and - steps to mitigate any potential harmful effects and evacuation of the site. City of Brentwood WWTP Project Chapter 3D. Public Health and Safety Draft Eliz 3D-4 June 26, 1998 I i The business plan.may also include an annual training program for safety procedures and emergency response. 1 j Emergency Response and Contingency Plan. Hazardous substances that are used at the existing WWTP are regulated under the existing ERCP. The plan identifies responsible parties for hazardous materials management at the facility, emergency contacts at local agencies, emergency response equipment, the type and quantity of chemicals stored onsite, and appropriate storage methods (Gaston pers. comm.). The ERCP also includes an emergency action plan that specifies # procedures to minimize health and property hazards in the event of upset conditions, describes emergency response information, and requires written notification of the CCCHSD and the California.Office of Emergency Services in the event of a spill or accident. Air Quality The City has a permit from the BAAQMD to regulate odors at the existing WWTP. The permit stipulates that no more than five confirmed complaints regarding odor can be received in any month; immediate action must be taken to solve the odor problem by the facility if the specified number of complaints is exceeded. No other conditions are stated in the permit. IMPACTS OF THE PROPOSED PROJECT Significance Criteria According to State CEQA Guidelines Appendix G and professional standards, the proposed project would result in a significant impact on public health and safety if it would: I a create a potential public health hazard, including contaminating a public water supply; . a expose people or animals to disease; or I a cause emissions of hazardous substances that would violate applicable regulations intended to protect human health and safety. Impacts and Mitigation Measures Impact: ?discharge of treated effluent to Marsh Creek could result in exposure of the public to pathogenic organisms in treated effluent. This impact is considered less than significant. The public could be exposed to pathogenic organisms in treated effluent through swimming or other recreational contact with Marsh Creek, or through contact with soil or plant materials in or City of Brentwood ifWP Project Chapter 3D, Public Health and Safety Draft BIR .lune 26, 1998 i i near the creek, in the event of a discharge of effluent exceeding NPDES permit limits. This is considered highly unlikely because the proposed treatment processes are highly reliable and would provide a generally effective level of pathogen removal. Additionally,in the unlikely event that the WWTP effluent would exceed coliform limits as a result of upset or failure,the City would be required by the R WQCB to post signs along the creek notifying the public not to go in the water. Therefore, this impact is considered less than significant. Mitigation Measure i No mitigation is required. i i Impact: The proposed VVNWP operations could potentially result in an increase in mosquito populations at the proposed facilities or in Marsh Creek. This impact is considered less than s significant. i The proposed WWTP facilities operations do not include any features that would result in an increase in mosquito populations. Overall,the amount of pond area at the existing WWTP would decrease substantially over the period of facility construction. The discharge to Marsh Creek would not result in an increase in mosquito populations over existing levels during low-flow periods in summer months. Therefore, this impact is considered less than significant. Mitigation Measure No mitigation is required. Impact: The proposed Wt'VTP operations could result in potential exposure of workers and the public to hazardous materials used at the proposed facilities. This impact is considered less than significant. i i Under the proposed project, liquid chlorine and sodium bisulfite may be stored and used at the WWTP for chlorination and dechlorination processes in the event that ultraviolet light disinfection is not used. Thus,the proposed project could increase the risk of potential exposure to hazardous materials in the area. i The chlorination and dechlorination facilities would be located near the proposed chlorine contact basins and filtration area (Figure 2-3). The proposed WWTP at 10 mgd would use approximately 600-700 gallons of chlorine solution per day,which would be stored in two 10,000- gallon cross--linked polyethylene tanks. These tanks would either be constructed in a containment j area or be double contained to prevent accidental release of the liquid in the event of a spill. The sodium bisulfate solution would be used in the same way as the chlorine solution and would be located near the chlorine tanks but in a separate area to avoid accidental mixing of the two solutions. (Skrel pers. comm.) City of Brentwood WWTP Project Chapter 3D. Public Health and Safety Draft EIR 3D-6 June 26, 1998 The risk of accidents involving hazardous materials at the proposed WWTP is minimal because liquid chlorine and sodium bisulfite are much less hazardous than gaseous chlorine and sulfur dioxide, which are commonly used for disinfection; extensive federal and state regulations must be adhered to; and precautions would be taken to prevent such accidents. The increases in use and storage of hazardous materials associated with the proposed WWTP would not substantially increase risk beyond the management level currently in place under the amended ERCP'. The same procedures and safety features identified in the amended ERCP, as well as any additional measures found to be necessary,would be implemented to reduce any increase in risk at the proposed WWTP. Therefore, this impact is considered less than significant. i Mitigation Measure I No mitigation is required. Impact: Construction of the proposed project could result in incidental exposure of workers and the environment to unknown hazardous wastes during construction. This impact is considered significant. j Construction of the proposed project could result in the incidental exposure of workers and the environment to hazardous wastes. No record exists of hazardous materials spills or accidents or the presence of hazardous wastes on the existing WWTP site, and hazardous wastes are unlikely to be encountered during construction of the WWTP. Although this impact is considered unlikely, it is considered significant because unidentified hazardous wastes could be encountered during construction, resulting in a potential public health hazard. Implementing the following mitigation measure would reduce this impact to a less-than-significant level. i i Mitigation Measure Mitigation Measure D-1: Stop work in the area and assess contamination if hazardous materials are encountered. If hazardous wastes are encountered during construction, work in the area shall stop and the City shall asses the nature and extent of the contamination and determine if remediation is necessary. If additional remediation is necessary, the City would prepare a site remediation plan and a health and safety plan. The City would then retain a qualified contractor to clean up the waste in accordance with those plans and applicable state and federal regulations. City of Brentwood WWTP Project Chapter 3D. Public Health and Safety Draft EIR June 2b. I998 3D-7 i f I i i i l E I i I r l City of Rrenhvood WWTP Project Chapter 3D. Public Health and Safety j Draft EIR 3D-8 June 26, 1998 I i i 3 Chapter 3E. it Quality This section describes the setting of the Marsh Creek WWTP project with regard to air quality;specifically,it focuses on the relationship between topography and climate,discusses federal and state ambient air quality standards and existing air quality conditions in the project area, describes the overall regulatory framework for air quality management in California and the region, and identifies sensitive receptors in the project area. The section then identifies impacts of the proposed project and proposes mitigation measures to reduce any significant impacts to a less-than- significant level. SETTING Regional Topography and Climate The concentration of a given pollutant in the atmosphere is determined by the amount of a given pollutant that is released by various sources and the atmosphere's ability to transport and dilute i the pollutant. The major determinants of air pollution transport -nd dilution are wind, atmospheric stability, terrain, and insolation(i.e.,exposure to sunlight). Brentwood is located just south of the Carquinez Strait region of the San Francisco Bay Area { (Bay Area) and east of the Coast Ranges. Prevailing winds in Brentwood are generally from the northwest. During summer and fall, the combination of high barometric pressure offshore and low ' pressure in the Central 'Valley causes marine air to flow eastward through the Carquinez Strait. The wind is strongest in the afternoon, with wind speeds of 15-20 mph being common. The climate in the project area is characterized by warm, dry summers and cool, moist winters. Regulatory Framework Air Quality Management Programs Air pollution control programs were established in California before the enactment of federal requirements. Federal Clean Air Act legislation in the 1970s resulted in a gradual merging of state City of Brentwood WWTP Project Chapter 3E. Air Quality Draft EIR June 2b, 1998 3E-1 and federal air quality programs, particularly those relating to industrial sources. Air quality management programs developed since the late 1980s have generally been responding to requirements established by the federal Clean Air Act. Enactment of the California Clean Air Act in 1988 and the federal Clean Air Act Amendments of 1990 has produced additional changes in the structure and administration of air quality management programs. The California Clean Air Act requires preparation of an air quality attainment plan for any area that violates state air quality standards for carbon monoxide(CO),sulfur dioxide(SO2),nitrogen dioxide (NO2), or ozone. Locally prepared attainment plans are not required for areas that violate the state standards for inhalable particulate matter less than 10 microns in diameter(PM 10). PM 10 attainment issues are being addressed by the California Air Resources Board(ARB). i Air pollution problems in the Bay Area are primarily the result offocally generated emissions. The Bay Area, however, has been identified as a source of ozone precursor emissions. which occasionally contribute to air quality problems in the Monterey Bay area, the northern San Joaquin Valley,and the southern Sacramento Valley. Consequently, in addition to correcting local air pollution problems, air quality planning efforts for the Bay Area must also reduce the area's impact on downwind air basins. In 1991,the BAAQMD released its Clean Air Plan,which was prepared in cooperation with the Association of Bay Area Governments and the Metropolitan Transportation Commission (Bay Area Air Quality Management District 1991). The plan, which was approved by the BAAQMD Board of Directors on October 30, 1991, addressed CO and ozone problems in the Bay Area. The ARB conditionally approved the BAAQMD's plan on April 30, 1992, with the provision that improvements be made to the transportation control measures included in that plan. The BAAQMD plan projected attainment of federal and state CO standards by 1994 for most portions of the Bay Area, although occasional violations of the CO standards were expected to continue in the San Jose and Vallejo areas. The BAAQMD's Clean Air Plan projected continued violations of the state ozone standard beyond 1997,thus classifying the Bay Area as a"severe"ozone nonattainment area. The BAAQMD 1. updated its Clean Air Plan in December 1997 (Bay Area Air Quality Management District 1997a). 1 i Federal and State Ambient Air Quality Standards California and the federal government have each established ambient air quality standards for several pollutants (Table 3E-1). For some pollutants, separate standards have been set for different periods, Most standards have been set to protect public health; however, for some pollutants, standards have been based on other values, such as protection of crops, protection of materials, or avoidance of nuisance conditions. City of Brentwood WR7P Project Chapler 3E. Air Quality Draft EIR 3 E-2 ,June 26, i998 ........................... _.. I E € 'c3 ani ams ami ami t v tz 1 � c G U CS cl 00 y} fJ N ro 'o "u N Lo Ci GJ Q7 di 61 C1 U ya ttt EJ d.1 > as c y cc Y, r%r .?' ami ani ai aXi '.„'C nxi c�i` d d d d r s~ nXi ' 1 aroi aroi v aros C3 "c rou `z ro c y a� � b ro 40 � -C -0roax � � -0 ' E c j < ¢i v v aKi d axi ai d v ctl3i d d chi cQ1s ai � E L a t`'7 d C�7 O ""w d <L .,may- b e� �..� •eC v`, C G, lyjz .0 Lj L cz.� t o o dui c> v � ry o t v L C-4 `C v h - o v Z - 10Z n cli CL ( ; c c � ) t> I t^. � cam€ c < < c { o C� z CY era. i aU v 8) f6 y it2 � L c-4 o d d d o cF Z o Z o o 6 Z Z Z- Z Z Z 2 � u G4 t5D v _� E v7 > > 21 Y co C E Y Y7 cp CS ai Rf ` C4 ccs > ,�,� � .�•, L v c3 cd � - L � e:1 m � cG m T is 0 0 C O t7 cc b G td �_ O 6 O J 0 C t3C! G C .� cc .1 -= '?� 'CJ .0 = G ..0 P' 11%, L .=� �, G r- �. C GJ 119. r � � r� O ao cc oo < - <C c14 < c - cv dc14 <t E cq cv J M E -9 y Y L L ci. nA c � r 3 T C.) � N a CJ U U t � t -5 n E o ro o c c = d z z op u 6/ L oD +z 4i ca u f m cl$ ;-, .0 cz C y 3r'3 The air pollutants of greatest concern in the project area include ozone and PM10. The primary effects of ozone(a component of photochemical smog) include reductions in plant growth and crop yield, chemical deterioration of various materials, irritation of the respiratory system, and eye irritation. PM10 can cause a wide range of pollution effects, including reduced visibility, respiratory irritation, corrosion of structures and materials, and soiling of materials and related economic concerns. a i Existing Air Quality Conditions i Monitoring Data j Data are collected for various pollutants at air quality monitoring stations throughout the region. Not all monitoring stations collect data on all pollutants, and variables such as topography, prevailing wind, and the types of emission sources in the vicinity affect the readings at a particular location. Therefore, the locations of monitoring stations are identified for each pollutant. i PM10. The closest monitoring station for PM10 is located on Grizzly Island. This station has recorded exceedances of the state 24-hour standard for PM 10 (30 micrograms per cubic meter [,Ug/M3]) during the last three years for which data are available (1994-1996) (Table 3E-2). Ozone. The closest ozone monitoring station to the project site is in Pittsburgh. This monitoring station has recorded exceedances of the state ozone standard during the three most recent years for which data are available (1994-1996) (Table 3E-2). Emission Sources i Ozone precursor emissions come primarily from vehicle traffic associated with urban development. A variety of emission sources contribute to PMI O problems in the area, most notably agricultural activities,dust resuspended by vehicle traffic, construction and demolition, and aerosols formed by photochemical smog reactions. Attainment Status The San Francisco Bay Area Air Basin (SFBAAB) includes the City of San Francisco; portions of Sonoma and Solano Counties;and all of San Mateo,Santa Clara,Alameda,Contra Costa, Marin, and Napa Counties. r The SFBAAB is currently classified as a nonattainment area for the state PM10 standards and for the state and federal CO and ozone standards. The SFBAAB is an attainment area for the federal PMI 0 standards and for the state and federal NO2 and SO, standards. City of Brentwood WWTP Project Chapter 3E. Air Quality Draft EIR 3E-4 June 26, 1998 i __ . .._................................................................................................................................................................................................................................. Table 3E-2. Summary of Ozone and PMIO Monitoring Data `'early Monitoring Data Pollutant 1994 1995 1996 Ozone 1st high(ppm) 0.11 0.12 0.12 2nd high(ppm) 0.11 0.12 0.12 Days above standard` 3 8 5 i PM10 j Highest 24-hour concentration(pg/m'). 65 56 76 Geometric mean(p.glm') 14.6 17.2 18.8 I Note: Ozone data based on Pittsburgh monitoring station. PM10 data based on Grizzly Island monitoring station. a Hours above standard=hours above state I-hour standard of 20 ppm. Days above standard=days above state 8-hour standard of 9 ppm. Days above standard=days with hourly concentration above state I-hour standard of 0.09 ppm. Source: California Air Resources Board 1997. 1 1 1 1 3E-5 Although certain portions of the SFBAAB are nonattainment areas for the state CO standard, Contra Costa County (where the project is located) is classified as an attainment area. Also, the BAAQMD, which has primary air quality management responsibilities within the SFBAAB, has j asked EPA to redesignate the entire SFBAAB as an attainment area for CO on the basis of recent monitoring data that show no violations of the federal CO standard for 1994-1996. r Air Quality Permits i The City's WWTP currently operates under an Air Quality Permit to Operate granted by the BAAQMD. That permit,which addresses odors,identifies eight sources of odors and requires that if odorous emissions cause more than five confirmed complaints in any month,the WWTP shall take immediate action to solve the odor problem(Walker pers. comm.). The eight sources of odors are identified by process and facility: wastewater treatment plant, preliminary treatment----headworks, ■ primary treatment—two oxidation ditches, ) flow equalization---emergency holding ponds, secondary treatment—secondary clarifiers, ■ secondary treatment—aeration basin, ■ sludge handling—drying beds, and ■ reclamation—percolation ponds. ; No odor abatement devices are currently required by the BAAQMD's permit. 1 Sensitive Receptors I Few sensitive receptors are located in the immediate vicinity of the WWTP. The closest receptors are isolated residences approximately 0.3 mile south, 0.35 mile east, 0.25 mile west, and 035 mile north of the treatment plants. These receptors are within the 1-mile range for which the i BAAQMD requires preparation of a detailed odor analysis, including investigation of odor complaints. IMPACTS OF THE PROPOSED PROJECT ; Significance Criteria i According to State CEQA Guidelines Appendix G and professional standards, the proposed project would result in a significant impact on air quality if it would: ' City of Brentwood WWTP Project Chapter 3F.. Air Quality Draft EIR 3E-6 June 25, 1998 • violate any ambient air quality standard, contribute substantially to an existing or projected air quality violation, or expose sensitive receptors to substantial pollutant concentrations; ■ generate criteria or noncriteria pollutant emissions exceeding the BAAQMD's emission thresholds contained in its CEQA .Guidelines for Assessing the Air Quality Impacts of Projects and flans (Bay Area Air Quality Management District 1996); or e conflict with the federal Clean Air Act amendments of 1990; the California Clean Air Act of 1988; or federal, state, or local air quality plans, or associated guidance. The BAAQMD's thresholds of significance for project operations equal 80 pounds per day (ppd) or 15 tons per year(tpy) of reactive organic gases (ROG), nitrogen oxide(NO,,), or PM 10. The BAAQMD recommends a two-step process to address odor impacts. The first step is a determination of whether a project represents an odor source and whether sensitive receptors are located within 1 mile. Second, if the proposed project is considered an odor source and sensitive receptors are located within the 1-mile screening distance, a more detailed analysis of possible odor complaints is required. Conformity Determination The proposed project would generate emissions of the ozone precursors, RUG and NO,,, I during construction and operation of the project. These emissions must be evaluated to determine whether they exceed the federal conformity de minimis thresholds applicable in the San Francisco Bay Area Air Basin. The project's RUG and NO,emissions,especially with the proposed mitigation measures in place, would be substantially less than the applicable de minimis thresholds and therefore,the project does not trigger the requirement for an in-depth conformity determination. Impacts and Mitigation Measures Impact: Construction activities would result in a significant increase in PM10 and emissions from construction vehicle exhaust and grading activity. This impact is considered significant. During construction of the W WTP, emissions would be produced by a variety of sources. They include criteria pollutant emissions produced by construction equipment and fugitive dust created by wind and the operation of construction equipment over exposed earth. The BAAQMD's CEQA guidelines do not require that emissions be estimated for construction activities. Instead, specific construction-related mitigation measures must be implemented to minimize dust generation. Consequently, construction-related emissions are not estimated for this project. Because City of Brentwood WWTP Project Chapter 3E. Air Quality Draft EIR June 26, 1998 3E-7 ................................... construction activities would result in a significant increase in PMIO and construction vehicle exhaust emissions, this impact is considered significant. The following mitigation measures are required to reduce this impact to a less-than-significant level. Mitigation Measures Mitigation Measure E-1: Implement dust control measures. The City will implement the following basic control measures to control dust emissions: a. Water all active construction areas daily, or as required. b. Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least 2 feet of freeboard. c. Pave, apply water daily to, or apply (nontoxic) soil stabilizers on, all unpaved access roads, parking areas, and staging areas at construction sites. d. Sweep(with water sweepers)all paved access roads, parking areas, and staging areas at construction sites, as needed. e. Sweep streets (with water sweepers) if soil is visible on adjacent public streets, as needed. f. Hydroseed or apply (nontoxic) soil stabilizers to inactive construction areas (previously graded areas that will be inactive for 10 days or more). g. Enclose, cover, water twice daily to, or apply (nontoxic) soil binders to exposed stockpiles (dirt and sand). li. Limit traffic speeds on unpaved roads to 15 mph. i. Install sandbags or other erosion control measures to prevent silt runoff to public roadways. j. Replant vegetation in disturbed areas as quickly as possible. Mitigation Measure E-2: Implement measures to reduce construction-related emissions. The City will implement the following control measures to reduce construction-related emissions: a. Minimize idling time for construction equipment(e.g., a maximum of 5 minutes). b. Maintain properly tuned equipment. City qfBrenfivood WW7P PrDjeci Chapter 3E. Air Quality Draft EIR 3E-8 June 26, 1998 ...........-................................................................................... ...................... ... ............ Impact: Expansion of the WWTP could result in an increase in odor complaints. This impact i is considered significant. Expansion of the WWTP could result in an increase in odor complaints by adjacent land owners. The primary cause of odors at such facilities is hydrogen sulfide, which is produced by anaerobic compounds in the wastewater collection system or treatment processes at the plant site. Another common cause of odors is un-ionized ammonia, which is prevalent and readily volatilizes (passes off as vapor) whenever the wastewater pH is elevated (i.e.,when the wastewater becomes less acidic). Even though most wastewater treatment odors are caused by hydrogen sulfide, many other compounds can contribute to odors at the plant. The proposed project includes enclosing the screenings facility and providing odor control. The screenings facility is anticipated to be a source of odors. In addition, perception of odor varies according to the individual and the season. 1 The WWTP is located in a rural area surrounded by agricultural uses with a few isolated residences,the closest of which is approximately 0.25 mile from the plant's boundaries. According to BAAQMD records, no odor complaints have been registered with this plant since January 1, 1991 (Walker pets. comm.). An increase in odor complaints is possible because of the increased volume of wastewater that will be treated as the plant expands from 1.4 mgd to 10 mgd. In addition, although the existing plant is surrounded primarily by agricultural users, urban encroachment is possible,and this would bring additional residents closer to the plant's boundaries. This impact is considered significant. The following mitigation measures are required to reduce this impact to a less-than-significant level. Mitigation: measures Mitigation Measure E-3: Maintain an easement around WWTP boundaries. The City shall strive to maintain a minimum 300-foot easementfbuffer around the plant boundaries to prevent urban encroachment of residential housing into the most odor-intensive area surrounding the plant. Such an easement/buffer would reduce the possibility of odor complaints by limiting the number of potential sensitive receptors present within 300 feet of the plant's boundaries. Mitigation Measure E-4: Evaluate odor control measures before construction begins J on each project phase. The need for odor control measures should be evaluated before construction i p begins on each of the four project phases. If operation of the plant during any phase results in an increase in confirmed odor complaints that exceeds the amount allowed by the BAAQMD permit (five per month), the City should identify and resolve the source of the complaint and incorporate appropriate odor control measures into the project. City of Brentwood{t 917P Project Chapter 3E. Air duality Draft EIR June 26, 1998 3E-9 Impact: Implementation of the WWTP project would result in increased emissions of organic compounds. This impact is considered less than significant. Expansion of the WWTP would result in increased emissions of organic compounds because of the increased volume of wastewater treated. The current emissions from the plant are estimated at i ppd of ROO(.Bay Area Air Quality Management District 1997b). Assuming a fivefold increase in treatment capacity and emissions, increasing the City's WWTP from 1.8 to Ifl mgd would increase ROG emissions from 1 to 7 ppd. This increase is below the BAAQMD's significance threshold and, consequently, this impact is considered less than significant. Mitigation Measure No mitigation is required. 1 r 1 i i r t i City of Brentwood WWTP Project Chapter 3E. Air Qualiry Draft FIR 3E-I0 .lune 25, 1998 a i ............................. _.... ..................... Chapter 3F. Land Use, Noise, and Energy This chapter describes the project's effects on land use, noise, and energy and recommends mitigation measures to reduce significant impacts to a less-than-significant level. Information about the project site and vicinity was obtained during site visits, discussions with representatives from the WWTP, and through review of the City's general plan. Impacts related to growth inducement are addressed in Chapter 4, "Other CEQA-Required Analyses". SETTING Land Use The project site is approximately 70 acres and abuts Marsh Creek. T'.le existing WWTP, which was constructed in 1973, includes influent screw pumps, screening, a secondary treatment process using two oxidation ditches,secondary clarifiers,aerobic sludge digesters,and sludge-drying beds with effluent disposal to 13 percolation ponds covering an area of approximately 18 acres. Major land uses surrounding the project site include Sunset Park(a recreational area with baseball fields, picnicking facilities, and open space areas), an apple orchard, an isolated residence to the south., Marsh. Creek and isolated residences to the north and west (along with a pedestrian trail), a solid waste transfer facility and an isolated residence to the east, an agricultural drainage canal east of the waste transfer facility, and an agricultural processing area to the southeast on the other side of the canal. General land uses in the project vicinity include agricultural, residential (along Sellers Avenue), and commercial uses. i Liaise Existing Noise Conditions During the preparation of the City's general plan, a community noise survey was conducted to document noise exposure in areas that have noise-sensitive land uses. Such land uses in the Brentwood General Plan Planning Area include residential areas, parks, and schools. The community noise survey results indicated that typical noise levels in noise-sensitive areas ranged. from 44 decibels(dB)to 53 dB measured as day-night average sound level(LdO. Noise from traffic and neighborhood activities is the controlling factor for background noise levels in the planning area Ciry of Brentwood WWTP Project Chapter 3F. Land Use,Noise,and Energy Draft E1R June 26, 1998 3F-1 (City of Brentwood 1993). Few noise sources are present in the project area primarily roadways, agricultural operations, and the solid waste facility. 1 Sensitive Receptors Some land uses, such as residences and schools; are considered more sensitive to ambient i noise levels than others. However, few sensitive receptors are in the immediate vicinity of the WWTP. The closest receptors are isolated residences approximately 1,600 feet south, 1,500 feet east, 1,320 feet west, and 1,500 feet north of the project area. Energy Natural gas and electrical services are provided to the project site by Pacific Gas and Electric Company (PG&E)using a 21-kilovolt(-kV) line. A 480-volt underground service line serves the existing WWTP. Regulatory Framework The Brentwood general plan is a long-range comprehensive plan that covers all aspects of future growth,development,and conservation within the city. It was adopted by the Brentwood City Council on June 8, 1993. i` The general plan identifies the land use designation for the project area as Public/Semipublic Facilities. This designation provides for public or semipublic facility uses that serve the community �. (e.g., city or school offices, corporation yards, and wastewater treatment facilities). Land use ' designations adjacent to the project area include Urban Reserve,Community Parks,Open Space, and Low-Density Residential ` t The general plan includes land use policies that provide direction for planned growth within the City's planning area. Because the proposed project is consistent with its land use designation and the project only requires constructing new facilities at the existing WWTP site, no policies from the land use element of the general plan relate directly to the proposed project. However, the infrastructure element of the general plan does contain policies that are specific to wastewater 1 treatment within the city. The following general plan policies related to wastewater treatment in the infrastructure element are relevant to the proposed project: 1 ■ Policy 1.1.2. Sizing of Utilities. Through development review,the City shall ensure that utilities are adequately sized to accommodate the proposed development and, if applicable, allow for extensions to future developments. City of Brentwood Wit'TP Project Chapter 3F. Land Use,Noise,and Energy Draft EIR 3F-2 dune 25, 1998 a Policy 1.1.4. Infrastructure Capacity. Existing water and wastewater facilities shall be expanded to accommodate existing and future developments. a Policy 1.1.5. Correct Inadequacies. The City shall develop a plan that establishes priorities and corrects existing inadequacies in the City's infrastructure system. Additionally,cities and counties in California are required to adopt a noise element as part of their general plans. Cities and counties can also adopt noise control requirements within their zoning ordinances or as separate ordinances. The noise element of the general plan establishes guidelines and methods for reducing noise to acceptable levels throughout the city. The following policy from the City's general plan noise element is relevant to the proposed project: a Policy 1.2.5. Construction. Construction activities near sensitive land uses should be limited to the hours of 9:00 a.m. to 7:00 p.m. on weekdays and 8:00 a.m. to 7:00 p.m. on Saturdays. Construction shall be prohibited on Sundays. IMPACTS OF THE PROPOSED PROJECT j Significance Criteria According to State CEQA Guidelines Appendix G and professional standards, the proposed project would result in significant impacts on land use, noise, or energy if it would: 1 a result in the substantial alteration of the present or planned land uses in an area; 8 conflict with adopted environmental plans and goals of the community where it is located; j in conflict with established recreational, educational, religious, or scientific uses of the { area; s e conflict with local general plans, community plans, or zoning designations; E create land uses that are incompatible with existing or planned land uses or that are inconsistent with community goals; 11 increase substantially the ambient noise levels for adjoining areas; n expose people to severely elevated noise levels; a use fuel, water, or energy in a wasteful manner; City of Brentwood WbiTP Project Chapter 3F Land Use,Noise,and Energy Draft EIR June 26t 1998 encourage activities that would result in the use of large amounts of fuel, water, or energy; or i 0 require electrical service that is not able to be provided to the project site_ Land Use Impacts and Mitigation Measures l Impact: The proposed project would not result in the development of land for uses that are incompatible with adjacent land uses. This impact is considered less than significant. i The modifications proposed for the existing WWTP,such as constructing the oxidation ditch f treatment trains and discharging treated effluent to Marsh Creek,are considered compatible with the adjacent land uses. The proposed project does not require acquisition of any new land for the expansion of the WWTP;therefore, the existing footprint of the facility would not be modified and ; no changes to the facility would be apparent from the adjacent properties. Direct effluent discharge to Marsh Creels would not affect recreational opportunities along the creek or impede any existing f uses of the pedestrian trail. impacts related to increased mosquito production and odors are analyzed in Chapter 317, "Public Health and Safety". Additionally,impacts related to growth inducement are t addressed in Chapter 4,"Other CEQA-Required Analyses". Therefore,this impact is considered less than significant. Mitigation Measure No mitigation is required. I Impact: The proposed project would be consistent with the City's general plan land use designation. This impact is considered less than significant. The land use designation of the proposed project site is Public/Semipublic Facilities. Under this land use designation, the WWTP is an acceptable land use and the project does not involve acquiring any new land for the proposed modifications to the existing facilities. Therefore, this impact is considered less than significant, Mitigation Measure No mitigation is required. i i City of Brentivood WWrP Project Chapter 3F. Land Ljse,Norse,and Energy Draft E1R June 26, 1998 3F-4 i ............................................................................................................................................................................................................................................................................................................................ Impact: The proposed project would be consistent with wastewater policies in the City's general plan. This impact is considered less than significant. The proposed project is consistent with the policies in the Brentwood general plan. The expansion of the treatment capacity would allow the City to accommodate future growth (Infrastructure Element Policies 1.1.2 and 1.1.4) and the City has prepared a wastewater facilities plan that addresses expanding the treatment capacity of the WWTP (Infrastructure Element Policy 1.1.5). Therefore, this impact is considered less than significant. Mitigation Measure No mitigation is required. i Noise Impacts and Mitigation Measures Impact: Construction of the proposed project could result in short-term increases in noise levels. This impact is considered less than significant. Noise levels could temporarily increase during construction activities, such as earthmoving to construct the oxidation ditch treatment trains;however, there are few sensitive receptors in the project area. The closest sensitive receptor is 1,324 feet from the property line of the project site. The sound level for sensitive receptors located 1,000-2,000 ft from construction activities is estimated to be between 64 A-weighted decibels(dBA) and 57 dBA. The City's general plan(City of Brentwood 1993)requires that noise-sensitive areas be protected from exposure to excessive noise by limiting;the hours of construction activities to the periods from 9 a.m. to 7 p.m. on weekdays, and 8 a.m. to 7 p.m. on Saturdays, and prohibiting construction activities on Sundays(construction of all phases would be subject to this general plan policy, so future sensitive receptors that could be located closer to the project site would be protected from excessive noise). Additional measures to reduce noise exposure may include requiring construction equipment, corepressors, and generators to be fitted with heavy-duty mufflers. Because construction activities would be temporary, the closest sensitive receptor is approximately 1,350 feet from the property line of the project site, and construction would be in accordance with the City's general plan policies, this impact is less than significant. Mitigations Measure No mitigation is required. City of Brentwood WPTP Project Chapter 3F Land Use,Noise.and Energy Draft EIR June 26, 1998 Impact: Proposed project operation could result in minimal changes in noise. This impact is considered less than significant. The aerators are generally the loudest piece of equipment at a WWTP and are used 24-hours a day. Noise levels generated by the aerators were evaluated because they represent the worst case scenario for the proposed WWTP noise generation. Each oxidation ditch at the existing WWTP includes two 40-hp brush aerators. The proposed WWTP will include two 100-hp submerged $ aerators for each oxidation ditch(the entire project would include eight aerators at the completion of the project). A 100-hp submerged aerator pump produces a noise level of 75 dBA at 3 feet. Other noise associated with the submerged aerator pump would include sound from water splashing and from the aerator itself The combined noise level of the submerged aerator pump, splashing water, and aerator at a distance of 3 feet is 80-85 dBA (Vestey pers. comm.). For the WWTP to operate at an acceptable noise level (less than 65 dBA) sensitive receptors could be located no closer than 48 feet from the WWTP. Because the closest sensitive receptor is located approximately 1,350 feet from the WWTP and future sensitive receptors would not be located within 50 feet of the treatment plant, this impact is considered less than significant. Mitigation Measure No mitigation is required. Energy Impacts and Mitigation Measures i Impact: The proposed project would result in an increase in fuel and gas consumption, but the energy use would not be excessive or wasteful. This impact is considered significant. r Construction of the proposed project would result in an increase in fuel use. Construction activities, such as grading and excavation, would require the use of fuel for operating heavy equipment. Because of modem construction practices, fuel consumed during construction activities would not be used in a wasteful manner. Operation of the proposed project, such as the oxidation ditch treatment trains and the point of discharge for treated effluent to Marsh Creek, also would result in the use of electricity and fuel consumed by motor vehicles and power-generating equipment. The pumps required for the influent pumps, screens, oxidation ditches, secondary clarifiers, tertiary filtration, disinfection facilities and sludge dewatering would use electricity. Activities associated with sludge disposal and maintenance of the treatment facility would use heavy equipment, resulting in fuel use. At the completion of Phase I the WWTP is estimated to consume 3.5 million kWh of electricity annually, increasing to 8.9 million kWh at the completion of Phase 4. PG&E has indicated that the increased level of service could be provided to the project site; however, the City would need to provide additional information to PG&E before construction of each project phase City of Brentwood WWTP Project Chapter 3F. Land Use,Noise,and Energy Draft EIR June 26, 1998 i (Lau pers.comm.). Because PG&E would need additional information regarding proposed electrical usage for the proposed project, this impact is considered significant. The following mitigation measure is required to reduce this impact to a less-than-significant level. Mitigation Measure l-1: Coordinate with PG&E. The City will coordinate with PG&E during the predesign for each phase of the project to allow PG&E adequate time to assess the incremental electrical service requirements of the project. I f City of&rent}vood WWTP Project Chapter 3,F. Land Use,Noise,and Energy Draft EIR June 16, 1998 1 i i i r r I 1 i Citi of Brentwood Wtir7P Project Chapter 3F Land Use,Noise.and Energy Draft EIR 3F-8 June 26, 1998 .. ......... ......... ............................................................................................................................................................................................................................................................................................................................ t Chapter 3G. Transportation, f Information about the transportation system in the project area was obtained through site visits,discussions with representatives from the WWTP, and review of the City's general plan EIR. (The Planning Center 1993) and the ISD EIR(Ironhouse Sanitary District 1994). SETTING 1 The project site is reached by traveling along State Highway 4 to Sunset Road and Tresch Avenue. The following provides a description of each roadway that provides access to the project site. State Highway 4, located west of the project site, provides access through Brentwood and is called Brentwood Boulevard within the city limits. The non-freeway portion of this state highway extends north-south through Brentwood and passes directly through downtown.Brentwood. It is a two-lane facility north of the downtown area with several intersections. Closer to the downtown area, it becomes a four-lane highway, and south and east of the downtown area it is a two-lane rural highway. State Highway 4 is also the main truck route through eastern Contra Costa County. (The Planning Center 1993). Much of the traffic passim through. Brentwood uses State Highway 4 to travel east-west and uses Lone Tree Way (west of the project site), Fairview Avenue (west of the project site),Balfour Road(south of the project site), and Walnut Boulevard (south of the project site) to travel north-south (The Planning Center 1993). The project site is currently served by Sunset Road, a collector street from Brentwood Boulevard that runs east toward Sunset Park. The WWTP is on Tresch Road, which is approximately 0.25 mile east of Brentwood Boulevard off Sunset Road. Regulatory Framework Although the City's general plan includes policies related to traffic and circulation, none of these policies apply directly to the proposed project. City of Brentwood WWTP Project Chapter 3G. Transportation Draft EIR June 26, 1998 3G-1 ............. ............... IMPACTS OF THE PROPOSED PROJECT Significance Criteria According to Appendix G of the State CEQA-Guidelines and professional standards, the proposed project would result in a significant impact on transportation if it would: • cause an increase in traffic that is substantial in relation to the existing traffic load and capacity of the street system or • interfere with emergency response plans or emergency evacuation plans. Impacts and Mitigation Measures Impact: Construction of the proposed project would result in a short-term increase in truck traffic on roadways that serve the project site. This impact is considered less than significant. The proposed project would not result in a substantial increase in vehicle trips or traffic congestion because associated construction and maintenance activities would not substantially increase vehicle trips beyond existing traffic levels on roads in the project area. Although each phase of project construction is estimated to take 1.5-2 years,most of the equipment used for construction would be brought to the project site at the beginning of each phase. The daily volume of construction-related traffic at the site would vary over the construction period; construction is expected to generate an average of 5-10 truck trips per day. This increase in traffic would be imperceptible and would be within the range of daily traffic fluctuations in the project area. Therefore, this impact is considered less than significant. Mitigation Measure No mitigation is required. Impact: Operation of the proposed WWTP would result in an increase in employee and delivery traffic on area roadways. This impact is considered less than significant. Operation of the proposed project is expected to result in an increase in the number of onsite workers at the project site. At full expansion of the WWTP (to 10 mgd of treatment capacity), approximately nine workers would be onsite, compared to the four workers at the existing facility. Additionally,because the proposed project includes plans to expand the treatment capacity from 1.8 mgd to 10 mod, additional truck trips to deliver chemicals and remove trash and sludge would be City OJIBrentwood WWTP.Projecr Chapter 3G. Transportation D,-aft EIR 3G-2 June 26, 1998 ......................................................................I................................................................................................................................ required. When treatment capacity is 3.3-4.3 mgd, one truck per day would be required to remove sludge from the project site; two trucks would be required when the WWTP has reached full treatment capacity (10 mgd). Chemical deliveries to the project site would take place approximately four to eight times a i month. The additional vehicles entering the project site would continue to use Tresch Avenue. The impact of these additional vehicle trips on the project site would be less than significant because of their limited frequency and minimal contribution to the existing load and capacity of the street system in and around Brentwood. Mitigation Measure No mitigation is required. 1 i City of Brennvood WWTP Project Chapter 3G. Transportation Draft EIR June 26, 1998 3G-3 City of Brentwood WWTP Project Chapter 3G. Transportation Draft EIR 3G-4 June 26, i 998 .............................................................. ....... ............................ .................. ................. ........... 4 3 Chapter 3H. Cultural Resources The analysis in this chapter has been prepared to comply with CEQA and also with Section 106 of the National Historic Preservation Act and its implementing regulations because of the possibility that this project may receive federal funding in the form of an SRP' loan from the SWRCB. SETTING Prehistoric Resources This section provides a brief overview of the changing adaptive strategies used by the prehistoric inhabitants of the Central Valley and the archaeological manifestations of these changes. A more comprehensive and in-depth survey of the prehistory of this area is presented in the cultural resources inventory report (Jones & Stokes Associates in prep.). 4 4 Although little archaeological evidence exists of human use of the area during the late Pleistocene and early Holocene Epochs (12,000-6000 B.C.), this is likely a product of the archaeological record itself,rather than an indication of the lack of use of this area. Most sites from the Pleistocene and Holocene Epochs are deeply buried in accumulated gravels and silts or have eroded away. The period from 6000 B.C. to 2000 B.C. is referred to as the Early Horizon. During this time, a generalized subsistence strategy is thought to have been replaced by a more specialized strategy. This intensification can be seen in what Fredrickson (1973). has identified as the Windmiller Pattern. Artifact assemblages and faunal remains at Windmiller Pattern sites indicate that the range of resources being exploited was diverse,including seeds,varieties of small game, and fish. The Middle Horizon dates from approximately 2000 B.C.to A.D. 500. Sites from this period have also been found in the Central Valley. The adaptive pattern that is found most frequently during this period is called the Berkeley Pattern (Fredrickson 1973), although sites displaying Windmiller Pattern assemblages have also been dated to the Middle Horizon.. The Berkeley Pattern differs from the Windmiller Pattern primarily in the increased use of the acorn as a staple. This is reflected in the more numerous and varied mortars and pestles. This complex is also noted for its especially well-developed bone industry and such technological innovations as ribbon flaking of City of Brentwood WWl P Project Chapter 3H. Cultural Resources Draft EIR June 26, 1998 3H-1 chipped stone artifacts. During this period, flexed burials replaced extended burials and the use of grave goods generally declined (Moratto 1984). i The period between A.D. 500 and the arrival of the Spanish explorers in central California has been named the Late Horizon. The predominant pattern during this period,the Augustine Pattern (Fredrickson 1973), is characterized by large village sites, increasing evidence of acorn and nut processing, the introduction and use of the bow and arrow, and the use of clam shell disc beads as the primary medium of exchange. During the last part of the period, cremation became a common mortuary practice. Ethnographic Background The earliest known inhabitants of the project area were the Eastern Miwok. This ethnographic context.is based primarily on Richard Levy's chapter in Volume 8 of R. F. Heizer's Handbook of North American Indians (1978). Except where otherwise noted, information in this section has been taken from this source. Five languages have been assigned to the three distinct groups of the Eastern Miwok (Bay, Plains, and Sierra Miwok), all belonging to the Utian language family. The Bay Miwok occupied the eastern portions of what is now Contra Costa County, from Mount Diablo northeast into the Delta. The Plains Miwok inhabited the lower reaches of the Mokelumne and Cosumnes Rivers and the banks of the Sacramento River from Rio Vista to Freeport. The Sierra Miwok inhabited the foothills and higher mountains of the Sierra Nevada. The project area is located in what was once Bay Miwok territory. The primary political unit was the tribelet. Composed of several fairly permanent settlements and numerous seasonally occupied camps, the tribelet was an independent, sovereign nation that defined and defended its territory. The basic subsistence strategy of the Eastern Miwok was seasonally mobile hunting and gathering. Acorns and other seeds served as storable staples, and other vegetal foods were gathered seasonally. Large and small garne obtained with bow and arrow, j traps, and snares supplemented the diet, along with fish and shellfish. Salt was obtained from springs or through trade with people of the Mono Lake area. Miwok technology included bone, stone, antler, wood, and textile tools. Basketry items included seed beaters, cradles, sifters, and rackets used in ball games; baskets were used for storage, winnowing, parching, and carrying burdens. Other textiles included mats and cordage. The Eastern Miwok constructed four types of structures. Conical structures of bark were used in the mountains, whereas those of tule matting were used more commonly in the lower elevations of the central Sierra Nevada. Thatched structures provided shelter at lower elevations. Semi-subterranean,earth-covered dwellings served as winter homes. Also within the typical Miwok settlement were acorn granaries, menstrual huts, sweathouses, conical grinding huts that enclosed bedrock mortars, and two types of assembly houses. Large, semi-subterranean structures were the City ofBrentwood W477P Project Chapter 3H. Cultural Resources Draft EIR 3I3-2 June?b, 1998 I focal points of ritual and social gatherings. Circular brush structures were used for mourning ceremonies in summer months. The Eastern Miwok first carne into contact with Europeans in the second half of the 18th century, when Spanish explorers entered the area. The Bay Miwok were the first to be affected by missionaries. The first baptisms took place in 1794 and the last in 1827. Converts were taken to the Mission San Francisco and the Mission San,Tose. Many Bay and Plains Miwok tribelets apparently disappeared as a result of the combined effects of population removal to the missions and epidemics. New converts(neophytes)who ran away from the missions were pursued by military expeditions. The Miwok initially hid but eventually began to fight back. Militarism grew in the 1820s and 1830s, particularly among the Plains Miwok. With the incursion of trappers, gold miners, and settlers into the area, the Miwok were exposed to new diseases. Although this early contact with settlers was profoundly damaging to the Miwok population, as a result of both disease and violent actions,the Miwok people have survived and still maintain strong communities and action-oriented organization. Historical Context Early Exploration and Settlement The first European groups to enter Contra Costa County were the Pedro Fages exploration party in March 1772 and Juan Bautista de Anza's exploration party in spring 1776. The area was first settled by Mexican.citizens who applied for land grants and established ranches in the area. The earliest land grants in the area were awarded in 1833. Early ranchos in the area were Rancho El Sobrante de San Ramon (granted 1833); Rancho San Pablo (granted 1834); Rancho San Ramon (granted 1834-1835); Rancho Monte del Diablo (granted 1834); Rancho Los Meganos (granted 1835); and Canada de los Vaqueros (granted 1844) (Beck and Haase 1974). Brentwood lies on the edge of the Los Meganos land grant, granted to Jose Noriega in 1834. In 1837, he sold his ranch to John Marsh, a Harvard graduate who was licensed by Mexican authorities to practice medicine (Hoover et al. 1990). Marsh was notoriously tight fisted and was ultimately murdered in 1856 by three young Californios(Mexican settlers). The town of Brentwood, named for Marsh's ancestral home in Essex, England, was established in 1878 along the Southern Pacific Railroad line, 4 miles northeast of Marsh's home. His home is now within the Stone House State Historic Park (Hoover et al. 1990). Agriculture Stock raising was the main economic pursuit of residents in the area during the Mexican period. Because of the relatively sparse and scattered population and the poor transportation system, commercial agriculture was not economically feasible during this period in most locales. ranchos were not fenced; cattle and other stock roamed at will, and stock from neighboring rancheros City of Brentwood WWTP Project Chapter 3H. Cultural Resources Draft EER June 26, 1998 3H-3 intermixed. At least once a year, a rodeo was held and each ranchero herded his own stock back to his land. (Sonoma State University Academic Foundation, Inc. 1992.) During the Mexican period,cattle were raised primarily for the hide and tallow trade because there was no market for large quantities of beef. An increase in population density, primarily as a result of the California Gold Rush of 1849, created a demand for meat and other animal products, and the orientation of ranchers changed dramatically during the 1850s and 1860s. Breed and range improvements followed shortly thereafter. Many ranchers began dairy ranching, growing crops,and raising other livestock such as sheep and chickens. Agriculture became an important pursuit in this area and has remained a principal industry in the area into modern times. r' Mining Although Contra Costa County is not in"Gold Country", it was affected by the California Gold Rush. Miners passed through the area and took supplies from the fertile land. Other aspects of mining had a more direct effect on the project area, however. Coal was discovered as early as 1848,south of the towns of Antioch and Pittsburgh. In 1855, George W. Hawxhurst settled at the future site of the town of Somersville and, while prospecting for coal, he discovered the Union vein in March 1855. In December 1859, Somers and Cruikshank discovered the Black Diamond vein. Mines opened in the area included the Black Diamond, Cumberland, Mount Hope, Empire, and Central Mines. (Hoover et al. 1990.) The mining of coal also led to transportation advances. Railroads were built to the mouth of the San Joaquin River to facilitate exportation. Additionally, towns (e.g., Nortonville, Somersville, Stewartsville, Empire, West Hartley,and Judsonville) sprung up in the area to house and supply the miners. These towns were populated by miners, including a substantial number of immigrants from the coal fields of Wales and Cornwall. (Hoover et al. 1990.) Sand was also mined in the area. Between 1920 and 1949, high-quality sand was mined at Somersville. (Hoover et al. 1990.) Twentieth Century A turning point for Brentwood took place in October I900, when Balfour, Guthrie and Company, a group of Scottish inventors, bought out the owners of Rancho las Meganos (Emanuels 1986). Within the next few decades, they built a first-class hotel and underwrote the Bank of Brentwood and the town's domestic water and sewer systems. They also operated irrigated farms on thousands of acres of the surrounding land. They sold off this land in 15- to 20-acre parcels and smaller allotments intended for use as homesites. By 1930, thousands of acres of fruit orchards were yielding apricots, peaches, and cherries. During the Great Depression, the Brentwood area attracted many migrants seeking work harvesting I i City of Brentwood WWTP Project Chapter 3H. Cultural Resources Draft EIR 3H-4June 16, J998 .................................................................................................................................................................................................... i crops. Brentwood was the scene of pickets organized by the Cannery and Agriculture Independent Workers Union(Emanuels 1986). i Since World War II, the Brentwood area continues to be primarily agricultural,although the amount of rural land has decreased as the overall population of nearby cities and towns has increased. The Brentwood WWIP was originally constructed in the early to middle 1940s and included a clarifier that still is on the project site. The facility has been upgraded and expanded numerous times(Gaston pers. comm.). The facility as it exists today was constructed in 1973 (Montgomery Watson 1997a)and consists of influent screw pumps, screening and secondary treatment using two oxidation ditches, secondary clarification, aerobic sludge digestion, and sludge-drying beds with effluent disposal to 13 percolation ponds. i Regulatory Framework State Regulations CEQA requires that a public agency proposing to finance or appro'v a public or private project must assess the effects of the project on cultural resources. Cultural resources are defined as buildings, sites, structures, or objects, each of which may have historical, architectural, archaeological, cultural, or scientific importance. CEQA states that if a project results in significant effects on important cultural resources, then alternative plans or mitigation measures must be considered, however, only important cultural resources need to be addressed. Therefore, before mitigation measures can be developed, the j importance of cultural resources must first be determined. Federal Regulations This analysis has been prepared in compliance with Section 106 of the National Historic Preservation Act (NHPA) and its implementing regulations because the City may receive federal funding(e.g., an SRF loan) for the proposed project. Section 106 requires federal agencies, or those state or local agencies they fund or permit, to consider the effects of their actions on properties that may be eligible for listing or are listed in the National Register of Historic Places (INRHP'). To determine whether an undertaking could affect NRHP-eligible properties, cultural resources (including archaeological, historical, and architectural properties)must be inventoried and evaluated for their eligibility for listing in the NRNP. Although compliance with Section 106 is the responsibility of the lead federal agency,the work necessary to comply can be undertaken by others. The Section 106 review process involves a five-step procedure: City of Brentwood WWTP Project Chapter 3H. Cultural Resources Draft EIR June?6, 1998 3H-5 m identify and evaluate historic properties, s assess the effects of the undertaking on properties that are eligible for inclusion in the NRHP, ■ consult with the State Historic Preservation.Officer (SHPO) and other agencies to develop an agreement that addresses the treatment of historic properties, ■ receive comments from the Advisory Council on Historic Preservation on the agreement or the results of consultation, and IN proceed with the project according to the conditions of the agreement. METHODS AND RESULTS OF ANALYSIS This section describes the methods used to conduct the analysis for cultural resources for the proposed project and presents the results of the analysis, which are used to determine potential cultural resources effects resulting from project implementation. Prefield Research A records search was conducted at the Northwest Information Center of the California Historical Resources information System, located at Sonoma State University in Rohnert Park. For this records search, the information center's records of previous studies and previously recorded cultural resource sites were consulted, and those sites located within a 0.25-mile radius of the WWTP were noted. Also consulted were the following historic inventories and resources: the National Register of Historic Places, the California inventory of Historic Resources, California Historical Landmarks, California Points of Historical Interest (California Department of Parks and Recreation 1992), the Historic Properties Directory, historic maps, and Government Land Office plats (all on file with the information center). The records search indicated that no previous studies have been conducted in the project area, and four previous studies have taken place within a 0.25-mile radius_ These studies include surveys conducted by the U.S. Bureau of Reclamation (1983), Smith and Baker(1989), Busby (1995), and the inventory conducted in conjunction with the Los Vaqueros Project (Bramlette et al. 1991). No previously recorded cultural resource sites were located in or within a 0.25-mile radius of the project area. The historical inventories and historic maps consulted indicated no historic cultural resources in or within a 0.25-mile radius of the project area. i City of Brennvood WWTP Project Chapter 3H. Cultural Resources Draft EIR 314-6 June 26, 1998 ........ ....... ___.... ... ......................................................................................................................................... ............................................................................................ ....... . ........................................ .................................................................................................................................................................. Native American Consultation The Native American Heritage Commission (NAHC) was consulted regarding Native American consultation for this project. The NAHC supplied a list of 11 potential representatives. i On February 13, 1998, Jones & Stokes Associates sent letters to all 11 Native American representatives requesting their comments and concerns regarding this project. As of March 3, 1998, none have responded. j Field Survey 'I Because the project area had not been previously surveyed for cultural resources, a survey was conducted by two Jones & Stokes Associates archaeologists in February 1998. The area was examined using intensive survey techniques on the periphery of the WWTP(Figure 3H-1). This area was surveyed using transects not more than 10 meters apart. The interior areas of the facility were given cursory coverage because much of the land was covered with buildings,structures,and settling ponds. In all cases, visibility was low because of vegetation, standing water, and development. No cultural resources were located as a result of this survey. Known Resources The only known historic resource in the project area is the clarifier dating to the mid-1940s (Gaston Pers. comm.), which was noted during a site visit before the survey. The smaller of the two j clarifiers present at the site, it is similar to the more modern unit located immediately to the south. It is a two-story circular structure with metal access stairs on the north side. Over the years, the interior parts of the clarifier have been replaced and a new catwalk has been added (Gaston pers. comm.). The clarifier has been evaluated as a cultural resource and determined not to be eligible for listing in the NRHP(Jones& Stokes Associates in prep.). It does not meet the criteria for listing and lacks integrity within its original context(i.e.,the 1940s WWTP). No other known cultural resources exist within the project area. City of Brentwood WWTP Project Chapter 3H. Cultural Resources Draft EIR .lune 16, 1998 3H-7 E-2 Discharge to Marsh Creek Creek Groundwater Extractioz 1 Systema #5 I #6 Emergency Disposal #4� Pond N #3 V #2 Existing Disposal #7 �✓ Ponds #8 Emergency #� Disposal Pond 0 175 350 Existing WWTP Facilities Scale in Feetj 1940s Clarifier #9 12"Culvert Existing Sludge Holding Pond #10 Disposal Emergency Pond HPo'dg ,to Discharge 1GMarsh Greek --- Property Line t #13 Disposal Solid j Pond Waste Facility Legend I Intensive Survey Coverage i Berm i I�Cursory Survey Coverage I 1� L JI(within Property Bounday) I _ Sunset Park I s ffff i Jones&Stokes Associates, inc. Figure 311-1 CZA Cultural Resources Survey Coverage 3H-8 _._.._..........._.................................................................... __ IMPACTS AND MITIGATION MEASURES i Significance Criteria l According to Appendix K of the State CEQA Guidelines and federal criteria for cultural resource significance established in the NHPA,the proposed project would result in a significant j impact on cultural resources if it would: ■ result in damage to or destruction of significant prehistoric sites or artifacts or i ■ result in damage to or destruction of historical structures,features,artifacts, landscaping, or sites that would meet CEQA or federal criteria for significance. i Impact: The project could result in damage to currently unknown cultural resources. This impact is considered significant. Unknown cultural resources may be located within the project area. Field surveys can locate only those cultural resources with an aboveground component. Cultural resources may be buried under alluvial sediments, however, and may not be locatable by surface inspection alone. Additionally, limitations of surface visibility may prevent the discovery of some cultural resources. i Construction or operation of the proposed project could result in the discovery of previously unknown cultural resources; therefore, this impact is considered significant. The following tf mitigation measure would reduce this impact to a less-than-significant level. j Mitigation Measure Mitigation Measure H-1: Stop work in the area if cultural resources are unearthed. If buried cultural materials are unearthed during project construction,work must halt in the vicinity of the find until a qualified archaeologist can assess its significance. If human remains are unearthed during construction, no further disturbance shall occur until the County Coroner has made.the necessary findings regarding origin and disposition as required by California Public Resources Code Section 5097.98. City of Brentwood WWTP Project Chapter 3H. Cultural Resources Draft DIR June 2G, 1998 31-1-9 Jai j i i� iI t i { 1 i 1 i City of Brentwood WWTP Project Chapter 3H. Cultural Resources Draft EIR 3H-14 ,Ione 26, 1998 i i I Chapter 4, Other CEQA-Required Analyses This chapter includes discussions on the following subjects as required by CEQA: � any significant irreversible environmental changes that would be involved in the proposed action, should it be implemented; a any unavoidable significant impacts; j a growth-inducing impacts of the proposed project; and a cumulative impacts. SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES i Section 15126(f) of the State CEQA Guidelines provides the following direction for the discussion of irreversible changes: Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvements which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to ensure that current consumption is justified. Determining whether the proposed project would result in significant irreversible effects requires a determination of whether key resources would be degraded or destroyed with little possibility of restoration. The proposed project would not result in the conversion of existing land uses or important resources because the proposed WWTP would be constructed within the footprint of the existing facilities. and expanded public facilities would be consistent with current uses of the site. The proposed project could result in the conversion of approximately 1-5 acres of ruderal-annual grassland habitat. City of Brentwood WWTP Project Chapter 4. Other CEQA-Required Analyses Draft 1IR June 2S, 1998 4-1 i Implementation of the project would also result in an irreversible commitment of energy ' resources, primarily in the form of fossil fuels (e.g., fuel, oil, natural gas, and gasoline) for construction equipment. The consumption or destruction of a relatively small amount of other nonrenewable and slowly renewable resources (e.g., gravel,asphalt, metals, and water)would also result from construction and operation of the proposed project. SIGNIFICANT AND UNAVOIDABLE IMPACTS The proposed project would have no significant and unavoidable impacts. All of the direct impacts identified in this EIR could be mitigated to a less-than-significant level through implementation of the recommended mitigation measures. GROWTH-INDUCING IMPACTS Section 15126(g) of the State CEQA Guidelines provides the following guidance on the discussion of a project's growth-inducing impacts: i Discuss ways in which a proposed project could foster economic or population growth,or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth(a major expansion of a wastewater treatment plant might, for example, allow for more construction in service areas). Increases in the population may further tax existing community service facilities, so consideration must be given to this impact. Also discuss the characteristics of some projects which may encourage and facilitate other activities that could significantly affect the environment,either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment. 1 Relationship of the Proposed Project to Growth j The City's general plan contains a policy to expand wastewater treatment facilities to accommodate existing and future growth. The City recognizes that the proposed WWTP expansion would remove one barrier to growth and that several other factors affect the magnitude, timing, and type of economic and population growth: local government planning, economic climate, quality of life, and availability of public services and natural resources. Each of these factors and its role in determining growth rates are discussed below. Ciof Rrent:vooc�t#N TP Project Chapter 4. Other CEQ1'-Required Analyses Draft EIR 4-2 Jane 26, 1998 ............................................................................................................................................... ............................................................................................................................................................................................................................................................................................................................ Local Planning Local planning is performed primarily by county and city government agencies,which adopt and administer general and specific plans, zoning maps and ordinances, and other planning documents. General and specific plans contain policies and maps that specify the areas where development will be allowed and those areas that will be preserved in a relatively undeveloped state. For each area where development will be allowed, the plans identify the intensity and type of development. Areas to remain undeveloped are categorized according to the types of uses to be permitted, such as open space, agriculture, and recreation. After a planning document is developed,an EIR is prepared to assess the overall impacts of the growth that would be allowed consistent with the plan. Local jurisdictions also may periodically amend their plans to more closely reflect their changing needs. As with the initial adoption of the local plan, each amendment is subject to environmental review. Another entity that is typically involved in amending local planning documents is the local agency formation commission(LAFCO). Each county has a LAFCO,the key role of which is to set the boundaries of the spheres of influence for cities and other local jurisdictions. These boundaries prescribe the future directions in which the jurisdiction's development will expand. Spheres of influence,are established based on various planning criteria,such as geophysical, infrastructure, and land use constraints. LAFCOs also play a key role in the approval process for proposals by local jurisdictions to annex additional land. Economic Climate Although local governments and LAFCOs define the type, magnitude, and location of allowed growth, the timing of development depends on economic factors such as the cost of developable land,the health of the local economy,the cost of capital,the demand for housing, and the anticipated return on investments. Quality of Life Many factors combine to create an area's perceived quality of life. Generally, these factors include the crime rate; the proximity of cultural and recreational activities; climate and air quality; the availability and variety of leisure activities and lifestyles of residents; traffic congestion and commuting distances, and the availability, cost, and quality of community services, including schools, transportation facilities,recreational facilities, and police and fire protection. Regions with a high quality of life would be expected toattract more new businesses and residents than other areas. City of Brentwood WWTP Project Chapter 4. Other CEQA-Required Analyses Draft EIR 4-3 June 26. 1998 Availability of Public Services and Natural Resources Public services and natural resources that affect economic and population growth include developable land, water supply and infrastructure, wastewater treatment facilities, and energy availability and cost. Without these, development cannot occur. The configurations of utility systems,such as water and wastewater systems, are usually identified in master plans prepared by i utility providers. The service area boundaries and system configurations ostensibly present constraints to new development. However,state laws mandate that local utilities must extend service to new development. Also, economic and political pressures that influence local government development decisions can potentially overwhelm concerns regarding infrastructure constraints. Therefore, although utility providers develop master plans for their service areas, the ultimate configurations of their systems are heavily dependent on local government decisions. Growth-Inducement Analysis The growth-inducement analysis relies on and tiers off of the analysis of growth inducement and cumulative impacts that was conducted for the City's general plan EIR(The Planning Center 1993). The City's general plan EIR addresses the regional growth effects of buildout within the Brentwood planning area. Implementation of the proposed project by the City would remove one barrier to growth that is needed to achieve buildout of the City's planning area and growth beyond the area. Therefore, this analysis summarizes the types of growth-related impacts that project implementation would facilitate. Because phased construction of the W WTP expansion to 10 mgd is ultimately expected to accommodate population growth beyond the levels assumed in the City's general plan, consideration of the growth effects beyond a population of 79,574 is included in this section. Discussion of growth effects beyond the City's general plan horizon of 2017 is highly speculative, however. Growth in Brentwood would result in the conversion of existing undeveloped and agricultural land to urban uses. This conversion would contribute to the overall urban development of the area and would change the visual resources of the city. Conversion of land used for agriculture to nonagricultural uses would result in a decline in crop production, an increase in conflicts between urban and rural uses, continued urban development in agricultural areas near urban areas, and a decline in the economic viability of agricultural operations. Additionally, growth within the city would result in the ongoing loss of natural habitat areas and agricultural areas with habitat value in the Central Valley. Potential impacts associated with ongoing habitat losses in the northern San Joaquin Valley include the reduction of available habitat for the San Joaquin kit fox and other special-status species. Growth in the city could result in a cumulative habitat loss that could endanger the continued survival of these and other species that are not adapted-to living in an urban environment. However, Contra Costa and Alameda Counties are presently preparing a habitat conservation plan that will address future impacts on the San Joaquin kit fox and may identify areas or habitat parcels to be preserved. Additionally, as future individual development projects are proposed in the city, studies to determine each project's effects on City of Brentwood PVTP Project Chapter 4. Other CEQA-Required Analyses Draft EIR 4-4 June 26, 1998 biological resources and mitigation measures to reduce or avoid the effects will be conducted in compliance with CEQA. i Growth within the planning area would also result in an increased demand for public facilities and services, such as water, solid waste facilities, utilities, police and fire protection, j schools, and parks. If public facilities and services are not available (or provisions are not made to make the facilities and services available), growth could not occur within the planning area. Such provisions include implementing the Brentwood Source Reduction and Recycling Element to reduce i the amount of waste requiring disposal at landfills and collecting impact fees for schools and fire and police protection from developers to ensure that adequate facilities are available for growth. Also resulting from growth are increases in traffic, air quality emissions, and noise. As growth occurs in the planning area, traffic levels would increase on roadways in the planning area and regional highways, such as State Highway 4. Increases in air quality emissions from stationary and mobile sources also would occur as a result of growth in the service area(buildout of the general plan would result in exceedances of BAAQMD thresholds for CO, NO, ROG, and PM10). Also, as growth occurs in the planning area, noise levels resulting from new development, industrial and other uses, and increases in traffic levels would also occur. As described above,the proposed project would remove one barrier to growth, and several other infrastructure improvements and factors related to determining growth rates would be required to enable growth to occur in Brentwood. Therefore,the impacts described previously are not directly related to the proposed project but are a result of general growth in the city. Additionally,the City's general plan includes plans for the expansion of wastewater facilities to accommodate existing and future development. CUMULATIVE IMPACTS i Requirements for Cumulative impact Analysis r Section 15130 of the State CEQA Guidelines requires that an EIR contain a reasonable analysis of the significant cumulative impacts of a proposed project. Cumulative impacts refer to two or more individual projects that, when considered together, are considerable or that compound to increase other environmental impacts. The cumulative impacts of a project are the changes in the environment that result from the incremental impact of the project when added to other, closely related past,present,and reasonably foreseeable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over an extended period (State CEQA Guidelines Section 15355). The cumulative impact analysis may be Tess detailed than the analysis of the project's individual effects. The cumulative impact analysis must identify related projects through either a "list" or a "projection"approach, summarize effects of the related projects, and contain a reasonable analysis City of Brentwood WWTP Project Chapler 4. Other CE'Qri-Required linalyses Draft RIR 4-5 June 26, 1998 I of cumulative impacts and mitigation measures. Section 15130(c) of the State CEQA Guidelines recognizes that, for some projects, the only feasible mitigation for cumulative impacts involves adopting ordinances or regulations that apply to a range of projects rather than imposing conditions on a specific project. i Projection Approach i Cumulative impacts are assessed in this EIR using the projection approach. Under this approach,cumulative impacts are evaluated using a summary of projections contained in planning documents that evaluate regional or areawide conditions. Section 15130 of the State CEQA Guidelines states that, when a projection approach is used, any planning documents that are referenced shall be made available to the public at a location specified by the lead agency. For this EIR,the planning documents used for cumulative impact analysis are the City's general plan (City of Brentwood 1993)and the general plan EIR(The Planning Center 1993),which are available upon request at the office of the City's Planning Department, 708 Third Street, Brentwood. Buildout Assumptions The Association of Bay Area Governments projected that in 2010, Brentwood would have a population of approximately 43,000 (City of Brentwood 1993). However, buildout of land uses specified in the general plan within the 30-square-mile planning area would allow for a population of 79,574, which is the level of growth that is analyzed in the general plan EIR. Additionally, the City's wastewater facilities plan indicates that phased expansion of the WWTP to 10 mgd would ultimately accommodate wastewater flows from a population of approximately 100,000 in 2062 (Montgomery Watson 1997a). Approach to Cumulative Analysis An analysis was conducted to determine the cumulative effects of buildout of the City's planning area in the general plan EIR. This cumulative analysis tiers off the analysis in the general plan EIR and recognizes that the WWTP capacity would accommodate a population beyond what is envisioned in the general plan. The cumulative impacts analysis prepared in the general plan EIR was reviewed and the project's contributions to the overall cumulative impact was assessed. Because the proposed project would provide capacity for population beyond the level analyzed in the general plan EIR, this cumulative analysis qualitatively evaluates the possible change in cumulative environmental effects that could result from development beyond the general plan horizon. The proposed project's potential contribution to citywide cumulative impacts is then assessed by comparing the project's contribution to the overall magnitude of probable cumulative impacts. 7 1 City o.,Erenttivood WYYTP Project Chapter 4. Other CEQA-Required Analyses i Draft EIR 4-6 June 26, 1498 i ................................ ...._._..................................................................................................................... i Impacts and Mitigation Measures Impact. The proposed project would contribute cumulatively to the loss of special-status wildlife species such as the burrowing owl. This cumulative impact is considered less than { significant. The general plan EIR identifies that buildout of the general plan area would result in the loss of habitat for special-status species and concludes that this impact is significant and unavoidable. The addition of approximately 20,000 people to the planning area beyond what was considered in the general plan EIR would also indirectly= result in the loss of special-status species; however, individual projects to accommodate the increased growth would be evaluated to determine each project's effects on special-status species,as required by CEQA. Implementation of the proposed project could affect one or more burrowing owl pairs or unpaired resident owls on the project site. However, mitigation measures are included in this EIR to mitigate this impact to a less-than- significant level by requiring the City to follow DFG's mitigation guidelines for burrowing owls (California Department of Fish and Game 1995). This mitigation includes conducting preconstruction surveys,and avoiding burrowing owl nest sites potentially disturbed by construction activities. No other special-status species would be affected by the proposed project. Because the proposed project includes mitigation to avoid affecting burrowing owl nest sites, the project s contribution to the cumulative impact is considered less than significant. Mitigation Measure No mitigation is required. i Impact. The proposed project would contribute to a cumulative increase in traffic. This cumulative impact is considered less than significant. The general plan EIR evaluated the cumulative impact of increased traffic levels on roadways in the planning area and on regional highways such as State Highway 4. That EIR concluded that increased traffic on local roadways and streets in the planning area would be less than significant ' with implementation of mitigation measures and significant and unavoidable even with the future implementation of mitigation measures for increased traffic on regional highways. The addition of approximately 20,000 people to the planning area beyond what was considered in the general plan EIR would generally result in the same types of traffic impacts as those described in the general plan EIR. As described in Chapter 3G,"Transportation",the proposed project's contribution to increased levels of traffic resulting from construction and operation of the proposed project would be negligible and would not be noticeable withinthe daily fluctuations of traffic. Therefore, the proposed" project's contribution` to the cumulative increase in traffic is considered less than significant. Cite of Brentwood WW7P Project Chapter 4. tither CEQA-Required Analyses Draft EIR June 26, 1998 4-7 Mitigation Measure No mitigation is required. Impact: The proposed project would contribute to a cumulative increase in air quality emissions. This cumulative impact is considered less than significant. ' The general plan EIR concluded that buildout of the general plan area would result in increases in air emissions from mobile and stationary sources that would exceed BAAQMD thresholds for CO,NO, ROG,and PM10. The general plan EIR concluded that this impact would be significant and unavoidable because mitigation measures included to reduce these emissions would not reduce the impact to a less-than-significant level. However,as identified in the air quality analysis for the proposed project, mitigation measures are included to reduce impacts relating to PM10,dust, and construction equipment exhaust to a less-than-significant level. Operation of the WWTP would result in increases of organic compounds because of the increased volume of wastewater treated (from I ppd to 7 ppd of ROG). Because the proposed project would contribute only a small amount to the overall air quality emissions resulting from buildout of the general plan, this impact is considered less than significant. The addition of approximately 20,000 people to the planning area beyond what was considered in the general plan EIR would not change the significance conclusion presented in the general plan EIR. Mitigation Measure No mitigation is required. Impact: The proposed project would contribute to a cumulative increase in noise levels. This cumulative impact is considered less than significant. The general plan EIR concluded that buildout of the general plan area would result in j increases in noise levels from future development and increased traffic levels. The EIR determined that this impact was significant and unavoidable even though severe increases in noise levels would be reduced. The addition of approximately 20,000 people to the planning area beyond what was considered in the general plan EIR would not change the impact conclusion presented in the general plan EIR because the additional growth would result in the same types of noise impacts. As identified in Chapter 3F, "Land Use, Noise, and Energy", the proposed project would result in a minor increase in noise during construction and operation. Mitigation measures are included in this EIR to prevent excessive noise during construction of the proposed project. The increased noise levels resulting from operation of the WWTP would be related to the use ofpi._nps for the aerators and would not be excessive. Because the proposed project would not result in excessive noise levels, the project's contribution to the cumulative increase in noise as a result of the buildout of the general plan is considered a less than significant impact. City of Brentwood fV07P Project Chapter 4. Other C.EQA-ReyuireJ Analyses Draft EIR 4-8 June 26, 1993 I _.__._......_....._........................................................................................................................ Impact: The proposed project would contribute to cumulative water quality degradation. This cumulative impact is considered less than significant. The general plan BIR concluded that flooding and water quality impacts in Brentwood would be cumulatively influenced by development throughout the Marsh Creek watershed. The analysis indicates that pollutants in runoff from the Brentwood area would contribute to cumulative increases in pollutants in all downstream waterways, including Marsh Creek. The general plan EIR determined that this impact was less than significant because the general plan contains policies to prevent flooding and water quality degradation. The addition of approximately 20,000 people to the planning area beyond what was considered in the general plan EIR would not change the impact conclusion presented in the general plan EIR because the additional growth would result in the same types of flooding and water quality impacts and would be regulated by the same policies included in the general plan. As identified in Chapter 3A, "Hydrology and Water Quality", the proposed project could result in degradation of water quality in Marsh Creek because the proposed project includes surface water discharge of treated effluent to Marsh Creek. However, measures are included to mitigate water quality impacts to a less-than-significant level. Additionally,the City will be required to comply with the requirements in the NPDES permit, which is regulated by the RWQCB. At full buildout, this project would contribute a negligible amount of flow to Marsh Creek (30 cfs) during peak flood conditions. Although peak flows increase as a result of urban. growth, FCWCD would actively manage and implement flood control measures and facilities. Because measures are included in this project to prevent water quality degradation in Marsh Creek and measures are included in the general plan to prevent water duality impacts on the Marsh Creek watershed and the project's contribution to flooding are negligible,the project's contribution to this cumulative impact is considered less than significant. Mitigation Pleasure No mitigation is required. City of Brentwood JV4 TP Project Chapter 4. Other CEQ.9-Required.4nalyses Draft EIR 4-9 June 26. 1998 i I i i i i i I City of Brentwood WWTP Project Chapter 4. Other CEQA-Required linalyses Draft EIR 4-10 June 26, 1998 1 { j f Chapter 5. Alternatives Analysis t CEQA REQUIREMENTS Section 15126(d) of the State CEQA Guidelines provides guidance regarding the analysis of alternatives to a project: Describe a range of reasonable alternatives to the project, or to the location of the project, which would Feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. l (1) Purpose . . . The discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly. (2) Selection of a range of reasonable alternatives. The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic purposes of the project and could avoid or substantially lessen one or more of the significant effects. . . .The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process . . . . (3)Evaluation of alternatives. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project . . . . (4)"No project"alternative. . . .The"no project"analysis shall discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved . . . . 4 (5) Rule of reason. The range of alternatives required in an EIR is governed by a "rule of reason"that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. . . . The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making. City of Brentwood WWTP Project Chapter 5. Alternatives Analysis Draft EIR June 26, 1998 5-1 i The range of reasonable alternatives should be chosen on the basis of feasibility and the possibility of reducing impacts by using an alternative location, i ALTERNATIVES ADDRESSED IN THE EIR The City has considered various wastewater treatment and disposal project alternatives during preparation of its Wastewater Facilities Plan (Montgomery Watson 1997a). The facilities plan has been used to screen those alternatives that are infeasible or do not meet the objectives of the proposed project. As a result of this screening evaluation, the City is considering one action alternative to the proposed project, the raw water conveyance pipeline to ISD, and the No-Project Alternative. r Wastewater Treatment and Disposal Alternatives Considered and Rejected { The City's facilities plan identified five wastewater disposal alternatives involving treatment at the City's WW TP that were not recommended for further evaluation: ® Surface Discharge into Indian Slough via East Contra Costa Irrigation District Main Canal. This alternative would involve pumping effluent into the ECCID Main Canal for summer reclamation uses and would require that the most stringent Title 2.2 discharge requirements be met. The treatment process would entail providing a filtered secondary effluent that meets total coliform limits of 2.2 MPN/100 ml and discharging it into the ECCID Main Canal south of the City's WWTP. During the winter months when irrigation ceases,the ECCID Main Canal would be used to convey treated effluent to Indian Slough. • Land Disposal (Onsite and Offsite). This alternative would involve disposal of up to 2.2 mgd through use of existing City disposal ponds and development of an additional percolation pond site of 150-410 acres for ultimate disposal of 10 mgd of treated effluent. The City evaluated several sites and identified a 370-acre site at Kellogg Creek and Marsh Creek Road as the preferred land disposal site. ® Urban Reclamation. This alternative would involve use of reclaimed wastewater for turf and landscape irrigation of parks, golf courses, and common areas. Based on a survey of potential recycled water customers the City estimated that the total peak-day demand for recycled water is 6.13 mgd, which could be met by the City's ultimate 10 :ngd treatment plant capacity. i i i City of Brentwood WWTP Project Chapter,'. Ahernatives Analysis Draft Elft 5-2 June 26, 1948 I I a Agricultural Reclamation. This alternative would involve crop irrigation in areas surrounding Brentwood using recycled wastewater and portions of the ECCID canal and distribution system. a Conveyance of Secondary Effluent to ISIS. This alternative would involve secondary effluent treatment at the City's WWTP and conveyance to ISD's Jersey_Island irrigation fields. All of the alternatives were evaluated with regard to construction and operation costs and noneconomic factors such as compatibility with land uses, environmental issues, reclamation potential, and institutional issues. All of these alternatives were ranked lower than the proposed project and raw sewage conveyance to ISD based on a weighted comparison of all criteria (Montgomery Watson 1997a). Wastewater Treatment and Disposal Alternatives Considered and Evaluated i Alternative 1. No Project As described in Section 15126 of the State CEQA Guidelines, a"no project" alternative is required to be analyzed in an EIR. For this analysis, the No-Project Alternative is defined as no improvements to the City's existing WWTP beyond the existing conditions described in this EIR. Under this alternative, the City would tape no action to improve or expand the WWTP beyond its current 1.8-mgd capacity. Alternative 2, Raw Sewage Conveyance to ISD Constructing a new raw sewage conveyance pipeline from the City's existing WWTP to the ISD WWTP near Oakley would allow the City to convey a projected 4 mgrs of raw sewage by 2017 (the project planning horizon) for treatment and reuse for irrigation (effluent disposal) at ISD facilities and would accommodate an ultimate conveyance capacity to the ISD WWTP of up to 10 mgd beyond the projected planning horizon. i The City would construct a raw sewage pump station on the existing WWTP site and an underground 30-inch force main from its WWTP east approximately 2,500 feet to Sellers Avenue (Figure, 5-1). The pipeline would be extended north within the Sellers Avenue right-of-way approximately 11,000 feet crossing the Atchison, Topeka & Santa Fe Railroad (AT& F) to the intersection with Cypress Road and then approximately 5,000 feet west to another AT&SF crossing. West of the railroad crossing the pipeline would be attached to the Cypress Road bridge across Marsh Creek approximately 400 feet to its western bank. The pipeline would then proceed approximately 2,400 feet north along a dirt access road that parallels the west bank of the creek to the Contra Costa Canal. The pipeline would be constructed under the canal, extend west on ISD City of Brentwood WWTP Project Chapter 5. Alternatives Analysis Draft EIR 5-3 June 26, 1998 v§<'�'�y'3�''�"^„�,y^os:�z.:ira��:�g�.:�ru«yb5�8zS :��,•w`." .s ��tv': ``'. y f° �., �;;yY,�a:,y�'. ;sa¢3�=?,•xsz ' t Jersey Island MUM e 30-Inch Treated 7 Effluent Disposal Pipeline ContraCosta 1i Oakley � < cypress Road 30-Inch Raw Sewage Conveyance Pipeline c� I Brentwood WWTP Raw N Sewage Pump Station 0 2,000 4,000 Sunset Scale in Feet �= v o? To Brentwood Figure 5-1 Jones&Stokes Associates, Inc. j Alternative 2: Raw Sewage Conveyance to ISTD 5-4 property,and then extend north approximately 3,204 feet to ISD's new WWTP site. Total pipeline length would be approximately 4.6 miles. Conveyance of 10 mgd of raw sewage to ISD would rewire the district, under agreement with the City,to expand the ISD WWTP,located northeast of Oakley to a total of 18 mgd. ISI?has already evaluated,in its facilities plan EIR(Ironhouse Sanitary.District 1994), future expansion of its existing WWTP to a total capacity of 8 mgd and acquisition of additional land for future effluent and sludge disposal Gronhouse Sanitary District 1994). ISD's Wastewater Facilities Expansion Ilan j (James M.Montgomery 199 1)envisioned that upgrade and expansion of the treatment system would be an oxidation ditch system and would occur in three increments of 2.7 mgd for a total capacity of 8 rngd. The proposed oxidation ditch process would consist of influent and effluent pumps,screens, ditches, clarifiers,effluent disinfection(as required), and sludge- handling facilities. ISD currently disposes of effluent on 300 acres of pastureland and is permitted to dispose of effluent on 350 acres of the total 3,200 acres on its Jersey Island property. The 8 mgd of treatment and disposal capacity envisioned in the 1991 Wastewater Facilities Expansion flan assumed a buildout population of ISD's sphere of influence beyond 2010 to be approximately 66,272. This estimate does not include providing service to Brentwood, which is outside ISD's sphere of influence. i The City's wastewater facilities plan indicates that a WWTP expansion serving ISD and the City would operate under ISD's current expansion plan for 8 mgd until approximately 2017. This ! estimate is based on growth in Brentwood of 550 dwelling units per year and ISD service-area growth of 250 units per year(Montgomery Watson 1997x). Beyond 2017,combined ISD/Brentwood wastewater flows (provided the annual growth rate remains constant) are projected to be approximately 18 mgd in 2062, which is beyond the planning horizon for both the City's and ISD's facilities plans. Future upgrade of ISD's WWTP to accommodate ultimate combined ISD/Brentwood flows would occur on ISD's existing property that has been evaluated in the 1994 EIR.. The ultimate treatment plant to serve ISD and the City would likely include expanding ISD's screening facilities,oxidation ditches,secondary clarifiers,disinfection system(as required),effluent pump station, and sludge-handling facilities. To accommodate expanded treatment capacity needed for ultimate combined ISD/City i wastewater tows,an additional 7,300-foot-long,30-inch-diameter disposal pipeline to Jersey Island would be constructed parallel to ISD's existing disposal pipeline. The City's facilities plan indicates that this pipeline could be bored and jacked under or trenched across Dutch Slough. ISD's current property is adequate to handle effluent and sludge treatment and disposal facilities for up to 18 mgd. Land required for effluent and sludge disposal, assuming an 18 mgd oxidation ditch treatment system.., is 1,142 acres and 1,368 acres, respectively. This assumes 10 rng/l total nitrogen in the effluent and nitrogen of the sludge produced is 5%. In addition, crop nitrogen uptake was assumed at 480 lbs/ac/yr. Land required for disposal of effluent from a pond treatment system is 2,511 acres. This assumes a 22 mg/l total nitrogen in the effluent and a crop nitrogen uptake of 480 lbs/ac/yr. Sludge from a pond treatment system is removed every 2 to 5 years and could be disposed on Jersey Island or hauled offsite. Pond sludge,if disposed on Jersey Island,would have minimal impacts on the overall acreage needed for effluent and sludge disposal. City of Brentwood WW7T Project Chapter 5, Alternatives Analysis Draft EIR June 26, 1998 5-5 i Alternative 2 incorporates the following environmental control measures into its design that would eliminate or reduce to acceptable levels all of the possible environmental effects: i • implementing erosion and sediment control plan, ■ providing levee protection at Jersey Island, s implementing effluent/sludge application and monitoring program, • implementing dust control procedures for construction, • implementing traffic control measures, o minimizing exposure to excessive noise, ■ identifying and avoiding underground utilities, ® conducting special-status species preconstruction surveys, ■ avoiding sensitive biological resources during critical time periods, • confining in-water work in Marsh Creek and Dutch Slough to low-flow periods, a avoiding emergent vegetation in Marsh Creek and Dutch Slough, • minimizing channel sedimentation in Marsh Creek and Dutch Slough, • complying with DFG streambed alteration agreement requirements, s avoiding disruption of unknown archaeological sites, and e complying with all other possible permit/regulatory requirements. ALTERNATIVES ANALYSIS Alternative 1. No Project I Linder the No-Project Alternative, the City would be required to operate its WWTP at the current 1.$-rngd permitted capacity(2.2-mgd rated capacity)using currently approved treatment and disposal facilities. The advantages of this alternative are that the City would not invest any additional money for wastewater treatment expansion at its existing WWTP and no direct discharges of treated effluent to Marsh Creek would occur. The disadvantages of this alternative include the following: • it does not address the need to upgrade and expand existing treatment facilities, i ® growth projected in the City's general plan would be partially constrained by limited WWTP capacity, • new development proposals awaiting City approval would be required to obtain wastewater treatment and disposal services from an alternative source, i • the likelihood of violating water quality discharge limits could increase, and The No-Project Alternative would also not achieve any of the project objectives because the existing WWTP is near full capacity and the City has planned development within its service area i City of Brentwood WWTP Project Chapter S. Alternatives Analysis Draft EIR 5-6 June 26, 1498 pending approvals that require wastewater treatment and disposal. This alternative, with likely future projects, could result in inability of the existing plant to meet water quality discharge limits. If this alternative is selected, the City would need to find another method to treat and dispose of I wastewater generated from future projects, and either identify means to upgrade the capacity and reliability of the existing WWTP or run the risk of not meeting discharge limitations. Because no City action would occur under this alternative, no environmental impacts identified for the proposed project in this EIR would occur. Possible environmental impacts that could result from the No-Project Alternative depend on various speculative actions that could occur as a result of limited wastewater treatment capacity. The City would pursue one of the facilities plan alternatives that had previously been rejected, such as conveyance of treated effluent to Jersey Island, discharge to Indian Slough, City-operated land disposal, or urban or agricultural reclamation. Each of these rejected alternatives would result in direct physical effects and indirect effects similar to those of the proposed project and would be more expensive than the proposed project(Montgomery Watson 1997a). ( Alternatively, future developments could be served by individual package treatment plants. Although predicting environmental effects of such a scenario is highly speculative, generally the result would be to require development of a relatively large number of small treatment facilities on undeveloped land in the.City's service area. This scenario could result in a much greater loss of high-quality agricultural and open space lands than under the proposed project at greater expense. Alternative 2. Raw Sewage Conveyance to ISI) Advantages of Alternative 2 over the proposed project include the following: a construction and operational maintanence costs are slightly less than those of the proposed project, 9 responsibility for raw sewage treatment and disposal would be transferred to ISIS under a contract service agreement, and i 9 less potential for additional costs to the City to meet more stringent surface water discharge requirements in the future. The disadvantages of Alternative 2 include the following: a pipeline construction would involve temporary disturbance of a greater number of transportation.facilities and utilities than WWTP expansion on existing City property, 0 the risk potential for raw sewage spills from pipeline rupture would be greater than under the proposed project, (;,ity of 8rentivood WP1'7`P Project Chapter S. Alternatives Analysis Draft EIR June 26, 1998 5-7 ® federal and state agency permit requirements would be required for disposal pipeline crossings at Marsh Creek and Dutch Slough, i • the level of City control over facility expansion world be reduced, and • potential reduction in the City's ability to enter into a cooperative agreement with industry. 3 Alternative 2 would meet all of the objectives of the proposed project as described in Chapter 2, "Project Description". Environmental effects of Alternative 2 compared to the proposed project are addressed below. i Hydrology and Water Quality Setting. Information on hydrology and water quality in the area of the City's existing WWTP is provided in Chapter 3A of this EIR. In addition to Marsh Creek, other major hydrologic features in the project area are the San Joaquin River(Big Break), Dutch Slough, Emerson Slough, and the Contra Costa Canal. The San Joaquin River flows along the northern border of Jersey Island and drains to the San Francisco Bay. The net downstream movement of water near Dutch Slough and the confluence of Marsh Creek with Big Break can be very small during periods of low Delta inflow and high rates of pumping for agriculture and Delta exports. Because of daily tidal action, streamflow also reverses direction and can move upstream during low flow periods. Agricultural drainage to the San Joaquin River has increased its salinity and concentrations of total dissolved solids, fertilizers, and pesticides. Contra Costa Water District operates a water quality monitoring station on Rock Slough approximately 4 miles east of Jersey Island that is the best source of information for water quality data in the project area. + Dutch Slough forms the southern border of Jersey Island. The slough channel is approxi- I mately 300 feet wide with an average depth of 10--13 feet. The mouth of the slough opens to the 1 southeastern corner of Big Break and provides navigable access for boats to Bethel Island and other points upstream. , Groundwater in the vicinity of the ISD WWTP exists in an upper surface zone that is shallow (4---10 feet below the ground surface) and of poor quality and deeper zones that are isolated from the surface zone by impermeable aquacludes. The deeper groundwater zones have higher water quality and are used for domestic water supply. Groundwater on Jersey Island exists in an extremely shallow zone that may be affected by cattle grazing and agricultural byproducts. Impacts. Alternative 2 would not result in changes in absorption rates, drainage patterns, or runoff because the amount of impervious surfaces in the project area would not increase. i Pipelines would be buried and would not adversely affect any groundwater infiltration areas in the Brentwood Planning Area or on ISD property. This alternative would also not expose people or property to flooding because the pipelines would not create flooding conditions and are not located near major population centers. Effects on Marsh Creek and Jersey Island levees from pipeline i City of Brernttvood WWTP Project Chapter 5- Alternatives Analysis i Draft EIR 5.8 June 26, 1998 i , I i construction would be minor because the City has incorporated environmental control measures into this alternative to reduce effects on levees. Measures to protect ISD's expanded treatment facilities from flooding have also been incorporated into facility designs as part of the final EIR prepared for i the ISD Wastewater Facility flan(Ironhouse Sanitary District 1994). Treated effluent from ISD's WWTP would be disposed of on Jersey Island. This alternative would not result in any discharge to surface waters or any change in water movements. Construction of parallel disposal pipeline across Dutch Slough to Jersey Island would occur in the existing ISD pipeline right-of-way and would require new permits with DFG,RWQCB, and the Corps for the crossing in the future. Conveyance of raw sewage to ISD would not increase the amount of groundwater in the Brentwood Planning Area,and disposal of effluent on ISD's Jersey Island property would be subject to mitigation measures addressed in the ISD Wastewater Facilities Plan EIR.(Ironhouse Sanitary District 1994). This alternative would also not substantially alter the direction or rate of flow of groundwater in the planning area, and the mitigation measures included in the ISD Facilities Plan EIR. would ensure that the project under Alternative 2 would have acceptable groundwater-quality effects on Jersey Island. ISD would be required to prepare and submit to the RWQCB a new report of waste discharge for future expansions of its Jersey Island disposal method. Before ISD began land application of effluent on. Jersey Island, the RWQCB issued a new WDR permit with requirements to ensure that groundwater quality would be protected. This alternative would have no effect on the amount of groundwater available for public water supply because the pipeline project would not adversely affect City or other public wells and. the Jersey Island operation would involve only the shallow aquifer, which is not used as a drinking water supply (Ironhouse Sanitary District 1994). Geology, Soils, and Seismicity Setting. Information on geology, soils, and seismicity in the area of the City's existing WWTP is provided in Chapter 3B of this EIR. The ISD WWTP site is located in a relatively flat area along the Delta. The geologic structure of the site consists of unconsolidated and semiconsolidated alluvium, lake playa, and terrace deposits (Ironhouse Sanitary District 1994). Jersey Island is surrounded by levees that protect it from being inundated by the San Joaquin River and surrounding sloughs. Levees are composed of sandy material lined with riprap, although some portions have been subject to slumping. Soils in the area range from sands to clays. The ISD WWTP and disposal pipeline site generally consists of clay soils with a high shrink-swell potential. Peat soils on Jersey Island lend themselves to subsidence, which is a major concern on Delta islands (Ironhouse Sanitary District 1994). Impacts. Based on the information provided in the City's general plan, no active or potentially active faults exist on or immediately adjacent to the Alternative 2 site; therefore, the potential for fault rupture near the pipeline alignment is minimal. The portions of the conveyance pipeline located on ISD property and the new discharge pipeline to Jersey Island are not anticipated to be subject to surface fault rupture because no active faults exist in these areas and ISD's City of Brer nvood WWTP Project Chapter 5, Alternatives Analysis Draft EIR 5-9 June 26, 1998 Wastewater Facilities Plan EIR(Ironhouse Sanitary District 1994)does not identify surface rupture from faults as a significant concern on ISD property or in the vicinity of existing facilities. i The site and vicinity could be subject to groundshaking because of the presence of local faults within several miles of the pipeline alignment; however; groundshaking is unlikely and the pipeline structure would be designed to withstand such events. I Areas of the pipeline alignments that would be sited outside an established road right-of-way and that have alluvial and sandy soils and shallow groundwater conditions, including the discharge pipeline to Jersey Island, may be subject to liquefaction. During a strong groundshaking event, soil liquefaction could cause failure of the pipeline, which could result in release of treated wastewater and potential public health concerns. However, because both the conveyance and disposal pipeline facilities would be designed to withstand groundshaking in accordance with applicable City and Contra Costa County design standards, this potential impact is considered less than significant. Construction activities related to 'installation of the Alternative 2 pipelines would require minimal soil disturbance that could result in localized wind and water erosion. Damage from subsidence was not identified in the general plan as an issue in the Brentwood Planning Area and has not been identified as an issue on the ISD WWTP site. No construction conditions for either the conveyance or discharge pipeline would create subsidence. However, areas with alluvial deposits are susceptible to subsidence if groundwater is removed, and Jersey Island is considered to have moderate to high potential for subsidence. Alternative 2 facilities are also not expected to be subject to significant shrink-swell conditions from expansive soils because, in general, such soils are not present in the conveyance and discharge pipeline corridors or on ISD property. Should expansive soils be encountered adverse effects could be avoided through proper drainage and foundation design (The Planning Center 1993). Biological Resources 1 Setting. Prominent landscape features in the project area include roads,Marsh Creek,Dutch Slough, and agriculture areas. Most of the Alternative 2 conveyance pipeline would be trenched in ruderal vegetation along road right-of-ways. Ruderal vegetation occurs along the access road east of the City's WWTP, Sellers Avenue, Cypress Road, and along the Marsh Creek and Contra Costa Canal levees. The vegetation is dominated by weedy annual grass and other species, including bromes, fescue, mustards,and filarees. Most of the levee-top roads are bare of vegetation. Ruderal vegetation provides limited habitat value for wildlife and typically does not support special-status wildlife species, in part because it occurs at the margins of agricultural fields adjacent to roads where tilling and weed control disturb vegetation,regularly. An exception occurs under road bridges,where nesting swallows and bats roost and nest. Swallow nests(10-15 nests)were found under the Cypress Road bridge over Marsh Creek. Swallow nests and their young are protected under the Migratory Bird Treaty Act and California Fish and Game Code 3503.5. Marsh Creek is a low-gradient, channelized creek flowing into Big Break. The proposed pipeline would be located along Marsh Creek in two locations,a southern reach and a northern reach. City of Breniwoo.cl WYY P Project Chapter 5. Alternatives Analysis 1lraft FIR 5-10 june 26, 1998 i The pipeline near the southern reach lies on the westside levee road of Marsh Creek between Cypress Road and the Contra Costa Canal. Near the northern reach, the pipeline lies on the east side of Marsh Creek, east of the levee road approximately 0.75 mile north of the Contra Costa Canal. The creek is characterized by moderate flows during winter and low flows in summer. Along the southern reach, the creekbed is approximately 15 feet below the levee grade at a 45°angle and the banks are dominated by Bermuda grass. Occasionally,riprap has been placed for bank stabilization i and irregular, small patches (less than 20 feet long)of emergent vegetation(bulrushes and cattails) line the bank margins. The creek width in the southern reach averages approximately 12 feet. Vegetation on the northern reach is characterized by a mix of emergents and riparian vegetation. Willows occur more frequently near the outlet of Marsh Creek. The creek is less channelized in the north and averages approximately 20 feet wide. The second most common habitat type in the project area is irrigated/grazed pasture. This habitat type occurs on ISD property on the east and west side of Marsh Creek north of Cypress Road and along Dutch Slough. The pasture is grazed by cattle and vegetation is relatively short (1--6 inches). Common wildlife species foraging in the pasture include Brewer's blackbird,meadow mice, great egrets, and killdeer. Occasional irrigation ditches cross the pasture where cattails grow in narrow strips along the margins of the ditches. The emergent vegetation may provide nesting habitat for red-winged blackbirds and marsh wrens. Additionally,a few oak trees occur at the edges of the field margin. The remaining habitat types on the Alternative 2 site include annual grassland and riparian vegetation. Annual grassland on the project site is located on the southwest comer of the City's WWTP. This small piece of grassland habitat is not regularly disturbed and bromes, fescues, rye, and foxtails are present. Common wildlife species, including western meadowlark, savannah sparrow, and house mice, forage and likely nest here. Riparian vegetation, the most sensitive habitat type on the site, occurs along Marsh Creek and Dutch Slough. It occurs as"stringers"along the creek and slough. Ecologically,riparian habitat is biologically rich, supporting more species than most other habitat types because of the presence of water and a productive, nutrient-rich environment. However, historic losses of riparian habitat have exceeded 90% statewide as a result of agricultural land conversion, urbanization, and construction of flood control and water conveyance systems. Many species dependent on riparian habitat are now considered rare, and several of these are now legally protected or are being considered for protection, under the state or federal Endangered Species Act. Because of the rarity of this habitat type and its importance biologically,riparian habitat is considered sensitive. Common species in riparian habitat include willows, cattails, toles, blue elderberry, white aider, button bush, blackberries, and California rose. Riparian habitat provides cover and nesting opportunities for a diverse group of wildlife species. The cattail, willows, and blackberries along the river and sloughs are used by numerous breeding birds, including song sparrows, common yellowthroats, spotted towhees, and red-winged blackbirds. Several migratory birds also use the riparian vegetation for foraging and cover while moving along their migration route. The thick riparian vegetation also provides cover for mammals, City of Brentwood WW7P Project Chapter 5. Alternatives Analysis Draft E112 June 2d, 1998 5-11 including striped skunks, Audubon cottontail, western harvest mice, Norway rats, and deer mice. In riparian areas that retain water into the spring and summer, Pacific tree frogs are abundant. Five special-status species are known to occur in the project vicinity:western burrowing owl, San Joaquin kit fox, winter-run Chinook salmon, Delta smelt, and Sacramento splittail. These species are described and their locations or the locations of their potential habitat on the proposed project site are identified in Chapter 3C of this EIR. Potential burrowing owl habitat(grasslands and nontilled agricultural fields) occurs on the project site on the City WWTP and ISD lands. Several burrowing owls are known to occur at the City's WWTP. During the reconnaissance-level field survey, two burrowing owls were observed, and one was using a burrow approximately 50 feet north of the proposed location for the conveyance pipeline east of the City's WWTP site. Although no surveys for San Joaquin kit fox were conducted for the kit fox and no foxes were identified during the reconnaissance survey, the project area is within the kit fox range. Critical habitat for winter--run chinook salmon includes the river water, river bottom, and adjacent riparian zone (i.e., those adjacent terrestrial areas that directly affect a freshwater aquatic ecosystem). Adult winter-run chinook salmon leave the ocean and migrate through the Delta into the Sacramento River from November through July. They migrate upstream of the Red Bluff Diversion Dam to spawn. Smolts (juveniles that undergo physiological changes to adapt to ocean salinity)may migrate through the Delta and San Francisco Bay to the ocean from December through May (Stevens 1989). Critical habitat for delta smelt was proposed by USFWS to include the Delta and Suisun Bay (59 FR 65256,December 19, 1994). The most probable spawning locations for delta smelt are dead- end sloughs and shallow edge waters of the channels of the Delta and the Sacramento River. Ideal spawning areas have moderate to rapid flow(including tidal action)and thriving aquatic vegetation (Wang 1991.). Larval delta smelt are planktonic and move passively with the current, typically toward the entrapment zone. Sacramento splittail is endemic to the lakes and rivers of central California and is abundant ' in the western and northern parts of the Delta (Moyle et al. 1989). In recent years, splittail distribution appears to have shifted to the lower Sacramento River and the south Delta(59 FR 862, January 6, 1994). Water diversion facilities, land reclamation activities, flood control projects, and agricultural development have eliminated and drastically altered much of the splittail habitat in lowland areas, and damns have restricted access to spawning areas and upstream habitats. USFWS estimates that diking and dredging have eliminated approximately 96% of the wetland habitats that splittail apparently require (59 FR 862, January 6, 1994). Other special-status species have the potential to occur on or near the Alternative 2 site. However, suitable habitat is not present on the Alternative 2 project site for many of these species, in part because construction of the pipeline will occur almost entirely in habitats that are regularly disturbed. A few special-status wildlife species have a high potential to occur on the site (i.e., City of Brentwood 6VWTP Project Chapter 5. Alternatives Analysis i Draft EIR 5-12 June 26, 1998 raptors), however, because these species are highly mobile and primarily occur on the site during winter, they will not be affected by project implementation. Additionally, special-status plants may occur on the project alignment,but these species could not be identified during field surveys because surveys were not conducted during the time of the year when the plants flower and much of the project area is regularly disturbed during maintenance activities. Impacts. As a result of implementation of the environ3nental control measures described above Alternative 2 would have minimal effects on biological resources. The western burrowing owl is known to occur adjacent to the proposed pipeline, and the San Joaquin kit fox,delta smelt, and Sacramento splittail may occur along the pipeline construction sites. Additionally,special status plants may occur on the proposed alignment. Environmental control measures will ensure that any impacts on these resources would be reduced to acceptable levels. This alternative would also not adversely affect locally designated species, such as nesting swallows, and would not affect any locally designated natural communities. By incorporating the environmental control measures into alternative design,no adverse effects on wetland habitats,including Marsh Creek and Dutch Slough, would occur. The alternative site is not within an important wildlife dispersal or migration corridor. Public Health and Safety Setting. No known or suspected hazardous waste sites are on or adjacent to the City's WWTP, and no known hazardous materials sites are located near the proposed conveyance or disposal pipelines. Normal operation of the ISD WWTP involves use of various chemicals considered hazardous, such as sodium hypochlorite,which is used for disinfection, and diesel fuel and other petroleum products. ISD has prepared a Hazardous Materials Management Plan for its existing facilities that provides a list of all hazardous chemicals used at the facility and provides procedures for properly storing, handling, and disposing of those substances. Hazardous materials on Jersey Island have been assessed in the Phase I Environmental Site Audit, Jersey Island, Contra Costa County, California (Montgomery Watson 1993). .Alone of the sites identified in this audit would affect or be affected by the proposed disposal pipeline. Impacts. Construction of the Alternative 2 raw sewage pump station and conveyance and disposal pipelines would involve the use of heavy equipment that is already periodically used in grading and routine maintenance operations at the WWTP site. The use of this equipment would also involve the use of small amounts of oils and fuels and other potentially flammable substances that are typically associated with these activities. No additional fuels or other hazardous substances would be placed or stored on the project site. The ISD 'Wastewater Facilities flan EIR (Ironhouse Sanitary District 1994) indicates that increased handling and storage of hazardous materials or generation of hazardous wastes at the WWTP would be mitigated by applying provisions of ISD's Hazardous Materials Management Plan,which requires that ISD personnel receive health and safety training, hazardous wastes are disposed of according to federal, state, and local regulations, and the WWTP is separated from public use areas, such as the East Bay Regional Park District trail, by fences to restrict public access. Therefore, Alternative 2 would not result in a substantial risk of explosion or accidental release of hazardous substances. Because the construction phase of City of Brentwood WWTP Project Chapter 5. A ternatives,4nalysis Draft EIR June 26, 1998 5-13 Alternative 2 would be of short duration and relatively small scale, it would not interfere with any City or Contra Costa County emergency evacuation plans. Construction and operation of this alternative would involve conveyance of raw sewage to ISD's expanded WWTP for secondary treatment,then land disposal of the treated effluent on ISD's Jersey Island property and property adjacent to the WWTP. Conveyance of up to 10 mgd of raw sewage through a 30-inch force main to ISD could pose a health risk if the pipeline were ruptured as a result of groundshaking or a human-created accident. Areas where potential sewage spills could be of concern include the Marsh Creek and Contra Costa Canal crossings and the portions of the pipelines located near rural residences. This impact is considered less than significant because the possibility of a spill is remote and the pipeline would be constructed to withstand groundshaking. The pipeline corridor would also be clearly marked to ensure the facility is not inadvertently damaged by future trenching or other construction activity along the corridor. Construction of Alternative 2 would involve trenching, shallow grading, and earthmoving j activities in the project area. The grading activities could result in workers being exposed to health hazards if unknown hazardous materials (e.g., materials buried underground) were present on the project site. However, no known or suspected hazardous materials are present in the project area, and therefore, people are not expected to be exposed to health hazards. i Air Quality i Setting. Chapter 3E of this EIR contains background information on general air quality relevant to the Alternative 2 site. The City's WWTP currently has a permit that designates each treatment process as a potential source of air pollution, from the BAAQMD for the treatment processes and associated structures. This permit includes a condition that stipulates that if odorous emissions (odors) cause more than five confirmed complaints in any one month, the WWTP must take immediate action to solve the odor problem (Gaston pers. comm.). No complaints of odor j problems at the City's WWTP have been recorded by the BAAQMD. According to the BAAQMD, approximately six odor complaints were lodged for the vicinity of the ISD WWTP over a 3-year period,and none were confirmed to be from the ISD's facilities (Ironhouse Sanitary District 1944). Odor is an aspect of air quality that can be of concern for both aesthetic and public health reasons. Although odor is not considered an issue at the City and ISD facilities, some odor may j result from the handling of raw wastewater or sludge at the WWTPs. However, odors are not generally associated with conveyance pipelines and disposal ponds and other facilities handling treated effluent. Impacts. Construction activities, such as excavation, grading, and vehicular traffic, may generate temporary increases in dust and particulate matter. Construction of the Alternative 2 facilities would not cause any applicable air-quality standards to be violated or contribute to an existing violation. The only potential source of air-quality impacts would be the generation of dust and particulate matter during the construction phase and possibly odors from expansion of ISD treatment facilities. The environmental control measures described above would reduce the potential City of Brentwood WWTP Project Chapter 5. alternatives analysis Draft RIR 5-14 June 26, 1998 i i I for dust generation. Expansion of the ISD WWTP, as described in the ISD Wastewater Facilities Plan EIR(Ironhouse Sanitary District 1994),would not involve a substantial increase in stationary source emissions of either criteria pollutants or toxic contaminants. When ISD applies to the BAAQML D for an Authority to Construct Permit for the new WW'TP,the BAAQMD will determine whether a health risk assessment is necessary. ISD's WWTP expansion would also be designed to 1 avoid adverse odor effects on adjacent land uses by maintaining a minimum buffer zone of 1,000 feet between the treatment and sludge-drying facilities and property boundaries to the east and west (Ironhouse Sanitary District 1994). Effluent and sludge disposal on Jersey Island would not create any adverse odors or air pollution. i The Alternative 2 facilities could potentially generate minor amounts of dust and particulate matter during construction along the pipeline corridor that could temporarily affect rural residences along Sellers Avenue and Cypress Read. This impact would be minor because pipeline and other utility construction is common along road right-of-ways and potentially sensitive receptors would be exposed to only minor amounts of construction dust and equipment emissions for very short periods. i Land Use, Noise„ and Energy Setting. Information on land use,noise,and energy in the area of the City's existing WWTP is provided in Chapter 3F of this EIR.. The conveyance pipeline alignment north of the Brentwood Planning Area is designated by Contra Costa County predominantly for agricultural uses, although land adjacent to portions of Cypress Road is designated for residential and light industrial uses. The conveyance pipeline alignment would cross the AT&SF right-of-way along Sellers Avenue and Cypress Road and would be constructed under the Contra Costa Canal. ISD property consists mainly of wastewater treatment facilities, administration buildings, and pasture land used for disposal of treated effluent. Approximately 261 acres of ISD's property are managed for agriculture. General plan designations for the ISD WWTP site include Public/Semi-Public, Agricultural Lands, and Light Industrial. The Contra Costa Canal separates two ISD parcels used for land irrigation from the rest of the project area in the southern portion of the site. To the north and northwest of the ISD WWTP site are lands designated as Delta Recreation, Parks and Recreation,and Water. These areas are primarily freshwater marsh habitat conservation areas and open water and marsh associated with Big Break on the San Joaquin River. The 30-inch-diameter disposal pipeline would be adjacent to ISD's existing disposal pipeline to Jersey Island. The pipeline would cross Marsh Creek,continue along the extreme western portion of the Emerson Dairy property,then cross hutch Slough to Jersey Island. Adjacent land uses to the east are entirely agricultural. An access road along Marsh Creek is located west of the alignment. Jersey Island consists of 3.700 acres designated as Delta Recreation outside Contra Costa County's urban limit line. Existing land uses throughout the island are for agricultural uses and pastureland. Alternative 2 would be consistent with the City's general plan goals and policies to ensure that public facilities and services are maintained or improved as the city grows, develop a plan that Cita of Brentwood WW7P Project Chapter 5. Alternatives Analysis Draft FIR 5-15 June 26, 1998 establishes priorities and corrects existing inadequacies in the City's infrastructure system, and expand existing water and wastewater facilities to accommodate existing and future development. Impacts. Implementation of Alternative 2 would be consistent with and would further the objectives of applicable environmental plans, goals, and policies of the City. The portions of the project that would be constructed on ISD property are consistent with Contra Costa County designations and policies for the area. No impacts on land use pians or policies would occur. Alternative 2 also would be compatible with existing land uses in the project area. Primary land uses that are adjacent to the project area include agricultural uses and pastureland, light industrial activities, open space, and low-density residential development. Construction of Alternative 2 would not conflict with any existing or planned uses in the project area. The portion of the pipeline extending from the City's treatment plant to Sellers Road would be in the vicinity of one rural residence but would create no significant construction or operational land use conflicts ` because construction would be temporary and the pipeline would be underground. The project would provide additional long-term capacity for the City's existing wastewater treatment system and would ultimately involve closing the City's WWTP. Expanded treatment facilities on ISD property would not result in adverse effects on adjacent land uses because expanded treatment facilities would be sited near the center of ISD property, and a 1,040-foot buffer would be maintained between the new WWTP and adjacent lard uses(Ironhouse Sanitary District 1994). The disposal pipeline to Jersey Island would not conflict with adjacent land uses because the alignment would be sited along the existing ISD disposal pipeline corridor and near agricultural and open space areas. Temporary increases in noise levels and fugitive dust emissions associated with construction activities are not expected to conflict with adjacent land uses. Implementation of the Alternative 2 conveyance pipeline would minimize loss of prime farmland and farmland of statewide importance because most of the pipeline would either be located within road right-of-ways or cross pastureland on ISD property. The portion of the conveyance pipeline that would extend between the existing City WWTP and Sellers Road would be located in an area that is generally identified as Prime Farmland and Farmland of Statewide Importance in the j City's general plan. The City would avoid impacts in this area by locating the pipeline along an existing access road north of the City's proposed solid waste facility. The City would ensure that no effect on current agricultural operations east of the WWTP will result from placing the pipeline in this location. Alternative 2 would also not require cancellation of Williamson Act contracts or divide an established community. Extending the disposal pipeline across Marsh Creek and parallel to the levee would not substantially affect agricultural operations because the pipeline would be adjacent to agricultural fields at the extreme western edge of the Emerson Dairy property and the pipeline would be underground. Noise levels could increase temporarily during construction activities for Alternative 2. The City of Brentwood General Plan EIR(The Planning Center 1993)requires that noise-sensitive uses be protected from exposure to excessive noise by limiting the hours of construction activities to 9 City of Brentwood WWTP Project Chapter 5. Alternatives Analysis Draft EIR 5-16 June 26, 1998 1 a.m.-7 p.m. on weekdays and 8 a.m.--7 p.m. on Saturdays. Construction activities would be prohibited on Sundays. Additional measures to reduce noise exposure may include requiring that construction equipment, compressors, and generators be fitted with heavy-duty mufflers. No significant noise impacts associated with constructing and operating ISD's expanded WWTP have been identified for the ISD's property (Ironhouse Sanitary District 1993). Alternative 2 facilities would not expose people to severe noise levels because operating a pump station, a buried pipeline, and an expanded WWTP would not substantially increase noise j levels for sensitive receptors over the existing conditions. I Implementation of Alternative 2 would also not result in conflicts with energy conservation 4 plans,use of nonrenewable resources, or loss of available known energy or mineral resources. As described in the City's general plan EIR,energy and mineral resources such as natural gas, oil, and coal are found primarily in the western and southern portions of the Brentwood Planning Area. No resources of this nature have been identified or are known to occur in the project area, including;on ISD property. No impacts on mineral or energy resources would occur. Transportation Setting. The most prominent feature of the Brentwood/Oakley street and highway system is State Highway 4,which is a two lane north/south highway in the project area. The City's WWTP is currently served by Sunset Road,a collector street from Brentwood Boulevard(State Highway 4) that runs east toward Sunset Park. The City's WWTP is located on Tresch Avenue, which is approximately one-quarter mile east of Brentwood Boulevard off Sunset Road. 1 The conveyance pipeline would be located along Sellers Avenue, a two-lane, undivided north/south collector street and Cypress Road, a two-lane, undivided east/west collector. Access to ! the ISD site is from State Highway 4 through the Vintage subdivision, either from Vintage Parkway or from Big Break Road to Walnut Meadows .Drive. These surface streets and arterial roadways carry considerable traffic volume and are generally expected to operate at satisfactory levels through buildout of the City's general plan area. Onsite parking is provided at both the City and ISD facilities. The Alternative 2 site is also bisected by the AT&SP tracks at Sellers Avenue and Cypress Road. The conveyance pipeline would cross the AT&SP tracks at three locations (Figure 5-1). i The disposal pipeline from ISD to Jersey Island would cross the Marsh Creek Regional Trail operated by the East Bay Regional. Park District. Impacts. Alternative 2 would not result in a substantial increase of vehicle trips or traffic congestion because construction and maintenance activities associated with the facilities would not substantially increase vehicle trips beyond existing traffic levels on project area roads. Construction of the raw sewage pump station of the City's existing WWTP site would create minor amounts of construction traffic and would require trips for operation and maintenance purposes. These traffic effects would be minor. Construction of the conveyance pipeline along City of Brentivood WWTP Project Chapter S. Alternatives Analysis Draft EIR June 1d, 1998 5-17 Sellers Avenue and Cypress Road could result in temporary construction-related traffic delays at various times during the construction period. During site preparation and placement of pipeline segments,construction equipment and employees could block portions of the roadway, resulting in traffic delays. Vehicular traffic could be diverted from the project area during a portion of the construction period. These impacts would be reduced to acceptable levels because the City has incorporated traffic control measures into this alternative to minimize temporary traffic disruptions during pipeline construction. Alternative 2 would not create safety hazards or incompatible uses associated with the transportation system because the infrastructure project would not involve substantial modification of roadways and would not result in changes to the emergency access system or access to nearby uses. Temporary construction in the road right-of-way would be required on Sellers Avenue and Cypress Road but long-term access would not be affected by the conveyance pipeline. The portion of the conveyance pipeline between the existing City WWTP and Sellers Road would be constructed along an existing right-of-way. The pipeline would pass near the City's solid waste facility and a warehouse but would not affect access to these facilities. No adverse impacts on access roads would occur. i Alternative 2 would not result in traffic hazards or barriers for pedestrians or bicyclists and would not conflict with adopted policies associated with alternative transportation. The project would also have no effect on rail or air traffic,although coordination with AT&SP would be required for pipeline boring activities. Because this alternative is an infrastructure improvement project and pedestrians and bicyclists would not use the site for transportation or recreational purposes, no impacts associated with traffic hazards would occur. Construction of the disposal pipeline across I Dutch Slough would require the City to contact the U.S. Coast Guard 2 weeks before the construction period to notify the maritime community of activities affecting navigation. I i Cultural Resources Setting. The City's general pian E1R indicates that the areas west of Marsh Creek could be sensitive archaeological and historical resource areas. Areas along creeks and foothills are identified as particularly sensitive because the possibility of historic and prehistoric habitation is greater near water sources. l Several cultural resource studies have been conducted within 0.25 mile of the proposed conveyance pipeline alignment, but only one cultural resource study has been conducted along the alignment. This study conducted by Busby (1976) covered the area along Cypress Road and the conveyance pipeline alignment for approximately 1 mile. Several study areas abut or cross the alignment. The cultural resources inventory study area for the Los Vaqueros Project water conveyance alignments (Bramlette et al. 1991) abutted the alignment to the east where it parallels Marsh Creek. A study by West (1982) covered the AT&SF alignment through the area. A study by West and Welch (1996) covered the area parallel to the Contra Costa Canal and the location of the proposed alignment. City of Brentwood WWTP Project Chapter 5. Alternatives Analysis Draft EIR 5-18 June 26. 1998 i The record search revealed no previously recorded cultural resource sites along this alternative alignment. Two historic sites are located within 0.5 mile of the alignment, but are far enough removed that they would not be affected by construction in the project area. i Two Jones& Stokes Associates archaeologists surveyed the conveyance pipeline alignment covering 14 meters on either side of the road from the Brentwood WWTP to Sellers Avenue and along Sellers Avenue and Cypress Roads. The alignment along the west side of Marsh Creek and through a cattle pasture to the new ISD WWTP site was examined by one Jones&Stokes Associates archaeologist covering a 10-meter corridor. In all cases, visibility was poor because of vegetation and disturbance, and no cultural resources were located during these surveys. The disposal pipeline alignment received a reconnaissance-level evaluation. The record search indicated that no cultural resource studies have been conducted along this alignment, and no { previously recorded cultural resource sites are located within a 0.5-mile radius of the alignment. The cultural resources investigation conducted for ISD's Wastewater Facilities Plan EIR 3 indicated that no archaeological sites have been identified on the ISD WWTP site. The EIR did indicate that one site(CA-CCO-5),a prehistoric burial site,is located on western Jersey Island. The EIR.recommended mitigation measures to reduce effects on this resource to a less-than-significant level (Ironhouse Sanitary District 1994). Impacts. Previous surveys of the Alternative 2 project area and a records search of the Historical Resources Information System conducted at the Northwest Information Center at Sonoma State University indicate that no previous archaeological or historic resources are located near the pipeline alignments. Archaeological surveys for the project area failed to locate any cultural resources that would be affected by this alternative. Although no sites have been identified within the project area,project implementation could potentially disturb previously undiscovered cultural or paleontological resources, including human remains. This alternative includes environmental control measures as described above that would minimize potential impacts on archaeological, paleontological, or historic sites or remains. Environmentally Superior Alternative i An EIR is required to identify the environmentally superior alternative from among the range of reasonable alternatives that are evaluated. Generally, the environmentally superior alternative would be the alternative that would achieve the most goals and objectives of the proposed project and would cause the least damage to the biological and physical environment. If the No-Project Alternative would be the environmentally superior alternative,the EIR.should also identify an environmentally superior alternative from among the other alternatives that were considered in detail in the EIR. Chy of Brentwood WWTP Project Chapter S. Alternatives Analysis Draft EIR Jane 16, 1998 5-19 i The proposed City of Brentwood wastewater treatment plant expansion project is considered the environmentally superior alternative. Because the City is also evaluating Alternative 2, raw sewage conveyance to ISD,as part of a separate,parallel environmental process,the proposed project and Alternative 2 represent the range of reasonable alternatives to provide wastewater treatment and disposal service for Brentwood's service area. The proposed project is the environmentally superior alternative because it would involve the least amount of physical disturbance during construction and 1 virtually all of the WWTP effects would occur within an enclosed compound that has already been a highly disturbed. The WWTP would also be designed to meet all surface water discharge requirements of the RWQCB. Although environmental control measures have been designed into j Alternative 2 that would reduce all effects to acceptable levels, it would involve more extensive I physical construction effects than the proposed project and would require considerably more regulatory permits for crossings of Marsh Creek, Dutch Slough, the Contra Costa Canal, and the AT&SF railroad. I I i 1 I i I i i I City of Brentwood WKTP Project Chapter 5. Alternatives Analysis Draft EIR 5-20 V20 June 26, 1998 List of Acronyms and Abbreviations ARB California Air Resources Board NA14C Native American Heritage Commission AT&SF Atchison,Topeka&Santa Fe Railroad NDDB Natural Diversity Data Base NHPA National Historic Preservation Act BAAQMD Bay Area Air Quality Management District NO, nitrogen dioxide Basin Plan Water Quality Control Plan NOP notice of preparation BOD biological oxygen demand NO,, nitrogen oxide Business Plan Act Hazardous Materials Release Response NPDES National Pollutant Discharge Elimination System Plans acid Inventory Law of 1985 NRHP National Register of Historic Places NTU nephelometric turbidity units CCCHSD Contra Costa County Health Services Division CCCMVD Contra Costa County Mosquito and Vector PG&E Pacific Gas and Electric Company Control District PM10 inhalable particulate matter €0 microns in diameter CEQA California Environmental Quality Act ppd pounds per day efs cubic feet per second ppt parts per thousand City City of Brentwood CNPS California Native Plant Society ROO reactive organic gases CO carbon monoxide RWQCB California Regional Water Quality Control Board, Corps U.S.Army Corps of Engineers Central Valley Region dB decibel SFBAAB San Francisco Bay Area Air Basin dBA A-weighted decibel SHPO State Historic Preservation Officer Delta Sacramento-San Joaquin River Delta so, sulfur dioxide DFG California Department of Fish and Game SRF State Revolving Fund DHS California Department of Health Services SWPPP stormwater pollution prevention plan DO dissolved oxygen SWRCB California State Water Resources Control Board EC electrical conductivity tpy tons per year ECCID East Contra Costa County Irrigation District EIR environmental impact report USFWS U.S.Fish and Wildlife Service EPA U.S.Environmental Protection Agency ERCP Emergency Response and Contingency Plan VELB valley elderberry longhorn beetle ERQWA Effluent and Receiving Nater Quality Assessment WDR waste discharge requirement FCWCD Contra Costa County Flood Control and WHR. wildlife habitat relationship Water Conservation District WWTP wastewater treatment plant FEMA Federal Emergency Management Agency y4g/m3 micrograms per cubic meter hp horsepower 4s/cm microsiemens per cubic meter ISD Ironhouse sanitary District ISWP/EBEP Inland Surface Water Plan and Enclosed Bay and Estuary Plan kV kilovolt kWh kilowatt-hours LAFCO Local Agency Formation Commission L, day-night average sound level Lcq noise-level equivalent mgd million gallons per day mg/l milligrams per liter MPN/100 ml most probable number per 100 milliliters 5-21 List of Acronyms and Abbreviations ARB California Air Resources Board NAHC Native American Heritage Commission AT&SF Atchison,Topeka&Santa Fe Railroad NDDB Natural Diversity Data Base NHPA National Historic Preservation Act BAAQMD Bay Area Air Quality Management District NO, nitrogen dioxide Basin Plan Water Quality Control Plan NOP notice of preparation BOD biological oxygen demand NOx nitrogen oxide Business Plan Act Hazardous Materials Release Response NPDES National Pollutant Discharge Elimination System Pians and Inventory Law of 1985 NRNP National Register of Historic Places NTU nephelometric turbidity units CCCHSD Contra Costa County Health Services Division CCCMVD Contra Costa County Mosquito and Vector PG&E Pacific Gas and Electric Company Control District PM10 inhalable particulate matter 10 microns in diameter CEQA California Environmental Quality Act ppd pounds per day cfs cubic feet per second ppt parts per thousand City City of Brentwood CNPS California Native Plant Society ROG reactive organic gases CO carbon monoxide RWQCB California Regional Water Quality Control Board, Corps U.S.Army Corps of Engineers Central Valley Region dB decibel SFBAAB San Francisco Bay Area Air Basin dBA A-weighted decibel SHPO State Historic Preservation Officer Delta Sacramento-San Joaquin River Delta SOZ sulfur dioxide DFG California Department of Fish and Game SRF State Revolving Fund DHS California Department of Health Services SWPPP stormwater pollution prevention plan DO dissolved oxygen SWRCB California State Water Resources Control Board EC electrical conductivity tpy tons per year ECCID East Contra Costa Count),Irrigation District EIR environmental impact report USFWS U.S.Fish and Wildlife Service EPA U.S.Environmental Protection Agency ERCP Emergency Response and Contingency Plan VELB valley elderberry longhorn beetle ERQWA Effluent and Receiving Water Quality Assessment WDR waste discharge requirement FCWCD Contra Costa County Flood Control and WHR wildlife habitat relationship Water Conservation District W WTP wastewater treatment plant FEMA Federal Emergency Management Agency µg/m' micrograms per cubic meter hp horsepower uSlem microsiemens per cubic meter ISD Ironhouse Sanitary District ISWP/EBEP Inland Surface Water Plan and Enclosed Bav and Estuary Plan kV kilovolt kWh kilowatt-hours LAFCO Local Agency Formation Commission L, day-night average sound level L.q noise-level equivalent mgd million gallons per day mg/l milligrams per liter MPN/100 ml most probable number per 100 milliliters 5-21 i a Chapter 6. Citations PRINTED REFERENCES Bay Area Air Quality Management District. 1991. Bay Area 91 clean air plan (CAI'): implementing all feasible controls. Draft. April. San Francisco, CA. Bay Area Air Quality Management District. 1996. BAAQMD CEQA guidelines, assessing the air I quality impacts of projects and plans. San Francisco, CA. Bay Area Air Quality Management District. 1997a. Bay Area 97 clean air plan (CAP): December. San Francisco, CA. Bay Area.Air Quality Management District. 1997b. Brentwood wastewater treatment plan source emissions. (Unpublished data--computer printout for Plant #10979.) October 21, 1997. San Francisco, CA. Beck,W. A., and Y. D. Haase. 1974. Historic atlas of California. University of Oklahoma Press. Norman, OK. Beedy, E. C., and W. J. Hamilton. 1997. Tricolored blackbird status update and management guidelines. September. (Jones & Stokes Associates 97-099.) Sacramento, CA. Prepared for U.S. Dish and Wildlife Service, Portland., OR, and California Department of Fish and Game, Sacramento, CA. j Bramlette,A. G., M. Praetzellis,D. A.Fredrickson,and A. Praetzellis. 1991. A summary inventory of archaeological resources within the Los Vaqueros project area,Alameda and Contra Costa Counties, California. On file at the Northwest Information Center of the California i Historical Resources Information System, Sonoma State University, Rohnert Park, CA. Brentwood, City of. 1993. City of Brentwood general plan 1993-2010. June. Brentwood, CA. Brentwood, City of. 1998. Discharge monitoring reports for the City of Brentwood wastewater treatment plant, 1991-1997. Unpublished data.. Brentw000d, CA. Busby, C. 1. 1995. Cultural resources assessment, parcel located in the vicinity of Liberty Link Highway and Sunset Road, City of Brentwood, Contra Costa County, California. On file at the Northwest Information Center of the California Historical Resources Information System, Sonoma State University, Rohnert Park, CA. City of Brentsvo©d 4Yt+TP Project Chapter 6. Citations Draft c1R June 16, 1998 6-1 i i Busby, C. I. 1976. East/central Contra Costa County wastewater management plan, California, cultural resources survey. On file at the Northwest Information Center of the California Historical Resources Information System, Sonoma State University, Rohnert Parr, CA, f i California Air Resources Board, 1997. California air quality data. Summary of air quality data, Volumes XXI, XXII, XXIII, and XXIV. Sacramento, CA. 1 California Department of Fish and Game. 1995. Staff report on burrowing owl mitigation. Sacramento, CA. California Department of Health Services. 1981 Manual of good practice for land spreading of sewage sludge. Sacramento, CA. California Department of Parks and Recreation. 1992. California points of historical interest. May 1, 1992. Office of Historic Preservation. Sacramento, CA. California Department of Water Resources and U.S. Bureau of Reclamation. 1994. Biological assessment: effects of the Central Valley Project and State Water Project on delta smelt and Sacramento splittail. August. Sacramento, CA. Prepared for U.S. Fish and Wildlife Service, Ecological Services Division, Sacramento Field Office, Sacramento, CA. i i California Regional Water Quality Control Board, Central Valley Region. 1995. Water quality control plan for the California Regional Water Quality Control Board, Central Valley Region. Sacramento, CA. California Regional Water Quality Control Board,Central Valley Region 1996. Waste discharge requirements for the City of Brentwood wastewater treatment plant, Contra Costa County. (Order No. 96-039.) Sacramento, CA. i t California State Water Resources Control Board. 1997. Draft policy for implementation of toxics standards for inland surface waters, enclosed bays, and estuaries of California and accompanying functional equivalent document. Sacramento, CA. i Contra Costa Water District. 1998. Your drinking water- annual water quality report. January - December 1997. Concord, CA. 1 Emanuels, G. 1986. California's Contra Costa County: an illustrated history. Panorama West Books. Fresno, CA. Fredrickson, D. A. 1973. Early cultures of the North Coast Ranges, California. Ph.D. dissertation. 11 University of California, Davis, Department of Anthropology. Davis, CA. 1 Hickman, J_ D. (editor). 1993. The Jepson Manual: higher plants of California. University of California Press. Berkeley, CA. City of Brentwood WWTP Project Chapter 6. Citations Draft EIR 6-2 .lune 76, 1998 i I i i Hoover, M. B.,H. E. Rensch, E. G. Rensch,and W.N. Abeloe. 1990. Historic spots in California. Revised by Douglas E. Kyle. Stanford University Press, Stanford, CA. Ironhouse Sanitary District. 1994. Ironhouse Sanitary District wastewater facilities plan and Delta Environmental Science Center final environmental impact report (SCH # 92093042). Oakley, CA. Prepared by Environmental Science Associates. James M. Montgomery. 1991. Ironhouse Sanitary District wastewater facilities expansion plan. Jennings, M. R., and M. P. Mayes. 1994. Amphibian and reptile species of special concern in California.. California.Department of Fish and Game, Inland Fisheries Division. Rancho Cordova, CA. .Tones & Stokes Associates, Inc. [In prep.] Cultural resources inventory and evaluation report for the City of Brentwood wastewater facilities expansion project, Contra Costa County, California.. Jones&.Stokes Associates,Inc. 1998a. Initial study/negative declaration for the City of Brentwood short-term wastewater treatment plant improvement project. January 1 , 1998. (JSA 97- 328.) Sacramento, CA. Prepared for the City of Brentwood, Public Works Department, Brentwood, CA. Jones&Stokes Associates,Inc. 1998b. Initial study/mitigated negative declaration for the City of Brentwood raw sewage conveyance to Ironhouse Sanitary District. Screen-check draft. (JSA 97-328.) March 17, 1998. Sacramento, CA. Prepared for the City of Brentwood Public Works Department, Brentwood, CA. Levy,R. 1978, Eastern.Miwok, Pages 398-413 in R. F.Heizer(ed.),Handbook of North American Indians,Volume 8—California. Smithsonian Institution. Washington, DC. Montgomery Watson.Consulting Engineers. 1993, Phase I environmental site audit, Jersey Island, Contra Costa County, California. Walnut Creek, CA. Montgomery Watson Consulting Engineers. 1997x. City of Brentwood wastewater facilities plan. June. Walnut Creek, CA. Prepared for the City of Brentwood, Brentwood, CA. Montgomery Watson Consulting.Engineers. 1997b. Technical memorandum-----City of Brentwood Effluent Receiving Water Quality and Assessment(ERQWA)study. May 29, 1997. Walnut Creek, CA. Prepared for the City of Brentwood, Brentwood, CA. Montgomery Watson Consulting Engineers. 1997c. Technical report on dissolved oxygen and electrical conductivity in Marsh Creek. February. Walnut Creek.,CA. Prepared for the City of Brentwood, Brentwood, CA. Moratto, M. J. 1984. California archaeology. Academic Press. San Francisco, CA. City of Brentwood WGYTP Project Chapter d. Citations Draft EIR June 26, 1998 6-3 Moyle, P. B. 1976. Inland fishes of California. University of California Press. Berkeley, CA. Moyle, P. B., and B. Herbold. 1989. Status of the delta smelt, Hypomesus transpacifzcus. Sacramento, CA. Prepared for U.S. Fish and Wildlife Service, Office of Endangered Species, Sacramento, CA. Moyle, P. B., B. Herbold, D. E. Stevens, and L. W. Miller. 1992. Life history and status of delta smelt in the Sacramento-San Joaquin estuary, California. Transactions of the Amorican Fisheries Society 121:67-77. i Natural Diversity Data Kase. 1997. Computer report of special natural communities, animals, and plants for the Brentwood 7.5-minute quadrangel. February 1998. California Department of Fish and Game. Sacramento, CA. Remsen, J. V. 1978. Bird species of special concern in California. California Department of Fish and Game. Sacramento, CA. i Skinner, M. W., and B. M. Pavlik. 1994. Inventory of rare and endangered vascular plants in California. 5th edition. (Special Publication No. 1.) California Native Plant Society, Sacramento, CA. I Smith, M., and S. Baker. 1989. Archaeological reconnaissance of subdivision MS 48-88, near Knightsen, Contra Costa County, California. On file at the Northwest Information Center of the California Historical Resources Information System, Sonoma State University, Rohnert Park, CA. Sonoma State University Academic Foundation, Inc., Anthropological Studies Center. 1992. Evaluation request for determination of eligibility, and effect for the Los Vaqueros Project, Alameda and Contra Costa Counties, California. May. Rohnert Park, CA. With assistance from Jones& Stokes Associates,Inc., Sacramento, CA(JSA 91-221), and Woodward-Clyde Consultants, Oakland, CA. Prepared for Contra Costa Water District, Concord, CA. Stevens, D. E. 1989. When do winter-run chinook salmon smolts migrate through the Sacramento- San Joaquin Delta? June 19, 1989. California Department of Fish and Game. Stockton, CA. Stevens, D. E., L. W. Miller, and B. C. Bolster. 1990. Report to the Fish and Game Commission: a status review of the delta smelt (Hypomesus transpacijlcus) in California. (Candidate Species Status Report 90-2.) California Department of Fish and Game. Stockton, CA. The Planning Center. 1993. City of Brentwood general plan final environmental impact report. Prepared for the City of Brentwood Community Development Department, Brentwood, CA. i City of Brentwood WW7P Project Chapter 6. C;talions Draft EIR 6-4 June 26, 1998 i U.S. Bureau of Reclamation. 1983. Class II archaeological survey,San Luis Drain and alternatives, Central Valley Project, San Luis Unit, California. On file at the Northwest Information Center of the California Historical Resources Information System, Sonoma State University, ! R.olert bark,CA. U.S. Sail Conservation Service. 1977. Soil survey of Contra Costa County. Concord, CA. Prepared in cooperation with University of California Agricultural Experiment Station. Wang, J. C. S. 1986. Fishes of the Sacramento-San Joaquin estuary and adjacent waters, California: a guide to the early life histories. (FS/10-4ATR86-9.) California Department of 'hater Resources. Sacramento, CA. Prepared for Interagency Ecological Study Program for the Sacramento-San Joaquin estuary, Sacramento, CA. Wang, J. C. S. 1991. Early life stages and early life history of the delta smelt, Hypomesus transpacificus, in the Sacramento-San Joaquin estuary, with comparison of early life stages of the longfin smelt, Spirinchus thaleichthys. (FS/BIO-IATR.I91-28. Technical Deport 28.) California Department of Water Resources. Sacramento, CA. Prepared for Interagency Ecological Studies Program for the Sacramento-San Joaquin Estuary, Stockton, CA. West, G. J. 1982. Class Il archaeological survey,Kellogg unit reformulation,Contra Costa County, California. On file at the Northwest Information Center of the California Historical Resources Information System. Sonoma State University, Rohnert Park, CA. West, G. J., and P. Welch. 1996. Class 11 archaeological survey of the Contra Costa Canal, Contra Cresta County, California. On file at the Northwest Information Center of the California Historical Resources Information System, Sonoma State University, Rohnert Park, CA. Williams,D. F. 1986. Mammalian species of special concern in California. (Wildlife Management Division Administrative Report 86-1.) California Department of Fish and Game, Sacramento, CA. Yates,M. V. 1993. Pathogens in reclaimed water. University of California, Riverside,Department of Soil and Environmental Utilities. Riverside, CA. PERSONAL COMMUNICATIONS Boucher, Mark. Civil engineer. Contra Costa County Flood Control and Water Conservation District,Martinez,CA. November 11, 1395—facsimile transmittal to Jenny Skrel(then with Montgomery Watson Consulting Engineers) of unpublished streamflow measurements in Marsh Creek. City of Brentwood WW7P Project Chapter& Citations Draft EIR June 2d, 1998 6-5 Carlson, Mike. Civil engineer. Contra Costa County Flood Control and Water Conservation District, Martinez, CA. February 2, 1998—telephone conversation with Jeff Lafer. i Gaston, Carl. Plant superintendent. City of Brentwood Department of Public Services, Brentwood, CA. January 28, 1998--discussion during site visit; February 17, 1998—facsimile transmittal of contingency and emergency response plans;and February 24, 1998--telephone conversation. Larson, S. 1998. Wildlife biologist. U.S. Fish and Wildlife Service, Sacramento, CA. Telephone conversation. Lau, Warren. Distribution engineer. Pacific Gas and Electric Company, Brentwood, CA. March 20, 1998 -telephone conversation. Parsons, Dave. City of Brentwood Department of Public Services, Brentwood, CA. October 27, 1997—telephone conversation; October 28, 1997—facsimile transmittal of information on mosquito abatement. Skrel, Jenny. Civil engineer. G. S. Dodson & Associates (formerly with Montgomery Watson Consulting Engineers), Walnut Creek, CA. February 19, 1998—telephone conversation; March 13, 1998---facsimile transmittal of excerpts from June 26, 1987 geotechnical report for existing WWTP. Vesley, Martin. Design engineer. JMZ Associates. April 7, 1998 -telephone conversation. Walker, Rochelle. Public records administrator. Bay Area Air Quality Management District, San Francisco, CA. February 13, 1998—letter with printout of BAAQMD odor complaints for the City of Brentwood's wastewater treatment plant and printout of the plant's air permit with the BAAQMD. Williams,Tom. Senior civil engineer. Contra Costa County Flood Control and Water Conservation District, Martinez, CA. April 1, 1998 -telephone conversation with Jeff Lafer. I i Cihy of Brentwood WWTP Project Chapter E. Citations Draft EIX 6-6 June 26, /998 i _.-..... Chapter 7. List of Preparers This draft environmental impact report was prepared for the City of Brentwood Public Works Department by Jones & Stokes Associates. Individuals who contributed to this report are listed below. CITY OF BRENTWOOD Thom Dead-Public Services Director Winston Rhodes-Associate Planner i Paul R. Eldredge- Assistant Engineer G. S. DODSON& ASSOCIATES { Jenny Skrel -Project Manager JONES & STOKES ASSOCIATES I Harlan Glines - Principal-in-Charge Steve Centerwall -Project Manager Christine Engel- Assistant Project Manager Shahira Ashkar- Cultural Resources Jeff Lafer- Hydrology and Water Quality; Geology, Soils, and Seismicity; Jeff Lafer- Public Health and Safety Tim Pdmpo - Air Quality Todd Sloat- Biological Resources Debra Lilly - Publication Specialist Charla McCollum - Word Processing Operator Bev Fish - Report Production City of Brentwood WRTP Project Chapter i. List of Preparers Draft EIR June 26, 1948 7-1 I f i' i f { I I { l { City of Brentwood WWTP Project Chapter i. List of Preparers Draft EIR June 26, 1998 7-2 i i I Appendix A. Notice of Preparation j i NTWODD Notice of Preparation TO: NOTICE AND ATTACHMENTS FROM: City of Brentwood, Public Services Department SENT TO ADDRESSES ON ATTACHED LIST 708 Third Street Brentwood, California 94513 j Subject. Notice of Preparation of a Draft Environmental Impact Report In accordance with the California Environmental Quality Act(CEQA)(Public Resources Code Sections 21000 et seq.)and the State CEQA Guidelines(Title 14,California Code of Regulations, Sections 15000 et seq.),this Notice of Preparation is hereby sent to inform you that the City of Brentwood Public Services Department will be the Lead Agency and will prepare an environmental impact report(EIR)for the project identified below_ We need to know the views of your agency as to the scope and content of the environmental information which is germane to your agency's stavitory responsibilities and/or concerns in connection with the proposed project. Your agency will need to use the EIR prepared by our agency if considering a permit or other approval for the project. i The project description,location,and the potential environmental effects are contained in the attached materials. A copy of I the initial study(FJ is F2] is not ) attached. Due to the time limits mandated by State law,your response must be sent at the earliest possible date but no later than 30 days after receipt of this notice. Please send your response to Thom Head.Public Services Director. at the address shown above. Please also include the name and telephone number for a contact person in your agency. Project Title City of Brentwood Long-Term Wastewater Treatment Plant Project Project Applicant,if any City of Brentwood, Public Services Department 3' Y Date December 19, 1997 Signature t(j4} f Title Public Services Director Telephone 510/634-6920 Reference:California Administrative Code, Title 14, Sections 15082(a), 15103, 15375. City}calf-706 Third Street,Brentwood,California 94613 * (510)634-6900 * Fax:(510)634-6930 Police Department-500 Chestnut Street,Brentwood,California 94513 * (510)634-6911 Fax:(510)634-6919 A-1 i 1 NOTICE OF PREPARATION OF All' ENVIRONMENTAL IMPACT REPORT 3 PROJECT DESCRIPTION, LOCATION, AND SUMMARY OF ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED Overview 'i The proposed City of Brentwood(City)Wastewater Facilities Expansion Project(the Project) concerns City wastewater treatment facilities located in eastern Contra Costa County and is comprised of three principal components. The three principal components are as follows: ■ a phased capacity expansion and upgrade for the City's existing wastewater treatment facilities from 1.8 million gallons per day (mgd) to 10 mgd, • discharge of treated effluent into Marsh Creels, and i • expansion of the City's sludge handling facilities to allow disposal to land or landfill. I Background I 1 The City of Brentwood is located in the Sacramento-San Joaquin Delta area on the western edge of the San Joaquin Valley, approximately 50 miles east of San Francisco (Figure 1). The f population of the City has grown consistently since the City was incorporated 1948. This population growth required updating the City's General Plan in 1983. The population has continued the grow rapidly since 1983, and growth pressures have required the continued general expansion of City public works services, including wastewater treatment capacity. Expansion of the existing wastewater treatment plant (WWTP) to accommodate growth was addressed in a Wastewater Facilities Plan prepared in June 1997 by the City. The project area is located in the northeast portion of the Brentwood planning area north of Sunset Road and east of Marsh Creek. The project site is currently designated as Public Facilities in the General Plan land use map and is consistent with the General Plan and the Zoning Ordinance. Major project area land uses include Sunset Park and an apple orchard to the south and a solid waste transfer station and an agricultural processing area to the southeast. A-2 i ............................................................................................ _. __ Z 680 780 River Suisun Bay Benicia 0 30 a 52P o Pittsburg 4 0 Antitsch 0 Concord O oaklely t 4 680 ats Ot ti Brentwood 24 a Walnut Creek ,ia CO f a C p Byron Clifton q� Court -� 680 Forebay costa co, a Dublin 580 Livermore N 0 5 Miles t Figure 1 Regional Location of Brentwood A-3 Existing Wastewater Treatment Facilities The existing WWTP is located on approximately 70 acres of City-owned land and abuts Marsh Creek(Figure 2). The existing WWTP was designed to accommodate an average dry-weather flow of 1.8 mgd and a maximum peak wet-weather flow of 5 mgd. The existing WWTP was constructed in 1973 and consists of influent screw pumps, screening, secondary treatment using two oxidation ditches, secondary clarification, aerobic sludge digestion and sludge drying beds with effluent disposal to nine percolation ponds covering an area of approximately 18 acres. A perimeter groundwater extraction system is also present consisting of monitoring wells and a discharge pipeline that collects a portion of the infiltrated secondary effluent from the disposal ponds and groundwater and discharges the water into Marsh Creek under an National Pollutant Discharge Elimination System (NPDES) permit from the Central Valley Regional Water Quality Control Board (RWQCB). Recently, problems at the WWTP have arisen which have caused the RWQCB to become j concerned with the current and future capacity of the City's wastewater treatment plant. Specifically, there is increasing concern regarding percolation rates in the effluent percolation ponds, potential Marsh Creek bank failure and bank instability, and soil subsidence around Oxidation Ditch No. 1. On August 28, 1996, the RWQCB issued a letter requiring the City to submit a technical report assessing the capacity of the effluent percolation ponds and structural integrity of the treatment facilities. A report was prepared in October 1996. This report rated the current effluent disposal capacity at 1.4 mgd. Based on this,the City implemented the following effluent disposal improvements to increase capacity: z • secondary effluent is discharged during emergency situations to an area south of disposal pond No. 9, ■ groundwater is pumped from new and existing groundwater monitoring wells to lower the groundwater levels in order to enhance effluent disposal performance, and • a groundwater extraction system was installed between the disposal pond No. 6 and Marsh Creek. This allows the City to maximize use of disposal pond No. 6 while minimizing Marsh Creek bank instability. With growth expected to continue and completion of a long-term wastewater treatment and disposal solution not anticipated until the year 2001, interim improvements to increase disposal capacity were developed. The City chose to construct a new percolation pond south of the existing plant on property currently owned by the City. The City is in the process of preparing an Initial Study for this project. A-4 ......................... I . i %++X + , + a fXSSTtHG DtSPGSK � {31I.TSiM€ oiY1d rs CDNTAGT SASINS EASTING OMPOSAI POND�6 ' w t FM!' i 1 J15POSM. UMTtNG Os5Po5At POND s7 t i;pOSTWO a i i PONOS ................... ._._.....__.........._.... rt y .i.. .._.\ HEnRTIAPY AD'XORKS U ..•.•` 5PUT7ER EMSTING O*POSA4 POND-4 fliLT'ER5 AEc E7i7511NG aMESTOR E3 01COATION r FILM;PUW q- ! t .t uYCH 3U1ION . N :.................. ' r !!"I..ANT ..A SPUTTER 57HUC:URE"""�: �SECONO.WY CLARIFIERS, SUw e. A ••_. .,.., OHMN-UNK:ENOE ..' .,,,"EASMG D95POSAL POND 00 UFT STATION PUMP STAWk ',x,..54d �.sri . 0MATION DITCHES i................».. t % EASPPING .�;, •••• YNNTEMAHCB f OfCOAT90N DITCH#2 r .\. . ,..� _ ._.Y__...4�...._s..._._...._._....�.... *`^_.._..�_,a,,..._.......,;..k._._._", ` 2. ._..E%45T$tti,f.M*`.AC.EkCY.NSk.C11NG ........... ............_..................«_...,....... ..........._._......._»_.__........._.»._..._.......__.__.. ,.•........ . ..�........_._..........,e-..._..... ...._..,.._. [ �............:._._:._.-s.._..__....,.�.............._.._.._......_.... .....k. _ .....X._ ,c__'::;��:::::w<a::::;:z::vrat::..v::::::::•rx:::::::p:::r.::r.:::.:",.w..: E 7 Legend ,a. phase 1 (see nate 1) Phase 2 Phase 3 O 75 ISO Phase d eFoe Not®. Phase I indurfes opomfing wdsting WWTP at 0.8 MGD with afftuwt dtsposai to sAsting pe=1atfon ponds. Figure 2 Proposed Layout for City of Brentwood Treatment Facilities A-5 Project Objectives The objectives of the proposed project are to: o provide the necessary treatment and effluent disposal capacity to meet the demands of ? planned growth that has already been evaluated and approved under the General Plan, • provide cost-effective and reliable wastewater treatment and disposal facilities, e locate and operate the proposed new facilities in a manner that will minimize adverse environmental effects, and o maintain compliance with NPDES permit requirements of the RWQCB and protect water quality and public health. Project Description i Projected Flow and Effluent Quality The City's population is projected to grow to 100,000. Based on the projected population and growth, wastewater treatment capacity for a flow of 10 mgd will be needed and has been designated as the ultimate design flow for the proposed WWTP. Direct discharge of treated effluent to Marsh Creek, which is the proposed project disposal method, would require a higher level of treatment than is provided by the current land disposal system. Effluent would be required to be a filtered secondary effluent with no more than 10 mg/l of biochemical oxygen demand and suspended solids and disinfected to produce a total coliform count of 23 organisms/100 ml (most probable number). Effluent discharged to Marsh Creek would also need to meet the requirements stated in the California Toxics Rule, if adopted by the State. The City has also expressed an interest in producing an effluent suitable for unrestricted reuse. This will require that the effluent meet the requirements set forth in Title 22, Division 4 of the California Administrative Code, which are currently under revision. Proposed Project Facilities The proposed new facilities would be located at the existing WWTP site. The site layout for the new oxidation ditch treatment facilities is shown in Figure 2. The proposed oxidation ditch treatment train consists of influent pumps, screens, oxidation ditches, secondary clarifiers, tertiary filtration,and disinfection. The oxidation ditch process would be an extended aeration activated sludge system that would combine the ditch raw sewage with A-6 return sludge and oxygen. From the ditch,wastewater would flow to final clarifiers. The clarifiers would separate the clear liquid and sludge components of the mixed liquor suspended solids (MLSS),returning the sludge to the oxidation ditch while discharging the clear liquid to the tertiary filters and disinfection facilities. Disinfection will be by either liquid sodium hypochlorite/sodium bisulfate or ultraviolet light. Effluent would be discharged to Marsh Creek in the vicinity of the current E-2 discharge. A pipeline from the disinfection facilities would terminate at a concrete outfall structure that would be constructed on the banks of Marsh Creek_ Appropriate velocity dissipation and bank stabilization measures would be built into and around the structure. ' Sludge handling and dewatering would be accomplished using belt filter presses and post sludge drying beds. Sludge disposal would either be by land application or landfill and would meet the applicable Environmental Protection .Agency (EPA) regulations (e.g., 40 CFI. fart 503), as required. Flexibility will be provided to allow the City to use the existing aerobic digester and the two existing oxidation ditches for digestion of the sludge for the new facilities before dewatering. Construction of the proposed facilities would occur in four phases of 2.5 mgd each, as shown in Figure 2. Upon completion of Phase I facilities, the City would have a WWTP with a capacity of 3.3 mgd. In addition to the first of four new 2.5-mgd treatment trains being constructed, the existing facilities would be operated to treat 0.8 mgd with continued disposal of the 0.8 mgd to percolation ponds Nos. 6, 7, 8, and 9. Upon completion of Phase 4 facilities, the City would have a new WWTP with a capacity of 10 mgd and the existing facilities would be abandoned with the exception of those facilities converted for use as aerobic digesters. Project Schedule The proposed implementation schedule indicates that the environmental documentation would be completed by the fall of 1998. Predesign, design, and bidding are to be completed by August 1999. Construction is anticipated to be completed in August 2001. Alternatives to the Proposed Project The Wastewater Facilities Plan prepared by the City identified seven alternatives to address the long-term wastewater treatment and disposal needs for the City of Brentwood. The alternatives are the following: a Alternative 1 - Surface Discharge into Marsh Creek, • Alternative 2 - Surface Discharge into Indian Slough via East Contra Costa Irrigation District Main Canal, A-7 3 ■ Alternative 3 - Land Disposal (onsite and offsite), • Alternative 4 - Urban Reclamation, i ■ Alternative 5 -Agricultural Reclamation, • Alternative 6 - Conveyance of Raw Sewage to Ironhouse Sanitary District(ISD), and • Alternative 7 -Conveyance of Secondary Effluent to ISD. The evaluation conducted in the facilities Pian rated Alternative 1 - Surface Discharge into Marsh Creek and Alternative 6-Conveyance of Raw Sewage to ISD as essentially equal alternatives in regards to cost and noneconomic considerations. The ISD facilities are Ic mted on Oakley, which is north of the City of Brentwood. In October 1994, ISD completed the final Environmental Impact Report (EIR) for Ironhouse Sanitary District Wastewater Facilities Plan and Delta Environment Science Center. The EIR described expansion of current ISD wastewater facilities from 2.3 mgd to 8.0 mgd. To evaluate the alternative of sending raw sewage to ISD,a mitigated negative declaration will be prepared and this alternative will be addressed in the proposed EIR. Approvals and Special Requirements The proposed project will be reviewed by various federal, state, and local agencies that will use the environmental document to evaluate the compliance of the project with regulatory requirements. The following agencies and actions are expected to be involved in project approval and implementation: I • the RWQCB would need to issue a new NPDES permit; ® a stormwater NPDES permit for construction activities would be required from the State Water Resources Control Board; r • the Bay Area Air Quality Management District would need to review the project for i conformance with its regulations and revise the existing air quality permit accordingly; • the California Department of Fish and Game would need to review the project to determine whether impacts on fish or wildlife habitat could occur, and a streambed alteration agreement, pursuant to Section 1601 of the Fish and Game Code, may be required for the project; m the U.S.Army Corps of Engineers(Corps)would need to review the project to determine vhether impacts on waters of the United States (e.g., Marsh Creek) would occur; activities subject to Corps jurisdiction may be addressed under the nationwide permitting program. A-8 The California State Water Resources Control Board would need to review the project because the City anticipates obtaining funds to build the project through the State Revolving Find Loan Program. i Summary of Environmental Factors potentially Affected The California Environmental Quality Act Guidelines(State CEQA Guidelines)allow a lead agency to skip initial environmental review of a proposed project if it determines that an EIR. is clearly required(Section I5060[c]). The City of Brentwood, as lead agency,has already determined through previous studies that the proposed project has the potential to adversely affect several environmental factors that must be evaluated under CEQA. Therefore,an initial study checklist has not been included with this NOR The EIR.will address all issues adequately but will be focused on the issues listed below and any other relevant issues identified during this scoping process. The proposed project has the potential to create a "significant impact" related to the environmental factors listed below. A brief description of the main environmental factors on which the EIR is expected to be focused is presented below. r Hydrology and Water Quality. The hydraulic capacity and flood potential of Marsh Creek could be affected by the proposed maximum discharge of 10 mgd. Water quality parameters,such as temperature,ply,dissolved oxygen,electrical conductivity,and trace metals, could also be affected. The discharge must be evaluated with respect to compliance with future NPDES permit conditions that would be required by the RWQCB. The beneficial uses of additional flow in Marsh Creek will also be evaluated, including potentially improving water quality in Marsh Creek during dry periods. a Geologic Conditions and Seismicity. The project area is located in an area with known seismic faults and soils that are potentially subject to liquefaction. a Biological Resources. There is very little habitat on the project site. The potential creation of habitat on the project site will be evaluated. In addition., burrowing owls, which are a state species of special concern, are known to occur in the project area. a Public Health and Safety. The proposed project must be evaluated with respect to attraction of vectors (e.g., mosquitos), generation of odors, and handling of hazardous materials. 8 Air Quality. The proposed project has the potential to affect air quality as a result of particulate emissions during construction, emissions from treatment processes, and odor generation. a Cultural Resources. According to the City of Brentwood General Plan, archeological, ethnological, or historic resources have been recorded in the general project area. No cultural resources have been identified to date on the project site. A-9 i ■ Growth-Related Issues. The State CEQA Guidelines require that the potential for the ' proposed project to result in growth-inducing impacts and to remove obstacles to population growth be evaluated. i i i i i I i I A-10 4 Pact c on and 9WW4 Camp" Odlo Division 2111 Hillueo Av= ' Antioch.CA 945M Janusry 12,=1990 j ( , Mr, Thorn Head i Publit.Servipes(W or of amntwoo�i ' 7th '�'hird Street; B r ntwood,�A X4513 R EIR, Waste Water Treatment.Plant Project north of Sut set Road &, eastof Marsh Creek €3rentwpod Dear Mr. Head. Thank you for giving me the opportunity to comment on your project at your Wi tstL-Water Tr4atment Plant in Brentwood. Jur Electric Planning and Er ineering Department has a few' questions I hope you can answer for us; 1. What is 9 W load of each phase? 2. What is the>s�a of motors required? 3. What type oflstarrting will be used?' 4. What is the tkning on each phase of the project? 5. What level ofservice would be required, {alternate feed, etc:}? Vers to the above questions will help us plan ahead for serving your pr je' t i If 1►ou have eny 4uestions, plerse,call me at(510) 779-7714. Si 1wrely, i 4 G mo Tedd6r Sr. New Bu4iness Representative. ' v Gilg ` iy x E F closures, pt CIT wOf s slu cc, &rL A-1 I t Ax i IRONHOUSE SANITARY DISTRICT Telephwt e ; �6 825.0169 450 Wdinut Meadows Drive • P.O.Box 1105 - Oakley,CA 94561 (510)625-22'79 i February 1.8, 1998 t 'Whom Had, Public Services Director City of. entwooc city Hal ! . j ,i 708 Thir Street �'.; Brentwood, CA.9 6I RE: Ci y of Bre�. twood Lang-Term Wastewater Treatment Plant roject Dear Th m: I writinj to you in regard to the Draft EIR that Brentwood is preparing for its LangTerm Wistewater Treatment Plant Project. As explained in the Notice of Preparation you bushed on December 19, 1997, a mitigated negative declaration will also a prep fed to evaluate the alternative of sending raw sewage to Ironhouse, and this lternatiVe will be addressed in the proposed EIR. In conversioAs we have had in our prior meetings on this subject, we undersea d that the mitigated negative declaration will be published separately and likely pr or to thel Draft EIR. We also understand that in addressing the alternative of sendii ig raw sdwage to lronhouse, both documents wilt rely in part on the Final EIR that Ironhou�e completed in'October, 1994. Ir nhouse evill have the opportunity.,to review and comment on bath of these dacvme is durin the formal public period. But I think it would be in both our interests iflronho4se could review the administrative drafts of the mitigated negative declarat" nand e Draft EIR-before they are published for public review. I ave twd primary reasons for this request. One, Ironhouse review of the -adminisi rative. drafts would eliminate any possibility for any inadvertent misi>nte retafiari of-the inforrnation, analysis and conclusions contained in. the Ironhio a Final IR. I would hate to see anything appear in the Draft EIR, that is uninttent onally at variance with the District's Final EIR. i i A-12 j ............................................. _ _ ................................................ f Paget ; Thom He 1ad February 18, 199 TV o,given the particular interest of'Ironhou;se in the alternative of sending raw sewage to our facility,;we would like to informally offer our comments on hover this subject is treated! in the Draft EIR while these two documents are stall at the t administ ative'le�,el. ;since these comments will be informal, you will be free to accept or reject th trt, but we thinly you will find any comments we do of'f'er(and we may ham none)t'be useful. f µ- Plo we call �ne after you receive this letter to give me your thoughts on this E request. f f j Sincerely, { David N. Bauer General Manager IRONHOUSE SA.I~3TTA.It.Y DISTRICT I t r i i F i I if 4 • ,crsblvrp�5 E ! dR6C3"h .�It. t ` F am ISIS Bow of[hector } A-I3 TOTAL P.il l FB 10 8 Mr. ora Head l?64 Services Director City Orentwodd Public Works 0 armment FEB �`w 708 ird Street if 1 1 ig > tf$:13''ster Bren ood, CA 44513 �11YOF s Dear r. Head: �iyitliiliWOWS rn.a f It'sltt:Wpfcr NEGATIVE DE LARATIONANMAL STUDY(ND/IS) FOR CITY OF BRENTWOOD -SNORT me. TE WASTOATER TREATMENT PLANf'MPROVENIIrNT PROJECT-(SC ht#98 1205 �tlj�g,tddress: s`. l' f9�z12 Than you for than opportunity to review.the above document. As you may know,the State Water i�na:CA Resou ces Contrdl Board (SWR•+CB), Division of Clean Water Programs is responsible for 4#7A�2120 admin stering Stale Revolving Fund (SRF)loans for eligible wastewater treatment projects. If the A4 4'x.s�+ect, City Brentwocg will be seeking funding from the SWRCA to assist in financing the above =,his�,,ftA refers administering projedt, the SWR will bra responsible agency under CEQA, and will use the final envi. ental document when deciding whether to approve a loran for the project. Fil,�tt9t6)223.4949 If you wish to pct flue SRF funding for this project, please contact Mr. Gus Atkins of this Division at ' + (916) 7-4475 r garding inclusion on the Statewide SRF Priority fist. We have enclosed a copy of the S CBs Poi o icy for SRF Loans for your information. We are also enclosing a copy of the updated environn`iental:guidelines,which replace the environmental guidelines in Appendix E of the SRF . licy. i For an SRF loam f please provide us with-a copy of: (1) the approved Mitigated Negative Declaration; (2)the resolution!adopting the Negative Declaration and making CEQA fibdings; (3)all comments receiv during�e review period and your responses to those comments; and (4) the Notice of Deten,iination filo with the Governor's Office of Planning and Research, when they become available. i I Proj which inlvolve an SRF Ion. which is partially funded by the U.S. Environmental Protection Agen (EPA), r qt additional "NEPA-like" cnvironmcntal documentation and review. For SRF loans, we are reTired to consult directly with agencies responsible for implementing federal enviro imental la*s and regulations. For an SRI" loan, you will need to send us eight copies of the draft TIDAS set that we may initiate fecleral consultation. Federally designated agencies are given thirty lendar dAys to review and comment on your. ND/IS. Six days mailing time is also added to the re, iew period, We will send you copies of Any comments received for your response. 'i While CEQA its��.,ff does not require formal public hearings during the environmental review process, at Jeas t one heariftg is required for an SRF loan.project. Notices need to be di s ibuted at least thirty days in advance,�r at least fourteen days in advance if a Notice of Availability -as-distributed 30 days i i advance Of the public hearing. Please send a copy o t e notices to us. SRF i Ian project also meed to be cleared with the com Bance with "on 1061of the'National Historic Preservation Act. The Section 106 process includes:—(Ua— backgound resrch for cultural resources-- including a.records search with the California Historical Resources Info cion System, consultation with interested Native Americans, local historical soeiet es, etc.; ('A a fidld survey by 3 qualified archaeologist and, possibly, other specialists; and (3) air in ntory of i cultural resources in the project's Area of Potential Effects. Additional submittals I 4-paper t?ar 1101tet it to prrurw and cnbarmr Air resaatrr".pod malar their piriper adJ3ecO&V ami q,f'CI-v—1W AV b*wfrrt vJprar eat and,&nnrc pmratfrirn. A-I4 ___............................................................................................................................ ............ . 4 FEB 10x3$ ' f , Mr. 71 om lead ; 2 may requited to document resource significance andlor project effects. Please see Part JJ, Section 13b ol the enclo SPIP Environmental Guidelines for more details about the required items. When adequate inform ion has been submitted,the Division's Cultural Resources Officer will review it for Sectio 1 106 com,Ranee and will forward approved documents to the State Historic Preservation i Office (SHPO). Jbe SPO has a thirty day review period in which to comment or to concur that the pros is compl4te. You may tontact Ms. Susan Wilcox at(916)227-4410 with any questions you have&out cultural resiwrces studies mWor required documentation. SELF ojects are Olso subject tv provisions of die Federal Endangered Species Act and must obWn a Sectio 7 cleara4e from the U.S. Fists and Wildlife Service(FWS). At a minimum, dxe IS should contai the results of a literatureldatabasc search conducted for die presence of special status species in the reject and.surrounding area. If this project has a potential to impact federally listed species, the S may ref ire preparation of a Biological Assessment to evaluate the potential impacts and pr€rpo mitigatitin. Biological surveys need w be conducted during the appropriate time ` of yea and befor�-completion of the NDJIS for undisturbed or sensitive areas impacted by the projec . L asey as part ofiour "�NEPA-like" requit rents, all environmental documents prepared for SRF lo projec s,.includink legative Dcclarations, need to provide an environmental analysis of project alterng tives, including the "no project" altemative. Your nvironrnan'cal document is very well prepared arta would be adequate for our purposes if the requir d cnvironr ental analysis of project alternatives was incorporated into the document. Please refer t page I$6f the enclosed SRF Environmental Guidelines for additional information on project Otem tive requirirments. Please contact mcg at(9:16) 227-•4572 if you have ary questions regarding the environmexxtat review of ^ ' this F ject. ' Sincer. ly, 1 .. t a Diane Edwards j Envirt nmental Sirvirea Unit Encic res(2) r 7 i j .. j z f o a xr"tr is"erw Nd SHIW=dX OWN atcollf0mia'r wairr raourm gnd rranrr ilirir Sprr ahwarton and ektew t -/71 of prriaw vnd',Mohr ge"rW10M A-15 It ......... .......... .. ................................ ..................................................................... ............. i i ' I 'utant a Elimination Discharge Appendix B. National �`o � System Permit , } f i , , iral7 nF t"Al 1 aRNtA- t: �i F}ratesdiors A PETE WILSON Goverr�,ar ^q!„IFGr NIA REGIONAL WATER QUALITY CONTROL BOARD h,iNTRt L VALLEY REGION ROUW Rood,SuAm ASom "Arft,CA 92'7- 98 (T -44ONE.{916}255-l'" IAX'(91b)256-3016 MM 1 219% IMarch DEPT,WND ,ERT D MAIL P 240 867 525 I r Mr. Mark Goto, P.E. City Engineer/Public Warks Director City of Brentwood 708 Third Street Brentwood, CA 94513 TRANSMTrTAL, OF ADOPTED WASTE DISCHARGE REQUIREMENTS FOR THE CITY OF BRENTWOOD, WASTEWATER TRF_4T ffNT P.LAJVT, CO7NTR4 COSTA COUNTY Enclosed is an official copy of Order No. 96-039 as adopted by the California Regional Water Quality Control Board, Central Valley Region, at its 23 February 1996 meeting. i KENNETH LANDAU Senior Engineer PCB:njs Enclosures: Adapted Order, Standard Provisions cc w/o enc: United States Protection Agency, Region San.Francisca Department of Health Services, Berkeley Department of Fish:and Game, Region II, Rancho Cordova Ms. Elizabeth Miller Jennings, Office of Chief Council, State Water Resources Control Beard, Sacramento Division of Regulatory Support, Division of Water Quality, State Water Resources Control Board, Sacramento CoMt ra Costa Cauritiy Health Department, Martinez Contra Costa.Planning Department, Martinez Mr, Donald. Freitas, Contra Costa County Clean Water Program, Martinez Mr. Carl Gaston, City of Brentwood Wastewater Treatment Plant, Brentwood Greenbelt .Alliance, Sara.Francisco B-1 CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION ORDER NO. 96-039 NPDES NO. CA0082660 WASTE DISCHARGE REQUIREMENTS FOR CITY OF BRENTWOOD WASTEWATER.TREATMENT PLANT CONTRA COSTA COUNTY i The California Regional Water Quality Control Board, Central Valley Region, (hereafter Board) finds that: i I The City of Brentwood (hereafter Discharger) submitted a Report of Waste Discharge, dated 22 August 1995, and applied for a permit renewal to discharge waste under the National Pollutant Discharge Elimination System (NPDES) from the Brentwood Wastewater Treatment Plant. Supplemental information to the application was submitted on 23 October 1995, and 7 December 1995. 2. The Discharger owns and operates a wastewater collection, treatment, and disposal system., and provides sewerage service to approximately 11,500 people. The treatment plant is in Section 6, TIN, R3E, MDB&M, as shown on Attachment A, a part of this Order. Treated municipal wastewater is discharged to Marsh Creek, a water of the United States and a tributary to the San Joaquin River, at the point latitude 37 deg., 57 min., 46 sec., and longitude 121 deg., 41 min., 01 sec., referred to as discharge point E2 on Attachment B, a part of this Order. 3. The facility has the capability to discharge to Marsh Creek from a discharge point referred to as discharge point E 1 on Attachment B. Discharge point E 1 has not been used by the Discharger during the term of the prior order. The Discharger anticipates discharging from E I only under emergency conditions. Discharge point E 1 is at the point latitude 37 deg., 57 min„ 37 sec., and longitude 121 deg., 41 min., 24 sec (California Coordinates 533,200N, 1,657,250E). This Order permits the discharge of treated effluent from El to Marsh Creek. i 4. The treatment system consists of preliminary treatment of a bar screen and comminutor. secondary treatment through an extended oxidation ditch; secondary clarification; filtration through percolation into the groundwater; and discharge of groundwater to Marsh Creek via groundwater extraction trenches. Waste activated sludge is treated in an aerobic digester, dewatered on-site in sludge drying beds, and disposed off-site. B-2 WASTE DISCHARGE REQULRI�I�NTS - 27 CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY 5. Fast monitoring apart data, and the Report of"Waste Discharge describes the discharge from Ew2 to Marsh Creek as follows: Average Annual Effluent Flow: Low Flows: 0.25 million gallons per day (mgd) High Flows: 0.60 mgd Average Annual Influent Flow: 1.02 mgd Design Flaw: 1.8 mgd Clarifier effluent Extraction Trench _CQnstitutnt luot 152 cads Ef Lent BOD51 mg/l 166 6 6 Total Suspended Solids mg/l 186 n/a <0.I Settleable Matter mill 4.9 trace <.0001 Dissolved Oxygen mg/l n/a n/a 4.9 I Specific Conductivity n/a Low µmhos/cm n/a IOOO 1050 High 1600 14003 pH Low pH units n/a 6.5 6.3 High n/a 7.1 6.7 i Bioassay Low % Survival n/a n/a 90% High 100°fp Total Coliform NTN/I00ml n/a n/a 16 Organism(highest monthly average) t 5-clay, 20°C biochemical oxygen demand 6. The U.S. Environmental Protection Agency(EPA) and the Board have classified this discharge as a Major discharge. 7 The Discharger is currently reviewing alternatives to expand current plant design capacity by 1.4 MGD, This could result in an increase in the quantity of effluent from the facility. In accordance with Board's policies contained in the Basin Plan as identified in Finding No. 8, B-3 WASTE DISCHARGE REQUFLEMENTS CITY OF BRENTWOOD WASTEWATER TREATNfENT PLANT CONTRA COSTA COUNITY the Board encourages the reclamation and reuse of wastewater, and requires as part of a k Report of Waste Discharge an evaluation of reuse a- J land disposal options as alternati-,e disposal methods. The Discharger must submit a Report of Waste Discharge at least 180 days prior to any increases in wastewater discharge flows beyond those allowed by this Order. That Report of Waste Discharge must include, in part, an evaluation of the feasibility of year-round or seasonal land disposal of the increased wastewater flow, and an evaluation of the anticipated impacts of the increased flows on the receiving waters. 8. The Board adopted a Water Quality Control Plan, Third Edition, for the Sacramento and San Joaquin River Basins (hereafter Basin Plan) which contains water quality objectives for waters of the Basin. These requirements implement the Basin Plan. 9. Federal regulations require effluent limitations for all pollutants that are or may be discharged at a level that will cause or have the reasonable potential to cause, or contribute to an in-stream excursion above a narrative or numerical water quality standard. Based on information submitted as part of the application, in studies, and as directed by monitoring and reporting programs the Board finds that the discharge does have a reasonable potential to cause or contribute to an in-stream excursion above a water quality objective for biochemical oxygen demand, total suspended matter., and total coliform. Effluent limitations for these constituents are included in this Order. 10. The prior Order, and this Order contain an effluent limitation requiring the discharge to not contain less than 5 mg/1 of dissolved oxygen. During the reporting periods between December 1993 and September 1995, the Discharger failed to meet this firmit on 3 occasions, without causing a water quality objective to be violated. The average concentration of dissolved oxygen in the discharge during this period is 5.05 mV1, indicating that the discharge is just meeting the effluent limit in most cases. The extraction trenches collect both ground water and percolated wastewater, which is allowed to gravity flow out of the extraction trenches to the receiving water, and is not treated to increase the dissolved oxygen prior to discharge. Groundwater dissolved oxygen concentration may vary between 0 to 10 mg/l, A dissolved oxygen concentration less than 5 mg/l can be reasonably expected. Based on monitoring data, the Board cannot determine if the effluent limitation for dissolved oxygen is inappropriate. Review of 21 receiving water monitoring reports indicate that the dissolved oxygen concentration in Marsh Creek decreased between the upmearn and downstream receiving water monitoring points during 17 monitoring periods. In no case did the decrease cause a water quality objected to be exceeded. Between the receiving water monitoring points is an agricultural drain, which has been observed discharging coincidentally with the Discharger's discharge. Based on information currently available, the cause of the decrease in dissolved oxygen concentration in Marsh Creek cannot be determined . B-4 WASTE DISCHARGE REQIaEMFNTS - 4 - CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT .CONTR.A.COSTA. COUNTY Provision E.4. of this Order directs the Discharger to conduct a technical study to evaluate the cause of the decrease in dissolved oxygen in Marsh Creek and the impact of the City's discharge on dissolved oxygen in the Creek at the discharge point. In addition, the monitoring program of this Order has been modified to assist the Board and the Discharger to better evaluate impacts, if any, the discharge may have on Marsh Creek. { Pending the results of the technical study and subsequent monitoring results, Provision EA. of this Order allows the Board to reopen this Order to revise or remove the dissolved oxygen effluent limit, if appropriate. l l. The prior carder establishes effluent limits for settleable matter and chlorine residual. Secondary treated effluent is discharged to ponds and allowed to infiltrate into the groundwater, where it naturally flows towards extraction trenches. The infiltrated waste water and groundwater gravity flows through the extraction trenches and then is discharged to Marsh Creek. Given this type of filtration system of the secondary effluent from the treatment facility, settleable matter is not a constituent of concern for the discharge. In addition, the discharge is not required to be treated with chlorine because the filtration system adequately treats the discharge to meet the total coliform effluent limit. Since the Discharger is not treating the effluent with chlorine, chlorine residual is not a.constituent of concern for the discharge. Monitoring results over the term of the prior order confirm that the Discharger has consistently met the settleable matter and total coliform effluent limits. G Therefore, since these constituents are of little or no threat to water quality for this discharge, this Order has deleted settleable matter and chlorine residual effluent limitsr and .t removed monitoring for these constituents from the monitoring and reporting program. 11 The prier Order, and this Order contain an effluent limitation requiring the discharge to not have a pH less than 6.5 nor greater than 8.5. During the reporting periods between December 1993 and September 1995 (98 sampling periods), the secondary effluent discharges to the infiltration ponds indicate an average pH level of 6.6 pH units, with a range of 6.5 to 7.l The effluent then infiltrates into the ground water and is extracted and discharged to Marsh Creek.. Monitoring records (based can 20 sampling periods) of the discharge from the extraction trench to Marsh Creek indicate that the Discharger failed to meet the "not less than 6.5" lirrait on four occasions. During these occasions, pH levels in Marsh Creek upstream and downstream of the discharge point were also below 6.5 pH units. However, on three of the four occasions the pH level improved in harsh Creek downstream of the discharge point. The Discharger is not required to monitor the pH of the ground water. Based on monitoring data., it appears that the effluent from the treatment facilities may not be the cause of the final effluent failing to .meet effluent limits. Monitoring records of the receiving waters indicate that pH levels in the receiving water typically improve between the upwearn and downstream monitoring points, indicating that the discharge may enhance the quality of the receiving waters with respect to pH. B-5 WASTE DISCHARGE REQUIREMENTS CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY Based on monitoring data, the Board does not believe that an effluent limit forpi-I is necessary. This Order has removed the effluent limitation for PH, and amen monitoring and reporting ing program to initiate ded the monitoring of PH levels in ground water. Pending the results of the monitoring program, this Order may be revised to include PH effluent limitations, or require the Discharger to conduct a technical study to determi cause of the pH excurs, line the 'Ons. Provision E.6 of this Order allows the Board to reopen this Order to revise or amend effluent limitations and Provisions regarding PH levels in the discharge. 13. During the monitoring Period between December 1993 and September 1995 receiving water monitoring results indicate a degradation of water quality of Marsh Creek between the upstream and downstream moruitoring points for electrical conductivity. Based on monitoring records of the extraction trench effluent, clarifier effluent and mo the Board cannot determine monitoring wells ine the cause of such degradation. Provision 5 Of this Order directs the Discharger to conduct a study that includes increased monitoring and evaluation of sampling methods and techniques to determine the cause of water quality degradation of Marsh Creek. This Provision allows the Board to reopen this Order to revise or amend effluent limitations, provisions, and monitoring and reporting requirements regardin electrical conductivity, g 14. On 23 June 1992, Board staff requested the Discharger to submit an Effluent and Receiving Water Quality Assessment (ERWQA) that: a required the Discharger to provide information as to whether the discharge has constituents that cause or contribute to, or have reasonable potential to cause or contribute to an in-stream excursion above a water quality objective-, and b. if the discharge causes or contributes to an in-stream excursion above a water quality objective, required the Discharger to submit to calculate effluent Ii for those constituents, mitations The Discharger failed to submit an ERWQA. Provision E.2 of this Order di Discharger to conduct an ERWQA- Pending the result of the ERWQA. directs the this Provision allows the Board to reopen this Order and include effluent limitations for those constituents, 15. The beneficial uses of Delta waters downstream of the discharge are municipal and domestic supply, Industrial Process and service supply, water contact and noncontact recreation.; warm. agricultural irrigation and stock supply; reation; warm.and cold freshwater habi habitat, and navigation. ]tat; warm and cold migration; warm water spawning; wildlife 16. The beneficial uses of the underlying ground water are municipal and domestic supply, industrial process and service supply, and agricultural irrigation and stock supply. B-6 ................... ....................................... .......... WASTE DISCHARGE R.EQUIREN ENTS - 6 - CITY 6 -CITY OF BRENTWOOD WASTEWATER TREATN ENT PLANT CONTRA COSTA COUNTY 17, The permitted discharge is consistent with the antidegradation provisions of 40 CFR 131.12 and State Water Resources Control Board .Resolution 68-16. The impact on existing water j quality will be insignificant. 18. Effluent limitations, and toxic and pretreatment effluent standards established pursuant to Sections 208(b), 301, 302, 304, and 307 of the Clean Water Act (CWA) and amendments thereto are applicable to the discharge. 19. The aischarge is presently governed by Waste Discharge Requirements Order No. 91-053, adopted by the Beard on 22 February 1991. 20. The action to adopt an NPDES permit is exempt from the provisions of Chapter 3 of the California Environmental Quality Act (CEQA) (Public Resources Code Section 21100, et i seq), in accordance with Section 13389 of the California Water Cade. 21. The Board has notified the Discharger and interested agencies and persons of its intent to prescribe waste discharge requirements for this discharge and has provided them with an opportunity for a public hearing and an opportunity to submit their written views and recommendations. 22. The Board, in a public meeting, heard and considered all comments pertaining to the discharge. 23. This Order shall serve as an NPDES permit pursuant to Section 402 of the CWA, and amendments thereto, and shall take effect upon the date of hearing, provided EPA has no objections. IT IS HEREBY ORDERED that Order No. 91-053 is rescinded and the.Discharger, its agents, successors and assigns, in order to meet the provisions contained in Division 7 of the California Water Code and regulations adopted thereunder, and the provisions of the Clean Water Act and regulations and guidelines adopted thereunder, shall comply with the following r A. Discharge Prohibitions: 1. Discharge of treated wastewater at a location or in a manner different from that 4 described in Finding Nos. 2 and 3 is prohibited. 2. The by-pass or overflow of wastes to surface waters is prohibited, except as allowed by i Standard Provision A.13. (Bee attached "Standard Provisions and Reporting Requirements for Waste Discharge Requirements Q ES)".) t B-7 WASTE DISCHARGE REQUIREMENTS CITY OF BRENTWOOD - 7 - WASTEWATER 7 -WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY B. Effluent Limitations: I. Effluent shall not exceed the following limits: Monthly Weekly Monthly Daily C{7tl5titLf rlts -AY== Average BODSmv-/I 52 102 __-- 202 l lbs day' 75 150 300 Total Suspended mg/l 302 452 ---- 502 Solids lbs/day3 450 676 75I Total Coliform 1 r Organisms MPN/100 ml ---- --__ 23 500 ' 5-day, 20°C biochemical oxygen demand (BOD) l ) l 2 To be ascertained by a 24-hour composite 3 Based upon a design treatment capacity of 1.8 mgd. 1 2. The arithmetic mean of 20°C BOD (5-day) and total suspended solids in effluent samples collected over a monthly period shall not exceed 15 percent of the arithmetic mean of the values for influent samples collected at approximately the same times during the i same period (85 percent removal). I 3. The discharge shall not contain less than 5.0 mg/l dissolved oxygen. 4. The average dry weather discharge flow from the secondary clarifier to the infiltration ponds shall not exceed 1.8 mgd. 5. The Discharger shall use the best practicable cost-effective control technique currently available to limit mineralization to no more than a reasonabie increment. 6. Survival of aquatic organisms in 96-hour bioassays of undiluted waste shall be no less j than: Minimurnforanyonebioassay - - - - - - - - - - - - - - - - - 70% Median for any three or more consecutive bioassays - - - - 90% 7. By-pass or overflow of untreated or partially treated waste is prohibited. 8. Wastes discharged to land shall not cause degradation of any water supply- B-8 WASTE DISCHARGE REQUIREMENTS CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY 9. The dissolved oxygen content of holding ponds shall not be less than 1.0 mg/l for 16 hours in any 24-hour period. 10. Freeboard of the holding ponds shall not be less than 2 feet. C. Sludge Disposal: I Collected screenings, sludges, and other solids removed from liquid wastes shall be disposed of in a manner that is consistent with Chapter 15, Division 3, Title 23, of the California Code of Regulations and approved by the Executive Officer. Any proposed change in sludge use or disposal practice from a previously approved practice shall be reported to the Executive Officer and EPA Regional Administrator at least 90 days in advance of the change. 3. Use and Disposal of sewage sludge shall comply with existing Federal and State laws and regulations, including permitting requirements and technical standards included in 40 CFR 503. If the State Water Resources Control Board and the Regional Water Quality Control Boards are given the authority to implement regulations contained in 40 CFR 503, this . Order may be reopened to Incorporate appropriate time schedules and technical standards. The Discharger must comply with the standards and time schedules contained in 40 CFR 503 whether or not they have been incorporated into this Order. 4, Within 90 days ftorn the adoption of this Order, the Discharger shall submit a sludge disposal plan.describing the annual volume of sludge generated by the plant and specifying the disposal practices. D. Receiving Water Limitations: Receiving Water Limitations are based upon water quality objectives contained in the Basin Plan. As such, they are a required part of this permit. The discharge shall not cause the following in the receiving water: I- Concentrations of dissolved oxygen to fall below 5 mg/l. 2. When upstream'dissolved oxygen in Marsh Creek measured at R-3 is less Than 5.0 mg/l, the disctWgt shall not cause ftirther decrease in dissolved oxygen in Marsh Creek 3. Oils, Weases, waxes, or other materials to form a visible film or coating on the water surface pr on the stream bottom. B-9 i WASTE DISCHARGE REQUIREMENTS CITY OF BRENTWOOD - WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY 4. Oils, greases, wakes, floating material (liquids, solids, foams, and scums) or suspended material to create a nuisance or adversely affect beneficial uses. 1 5. Aesthetically undesirable discoloration. 6. Fungi, slimes, or other objectionable growths. 7 Turbidity to increase more than 10 percent over background levels. 8. The normal ambient pH to fall below 6.5, nor exceed 8.5. i 9. Deposition of material that causes nuisance or adversely affects beneficial uses. 10. Aquatic communities and populations, includingvertebrate, invertebrate,brats, and plant species, to be degraded l l. Toxic pollutants to be present in the water column, sediments, or biota in concentrations that adversely affect beneficial uses; that produce detrimental response in human, plant, animal, or aquatic life; or that bioaccumulate in aquatic resources at levels which are harmful to human health. 12. Violations of any applicable water duality standard for receiving waters adopted b the Board or the State Water Resources Control Board pursuant to the CWA and y i regulations adopted thereunder. If more stringent applicable water quality standards are approved pursuant to Section 33 of the Clean Water Act, or amendments thereto, the Beard will revise and modify this Order accordingly. 13. Taste or odor-producing substances to impart undesirable tastes or odors to fish flesh or other edible products of aquatic origin or to cause nuisance or adversely affect beneficial uses. i E. Provisions: I The Discharger shall not allow pollutant-free wastewater to be discharged into the collection, treatment, and disposal system in amounts that significantly diminish the system's capability to comply with this Order. Pollutant-free wastewater means rainfall, ground water, cooling waters, and condensates that are essentially free of pollutants. 2. The Discharger shall conduct an ER.WQA study. The objectives of the study are to: (1) t determine whether the discharge has constituents that cause, have reasonable potential to cause, or contribute to an excursions above a State water quality standard whether it be a numeric or narrative standard, and (2) to determine the most appropriate measures and/or actions to be takenn to achieve compliance with potential effluent Iimitations. B-10 WASTE DISCHARGE REQURRE?-NTS _ 10 - CITY 10 - CITY OF BRENTWOOD WASTEWATER TREAT ENT PLANT CONTRA COSTA COUNTY t 14 Within 60 days after adoption of this Order, the Discharger is to submit a workplan for the ERWQA, including a sampling and quality assurance plan and a time schedule. In !. general, sampling will have to occur over an entire year to account for seasonal variability in effluent and receiving water conditions. Constituents that need to be 1 analyzed by the Discharger for the ERWQA are metals and organophosphate pesticides. E By 1 June 1997 the Discharger shalt submit to the Board the study results. If it is } determined that the discharge contains constituents that have reasonable potential to cause or contribute to an exceedance of a water quality objective, this Order will be reopened and effluent limitations added for the subject constituents. 1 3, The Discharger shall conduct an effluent chronic toxicity monitoring program to ensure that their discharge does not produce in-stream toxicity. The Discharger shall carry out the biotoxicity monitoring program once per quarter over a period of 12 consecutive months in accordance with the following schedule.- a, Within 9€3 days of the adoption of this Order, a proposed program shall be submitted for Executive Officer approval. b. Within 60 days of Executive Officer approval, the Discharger shall implement the approved biotoxicity monitoring program. If the testing indicates that the discharge causes, has the reasonable potential to cause, or contributes to an in-stream excursion above the water quality objective for toxicity, the Discharger shall submit a workplan to conduct a.Toxicity Reduction Evaluation (TRE) and upon approval conduct the TRE, and this Order will be reopened and a chronic toxicity limitation included and/or a limitation for the specific toxicant identified in the TRE included. Additionally, if a chronic toxicity water quality objective is adopted by the State Water Resources Control Beard, this Order may be reopened and a limitation based on that objective included. '4. The Discharger shall conduct a technical study to evaluate the cause sof the decrease in dissolved oxygen in Marsh Creels, and the impact of the Discharger's discharge on dissolved oxygen in the Creek at the discharge point. Pending the results of this study, this Order may be reopened to revise or remove the dissolved oxygen effluent limit, if appropriate. The Discharger stall conduct this study in accordance with the following schedule; a. Within 120 days of the adaption of this Order, a proposed workplan to conduct the study shall be submitted for Executive Officer approval. b. Within 60 days of Executive Officer approval., the Discharger shall implement the study. c. By 1 March 1997 the Discharger shall submit to the Board a report of the study results. B-11 WASTE DISCHARGE REQUIREMENTS CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CO,7RA COSTA COUNTY A5.. The Discharger shall conduct a technical study to evaluate the cause of the degradation of Marsh Creek due to electrical conductivity, a--d the impact of the 1;33ischarger's discharge of electrical conductivity in the Creek at the discharge point. Pending the results of this study, this Order may be reopened to revise or amend effluent limitations, i Provisions, and monitoring and reporting requirements regarding electrical conductivity. i The Discharger shall conduct this study in accordance with the following schedule: 3 a. Within 184 days of the adoption of this Order, a proposed workplan to conduct the study shall be submitted for Executive Officer approval. b. Within 60 days of Executive Officer approval, the Discharger shall implement the k study. c. By 31 December 1997 the Discharger shall submit to the Board a report of the study results. 1 i 6. This Order may be reopened to revise or amend effluent limitations and Provisions regarding pH levels in the discharge. i 7. The discharge shall not cause the following water quality objectives for ground water to be exceeded.- a, xceeded:a. Bacteria: In ground waters used for domestic or municipal supply, the most probable number of coliform organisms over any seven-day period shall be less than { 2.2/100 ml. b. Chemical Constituents: Ground waters used for domestic or municipal supply shall not contain concentrations of chemical constituents in excess of the maximum containment levels specified in CCR, Title 22, Division 4, Chapter 15. f Ground waters shall not contain chemical constituents that adversely affect beneficial uses. 1 I Ground waters used as agricultural supply shall not contain concentrations of chemical constituents in amounts that adversely affect such beneficial use. 8. Reclaimed waste water shall meet the criteria contained in Title 22, Division 4, CCR (Section 60301, et seq.) 9 Ponds, sludge handling and disposal areas, and overland flow areas shall be adequately maintained to prevent odor nuisance or mosquito breeding. 10. Ponds, sludge handling and disposal areas, and overland flow areas that can be accessed by individuals other than treatment plant personnel shall be adequately posted. j B-12 __... WASTE DISCHARGE REQUIREMENTS - 12 - CITY 12 - CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY i' 11. The Discharger shall comply with all the items of the "Standard Provisions and Reporting Requirements for Waste Discharge Requirements (NPDES)" dated ] March r 1991, which are part of this Order. This attachment and its individual paragraphs are referred to as "Standard Provisions)" 12 The Discharger shall comply with Monitoring and Reporting Program No.96-039, which is a part of this Order, and any revisions thereto as ordered by the Executive Officer, When requested by EPA, the Discharger shall complete and submit Discharge Monitoring Reports. The submittal date shall be no later than the submittal date specified in the Monitoring and Reporting Program for Discharger Self Monitoring Reports. 13. This Carder expires on 1 February 2001 and the Discharger must file a Report of Waste Discharge in accordance with Title 23, CCR, not later than 180 days in advance of such date in application for renewal of waste discharge requirements if it wishes to continue I the discharge. 14. Prior to making any change in the discharge point, place of use, or purpose of use of the wastewater, the Discharger shall obtain approval of, or clearance from, the State Water Resources Control Board (Division of Water Rights). 15. In the event of any change in control or ownership of land or waste discharge facilities presently owned or controlled by the Discharger, the Discharger shall notify the i succeeding owner or operator of the existence of this Order by letter, a copy of which shall be immediately forwarded to this office. To assume operation under this Order, the succeeding owner or operator must apply in writing to the Executive Officer requesting transfer of the Order. The request must contain the requesting entity's full legal name, the state of incorporation if a corporation, the address and telephone number of the persons responsible for contact with the Board and a statement. The statement shall comply with the signatory paragraph of Standard Provision D.6 and state that the new owner or operator assumes full responsibility for compliance with this Order. Failure to submit the request shall be considered a discharge without requirements, a violation of the California Water Code_ Transfer shall be approved or disapproved in writing by the Executive Officer. � 4 1 B-13 }I 3' 3' CALIFORNIA REGIONAL WATER. QUALITY CONTROL BOARD j' CENTRAL VALLEY REGION MONITORING AND REPORTING PROGRAM NO. 96-039 1 NPDES NO. CA0082660 FOR f CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY INFLUENT MONITORING Samples shall be collected at approximately the same time as effluent samples and should be representative of the influent for the period sampled. The following shall constitute the influent monitoring program- i Sampling onstilutnt Laila Type o-- I?k � v 20°C BOD, mg/1, lbs/day 24-hr. Composite Monthly Suspended Solids mg/l, lbs/day 24-hr. Composite Monthly Electrical Conductivity µhmos/cm Grab Daily pH pH Units Daily Flow mgd Cumulative Daily 1 TREA TMEAIT PLANT EFFL UENT MONITORING Effluent samples shall he collected downstream from the last connection through which wastes can be admitted prior to discharge to the infiltration ponds. Effluent samples should be representative of the volume and nature of the discharge. Time of collection of the grab sample shall be recorded. The following constitute the treatment plant effluent monitoring program: Sampling Constituent � Type of Sa-,nnie 1g i 20"C BODS mg/l, lbs/day 24-hr Composite Monthly Suspended Solids mg/l, lbs/day 24-hr Composite Monthly Dissolved Oxygen mg/1 Grab Weekly B-14 .__._........._......... x MONITORING AND REPORTING PROGRAM - 2 - CITY 2 ;CITY OF BRENTWOOD WASTEWATER TREATMENT PLA'I'T CONTRA COSTA COUNTY Sampling C—Qj tuent jy2e gf Smt I EreQuency Electrical j.hmos/cm Grab Weekly 1 Conductivity PH pH Units Grab Weekly T POND MONITORING Each pond shall be monitored as follows: Sampling constituent uaiu Type szf Sa=le Frequency Dissolved Oxygen mgA Grab Weekly a Electrical Conductivity uhmos/cm Grab Weekly PH pH units Grab Weekly Pond Freeboard Feet --- Monthly { GROUND WATER MONITORING Ground water inside and outside of the ground water extraction system shall be sampled . The ? following shall constitute the ground water monitoring program: Sampling Constituent t i L ,Qf Sa=le ,FyZjQy l Nitrates mg/l Grab Quarterly Electrical Conductivity 4nhos/cm Grab Monthly Total Coliform `r Organisms MPN/100 ml Grab Quarterly pH pH units Grab Monthly B-15 t MONITORING AND REPORTING PROGRAM 1 3 - CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY Sampling Constituent LaL Type of Sample Fre!quencv_ Water Table Feet (MSL) and ---- Quarterly Elevation Hundredths i Ground water between the extraction system pipes also shall be sampled quarterly as follows- I Sampling Constituent Units Type of Sample FreQue 1ZL Water Table Feet (MSL) and ---- Quarterly Elevation Hundredths r i' WELL MONITORING Water from the domestic well on-site shall be sampled quarterly. The following shall constitute the well monitoring program: I Sampling Constituent LuilL Type of Sample Frcquencv Nitrates mg/1 Grab Quaner ly Electrical 1 Conductivity umhos/cm Grab Monthly pH pH units Grab Monthly Total Coliform Organisms, MPN/100 ml Grab Quarterly i B-16 MONITORING ANIS REPORTING PROGRAM - 4 . CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY GROUND WATER EXTRACTION SURFACE WATER DISCHARGE MONITORING Ground water extraction samples shall be collected at Station E-I and E-2 either at the discharge point to harsh Creek, or at a point prior to discharge to Marsh Creek if the discharge paint is submerged, as follows: } 51Ujo De,acription t E-i Extraction system above ponds. At flaw meter manhole adjacent to Marsh Creek near entrance read to plant (see attachment A map). _1 E-2 Extraction system below pends. At flow meter manhole adjacent to ,Marsh Creek, north of disposal pond area (see map). j Sampling Constituent unill Tue of S FreQuency BODS mg/l, lbs/day 24-hr Composite Monthly ? Suspended Solids mg/l, lbs/day 24-hr Composite Monthly Dissolved Oxygen mgll Grab Weekly ' Electrical Amhos/cm Grab Monthly Conductivity pH pH Units Grab Monthly Bioassay % Survival Grab Quarterly Total Coliform NPN/100 ml Grab :Monthly Organisms Flow mgd Cumulative Daily a Frequency may be revised or reduced pending results of study being conducted in accordance with Provision EA. of this Order. If the discharge is intermittent rather than continuous, then on the first day of each such intermittent discharge, the Discharger shall monitor and record data for all of the constituents listed above, after which the frequencies of analysis given in the schedule shall apply for the duration of each such intermittent discharge. In no event shall the Discharger be required to monitor and record data more often than twice the frequencies listed in the schedule. B-17 MONITORING AND REPORTING PROGRAM _ 5 - CITY OF BRENTWOOD WASTEWATER TREATMENT PLANT CONTRA COSTA COUNTY MARSH CREEK MONITORI1VG All Marsh Creek samples shall be grab samples. Receiving water samples shall be taken from the following: i Station Description R-1 Marsh Creek 300 feet upstream from extraction system E-I. The R-1 sample point is j where the entrance road to the pian is closest to Marsh Creek. R-2 Marsh Creek 140 feet downstream from extraction system E-1. 1 R-3 Marsh Creek 104 feet upstream from extraction system E-2 }} R-4 Marsh Creek 100 feet downstream from extraction system E-2. 1 r Sampling Constituents Units Station Fleguency Dissolved Oxygen mg/1 R-1', R-2`, R-3, R-4 Monthly i pH pH units R-1', R-2', R-3, R-4 Monthly Specific Conductance 4mhos/em R-1', R-2', R-3, R-4 Monthly Total Coliform 1 Organisms MPN/100 ml R-1', R-2', R-3, R-4 Monthly Turbidity Turbidity Units R-1', R-2', R-3, R-4 Monthly ' Sampling at R-i and R-2 will be conducted only when discharge is occurring from E-1. In conducting the receiving water sampling, a log shall be kept of the receiving water conditions throughout the reach hounded by Stations R-1 through R-4. Attention shall be given to the presence or absence of: a. Floating or suspended matter. b. Discoloration e. Bottom deposits d. Aquatic life. 1 i t B-18 MONITORING AND REPORTING PROGRAM - 6 - CITY 6 - CITY OE BRENTWOOD } 'WASTEWATER TREATMENT PLANT 4 CONTRA COSTA.COUNTY r e. Agricultural drains that are discharging to Marsh Creek during the period the Discharger is collecting receiving water samples. The lccatior of the agricultural drain shall be noted. f Other drains that are discharging to Marsh Creek during the period the Discharger is collecting receiving water samples. The location of these other drains shall be noted. Notes on receiving water conditions shall be summarized in the monitoring report. WATER SUPPLY MONITORING i A sampling station shall be established where a representative sample of the municipal water supply can be obtained. The following shall constitute the water supply monitoring program: i 4 Conai13 ns. vhla Sampling Frain 1 f Standard Mjnerals mg/1 Yearly { Electrical Conductivity 4mhosfcm @ 25°C Monthly i Total Dissolved Solids mgll Yearly SLUDGE MONITORING a ..i A composite sample of sludge shall be collected annually in accordance with EPA's PO TW Sludge Sampling and Analysis Guidance Document, August 1989, and tested for the following metals: i cadmium, chromium, copper, lead, nickel, and zinc. Sampling g records shall be retained for a rrunimum of five years. A lag skull be kept of sludge quantities generated and handling and disposal activities. The frequency of entries is discretionary; however, the lob, should be complete enough to serve as a basis of the annual report. REPORT17VG t In reporting the monitoring data., the Discharger shall arrange the data in tabular form so that the date, the constituents, and the concentrations and mass loadings are discernible. The data shall be summarized in such a manner to illustrate clearly compliance with this Order. Any results that not in compliance with this Order shall be addressed in the monitoring report. The Discharger shall discuss the incidents that caused the incident to occur, actions taken by the Discharger to remedy the incident, and actions the Discharger intends to take to prevent such an incident from occurring in tate future. By the 15th of each month monthly monitoring reports shall be submitted to the Regional Board for the preceding months monitoring results. All results of monitoring conducted by the Discharger more frequently than required by this Carder shall be reported to the Board. B-19 F t I i ATTACHMENT A ' 1 j• �r r Hlill t t ta Viz:`'. .. • +,y � i ` ' j _ i. :—. Right eNw"\ j6m 72 € R-4 _ IWASTEWATER TREATMENT PLANT" :'�.. •MARSH CR EIC s------------ ----------- HIGHWAY --------HIGHWAY 4 f.. CITY OF BRENTWOOD WASTEWATER CONTRA �REATI4d1ENT PLANT CONTRA COSTA COUNTY �j SECTION 6, T IN, R3E. MDO&M USGS 7.5' BRENTWOOD QUAD Brantzood SCALE V B-20 ....................................................................................... ATTACHMENT c i i ars n C r-e e w ---�--- - .�.� . _ 1 ry E"G 1 4 ' Wastewater QISDOS21 Area y MW-2 W-2 OUT IN . j t Treatment Plant Emergency Mw-1 i Dona 1N E-1 MW-1 OUT , rt?unc3 wafer C'TY C1` BRENTWOOD WAST WATcr `PEA f"�NT PLANT CONTRA COSTA COUNTY Grour,4 Water Morutonng Wells t.i0 i 8tW5��:t(L?L B-21 I i i I 1 i A E i Appendix +C. :Hydraulic, Dissolved Oxygen, and Electrical Conductivity Analysis for Brentwood Wastewater Treatment Plant f t t r t t 1 1 I I I I i i I 1 INTRODUCTION This appendix presents an analysis of the potential changes that the proposed Marsh Greek i wastewater treatment plant (WWTP) project could have on hydraulics, dissolved oxygen, and electrical conductivity as a result of the proposed discharge to Marsh Creek. r HYDRAULIC ANALYSIS 1 i Methods 1 ' Potential water level changes resulting from increased discharge of treated wastewater effluent to Marsh Creek were estimated with a model that calculates normal flow characteristics for 1 trapezoidal channels (university of Central Florida 1997). The model requires input for bottom f channel width, channel slope, side bank slope,Manning's n value,and strearnflow.rate. The condition where the effluent comprises all of the flow in the channel was assumed to represent.the worst-case condition for the summer period. lender these flow conditions, potential changes in water level could affect the quality or characteristics of habitat for aquatic organisms and terrestrial vegetation growing along the stream.channel corridor. The largest percentage change in water depth would occur when no flow is present in the channel aside from the effluent discharge. In addition,water level changes in a channel of uniform width are generally largest in sections of the channel with riffles that drain completely dry at zero flow. In areas where residual pools exist at zero flow, such as channel slopes,drop structures,or scoured areas,the percentage change in water level at a given flaw is less than that in the areas with riffles. under winter conditions, the worst--case condition for evaluating water level changes would occur under the combination of peak streamflow during a 100-vear flood event and peak daily effluent discharge rate. Lased on field observations of the channel near the existing WWTP, a channel width of 10 feet with an average dry-weather flaw rate of 10 million gallons per day (mgd) was assumed to represent the worst-case conditions for changes that would occur in the summer. For high-flow conditions where flooding would be a potential concern, parameters provided by the Contra Costa County Flood Control and Water Conservation District(Braucher Pers.cornet.)were used to estimate elevation changes for a I00-year flow volume in combination with a peak wet-weather effluent discharge rate of 20 mgd. Table C-1 contains a list of variables represents the worst-case assumptions for summer and winter conditions. Cit,,ofBrentwood FI'4M Project Appendix C Hydraulic,Dissolved Oxygen, Grafi RIR and Electrical Conductivity Analysis June 26, 1498 C-1 Table C-1. Worst-Case Assumptions for Hydraulic Analysis Characteristic Summer Winter Effluent flow 10 mgd(15.5 cfs) 20 mgd (31 cfs) Channel slope 0.002 0.002 Mannings n value 0.035 0.035 Channel width (feet) 10 30 Streamflow(cfs) 0 2,322 Residual pool depth(feet) 0 0 i Results J The results indicate a minimal effect from the proposed effluent discharge on water i elevations under summer and winter conditions. Water depth during the 100-year flood event would increase by less than 0.1 foot from a base floodflow depth of 7.9 feet, for an increase of approximately 0.8% above the existing base floodflow. Results for low-flow summer conditions indicate a potential change of 0.88 foot in channel sections that are approximately 10 feet wide. Based on field observations,the channel width increases downstream of the WWTP. In areas where the channel width is 15-20 feet wide,the maximum elevation change would be approximately 0.6- 0.7 foot. Contributions of flow in the summer, with resulting minimal changes in depth,would also provide some benefits to aquatic habitat factors such as fish passage, prevention of channel drying during periods of zero flow upstream of the WWTP, and additional water for uptake by terrestrial stream channel vegetation. At full buildout and full operational capacity of the WWTP facilities, the maximum average dry-weather discharge of treated effluent to Marsh Creek would be 10 mgd(15.5 cfs) and peak wet- weather flow would be 20 mgd (31 cfs). The treatment plant would be designed to allow gravity flow of the peak effluent discharge during floodflows in Marsh Creek. The peak rate of effluent discharge would be approximately 1.4% of the 100-year floodflow of 2,322 cfs. The effect of the peak discharge on the elevation of floodflows in Marsh Creek was evaluated with modeling results prepared by the 1~CWCD(Boucher pers. comm.). The methods used and results of the analysis are presented in Appendix C. The results indicate that the peak effluent discharge would increase the depth of the 100-year floodflow by less than 0.1 foot. Because the discharge would not contribute measurably to normal floodflows, the effect on the severity or extent of downstream flooding would be minimal. During periods (estimated as lasting approximately 6-12 hours) when peak floodflows are occurring in Marsh Creek,the discharge of effluent to the stream may need to be curtailed(Williams pers. comm.). The City and IjCWCD would develop the specific operational criteria for detaining effluent discharges during peak floodflows. If required,the City would monitor stage (water level) City of Brentwood WKIT Project Appendix C. Hydraulic;Dissolved Oxygen, Draf,EIR and Electrical Conductivity Analysis C-2 lune 26, 1998 in Marsh Creep, cease discharge of effluent to the stream, and provide sufficient reserve storage capacity onsite for effluent until the peak flow in the stream has passed. The FCWCD has recently completed plans to eliminate flooding of Marsh Creek upstream of the Highway 4 crossing. The FCWCD now plans to review channel conditions downstream of the Highway 4 crossing. If this review reveals no flooding potential or the FCWCD implements channel improvements to eliminate flooding, storage of effluent may not be required.. Therefore, the effect on flooding would be negligible. DISSOLVED OXYGEN ANALYSIS Methods An analysis of dissolved oxygen (DO) for summer and winter discharge periods was conducted using a standard DO sag (e.g., the potential decrease) equation shown below. The equation provides an estimate of the remaining deficit in potential stream DO levels at any distance from the point of discharge. The DO sag is then calculated as the initial deficit annus the remaining deficit. .Accurate analysis with a DCS sag equation requires information for several physical and biochemical parameters, including stream temperature, stream.flow and velocity, carbonaceous and nitrogenous biological oxygen demand(BOD)levels in the effluent discharged and receiving water, initial DO conditions in the stream, and coefficients for BOD decay and stream re-aeration rates. Input data used for the analysis were based partly on information provided by the City of Brentwood's(City's)consulting engineer(Skrel Pers. coram.), flow characteristics calculated with the model for trapezoidal channels described above; and field observations of depth and flow made at the WWTP site. D(x)=(Do)e _K'1y,u) L,, to-Kr(x/u) 'e-Ka(x/w)} I K,' K, D,xi = dissolved oxygen deficit at a certain distance"x"(mg/1) Ila = initial dissolved oxygen deficit(mg/1) Kg = re-aeration coefficient(11day) Kd = deoxygenation rate coefficient(1/day) K, = river decay coefficient(I/day) I p = ultimate BOD of mixed river and waste discharge(mg/1) x = distance downstream from discharge(miles) u = velocity of river(miles/day) where K.=(12.9 * V`)/d 312 v= river velocity(feet per second) d =river depth (feet) then K,�7a 20°C =ka * 1.024{r-1o) T=actual temperature of mixed river and waste discharge Cary of 11rentwood WWTP Project Appendix C. Hydraulic,Dissolved Oxygen, Draft Ells and Electrical Conductivity Analysis June 26, 1998 C-3 i t Assumptions and Input Values for DO Sag Analysis Because very few hydrologic or water quality data exist for Marsh Creek other than those I collected by the City's WWTP staff under its existing National Pollutant Discharge Elimination System(NPDES)permit,the DO analysis was conducted with several simplifying assumptions. The existing NPDES permit limit for the discharge from the WWTP groundwater extraction system I requires a minimum DO of 5.0 mg/1 at all times. Therefore, both winter (November through April) and summer (May through October) conditions were analyzed because water temperatures vary considerably between the two periods and water temperature dramatically affects DO levels in water. Data on background BOD loads and loading from sources other than the WWTP do not exist; therefore, the analysis was conducted considering only carbonaceous BOD sources. Nitrogenous BOD loading, benthic sediment oxygen demand, and factors of aquatic plant photosynthesis and respiration were not included. This assumption is justified because the proposed plant would fully nitrify the effluent, greatly reducing the potential nitrogenous BOD loading. For analysis of each summer and winter discharge period, conservative assumptions for physical and chemical conditions were used to simulate worst-case conditions. For both discharge periods,it was assumed that there would be no background streamflow and WWTP effluent would be the only flow in the channel. Field observations of the channel depth and flow characteristics were made on January 28, 1998, when streamflow was estimated to be 8-10 cfs. Based on field observations of the pools and riffles present in the stream channel,it was assumed that pools would create an average water depth of approximately 0.5 foot when there is no background flow. The re- aeration coefficient,K�,was calculated from the stream velocity,water depth,and water temperature. The anticipated NPDES permit limits during both discharge periods include maximum allowable effluent BOD of 10 mg/l and a minimum allowable effluent DO of 5.0 mg/1. Temperature is not measured routinely in Marsh Creek; therefore,conservative values of 24°C in summer and 12°C in- winter nwinter were assumed for the DO sag analysis. Initial effluent DO values were set to equal the historical 1991-1997 creek DO for the summer(7.74 mg/1)and winter(8.88 mg/1)periods,assuming that the effluent would be aerated with a cascade aerator system. Initial DO deficits were then i calculated from assumed effluent DO and stream temperature. Stream velocity used for the shallow scenario was calculated in the model for trapezoidal channel flow characteristics described above. Based on the hydraulic analysis, average streamflow velocity with a 10-mgd effluent discharge would be approximately 1.56 feet per second in an unimpeded channel with zero background flow. under conditions with the assumed presence of pools in the channel providing an average of 0.5 foot of water at zero flow, the stream velocity was adjusted to account for increased wetted channel volume. Because data were not available to calculate BOD decay and deoxygenation rate coefficients,baseline values for both were set at a value of 2 for both summer and winter conditions based on literature values. Table C-2 is a list of values for each parameter used in the DO sag equation. i City of Brentwood WWTP Project Appendix C. Hydraulic,Dissolved Oxygen, Draft EIR and Electrical Conductivity Analysis C-4 June 26, 1998 a f r i i 3 i Table C-2. Values Used in the DEQ Sag Equation Summer Winter Background streamflow 0 cfs 0 cfs Channel width loft 10 ft Water temperature 24 c C 12°C Effluent BOD 10 mg/I 10 mg/I { Stream DO at discharge(i.e., effluent) 7.74 mg/1 8.88 mg/I Initial saturated DQ 8.33 mg/I 10.75 mg/I Initial DO deficit (Da) 0.59 mg/1 1.87 mg/I I Re-aeration rate(K..) 1{x.1/day 5.8/clay BOD decay rate (K) 2/day 2/clay BOD deoxygenation rate(Kd) 2/day 2/day Velocity (U) 18.4 mi/day 18.4 mi/day Ultimate BOD(Lj 17.6/day 17.6/day s i C-5 I Results DO values were calculated for a total distance of 5 miles from the point of discharge to determine the pattern of conditions that would occur given the assumptions used for the calculations. The reach of Marsh Creek from the Brentwood WWTP to its confluence with Big Break is approximately 3.6 miles long. However, the results of the analysis are applicable only to Marsh Creek because conditions in Big Break were not included in the analysis. Table C-3 shows a summary of model coefficients and calculated DO values under summer and winter discharge conditions. The projected DO concentrations in Marsh Creek below the WWTP discharge are presented in Figure C-1. I Under summer conditions, the projected DO would steadily decrease downstream of the discharge from the initial DO of the effluent(7.74 mg/1)to approximately 5.90 mg/l by mile 3.0 near the confluence with Big Break, There would be no decrease below the regulatory DO objective of 5 mg/l. Under the assumptions for winter conditions, DO simulated with the shallow scenario would decrease steadily downstream of the discharge from the initial DO of the effluent (8.88 mg/1) to approximately 6.87 mg/l at mile 3.5. There would be no decrease below the regulatory DO objective of 5 mg/l. The conditions assumed for this analysis were conservative with respect to factors that typically are beneficial to enhancing DO conditions in a stream, such as upstream flow for dilution of the waste load, improved re-aeration through shallow flow and depth conditions, and reduced BOD loading in the WWTP effluent. The results indicate that given the relatively shallow flow and rapid velocity characteristics of a small channel such as Marsh Creek,re-aeration would be sufficient to maintain DO at levels that comply with state water quality objectives and anticipated NPDES permit limits. r ELECTRICAL CONDUCTIVITY ANALYSIS This analysis was performed to determine potential impacts of electrical conductivity (EC) in Marsh Creek that could result from the proposed effluent discharge from the Brentwood WWTP. Previously measured and reported EC values from Marsh Creek and WWTP sampling locations (Montgomery Watson 1997) were evaluated with a mass balance equation to project future EC concentrations in Marsh Creek. The summer period (May through October) was assumed to represent the period with the greatest potential impacts on water quality from discharges of dissolved salts contributing to the EC in Marsh Creek. Summer conditions tend to have higher water temperatures and lower streamflows, which cause greater stress for most aquatic organisms. Winter conditions were not analyzed because background base flow would tend to reduce the concentrations of EC by providing greater dilution of the WWTP effluent discharges. City of Brentwood t311-P71'Project Appendix C. Hydraulic,Dissolved Oxygen, Draft E1R and Electrical Conductivity Analysis C-6 lune 19, 1998 Table C-3. Model Coefficients and Results of Dissolved Oxygen Analysis for the Proposed City of Brentwood WWTP Discharge to Marsh Creek Base Stream Flow = 0.0 efs SUMMER DISCHARGE:Effluent BOD=14 mg/L lntial Saturated DO 8.33 Calculated Resultant` D13 Sag Equation Cnefftclents' DO Deficit River f Lo Ka Kd Kr Do u x at"x"tulles DO ji f (lfday� {ltday} t9tdaY} (1I_ d�� (mgJL} {mildap} (rniies} (mgll.) {rng1L} 1 Summer,initial effluent DO=7.74 mg/l y 17.6 10.1 2 2 0.59 18.4 0 0.59 7.74 17.6 10.1 2 2 0.59 18.4 0.5 1.26 7.07 17.6 10,1 2 2 0.59 18.4 1 1.73 6.60 17.6 10.1 2 2 0.59 18.4 1.5 2.04 6.29 17.6 100 2 2 0.59 18.4 2 2.24 6.09 j 17.6 10.1 2 2 0.59 18,4 2.5 2.36 5.97 f 17.6 10.1 2 2 0.59 18.4 3 2.41 5.92 f 17.6 10.1 2 2 0.59 18.4 3.5 2.42 5.91 ' 17.6 10.1 2 2 0.59 18.4 4 2.40 5.93 17.6 10.1 2 2 0.59 18.4 5 2.28 6.05 i i WINTER DISCHARGE:Effluent$t7D=10 mg/L lntial Saturated Do 14.75 Calculated Resultant DO Sag Eauation CoefficientsDO Deficit River Lo Ka Kd Kr Do u x __ at'Y'miles DO _(lfday) (11day} 11d_Yl (mg+`L) (rrtifday) {miles _�mg/1� (mg/L} Winter,initial effluent DO=8.88 mgA 17.6 5.8 2 2 1.87 18.4 0 1.87 8.88 17.6 5.8 2 2 i.87 18.4 0.5 2.46 8.29 17.6 5.8 2 2 1.87 18.4 1 2.91 7.84 17.6 5.8 2 2 1,87 18.4 1.5 3.26 7.49 17.6 5.8 2 2 1.87 18.4 2 3.52 7.23 17.6 5.8 2 2 1.87 18.4 2.5 3,70 7.05 17.6 5.8 2 2 1.87 18.4 3 3.81 6.94 17.6 5.8 2 2 1.87 18.4 3.5 3.88 6.87 17.6 5.8 2 2 1.87 18.4 4 3.90 6.85 17.6 5,8 2 2 1.87 18.4 5 3.85 6.90 i Notes:`Refer to'ext for descriptions of DO sag equation coefficients. r C-7 a LOLO w ........_. ...... ....._..__._..... ........... ..... ...... 3 d- • b1l Im .._._..'. _........ .. . .. C'3 s... �- ...: ...... :.... ........... 'r? • as a . Cif i _.. •.._.. .. `f7 • j • i 1 0 • i c e E • ♦ I d i � w ttZ G C37 LO CO Lo I-- DC7 CD lt7 Lo LO -t C7 r- C33 CO [ CD L6 d' r i (I/6w) ue6Axp panlossIQ C-8 i Methods The City is experiencing quality and quantity problems with its current groundwater source. Because of these problems, the City will be relying on surface water to supplement its current potable groundwater supply system. It is expected that future EC levels in the inflow to the WWTP will be considerably lower than current conditions. The source of this future water is anticipated to cornu from the Sacramento-San Joaquin River Delta (Delta). Based on information obtained in Contra Costa Water District's (CCWD's) 1997 Annual Water Quality Report, the total dissolved solids of raw water taken from the Delta ranged from. 170 to 389 mg/1 with an average of 267 mg/l, which equates to an approximate average EC of 411 microsiemens per centimeter (µS/cm), considerably lower than the levels of dissolved solids in groundwater (770 mg/1). The projected annual use of surface water in the future is 22,800 acre-feet and groundwater will constitute approximately 3,800 acre-feet of the supply. Recent EC data collected by the WWTP in May through of 1996 and 1997 at the monitoring site upstream (R-3) of the WWTP and from the secondary clarifiers of the existing WWTP were. } used to represent background conditions in Marsh Creek. Graphical analysis of historical monitoring data collected by the City indicates that EC in Marsh Creek has not been increasing. The EC of the future combined water supply (groundwater and surface water) was estimated from the City's projected ratio of use between surface and groundwater and the existing EC levels in the two water sources. The weighted average EC of existing groundwater (1,235 pS/em) was calculated from total dissolved solids(TDS) measurements from each well multiplied by the wells' pumping capacity.' The measured average TDS of 267 mg/1(411 µS/cm) in CCWD's water supply was assumed to be representative of the future surface water supply for Brentwood. The average EC of the future source water was calculated to equal 5301 µS/cm. The projected future EC in the influent and effluent for the proposed WWTP was then calculated by multiplying the source water EC by a coefficient to account for the increase in EC that occurs as water is used for domestic consumption. The existing coefficient for consumptive use of 1.37 was calculated as the ratio of the existing weighted average EC in well water (1,.235 gS/cm) to the existing effluent EC of 1,650 j �6/cm, Given the future source water EC and increase due to consumptive use, the future effluent EC was calculated to be approximately 705 VS/cm. EC levels in Marsh Creek were calculated from the mass balance analysis of effluent and background streamflow and EC conditions with the following equation: ECmars4 C k=(Flowfixckgrmand* ECa ck&,aund+ FlowEf'tksene* ECEfr,,, t}/(Total FloWB,,kground+Effluent) The mass balance was calculated for existing conditions resulting from the existing WWTP groundwater extraction system discharge rate of approximately 0.40 mgd (0.60 cfs). A future scenario was calculated with the proposed 10-mgd effluent discharge. For both existing and future conditions, the mass balance was calculated with measured EC levels in Marsh Creek at R-3 and a range of assumed low background streamflow rates. The average EC in Marsh Creek for the summer City of Brentwood WWTP Project Appendix C. Hydraulic,Dissolved Oxygen, Draft EIR and Electrical Conductivity Analysis C-9 .lune 19. 1498 1 periods in 1996 and 1997 was 885 µS/cm. The impact of the future WWTP discharge was then ) calculated as the simple difference between the projected and existing Marsh Creek EC conditions. Flow and EC values and assumptions used for the analysis are listed in Table C-4. Table C-4. Flow and EC Values and Assumptions 'i Input Variable Marsh Creek Background WWTP Effluent Existing flow rates 0-10 cfs 0.60 cfs Future flow rates 0-10 cfs 15.5 cfs Existing average EC 885 µS/cm 1,650 pS/cm Future average EC 885 pS/cm 705 pS/cm Results i The calculated existing and future Marsh Creek EC values and percent change from existing conditions are presented in Table C-5. i i Table C-5. Results of EC Analysis Marsh Creek March Creek Assumed Existing EC Projected EC Percentage Streamflow(cfs) (µS/cm) (µS/cm) Change g 0 1,650 705 -57 2 1,060 725 -31 i 4 985 745 -24 6 955 755 -21 8 940 765 -18 10 930 775 -16 The results indicate that, under worst-case conditions in the summer with a background streamflow ranging from.0 to 10 cfs,projected EC could range from 705 to 775 µS/cm. The range would represent,an approximate-57 to -16%decrease in EC over the estimated level under existing WWTP effluent discharges. At extremely high background flows, EC levels would be essentially Citi of Brentwooa WWTP Project Appendix C. Hydraulic; Dissolved Oxygen, Draft EIR and Electrical Conductivity Analysis C-10 June 19, 1998 ...................................................................................................................._.._.- ...__ ...................................................................................._..._._..._ i f equal to the background value of 885 µSlam and the proposed discharge would have a negligible 4 effect on the EC of Marsh Creek. In the future when the City begins to use more surface water for potable water use,discharge of treated effluent will have a positive impact(decreased levels) on EC levels in Marsh Creek. I CITATIONS i f Printed references I I i Contra Costa Water District. 1998, Your drinking water- annual water quality report. January- December 1997. Concord, CA. i Montgomery Watson. 1997. Technical report on dissolved oxygen and electrical conductivity in Marsh Creek, February. Walnut Creek, CA. Prepared for the City of Brentwood, Brentwood, CA. I University of Central Florida. 1997. Surface profile calculator for normal flow in trapezoidal channels. Public domain Windows-based shareware program. World Wide Web address: http-//www-cce.engr.ucf.edu/software/index.htm. Personal Communications i Boucher, Mark.. Civil engineer. Contra Costa County Flood Control and Water Conservation District,Martinez, CA. November 11, 1996-facsimile transmittal to Jenny Skrel (formerly with Montgomery Watson Consulting Engineers) of unpublished streamflow measurements in Marsh Creek. Skrel, Jenny. Civil engineer. G. S. Dodson & Associates, Walnut Creek, CA (formerly with Montgomery Watson Consulting Engineers, Walnut Creek, CA). February 12, 1998 - i fascimile transmittal of dissolved oxygen analysis information to Jeff Lafer. t City of Brentwood PYWTP Project Appendix C. Hydraulic,Dissolved Oxygen, Draft EIR and Electrical Conductivity Analysis June 19, 1998 C-11. k ,� 1 ---- - - ai . k r 1 t .' Tg T 1. ty, • LL '� ri• �' / t.. rr� J, ) t M .11'....' 1' ;C i n , J � 1 t i t ' " tJ "4 l Y,". k i. Y-1 - r [ "- t .5 ay. f. .. f L a. s - 1 INAIf t ,,t 11`�lF t3 +tt�t�&' L'1. RMPA T 1 MEPC tT F THS Ct�r�rF 'EN'1`i!�tC � j tA/As -1 I ti�-ra 7# TNt�NT: s r - a i City b'B�ekit- dd ^ x1. a r ? T�1ir Sti6q i3tit8Ct IO�tii` tC#E}SOi2, 'iiiYiI ��yy �'itf. c 7 16' ' x -- ,:x 1. - , o y w , f i NV{14GJNMENTAL.<'CG>IISUL TACIT z r x ` v n f b?ii;S'&-St0ktt5 A'sg6Cjk' $ Ihe;' trQt7�: t�Ei ta' llit£I }, �(0Li}jt ^tJ.� y�t/e�ve C,,eriter�yai# `'y `. , ` 7 FVI 11." 4�t7� :� f J r;C ..' r .., G .4 y , "n . h1OYEI�tf3Ei # 9E3 1414 �. . . :q' TABLE OF CONTENTS Page Chapter 1. Purpose and Format of the Final Environmental Impact Report . . . . . . . . . . . . . . . 1-1 Chapter 2. Response to Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 Chapter 3. Errata . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 .........................��Oa......................... ........................ ............................... ................................................. ............ ................ ................ .........I.—IoX.I.I.I.I.I.,........... ................................... ............................ i t Chapter 1. Purpose and Format of the Final j Environmental Impact Report i{ Under the California Environmental Quality Act (CEQA), the City of Brentwood (City) is required, after completion of a draft environmental impact report (EIR), to consult with and obtain comments from public agencies having jurisdiction by law with respect to the proposed t project and to provide the general public with, opportunities to comment on the draft EIR. The City, as lead agency, is also required to respond to significant environmental issues raised in the t review and consultation process. This document has been prepared as an attachment to the draft EIR as allowed by Section 15146(b) of the State CEQA Guidelines. This document and the draft EIR, herein incorporated by reference, constitute the final EIR. The draft EIR review period was from June 29, 1998 to August 13, 1998. A public hearing was held before the City of Brentwood Planning Commission on July 28, 1998, to receive input on the adequacy of the draft EIR as required by CEQA. The Final EIR incorporates the draft EIR.by reference and contains the following chapters: I ■ Chapter 2. This chapter contains the City's responses to environmental issues raised during the draft EIR public review process. The City's responses to comments on the draft EIR have been organized according to comment letters received during the i review period and comments received during the public hearing. Some comments have been cross-referenced to other responses to avoid duplication. Each comment letter and individual comment is numbered to correspond to responses presented on the pages following each comment letter. Table 2-1 lists all parties that prepared written comments on the draft EIR. a Chapter 3. This chapter contains an errata presenting tent, tables, and figures from the draft EIR that have been amended as a result of comments received during the public review process. The errata is organized according to the chapters of the draft ETR. E City of Brentwood WWTP Project Chapter 1. Purpose and Format of the Final Final EIR Environmental Impact Report -1 November 1998 Chapter 2. Response to Comments This chapter presents the City's responses to all the comments received on the draft environmental impact report(EIR) during the public review period from.Tune 29, 1998, to August 13, 1998. Each comment and response to comment is provided with corresponding numbering for ease of reference. Responses to three comments received during the July 28, 1998 City Council hearing are also included. References in this chapter to the errata refer to changes to the draft EIR as described in Chapter 3 of this document. All changes indicated in Chapter 3 have been determined to have no substantive effect on the impact analysis, significance conclusions, or mitigation measures included in the draft EIR. The revisions described in Chapter 3 are provided for information purposes only. Twelve cotnrnent fetters were received on the draft EIR for the proposed project. T able 2-1 lists all parties that submitted written comments,their affiliation, and the date of the letter. Table 2-1. Written Comments Received on the Draft EIR for the City of Brentwood Wastewater Treatment Plant Expansion with Discharge to Marsh Creek Agency/Organization Date Letter Number California State Water Resources Control Board August 11, 1998 1 California Regional Water Quality Control Board August 14, 1998 2 California Delta Protection Commission July 8, 1998 3 Contra Costa County Flood Control and Water July 13, 1998 4 Conservation District East Bay Regional Park District- Regional Parks July 9, 1998 5 Ironhouse Sanitary District August 6, 1998 6 Contra Costa Water District August 12, 1998 7 California Urban Water Agencies August 13, 1998 8 Central Delta Water Agency August 13, 1998 9 The Delta Science Center August 13, 1998 1 o California Department of Water Resources August 25, 1998 11 United States Fish and Wildlife Service September 28, 1998 12 City of Brentwood WW1'P Project Chapter 2.Response to Comments Final EIR 2_1 November 1998 State Water Resources Control Board Jahn P. Caffrey,Chairman Petry M.Rooney Dirision of Clean Water Programs Pete Waaa SeC ntctr�'fur 2014 T atnet•S r�ur�mta.Caldornia 95814•(91 b)2274400 FAX(916)2274349 fr�•erncr 1 wis+ catut M;u1ing Atjdrm: P.O.Hos 9442(2•$ncratrurcW.CalMmia•942##-2120 4 P•ntrcYiure l ntemei A"ris; hup)Avwwswrcb.ea vv AUG -1. Mr. Thoth Head Letter 1 Public Services Director Y ; City of Brentwood f Public Works Department 708 Third Street Brentwood, CA 94513 ! Bear Mr. Heats: ENVIRONMENTAL IMPACT REPORT(EIR)FOR CITY OF BRENTWOOD(CITY) WASTEWATER TREATMENT PLANT EXPANSION WITH DISCHARGE TO MARSH CREEK PROJECT--STATE REVOLVING FUND (SRF)LOAN NO. C4)64585-110 (SCR#98012055) Thank you for the opportunity to review the above document. We understand that the City will be seeking an SRF loan from the State Water Resources Control Board(SWRCB), Division of Clean Water Programs(Division)to assist in financing the proposed project. As a funding agency, the SWRCB will be a responsible agency pursuarZt to the California Environmental Quality Act(CEQA) and mit consider the information in the eavirontliental document prepared for the project when deciding whether to approve funding for the proposed Project. Pit-ase provide us with a copy of: (1)the Final EIR, (2)the resolution certifying the EIR and making CEQA findings, (3) all comments received during the review period and your responsm to those comments, (4) the adopted mitigation monitoring plata, and(5) the Notice of Determination filed with 1-1 the Governor's Office of Planning and Research, when they become available. In addition, we would appreciate notices of any hearing or meeting held regarding environmental review of the project. The Division is required to consult directly with federal agencies responsible for imple!nenting federal environmental laws and regulations for projects that involve an SRF load, since it is partially funded by the U.S. Environrnerital Protection Agency. Accordingly, copi«.s of your envirotunental docurtient were distributed to applicable federal agencies for review on July 9, 1998. The review period will end August 29, 1998. We will send you copies of any comments we receive during the review period for your response. SRF loan projects also need to be cfeared with the State Historic Preservation Officer(SHPO) for compliance with Section 106 of the National Historic Preservation Act. The Section 106 process includes: (1)background research for cultural resources—including a records search with the California Historical Resources Information System, consultation with interested Native Americans, local historical societies, etc.; (2)a field survey by a qualified archaeologist and, possibly, other specialists: and(3) an inventory of all cultural resources in the project's Arca of Potential Effects. I-2 Accordingly, the infortnation provided in your environmental document will be referred to the Division's Cultural Resources Officer, lois. Susan Wilcox, for review for Section 106 compliance. Ms. Wilcox will, contact you if any additional information is required. Once all required information has been.submitted, Ms. `,Wilcox will forward approved documents to the SHPO. The SHPO has a California Environmental,Protection Agency erre PaFrr� 2-2 Mr. Tum Head -2 - AUG Ms. Wilcox will contact you if any idditional information is required. Once all required irtformatiotz has been submitted. Ms. Wilcox will forward approved documents to the SHM. The SHPO has a 1-2 30-day review period in which to comment or to concur that the process is cotttplete. You may contact (can't) Nis. Wilcox at(916) 227-4.414 with questions regarding cultural resources studies and/or required documentation. The FJR.will be adequate for our consideration. We appreciate your efforts to prepare:a docurnent dw follows our enviroz n=atal guidelines and meets our requirements for the SRF loan program. 1f you 1-3 have any questions regarding the enviroearacntal review of this project, please contact rue at (916)2274572. -Sincerely, Dimte Edwards Envtroutxi+ rxW Services Unit cc: .State Clearinghouse +� 1400 Tenth Street Sacramento, CA 95814 Mr. Rich Condit San Francisca Bay Regional Water Quality Control Board 2101 Webster Street, Suite 500 Oaklat3d, CA 94612 r California,Exvironrnen4 d,Protection Agency 4 7 Recycled 1trKrrr 2-3 If Responses to Comment better 1 from the State Water Resources Control Board 1-1. The City appreciates the State Water Resources Control Board's (SWRCB's) guidance regarding the State Revolving Fund Environmental Compliance Requirements. The City has followed the guidance provided in Appendix E, "Environmental Review Process Guidelines for State Revolving Fund Loan Applicants - May 13, 1998" in the SWRCB's Policy for Implementing the State Revolving Fund for Construction of Wastewater Treatment Facilities (Amended June 18, 1998). The City has also contacted SWRCB staff',Mr.Wayne Hubbard, for guidance in interpreting the guidelines. A copy of the final EIR, including comments on the draft EIR and responses to comments,an adopted mitigation monitoring plan, notices of public meetings and a copy of the Notice of Determination will be provided to the S WRCB when they become available. 1-2. The City has also complied with Section 145 of the National Historic Preservation Act. The City has prepared, under separate cover, a Cultural Resources Inventory and Evaluation Report for the City of Brentwood Wastewater Facilities Expansion Project, Contra Costa County,California that has been forwarded to the Northwest Information Center at Sonoma State University. Two copies of this document will be forwarded to the S WRCB once the final EIR is certified to ensure that the state historic preservation officer (SHP4) requirements are met. 1-3. The City appreciates SWRCB's comments on this draft EIR. i' i i i City of Brentwood WWTP Project Chapter 2.Response ro Comments Final EIR 2_4 November 1998 ~ Letter 2 California Regional 'Water Quality Control Board Central Valley Region 'sirr M. Swrameatn Mates Onke Ott J_Sd+rtxiiet Srrnrmryfr+r ttitcrasz rAdidiru: rittp-1tWWW-3*Trhe2.r 1--fW"� Chit** tYxYfrnawmtat 3443 Pjy4r{koad,$viae A,300 MIM.t;2hibInta 9W7-300:3 i'rorctaticw P'14w(916):55-3=-VAX(916)253-3U1 S 14 August 1998 Mr.Thom H cad Public Services Du'rxtvr City of 13rc:utwootl ?Utf Third Strc t Brentwood,CA 94513-1396 DRAF"I' IrNY1RONMENTAL 1MPA(;T REPORT FOR WASTEWATER TREATMt rNI 1'LAN l' EXPANSION AND DISCHARGE TO MARSH CRE)tK AND INITIAL,STUDYtM1TIGATF-T) NEGATIVF DECLARATION FOR THE CTI'Y OF HKIIN'I'V1001)RAW SEWAGE CONVEYANCE, TO iRON110USIi SANITARY DISTRICT,CITY OF BRENTWOOD,CONTRA CO.s—I`A COUN-1-Y Due to our current workload,we are unable to provide specific comments on tltc two reports listed abovc, Ilewevcr,we would like to submit the fxsllowing comments for the record: 1. The Regional Board's I.aTtivater Reuse Policy,eontxinod in the Basin Plan(page 1V-15.00)states the t:ollowing- "The Itegional Water Board entourages the reclamation and reuse of wastcwatcr..... ,Akre practicable and rcquires u:s part of'a Deport of Waste Discharge and evaluation ofrcust and land d=sTuz:wl options as altemtttivc disposal mctbods. ...Whcre reuse or land disposal of all of tate wastewater is not practicable,the Regional Wager Beard will roquirc dischargers to evaluate how rt✓ttsa or land disposal can be optimized,such as consideration of reuse/disposal for}cart of the flew and seasonal reuscidisposal options(e.g.,dry season tend disposal)." Thercfore,laud disposal wczuld be our preference over increasing discharges to Marsh Creek. The lronhouse facility alternative would provide a long-tecta land disposal option- If the City chooses to expand the existing plant and 2-1 increase discharges to Marsh Creek,as part of a Kcport of Waste Discharge for a new NFDES � permit, the City must dcrntmstrate that land disposal alternatives,such its the Irottliouse option,are not practicable. 2, if the City chooses to expand the existing plant,and the Regional Fltard agrees,the effluent will aced to meet tertiary mndards for promerion of beneficial mv,,of the receiving water for contact E 2.2 recreation and drinking water supply. Spocific cllluent limits will be evaluated following the submittal of a Report of Waste Discharge. If you have any questions,ptcasc call Jean McCue at(`J 16)2,.55-3030 or me at(91 G)255-3142, C,REG K. VAUGHN Senior Water Resource Control Engineer JL'M.0KV:3m c:: Contra Costa County Environmental health Department,Concord California Environmental Proiec tion Agency Xpe.wW rpjwr 2-5 , l Responses to Comment Letter 2 from tate California Regional Water Quality Control Board, Central Valley Region 1 2-1. In addition to the analysis in the draft EIR for Alternative 2, Raw Sewage Conveyance to Ironhouse Sanitary District(ISD),the City has initiated and circulated for public review a draft Initial Study/Mitigated Negative Declaration,studying the ISD conveyance option. The City has preliminarily concluded that this alternative is technically feasible from an engineering and cost perspective and has found no environmental impacts that could not be i reduced to less-than-significant levels with incorporation of environmental control measures into project design. The City's Wastewater Facilities Plan(Montgomery Watson 1997)also concludes that City expansion of its wastewater treatment facilities and the ISD raw sewage conveyance option are the two most feasible alternatives for meeting future wastewater treatment capacity needs in the City. The City's main concerns with raw sewage conveyance G to ISIS are the following: ■ the City would not have a representative on the ISD Board; i' , ■ the possibility that the City and ISD will not be able to agree to a long-term service contract; ■ the City's ability to provide reclaimed water cost effectively would be reduced; ■ the City's level of control over facility expansion would be reduced; and 1 ■ the.City's ability to enter into cooperative agreements with industry potentially could be reduced. I 2-2. The City recognizes the need to meet tertiary standards for protection of beneficial use of the Marsh Creek receiving waters and will comply with Regional Water Quality Control Board (RWQCB)effluent limits. The draft EIR describes in Table 2-1 on page 2-8 the anticipated s discharge requirements that would apply to the City's Wastewater Treatment Plant(WWTP) Project. As shown in Table 2-1 of the draft EIR., the RWQCB is currently reviewing the appropriate total coliform bacteria disinfection level required for direct discharge to Marsh Creek.. The draft EIR incorrectly states in Table 3A-4 on page 3A-8 that a 23 MPI' /100 ml total coliform requirement will be met. Tables 2-1 and 3A-4 will be amended to indicate that a 2.2 MPN/l00 ml total coliform requirement will be met. City of Brentwood'419TP Project" Chapter 2. Response to Comments Final EIR November 1998 2-b SLATE e1F CALWMNLA N.Commor DELTA PROTECTION COMMISSION t421S RW R MAO P_0. BOX 330 WALNUT G*OvE,CA 45644 M40M. 19161 776.2240 Letter 3 FAX: {4161 776-2243 July 8, 2948 JUL } City of Brentwood Of RR 708'Third Street NO)BLIc WORKS M�► Brentwood, CA 94513 Attention: Thom,Read Subject: City of Brentwood Wastcwatcrr� Treatment Plant Expansion with Uiseaarge tobitfat'sFu Czeek`I"rii'cet Euivirronme�tal __ _..... __ . 3 Fact Re2aort(1� .);BCH Nv:9 0 2#158 Dear Mr. Head- I atxt writing regarding the above-named DEIR dated June 26, 1998. ne Commission itselfhas not had the opportunity to review the DEIR so these are stff comments only. They are based an the Commission's on's adopted"LAnd Use and Resource Management Plan for the Primary Zone of the Delta". The DEIR states that the proposed project will include"expansion of the biosob& hauudliag facilities to,allow disposal to hand or landff'(page ES-2). The Commission's Plan states in Utilities and lufxastructuxe Policy P-3 "New sewage treatment facftes(including storage ponds)and areas for disposal of sewage efl =t and sewage sludge shall not be located within the Delta Primary Zone." While the proposed expansion of the sewage treatment plaza is 3-1 not in the Priumry Zoxue of the Delta,the City should be aware that lands in the Primary Zone are not an appropriate location:for"disposal to land"of sewage sludge(biosolids). Thank you for forwarding a copy of the DEIR for review. Please call if you have auy questiions about these comments, or the Commission. Sincerely, AIN- Margit� Aramburu Executive Director cc: Chauxnan Patrick N. McCarty Supervisor Joe Canciamilla 2-7 t Responses to Comment Letter 3 from the State of California Delta Protection Commission l 3-1. The City is familiar with the Land Use and Resource Management Plan for the Delta Primary Zone. The City's proposed WNVTP expansion is not located in the Primary Zone. The draft EIR indicates that the City would like to dispose of sludge either on land or in a landfill. At this time, the City has not contracted with a sludge disposal company or identified lands for sludge disposal. All sludge, if it is disposed to land will: ■ meet applicable requirements of the Environmental Protection Agency's (EPA's) 503 regulations, ■ comply with requirements set by the Central Valley RWQCB, and ■ be evaluated to ensure compliance with. the California Environmental Quality Act (CEQA). x F i t i Ory of Brentwood WWrP Project Chapter Z. Response to Comments Final EIR November 1998 Letter 4 Contra Costa County J.Michael Watford ' - FLOOD CONTROL rV COM * 255 Ga6er anus.WrWms.CAWM. i Water Conservation District �# '�tars}a,�.z�at July 13, 1998 U Thom ReadJUL J 3$ Public Services.Director City of Brentwood #iEWtltlt5� 708 3`d Street Brentwood,CA 94513 File_ 97-52C Bear Mr.bead: We have reviewed the Draft FIR,for the City of Brentwood Wastewater Treatment PIant Expansion with Discharge to Marsh Creek, received by our office on June 30, 1998,and submit the following comments: 1. A Flood Control permit will be rewired for the construction of the outfall structure into Marsh Creek. s A modified B-50 detail will be required along with any modifications necessary, such as velocity 4-1 dissipation or bank stabilization measures. The plans and details should be in accordance with District standard plans and practices. 2. This outfall str-icture to Marsh Creek may be subject to the requirements of the Department of Fish armd Game (streambed alteration permit), the U.S. Army Corps of Engineers (nationwide permit), and lite 4-2 Regional Water Quality Control Hoard_ Documents which show that the City has complied with the requirements of the above agencies will be required before a Flood Control permit will be issued. 3. Currently there is an outfall for the exiting W WTP at the E-2 discharge point as well as a 30"District outfall for the upstream drainage arca facilities. The EIR states that the"effluent would be discharged to Marsh Creek in the vicinity of the current E-2 discharge". It appears that there will now be an additional outfall structure built in the vicinity of the other two. Perhaps this is not the case and the City intended to tie in at the existing discharge point. In either case, your engineer should look: at the 4-3 proximity of all outfall structures in the immediate area and design their creek and bank protection accordingly,ic.additional rock slope protection and creek bed protection may be necessary above and � beyond the modified B-50 detail if the outfalls are too close to each other. The District prefers combining the outfalls into one to rrminirrrize maintenance costs. � 4, In regards to the effluent from the WWTP, the District is concerned that Marsh Creek will not be � adversely impacted. District records indicate that the.Marsh Crcek channel has a bottom width of 30'. The Hydraulic Analysis Method section in the EIR(page C-1)states that the bottom channe=l width is used in the model that calculates flow for trapezoidal channels. Tabic C-1 on page C-2 makes a comparison between summer and winter flow characteristics. We noticed that in the summer the model uses a charnel width of 10'while in the winter a width of 30' is used. The bottom width of the channel 4a4 does not change throughout the year. This may affect the results of the model. Furthermore,the next section on Dissolved Oxygen Analysis on page C-4 makes a similar comparison between summer and winter for the D4 Sag Equation and uses a channel width of 10' for both the summer and winter scenario. This inconsistency should be explored as it may affect the outcome of the modeling and thus create more impact to the creels than this document indicates. 5. In the Hydrology and Water Quality section of this document it states that mho: effluent would be' introduced into the creek by gravity flow(page 3A-18). The City should develop specific operational 4-5 2-9 j criteria for detaining effluent discharges during peak floodflows and submit there to the District. The District will work with the City to develop an appropriate plan. The District will require the City to monitor the water levet in Marsh Creek during a significant storm event and restrict discharge of effluent until which time the peak flow in the channel has passed_ This would require a sufficient detention or storage facility within the plant improvermerb to accommodate the retained effluent. Further calculation 4-5 would be necessary to determine the:appropriate time to wait for tete peak flow to pass the.plant The - District would allow effluent discharge to resume a#trr the creek flaw dropped t+n 100 fs. "The lt3�t7cfs ( n't) flow a oetnt is the target amount at which detention basins tributary to Marsh Creek are allowed to release back into the creek once ftoodflows have passed. Our calculations indicate that the 100-year flood elevation is very hear the top of batik in this portion of Marsh Creek. Because tete W WTP collects waste from the entire City,the effluent is in essence water diverted from other watersheds that would not naturally enter Marsh Creek at the plants discharge point. The above requirements and precautions are necessary to protect the downstream areas, especially daring the times when the creek is in a floodflow stage. 6. This proposed project is located.within Drainage Area 52C(DA 52C)for which a drainage fee is due in accordance with Flood Control Ordinance Number 84-38. This drainage fee was previously adopted by the Board of Supervisors. By ordinance all building permits or subdivision maps filed in this arca 4-6 are subject to the provisions of the drainage fee ordinance. The fee for a non-residential or industrial type project is$14,390 per acne. When the pcartnit application and plans are submitted for review,please include with the information the number of acres included in the W M site. 'The City of Brentwood will need to submit this fee at the time of pulling a permit We would like to make the City aware of number ofpennits we have issued the City that have not been closed. Theme arc permit nos.619-91,625-93,636-93 and 614-44. Our concerns regarding these p=mits were addressed in the enclosed letter dated July 7, 1997. Please provide us with a contact person at the City so that we may close,out these old permits. We; appreciate the opportunity to review plans involving drainage matters and welcome continued coordination.If you have any question,you may rcacb me at(925) 313-2257. l- `ere truly y s, E Cary D.1`Iuisi Kh Civil Engineer Flood Control Engineering cs;sh Cl:tGtgbasx�F?dCifteistytimniwood�W W�PdtafC£dR.do¢ Enclosure C. T,Williams.Flood Control M.Boucher,Flood Control Sohn E.st"VnNoo.City of 8rrntwood F.Scudeto.Aceountist AaN 018-140406&Ol E-310419 2-1p s Contra Costa county J.Michael VOD CONTROL offkiv cty (rnomm Milton F. } & Water Cocrsetvatian District ass G Kfiblcok.0"IV car P-MWUAez.CA 94353.4897 Takuha e:(510)313-20M AX(510)313_,2, July 7, 1997 John Stevenson City of Brentwood 708 Third Street Brentwood, CA 94513 File:4401-36-04 Dear Mr. Stevenson: 4001-37-09 We are writing concerning flood control permits issued to the City of Brentwood for projects within the Flood Control.District right of way. These permits have not been closed because of work that still needs to be completed. The District needs your assistance to expedite the closure of these permits. Below is a list of the permits with a discussion of the work that needs to be completed..Copies ofthe permits are attached with the related permit conditions higillighted. I. Permit 619-9I, CotWruefion of Afinnesota Avenue Bridge Over Sand Creek d'Some portions of the new bridge were constructed over District right of way and the City needs to acquire that right of way from the District. The District will retain easement rights for Sand Creek flood control cliannel. The City needs to prepare the plat snap and legal description for the right of way and submit the documents to the District for review and approval. Our Real Property Division estimates that the review of the legal documents and the processing of the transfer will cost about S2,000. 2. Permit 625-93, Installrrdvn of a 12-inch Water Luce Between Well Number 8 and Well Number 7 at Marsh Creek Channel near Hanson Lwie e Visible markers should be placed at the line's termini to identify the water litre locatiolt as required by the permit condition. e The drainage ditch along the service road appears to have been covered up with soil during the pipe laying. Please restore the ditch between the two wells. e9 A valve manhole near well number 8 needs to be adjusted so that it is flush with the ground. A cover for the manhole should be provided. tO' An unused Christy box near well number 8 needs to be removed and the area around it n(xds rcgrading to remove [lie suikholcs. l 2-11 V A PVC riser pipe is protruding above the ground near well number 7. if the pipe has to remain in place,Please provide appropriate-housing or guard around the pipe, or cut the pipe and provide an appropriate cover flush with the ground. tO,A,joint use agreement needs to be prepared to cover the presence of the water line in the District right of way. One permit condition states that the City agrees to compensate the District for all joint use agreement costs, The District can have the County's Real Prop" Division prepare and process the agreement.The City needs to prepare the plat map and legal description:%r inclusion into the agreement document. The estimated cost of processing these documents is about$2,000. 3. Permit 636-93, Construction of B-50 Outf Xfor Hanson Lane Storm Drain tfReconstruct the rock rip rap outfall structure on the embankment including the cutoff was (see copy of a photograph of the dilapidated spillway attached to the copy of the permit). zf Grout the spillway area of the reconstructed rock rip rap outfall mentioned above, ti tor Coat the mitered end of the outfall pipe with galvanized or bituminous paint. 4. Permit 614-94, 13aour Boad Bridge OverM=h Creek tf Similar to the NImnesota Avenue bridge,the Balfour Road bridge improvements and trail enhariccments are within the Marsh Creek right of way owned by the District. The City needs to prepare a plat map and legal description for the roadway area and submit the documents to the District for review. We estimate that the associated cost for processing the right of way transfer is about$2,000. e The City will also need to prepare a plat map and legal description for the area of the new landscaping and trail improvements installed as part of the Balfour Road bridge project. The documents will become part of the proposed license agreement between the City I of Brentwood and the Flood Control District and will identify the City's responsibility over these improvements. V Other works need to be completed in relation to the bridge and the City-sponsored trail and bike path. Attached to the copy of the permit is our letter to the City dated July 17, 1995 outlining those works. Thosc items that identify a processing asst will rNuire a deposit for our Real Property staff to charge against.Unused deposit amounts will be returned to the City after the right of way documents and/or agreements are processed. 2 2-12 We would appreciate a meeting with you or the appropriate City representative to discuss these pexmit issues.Please call me at 313-2278 or Mario consolation at 313-2257 to schedule the meeting, Very truly yours, Mark.Boucher Associate Civil Engineer Flood Control Engineering MB:MC:0 g:lfldctllworklstevcso.t7 Enclmre c: M. Morton, Flood Control M. Consolation, Flood Control T. WOOWn,City of Brcntwood 3 2-13 i Responses to Comment Letter 4 from the Contra Costa County Flood Control & Water Conservation District t 4-1.. The City will obtain and comply with all requirements of the Contra Costa County Flood Control and Water Conservation District's(District's)Flood Control Permit. As part of the permit application process,the City will submit design drawings for the outfall structure.The draft EIR indicates on page 2-11 that appropriate velocity dissipation and hank stabilization measures would be built into and around the outfall structure. 4-2. The draft EIR presents on page 2-13 the approvals and special requirements that may be required for the WWTP Expansion Project, including a California Department of Fish and Came(DFC)Streambed Alteration Agreement,a U.S.Army Corps of Engineers Nationwide Permit,and permits from the RWQCB and SWRCB. The City will erasure that all applicable permits are.complied %kith before they apply for a.Flood Control Permit. 4-3. The City intends to maximize land disposal of treated effluent by means of the existing effluent disposal ponds and associated extraction pipe system with indirect discharge to Marsh Creek via discharge point E-2. The extraction pipe system is comprised of four perforated pipes installed approximately 10 feet deep. During periods of high creek flow, the discharge from E-2 can be pumped to Marsh Creek. The proposed WWTP facilities will be designed with a different hydraulic profile than the current plant. The proposed WWTP will be designed to allow a gravity discharge to Marsh Creek at the 100-year-flood elevation. Therefore, it may be possible for the City to have two outfall structures in the vicinity of E-2 that are at different elevations. During the design phase of the project, the possibility of combining existing discharges with the proposed discharge facility will be reviewed. 4-4. The hydraulic analysis for impacts of the proposed discharge on flooding conditions during the winter months was conducted assuming that the channel would be 30 feet wide as indicated by the District. For the analysis of dissolved oxygen under summer conditions, a more conservative assumption of a 10-foot channel width was used. The conservative assumptions were not used for evaluation of flood-control impacts. 4-5. The City will comply with the District's requirement to detain effluent during peak flood flows in marsh Creek as indicated on page 3A-18, third paragraph of the draft EIR. Although the City has not specifically designed detention facilities, space is available at the current treatment plant site to accommodate these facilities. The City will work with the District to incorporate into the project creek-level monitoring in Marsh Creek. Assuming a set creek flow level of 1,000 cfs,the City will cease discharge of treated effluent to Marsh Creek when Bows exceed 1,000 cfs until flows fall below 1,000 cfs. The information on page 3A-18 is incorporated into the description of the proposed facilities in Chapter 2, "Project Description",of the draft EIR.. Please refer to Chapter 3,"Errata", of this document. 4-6. The City will comply with all drainage fee requirements applicable to the proposed project. City of Brentwood VMTP Project Chapter 3. Response to Comments Final EIR November 1998 2-14 Letter 5 EGIONAIL PARI<S -R EAST SAY REGIONAL PARK DISTRICT BOAAO Of rIACCTOA5 sw July 9, 1998 Prodrlw, p � vuWp cNa se-Win Mr. Thom Head + Q ;�w City of Brentwood swamg Public Services Department PU81IC '� Ted Rsaft �s« 708 Third Street Brentwood, CA 94513-1396 c� RE:Marsh Creek Regional Trail -DEIR Wastewater Treatment Plant Expansion and Discharge to Marsh Creek Dear Mr. Head: The East Bay Regional Park District received and reviewed the draft environmental impact report for the wastewater treatment plant expansion and discharge to Marsh Creek. The District's interest in this project is that of any impacts to the adjacent Marsh Creek Regional Trail. The District established the multi-use regional trail in 1992 as a major north/south trail corridor between Round Valley Regional Preserve and Big Break Regional Shoreline along the cast side of Marsh Creek. The existing trail runs from Balfour Road north to Big Break on the east flood control maintenance service road. The draft EIR does not mention the regional trail. The impacts of the expansion on the regional trail appear to be minimal_ However, there is a potential for visual impacts, odors from the expanded operation, and temporary impacts to the trail use during the construction of the outfall 5-1 structures. The District requests acceptable mitigation measures to address these concerns. Specific wording for mitigations should be discussed with Steve Fiala, Trails Specialist, (5 10) 635-0138 ext. 2602. Thank you for the opportunity to comment on this project. The District requests a copy of the Final EIR very truly yours, Linda I.P. C Park Planner 11 cc: Brad Olson Steve Fiala Iry 2950 Peralta Oaks Court PC. Box 5381 Oakland, CA 94605-0381 Te,:(510;63S-0735 TDO.-(510)6X-C-460 Fax:(510)569-431,9 2-15 f({ Responses to Comment Letter S from the East Bay Regional Park District 1 5-1. The draft EIR does refer to the East Bay Regional Park District's (EBRPD's) regional trail adjacent to the City's WWTP as a"pedestrian trail" on page 3F-1 and again on page 3F-4 and indicates that the project "would not impede any existing uses of the pedestrian trail." Noise effects of the project were found to be less than significant because construction noise would be temporary and operational noise would be similar to existing noise levels. Odors that could affect trail users would be mitigated to a less-than-significant level by mitigation measure E--4, presented on page 3E-9 of the draft EIR, requiring the City to resolve odor complaints received on the plant that exceed its Bay Area Air Quality Management District permit limits. The City has determined that no change in visual resource effects of the proposed project 4 would result because expanded facilities would be contained in the existing WWTP site.No additional evaluation of this issue is warranted. i i 1 i t i City of Breni-wood W,,7P Project Chapter 2. Response to Comments Final EIR 2-16 November 1998 i Atm--07--19' Letter 6 FAX IRONHOUSE SANITARY DISTRICT (510)82S.0169 450 WV&W NQS Drive + P.o_i3ox 1105 • TWePho C}ak�rtY.CA 94661 (5 r 0}625-.VN August 6, 1998 VIA: Teleeopier and U. S. Nail Thom Dead„ Public Services Director City of Brentwood City Hall 708 Third Street Brentwood, CA 94613 Re: Comments on Draft Environmental Impact Report, Wastewater Treatment Plant Expansion with Discharge to Marsh Creek Dear Thorn. On behalf of Ironhouse Sanitary District (ISD), thank you for the opportunity to comment on the Draft EIR (DEIR) which has been prepared for the City of Brentwood Wastewater Treatment Plant Expansian with Discharge to Marsh Greek (Marsh Creek Alternative). Before presenting our specific comments,we offer three general comments- Clenexai Comment Qae The DEIR incomedly characterizes the ISD project (Alternative ?) as ars "effluent disposal" project_ The ISD project is a reclamation project and is so defuied in the Waste Discharge Requirements for the project. The project would Utilize the total flaw from the joint treatment plant for irrigation of crops on land on Jersey Island,and south of Big:Break. This use for irrigation eliminates the withdrawal of a comparable amount of water historically used from Delta channels, There would be no discharge of effluent for disposal, either directly to surface water or indirectly through 6-I application on lancL We believe the DEI.R. is deficient in deal it fails to give any recognition to the environmental benefits £rem reuse of the reclaimed water ofAltemative 2 versus the direct surface discharge of effluent to Marsh Creek as would occur with the Proposed Project, 2-17 AL"7-1998 1058 tRONHOUSE SANI7AW 510 625 0165 P.03 i r Thom Head Public Services Director August 6, 1998 Pages 2 of 6 l i The Alternatives Analysis concludes that the Proposed Project is environ tally # superior to the No Project AlWmative and to Alternative 2 Raw Sewage Conveyance to MD. This conclusion is not supped by the acts and analyses 6-1 presented in the DEIR- These facts and analyses support the conclusion that (can't) I Alternative 2 is superior to the No Project Alternative and to the Pmposed Project. i Please see the detailed discussion ofthe Altmud v+es Analysis below. Gen, p-mment Two 1 There are several references in the DEIR to a "joint City,and ISD WWI?". A joint City and ISD WWI? is one of several options for the City's participation in the ownership in the plant and Jersey Island. However,no decisions have been made on �`� i this question at this time,and we suggest 1t is best that references to a joint City and ISD WWT`P be deleted from the DEM Gomer 1 Co=ent The DEM has several references to "effluent disposal" on Jeney Island as opposed to the planned use of reclaimed water for irrigation on Jersey Island,as is set forth in the ISDWaste Discharge Requirements. We request that reference to effluent 6-3 ! disposal be replaced with references to the planned use of reclaimed water,the use of reclaimed water on Jersey Island, etc. as appropriate. S .S`F11Pi i f ig C{}i7rrr e-= The fallowing are specific comments on the text of the DEIR addressing technical errors or clarifications, 'These comments at keyed to the pages of the DEIR. f s Page 2--2 - Reference to California Tonics Rule in the last sentence. Would the requirement to comply with the California Toxics Rule increase the cost of 6-4 constructing and operating the proposed project? If so, this should be noted here. Would Alternative 2 require such compliance and potential added costs? 2-18 i ................... POU-07-199e 10:58 I RONi DLJSE SRN I 7 FRY 510 625 0169 P.04 Thom Head Public Services Director August 6, 1998 Pages 3 of 6 Page 2-11 -Third full paragraph.,line three. The"treatment capacity of 3.3-4.3 mgd." is a very broad range. The treatment capacity should be presented at one end of this 6-5 range or the other, accompanied by a listing of the assumptions on which the stated treatment capacity is based. Page 3A-17 - Hydrologic Impacts and Mitigations Measures, The DEIR does not make it clear that the proposed project could cause the flow of Marsh Creep 6-6 downstream of the WWT? to approach 100 percent treated effluent. Page 3A-23 -Dissolved Oxygm Would the impact be the same at the lower initial flows? What if flow is not zero and upstream DQ is 5.0 mg/l or lower,would initial ' 6-7 flows meet the non-reduction requirement of the NPDES permit? Page 3A-24 -Mitigation Measure A-1, This discussion fails to address the issue of how and what it might cost for treatment processes to "be iraplemeated and operated 6-8 accordingly to help ensure compliance with NPDES permit limits." Are these facilities or related costs all included in the proposed project? Page 3D-1, First paragraph under "PathOgcns..." While it is cur=t that treated wastewater is discharged to sirwans and rivers, it most often is discharged where the 6-9 stream or river provides significant dilution of the wastewater at the paint of discharge. Discharge whom the treated wastewater will comprise the majority of flow is not widely practiced. Page 3D-2 -First full paragraph, it is not correct that the effluent could be "used fbr reclamation without restrictions on existing beneficial uses with regard to public 6-10 health". It would depend on the proposed reclamation use. Some uses could require disinfecting to 2.2 NTN/100 ml which is not provided by the proposed project. Page 3D-5 - Fast paragraph, The DEER discusses public "swim=ing or other recreational contact with Marsh CreelC%but does not relate this discussion to the Titley � 6-11 22 Water Reclamation Criteria discussion at pages 3A-15 and 3A-16. tin page 3A-15 continuing on page 3A-16,it is stated that dor discharges to surface waters that mayr 2-19 AUG-07-19% 10:59 IR°WEA SMITARY 510 625 0169 P.eS i Them Head PublicServices Director August 6, 1998 Pages 4 of 6 involve body-contad res Batton,Title 22 provisions reqs 2.2 MPNJ100 ml. Table 2-1 notes that the City's discharge from the Marsh Creek WWTP Plrojeet will meet a standard of 23 NIPN1100 ml, unless parks are developed along Marsh Creek, i presurnably in which sass it will meati a standard of 2.2 MPN1100 rel. Even if parks are not developed, it is reasonable to expect that some of the children, and possibly 6-11 some of the adults, living along Marsh Creek "I come into beadily contact with (can't) Marsh geek., Assuming the City.meets only the 23 NTNf 140 ml standard,what are the City's intentions as to posting signs along the length of Marsh Creek notifying the clic ofthe potential public health hazard posed by the City's discharge of treated eluent into ash Creek? It appears the City should be considering meeting the 2.2 MPNIl00 ml>standard from the initiation of the discharge of treated effluent into Marsh Creels. y Page 5-3-First paragraph under Alternative 2,the text snakes parenthetical reference to the ISIS alternative as "effluent disposal" after correctly describing it as reuse for 6-12 irrigati . "The District disagrees with this characterization as discussed czrlier in our general'comments. Page 5-3 - Last full sentence, this sentence should include mention of the send � 6-13 railroad crossing shown can.Figure 5-1. Page 5-5 -This pie contains multiple references to"disposal" by ISD. This is not correct. The ISD project(Alternative 2) cun=tly, and as projected, uses all of the 6-14 } reclaimed water for crop irrigation.. There is no discharge of treated effluent for disposal. Page 5-6-Alternadve 2,The discussion of advantages of Alternadve 2. Raw Sewage Conveyance to ,ISIS is incomplete and.inadequate. Among the other advantages of Altertmative 2 which should be included in the D£I are: 6-1 S (a)The isolation of the ISD treatment plant from the public and potential odor problems. i 2-20 i AWT-W-1598 10:59 I RONHMISE &W I TfiRY 510 625 0169 P.06 Thom Head Public Services Director August 6, 1998 Pages 5 of 6 (b)The elimination of any possibility of adverse impacts to Marsh Creek, Dutch Slough and the Mita resulting from the discharge oftreated effluent (c)Avoiding any potential adverse environmental impacts associated with the 15 nutrients contained in the treated effluent del i-vered to Dutch Slough,and the (conn 's) Delta via Marsh Creek, and instead capturing the'value of these nutrients (c through crop.irrigation on Jersey Island. (d)The recovery of the current 70 acres of land devoted to the Brentwood '4tV''V41TP. Page 5-6 - Alternative 2, Pour of the five bullets listing the disadvantages of j Alternative 2.Raw Sewage Conveyance to ISD are either not consistent with the facts � and analyses contained in; the DECK, or are not related to environmental issues. (a)Second Bullet Item: At page 5-12 of the DEIR,, fourth paragraph, The risk potential for raw sewage spills due to pipeline rupture is determsned to be less 6-16 than significant. ('bb)Third Bullet.Item:Federal and std agency permit requirements are not an environmental impact. (c)Fourth and Fifth Bullet Items: The DEM contains no analyses supporting these statements. In any case, level of control over facility expansion or industrial agreements are not environmental impacts. Page 5-9—First partial paraagrapdi, the last sentence is not correct Reclaimed water from ISD's WTP would be used for irrigation on Jersey Island, not "disposed of. 6-17 Pages 5-9 through 5-19 - The comment above for Page 5-5 also applies to the 6-18 multiple .references to "disposal" on these pages. Page 5-17 - Ist paragraph, 6th line and 7th paragraph, Ist line, change "disposal" to 6-19 "reclaimed'water". Page 5-19-Environmentally Superior Alternative,The conclusion that the Proposed ' 6-20 Project is environmentally superior to the.Ahernative of ocmveyi.ng raw sewage to the 2-21 PUG-07-1998 11:00 I T4ONHOU.7G Jr'7f Z T TAL 1 '�G"ii ii:w7 f ' u4J P.01? Thoth Head Pubiic SeMces Director Augur 6, 1998 Pages6 of 6 ISD VIWI? hinges on a comparison of reladvely inconsequential temporary construction impar. This analysis is also flawed because it totally ignores the identified adve impacts of discharging treated effluent into Marsh CreeX and the gamer potential exposure of'the public to treatment plant odors or chemical hazards_ 6-20 This conclusion ignores Item 7 of the e)dsting NPDES permit(Appendix B,pages 2 (con's) 1 and 3)which stems that the RW CB encourages reclamation and reuse ofwastewater (Alternative 2)and requires as a part of a Report of Waste Discharge an evaluation of'reuse and land disposal options and alternative disposal methods. I This concludes our comments on the DEIR. In closing, thank you for the opportunity to comment on this document,. 7 I Sincerely, } David N.Bauer District Manager. 1RONHOUSE SANITARY DIS"t CT i +cx= � .0.5.LbOtr�+Je A�age€ikz d►�►fde 2-22 TOTAL P.O? Responses to Comment Letter 6 from the Ironhouse Sanitary District 6-1. The comment on ISD's use of reclaimed wastewater for irrigation on Jersey Island is noted. The City understands the distinction between "effluent disposal" and "use of reclaimed wastewater for irrigation" and this distinction has been considered in evaluation of alternatives to the proposed project. The City disagrees with the commenter's characterization that the draft EIR.characterizes Alternative 2 as an effluent disposal project. Use of reclaimed water/effluent on Jersey Island is merely one component of Alternative 2. The City notes the comenter's opinion that Alternative 2 is the environmentally superior alternative and does not dispute the benefits of use of reclaimed water for irrigation on Jersey Island. The City considers both the proposed project and Alternative 2 viable options to providing wastewater service in the City and has documented that both projects could be implemented with relatively minor environmental effects, all of which could be reduced to acceptable levels. Despite this finding,the City has determined that the proposed project is the environmentally superior alternative because the City is designing its WWTP to meet all of the RWQCB Waste Discharge Requirements for surface discharge to Marsh Creek and, therefore, would not adversely affect water quality conditions in Marsh Creep or the Delta. The draft EIR also notes that under Alternative 2 construction of the disposal pipeline across Dutch Slough would require breaching levees and trenching in Dutch Slough.;an activity that would require coordination with the U.S. Army Corps of Engineers, DFG, RWQCB, State bands Commission,and Department of Boating and Waterways. Additionally,the draft EIR does note that ISD's Wastewater Facilities Plan EIR(Ironhouse Sanitary District 1994) indicates that mitigation measures are required to reduce effects of reclaimed water irrigation on shallow groundwater conditions that exist on Jersey Island; a condition that must be closely monitored. ISD would also be required to prepare and submit a new report of waste discharge for future expansion of its Jersey Island operation. 6-2. The City has reviewed the draft EIR and could not locate references to "joint City and ISD WWTP." 6-3. Please refer to response to comment 6-1. 6-4. The paragraph noted is intended to describe the California Toxics Rule. The draft EIR on pages 3A-24 and 25 indicates that mitigation measures A-I and A-2 would be implemented to reduce significant effects of priority pollutants to a less than significant level. Mitigation Measure A-1 involves designing and operating the WWTP to meet National Pollutant Discharge Elimination System(NPDES)permit limits for priority pollutants.If the California Toxics Rule is adopted and permit limits are included in the City's NPDES permit, the WWTP effluent shall also be treated as required to comply with the applicable numeric City of Brentwood"?TP Project Chapter 2. Response to Comments Final EIR 2-23 November 1998 i i ' criteria for priority pollutants. Mitigation Measure A-2 would involve implementing a priority pollutant source control program,including.monitoring based on consultation with i the RWQCB. Both of these measures could increase the cost of constructing and operating the proposed project. The proposed California Toxic Rule would not apply to.Alternative 2. 6-5. The City is currently conducting studies to determine the realistic long-term capacity of existing wastewater facilities. The current estimate of 3.3-4.3 mgd for Phase 1 treatment capacity is the best available information to date. i 6-6. The "Hydrologic Impacts and Mitigation Measures"section in Chapter 3A of the draft EIR describes flooding issues associated with added flow to Marsh Creek. The draft EIR indicates on page 3A-19 that the assumed worst-case summer flow was no flow in the channel. The calculations are considered conservative because the stream normally contains I some flow and the channel is generally wider than 10 feet.The draft EIR indicates that a 15.5 efs discharge from the proposed project during summer(assuming no flow in Marsh Creek) would result in a flow that is approximately 0.9 foot deep with a velocity of 1.56 feet per 1 second. I 6-7. The dissolved oxygen(SAO) analysis 'included in the draft EIR.assumed background creek } flow would be 0 cfs. If up-stream flows had less than 5.0 mg/I DO, the proposed effluent discharge would not cause the creep's DO levels to degrade further because the DO levels of the effluent would still meet the minimum DO level of 5.0 mg/l. f 6-8. The City has been conducting monthly monitoring for priority pollutants; results are given in Table 3A-3 of the draft EIR. The City has no major industrial discharges; therefore, effluent will likely meet requirements of the proposed California Toxics Rule. The draft ESR indicates that if non-compliance becomes an issue, optimization of the treatment process and a source control program will be implemented. The costs of these programs were not included in the capitol costs but are expected to be minimal because the programs will be conducted by City staff. Costs for additional treatment processes, such as microfiltration and reverse osmosis that could be required to meet the California Toxics Rule,were not included i in the capitol costs presented in the City's Wastewater Facilities Plan. These costs have not been included for the following reasons. ■ With no large industrial user in the city, the likelihood of needing these treatment processes is minimized. ■ If non-compliance did occur, the benefit versus casts would be reviewed before constructing costly treatment processes. j 6-9. The draft EIR indicates on pages 317-5 and 6 that the proposed WWTP would be designed to be highly reliable and would provide an acceptable level of pathogen removal (2.2 MPN/100 ml total coliform count), even when summer background flows in Marsh Creek are minimal. In the unlikely event that the WWTP effluent would exceed coliform limits as City of Brentwood WWTP Project Chapter Z. Response to Comments Final EIR November 1998 2-24 i I a result of upset or failure,the City would be required by the RWQCB to post signs along the creek notifying the public not to go in the water. 6-10. The changes requested in this comment have already been incorporated into the draft EIR. No additional response is needed. 6-11. The proposed project will meet a 2.2 MPN/100 ml total coliform count year round. Tables 2-1 and 3A-4 will be amended. Please refer to Chapter 3,"Errata", of this document. 6-12. Comment noted. The City has referred to ISD's treatment and reuse for irrigation as "effluent disposal" for ease of reference and consistency within the draft EIR. The City understands ISD's distinction, and it has been considered as part of the draft EIR analyses. 6-13. The draft EIR is amended to include reference to a third railroad crossing. Please refer to Chapter 3, "Errata", of this document. 6-14. Comment noted. Please refer to response to comment 6-12. 6-15. The commenter's opinion on additional advantages of Alternative 2 has been considered and included in the administrative record. 6-16. The discussion of advantages and disadvantages of the No--Project Alternative and Alternative 2 are not intended to represent "impacts" as defined under the State CEQA Guidelines,but rather a discussion of relevant factors that the City has considered. The last two disadvantages on page 5-8 are the opinion of the City, as lead agency for CEQA review. 6-17. Comment noted. Please refer to response to comment 6-12. 6-18. Comment noted. Please refer to response to comment 6-12. 6-19. Comment noted. Please refer to response to comment 6-12. 6-20. Please refer to response to comment 6-1. City of Brentwood WWTP Project Chapter 2. Response to Comments Final EIR November 11998 i .. t Vetter 7 .101w fir' C Vn1A COSTA WATER WSTRI C t .rr 1331 Cmvord Avanus , U P.O.Bray 1420 �. Concord,CA 94524 (5i0)688-8000 FAX(510)688-8122 pt}�ltC�}�RKS August 12, 1998 Directors V Ltsr $' vbeg Fin 'Via Fax 9251634-6930 Jam prard } 1rcaPmdwx Mr.Thum Head,Public Services Director E''zabeth R.rneW City of Brentwood zee Soalmun Noe*0,e►o,kv,O.C. 708 Third Street walterJ.awhv Brentwood,California 94513-1396 drat marker Subject: Draft Environmental Impact Report for the City of Brentwood Wastewater Treatment Plant Expansion with Discharge to Marsh Creek j Dear Mr. Head: 4 `unit you for the opportunity to review and comment on the City of Brentwood's Wastewater Treatment Plant (R W7P) Expansion with Discharge to Marsh Creek I Draft Eli.. The project includes three principal components: i a four-phase expansion and upgrade of the City's existing wastewater treatment facilities, and construction of new facilities to increase flow from 1.8 to 10 million gallons per day; direct discharge of treated effluent to Marsh Creek;and j • expansion of the biosolids handling facilities to allow disposal to land or landfill. The project area is the site of the City's existing WWTP at 32.5 Sunset Road, east of Marsh Creek and State Highway 4. Communities near Brentwood are Antioch to the northwest, and the unincorporated communities of Oakley to the north,Discovery Bay to the east and Byron to the southeast. The CCWD boundaries include the northernmost portion of Brentwood along 'highway 4 and the western margin of Brentwood planned for new development. Brentwood has also entered into an interim water supply agreement with CCWD to supply treated water to the city from the Randall-Bold Treatment Plant in Oakley to the year 2003. 2-26 i rli40c d Mr.Thom Head,Public Services Director City of Brentwood August 14, 1998 Page 2 The 'WWTP discharge enters the Delta at Big Break and could reach the District's main Delta intakes at Rock Slough and Ofd River' through tidal dispersion, especially at times of low Delta outflow. The discharge will also impact the water quality at the District's Mallard Slough intake off the south bank of the Sacramento River (across from Chipps Island). Since the surface water supply for the City of Brentwood is currently, and will likely continue to be taken at the CCWD intakes or in their vicinity, any water quality impacts on CCWD would also impact the quality of water supply to the City of Brentwood. CCWD is very concerned about the cumulative impacts of increasing municipal wastewater discharges into the Central Valley and the Delta as a result of continuing population growth. Most of these new or expanded discharges are likely to be upstream of drinking water intakes in the Delta. ;increased pollutant concentrations at these Delta intakes will make it more costly and difficult for urban water agencies to meet state and federal drinking water standards which will become increasingly stringent in the near future. In particular, increaser) organic carbon, pathogens, salts, metals, and other toxins in the source water will, in the absence of adequate management controls and mitigation, lead to higher health risk and increased economic cost for the 22 million or more Californians using Delta water. These impacts are discussed to more detail to Attachment B. CCWD believes that all urban developments that would discharge wastewater into the Central Valley or the Delta should maximize the use of recycled water, bath within and outside the service areas of the wastewater treatment plants. Adequate measures to minimize water quality impacts on surface water, and in particular the impacts on municipal intakes should be developed and adapted. The CEQA compliance documentation should include a discussion of the practicable measures to reduce the volume of discharge into Delta channels and to minimize the pollutant loads in the -1 discharge. These measures should be included in the mitigation program for the project. COMMENTS ON THF,DRAFT EIR Water Quality Impacts(pa es 3A-19 through-25) The impact analysis indicates that reductions in dissolved oxygen levels and increases in electrical conductivity could result in minor reductions in water quality of Marsh t Contra Costa Water District's operations and facilities in the Delta is discussed in Attachment A. 2-27 rtrue CJJ Mr.Thom Head,Public Services Director City of Brentwood August 14, 1998 Page 3 Creek.. This impact is considered less than significant. While the Waste Discharge Requirements (WDR's) for the City's NPDES permit renewal are referenced as mitigation for several of the water quality impacts that are identified,there is no VrDR requirement that addresses salinity directly. Other wager duality parameters of concern to drinking water treatment, such as total organic carbon, pathogens, and toxins,could also increase as a result of the project. Any increased wastewater discharges to Marsh Creek will enter Delta channels (the San Joaquin River and Butch Slough)at Big Break.. A fraction of the higher pollutant load could reach drinking water intakes in the interior Delta, including CCW Vs, when the Delta outflow is tow. The discharge would also reach the District's Mallard Slough intake: near Hanker flay. They Final EIR should acknowledge this potential impact on drinking water supplies and incorporate all practicable measures available to reduce the volume and pollutant load of discharges to miniinize or avoid impacts on drinking water intakes. Practicable measures would includt adherence'to,fest Management Practices (including water conservation),pollutant � � i tattling options, and reclamation and reuse v,f"wastewater. Reclantallon and reuse of wastewater, which is encouraged by the RWQCB, could effectively eliminate the need to discharge to Marsh Creek. Cumulative Itnpabcts-Water Qg ty tpages 4-5 thr pugh�9� It is indicated that the proposed project would contribute to cumulative water quality degradation, but that it is considered less than significant (page 4-9). It is concluded that no mitigation actions are necessary. This analysis, however, only references the City Generul plan EIR and its conclusion that the"flooding and water quality impacts I in Brentwood would be cumulatively influenced by development throughout the Marsh Creek watershed". Neither the General flan FIR or this Draft EIR offers an analysis of water quality cumulative impacts beyond Marsh,Creek. As noted above in the comment on Water Quality Impacts, there is a potential project incremental contribution of Higher salinity to the San Joaquin River, which is already impacted by high chloride and salinity levels influenced by other municipal, industrial, and agricultural wastewater discharges. The Final EIR should expand the cumulative! 7_3 inipacts analysis to include an evaluation of the cumulative effects of increased municipal and industrial discharges arra Delta water quality. I A to ative tial sis Alte ative 2. Raw Se wa a onve ance: to es 5-7 ',thou lei -►9i i i 2-28 i Mr.'Thom Head,Public Services Director City of Brentwood August 14, 1998 Page 4 Alternative 2 is the construction of a new raw sewage conveyance pipeline from the City's existing WTP to the LSD WWTP in Oakley. This would allow the City to convey a projected 4 mgd of raw sewage by 2017 for treatment and reuse for irrigation (effluent disposal) at ISD lands, including Jersey Island. It would rewire the construction of a raw sewage pump station on the existing City WWTP site and an underground 30-inch force main nearly 4.2 miles north along surface streets, including an underground crossing of the Contra Costa Canal, to the ISD WWTP. Conveyance of the full 10 mgd of City generated sewage would require an expansion of the ISD facility from 8 mgd treatment capacity to 18 tngd capacity in order to replace the capacity taken by the Brentwood project. This would require a future CEQA document prior to construction before 2017. . The combined effluent and sludge disposal requitement is 2,510 acres, assuming an 18 mgd oxidation ditch treatment system. LSD owns 3,200 acres on Jersey Islandas well as other lairds adjacent to the ISD usable for irrigated disposal. On page 5-9 under Hydrology and Water Quality Impacts, it is stated that "this alternative would not result in any discharge to surface waters...." On page 5-16, it is also stated that "expanded treatment facilities on ISD property would not result in adverse effects on adjacent land uses because... a 1,000-foot buffer would be 7-4 maintained between the new WWTP and adjacent land uses (Ironhouse Sanitary District 1994)". 77te Final FIR should note that some of the ISD irrigation lands are adjacent to unlined portions of the Contra Costa Caiud and Heat with heavy applications of effluent, there is the potential for infiltration onto the canal wester supply as well as increased pressure on the canal levee embankment_ The risks to the Canal are expected to be reduced as ISD increases its use of,jersey.Island for disposal, However, Alternative 2, by increasing the amount of sewage to be treated by ISD from an 8 to 18 rngd, could result in the need to continue applying effluent neat to the canal, increasing the risk of infiltration or canal levee failure. Environmentally Superior Altemative(pages 5-19 and-20) It is stated on page 5-20 that "the proposed project (i.e., WWTP Expansion and Discharge to Marsh Creek] is the environmentally superior alternative because it would involve the least amount of physical disturbance during construction and virtually all of the WWTP effects'would occur within an enclosed compound that has already been highly disturbed". Given the comments above on the potential for an incremental increase of salt discharges and possibly other pollutants, including pathogens, itao die Scut Joaquin Vcha, this cottc.lusion shuuld lw ra eco It is � 7`5 2-29 t Mr.Thom Head,Public Services Director City of Brentwood August 14, 1998 Page 5 recommended that the Final EIFt include quantitative means or methodology to � .7-5 determine the environm enta y superior alternative. (Ic0n t) CCWD appreciates your consideration of these comments. Please contact Mr.Dennis Pisila at (925) 688-8119 if you would like to discuss any of these issues in more detail. Sincerely, t I of Greg Gartrell Director of Planning Attachments i WIFGIDP/KTSfrlr i j i I I 2-30 I Ub Attachment A CCWD OPERATIONS AND FACILITIES The Contra Costa Water District ("CCWD") serves approximately 400,000 people throughout north-central and east Contra Costa County. Its clients also include 10 major industries, 36 smaller industries and businesses, and 50 agricultural users. CCWD operates raw waster distribution factities, water treatment plants, and treated water distribution facilities. CCWD supplies raw and treated water to Antioch, Concord, Diablo Water District (serving Oakley), Pittsburg, Southern 'California Water Company (serving Bay Point),Martinez, and parts of Pleasant lfill and Walnut Creep. CCWD The treated water service area for CCWD encompasses all or part of the cities of Concord, Clayton, Clyde, Pleasant Hill, Walnut Creek, Martinez, and Port Costa. Treated water for this service, area is provided from the District's Bollman Water Treatment Plant in Concord. The Bollman facility is a 75 MGD conventional plant which is currently being upgraded to include intermediate ozonation. CCWD also supplies treated water to the Diable Water District("DWD"), which serves customers in Oakley from a plant jointly owned by CCWD and DWD. The Randall-Bold Water Treatment Plant is a 40 MGD direct/deep-bed filtration plant which utilizes loth pre- and post-ozonation to provide a high quality drinking wavier to the customers in its service area. CCWD is entirely dependent on the Delta for its water supply. The Contra Costa Canal and the Lets Vaqueros Project (partly completed with full operation expected by mid-1398) make up CCWD.s principal water supply and delivery systern. CCWD diverts unregulated flows and regulated flaws from storage releases from Shasta, Folsom, and Clair Engle reservoirs into the Sacramento River as a contractor of the United States Bureau of Reclamation's ("Bureau") Central Valley Project ("CVP"). Under Water Service Contract 1750401 (amended) with the Bureau, CCWD can divert and redivert up to 195,000 acre-feet annually ("AFA") of water from Rack Slough and the new Old River intake. Currently, CCWD uses between 125,000 and 140,000 AFA. CCWD can also divert up to 26,780 AFA of water from Mallard Slough under its own water rights (Water Rights License No.3167 and Permit No.19856). The City of Antioch and Gaylord Container, both customers of the District,also have water rights permits to divert water from the Delta. CCW'D has obtained its water supply from the Delta since 1940. Delta water is subject to large variations in salinity and mineral concentrations and this water supply has made CCWD and its customers vulnerable to any man-trade or natural sources that could degrade Delta water quality. Water quality changes in Delta water are noticeable to those who drink the water or use the,water for commercial and industrial processes. Degradation in water quality is objectionable to many CCWD customers, costly to all residential and industrial users, and a health risk for some individuals- 2-31 ritru: c�st HAGE 07 i i� 4 { Degradation of Delta water quality impairs the beneficial uses of water supplied by CCVVD to its customers. Contra Costa"Water District is committed to supplying its customewith the highest quality water practicable and providing all reasonable protection of the supply from any known or potential source of hazardous contamination. CCWD Resolution No. 88-45 states in past that: "CCWD is committed to reducing the concentration of sodium and chloride in the District's water, thereby reducing household and landscape irrigation concerns and industrial and manufacturing casts caused by the fluctuating sodium and chloride level of CCWD's Delta source...." In May 1987, CCWD's Board of Directors adopted water quality objectives for water distributed within its service area.. The acceptable concentration levels for sodium and chloride were established at 50 milligrams per liter (mg/1) and 65 mgtl, respectively. to 1988, the voter-constituents of CCWD approved the issuance of ! bonds to finance a$450 million water quality and reliability project known as the los Vaqueros Project. The primary purposes of the Los 'vaqueros Project are to improve the quality of water supplied to CCWD customers and minimize seasonal quality changes, and to improve the reliability of the emergency water supply available to CCWD. The Los Vaqueros Project consists of a reservoir with 100,000 acre-feet of storage, a new point of diversion (at Old Diver south of the Highway 4 crossing) which operates in conjunction with the current Rock Slough diversion paint, associated water conveyance and delivery facilities, pumping plants, and other facilities. On Jane 2, 1994, the Mate Dater Resources Control Board issued Decision 1629 which gives CCWD additional rights to divert and store water for beneficial uses. Ibe State Board subsequently issued Water Rights permits No. 20749 and 20750 for filling Los Vaqueros Reservoir from the new intake at Old River near Highway 4 and diversion and storage of the water of Kellogg Creek. These= rights are in addition to the contractual rights to divert and store water furnished through the CVP. Construction of the reservoir began in September 1994 and diversion from the Old River intake for delivery to CCWD's service area began in the summer of 1997. Up to 95,850 APA may be diverted for storage between November I of each year to .lune 30 of the succeeding year under Water Rights Permit No. 20749. A key to the successful performance of the Los Vaqueros Project is the District's ability to fill and continue to refill the reservoir from Old River with high quality water and to use that water for blending when salinities at the District's Deltas intake: exceed Clic 65 ing/L chloride goal. Any inc;re a,,o.� in Delta salhiitic s causc d by new Bay-Delta projects will increase the demand on blending water- from the reservoir i 2-32 r UDL-.L Vk ULn PAGE 08 while at the same time reducing the availability of high quality water for refilling. The District and its 400,000 customers will be impacted through higher pumping costs to replace the extra blending water that is released and through the additional treatment costs, increased corrosion and health effects of delivering higher salinity water. 2-33 I i I i } I i Attachment B j IMPACTS OF HIGIUR CONTAMINANT CONCENTRATIONS ON CC'Vf D Wastewater discharges in upstream and Delta channels directly impact the water quality at municipal intakes in the Delta. Because of the location of the project south east of the Tracy Pumping Plant and Clifton Court Forebay, the impacts of river disposal will be greatest at those intakes. However, any additional contaminant disposal into ripper told River will also affect the water quality at CCWD's two Delta intakes on Old River near Highway 4 and in Rack dough when Delta exports are low or when the south Delta flow barriers are operating. Degradation in water quality could injure CCWD and other water users downstream t in a number of ways: 1. hicreased salinity (quantified as total dissolved solids, chloride, bromide, and sodium t concentrations) will impact industrial and municipal uses by increasing corrosion and, causing health problems. 2. The water quality goal of CCWD's $450,000,000 Los Vaqueros Project is to provide District customers with water at,or below 65 mg/l chloride concentration. The water quality improvements with the Lis Vaqueros Project come from a new intake at told River near Highway 4 and from the storage of high quality water in Us Vaqueros reservoir for use to blend Delta diversions down to the 65 mgfL. chlorides goal. A higher salinity in the Delta will reduce the performance of the Los Vaqueros Project I by decreasing the amount of-water available for storage in the reservoir and increasing j the salinity of both the stored water and water diverted directly from the Delta, and increase pumping costs. i !, 3. Higher pathogen concentrations (e.g. Cryptosporidium and Giardia) in the source water increase treatment cost and the risk to public health. 4. A, higher pat'ticulate and dissolved organic carbon concentration in the source water would require a. higher ozone dosage and increase treatment cast. A higher ozone dosage also increases the level of disinfection by-products such as bromate in the treated water, increases health risk to the public, and makes it more difficult to comply with existing and future drinking water regulations. i 5. Higher concentrations of heavy metals and tither toxins could lead to exceedances of national drinking water standards for primary pollutants. The number of regulated pollutants has been increasing in the past twenty years and will increase further as a result of the recently re-authorized Safe Drinking Water Act. 1 1 b-34 The California water user community has expended a great deal of effort to develop programs for improving water quality in the Delta. Contra Costa 'Water District, in collaboration with a number of urban water agencies,has been an active participant in the development and implementation of the Bay-Delta Accord, implementation of the Central Valley Project Improvement Act, and the CAI ED Bay-Delta Program. The District has contributed both funding and in-kind services to stop degradation of Delta water quality and improve conditions in the Delta. The District believes that source control is one of the critical elements in these efforts, Potential degradation of Delta water quality, if left unmitigated, will significantly reduce the benefits of nullify these efforts that have been made at significant costs, 2-35 i f Responses to Comment Letter 7 from the Contra Costa Water District i 7-1. The City understands Centra Costa Water District's(CCWD's)concerns regarding general water quality in the San Joaquin-Sacramento River Delta (Delta) and has considered this general concern in the responses to CCWD's comments on the draft EIR,below. 3 7-2. The analysis of water quality impacts and mitigation measures presented on pages 3A-19 through 3A-25 of the draft EIR identifies all of the potential water quality effects that could result from implementation of the proposed project, including impacts from temperature, pH, turbidity, biological oxygen demand(BOD),total suspended solids,total coliform bacteria,biostimulatory nutrients, dissolved oxygen, and electrical conductivity. All of these potential impacts are i considered less than significant for the reasons stated in this analysis. j In the case of salinity impacts, the analysis presented on page 3A-23 (and in Appendix C) I indicates that electrical conductivity(a measure of salinity)would decrease assuming that the City would increase the use of treated surface water for domestic consumption in place of groundwater. The draft EIR also indicates on page 2-7 that the City has already installed I distribution pipelines for reclaimed effluent in city streets to accommodate future reclamation projects. The City wants to maximize use of reclaimed water. The City will also continue to € dispose of treated effluent in the existing effluent disposal ponds to the maximum extent possible. ! Through these efforts the City anticipates that the amount of treated effluent discharged into Marsh Creek will be minimized. i 7-3. The City understands CCWD's concerns regarding cumulative effects on Delta water quality from increased municipal and industrial discharges and is committed to ensure the proposed project has no significant adverse impacts on Delta water quality. A more detailed discussion of cumulative Delta water quality effects was not included in the draft EIR for several reasons: ■ The 15.5-cfs wastewater flow proposed to be discharged by the City of Brentwood constitutes such a small percent of the water cycling through the Big Break area that its contribution to effects on regional Delta water quality conditions would be judged less than significant. After the initial discharge is diluted in Big Break tidal flows,the water 1 will eventually enter the San Joaquin River near Antioch. The actual dilution volume of the 15.5-cfs discharge would be intermediate between the net flow of the San Joaquin j River at Antioch and the flows resulting Born tidal exchange. The limited flow measurements for Antioch from the U.S. Geological Survey using ultrasonic velocity measurement techniques were used to develop a regression relationship to estimate flows at Antioch using flows at Rio Vista and {west. During 1990, a relatively dry year, '• estimated Antioch flows varied from -3,500 cfs to 12,000 cfs, and during 1996, a relatively wet year, estimated Antioch flows varied from -3,500 cfs to 40,500 cfs. Delta flow modeling by the California Department of Water Resources for May 1988 (Oakley-Bethel Island Wastewater Management Authority. January 1990. Data Supporting a Surface Water Discharge for the Oakley-Bethel Island Wastewater Management Authority.)estimated a minimum tidal volume change in Big Break of 340 i City of Brentwood WWTP Project Chapter 2.Response to Comments rinat EIR November 1998 2-36 million gallons(MG)and a maximum of 2,210 MG,with the smallest volume change for 2 consecutive tidal cycles being about 1,100 MG. The 15.5-cfs discharge from the City's wastewater plant represents only 5.2 MG during a tidal cylcle(1.5%of the smallest tidal volume change). The 15.5-cfs worst-case wastewater flow is very small compared to the tidal flows in the San Joaquin River near Antioch. Tidal flows measured by the U.S. Geological Survey upstream from Antioch have been as large as 144,000 cfs (Gage RSAN018,http.//www.iep.ca.gov). The 15.5 cfs discharge would have minimal effects on water quality in the Delta because it represents such a small flow compared to the San Joaquin and Sacramento River water moving through.Big.Break and the Antioch area. ■ Average flow and tidal exchange rates in the Delta are large relative to the proposed discharge and would provide substantial dilution capacity for potential contaminants. • Evaluation of project-specific impacts indicated that water quality impacts in Marsh Creek would be less than significant and potential effects of priority pollutants could be reduced by proper design of the WWTP and implementation of a source control and water quality monitoring program. ■ Given the factors above,a quantitative analysis of cumulative Delta water quality impacts is not warranted and is beyond the scope of the draft EIR because the City's contribution to cumulative impacts would clearly be less than significant. Despite these findings,the City agrees that the proposed discharge could contribute a small, less- than-significant amount to the cumulative loading of contaminants in the Delta and will amend the cumulative impacts analysis to include a qualitative discussion of potential cumulative Delta impacts. 7-4. If Alternative 2 is implemented,it is the City's understanding that ISD would not apply reclaimed water to lands adjacent to the Contra Costa Canal at rates higher than currently practiced. Most likely,the application rate on these lands would decrease as ISD expands the reclaimed water operations on Jersey Island. 7-5. The City considers both the proposed project and Alternative 2 viable options for providing wastewater service in the City and has documented that both projects could be implemented with relatively minor environmental effects,all of which could be reduced to acceptable levels.Despite this finding, the City has determined that the proposed project is the environmentally superior alternative because the City is designing its WWTP to meet all of the RWQCB Waste Discharge Requirements for surface discharge to Marsh Creek, and therefore, the proposed project would not adversely affect water quality conditions in Marsh Creek or the Delta. Because these two projects are fundamentally different methods for disposal of treated effluent, a quantitative environmental comparison is not possible; however, the City has included a methodology for comparison of all ofthe possible wastewater capacity alternatives in its Wast-water Facilities Plan (Montgomery Watson 1997). City of Brentwood WWTP Project Chapter 2. Response to Comments Final EIR 2-37 November 1998 AUG-13—i9% yUG- ryryi9% qq }�yy 01/05 (yy4. Letter 8 I CALIFORNIA U1tNAH WATER At3ENCfES Maust 13, 1999 Mr. Tbom Head Public Setrvieft Director City ofBrent rood , 708 Third Street Brentwood,CA 94513 Draft Fx-,irottmental Impact Report Wa9xewat Tr Fl `+gin Zvi <C Dear Mr. Head: The Califo tylia Urban Water Agencies("CUWA"j is an organization representing the state's twelve largest municipal watar pmviden serving over 22 million water consumers in the Catty cif Sacratnento,San Francisco Ray Area and Soutf=Cali ornia. Our member agencies use about WK ofthe urban wutr supplies tabu f vm the Sacramento-San 7oaquin Delia and its ttbturus. The following contents are in resgowe to the Draft EnvironmeaW impact Report I (DEM)for the City ofB ntwood's wastawater trent plant o"asion. The proposed project involves the construction of wastewatertreatm=t facilities needed to incresse the capacity of the existing plant ftm l.8 million gallons per day(mgd)to 10 mgd with a discharge to Mush Cry,a tributary to the Sacrame:vto-San Joaquin Dalta. CU'W'A and its member agencies operate under a long-standing policy to prate4 and preserve the intcWty Of water rft=cea of the Sacra m to-S'an Joaquin watershed to ensure the wed suitability ofd diverted fm=the Dealt&for driuldrig water pwPoses. We are plea3ed'that the City is proposing a high lel of wastewater trent prior to discharge_ In the comments below,we am requesting the final EI elaborate ou me&pAv3 to be incorporated into the prrsPosed project to ensure that impacts to receiving water quality would be teas than significant In support Of our comments,we would like to bring ttD the anernion of the City the f0110wing water quality issues Acing water utilities diverting drinking water supplies from.the 1. Drinl£im Water Owlt Issues The quality of the watrr in the Deha as a source of drinking water supply is marginal and compliance with incrusingly stringent dritnit ng waster"standards is becoming problematic. CU'W A.members at-e spending hundreds of millions of dollars on measures to address source water qualify problems to provide Modest improvements in the quality of drinking water diverted from the Delta,1 in contalst„we are lware of a number of proposed projects that would result in increased po ni and nonpoint pollutant discharges to the watershed i wtdck left utunhigated,would si cantl impair Mita water impair the �'� p quality and COMM COKa Wale`DisMM Los Vgq=m Rv=vw 5454 medic,Cz=M COM Wat= Mutton Watier Muit of&rjthcrct C.9&=w Sa=Clam Valley Wore Di,*=mm tc u=zd a pracclxzxzzatdy S- n t 455 CAPIrOL MALI, *105). SACRAMENTO, CA 9581# 916-S519•4929 FAX 9ttr•5551•2931 ` f 2-38 r At lrri 3-19?8 f 5 36 Pace-L43GAN 619 523 4194 P.02105 Mr.Thom Bead Coguggggs gra WWrP DEER Augua 13, 1999 PUP Z of pe .eof a significantinvestment in facilities to address Delta water quality Prvbte n Of cow=to Brit king,v,r4er utilities arc ccmtarAinants such as disinfection by-products(D]Vs), DBp pre;t=sors total organic carbon(TOC)and bromide,pathogens,total dissolved solids (TDS)arsd cMoride. Cucre ndy,the onal Board does not re;plate many ofthese COiltaIrYi218SftS. A. T mr r4dn and Disinfectim 13y-1191M 1.n i996,the United States Congress re,.authorixe;d the.Safe Drinking Water Act. As part of that reaauchorixation,Congress mandated that the U.S.EPA promulgate Stage 1 and Stage 2 of the Dimferctants0isinfe ctinn By-Product(DIDBP)We by November 1998 and May of 2002, respectively. The DIDBP Rule calls for sig-nsfscant toweling of the standard for tnbalornethanes(rHMs),bromate and other dinnfection by-products(DaPs)mud for the first time in the history of the Safe Dr4+.ing Water Act,Congress identified TOC as a contaminant that drinking water utilities will be required to remove from their source`waters. The Stage I Rule will require drinking water utilities to reduce influent TOC beginning in November 1998. Twenty-five percent of the TOC in the influent to the water treInient plant must be removed when the ambient TOC owcentration is less than or equal to 4.0 mg/L. Thirty-frvo percent of the influent TCC mist be removed when the influent TOC concentration is greater thin;4.0 mg(L The ambient TOC concentrations of Delta water are g cncrally greater than 4.0 mgtL in the winter months and slightly less than 4.0 mg/L during the summer. Left uuttmi699cd,the;=uWatiNv iMPW of addit vsral point and nonpoim discharges to the watershed will likely to rein a year Around m eeda+nce of the 4.0 mgfl r TOC starnxiard,and additional cost of treatment far the drinking water utilities on the order of millions of dollars Far year. Regardless of the type:of treatment einployed,increases in TQC levels in source water can have significant impacts on water treatment operations and DBP levels in drinking water supplies. Uncles Stage 2 of the Safe Drinking Walter Act drinking water utilities may be required to reduce THM levels in their treated water from the curreut s lard of 100 98&to 40 gg/L. The discharge of increased quantities of IBMs and THM precursors to the Delta would make it more difficult fbr CUWA members to comply with THM standards and could increetse human health risks associated with the production ofTHMs and othcr DBPs in treated drinking water. TOC and bromide are the DBP preairscm in Delta waters that present the greatest health and regulatory concerns, Disinfection of drinking water supplies containing elevated concerrtrations of TOC or bromide results in the formation of hundreds ofDBPs. Exposiu-e to tbese chemical by-products of drinking water disinfection has been shown to cause cancer- other DBPa may cause adverse developmental and reproductive offects. Thus, even short--turn Spikes in TOC and Dl3Ps could be sufficient to trigger serious public healttb impacts. S. PaChago-s Also of concern to the drinking water utilities are pathogens. Cryptvqw ldium and Giardia are two protozoan pathogens that are found in treated wastewater that are resigtsnt 2-39 FW-1.3-1998 15.37 RP LPCZA3 619 523 4194 P.03/05 i Mr.Tbom Ftrd cocimme tact WWII"DM 13,1 "a PAW 3 of 3 to chlorixic and can survive in the aquatic environment for very long paieds. There are many I species ofthe p!°�&wn otgarsism The one most commonly associated with human disease is trryplaTorr&mparm r,which causes the domse cryptospondiow. Symptom of the disease are flu tike,,with most common symptoms or complaints including abdominal 1 crunping,,nausea, ctisrrhea,weakness,and f tt guo. The disease is not treatable. ,tri healthy I indiv°icioals it is 34f-lisn%tin&bit it can be fatal to those with weakened immune systems,such as Ch=t3ftmp'y patients,organ transplant rMilrieW,people with f fV,the elderly,el 4 the very young. •There are outbreaks of c ryptuspond'tosis oca iaTing throughout the wortd. The largest coed outbreak of the d saw to date occwred m 1993 in Milwaukee. in this single episode, more than 400,000 people became ill with symptmns of tete disease, and soores died from it. r Wye the specific source ofthe contaxnination has yet to be confirmed,a recent study sunests that human waste in city water drawn from Lake Michipo was the source ofthe N ilwaukee outbreak-, Currently,Crypfo*m&ww is meted,in large part due to uncertainties in ci=ent measurement techniques,i ques, The Information Collmion Rule,which began in July 1997 and rusts for IS months.requires larger drinking water utilities to sample cad test for ! Cayp&mp orardizt+irr. The long-tem Enhanced SmIke Water Treatment Rule may include C.SryptaVoru'ua!i►t inactivation as well as removal r quiremems. It will be promulgated in November 2000, and by November 7003, all communities with populations gseater than 10,000 1 that use surface water will he required to be in compliance. poi'utilities employing conventional tri the higher pathogen concenuatitms could bc probl atie,as they would be unable to ina ase+pathogen removal and inactivation without significant capital investment and increased mon and mat kdentanace cost For water utilities employing ozone as their primary disinfectant,the likely impact is a significant inert in ozone demand and possibly additional cVitasl invests neat it odes to achiove higli=levels of Inactivation of pathogens. Tbus, j regsrdlcss of the type of treatment employed,4=cxses in source water pathogen levels can have significant impacts on water treatincut opeusdarts and presents serious public health c onccrn& C. T-oW DiMly-edSolids okride I Total dissolved solids(TICS)and chloride conceatrations are also of ooncernt to the drialdug crater utilities. Under las csent Iota operating criteria, elevated TDD concentrolions j wm dd resWt in the Central Valley Project(CVP)and State Water Project(SWIG)leaving to release additional waiter from storage to comply with DcU water quality standards. Increased Ti)S inn source water WOUld also have air awe impact on waste discharge permit compliance and water management programs of the CLTWA.ageneses; most notably water recycling and groundwater storage proguns. Ct1WA member agencies have invested over a billion dollars in capital facilities to maximizetheir water recycling and groundwater storage opportunities, The *A 1997 Cc&zr fur Discam C4ntwl atudy riggmts that Ox==of CrypksportraJwm pavom in the mAwa Outbreak is human radvr orates t mma. LTb'ix:g polymerase claw rem iocbWgwa faun Jwl�wa t egad :from the"luvAm au t vak All faint isaWm vmm f+ot w to hm a gmcgy cumved way in isoiatea ttosu Wham CDC's Cb2rka Bcwr L vac of tbe.avhrirs arthe staff,acid that the o*suggests tbat hum=wwtc in city wam dire"ftvin,Tali.loodu A was&e wa=of tft mhvmd=oaftwk is ma vft and AOA of 1993. (C�o� 'da uw Capnde VaL 3,hsw 1,Novonber 19M, 1 2-40 OU U'J�,c;I t-7']41 .. �,t r.a/?d f 7'14it 1 F. R At_1G-13-1998 15=37 PMPt'l..F+OGM 619 523 4194 P.04/05 Mr.Tb m►Had CQAUV=ft on WVM I)MR Anva 13.1999 ftV4of5 1 s s of these water�cm�PTO is c upon fire availability Of On ar table cfwatT wai r from the Delta L.octl and regional v eer gla aircg ° rY decWons have beep based upon SWP conblad pro VWOns which spercifies a TDS objective of 220 MS/L en average.for any ton-,ypeaiod and# ? for OY zno#z Over the last teir yrars, TDS cottcentratiom of the SWP have cv istm*exceeded the 220 mg/L.objective. As a;re it, local water and wwwwlter atv=e s throughout the SWJ>and CVP samce areas have had difficulty rt„ cplyistg wi#h Waste discharge re Wwttents and in some cases are operating trader t �Y waivers from the Re&uat WNW t�uality Control Boards. Sncr�ses in TDS coetcentrimons in the Delta will fiuther exacerbate diVWp per�compliance problems. U. Aa c A. si i ce Criteria '1'hrDEUL should not assume that pimply becum the expanded wastewater tieattr al pie=scrvitag the City WMW comply with elrglicable water quality objectives,policies and pamits,that the overall project would not ase a si0ii3cant impact to water quo"ty These $-1 water quality objectives,Policies and permits do not take into cumsideration the teed for t utilities to be abler to consistently riorc►ply with the requiremcM of the SR&Dfill dV9 Water of 1996, �) pathosten Control The DEM provides that the d'ischarge is to receive tittle or no dila on during many months of the year and that the efferent would be required to be a disinfected filtered, secondary effluent with no more than 10 mgfL of biochemical oxygen demand(BOD)and total suspended solids(TSS)remaining,and disinfected to produce a total c Oliform count of 23 (most probable number of coliform organisms per 100 milliliters(NVNI100 ml)). For discharges where the ratio cif down= am writer flow to dfiucm at tour stream flow is less than 0 o 1,t3 e 8-2 Dept of Health Se Mces(STS)recommends that the eluent be ade to y (median WN of ccsfiform orgaais=doe8 not exceed 2.2 pen° loo mi),oxidized,coagulated,and I filtered w ' 'T wastewater to ensure adequate pathogen control.' final EIR should addr=the l discrepancy betweeu DHS"a recommended level of pathogen control and that proposed by in the 2) Solids,Chloride T17,0 DEIR states that the discharge of conversional pollutants would result in a an impact than is less than significant. This claim is nest adequately suppdtted try the iitfatmatiosn 8.3 contained in the Dom. The a=nt NPDES permit does not Have numerical limits for TOC, 'Ce f ecu a DVa==U at`He9th Smvicxs,SAatar'Y EnW=M9 nlnadr`"W"'C-OW DiSwfettiotc fdr He4th PmtCaicm"Q°cbnwy 1587). 2-41 jAEJ -13-1 i5 P3 9 CL�t U9 523 41134 P.OS./05 1 rt.'Ibrm a 11=d Cacnacaft an WWTP DM 13, 199S P s cf s j MPs,TDS or chloride and there is iudequate iltdort vwon in the DEIR regarding anaa=re:s to 1 control the discharge a these polite of cone m As dim in section I.A. and I.C. above, elevated concentrations of these coustittwnts in the proposed discharge may have a significant 1 impact on d wnstreastrn rnunie pal and industrial beneficial uses. T;ra f ud E.should describe ' the fWowiug: } a) Ability of the proposed wastewater treatment process to cowl TOC and DBP 8`3 (can't) b) NkA&=the City would employ to comply with Renal Water Quality Control Board moments that dischargas use the best practicable cost-dTwtivc costuvt f gigue cirreutly available to limit'ISS to no more than a masonable inc lent; axid c) Pmacdve3 atctiaas to be undertaken by the City to m>1 dmize the use of recycled water and conservation mems m to minimize the need to cliscbarge to NUrsh Creed. C. tCmxlative Im2actg The environmental review of'the proposed project should include an evaluation of the cunuilative effects ofprajwt irnple mcatidom In assessing the cuumintiv'e impaom of the project,the emviroxemental review ahculd consider all reasonably formeable wurces of water I pollution,irtcltading nonpamt runoff from the newly urbanized parts of the City served by the i oq=ded wastowder autnent capacity. Tw praject impacts should be considered in conjunction with other prciects.pladng similar pressurev cc the quality of&mkingwater 8-4 ( vertu from the 5a ewo-San 3oaqum wat ed,including,but amt limited io the S=zmento CSD WWTP ocpansion,City ofVacavillc WWTP expansion,Discovery Bay WWTP cqm sura,City oPTrzcy WWTP espanskm proposal Sutter Power Platen,Mounta n i House CSD WWTP,and proposed Delta Wetlands Project, { CUWA appremzt=the opportunity to comment on the;DEIR.for the City of Brentwood waamate r'int plant a zpausiou. We look forward to working with the City staff in the development of an env rortnaW review process that will ensure the success of the s project. Please 3dd my name to the,prchject trailing list. If you have any questions,ple a feet free to contact CU WA's water quality comhata,Peter MacLagga n at(619)523-4661. I Spy, ExecutiveDirector oc: Carer Carlton,CVRWQCB Wait Pefst,SWRCB Dr.Ptviei Spar,DHS Ride Breuer,DWR. i Susan Roffman,MR 1 TOTF` P.0 i 2-42 J i I Responses to Comment Letter 8 from the California Urban Water Agencies j I 8-1. The City understands the California Urban.Water Agencies' (CUWA's) concerns regarding use ofRWQCB,Waste Discharge Requirements(WIDR);however,the anticipated discharge requirements presented in amended Table 2-I are the expected RWQCB standards by which the City would be required to design and operate the proposed WWTP. Although these requirements do not restrict the City from implementing other programs, such as water conservation and reclamation, that could reduce the amount of treated effluent that is discharge to Marsh Creek and the Delta,for the purposes of evaluating water quality effects of the project, the RWQCB's WDRs are the standards the City must meet. A discussion of the hydrology and water quality impact significance criteria is presented on page 3A-17. 8-2. The proposed project will meet a 2.2 MPN/100 ml total coliform count. Please note that Tables 2-1 and 3A-4 has been revised to reflect the RWQCB's current review. Please refer to Chapter 3,"Errata", of this document. 8-3. The City understands that the CUWA is concerned with the following issues. ■ the effect of the proposed discharge into Marsh Creep on total organic carbon and ?, disinfection by-products, ■ the City's methods for controlling total dissolved solids in its discharge, and • the City's proposed actions to maximize water reclamation. i The anticipated NPDES permit will require the City to meet an effluent BOD of 10 mg/l. In meeting this requirement the level of total organic compounds(TOC) in the effluent would be in the approximate range of 10-15 mg/l. The City is also using an oxidation ditch process with an approximate mean cell residence time of 25 days, which will also help to minimize TOC levels in the effluent. It is the City's opinion that TOC effects of the discharge would be minimal because the WWTP will meet stringent discharge requirements(by employing an appropriate treatment process)and the volume of water and tidal action in the Delta would have a substantial dilution effect. The City is currently evaluating the type of disinfection method that will be used at the WWTP; either sodium hypochlorite/sodium bisulfate or ultraviolet disinfection. The City is aware that the use of ultraviolet disinfection would decrease disinfection by-products, and this method will be considered when disinfection alternatives are evaluated. As discussed in the draft EIR, the City is currently using surface water to supplement its potable water supply. This trend is expected to continue and the projected annual use of surface water in the future is 22,800 acre-feet.Groundwater use will constitute approximately 3,800 acre--feet. The electrical conductivity of existing groundwater is 1,235 uS/em. The electrical conductivity of the proposed surface water is 4I1 uS/cm. Because of this Chapter 2. Res nese to Comments # City of Brentwood WWTP Project F P Final EIR Vavem6cr 199 2-43 i difference,the City anticipates that electrical conductivity values in its effluent will decrease. Please refer to,pages 3A-23 and 24 of the draft EIR. The draft EIR indicates on page 2-7 that the City has already installed distribution pipelines for reclaimed effluent in city streets to accommodate future reclamation projects. The City wants to maximize use of reclaimed water. The City will also continue to dispose of treated effluent in the existing effluent disposal pends to the maximum extent possible. These efforts will ensure that the amount of effluent discharged to Marsh Creek will be minimized. 8-4. Comment noted. Please refer to response to comment 7-3, above. �y I f 1 1 t 4 1 1 1 1! i City of Brentwood WWTP Project Chapter 2. Response to Comments Final ErR November 1998 AUG. 13. IS98 4:59?� nuo Mal* Letter 9 011.R.zacxmaw GtiVN&�t- Dents,tatt�t HarercftA�t Ttam M.ZMhWM CENTRAL DELTA WATER AGENCY 235 East Webo Avenue 0. Bax 1461 + &twaktod,CA 95201 phone 2ti 46. s August 13, 1998 i 925 91 Vis Facs"S' mil f Thom Head, public Services Director City of Brentwood Public works Department 703 Third Street BrQntwood, CA 94513 Re. Comment4 on the Draft Environmental Impact Report for the City of Brentwood Wastewater Treatment Plant Zxpansion With Discharge to Marsh Creek (SCH NO f 98012058) . f Thank you for the opportunity to COMent pn the above I matter. The Central Delta. Water. Agency (MWA) has been and cont to he arti ly interested h alth imps tsngssocithe ated with adverse envIroumental and p s the land application of biosolids. In additi vz� to concerxzs about adverse irWaits on the envirormeat cul.arly concerned about thend impublic in pactsafr©the CDWA, is particularly the application Of biosolids on ground and surface waters which n.atuxall.y flow into or eventually are discharged into the Sacramento/sari Joaquin Delta- CCUMMants Regards the City's proposed Disposal of � Diasolide� i On page 2-9 of the DEIR, it states: �I "The proposed project comprises three principal components; ( C3J expansion of the bioevlids handling facilities to allow disposal tca land or landfill." ! while the proposed project clearly contemplates an g-1 liexpar_sion of the biosol.id handling facilities" and thereby an increase in the amount of b.iosoli.ds produced kty the City's treatmftnt plant, the DEIR appareutl.y fails to discus-3 or analyze the potential ellv-ironmental impacts from the disposal- of this 1 1 2-45 ..........................................:::::::::: ............................................................................_._...... __ - r ry Txt t+r+�t 1T!"r t` +' li iY'� tlih AIIG. I3.~199 :QOPIt _» O)ELLIKI ORILLI BCCI? tIO. II590 t'. J I increased load of biosol.ids. while the DEIR states on page 201.1 that tsl ludge disposal would involve either land application or deposition in a landfill and would meet applicable SPA regulations (e.g. , 40 CFR Fart 503) , " thew DEIX tails to provide any more information about the nates of the contemplated sludge disposal. For example, the HEIR falls to discuss the following questions, to name a few. A. What proportion of the increased amount of bi.osollds will be lazes applied, as opposed to disposed in a landfill? B. To the Ment some of the biosolids will be land. applied, . 1. Where exactly will the bioevl.ida be Land applied? 2. Will the bi.ocol.ids be applied to farmland or pasture land? A. if farmland, what crops will be grown? if pasture, wast type of animals will bee allowed to graze on the land? 3 . What is the nature of the surface mater drainage at the proposed land application sites? 4. what is the minim= depth to groundwater at the 9-1 proposed application sites? (can't) S. Are the sates located within the 100-yr floodplain? 6. Are there any abandoned or improperly sealed sells or mine shafts for other similar structures) which would greatly facilitate the downward migration of biosolid pollutants and pathogens into the underlying groundwater? C. Are there any endangered or threatened species located at or near the proposed land application sites? D. With regard to complying with the SFA's 503 regulations regar"zag biosolide, j 1. What standards will the City comply with? a. To the Class .A. Exceptio:,rml Quality Standards? b. To the Class B Non--Exceptional Quality Standards? 2. what vector-attraction reduction requirements will. the City comply with? 3. what is the extent of the seasonal fluctuation, if any, of the pollutant and pathogen cozoentratio ne in the City's bioaolids? I Since the disposal of the biozol,ids resulting from the 1 City's proposed expansion of its water treatment, facilities is an integral part and inevitable consequence of the proposed "project" (which is the subject of the DBIR) the DEIR's complete 9-2 lack of discussion or analysis of the potential impacts from the disposal of the City's biosoli.ds prevents the DBIR from f 2-46 i ADG, 13, 1998 SAM KOMELLINI GRILLI MCD N0, 0SU Y. 4 fulfilling the DEIR's primary purposes as expressed on page I-1 of the DSIR. i (1) The DEIR fails to na:tisfy th* requirements of the California :Snvironmental Quality Act (CA Public Resources Code section 21000 et seq.) 1. (2) The DEIR fails to inform the general public, laical 9-2 residents, and responsible and interested public (can't) agencies of passible environmental, impacts of the proposed project, mitigation mems to avoid or minimize those impacts, and alternatives to the proposed project; and (3) The DEIR fails to inform decision makers of the environmental consequences of the project to aid them in deciding whether to approve the project. 11. Camnaats on the Potential acts from the Cry's Proposed { 4n-site Handling of its Siosolidss Oa page 2-11 of the DZIR, it states: "Sludge handling would corusist of mechanical dewatering and post-sludge drying beds- 0 The DEIR should discuss and analyze the extent to which the ' ( sludge contaminants and/or pathogens present may percolate .from the *poat-sludge drying beds" (anal other ca-site sludge holding facilities) to the underlying groundwater. For example, the DEIR should discuss (1) the moisture content of the sludgo which is disposed on the drying beds, (2) whether the drying beds are specially lined to prevent or minimize the downward migrati(!= of contaminants and/or pathogens into the underlying groundwater, (3) the time periods during which the sludge is delivered to the S ym beds--e.g. , will it he delivered to the drying beds year- round on a continual basis? During the rainy season? During rain # events? only during the Summer?, and (4) how long will, a 9-3 particular batch (e.g. , one day's load) of sludge remain in the drying beds before the sludge is transported and di.eposed off- site? since 71 [t]he principal souroe of domestic drinking water for Brentwood is t,-zxn groundwater* ,and since " (la ocal use of groundwater for domestic drinking water is extensive", and further since * igg)roundwater in the project region in typically i shallow, with depths of approximately 10-30 feet below ground surface", the CDWA believes the DEZR should more fully discuss, analyze and mitigate the potential, adverse, groundwater impacts from the post-sludge drying beds and other on-site sludge holding � facilities. 3 f 2-47 1 9l�t 17' /7 4u4t 1 r•you 4-}^.,a,t h/j't'. Y#.4CtL_Lt,")C.�'V lt.,t.� i"iw1t.'fC, Lf7 Aur. l3 1998 11U. na r, j moreover, the CA believes additional monitoring wells should be installed to more adequately monitor the potential downward migration of contaminanta and/or pate from the *post-sludge drying beds' and other on-site sludge holding 9-3 facilities. For 'e:xArmle3, the two monitoring wells--MW #6 and MW (const) :99--depictod on the map on figure 2-3 an page -10 of the DZIR do } not ,appear sufficient to adequately and accurately monitor the eLxte=t of contaminant and/or pathogen migration from the sludge drying beds. r t ITT. The CDWAI s Position Regardiug the Land Application of With regard to the land application of biosolid.e, the CMWA i has not suggested ae total prohibition of land application, but rather, leas advocated significantly more restrictive use than what the US SPA,s 5013 regulations currently allow. (U.S. code of Federal Regulations, Title 40, Part $03) . While the ETNA„ has prmulgated regulations dealing with the land application of biosoli.d:s on a national scale, a review of the scientific literature and the 503 regulations themselves demonstrates that the 503 regulations fail in numerous respects to adequately protect the public and the environment from potentially significant adverse impacts. (Fox examples of some of the inadequacies of the 503 regs, please see Attacb ntn *A", "Bu, and tic*) A. siosolideef flbo l.d Not be 'Land Applied to Areas Vfti.ch Unreascmably and Unnecessarily Jeopurdire the Public and the xnvirox=e nt. I Given the conceded lack of an adequate scientific j understanding of the full potential impacts from the land application of biosolids on public health and the environment, together with substantial scientific evidexz.ce demonstrating the clear potential for advarse impacts, the CDWA, has been advocating and continues to advocate the prohibition of the land application of biosol ids to areas that unreaacnabl.y and unnecessarily jeopardize the public and the environment. 9.4 f With regard to the location of proposed duplication sites, the C.riWA. has urged biosolid applicants and regulatory agencies to choose sites which sufficiently minimize the numerous potential ? known and unknown risks associated with the land application of biosol.i.ds. For example, with .regard to minimizing potential ground and surface water contamination, the CDW believes the available scientific evideact demonstrates, that the staging, storages and bulk application of biosolid.s (including 3path *Exceptional 4ual.i.ty° and "Non-excesptional Qual tyu biiasolids) shoul..d, be prohibited in the following areas: S 4 1 2-48 ,.nnC? ->.n„ n•.cC,r-r-.n, Ct iQt T(ICC^i IT/+C'r „AUG. 13. 1998 5:0IPA NOIELI.INI GRILLI MCD IVU. UCH r. b {:,) Any area having less than 60 feet of depth to groundwater. (2) Any area for which the elevation is not at least three feet above the i0o year flood plain elevation. (3) Any area protected from flooding by levees. (a) A11y area within the inundation zone of any dam or dawn failure. . (5) Any area within 850 feet from any water well fin current use or abandoned) . (6) Auy area within 850 feet from surface waters, including creeks, ponds and maxahes, water supply ditches and canals and drainage ditches and canals which discharge into surface watere in addition to potential icpacts on water quality, the C WA similarly believes the available scientific evidence demonstrates the need to locate application sites in areas that minimize the potential impacts on the public, including the local residents i and workers, and the environment from airborne pathogens and i pollutant$ (which can enter the air (and water] via wind erasion, physical sludge agitation, or otherwise) . ` 9-4 (coni) Moreover, the CDWA believes the available scientific evidence further calls into question the propriety of applying biaeoli_ds to our limited, high-quality farmlands. Soma of the many potential adverse impacts from biosolid applications on farmlands include both short-term and long-terry, adverse impacts on (1) the productivity of the sail; (2) the health of consumers of food and animal products expoged to biosolids; (3) the health of animals which graze on or eat fond grown from biosolid amended soil; and (4) the health of faxm workers and farm families who are exposed to biosolid contaminants via interaction with the soil, water and air which codes into contact with biosolids. 'T`Yse C:DWA believes these impacts' as well as numerous other known and unknown potential impacts ausbciated with the application of biosolide on farmlands weigh heavily against subjecting our limited, high-quality farmland to such impacts. The potential for significant adverse impacts also clearly justifies a thorough and detailed analysis and demrastratioa of the neo, if any, to dispose of biogolids on our precious farmlands in lieu of disposing biosolids on less productive lands, or disposing (and reusing) biosolids by other potentially more environmentally- friendly methods, e.g. , sludge recycling by gasification, etc. E (See Attachment "D") . , B. Additional Deficiencies in the Curreat Regulationa Regarding the Land Application of Bi.osoli.ds Which Subject the Inviro=amt and the Public to Potentially Significant Advevae Inpaccts. 9-5 The CDWA not only believes a proper location for di wposal of I biosolids is essential to minimize the potential impacts on public health and the environment from the land application of 5 2-49 t?152fI"-�I!W4M S1-V14 �'Pnll4 MAIMS 5,01PY NELLIE GRILL! MCD bioaol de. but, in addition, believes there are tither numerous Al deficiencies in the current regulations regarding biosolid applications which subject the environment and the public to psstentiaal.y significant adverse impacts. Some of these deficiencies include the following; (A) Lack of adequate quality assurance (i.e-, NAre the bicsoli.ds of the quality they claim to be?") . 1. Lack of accountability for the variability (seasonal or otherwise) in biosolid quality leaving the various treatment plants; a- (I.e. , there is a need for adequate verification, that sampling and testing procedures reasonably represent the biosolids being applied--e.g. , 'Does a yearly sample adequately represent the biosolid quality during the rest .cif the year?") . r 2. Lack of independent oversight of quality claims; i 3. Lack of effective pathogen detection methods; 4. Lack of understanding and quantification of the regrowth potential of pat.hQgena after biosol ds leave the treatment plants, S. back of adequate traoking of bionol.i.ds from the treatment plants to the application sites; 6. Lack of adequate aeco=ting and documentation of the sources of raw sewage Ad the respective { contaminants and pathogens introduced into the treatment plants and thereby into the environment 9-5 via biosolid applications; 7. Lack of an express assumption of liability from the generator and applicator of bioeolids for any resulting contamination and pollution and any required cleanup of the land and water. (Such liability would help ensure that quality claims are accurate and proper application methodes are followed) . } (H) Lack of adequate testing of the soil and potentially affected waters (including both ground and surface waters) . 8. Testing ;should be conducted prior to each application and at least annually thereafter to monitor, and pr+eveiat both short and long term adverse impacts from the accumulation of pollutants anis pathogens. 9. Testing should include addi.tiona.l potentially barmful cont&minanta and pathogens not presently required to be tested for by the $03 rags. (C) Lack of adequate notice of the potential impacts from the application of bi osolids to the following; 10. To conzumers of fond and animal products derived from or exposed to biosolid amended soils that ( such products were: derived from or exposed to such i sails; 6 i 1 2-50 r C AUG. 13. 1998 5:01FI NOMLLINI GELLI ICD AQ 0H f, d 13. To nearby and downstream surface water users, and users of the underlying groundwater basin; and 12. To people living and/or working in the vicinity of the proposed application of the potential i=pacts from airborne contaminants and. pathogens, C. cozolu ioa. While the forgoing discussion haat not attempted to cover all of the CDWAIs issues and concerns regarding the land application of bio,soli.dss, this discussion nevertheless prevents some of the CDWA'z major issues and concerm a regarding such applications. Az wawa mentioned wave, the CDWA has not suggested a total prohibition of Land.application. but rather, has advocated , significantly more restrictive use than what the EPA's 503 regulations currently allow. The CMA's review of the available 9-6 scientific evidence has clearly demonstrated that there are not only numerous kaomn risks associated with the land application of biosolicls, but, in addition, there are substantial pn&&Qwn risks associated with such applications. As such, the CD believes increased limitations on where bi.osolids may be Land applied together with substantial improvements to the method.9 and procedures by wh:.ch biosolids are applied, are necessary to i adequately protect the public and the environment, from I significant adverse impacts. If you should have any further quest' regarding our concerns please do not hesitate to contact very tru yours, Dante Jo Nome l.i,ax ,Jr. Cc-counsel for the Central Delta Water Agency DJRdjr Enclosures P.S. Attachments submitted with: mailed copy only_ 7 1-51 1 Responses to Comment Letter 9 from the Centre Delta Water Agency r 9-1. The draft BIR indicates that the City would like to dispose of sludge either to land or a landfill. The City has not yet contracted with a sludge disposal company or identified lands for sludge disposal. All sludge, if it is disposed to land will: a meet applicable requirements of EPA's 503 regulations, a comply with requirements set by the Central Valley RWQCB,and ■ be evaluated to ensure compliance with CEQA. 9-2. Please refer to response to comment 9-1. 9-3. The proposed project includes installing new,paved, sludge drying beds with under drains I and decant-capability. The existing sand sludge drying beds (with under drains) will be 4 phased out. The City will meet RWQCB requirements as they relate to the location and quantity of monitoring wells, if required. i 9-4. The City notes the Central Delta Water Agency's (CDWA's) concerns regarding land application of biosolids. 9-5. The City notes CDWA's opinion that the current regulations regarding land application of biosolids are deficient. i 9-6. The City notes CDWA's concerns regarding land application of biosolids. t t r F 7 Ciry of Brentwood VMTP Project Chapter 2.Response to Comments Pinar RIR November 1998 2-52 t=om"I Pana sc�n I c Sep. 13 19% 03: h'! P2 Letter 10 August 13, 1998 Mr. Thom Head, Public Services Director City of Bmntwood City Ran 708 Third StrejA- Bresntwood, CA 94513 Re: Comments on Draft Environmental ,bWact Report, 'W'astewater Tmatlnerlt Plant Expansion with Discharge to Marsh Creek Dear Mir. Head: ()a b of;Che Delta Scien= Center at Big Break, I appreciate this opperr n tY to comment on the city of Brritwood Wastewatcr Trezt )ent PLUt ExPMSios'with Discharge to Marsh C=k. As the-, Executive Director of the scknc+c center. my charM is to develop a s4nificant public institution focused on Delta restoration, research and @ciucation. The proposed site for The Delta Science Center (DSQ is located sear the confluence of Marsh Creek and Big Break. Member organizations.repr=nting the DSIC on its Board of Directors include Contra Costa County, East Bay Regional Park DistriCt, Ironhouse Sanitary District, Contra Costa:Contmtu ity Colltge District, Cahffmuia etc XIniversity at Hayward, Centra Costa Mosquito Abatemont and Vector Control, Mt Diablo Audubon and the Delta Chapter of the Sierra Club. PrtUmina platrning W design of the DSC has given us a familiarity with the Marsh Creek watershed and its bmporw= to the western Delta.. While we do brrScvc thaat the goals of Brentwood wsgtewaWr treatment and the federal, stage and local mandate' to restore the Bay-Delta ecosystem can be Compatible, the Draft ERR (DEIR), as presented.hire, generates serious questions and concerns about the assumptions and design of this waswwatcir tr6atrAbnt ptvject. GENERAL COMMENTS If the proposed wast,ewatex Treatment Plant was designed to increase the water quality of Matsu Creek, it could serve the: interests of the Delta, the watershed and rhe public. Its current design, pe'e's cost cffcctivt for rate payers, does not meet the greater public good, imiuding the federal, state and local mandate to restore the Delta. THE DELTA SCIENCE CENTER At Bag Break 2-53 = Pana-4n%c FPO SYSTEM P! E N[l. Sep. 13 2gg8 03:S1Ppt Fra i r 1 There seems to be an asstunption that historic negative impacts on Marsh Creek, including Rood control, grazing, agriculture aid tin use have created a situation that coadonos €C or degradation of watershed when, in fact,, thexo is growin scientific i ccamensxs that dr- co aftttence of Marsh Creek and Big Banc may be a civet remotion opptrrt wity in the mita. To use Marsh Creek as an effluent conveyarm system with a direct duchart e+hito the i Deft,lwithout wxuxu consideration gives to reclaiming the water for habstal mWor Wimiturai use appows very shortsighted and antiquated given what we now know amt esigni er mg and designing system more rmp4ble with natural pwcesm and needs. Many 3cienwb arnd parties have recognized Big $rule and the mouth of Marsh Cre&as One, of the s ra& be&fidal marsh and shallow water habitat rtakration afts= the ffflI= Delta. CA LFED, the atm and ftderal consortium worldng to restore dte Bay-Defta acosysicin, has also icdestific+ri Big Break at the wxnin s of Marsh Crock as anim;xaunt zest oplxirumity. We am concerned that plans to disclump effhamtt into the creek would degra&existing values and compromise opportimities to mestanre and ecce the 10-1 J MArsh',Creek ecosystem. The DSC Moves that the project could be modified to actus y habitat and opportimitiies in:Marsh Creek and Rig Break. We would welcmw the ap ►yrhztadry to wcaxlc with projtcttropon m develop Y annually agreeable pian_ Itirmy e bo po&jNa to obuin a grant from CA ..F)to modify curt plans in a.mav=r that wvudd resteft mid cnha=Marsh Crack and habitat for CAS tatrgot species in $ig Break nib"than depada ftm. The DEW fi&to make the watershed cion between Marsh Crwk and tho Delta by way of',Bid;RreaL Ajny poor quality water discharged into Marsh Creek will.de de waxer quality in lower Nbrsh Crock, Big Bares, and poundally the larges wester Delta- 10-2 Bef= t'be ab tttative of&awging secondary water into Marsh Creek advances, the Pmect Proponenu;should do a therough analysis of the water quality un accts and species known to be present in lower Marsh Cre ck and Brig Break. I -Big Break is a vast flooded farm that encompasses large areas of tidal marsh and is one of the largest arm of shallow water habitat in the legal Delta. TicW nuaarsla,aW slab m water habitat have bort ideatiAed by CA LFED as high priaritty target habitats and CAI:F .,D ecosystem restoration PI%n verses to reOver 50,000 acres of habitats in the :ext 20 yem. The DEm;appears to ignore the importance of Muth Creek, Bag Break, and the Wooem 10-3 Deft to nauve fish. Several rare and ondanprW native fish specam concentrate m i 2-54 :.#:; • t� J� i +' !t ##:. #. M " i «! it #'! ;..� ♦! } ♦ ♦. t#t-!.• t. .ta,.. .a' • �' a f! t }f#;.� ; : . }..s • y„ ## {� <} ;. R3 t": } "' • }:` # , Mt �� iDt '. t PS ## Y.t ! f 1 # •- - .i .%# ! • AR } • !1 # 111.. ♦ } ! • r !t } # ►-.# f+^: M 4 }': t+.R # •t % !! #i • #} t t . 1!•; « ! .'. •! !+•t • r# } % ♦. #. t • $: t# v ; 40 ! s i M 1, #Rom panastyiic FAX SYSTEM PHONG No. Sep. 13 2998 133: # PS I 1 Pap 3oAI — What concerns have been exprewd/studied on the pile 00tI aYtt3 #on 10-8 of hmschold dri�g water where the Contra COSU Canal crosses under Marsh Creek? I r Paige 3A-3 --- On liming tides and slack tides, particularly in the low flow surmer months, will elft fivm the project bank up, stagnate, or cause odors and other 10-9 dous probers? Page 3A-4 — Considering the fedcral state matte to reaw re the Delta, should the perexpect that the Very MV0,rsaet waw qw pate macr of cl alvod oxygen (DO) be stained or ptefi=bly improved upon Marsh Creek's histo avertp DO 10-10 measmezz of 7.7 mgM Wendel k be accaratz to assume that-evena modest restoration of the trec canopy along Morsh Creek would tit DO levels beyond the avexnges 7.7 mgll and agn ftcraun dy m ance the populatiam and diversity of aquatic organiw=in the Page 3A,-9 — If the'whit effluent Wxidty test for the reproduction of Daphnia yiti&d results'lovwicr than the control%W, aril the xtadu were deemed inexat sive as to thesix' � 10-11 twdc%ty, show tbh public exert muse conVrehensive testing at this stige of the prtjw's t3evek�p� # 3A-20 — b it ns#more accurate to say that the pollutants in treated effluent wcnrtcf 10-12 remit lir de `on of water quality in Marsh Creek and dw this impact cmU be Page 3A-21 to 3A-24 -- Are the cumulative avd synergistic e&cts of rseduc ed dissolved mygrt, mcceasCs in etc al=WuCt iiy, the dtscchanrge of px etc rlty poems, increased 10-13 water tmtperatum, and flet-cmathlg PH levels capable of significantly rednimg bier diversity in lower Marsh Creek? Page 3C-13 w 3C-20 -- An you awara tlat them is a relatively stable Population of weaftm pood turfts surviving in the louver reaches of Marsh CreaO. i _. Are you aware of the regular use of lower Marsh Creek by s4pdficant munbers of } northern barriers? Am you Aviram of te:hoonfirmed sightings of blade raiLs using the wetlands at the 10-14 mouth of Marsh Creek? Are you aware of the regular sightings of white-tamed kites alog mower Marsh Creek? -4 - i -56 QanaSprtSC FPX SYSTBI pHow NO. Sep. 13 1995 e3.53pm P6 — ,Ate YM AWVO that tncOlored bkckbff& have bow &&W m lower 113}1 C=k? --- Are ym aware that IN-alta smelt are known to occur at the coAft=w of Marsh Cytec aid Big Bm&? 10-14 -- Are you aware That gvw=nant aciendsu Fwd urbim water users have F (conmouth i} of Marsh Cre k as me of two primo k= ims for a sacxanncrzty spoil rewm y Fog ? ... Ar, yo. that,a fall Chmo*� run =00a g e in Marsh Creelt:t SbecsU=d sings have also been reported- - is it fair to say that m ons aside, this project'gilt contanl7ute Aim-ly to the 10-15 dw1mG of big owls? In elosmig, I regm that I W htdc lead time to fu Hy aDmment 10 the D or si re it with DSC mom, but hope thew per `i cats and the its by othm give an of us the MpMI&y to CMfuity amlyze and =xin= the needs and posiOffifieg for =, ,ty mg water issws import to Brand and the Delta.- Thank y+au. a spy, swpbcn Babata Examfive Dh=toC (925) 947-1473 a 2-57 t . i Responses to Comment Letter 10 from the Delta Science Center At Big Break ` 10-1. The City welcomes the opportunity to work with Delta Science Center staff to ensure that no adverse effects on Marsh Creek or Big Break result from the proposed project. The draft EIR presents all of the environmental impacts that could result from the proposed WWTP with discharge to Marsh Creek. Overall,the EIR conclusions show that most of the impacts addressed would be less than significant,and those that were considered significant could be reduced to less--than-significant levels. Chapter 3A, "Hydrology and Water Quality", addresses flooding and water quality issues in Marsh Creek and its connection to Big Break. The project's contribution to Marsh Creek flooding would be reduced by the Contra Costa County Flood Control and. Water Conservation District's requirement that the City stare treated effluent onsite during times of peak flood flows in Marsh Creek. The draft EIR also indicates on page 3A-19 that during worst-case, low-flow conditions the project discharge of 15.5 efs would result in a flow that is approximately 0.9 foot deep with a velocity of 1.56 feet per second in the channel; this small increase in water depth and velocity would not cause adverse hydrologic effects because flow in the channel varies routinely as a result of base stream flows. The effects of these flows are also expected to be negligible in the tidally r affected lower reaches of Marsh. Creel. near Big Break, where daily tidal action already causes water levels in the channel to vary. The draft EIR also presents a detailed evaluation of construction effects on Marsh Creek, ' discharge of conventional pollutants, temperature, pH, turbidity, BOH total suspended solids,total coliform bacterid,ammonia toxicity, biostimulatory nutrients,dissolved oxygen effects,and electrical,conductivity. The draft EIR concludes,based on the available data and modeling presented in Appendix C, that because the project would be designed to meet the anticipated RWQCB discharge requirements,these impacts would be less than significant. Please refer to pages 3A-19 through, 3A-24 and Appendix C of the draft EIR. Therefore, the City proposes that its WWTP expansion project would meet the RWQCB Waste Discharge Requirements for discharge to a surface water and would be compatible with existing Marsh Creek and Delta conditions and future restoration projects. 10-2. Please refer to response to comment 10-1. A thorough water quality analysis is presented in the draft EIR. 10-3. The draft EIR, beginning on page 3C-4, addresses 28 special-status species that have the potential to occur in the project vicinity(Table 3C-2). The draft EIR indicates that,given the available habitat at the WWTP site and in Marsh Creek and Big Break., of those 28 species, 12 special-status species could occur in the project area. The Sacramento splittail and delta smelt are discussed on pages 3C-14 and. 15 and are evaluated on page 3C-20. No evidence exists that would suggest that the proposed effluent discharges to Marsh Creek would have an adverse impact on these species or the winter-run Chinook salmon. i City of Brentwood WWTP Project Chapter 2.Response to Comments Final EIR November 1998 i 104. Please refer to response to comment 10-3. 10-5. The draft EIR addresses the western pond turtle on page 3C-13. No pond turtles were observed during the field survey and the project could potentially result in more ponded water in the creek that would benefit the western pond turtle. No need exists for additional mitigation. 10-6. The draft EIR indicates on page 3A-24 that discharge of priority pollutants in treated effluent is a potential impact that is considered significant. The draft EIR recommends two mitigation measures to ensure the WWTP is designed to meet NPDES permit limits for priority pollutants and to implement a source control program in the City to reduce concentrations of these pollutants in WWTP influent. The City would also implement a monitoring program for influent, effluent, and receiving water quality. 10-7. Please refer to response to comment 8-2 above. 10-8. The issue of contamination of Contra Costa Canal water quality is considered a remote possibility given the level of effluent treatment proposed by the City. The Contra Costa Water District(Letter 7)did not identify this issues as a potential concern. 10-9. Because of the level of effluent treatment proposed and the additional flow anticipated in Marsh Creek, stagnation, odors, or other related problems are not anticipated. 10-10. The dissolved oxygen results presented on page 3A-23 and in Appendix C of the draft EIR indicate that DO levels would remain above 5.0 mgfl in Marsh Creek,which meets the water quality objective identified in the Basin Plan. Other projects, outside the scope of the proposed project, could result in further improvement of DO levels in Marsh Creek. 10-11. The anticipated NPDES permit for the proposed project will likely require the City to conduct three species toxicity tests as well as flow-through bioassays. The effluent quality from the proposed project will be better than that currently produced at the existing facility. Therefore, comprehensive toxicity testing is not warranted at this stage of the project. 10-12. The water quality analyses presented in the draft EIR indicate that discharge of conventional pollutants in treated effluent would result in a less-than-significant impact on Marsh Creek water quality. The City considers the conclusion that these impacts would be significant to be inaccurate. 10-13. Based on the water quality analyses presented in the draft EIR and the City's commitment to design the WWTP to meet RWQCB requirements, effluent discharges are not expected to reduce biodiversity in Marsh Creek. 10-14. The draft EIR indicates that the potential exists for western pond turtles to occur in the project area. However, no pond turtles were observed during field surveys conducted on City of Brentwood WWTP Project Chapter 2.Response to Comments Final BIR November 1998 i i May 2, 1997,and January 18, 1998,by a qualified wildlife biologist. Your observation about western pond turtles is noted. No adverse effects on this species would result from the jproposed project. The draft Elia.identifies, based on the California.DFG's Natural Diversity Data Base, the known occurrences of special-status wildlife species in an area. The northern harrier,black rail,white-tailed kite,tricolored blackbirds,delta smelt, Sacramento splittail,and winter-run chinook salmon are all addressed in Table 3C-2, and in text beginning on page 3C-13. No adverse effects on these species from project implementation are expected. Specifically,no effects on salmon are expected because their occurrence in Marsh Creek is not well documented and effluent discharge conditions from proposed project effluent that could affect salmon and ether aquatic organisms (such as un-ionized ammonia)are not expected to occur. The WWTP will be designed to produce an effluent ammonia level that is less than ! 1 mg/l. The condition will result in low un-ionized ammonia levels as long as high pH levels in the creek do not occur. The City will also comply with the R.WQCB's receiving water temperature requirement. j 10-15. The mitigation measures recommended on page 3C-18, which require compliance with the DFG's burrowing owl mitigation guidelines, would reduce impacts of the project on this - species to a less-than-significant level. Decline of burrowing owl populations would not result from this project. 4 i G i i Cit,}of Brentwood WWTP Project Chapter 2. Response to Comments Faust EIR November 1998 , 3 Letter 11 STATE OF CALIFORNIA--THE RESOURCES AGENCY PPTf WILSON. G*Veenor DEPARTMENT OF WATER RESOURCES 1416 NINTH STREET. P.O. Box 912636 C _ SACRAMENT©,CA 94236-OWI \' w 19I61 653-5791 � August 25, 1998 Mr. Thorn Head, Public Services Director l ,;r t City of.Brentwood Public Warks Department 708 Third Street '. r; CITY=tr B EIwutyv Brentwood, California 94513 Dear Mr. Head: SCH No. 980/2058/ Environmental impact Report for the City of Brentwood WastqMnder Treatment Plant rtsion ischer e Marsh-CLej& This is our response to your EIR for the City of Brentwood's Wastewater Treatment Plant Expansion with Discharge to Marsh Creek. Thank you for the opportunity to review this document The City of Brentwood proposes to expand its existing wastewater treatment plant capacity from 1.8 MGD to 10 MGD (average dry weather flow) with peak wet weather flow of 20 MGD (31 ds), Filtered secondary wastewater effluent will be directly discharged into Marsh Creek at a rate of 15.5 cfs. Marsh Creek will convey the wastewater into Big Break, near the mouth of Dutch Slough in the western Sacramento- San Joaquin Delta. The Sacramento-San Joaquin Delta is a source of drinking water for about two-4hirds of California's population. The Department of Water Resources exports Delta water supply at its Banks Pumping Plant in the southern part of the Delta, near Byron. DWR takes an active role in evaluating the suitability of Delta water as a drinking water source with programs that seek to identify sources of water quality degradation and investigate means of eliminating or preventing degradation of Delta water quality. Our comments are in response to the following findings and determinations: Paagt-JA-24 lmoacf: Discharge of priddly aol/utants in treated effluertf.goidd resulf r�dation water quaa&in Marsh Creek. This imDact is conside sig ifica�t. The EIR does not address the impact of increased discharges on lower creek reaches or Delta water quality. All supporting water quality data, with the exception of dissolved oxygen analyses, were obtained from identified monitoring sites. All sites are 2-61 { 4 Mr. Thorp Head August 25, 1998 Page Two within the existing wastewater treatment plant or 100 feat or less immediately downstream of the property and do not include any locations along the 3.8 miles of 11-1 { Marsh Creek or at its discharge paint into the delta(Page 3A-4 and Figure 3A-2). {coat's} In the EIR, Marsh Creek is described as a small stream(page A-3). ,Although no estimates of summer flows in !Marsh Creek were available, present summer stream flout+is described as "generally low during most of the summer.... Sources of flow in the summer may consist of upstream reservoir releases, agricultural return flow, and urban drainage from the Brentwood area" (page 31xA). Under low summer streamflow, the waste discharge of up to 15.5 cfs, an over fivefold increase from present wastewater } discharge, may constitute a major proportion of the crock's flow, The project's i dissolved oxygen analysis already indicates low oxygen levels in summer creek flows_ Oxygen levels diminished further downstream, reacting levels near the regulatory dQ objective of 5 mgll at the lower reaches (page Cps and 3A-23). Low dissolved oxygen 11-2 levels are fatal to aquatic life. The ElR does not adequately show that increased wastewater discharges will not harm downstream aquatic life or negatively impact delta water quality through pollutant loading(BOD, suspended solids, total dissolved solids, and temperature). ftge 3A--S.- d:o ' EQ&1a t - Th e bra arta# #hal y�rara c# erminred to car dla crit / and tl:a to or, - landz1w wgM detectedu0nay flevelsow regulatory crtari�r., The I lR recognizes that the project's discharge of priority pollutants is significant (3A®24). The loading of priority pollutants under current conditions is already frequently exuded for lead and thallium and approaches regulatory levels for several metals_ Results from effluent toxicity tests have also been problematic with either reduced growth compared to control test species or inconclusive toxicity results 11- (3A-9). The louver, brackish reaches of many creep systems often function as estuarine nursery areas for many resident fisheries. It is critical to assess tate impact to water quality in Marsh Creek's lower estuarine reaches, which may also contain more sensitive wetlands areas and in discharges to Big Break for impacts to delta water quality_ a e 3D-_6 /m - Discharge of#m ---aW RMYR-ritIQ Marsh C=k c uId resuff in MolureAtAL0 R-OhliCIQ Path,09WIL0 gr-02-ailmas in effluent. Thfs.LnUact is cons det al'I+ s than "rinflan, r 2-62 Mr. Thom Head August 25, 1998 Page Three Pane IDA Pathogens in Tmfed Wa#er tftirr3f fra aranh RThe 1% as uses of Marsh k do clu e i se as a soptie of dduh in WWU.. P ' A-1 Sut&ce Watrq#o coed ra h- ur su a wa#eE featu the ar bre d a ch Slough and Rack fou h. P 3A- 3 tri dr�ct}v f tr - _._7" ou►ce c� s future .surface water is MUjapated ce Same from the De We do not concur with a finding that proposed mitigation measures significantly j reduce the potential exposure of the public to microbial pathogens. Though the wastewater treatment plant would comply with applicable water quality objectives, policies, and permits (NPDE'S), the overall project may still cause a significant impact to water quality because the NP'DES permits do not take into consideration the need for water utilities to be able to consistently comply with the requirements of the Safe 11-4 Drinking Water Act of 1996 which targets pathogens. Wastewater treatment,plants are known sources of pathogens, including Cryptosporidium, Giardia, coliform bacteria, and viruses. Secondary treatment only provides a small margin of safety for exposure to pathogens. Tertiary treatment of all discharges should be required to more fully comply with the Safe Drinking Water Act's requirement to remove pathogens. Marsh Creek and Big Break may be sources of drinking water. The Marsh Creek wastewater discharge into Big Break may convey pathogens and pollutants into Delta water that under certain hydraulic conditions can reach Contra Costa Water District's pumping station at Rock Slough to the south. Reverse flow conditions can occur when high export at the State Water Project, U.S. Bureau of Reclamation and CCVVD south Delta pumps combine with the closure of the Delta Cross Channel Gate to cause the not seaward flow of the San Joaquin River at Antioch to reverse southward, Rock Slough is the closest potential drinking water source for the CCWD and may be one of the proposed sources for the City of Brentwood water supply (3A-23).. The CCWD's Old River pump and the SWP and USBR south Delta pumping facilities are also points of export of Delta waters for potential drinking water use. When the San Joaquin River flow is seaward, pathogens and pollutants may be carried west to the City of Antioch's Pumping Plant No. 1, just west of the mouth of Marsh Creek. The Safe Drinking Water Act of 1996 also targets disinfectant by-products and emphasizes source water protection. Several raw water constituents are problematic for the production of drinking water from Delta sources. These include bromide, natural organic matter (as TOC), nutrients, total dissolved solids (TDS), salinity, coliforin bacteria, and turbidity. TOC reacts with chlorine to produce hziogenated organic 2-63 t Mr. Thom Head August 25, 1998 Page Four l compounds of public health and regulatory concern. Wastewater treatment plants are also known sources of TOC, TICS, and nutrients_ The impact analysis for water quality should also include TQC,TDS, and disinfectant by-product analysis. A tentative requirement for pathogen monitoring should be required pending the availability of dependable collection and laboratory identification technology. { i Page - J ct The.pop a n i'q4 uld conhibute Lg cLtlfttrilVa war demdatio& This emmuLadve " ct is considered less than nif-c We do not concur with the finding that the project will not create significant impacts when combined with other anticipated regional developments (cumulative i impact). 'While Brentwood's discharge volume may be low, its constituents concentrations may cumulatively add to the overall mass loading from region-wide wastewater discharges. The Elly does not sufficiently address cumulative impact_ ( Recently proposed new or expanded discharges to the Sacramento-San Joaquin Delta '. include Sacramento Regional Wastewater Plant, Discovery Say WWTP, City of Tracy V�l`VL/T`P, and Mountain House WU1tTP. A comprehensive analysis of cumulative 11-5 i impacts on water quality, downstream municipal Water supply, and biological resources should be performed for these and other projects within the wider surrounding watershed of the Sacramento-San Joaquin Delta. Water quality constituents should ! include an analysis of TOC, disinfection byproducts, TICS and pathogen loading. In assessing the cumulative impacts of the project, the environmental review should also consider all reasonably foreseeable sources of water pollution, including nonpoint I runoff from newly urbanized areas (stormwater discharge), p e A_1:5 a 998 fa.w Thom from e AMR 2- andparagraph-SRF proit ts are g "ac r+ovis' of t EedgW E'nd red Species Act and must obtain a Sect&n 7 c&1rance from the t LS. ElsA ind fflilf tlLe SwY c-o LF-W-S). We concur with the letter dated February 10, 1998 from Diane Edwards of the Environmental Services Units of the State Water Resources Control Board. Ms. Edwards has advised that the U.S. Fish and Wildlife Service be consulted in regard to Federal Endangered Species Act issues. The ElR has not addressees how the 11-6 increased discharge of treated wastewater into the Sacramento-San Joaquin pelta may Impact special status fisheries that use Big Break and Dutch Slough as habitat and ' migration paths. These species include Delta smelt, winter-run chinook salmon, steelhead trout, and Sacramento splittall. i 2-C4 ................. .......................... ............... Mr. Thom Head August 26, 1998 Page Five If you have any questions regarding our review of this EIR, please call Larry Joyce, Chief, Water Quality Control Section, at (916)653-7213 or Deborah Condon of his staff at (9 16)6,53-9570. Sincerely, Edward F. Huntley, Chief Division of Operations and Maintenance (Coordinated with the Division of Planning and Local Assistance) 2-65 ............................. ................... .................... ................................................... .............................................. ............................— 1 t Responses to Comment Letter 11 from the.California Department of Water Resourees i 11-1. The impacts in the lower reach of Marsh Creep(i.e.,WWTP to the tidally influenced:estuary) were assumed to be similar to impacts evaluated at the point of the proposed wastewater ' discharge because the hydrologic, channel shape, stream bank vegetation, and channel substrate conditions are relatively similar along the entire free-flowing stream segment upstream of the tidal estuary. While, no water quality data were available with which to evaluate conditions in the lower reach of the river, the impact analysis was based on a substantial record of recently collected monitoring data(1991 through 1997) from upstream and downstrean of the WWTP. The CEQA impact evaluation conducted for the draft EIR. i used the full record of available data collected near the WWTP. Consequently, the impact analysis is considered applicable to the entire stream downstream of the proposed discharge. t 11.2. The proposed Vv WTP will be designed and constructed with sufficient capacity to produce an effluent that complies with the NPDES permit limits for DO in the effluent and receiving water. An analysis of receiving water DO for the draft EIR was conducted with standard DO sag equations and conservative assumptions of zero background flow in Marsh Creek and high summer temperature conditions. The analysis was conducted for the entire free-flowing stream reach downstream of the proposed discharge. The results indicated.that DO would 4 remain above the Basin Plan water quality objective of 5.0 mgll in the free-flawing reach of Marsh Creek. 11-3. The impact on water quality from discharges of priority pollutants was considered significant because of the uncertainty of proposed regulatory criteria that may be adapted in the future. j The quantitative analysis of recent effluent samples indicated that most priority pollutants are not detected or present at low levels. Concentrations of lead and thallium indicated that the lowest proposed ambient water quality criteria could be exceeded. Mitigation measures are proposed in the form of source control through a City sponsored source monitoring and reduction program if concentrations are determined to be consistently elevated with respect to water quality criteria. Consequently,the impact was considered less than significant with implementation of recommended mitigation measures. Direct project effects of the proposed discharge to Delta water quality were not specifically evaluated. Significance criteria used for the draft EIR were adopted from.the State CEQA Guidelines, which state that water quality impacts would be considered significant if the project would cause substantial degradation of a water body or exceed a Basin Plan water quality objective. Although not specifically addressed in the draft EIR, the quantity of the WWTP effluent discharge at full project buildout (approximately 15.5 cfs) would be extremely small compared to the average daily stream flow and tidal exchange rate of water at Big Break. Consequently,it is reasonable to assume that the incremental change in Delta water quality would be small and would not exceed CEQA significance criteria. Please refer also to response to comment 7-3, above. Chy of Brentwood WWTP Project Chapter 2.Response to Comments Final EIR !November 1998 11-4. The City is aware of environmental concern over the discharge of pathogens, trihalomethane precursors, salinity, and other unregulated constituents to Marsh Creek and the Delta. The City is committed to designing and constructing the V vVTP to ensure that its operation complies with applicable NPDES permit limits and water quality objectives. If more stringent regulations are implemented in the future, the City would upgrade its treatment processes to ensure compliance with the new discharge limits. The analysis did not specifically evaluate impacts from unregulated constituents, such as cryptosporidium. and giardia,because Marsh Creek is not used for domestic water consumption within the project area. However,the impact analysis did specifically include a mass balance impact analysis of potential changes in electrical conductivity that is representative of salinity and total dissolved solids. As noted above, potential impacts on Delta water quality were also not specifically described because it is reasonable to assume that the proposed effluent discharge would be small relative to the large dilution provided by Delta flow and tidal exchange rates at Big Break. 11-5. As'stated previously,the average flow and tidal exchange rates in the Delta are large relative to the proposed discharge and therefore provide substantial dilution capacity for potential contaminants.The City agrees that the proposed discharge could contribute to the cumulative loading of contaminants from other WWTPs; however, the quantitative analysis of all contributions is beyond the scope of the draft EIR given that the direct project impacts are less than significant. In addition,quantifying the cumulative contribution with other VVVv TP discharges and nonpoint source pollution sources and evaluating associated impacts on municipal water supplies at locations throughout the Delta would require a complex and potentially speculative analysis that is not within the scope of this project. Please refer also to response to comment 7-3, above. 11-6. Please refer to response to comment 10-3. City of Brentwood WWTP Project Chapter 2.Response to Comments Final RIR 2-67 November 1998 i. Letter 12 United Stags Department of the Interior HSH AND WILDLi sEkvicE D3 Sacramtnto Fish snd WdcWs Office 3310 E1 Can&o Avenue,SWte 130 Ste,C 95921 ' �--� =ber 28, 1998 Mr. Thom Bead _o �. ! City of Brentwood �` 708 'Third Strut, etre Brentwood, California 94613ttc aF Bil�$ Subject: Draft Fx v rontzxwal Imnpa+ct Report for the i ntwood Proposed W4stewater Treatment Plant Expansion,Contra Costa County, California Dear Mr. FJead: I This is in respomse to a Drat Environm=ental Impact Report(DEIR.)on the vptssed City of Brentwood wastewater treatment plant,prepared by the City of Brent�+odateri Jane 26, 1998. I The DEIR has been reviewed by the U.S.Fish and't�irildlife Service(Service)relative to the proposed treatment plant located north of Sunset Road and east of Marsh Creek, Contra Costa. County, California_ This action is subject to the California Environmental Quality Act. Based on the DE13t, project opansion will occur on the existing 70-acre project area.. j Theroject site occurs within the geographical rango of the federally end eyed San Joaquin.kit fox(Valves m acro is mudca),Amen=peregrine falcon(ale peregri , and winter--tort. I chsno+ok salon(O nevrhyxr mus myk ss);the federally threatened valley elderberry lGagho beetle(D)eax ocex'rrs 'ifvrnicus& morphus), bald eagle(Naliaeetus leu cote,phalrrs), delta smelt ZE,y,parne.ws#rrtr i rc ), and�alifflrn a red-legged frog(�aurora dr,�}rtanii);and the erally propose as threatened Sacramento splittail(F'ogonichthys macrolepidow). If these I listed species occur within the project area, they may be subject to take by the proposed project. Section 9 of the Endangered Species Act of 1973, as amended (Act)and its a nt ng regulations prohibit the"take" of federally listed species of wildfe. Fake is dcfined by the,Act i as "to harass,harm, pursue, hunt, shoot, wound, kill,trap, capture, or collect" any such wildlife species. Take may include significant habitat modMoation or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns,including bre feeding, or sheltering(50 CFR.§ 17.3). Service staff have reviewed the DEIR prepared by the City of Brentwood. Two species discussed in the LJEIIt.are delta smelt and Sacramento splittail. Delta smelt occur in the vicinity ' 'the pro,posed outfall facility. Sirnila.r to delta.smelt, Sacramento splittail are freshwater fish capable: of`tolerating moderate levels of saiiziity,have larvae that move into habitats in Suisun. Hay, a nti may occur�the project arca Based e7n page 3C-20 in the DEIR, delta smelt and Sacramento splittaiI could poteo�tially occur near the mouth of Marsh Creek where Marsh Creek flows unto Big Breal� The TJEIR concludes that the delta smelt and Sacramento splittail are unlikely to occur in the area of the proposed outfall structure. The increased flows may change the water temperature and salinity m Marsh Creek. The DEIR concludes that these variable changes in water temperature and salinity should have a minimal effect on delta smelt and Sacramento splittail. t 2-68 .............. ...... Mr. Thom Head 2 The DER contained an miadeouate analysis regarding the effects of the project an winter-run chinook salmon. 'The Natior4 Marine Fisheries Service has jurisdiction over the winter-run chinook salmon. Also, the Dl IR contained an inadequate analysis regarding the effbas of the project on the California red-legged frog. The Service understands that California red-le ed 12-1 frogs are located in Marsh Creek. The Service recommends that the City of Brentwood evelop mitigation measures relative to the discharge of effluent into the Marsh Creek watershed. A=rding to the DEIK the City of Brentwood-vvrill need 22,000 acre feet of-water from the Delta in 20 years. The Service recommettis that the City of Brentwood contact the Contra Costa Water District regarding the need for additional Delta water. The existing wastewater treatment plant is an area that has been extensively disturbed by Serviceommends thet'SwxkrdizedRecommw7dadonsor f construction activities. The recommends P�-otecnon qJr4he San Joaqum Kit Fax be implemented at the project site prior to or during 12-2 Quad disturbance in th!e w3ion area. Based on habitat conditions-within the project area, biological information proviled in the DEIR, and the proposed action, the Service has determined that the California red-legged frog Sacramento splittail, and delta smelt may be adversely affected by the proposed project.. Takeincidental to an otherwise lawful activity may be authorized by one of two procedures. If a Federal agency is involved with the permitting,funding, or carrying out of this project, initiation of formal consultation between that agency and the Service pursuant to section 7 of the Act is required if it is determined that the proposed project may affect a federally listed species. Such consultation would result in a biological opinion addri tsaing anticipated effects of the project to fisted and proposed species and may authorize a limited level of incidental take. If a Federal agency is not involved with the project, and federally listed species may be taken as part of tile project, then an"incidental take*pemit PXAMM to section IC) a)(l M.of the Act should be obtained_ Section 10 provides for permitting take incidental to otherwise awful activities, provided that; (1) a Habitat Conservation Plan(HCP)has been proposed by the applicant and accepted by the Service, and(2)there is an assurance the term and conditions deemed necessary or a ropriate by the Service will be met The Service may issue such a permit upon om cletion by the permit applicant of a satisfaacry conservation plan for the listed species that won be affected by the project. If you have any questions or further inParmatior4 please contact Don Hovik or Peter Cross regarding terrestrial species, or Stephanie Brady regarding aquatic species at(916)979-2725. Sincerely, David L. Har w Acting Field Supervisor cc, CDFG, Region 3, Yountville, CA 2-69 Response to Comment Letter 12 from the U.S. Fish and Wildlife Service 12-1. The City has conducted a comprehensive evaluation of the biological resources and special- status species that could occur in the vicinity of the proposed WWTP Expansion site. The draft EIR indicates in Table 3C-2 on page 3C-11 that a potential migration passageway in Big Break may occur near Marsh Creek for winter-run chinook salmon smolts. A habitat assessment conducted by a professional biologist indicates that habitat conditions do not exist in Marsh Creek down stream of the WWTP that would support winter-run chinook salmon. Therefore, no impacts on winter-run chinook salmon are expected to result from construction of an outfall to Marsh Creek or discharge of treated effluent.The results of the water quality analysis beginning on page 3A-1'7 indicate that the water quality effects of discharging 10 mgd of treated effluent to Marsh Creek would be less than significant according to the Central Valley Regional Water Quality Control Board's requirements for discharge of treated effluent to surface waters. A search of the Natural Diversity Data Base and a site survey by a professional wildlife biologist indicated that the California red-legged frog does not have the potential to occur in the vicinity of the project site. The proposed project would likely have little to no effect on special-status species, including the California red-legged frog, because effects of the outfall structure on Marsh Creek would be minimal and would occur in a relatively disturbed area, and discharge of 10 mgd oftreated effluent would meet the Central Valley RWQCB requirements for surface water discharges. No additional analyses for the purposes of CEQA are required. The City has discussed surface water supply with the Contra Costa Water District. 12-2. The comments regarding the San Joaquin kit fox habitat are noted. The City has not proposed mitigation measures for the San Joaquin kit fox at the WWTP site because suitable habitat does not exist, the site is regularly disturbed, and it is fenced, limiting access. The City has proposed conducting preconstruction surveys for nesting raptors (mitigation measure C-1)and burrowing owl(mitigation measure C-3)and could informally confirm that no kit fox occur on the project site at that time. The City has also addressed issues related to the delta smelt and Sacramento splittail on pages 3C-14,3C-15,and 3C-20 ofithe draft EIR. The draft EIR indicates on page 3C-20 that delta smelt and Sacramento splittail could potentially occur near the mouth of Marsh Creek where it flows into Big Break but are unlikely to occur near the WWTP outfall structure. Because water quality in Marsh Creek would meet the Central Valley RWQCB requirements for surface water discharges and increased flows in Marsh Creekwould only slightly change water temperatures,this potential impact is considered less than significant. No mitigation is required. Ciry of Brentwood WWTP Project Chapter 2.Response to Comments Final EIR 2-70 November 1998 i } 1 .s t ORAL. COMMENTS AND RESPONSE TO COMMENTS Summary of Comments Received at the July 28, 1998.Public Hearing j Draft ETR,for the City of Brentwood Wastewater Treatment.Plant Expansion with Discharge to Marsh Creek i I Comment1: Mr. Gene Dickey stated his approval of the City hooking up to Ironhouse Sanitary District. Response 1: The City notes Mr.Dickeys preference for Alternative 2 as presented in the draft EIR. Comment 2: Mr. Ron Nunn, 741 Sunset Road, expressed concern about the environmental analysis in that it was inadequate relative to the potential impacts on his food processing plant located immediately east of the proposed expansion. Further, that as a precaution, he uses his own water source for washing food and was concerned about what would happen if possible mounding of sewage overtaxes the extraction system and would then contaminate his wells. Mr. Nunn asked how he would know if this would occur, or would he only find out when people became sick. In view of the foregoing, Mr.Nunn thought that a detailed analysis be conducted and that a mitigation program or emergency program be put in place, if in fact, a mounding of sewage were to contaminate the water wells within the immediate area. Response 2: The City appreciates the comments from Mr.Nunn. The draft EIR indicates on page 3F-4 that the proposed WWTP expansion would not adversely effect adjacent land uses because the facility expansion would occur within the existing plant boundaries and is consistent with the City's land use designation for the site. No adverse effect of the project on the food processing operation would occur. The City's proposed WWTP would reduce the need for disposal ponds that affect groundwater levels; therefore,the proposed project would reduce the amount of groundwater mounding that would result from WWTP operation. The existing system also employs a groundwater extraction system, with monitoring wells, that collects a portion of the infiltrated secondary effluent from the disposal ponds, mixes it with groundwater, and discharges the combined water into Marsh Creek. 1'he proposed project and existing groundwater extraction system is expected to eliminate the potential for groundwater contamination to occur near the WWTP. Therefore, no additional mitigation is warranted. City of Brentwood WWTP Project Chapter 2.Response to Comments Final ETR 2-71 November 1998 i 7 { Comment 3. Mr. Tony Ramirez, 19 Spruce Street, questioned why the citizens of Brentwood could not be provided with well water and felt it was more than adequate to be provided for drinking water. Response 3. The City notes Mr. Ramirez's comment. Because this comment is not related to the contents of the draft EIR or the proposed project, no response is necessary, { t 1 i l 1 t 1 1 I i t 1 { City of Brentwood#i WTP Project Chapter 2.Response to Comments Fina EIR November 1998 I Chapter 3. Errata The errata presents minor revisions and corrections that are incorporated as part of the final EIR in response to comments on the draft FIR. CHAPTER 2. PROJECT DESCRIPTION Errata to Page 2-6 and 2-7 Direct discharge of treated effluent to Marsh Creek, which is the disposal method proposed for this project, would require a higher level of treatment than is provided by the current facilities. Effluent would be required to be a disinfected filtered,secondary effluent(also known as disinfected tertiary effluent), with no more than 10 mg/1 of BOD and suspended solids remaining, and disinfected to produce a total coliform count of 24 2.2(most probable number ofcoliforni organisms [MPN] per 100 milliliters (MPN1100 ml). Dissolved oxygen and electrical conductivity are also parameters of concern. Studies have been conducted to evaluate the potential effects of the proposed discharge on these characteristics of Marsh Creek. Errata to Page 2-8 Please refer to revised Table 2-1 and 3A-4. Errata to Page 2-11 Effluent would be discharged to Marsh Creek in the vicinity of the current E-2 discharge. A pipeline from the disinfection facilities to a concrete outfall structure would be constructed on the banks of Marsh Creek.. Appropriate velocity dissipation and bank stabilization measures would be built into and around the structure. .During periods (estimated as lasting 6-I2 hours) when peak floodflows are occurring in Marsh Creek, the discharge of effluent to the stream may need to be curtailed (Williams pers. comm.). The City and.F'CWCD would develop the specific operational criteria for detaining effluent discharges during peak floodflows. If required, the City would monitor stage (water level) in Marsh Creek, cease discharge of effluent to the stream, and provide suicient reserve storage capacity onsite for effluent until the peak flow in the stream has passed: City of,Brentwood VA TP Project Chapter 3. Errata Final EIX November 1998 3-1 �4 I j CHAPTER 3A. HYDROLOGY AND WATER QUALITY Errata to Page 3A-13 ! .Please refer to the revised Tables 2-1 and 3A-4 i CHAPTER 4. OTHER CEQA-REQUIRED ANALYSES J i Errata to Page 4-9 j At full buildout,this project would contribute a negiigible amount of flow to Marsh Creek: 15.5 cfs at normal flow periods and 30 cfs during peak flood conditions. Although peak flows increase as a result of urban growth,FCWCD Would actively manage and implement flood control measures and facilities. Because measures are included in this project to prevent water quality i degradation in Marsh Creek and measures are included in the general plan to prevent water quality impacts on the Marsh Creek watershed and the project's contribution to flooding are negligible,the j project's contribution to this cumulative impact is considered less than significant. Cumulative impacts on Delta water resources near Big Break also occur from a number of industrial, municipal, and agricultural discharges to the Delta that together have an uncertain effect on uses of Delta water for municipal and industrial water supply and the Delta ecosystem. The City's ultimate discharge of 15.5 cfs to Marsh Creek and ultimately Big Break would occur in approximately 60 years according to projections in the City's Wastewater Facilities flan. This effluent discharge to the Delta would be extremely small compared to other existing municipal, f industrial, and agricultural discharges to Delta waterways and compared to the dilution potential } in Big Break After the initial effluent discharge is diluted in Big Break tidal flows, the water will eventually enter the San Joaquin River near Antioch. The actual dilution volume of the 15.5 cfs discharge would be intermediate between the net flow of the San Joaquin River at Antioch and the flows resulting from tidal exchange. The limited flow measurements for Antioch from the USGS using ultrasonic velocity measurement techniques were used to develop a regression relationship to estimate flows at Antioch using,flows at Rio Vista and Qwest. During 1990, a relatively dry year, estimated Antioch flows varied from -3,500 cfs to 12,000 cfs and during 1996, a relatively wet year, estimatedAntioch flows varied from-3,500 cfs to 40,500 cfs. Delta flow modeling by the California Department of Water Resources(DWR)for May 1988 i (Oakley-Bethel Island Wastewater Management Authority 1990) estimated a minimum tidal volume change in Big.Break of 340 million gallons (mg) and a maximum of 2,210 mg, with the smallest volume change for two consecutive tidal cycles being about 1,100 mg. The 15.5 cfs discharge from the City's'wastewater plant represents only 5.2 mg during a tidal cylcle (1.5 %of the smallest tidal volume change). The ultimate 15.5 cfs effluent discharge would therefore be very small compared City of Bren wood iWVrTP Project Chapter 3. Errata Sinai Ef? November 1998 3-2 { i to the tidal flows in the San Joaquin River near Antioch. Tidal flows measured by the USGS upstream from Antioch have been as large as 140,000 cfs (Gage RSAN018, http://www.iep.ca.gov). Thus, the ultimate 15.5 cfs discharge would likely have minimal effects on water quality in the Delta because it represents such a small flow compared to the San Joaquin and Sacramento River water moving through Big Break and the Antioch area. The evaluation of project-specific impacts for the Brentwood WWTP indicates that water quality impacts on Marsh Creek would be less than significant, and potential effects of priority pollutants could be reduced by proper design and a source control program. Therefore, the project contribution to potential cumulative water quality impacts on the Delta at Big Break are considered less than significant. CHAPTER 5. ALTERNATIVES ANALYSIS Errata to Page 5-3 The pipeline would then proceed approximately 2,400 feet north,again crossing the AT&SF right-of-way, and then continue along a dirt access road that parallels the west bank of the creek to the Contra Costa Canal. City of Brentwood WWT'P Project Chapter 3. Errata Sinal EIR November 1998 3-3 ! Table 2-1. Anticipated Discharge Requirements for the City of Brentwood Marsh Creek WWTP Project j Constituent Discharge Requirement Effluent Requirements Biological oxygen demand 10 mg/l Suspended solids 10 mg/l Settleable matter 0.1 mg/l r Oil and grease 10 mg/l Total residual chlorine 0.0 mg/l Total coliform bacteria 2-3 2.2 MPN/100 ml' Methylene blue active substance 1.0 mg/l i Turbidity - P14 6.5-8.5 Dissolved oxygen 5.0 mg/l Ammonia Level that provides no effluent toxicity(in mg/1) Bioassay' Yes Priority pollutants Yes Receiving Nater Requirements PH Shall not alter normal ambient pH of receiving water by more than 0.5 unit Turbidity No increase more than 10%above background levels(in NTU) ( Dissolved oxygen 5.0 mg/l,or no further decrease if upstream levels are less than 5.0 mg/l j Note: mg/l=milligrams per liter, mi=milliliter,MPN=most probable number,NTU=nephelometric turbidity units. j23 MPN/100 ml unless parks are developed along Marsh Creek, in which case the requirement would be 2.2 MPN/100 mi. Effluent used for reclamation will meet the requirements set forth in Title 22, Division 4 of the California Code of Regulations. ' Survival of test organisms shall be minimum one bioassay- 70%;median any three or more bioassays- 90%, Must also meet metal limits in the California Toxics Rule, if it is adopted. Source: Montgomery Watson 1997a. 1 1 i Table 3A-4, Anticipated NPDES Permit Limits for the Proposed Brentwood WWTP Effluent Discharge Limitations Effluent Marsh Creek Constituents Units Limits Limits BOLA,5-day mg/L 10 Total suspended solids mg/L to -- Settleable matter ml/L 0,1 -- Oil and grease mg/L 10 - Total coliform bacteria MPN/}00 mi -23 2.20 -23 2.2° Methylene blue active nig/L Lo substances Turbidity NTU -- < 10% increase over background pH Standard 6.5 to 8.5 <0.5 change from background Dissolved oxygen mg/L 5.0 5.0 or no further decrease below background Ammonia(N) mglL No effluent toxicity Chlorine(residual) mg/L 0.0 _. Temperature °C -- <5 °C change from background Chronic toxicity bioassay -- To be determined to be determined Central Valley Regional beater Quality Control Board staff are currently reviewing the appropriate disinfection level required for direct discharge to Marsh Creek. Effluent used for reclamation will meet the requirements set forth in Title 22, Division 4 of the California Cade of Regulations. • l i r I i I