Environmental Impact Report and Statement : South Bay Dischargers Authority Treated Wastewater Disposal Program ; Final

FINAL ENVIRONMENTAL IMPACT REPORT AND STATEMENT TREATED WASTEWATER DISPOSAL PROGRAM -v ^> U.S. Ei>viroi?rtKi)taI Protection Agei>cy South Bay Dischargers Authority ------- ------- EPA-9-CA-South Bay Dischargers Authority - 80 FINAL ENVIRONMENTAL IMPACT REPORT AND ENVIRONMENTAL IMPACT STATEMENT SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM June, 1980 Prepared by: U.S. Environmental Protection Agency Region IX 215 Fremont Street San Francisco, California 94105 With technical assistance from: Bechtel 50 Beale Street San Francisco, California 94119 and South Bay Dischargers Authority 801 North First Street San Jose, California 95110 Grant No. CA-06-1135 RESPONSIBLE OFFICIALS: 3aul De Falco, J Regional Administrator Environmental Protection Agency Region IX James A. Alloway £s Chief Executive Officer South Bay Dischargers Authority 04 3 ENWRONMENW MOrBnONAGMr WASHINGTON. O.C. 20460 ------- ------- To All Interested Agencies, Public Groups, and Concerned Individuals: discharges were moved north of the Dumbarton Bridge. The Final Environmental Impact Statement (EIS) and Environmental Impact Report (EIR) for the South Bay Dischargers Authority Treated Wastewater Disposal Program is being distributed at this time for your review and comment. This program investigated alter- natives for providing a wastewater disposal system for the San Jose/ Santa Clara, Sunnyvale, and Palo Alto wastewater treatment plants, located in the Santa Clara County Baylands along the southeastern edge of San Francisco Bay. The Final EIR/EIS has been prepared to conform with the requirements of the National Environmental Policy Act of 1969 and the California Environmental Quality Act of 1970, as amended. The Draft EIR/EIS was jointly issued by the Environmental Protec- tion Agency (EPA), Region IX, and the South Bay Dischargers Authority (SBDA) on March 19, 1979. The Draft EIR/EIS was filed with the State Clearinghouse (SCH No. 79040905) and with the EPA Office of Environmental Review (EIS Order No. 90292), and circu- lated for review among various Federal, State, and local agencies as well as firms, organizations, and concerned individuals. This document contains a record of the public hearing, responses to the comments received at the public hearing, written comments, and further information which has been developed concerning the proj- ect. This document, along with the Draft EIR/EIS (Summary, Technical, and Appendices Volumes) constitutes the Final EIR/EIS. The project alternative that has been selected is the "no project alternative." It was selected for the following reasons: 1. The degree to which increased dilution resulting from a dis- charge north of the Dumbarton Bridge will mitigate the adverse impacts of toxicants on the biota of the South Bay cannot be predicted. 2. Modeling studies have not shown that a substantial improve- ment in dissolved oxygen concentrations would result if the 3. The viability of future full reclamation is being investigated in the Regional Wastewater Reclamation Study. Should such an alternative prove to be feasible, it would meet the planning requirements of the San Francisco Bay Basin Plan. Operation of newly constructed advanced wastewater treatment facilities was begun by the San Jose/Santa Clara and Sunnyvale wastewater treatment plants in early 1979. Palo Alto's advanced treatment facilities will be operational by mid-1980. It is anticipated that the overall water quality in the South Bay will be improved due to the operation of these facilities. Monitoring programs of the SBDA member agencies and the San Francisco Bay Regional Water Quality Control Board (RWQCB) will continue to be evaluated and, if appropriate, the selection of the "no project alternative" will be reconsidered. During September, 1979, the San Jose/Santa Clara wastewater treat- ment plant experienced an upset and was temporarily unable to provide full treatment to all wastewater flows prior to discharge. This resulted in extensive pollution of the lower portion of South San Francisco Bay in the vicinity of Coyote Creek. The RWQCB, in response to the wastewater treatment plant upset, issued a cease and desist order. This order requires that the cities of San Jose and Santa Clara develop means to protect against future upsets. San Jose and Santa Clara are now working to develop a solution to this requirement. Wastewater reclamation was investigated as a possible effluent dis- posal alternative, but was not selected due to its high cost. The three discharging agencies, as a group and individually, are continuing to evaluate regional wastewater reclamation and have implemented localized reclamation. A continued commitment in this area by the agencies is an integral factor in the alternative selected at this time. Written comments sould be submitted within thirty (30) days of the issuance of this Final EIR/EIS to: ------- ------- U.S. Environmental Protection Agency Region IX Attn: Hearing Office (HE-141) 215 Fremont Street San Francisco, CA 94105 After review of comments received on this Finat EIR/EIS, EPA will issue a public record of its decision on the selected project alternative. The Final EIR/EIS may be reviewed at the following locations: U.S. Environmental Protection Agency Region IX Library 215 Fremont Street San Francisco, CA 94105 U.S. Environmental Protection Agency Public Reference Unit (P. M. 213) 401 M Street, S.W., Room 2922 Washington, D.C. 20460 Documents Librarian Santa Clara County Library Research Center 10400 Torre Avenue Cupertino, CA 95014 San Jose Public Library 180 W. San Carlos Street San jose.CA 95110 Palo Alto Public Library 1213 Newell Road Palo Alto, CA 94303 Santa Clara County Library 7387 Rosanna Street Gilroy.CA 95020 Santa Clara County Library 78 South Dempsey Road Milpitas, CA 95035 Mountain View Public Library 585 Franklin Street Mountain View, CA 94040 Library Water Resources Center University of California Berkeley, CA 94720 Santa Clara Public Library 2635 Homestead Road Santa Clara, CA 95051 Sunnyvale Public Library Attn: Documents Librarian 665 W. Olive Avenue Sunnyvale, CA 94086 Santa Clara County Library 1095 North 7th Street San Jose, CA 95112 NASA Ames Research Center Technical Library Moffett Field Sunnyvale, CA 94040 City of San Jose Planning Department 801 North First Street San Jose.CA 95110 ------- ------- FINAL EIR/EIS This volume provides a brief description of the alternatives for dis- posal of South Bay Dischargers Authority (SBDA) highly treated wastewater, the impacts of each alternative, the rationale for the selection of an alternative (No Further Action), and responses to comments on the Draft Environmental Report and Statement (E/R/E/S), the Draft Summary, and Appendices A — L of that draft EIR/EIS. More detailed analyses of primary and secondary impacts, both adverse and beneficial, are contained in the Draft EIR/EIS, which was issued March 19, 1979 for public review and comment. Since the Draft EIR/EIS is not being reprinted, an errata list for that report is provided in this volume {Section 4). This volume and the Draft EIR/EIS comprise the Final Environmental Report and State- ment, Treated Wastewater Disposal Program. A BRIEF DESCRIPTION OF THE DISPOSAL PROBLEM BACKGROUND AND HISTORY -Prior to the formation of the South Bay Dischargers Authority (SBDA), an information organization consisting of San Jose, Santa Clara, Sunnyvale, Palo Alto (its member cities) and the Union and Menlo Park Sanitary Districts initiated a study to investigate alter- native long-term solutions to wastewater management programs in the portion of the San T-ancisco Bay south of Dumbarton Bridge (South Bay). A recommended plan was presented in the Consoer- Bechtel (1972) report entitled Water Quality Management Plan for South San Francisco Bay. The SBDA was formed on April 1,1973, when the cities of San Jose, Santa Clara, Sunnyvale, and Palo Alto entered into a Joint Exercise of Powers Agreement, and a second study was commissioned. Bechtel Incorporated completed the Overview Facilities Management Plan in 1974, which recommended that three subregional plants pro- vide advanced treatment (AWT) for wastewaters generated within the SBDA service area. The plants would be at the sites of the existing secondary plants operated by San Jose/Santa Clara, Sunnyvale, and Palo Alto. It was further recommended that treated wastewaters from these three plants be collected in a regional intercepter for dis- charge through a common outfall into deep waters north of Dum- barton Bridge, in order to meet interim water quality standards that prohibited discharge south of Dumbarton Bridge or to the dead-end sloughs tributary to the Bay. The 1974 report found that even if a different method of effluent disposal were chosen, the advanced level of treatment recommended would still be required. On this basis, EPA in late 1974 issued Nega- tive Declarations (findings that impacts from proposed projects will be insignificant) on upgrading the three secondary plants to provide the advanced treatment. This action allowed the design and construc- tion of these facilities to proceed at once. On May 30, 1975, EPA issued a Notice of Intent to commence with the preparation of an EIS on alternative effluent disposal systems. SBDA, as a State-Chartered Agency, entered into an agreement with EPA to prepare a joint EIR/EIS, responsive to both State of Cali- fornia and United States requirements. The common outfall to the north of Dumbarton Bridge, by that time incorporated in the San Francisco Bay Water Quality Management Plan (or Basin Plan) by the State Water Resources Control Board .(SWRCB) and Regional Water Quality Control Board- (RWQCB) in 1975, was to be consid- ered as one of these alternatives. Since that time, the SBDA and its consultant, Bechtel Incorporated, have been engaged in the background studies required to generate sufficient data for the EIR/EIS. The Draft EIR/EIS is a result of those studies. On April 4, 1979, the EPA issued a notice of joint public hearing on the Draft EIR/EIS to be held May 16, 1979. The hearing was adjourned and the comment period closed on August 24, 1979. This report documents the hearing, comments received, and information developed in response to the comments. ------- WATER QUALITY PROBLEMS AND GOALS OF A DISPOSAL PROGRAM Historically, wastewaters from SBDA member agencies have been discharged into sloughs draining into the South Bay. This has caused an increase in pollutants in South Bay waters — the degradation of water quality in the South Bay has been severe. Depression of dis- solved oxygen concentrations to levels as low as 0.7 milligram-per liter, high concentrations of toxic heavy metals in the sediments, and localized problems of fish kills and waterfowl botulism out- breaks have all been attributed to the waste load accumulations in the South Bay. These conditions are thought to be further aggravated by the lack of freshwater inflow during the dry season and the sub- sequent reduced flushing of the estuary. During September 1979, the San Jose/Santa Clara wastewater treat- ment plant experienced an upset and was temporarily unable to provide full treatment to all wastewater flows prior to discharge. This resulted in extensive pollution of the lower portion of South San Francisco Bay in the vicinity of Coyote Creek. Monitoring during the first few days after the upset showed that many species of fish nearly disappeared. However, by mid-October there was some evidence that aquatic life was returning to the South Bay. This evidence is not conclusive and new information continues to be evaluated. While the pollution of the Bay due to the plant upset resulted in a rapid loss of water quality in the vicinity of the discharge, it appears there has been a return to near normal water quality conditions. Uncertainty exists about the long-term impact of the wastewater treatment plant upset upon aquatic biota. It is expected that moni- toring programs begun since the upset will provide more accurate information about the status of impacts to the Bay. The RWQCB, in response to the wastewater treatment plant upset, issued a cease and desist order. This order requires that the cities of San Jose and Santa Clara develop means to protect against future upsets. San Jose and Santa Clara are now working to develop a solu- tion to this requirement. The upset incident has demonstrated the need for reliable treatment in conjunction with adequate disposal. The cities of San Jose and Santa Clara are reviewing the plant's treatment capabilities and oper- ating procedures in an effort to improve treatment reliability. Operations of newly constructed advanced wastewater treatment facilities was begun by the San Jose/Santa Clara and Sunnyvale wastewater treatment plants in early 1979. Palo Alto's advanced facilities will be operational by mid-1980. It is anticipated that the overall water quality in the South Bay will be improved due to the operation of these facilities, information obtained from monitoring programs of the SBDA member agencies and the RWQCB will con- tinue to be evaluated. The goal of the Treated Wastewater Disposal Program was to elimi- nate the discharge of wastewaters to South San Francisco Bay as re- quired by the SWRCB's Bays and Estuaries Policy and the RWQCB's Basin Plan. Each alternative discussed in the Draft EIR/EIS was evaluated with regard to the achievement of the water quality stan- dards of the SWRCB and RWQCB, the implementation of advanced waste treatment (AWT), and the environmental impacts and econo- mic costs expected. At this time, it is felt that more information is needed to fully eval- uate the impacts of the present treatment and disposal systems against the standard of a level of environmental protection equal to a deepwater outfall. Specific areas of concern over South Bay waste discharges include: (1) impact on the aquatic biota; (2) botulism po- tential; (3) dissolved oxygen levels; (4) toxicity levels; and (5) heavy metal levels in the South Bay. It is recommended that appropriate monitoring programs be developed to provide the needed informa- tion base for future reevaluations. The actions that will be taken in response to the September 1979 upset, together with the ongoing ------- monitoring and evaluation efforts, will provide the information for further evaluation of either the "no project alternative" selection or the existing water quality standards and discharge prohibitions. SETTING OF THE ALTERNATIVES The study area considered in the Draft EIS is that portion of the Santa Clara County Baylands between San Jose and the Dumbarton Bridge (Figure 1). This gently sloping, almost flat, plain and the open waters of the Bay have been extensively developed for urban, commercial, and institutional uses, including water pollution control facilities, sanitary landfills, commercial salt concentration ponds, and recreational areas. The waters of the South Bay have a moderating effect on the climate of Santa Clara County; this climate in turn influences the suscepti- bility of the area to air quality problems. The study area is in a crit- ical air basin; the combination of strong subsidence inversions common along the Pacific Coast and a basin ringed by mountains and open to the sea results in a high potential for impaired air quality. During the summer and early fall, when air temperatures are higher, these conditions result in periods of increased air pollution, primarily from non-point sources such as automobile traffic. However, disposal is not growth-related and, since no increase in treatment capacity is planned, no secondary impacts on air quality are expected. Geologic hazards consist of the potential for major earthquake activ- ity along the San Andreas fault zone to the west of the Bay and along the Hayward fault zone to the east. A major earthquake could affect the structural integrity of a pipeline should the firm Bay Muds supporting the structure lurch or slide. One of the most characteristic features of the South Bay is the di-: verse habitat available for fish and wildlife. This habitat, designated as a beneficial use of the area in the San Francisco Bay Water Quality Management Plan, consists of open bay waters, estuarine and tidal mud flats, fresh and saltwater marches, salt concentration ponds, and grasslands. Although somewhat reduced in productivity as a result of water pollution problems and extensive urban develop- ment pressures, these Bayland habitats still support a diverse plant and animal community, including three resident endangered species (California least tern, California clapper rail, and salt marsh harvest mouse). Portions of the South Bay have been designated as part of the San Francisco Bay National Wildlife Refuge; in the area south of Dumbarton Bridge, the wildlife refuge consists of the marshlands, salt ponds, and sloughs from Alviso Slough north on the eastern side of the Bay. ALTERNATIVES CONSIDERED During the development of the Water Quality Management Plan for South San Francisco Bay and the Overview Facilities Management Plan, a number of treatment and disposal alternatives were examined. In the Draft EIR/EIS, nine disposal alternatives were evaluated, some of which were considered in the earlier studies. The criteria for evaluation in the Draft EIR/EIS include legal and institutional re- quirements as well as economic, engineering, and environmental (physical, chemical, biological, and sociocultural) factors. BASIN PLAN ALTERNATIVE The Basin Plan-Alternative consists of a regional conveyance pipeline, connecting lines, and pumping facilities along the southwestern shore and in the waters of the South Bay (Figure 2). The pipeline is approximately 16 miles long, extending from a pumping station at the existing San Jose/Santa Clara treatment plant to a discharge point in the deepwater channel approximately one mile north of Dumbarton Bridge. The pipeline varies in diameter from 90 inches (inside diameter) at its southern end to 102 inches at the outfall. The three subregional advanced waste treatment plants (San Jose/ Santa Clara, Sunnyvale, and Palo Alto) discharge wastewaters into ------- VP^\\W^_^0-, ^^^^^^^;rfs-i'i-5-^w^\)f^x^^';v^.v'''V\ . v\ SBDA SERVICE AREA APPROXIMATE BOUNDARY OF BASIN PLAN ALTERNATIVE STUDY AREA Figure 1 STUDY AREA LOCATION AND PRINCIPAL MUNICIPALITIES ------- this conveyance at pumping stations Jocated near the treatment plants. The pumping stations could be modified to accommodate reversal in flow direction if large-scale regional reclamation and reuse programs that require transport of wastewaters southward are implemented in the future. The Basin Plan Alternative facilities would be located on the Bay- lands plain, roughly between the Bayshore Freeway (U.S. High- way 101) and the inboard levees of the salt ponds."Where possible, the route follows existing utility corridors. Pumping stations are located on treatment plant or industrial park property. However, due to the nature of the Santa Clara Baylands, approximately 74 per- cent of the proposed alignment is located in relatively natural bio- logical areas. The main goal of the Basin Plan Alternative is compliance with the terms set forth in the Basin Plan, e.g., general improvement in dis- solved oxygen levels in the South Bay, which contributes to the protection of the designated beneficial uses of these waters. Three wastewater outfalls to the Bay south of Dumbarton Bridge, including one in the San Francisco Bay National Wildlife Refuge, are elimi- nated. However, this alternative'could result in primary adverse impacts during construction as well as secondary adverse impacts during operation. Adverse construction impacts could include alteration of topog- raphy, erosion, dust, air pollution, noise, degraded water quality, and loss of biological habitat. All of these impacts are short-term, lasting only during construction (approximately two weeks at any point along the conveyance) and a recovery period immediately following completion of construction. Mitigating measures such as route selection, surface, restoration, stream bank stabilization, and reveg- etation could reduce the significance of these impacts. The areas most affected include the Palo Alto discharge canal and the Palo Alto Baylands Reserve. These areas have been disturbed in the past and are now recovering from this disturbance; construction would slow this recovery. No known historical or archaeological sites are LEGEND «•— CONVEYANCE O DISCHARGE POINT • TREATMENT PLANTS MIL SJ/SC SV Figure 2 SCHEMATIC-BASIN PLAN ALTERNATIVE, ON-LAND affected; no relocation of residents is anticipated; and no long-term disruption of aesthetics or access would occur. Operation of the conveyance contributes to degraded water quality in two locations. The disposal point is locally affected by pollutants in the discharge, but no violations of water quality standards are anticipated. The headwaters of Artesian Slough could be degraded as they become more saline with the removal of the freshwater dis- charges from the San Jose/Santa Clara treatment plant. The head- waters are expected to exhibit an increased expression of background oxygen demands. Reduced.flows also result in increased salinity in the South Bay to levels above those now occurring north of Dum- barton Bridge. Levels of 50 ml/1 of toxicity are expected to occur in the 1985 dry season (the toxicity guidelines are 40 ml/1). These changes in water quality in the South Bay and its sloughs affect both ------- biological productivity and habitat diversity in an adverse and in- direct manner, particularly in Artesian Slough. Hazards to structural and operational integrity of the Basin,Plan Alternative include potential damage by earthquake, plant upsets, pumping station malfunctions, or power failures. Each of these could potentially result in a bypass of wastewater to the South Bay. The proper selection of pipeline alignment, the use of pilings placed in stiff clays in areas of soft muds, and backfill with coarse granular material could reduce, to the extent possible, the potential for earthquake damage. Backup pumping systems and power sup- plies, as well as some storage capacity for bypassed flows at Sunny- vale, could reduce in-Bay impacts that could be caused by system failures. Operation of the. Basin Plan Alternative would result in electrical energy consumption in 1981 on the order of 7.9 million kilowatt- hours per year; this is equivalent to approximately 4,900 barrels of crude oil per year. To place this in perspective, the same energy consumption would occur if each of the residents of Santa Clara County burned two 150-watt light bulbs for slightly less than one day each year. Capital costs for the conveyance and pumping sta- tions are estimated to be $86 million (1978 dollars escalated to 1980), 87.5 percent of which is covered by federal and state grant funds. Annual operating costs (estimated for 1981-1983) of approx- imately $320,000 (power consumption, maintenance, and adminis- tration) would not be grant fundable. Each user — residential, commercial, institutional, and industrial — that discharges into the SBDA sewer system must pay a fair share of the cost of operating and maintaining a conveyance pipeline. A sys- tem of "user charges" would be established to accomplish this. In addition, each industrial user must pay back to the cities in the SBDA its share of the federal funds for capital costs; this is known as "industrial cost recovery." Annual revenue requirements for industrial users, therefore, could impose a burden on the individual industries, varying with the percentage treatment capacity of the system attributable to each industry. Seasonal large-volume dis- chargers, such as the canning industry, are likely to have higher revenue requirements than year-round and low-volume dischargers. Alternative (Estuarine) Alignment for the Basin Plan Alternative This subalternative involves a common conveyance from San Jose to the discharge point north of Dumbarton Bridge, with the alignment being located primarily in the waters of the South Bay (Figure 3). Impacts associated with operation of this subalternative are identical to those expected from the Basin Plan Alternative, although more salt pond, mudfalt, and open water habitat are affected by construc- tion, increased construction time is required, and more dredge spoils are generated. In addition, construction in salt ponds is more costly LEGEND -+— CONVEYANCE D DISCHARGE POINT • TREATMENT PLANTS MIL SJ/SC Figure 3 SCHEMATIC-BASIN PLAN ALTERNATIVE, ESTUARIAL ------- because special techniques have to be developed to avoid disruption of salt pond operation and to prevent breaching of the dikes. As a result, construction costs are slightly greater than those expected for the proposed project. The estuarine route, then, was eliminated from full consideration, since, when compared with the Basin Plan Alter- native route, it has a similar impact on water quality, is not less costly to construct or operate, and has more adverse environmental impacts during construction. Leslie Salt Company Participation in the Basin Plan Alternative For the past several years, Leslie Salt Company has stored the toxic residue from evaporative salt production (bittern — the highly con- centrated fluid that remains after salt crystallizes out in the salt LEGEND a CONVEYANCE DISCHARGE POINT TREATMENT PLANTS MIL SJ/SC SV Figure 4 SCHEMATIC-BASIN PLAN ALTERNATIVE, LESLIE SALT ponds). However, this storage is encroaching on the productive salt ponds at the rate of one per year and, consequently, is reducing the diversity of the habitat in the National Wildlife Refuge as well as limiting the economic production of salt in the South Bay. Since bittern is highly toxic and cannot be treated for toxicity, it may be discharged only after dilution of 100:1 concentrations. One source of water for dilution is the Bay itself; however, a toxic plume of wastewater might affect as much as one-third of an acre of Bay bottom under such conditions. Another source of dilution water is wastewater from a South Bay discharger. SBDA is a logical choice of such diluent, and if the Basin Plan Alternative were to be imple- mented, it would be technically feasible for Leslie Salt to connect to the disposal pipeline in order to discharge bittern (Figure 4). There are institutional constraints to the joint participation of SBDA and Leslie Salt Company. • SBDA is a chartered municipal discharger located entirely within Santa Clara County, while Leslie Salt is an industry .in Alameda County; the SDBA charter would require amendment. 0 Leslie Salt Company would have to arrange payback to state and federal granting agencies of the pipeline and diffuser capacity preempted by its use. . • Leslie Salt would have to arrange self-monitoring and automatic shutdown of discharge to assure 100:1 dilu- tion minimum discharge at the proper flows and discharge only at ebb tide in winter. NO ACTION BEYOND CURRENTLY APPROVED IMPROVE- MENTS AT TREATMENT PLANTS Under this, the selected alternative, no further improvements would take place beyond the recently (1978,1979) implemented advanced waste treatment facilities (Figure 5). Continued discharge at present disposal points retains freshwater flushing in Artesian Slough; water ------- LEGEND •— CONVEYANCE Q DISCHARGE POINT • TREATMENT PLANTS MIL SJ/SC sv Figure 5 SCHEMATIC-NO FURTHER ACTION ALTERNATIVE PA LEGEND «•— CONVEYANCE O DISCHARGE POINT • TREATMENT PLANTS MIL SJ/SC Figure 6 SCHEMATIC-INDIVIDUAL DEEPWATER OUTFALL ALTERNATIVE quality standards are not, however, met south of Cataveras Point during dry and canning seasons. No further action does not comply with Basin Plan prohibitions against discharge south of Dumbarton Bridge or to tributaries on the South Bay, does not guarantee a 10 to 1 dilution rate, and may result in toxicity levels of up to 400 ml/1. A No Further Action alternative could be considered part of a deferred action program, however, in which the effects of the approved AWT could be monitored and documented, and the via- bility of future full reclamation could be investigated further. No additional costs or construction impacts are incurred with this alternative. Should additional action be required at some future date to meet water quality standards, the cost of this new action is significantly greater than present estimates, and the effects of inflation on labor and materials all contribute to this increase. INDIVIDUAL OUTFALLS TO BAY SOUTH OF DUMBARTON BRIDGE Using separate outfalls, dischargers would convey effluent to the nearest deep water south of Dumbarton Bridge (Figure 6). Under this arrangement, effluents from the San Jose/Santa Clara and Sunnyvale treatment plants are combined and conveyed to a discharge point in the vicinity of Calaveras Point; effluent from the Palo Alto plant is discharged from an outfall in deep water northeast of its present dis- charge location. This system should meet dissolved oxygen require- ments in open waters of the Bay, while discontinuing wastewater discharge to the sloughs. However, improvement in water quality in the South Bay is not as great as would be expected if discharges were relocated north of the Dumbarton Bridge, and the prohibition ------- against discharge to the Bay south of Dumbarton Bridge is not met. Toxicity levels of 125 rnl/l could occur and, as with the Basin Plan Alternative, this alternative eliminates freshwater flushing of the sloughs during the dry season, endangering the freshwater habitat of Artesian Slough. The nature and extent of construction impacts from this alternative are not significantly different from those of the Basin Plan Alterna- tive, although more extensive impacts would occur on natural habi- tats, such as marches and salt ponds. The cost of construction and, the first year of operation is estimated to be approximately 80 percent of that of the Basin Plan Alternative, or $69 million; however, this estimate does not provide for the technical problems of construction in salt ponds. These problems would increase construction time and costs. This alternative is compatible with local or small-scale reclamation and reuse projects and coujd function as an off-season disposal sys- tem for such projects. However, this alternative is less compatible with large-scale Bay Area reclamation than the Basin Plan Alterna- tive, since a regional collection system for Santa Clara would not exist. UPGRADED TREATMENT WITH CONTINUED LOCAL DISCHARGE No new conveyance systems would be built in this alternative; each treatment plant continues discharging at its present location (Figure 7). Treatment levels at San Jose/Santa Clara are further up- graded, to include breakpoint chlorination for residual ammonia removal and carbon absorption for removal of toxicity and for further removal of oxygen demanding materials. This alternative should meet dissolved oxygen requirements in open waters of the Bay. The sloughs would continue to receive flushing flows, and the freshwater habitat would persist in Artesian Slough. LEGEND •— CONVEYANCE O DISCHARGE POINT • TREATMENT PLANTS MIL SJ/SC SV Figure 7 SCHEMATIC-UPGRADED TREATMENT WITH CONTINUED LOCAL DISCHARGE ALTERNATIVE Oxygen depletion in the dry season and the buildup of conservative elements in the sloughs would continue, however. This alternative does not'meet the prohibitions against discharge south of Dumbarton Bridge or to dead-end sloughs, nor does it provide the 10:1 minimum dilution required by the Basin Plan. Toxicity levels of 400 ml/l are expected to occur in the dry season of 1985 in the South Bay. Construction impacts are less extensive for this alternative, limited to the San Jose/Santa Clara plant site. The cost of construction and the first year of operation is estimated to be approximately 1.4 times that of the Basin Plan Alternative, or $121 million: Costs of operating the advanced treatment facilities are greater than those of the Basin Plan Alternative primarily due to in- creased consumption of-chemicals and energy. Reclamation and 9 ------- reuse on a local scale is compatible with this alternative; however,.it is4less compatible with large-scale projects since a regional collector for Santa Clara County would not exist. RECLAMATION AND REUSE Reclamation of wastewater from the SBDA treatment system, and the reuse of this water, was considered as an alternative to disposal. Depending on the market location, size, and water quality require- ments, a reclamation and reuse alternative might include a reclama- tion treatment plant for additional treatment of a portion of the SBDA effluent, a distribution system to transport reclaimed waters to the market area, and an off-season disposal system for the dis- charge of that unreclaimed effluent (Figure 8). The benefit of this alternative is conservation of water resources by using reclaimed wastewaters in place of potable water supplies. Studies of the viability of reclamation and reuse in the Bay Area"have been sponsored by various member cities of SBDA, by the Depart- ment of Water Resources, by the Santa Clara Valley Water District, by the State Water Resources Control Board, by the EPA, by the State Department of Water Resources, and by the U.S. Bureau of Reclamation. Assuming a market in the Santa Clara Valley for a portion {67 mgd) of the San Jose/Santa Clara effluent, construction impacts include those anticipated for an in-Bay outfall system for off-season dis- charges as well as impacts on water quality, air quality, habitats, and aesthetics in the grasslands and agricultural lands of the Santa Clara Valley. The extent of these impacts vary with the market served (i.e., Santa Clara County only or Santa Clara and San Benito Counties). Operational impacts are primarily related to the cost and quality of the water in the market area. Salt buildup in soils, restrictions in crops, and the high cost of treating wastewaters to acceptable quality levels are all factors with potentially adverse impacts. Bay impacts vary with the disposal system chosen; generally, improvements in water quality similar to those proposed for the Upgraded Treatment Alternative would result, if the major portion of the effluent could be reclaimed year-round. The cost of construction and the first year operation of a 67 mgd facility is estimated to be 3.8 times that of the Basin Plan Alterna- tive, or $328 million. Increased cost is primarily due to increased treatment requirements and the cost of conveyance to the market. These include significant increases in energy consumption. Not included in this calculation are the revenues received for the sale of reclaimed waters, or the costs of an off-season discharge system. A study to determine the engineering, economic, and environmental feasibility of reclaiming a smaller portion of SBDA wastewaters for LEGEND .<— CONVEYANCE Q DISCHARGE POINT • TREATMENT PLANTS MIL Figures SCHEMATIC-RECLAMATION/REUSE ALTERNATIVE 10 ------- agricultural use in the South Santa Clara Valley and the Bolsa area of San Benito County was undertaken for this EIR/EIS. As an option for water resources management, such a small-scale reclamation/ reuse project has the benefits of (1) reducing SBDA discharges by approximately 10 percent, (2) increasing the amount of irrigation water without increased use of potable, diverted water supplies, and/or (3) opening up additional lands for irrigation. Disadvantages of such a project are primarily economic — depending on the level of treatment used, reclaimed water costs between $150 and $570 per acre-foot. If fully subsidized, the cost to the user (the farmer) is between $9 and $56 per acre-foot. However, in water-short areas, in drought years, and in areas with low-quality water supplies, such a water management option may be economically feasible and could be implemented regardless of the disposal alternative chosen. Such limited reclamation does not replace the requirement for a disposal system and, depending on the off-season or partial system chosen, may not comply with the water quality standard, toxicity guidelines, prohibition against discharge below Dumbarton Bridge, or a mini- mum 10:1 dilution. CONSOLIDATION WITH OTHER DISCHARGE AUTHORITIES This alternative involves consolidation with other discharger author- ities in San Mateo County, with discharge north of the San Mateo Bridge, and has been considered in earlier management programs. Although it meets water quality requirements in open water, many of the environmental disadvantages associated with the five pre- viously described alternatives occurs, such as decreased freshwater flushing in the sloughs. This alternative has more severe construction impacts and a higher cost (approximately twice) than the Basin Plan Alternative. Since many of the other Bay Area discharger author- ities have completed independent studies and, in some instances, begun construction of their own improved treatment facilities, consolidation requires forfeiture of invested funds by these other authorities, with no guaranteed benefits accruing to these authorities as a result of that action. For this reason, this alternative was not given further consideration. DISCHARGE TO THE OCEAN This alternative consists of a collection and disposal conveyance from the Baylands to the Pacific Ocean. A tunnel through the Santa Cruz Mountains, a deepwater ocean outfall, and a series of pumping sta- tions are required in addition to the major portion of the on-land systems of the Basin Plan Alternative. Construction impacts are sig- nificantly greater than those of in-Bay disposal Alternatives and. affect additional acreage of grassland, woodland, coastal zone, and ocean habitat. Water quality in the South Bay is expected to improve to levels similar to those expected for the Basin Plan Alternative. Freshwater habitat and flushing in Artesian Slough is lost. However, it was determined that the increased costs (approximately 2.7 times that of the Basin Plan Alternative) and construction impacts were not justified by the small increment in improved Bay water quality, and this alternative was not given further consideration. LAND DISPOSAL Transport of effluent to a land disposal site removes wastewater from the Bay and improves water quality to levels similar to those ex- pected for the Basin Plan Alternative. However, suitable land disposal sites do occur in Santa Clara County, and public acceptance outside the county appears to be lacking. In addition, construction impacts for a conveyance, storage, and dispersal system are large. Construc- tion and operation costs might range as high as eight times that of the proposed project, and energy usage is significantly greater. There- fore, this alternative was not considered further. NONSTRUCTURAL WASTEWATER MANAGEMENT Nonstructural wastewater management uses phased development of treatment and disposal facilities to meet water quality criteria. This alternative entails source control, land-use planning, and enforcement of environmental regulations to control the quality and quantity of wastewater. The alternative modes of disposal discussed in this 11 ------- EIR/EIS were considered as part of ongoing phased development plan, which in turn was designed in response to source control, land use, and environmental regulations. For this reason, nonstructural wastewater management is not an alternative mode of disposal; it is a criterion -for disposal and is incorporated as such into the client alternative disposal systems. SELECTION OF THE NO FURTHER ACTION ALTERNATIVE At the time of issuing the Draft EIR/EIS, no decision had been made as to the selected, or preferred, alternative. However, at that time, both the EPA and the SBDA were recommending a "no project alternative" (No Further Action) because: 1. The degree to which increased dilution resulting from discharge north of the Dumbarton Bridge will mitigate the adverse impacts of toxicants on the biota of the South Bay could not be predicted. 2. Modeling studies had not shown that a substantial im- provement in dissolved oxygen concentrations would result if the discharges were moved out of the sloughs (Individual Deep Water Discharge Alternative) or out of South Bay (Basin Plan Alternative). 3. The viability of future full reclamation is now being in- vestigated in a Regional Wastewater Reclamation Study. Several local small-scale programs are in the planning or implementation stage; however, these programs do not preclude a requirement for disposal of some portion of the flow. The Regional Wastewater Reclamation Study and smaller programs, if implemented, could meet the planning requirements of the San Francisco Bay Basin Plan. The EPA and SBDA recognize that many questions have been raised about the impact of treated effluents on biota which cannot be answered with data now available, and that the effects of the ad- vanced waste treatment (AWT) now being provided at each plant have not been documented or confirmed. However, EPA and SBDA feel that delay of a decision in order to obtain more data is not an acceptable approach, particularly since many of the issues left un- answered (chronic toxicity; aggravation of avian botulism; degree of oxygen depletion from presently "polluted" Bay muds, marshes and/ or wastewater; degree of flushing imparted by wastewater flows) require special, beyond state-of-the-art studies which often, in turn, ask more questions than they answer. Similarly, implementation of a construction program for a disposal or treatment system, which present data indicate will not guarantee improvement of water qual- ity or the beneficial uses of the Bay, does not appear to be acceptable. Comprehensive monitoring of the AWT effluents and present dis- charge points may confirm the reported current trend toward im- proved biologic conditions, increased biotic diversity, and recovery of shrimp, striped bass, and marine species fisheries. In addition, SBDA and its member agencies are committed to regional and local wastewater reclamation investigations. EPA and SBDA will continue to reevaluate results of this monitoring program and re- clamation studies, and will reconsider the disposal problem, if appropriate, after these data are available. SUMMARY OF THE COORDINATION PROCESS During the preparation of the SBDA Draft EIR/EIS, twelve Techni- cal Advisory Committee (TAC) meetings were held. A list of the members of the TAC, as well as the preparers of the EIR/EIS, is presented below and in Chapter VII of the Draft EIR/EIS. A dis- tribution list for the Final EIR/EIS is also presented here. PREPARERS OF THE EIR/EIS This Environmental Impact Report and Statement (EIR/EIS) has been prepared under a joint agreement dated 12 March 1975 be- 12 ------- y;ween the Environmental Protection Agency (EPA), the lead federal agency for the project, and the South Bay Dischargers Authority (SBDA), the lead state agency. Pursuant to this agreement, entitled "Agreement between the U.S. Environmental Protection Agency and the South Bay Dischargers Authority Regarding the Preparation of an Environmental Impact Statement and Provision of Payment Therefor," SBDA engaged Bechtel Incorporated as its consultant to assist EPA in drafting the EIR/EIS. The EIR/EIS project partici- pants and their affiliations are presented below: Technical Advisory Committee U.S. Army Corps of Engineers U.S. Geological Survey Department of the Navy Moffett Field Naval Air Station Col. H. A. Flertzheim, Jr. D. S. McCulloch LCDR W. V. Sayner, Jr., Ens. C. F. Winsor Environmental Protection Agency, Region IX Peter R. Perez Project Evaluator Charles H. Campbell Project Evaluator William Helphingstine Project Evaluator Lauren Fondahl Project Evaluator Statewater Resources Control Board F. W. Pierson Lyndel Melton Curtis Swanson Project Evaluator Project Evaluator Project Evaluator South Bay Dischargers Authority R. R. Blackburn 30 May 1974 to 21 August 1975 21 August 1975 to 4 June 1976 4 June 1976 to 11 April 1980 11 April 1980 to present 30 May 1974 to 8 September 1976 8 September 1976 to 16 September 1979 16 November 1977 to present City of San Jose, Project Coordinator State Water Resources Control Board State Department of Fish and Game III State Lands Commission State Department of Public Health San Francisco Bay Conservation and Development Commission Association of Bay Area Governments Bay Area Sewage Services Agency Regional Water Quality Control Board (2) U.S. Fish and Wildlife Service, River Basins Omer Peck, Howard Wright, Fred Botti, Jim Lee, John Harris, Bob Brown Michael Rugg Gary Horn William Joppling and Robert Witt Patricia Weesner Waide Egener and Robert Wong Dan Murphy and Karol Enferadi Robert Scholar, Robert Roche, Val Miller, Don Dalke, A. Van Kleek R. Breitenbach 13 ------- U.S. Ftsh and Wildlife Service, San Francisco Bay National Wildlife Refuge U.S. Food and Drug Administration Richard Nugent, Cathy Osugi, and Robert Personius David Alton Santa Clara Valley Water District Lloyd Fowler, Val Miller County Executive Santa Clara County Board of Supervisors City of Palo Alto City of Mountain View City of Sunnyvale City of San Jose City of Santa Clara State Department of Parks and Recreation U.S. Department of the Interior, Haydn C. Lee, Jr. Bureau of Reclamation City Manager and H. R. Remmel Norman H. Lougee City Manager and D. M. Somers City Manager, F. Belick, A. R. Turturici Robert R. Mortenson Santa Clara County Health Department San Benito County Board of Supervisors E. H. Pearl George E. Shore U.S. Department of Agriculture, Robert Ayers Agricultural Extension Service San Jose/Santa Clara Treatment Plant U.S. Coast Guard, Marine Environmental Protection Branch San Mateo County Board of Supervisors State Department of Water Resources Advisory Committee (F. Belick, E. Becker) N. Bell Country Executive Donald Finlayson, Hal Higgins, William Mitchell, jr. South Santa Clara Valley Water M. Sheeny, D. I. Martin, Conservation District J. Jeske Agricultural Extension Service, Edward Lydon U.C., County of San Benito Agricultural Extension Service, Peter Lert U.C., County of Santa Clara Bechtel John A. Peterson C. M. Spink R. L. Bardin University of California, Davis Dr. Robert Hagen Project Manager Project Manager Project Engineer, supervising design and engineering, pipeline 30 May 1974 to February 1976 . February 1976 to present 14 ------- C. Cain Carol M. Harper, Ph.D. Project Engineer, supervising design and engineering, treatment Project Engineer, supervising EIS writing and data gathering Hsing-Chi Chang, Ph.D. Noise control technology Walter T. Clark Physical geography David A. Cobb, Ph.D. candidate Marine biology — benthos J. A. Coil ill, Ph.D. G. S. Dhillon,Ph.D. S. Douglas R. Eggers J.W.Gerald, Ph.D. ' E. Goldman J. D. Gouge W. S. Gray, Ph.D. Charles A. Harper, Ph.D. Aquatic ecology, water chemistry Agriculture, soils Planning Planning Fisheries Environmental monitoring, chemistry Marine biology — plankton Marine biology — amphipods Terrestrial biology — birds and arthropods J. A. Hepper, Ph.D. candidate R. A. Hughes, Ph.D.. Martha H. Kohler, Ph.D. Douglas R. Longwell, Ph.D. Peter F. Mason, Ph.D. J. J. Meersman Ramon Nugent J. L. Owen F. Z. Patassy' Max G. Rodel R. B. Scheibach Brent P. Sherfey C. Valentino John D. Walsh B. L. Westree Consultant to Bechtel Michael Melanson Economics Water chemistry Oceanography and limnology — sediments Air chemistry Urban geography Water quality Noise control technology Terrestrial ecology-botany Agronomy and reclamation Water chemistry Groundwater, geology, water quality Economics Ecology Meteorology Marine ecology, estuarine biology* Terrestrial biology — mammals and plants 15 ------- E. H. Smith and Associates, Sebastopol, CA Edmund Smith, Ph.D. Benthic biological survey and collection of water samples (for qualifications of technical personnel, see Appendix H of DraftEIR/EIS) Archaeological Consulting and Research Services, Inc. Mill Valley, CA Archaeological and paleontological survey . R. C. Harlan and Associates, San Francisco, CA Collection of sediment samples and physical analyses of these sediment samples Pacific Environmental Laboratory, San Francisco, CA Chemical analyses of sediment and water samples Hydroscience, Inc., Westwood, New Jersey Mathematical model of water quality for South San Francisco Bay On FEIR/EISonly 16 ------- RESPONSE TO COMMENT ON SOUTH BAY DISCHARGERS AUTHORITY DRAFT EIR/EIS 17 ------- City of Santa Clara Planning Department 1500 Warburton Avenue Santa Clara, CA 95050 City of Mountain View Planning Department 540 Castro Street Mountain View, CA 94040 City of Sunnyvale Planning Department P.O. Box 607 456 W. Olive Avenue Sunnyvale, CA 94088 City of Los Altos Planning Department 1 N. San Antonio Road Los Altos, CA 94022 City of Palo Alto Planning Department 250 Hamilton Street Palo Alto, CA 94301 City of Milpitas Planning Department 455 E. Calaveras Blvd. Milpitas, CA 95035 City of Cupertino Planning Department City Hall, 10300 Torre Avenue Cupertino, CA 95014 Town of Los Altos Hills Planning Department 26379 Fremont Road Los Altos Hills, CA 94022 City of Los Gatos Planning Department P.O. Box 949 Los Gatos, CA 95030 City of Monte Sereno Planning Department 18041 Saratoga-Los Gatos Road Monte Sereno, CA 95030 Please bring this notice to the attention of all persons who would be interested in this matter. U.S. Environmental Protection Agency, Region IX by Paul De Falco, Jr. Regional Administrator South Bay Dischargers Authority by James A. Alloway Chief Executive Officer M it ------- TABLE OF CONTENTS RESPONSE TO COMMENT ON DRAFT EIR/EIS 1 SUMMARY OF COMMENTS PRESENTED AT 16 MAY 1979 PUBLIC HEARING • Transcript of Hearing 1.1 TESTIMONIES REQUIRING NO SPECIFIC RESPONSE 1.2 TESTIMONIES ADDRESSED IN OTHER SECTIONS OF THIS REPORT 1.3 TESTIMONIES REQUIRING RESPONSE 2 RESPONSES TO WRITTEN COMMENT RECEIVED DURING THE REVIEW PERIOD ENDING 6 JUNE 1979 2.1 LETTERS REQUIRING NO SPECIFIC RESPONSE • Office of the Governor, Office of Planning and Research, State Clearinghouse - EPA No. (HE149)3 • City of Saratoga - EPA No. (HE-149)4 • Town of Los Gates - EPA No. (HE-149)5 • City of Milpitas, Milpitas Sanitary District Board of Directors - EPA No. (HE-149)7 • City of Campbell - EPA No. (HE-149)10 • Paul N. McCloskey, Jr., U.S. Congress - EPA No. (HE-149}14 • U.S. Department of Transportation - EPA No. (HE-149H6 • Santa Clara Chamber of Commerce - EPA No. (HE-149H8 Page 25-51 53 55-56 57-58 62 62-63 63-64 64-65 65-66 66 67 67-68 Page * Cupertino Sanitary District - EPA No. (HE-149)19 68-69 • Norman T. Mineta, U.S. Congress - EPA No. (HE-149)25 ' 69 » County of Santa Clara, Board of Supervisors'- EPA No. (HE-149)26 70 2.2 LETTERS REQUIRING SPECIFIC RESPONSE • County Sanitation District No. 4, Santa Clara County - EPA No. (HE-149)! 73-77 • Santa Clara County Citizens Advisory Committee - EPA No. (HE-149)2 78-79 * U.S. Department of Commerce - EPA No. (HE-149)6 80 * Drs. Howard S. Shellhammer and H. Thomas Harvey, San Jose State University - EPA No. (HE-149)8 81 • Dr. L. Richard Mewaldt, San Jose State University - EPA No. (HE-149)9 82 • Santa Clara County Canners Association - EPA No. (HE-149H1 83-84 • U.S. Department of Agriculture - EPA No. (HE-149)12 85 • San Jose/Santa Clara Water Pollution Control Plant - EPA No. (HE-149)13 86-87 * Santa Clara Valley Water District '- EPA No. (HE-149H5 88-89 • California Department of Fish and Game - EPA No. (HE-149)17a 90-95 • California Water Resources Control Board - EPA No. (HE-149)17b 96-103 • D. E. Myers, Loma Prieta Chapter, Sierra Club - EPA No. (HE-149)20 104-105 • U.S. Department of Interior, Pacific Southwest Region - EPA No. (HE-149)21 106-108 • Patrick Ferraro, Santa Clara Valley Water District, District 2 - EPA No. (HE-149)22 109-110 19 ------- Regional Water Quality Control Board, San Francisco Bay Region - EPA No. (HE-149)23 ABAC - EPA No. (HE~149)24 Advisory Council on Historic Preservation - EPA No. (HE-149)27 Page 111-119 120-122 123-124 RESPONSES TO WRITTEN COMMENT RECEIVED AFTER 6 JUNE 1979 • Florence M. LaRivere - EPA No. (HE-149)28 • County Sanitation District No. 4, Santa Clara County EPA No. (HE-149)29 • Sunnyvale Chamber of Commerce - EPA No. (HE-149)30 128-129 130 131-132 4 ERRATA 5 DISTRIBUTION LIST 135-138 141-160 20 ------- Scctiop 1 SUMMARY OF COMMENTS PRESENTED AT 16 MAY 1979 PUBLIC HEARING ------- ------- RESPONSE TO COMMENTS SUBMITTED BY THE PUBLIC AND BY AGENCIES REGARDING THE DRAFT EIR/EIS In accordance with the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA), comments from the public have been solicited by the South Bay Dischargers Authority (SBDA) and by Region IX of the Environmental Protection Agency (EPA) on the Treated Wastewater Disposal Program Draft EIR/EIS. This solicitation took three fo rms: • Mailout on 29 March 1979 of Draft EIR/EIS or Summary to those individuals or agencies listed in Section VII.4 (pages 335-353) of the Draft EIR/EIS Technical Volume • Publication of notices in the Federal Register on 30 March 1979, and in local newspapers • Public Hearing, 16 May 1979, 7:30 p.m., at City of Santa Clara This appendix summarizes the comments received at the public hearing (incl- uding the transcript of that hearing) as well as copies of, and responses to, letters received as a result of public and agency review. Ms. D. Wulfhorst, Council Member, City of Sunnyvale (transcript pages 31-33) Mr. R. R. James, Chief Executive Officer, San Jose Chamber of Commerce (transcript pages 33-35) Mr. L, F. Cournoyer, Santa Clara Valley Water District (transcript pages 35-36) Mr. J. Quintal, Santa Clara County Canners Association (transcript pages 36-39) Mr. B. E. Schoppe, Santa Clara Chamber of Commerce (transcript pages 40-41) Mr. M. Pearl (transcript pages 41-42) Mrs. M. Brendler, Sunnyvale Chamber of Commerce (transcript pages 42-43) Mr. B. Martin, Citizens Advisory Committee, City of Santa Clara (transcript pages 44-45) Mr. P. Ferraro (transcript pages 45-49) Mr. C. Harrison, Director, Cupertino Sanitary District (transcript pages 49-50) Issues raised in this testimony are addressed on pages following the full transcript of the hearing. 1. TRANSCRIPT OF 16 MAY 3979 PUBLIC HEARING The following individuals testified at the public hearing, held in May 1979, in the City of Santa Clara Council Chambers: • Mr. R. Diridon, Supervisor, County of Santa Clara (transcript pages 26-30) • Mr. S. Goodman, Santa Clara County District Four (transcript pages 30-31) 23 ------- ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 IS 17 18 19 20 21 22 23 24 25 26 27 28 JOIIIT PUBLIC HEARING By the U.S. ENVIRONMENTAL PROTECTION ASEf.'CY and THE SOUTH BAY DISCHARGERS AUTHORITY COMBINED DRAFT ENVIRONMENTAL IMPACT STATEMENT'EM'mO'lMENTAL IMPACT REPORT HAY 16, 1979 7:30 p.m. Q.J< • Jfff HICMALL- 5. WALKER, CHAIRMAN M/Qtc.itc t^A. xJucw £ onfisopifitfs CEFTtnED SHORTHAND REPOFiTEFiS , 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 I Q ID 19 20 21 22 23 24 2i 26 27 28 j HR. GISSLER: The South Bay Dischargers Authority started their meeting at 7:00 p.m. and then adjourned to this time and I would now like to fcii-r.ially declare the'public hearing on the draft EIR/EIS for this project officially open. I would like to turn the meeting over to Matthew S. Malker a Senior Attorney Hearing Officer for the Environmental Protection Agency. MR. WALKER: Thank you, Mayor. Good evening, ( , MATT His W IK/ my name is Hicharr S. Walker and I've been appointed />'J to act as Hearing Officer for the purposes of these proceedings. This hearing is a joint hearing between the Environmental Protection Agency and the South Bay Dischargers Authority. Pursuant to the federal reaula- \ //// tions, a notice of this hearing was published en U April 2nd, 1979, in Volume 44 of tne^Register at page .-.^ j 19241. As we all know it is the Oc 1 1 o '0-t A tu toi y law I ,.> m that everybody readfe 4- the Federal Register every day,// So in addition to that, a notice of this hearing was aiso given by publication in newspapers in this vicinity and I have here a copy of the Notice of Joint Public Hearing by the U.S. Environmental Protection Agency and the South Bay Dischargers Authority. For the purpose of this record I am going to mark this copy of the Notice as Exhibit 1. We will have other exhibits later on to talk about. /// H/QujMe c«A. ijHCt' £ (_A>SGCiflit2 CERTtFIED SHORTHAND "EPOr.Tgfis 5B6NQ,Flfl$T ST , SN jO£c. CA9I11? TELEPHONE: ! ------- 1 2 3 4 5 6 7 B 9 10 II 12 13 14 15 16 1? IB 19 20 21 22 23 24 25 26 27 28 (Thereupon, a four-page document entitled Notice of a Joint Public Hearing by the U.S. Environmental Protection Agency was marked Exhibit 1 for identification.) MR. WALKER: This hearing being a joint hearing is being held pursuant to two different statutes; the National Environmental Policy Act of 1969, which is often called NEPA, requires that a detailed statement be made on the environmental impact and effects of any recommendation or reports of any major federal action. The Federal Water Pollution Control Act, also known as the Clean Water Act, requires the administrator of the Environmental Protection Agency to encourage waste treatment management that results in desirable environmental impact effects to the extent it is possible on an area wide basis. Title 40 of the Code of Federal Regulations requires the Environmental Protection Agency to hold a public hearing. Pursuant to those regulations the inte/i/tio/v Regional Administrator publicly announced the protection / of the Environmental Protection Agency to prepare an LUltA environmental impact statement in compliance -of- the' Section 102 of the National Environmental Policy Act. In addition to these requirements,' Resolution Number 73-16 of the South Bay Dischargers Authority requires preparation of an environmental impact report for the SBDA treated water disposal program. This resolution further requires that a public hearing be held during and before which any and all interested persons shall be 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 given an opportunity to be heard on the proposed environmental impact report. This is that hearing. A combined environmental impact statement, environmental impact report, has been prepared. It is entitled "Draft Environmental Impact Report and Statement, Treated Wastewater Disposal Program.' These four volumes constitute that report, and for the purposes of this record they will be marked as Exhibit 2. (Thereupon, a report entitled Draft, Environmental Impact Report and Statement, Treated Wastewater Disposal Program, Summary, dated September 197B was marked Exhibit 1 for identification. ) MR..WALKER; This hearing has been called to receive public comments on this Draft Environmental Impact Report. The notice states that the hearing may be continued from time to time or to a different place to accommodate the needs of witnesses or the Environmental Protection Agency. In order to bring the matter to some sort of a conclusion, so that a final Environmental Impact Statement can be prepared, the Environmental Protection Agency proposes at the end of this public hearing to close the record for the receipt of oral statements, but to leave the record open for three weeks, that is fifteen working days, for the receipt of supplemental written statements. Several people have requested permission to file supplemental written statements. It is expected that the fi u4 CERTIFIED SHQBTMANDBEPOf TESS Xt NO. FIRST ST.. SAN JOSE. C* 95(12 TELEPHONE: 403; 0 CERTIFIED SHORTHAND REPORTERS SM NO. F tR£T S F , SAN JOSE, CA 951U TCLEP!I01E: «OB\| 9994699 26 ------- l supplemental statements will amplify and enlarge the 2 positions that are taken tonight. 3 If for any reason the supplemental statements 4 take new positions, or bring substantially new facts to 5 the attention of the hearing bodies, it may be necessary 6 to schedule a new public hearing so that everybody can 7 have an opportunity to comment on those statements. 8 Now, this being a formal hearing, we are 9 making a record of the hearing, and Mrs. Valerie Fitch 10 of the firm of Fitch and Associates is a certified 11 shorthand reporter and is making a stenographic record of 12 all of the comments made here tonight. 13 We are going to request that all persons come 14 to the podium, use the microphone, tell us their name representative. 15 and if they are appearing in a roproocntod capacity, also 16 tell us in what capacity they are appearing. We win 17 not entertain questions from the floor, because it is 18 Impossible to keep an orderly record in such circumstances. 19 However, if people in the audience feel the 20 need for It, we will take a recess after the hearing 21 has been going on for some time for a question and answer 22 period. 23 Mr. Helphingstine, who is on my left, will be 24 glad to assist anyone in answering questions that may 25 occur to you. However, I have to note that the cdmments 26 that are made in a question and answer period are not a 27 part of the official record and way not be considered 28 when the final report is drafted and prepared. That 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 question and answer period is for your assistance and help. However, if anything comes up during that period that you feel should be on the record, it would be necessary for you later on to take the podium and recite it for the record. How, I have certain tedious work to do here, and if you will bear with me, 1 will announce some of the notices that have been received and the publications that have been made. 1 have an Affidavit of Publication of the Notice in the San Jose Hews on the 12th of April, which will be Exhibit 3. (Thereupon, a one-page document entitled Proof of Publication dated Hay 1st, 1979, was marked Exhibit 3 for identification.) MR. HALKER: It was published in the San Jose Mercury on the 12th of April, and the Affidavit of Publication will be Exhibit 4. (Thereupon, a one-page document entitled Proof of Publication dated May 1st, 1979, was marked Exhibit. 4 for identification.) MR. WALKER: It was published in the San Jose Sun on April llth, and that Affidavit of Publication will be Exhibit 5. (Thereupon, a one-page document entitled Proof of Publication dated April 11, 1979, was marked Exhibit 5 for identification.) MR. WALKER: It was published in the East Ssn "tTifeli fi Associates CERTIFIED SHORTHAND REPORTERS HE NO. FIRST ST.. SAN JOSE. CA 951 '2 TELEPHONE: 4MB) 996-0699 ie (A 9fifcli 6 (Associates CERTIFIED SHORTHAND REPORTERS W6 NO. FIRST ST.. SAN JOSE. CA 95117 TELEPHONE: KM] MBO6» 27 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 28 Jose Sun on the llth of April and that Affidavit-win be Exhibit 6. (Thereupon, a one-page document entitled Proof of Publication dated April 11, 1979, was marked Exhibit 6 for identification.) MR. WALKER: It was published in the South 'San Jose Sun on the llth of April and that Affidavit of Publication will be Exhibit 7. (Thereupon, a one-page document entitled Proof of Publication dated April 11. 1979, was marked Exhibit 7 for identification.) MR. WALKER: It was published in the Santa Clara Sun on the 10th of April and that Affidavit will be Exhibit Number 8. (Thereupon, a one-page document entitled Proof of Publication dated April 10, 1979, was marked Exhibit 8 for identification. ) MR. WALKER: It was published in the Campbell Press on the 12th of April and that Affidavit of Publication will be Exhibit 9. (Thereupon, a one-page document entitled Proof of Publication dated April 12, 1979, was marked Exhibit 9 for identification. ) MR. WALKER: It was published in the Cupertino- Monta Vista Courier on the .10th of April and that Affidavit of Publication will be Exhibit 10. (Thereupon, a one-page document entitled Proof of Publication dated April 10, 1979, was marked Exhibit 10 for identif i cd tion. ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MR. WALKER: It was published, in the Los Gates Times-Saratoga Observer on the 10th of April, and .that Affidavit of Publication will be Exhibit. 11. (Thereupon, a one-page document entitled Proof of Publication dated April 10, 1979, was marked Exhibit - 11 for identification. ) MR. WALKER: In the Milpitas Post on the 10th of April and that Affidavit will be Exhibit 12. (Thereupon, a one-page document entitled Proof of Publication dated April 10, 1979, was marked Exhibit 12 for identification. ) 11 MR. WALKER: The Sunnyvale Scribe on the +&th of April, and that Affidavit will be Exhibit 13. (Thereupon, a one-page document entitled Proof of Publication dated April 11, 1979, was marked Exhibit 13 for identification. ) MR. WALKER: In The Town Crier in Los Altos on the llth of April and that Affidavit will be Number 14. (Thereupon, a one-page document entitled Proof of Publication dated April 11, 1979, was marked Exhibit 14 for identification.) MR. WALKER: In the Henlo-Atherton Recorder ^ on the 10th of April and that Affidavit will be Number 15. '(Thereupon, a one-page document entitled Affidavit of Publication dated April 10, 1979, was marked Exhibit 15 for identification.) MR. WALKER: The San Mateo Times on the 12th of April, 1979. and that Affidavit will be Number 16. iA 'EJ'ilck fi ^Associates CERTIFIED SHORTHAND REPORTERS MS NO. FIHST ST.. SAM JOSE. CA 9"2 TELEPHONE: <<»» B9B-4U99 'tJ'Uci 6 Associates CERTIFIED SHORTHAND REPORTERS SEC NO. FIRST ST., SAN JOSE. CA 95112 TELEPHONE: <«»J B98-08M 28 ------- MR. WALKER: In the Valley Journal on the llth of April, and that Affidavit will be Number 17. (T.,,.i cupon, a one-page document entitled Proof of Publication dated April 11, 197». was marked Exhibit 17 for Identification.) MR. WALKER: In the San Francisco Chronicle on the 12th of April and that Affidavit will be Number 18. (Thereupon, a one-page document entitled Declaration of Publication dated April 13, 1979, was marked Exhibit 18 for identification.) MR. WALKER: 1 have also a press release that was issued by the Environmental Protection Agency and to keep the record complete, that will be Exhibit 19. (Thereupon, a one-page document entitled EPA Environmental Hews. For Immediate Release, Where Should All the Wastewater Go, was marked Exhibit 19 for identification.) MR. WALKER: And there was a notice of this given by mailing to a large mailing l.ist of interested persons, the publication is dated May 30, 1975? MR. HELPHINGSTINE: This was a Notice of Intent to prepare it. MR. WALKER: Oh. excuse me, this was the Notice of Intent when we were first starting on this journey. And that will be Exhibit Number 20. (Thereupon, a two-page document entitled To All Interested Agencies, Public Groups and Concerned Individuals dated May 30, 1975, was marked Exhibit 20 for identification MR. WALKER: Thank you for bearing with me on 1 2 J 4 5 6 7 8 9 10 11 12 15 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10 that. Now we have a procedure for the Environmental protection Agency that we use in conducting public hearings, and in this procedure we take people more or less In the order in which they have registered. There were certain cards that look like this (indicating) as you came in the door and you 'may have been asked to sign a registration card. If you wish to make a statement, you were asked to check the box. I have several cards here of people who have checked the boxes, stating that they want to make a statement. Now, in our procedure we ordinarily call on elected officials first. Thereafter we call on people in different groups; Interested public citizens, people representing public agencies, people representing Chambers of Commerce, people representing industries and we rotate the call among those various groups. However, this evening, since we don't have many requests for people to be heard, I propose to take them just in the order in which the cards were received. If you would like to make a statement, and I do not have your card, I suggest that you go to the young lady at the door, just outside the door, and ask to have a card checked with the box that says you would like to make a statement. Now, what is goiflg to happen next? After the conclusion of this oral part of the public hearing, the Environmental Protection Agency will receive public comment as I said, for three weeks, and that would be until the- fi (Associates ut. CERTIFIED SHORTHAND RERORTEPS SM HO. FIRST ST.. SAN JOSE. CA «! 1 2 TELEPHONE: MM! M34«* & (Associate CERTIFIED SHOATHANO REPORTERS SMNO. FIRST SI.. S«N JOSE. C* 911! TELEPHONE: («» 29 ------- 12 l 6th of June. Any comments that people want to make 2 subsequent to this oral'part of the hearing must be 3 received in the Environmental Protection Agency, 213 4 Fremont Street, San' Francisco, before the close of business 5 on the 6th of June. At that time our records will be 6 closed. • 7 As 1 earlier mentioned, if the' comments are 8 in amplitude or supplemental to the statements made 9 tonight, there will be no further part of our public 10 hearing. The record will be closed and it wiH be reviewed 11 a staff recommendation will be made, and that will be 12 made to the Regional Administrator who will approve 13 or disapprove or take some other action with respect to 14 the environmental impact statements, so .far as federal 15 action is concerned. 16 Other action may be taken by the South Bay 17 Dischargers Authority, and there will be other comments 18 on that a little later on. 19 How, I don't know whether everybody knows who 20 ' all the people are here. Mr; Mayor, would you like to 21 introduce the people? I have some notes here but you 22 know them better than I. 23 MR. GISSLER: All right, from the City of 24 palo Alto, CounciImember Al Henderson. From the City 25 of San Jose, Mayor Janet Gray Hayes. On my far left 26 from the City of San Jose, Councilman Jerry Estruth. 27 And next to him from the City of Sunnyvale, still mayor? 28 MR. GUNN: Yes. i 2 3 4 5 6 7 8 9 10 II 12 13 U 15 16 17 18 19 20 21 22 23 24 21 26 27 20 MR. GISSLER: Mayor Gil Gunn. I guess you will be changing soon, I guess. MR. WALKER: Thank you very much. Mr. Helphingstine has a brief statement to make about this, and then we will call on the consultants and then we will be calling on the public: Mr. Helphingstine? MR. HELPHINGSTINE: Good evening, ladies and gentlemen. My name is Bill Helphingstine. I am the Project Officer for the Environmental Protection Agency. The Environmental Protection Agency 'and the South Bay Dischargers Authority have jointly prepared this Environmental Impact Statement and Report in order to disclose the impacts of the proposed project alternatives for the construction of treated wastewater disposal facilities to serve the greater Santa Clara County area. I would like to take this opportunity to mention the water quality problem in south San Francisco Bay and to summarize the purpose of this project and the Draft Environmental Impact Statement and Report. Waste load accumulations over the years have caused depression of dissolved oxygen concentrations, high concentrations of toxic heavy metals in sediments, and localized problems of fish kills and waterfowl botulism outbreaks. Lack of freshwater inflow during the dry season and subsequent flushing of the estuary have further aggravated these conditions. The purpose of this project is to provide a treated wastewater disposal system for the San Jose/ «A 6 Associates CEMTIREO SHORTHAND REPORTERS 586 NO. FIRST ST., SAN JOSE. CA9S112 TELEPHONE: (" CERTIFIED SHORTHAND REPORTERS SB6NO. FIRSTST., SAN JOSE, CA9S112 TELEPHONE: HM; mg-OtM 30 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LL Santa Clara, Sunnyvale and Palo Alto wastewater treatment plants. These plants presently discharge their treated effluents Into sloughs or a drainage canal which drain into south San Francisco Bay. The treated wastewater disposal program was initiated because the California Water Quality Control Board's Basic Plan prohibits the discharge of any plant effluents into South San Francisco Bay below the Dumbarton Bridge. , The Environmental impact Statement and Report has been prepared because significant impacts could result from the implementation of several of the project alternatives. These alternatives include wastewater reclamation, further advanced treatment, a long outfall extending to north of the Dumbarton Bridge. By the way, you notice there are some large maps to the left, my left, by the seal. Those indicate some of the major routes considered in this Environmental Impact Report and Statement. The other alternatives considered would be •individual outfalls to the South Bay and a no-project alternative. Environmental impacts of the basin plan alternative would include disruption of rare and endangered species; the salt marsh harvest mouse, and the California clapper rail1; and also possible improve- ments in the beneficial uses of the South Bay, such as fishing and recreation. These alternatives range in estimated cost from $86 million for a sixteen mile l 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 2} 26 27 • 28 pipeline and outfall to discharge effluent approximately one mile north of the Dumbarton Bridge, to $323 million for a water reclamation and reuse alternative. And these costs are based on a couple of years ago. The construction costs of either of these alternatives would now be higher to incorporate the inflation which has been going on during the last several years and the next several years it would take to actually construct to get those alternatives. The project alternative has not been selected. However, the Environmental Protection Agency and the South Bay Dischargers Authority recommend a no project alternative because the degree to which increased dilution resulting from a discharge north of the Dumbarton Bridge will mitigate the adverse impacts of toxicants on the biota of the South Bay cannot be predicted. i Modeling studies have not shown that a substantial Improvement in dissolved oxygen concentrations would result if the discharge were moved north of the Dumbarton Bridge. The viability of future full reclamation is being investigated in the Regional Wastewater Reclamation Study. Such an alternative, if It proves to be feasible, would meet the planning requirements of the San Francisco Bay Basin Plan. The Environmental Protection Agency and the South Bay Dischargers Authority recognize that compre- hensive receiving water monitoring will-be needed to CERTIFIEDSHOKTHiNO HEPOBTf US set NO. FIRST ST.. S»N JOSE, c« ssi 12 CERTIFIED SHORTHAND REPOPTERS 598 NO. FIRST ST., SN JOSE. C 9S1,2 TELEPHONE: H0819P8-OBW 31 ------- ^____ IS 1 to document the impacts of wastewater discharges in the 2 South Bay. This decision Is being recommended based on 3 present knowledge. However, if the final selection is 4 a no project alternative, we will continue to evaluate 5 results of the monitoring program and will reconsider 6 our selection, if appropriate. 7 that concludes my comments. 8 MR. WALKER: Thank you, Mr. Helphingstine. 9 1 will say that the maps on the wall that have been 10 referred to in his statement are, I am told, reproductions U of maps or diagrams that earlier appeared in the Draft 12 Environmental Impact Statement Report. For that reason lj they will not be marked as exhibits or incorporated in U the record physically. They are already there in another J5 form. 16 Now, the next person 1 will call on to explain 17 the project here is Dr. Carol Harper of Bechtel National, 18 Incorporated. 1 believe you were representing the con- 19 sultants on this matter. 20 DR. HARPER: Mr. Chairman, I am with the South 21 Bay Dischargers, my name is Carol Harper and I am the 22 Project Engineer for the Environmental Impact Statement 23 for Bechtel National, Inc., and we are the consulting 24 firm for the South Bay Dischargers Authority on this » project. 26 My purpose tonight is to present a summary of 27 the Draft Impact Report and Statement and the associated 28 work that contributed to it. I 2 J 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The South Bay Dischargers Authority has a service area of Santa Clara County and for the most part encompasses the cities of San Jose, Santa Clara, Sunnyvale and Palo Alto and their tributary agencies. These facilities in 1973 and '74 began work on advanced waste treatment, for their three treatment plants. This Environmental Impact Statement-Environmental Impact Report is concerned solely with disposal alternatives for that advanced treated wastewater. At any time the estimates for the quantities of this disposed wastewater are about 370 million gallons a day in the year 1995. And that's a peak flow. The alternatives are described in detail, a number of alternatives are described in detail in the Environmental Impact Statement and Report which has been put into the record. In order to provide a comparative analysis in this report so a decision can be made, a number of field studies were initiated. I would like to list these off and indicate who did these studies. The first one was a detailed study on sediment quality and engineering bearing strength of the Bay muds by R.C. Harlan and Associates. There were two separate studies by Mr. Harlan. The second study was a surface archaeological survey by Archaeological Co-nsulting and Research Services, Inc., of Mill Valley. The third was a series of water quality and biological surveys by E.H. Smith and Associates of 6 [.Associates CERTIFIED SHORTHAND fl€ PORTE AS 586 NO. FIRS'! ST.. SAN JOSE. CA Ml 12 TELEPHONE: t«M) 99«-<>aM jiifi WS-06) 32 ------- . 17 Bodega Bay. The fourth was a laboratory water quality survey by Pacific Environmental Laboratory of Kennedy Engineering. The fifth was a water quality modeling study performed by Hydroscience, Inc. with offices in Hew Jersey and in Walnut Creek, California. In addition, a Technical Advisory Committee was formed consisting of representatives from thirty-four federal, state and local agencies. These individuals regularly net, reviewed draft material, commented on this material, provided data and also provided contacts with experts in the area across the country as well as in California. I will briefly refer to some of the maps on the wall. It might be easier for you to look at them during the recess. But all of the alternatives for disposal that were considered by us were located in.what is considered the Bay Lands of San Francisco Bay. - The dominant feature of the area is the San Francisco Bay, south of Dumbarton Bridge and the associated marshes, mud flats and open waters. In the past hundred years much of the marsh and mud flat area has been filled and has undergone extensive urban, industrial and govern^ mental development. But the unique qualities of the bay continue to dominate the characteristics of the area.and many natural areas persist in parks and in open space surrounding the west side of South San Francisco Bay. 1 2 3 4 5 6 7 8 9 10 a 12 1} 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18 In these areas have been found as many as five endangered species and a number of threatened plants and animals on the federal and state listings. At both the cities of San Jose and Palo Alto the wastewater discharges resulted in the creation of a fresh water aquatic habitat, In particular, wading birds, such as herons and egrets, which are considered species of concern by official wildlife services of the United States government and much fresh water vegetation are now common in Artesian Slough which is the discharge location for the City of San Jose and the City of Santa Clara. This slough is within the National Wildlife „,!. refuge system and ID eall/* k 1' In. the South San Francisco Bay National Wotoi- life Refuge. And the fresh water communities contribute to the diversity within that wildlife refuge. , In the years since World har II, as I mentioned, the region has changed markedly from an agricultural center to an industrial center. And increases in population have accompanied this change and contributed to the degradation of water quality in the Bay such as Mr. Helphingstine has outlined. Other sources of degradation include reduction of flows to the South Bay by the damming, diking and channelizing of various natural waterways and by the filling of marshlands thereby reducing water surface area and restricting flows south. The Bay Water Quality Control Plan addressed the problem in South San Francisco Bay and recommended CERTIFIED SHORTHAND REPORTERS 566 NO FISSTST.. SAN JOSE. CA 95112 TELEPHONE: HC8t»-OeS9 CERTIFIED SHORTHAND REPORTERS M6 NO. FIRST ST.. SAN JOSE. C 95112 TELEPHONE: H081M8.MM 33 ------- 19 I increasing treatment to the secondary level and by limiting 2 wastewater discharges to areas with good mixing and 3 dilution potential. 4 In the Basin Plan it was recommended that this 5 area be north of Dumbarton Bridge. The South Bay 6 Dischargers has complied with the secondary treatment 7 limit but they still have not determined the appropriate 6 disposal system to meet the secondary restriction. And 9 that, as I mentioned also, is the purpose of this report. 10 ' In the study there were five alternatives 11 which were thought to be cost-effective responses to the 12 state and federal requirements. These were: No further !3 action,'which constitutes continuing to dispose at the 14 present treatment plant sites, Artesian Slough for San 15 Jose-Santa Clara, Guadalupe Slough for Sunnyvale, and '6 a discharge canal that comes out of the Palo Alto Treat- 17 ment Plant near Mayfield Slough. 18 The second alternative is termed "The Basin 19 Plan Alternative" in the EIS. This is the plan specified 20 in the study as a disposal pipeline to the San Francisco 21 Bay north of Dumbarton Bridge to the deep water area. 22 The third alternative was individual deepwater 23 outfalls. These will be outfalls to deep water south of 24 Dumbarton Bridge and would consist of two individual 25 pipelines, one from the City of Palo Alto and the other 26 a joint Santa Clara-San Jose-Sunnyvale pipeline. 27 The fourth alternative would be to further ZB upgrade treatment. In this case it would "include treatment 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ?D beyond the present wastewater treatment and 1 will go into that in a little more detail later. And the disposal would continue at site much like in no further action. In the fifth alternative reclamation and reuse where wastewater would be further treated, or reclaimed and then distributed on a large scale or on several small scale projects to various users throughout the service area or even outside the service area for the South Bay Dischargers. As Mr. Helphingstine has mentioned, no project alternative has been selected but the recommendation has been towards a no further action alternative. I can go into more detail on what the no further action and the other alternatives consist of and 1 can tell you what the impacts were determined to be in the EIS, First, the no further action alternative requires no reconstruction and imposes no increased Operational costs on the dischargers or their service areas. While wastewater would continue to be discharged to the tributaries of the South Bay, contributing to oxygen demand and the potential build-up of toxic substances, the use of advanced waste treatment at each plant will reduce these loadings from past levels. In addition, mathematical modeling has shown that while the quantity of wastewater flowing through the tributaries as a result of discharge actually contributes to the flushing, in South Bay, reducing the effect of pollutants at the discharge site and distributing it over the open CERTIFIED SHORTHAND REPORTERS 186NO. FIRST ST , SAX JOSE. C» 95' 12 TELEPHONE: ('OBI 96B-OB99 CERTIFIED SHORTHAND REPCflTER£ MS NO. FIRST ST.. S«N JOSE, C* «Stt2 TELEPHONE: ««>OTB MM 34 ------- 1 water portion of the Bay. This flushing reduces the 2 net effect of the viater discharge by keeping oxygen 3 levels higher than might occur if there were no flews 4 in the tributaries. 5 The Basin Plan Alternative consists of a 6 nominal ten foot inside diameter concrete pipe connecting 7 the three treatment plants and associated pumping 8 stations and running along one of several alternatives tc 9 a discharge point about one mile north of Dumbarton Bridge 10 in a ship channel, in the deep ship channel.. Located 11 entirely within the Baylands, construction of this 12 sixteen mile long pipeline would alter the topography, 13 disrupt biological systems, temporarily degrade air and 14 water quality and increase noise an«S traffic levels 15 locally. 16 The operation of tlie system would remove the . 17 wastewater discharge fro;n the sloughs and the South Bay, IS decreasing the contribution of pollutants' to that area, 19 while reducing the inflow to the Soimth Bay in terms of 20 total water input. 21 The mathematical model indicates that water 22 quality would improve in open water slightly but 23 tributaries south of the Dumbarton Bridge would continue 24 to suffer oxygen depletion due to the loss of flashing. 25 The capital cost of the system was estimated ( 26 to be about $86 million in 1979 dollars. This was ^ 8 27 assuming a midpoint construction of 19/0 and tha first ?8 year operation of 1981. As was mentioned earlier, the , i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 study was started some time ago and this cost would have to be updated. The first year operating costs in 1981 was estimated to be about $280,000 and the majority of this cost would be consumption of energy, pumping station estimated to be about 7.9 million kilowatt-hours in the year 1985. This is about forty-nine hundred barrels of oil consumed. The third alternative, individual deepwater outfalls consists of a joint San Jose/Santa Clara and Sunnyvale disposal line running to a location off Coyote Point and a separate disposal line for Palo Alto, dis- charging to the main channel off of their present discharge location. The construction of this alternative woul'd have effects similar to the Basin Plan Alternative although more extensive effects would occur in the water itself, on the marshes and the mud flats and in the open water habitat and less effects would-occur on dry land. Operation of this alternative would remove pollutant discharges from the tributaries but not from the South Bay and improvement in open waters and the tributaries would be no different than is in the Basin Plan Alternative. The capital investment is estimated to be about $69 million in 1979 dollars. This is about 20 million less than the Basic Plan Alternative with the first year cost approximately the same, $280,000. The fourth alternative, Upgraded Treatment, 9"i(cl> 6 CERTIFIED SHORTH AND REPOflieflS 5M NO, FIBSI SI. SAN JOSE r.A 95112 TCUPHONE: «0») WMSW 35 ------- 23^ consists of the addition of carbon absorption to reduce toxicity and oxygen demands and to breakpoint chlorination for residual ammonia removal at the Santa Clara/San Jose plant only. Each treatment plant would continue to dispose at the present locations as in the No Further Action Alternative and construction impacts would be limited to the San Jose/Santa Clara plant site. Operation of such a facility would improve water quality in both open water and tributaries with the amount of improvements small compared to the increased consumption of chemicals and energy typical of such plants. In addition, violations of both dissolved oxygen standards and toxicity guidelines would still occur in the tributaries during periods of stress,such as high water temperatures or discharges due to the canning season. The capital cost is estimated to be approxi- mately $120 million in 1979 dollars, or about $40 million more than the Basin Plan Alternative and operating cost were not estimated, but are expected to be greater than the Basin Plan Alternative due to increased energy consumption. • The fifth alternative is Reclamation and Reuse and was considered both as an alternative to disposal, that is we considered using all of the pro- jected wastewater, and as a- supplement to any other disposal alternative whereas only a portion of the waste- water would be reclaimed and the remainder disposed through a Bay disposal system. I 2 3 4 5 6 7 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 24 Since the technology is available to reclaim wastewater for any use excepting drinking water, because of the restrictions of state law and federal policy, the cost of reclamation and the existence of an available market for the water become the limiting factors in this alternative. A number of studies over the past six years have shown that the cost of reclaiming water is more, both in terms of energy consumption and total dollars than 1s the cost of treating for disposal only. Reclamation treatment would resemble a freighted treatment and you would still have to figure out some way to get the water to market or to a disposal site, so you are adding a total treatment to a disposal system. If the full capital and operating cost of developing the new water supply, for example, importing water from the Sierra mountains to the Bay Area, were considered, reclamation for most users is competitive. But we say here the true cost, the full cost, not the subsidized cost of developing the water supplies. And thirdly, markets in the South Bay are limited to Industrial use, agricultural irrigation, open space irrigation and recreational use such as ponds or parks. And a maximum amount of water which could be consumed in these uses is constrained by the seasonal variation in the Bay area, the needs are reduced to nearly zero in the wintertime for most users and are maximized during the hot summer months. (A 0i(cli fi (Associates CERTIFIED SHORTHAND REPORTERS S06NO. FIRST ST., SAN JOSE. CA 95112 TELEPHONE: (>M»M-OM< 9"Uefi 8 CERTIFIED SHORTHAND REPORTERS 6M NO. FIRST ST.. SAN JOSE, CO 8511 J TELEPHONE; (4M) M8-08W 36 ------- I A 67 HGD facility would supply the majority of 2 the identified markets in Santa Clara County but would 3 only reduce the disposal requirements by approximately 4 twenty percent. In addition, the water would only be 5 needed during the summer dry season and a full disposal £ system would still be required. In order to increase the 7 market demands, the reclaimed water would have to be B transported out of the San Jose marketing area. And this 9 is the subject of the Regional Study .that is now being 10 participated in by EPA. II The construction impacts of the Reclamation 12 Alternative would include the alterations resulting from 13 construction of a transport and distribution pipeline, H from wherever the reclamation plant were built to where- 15 ever the water was being used, as well as construction 16 on site at the treatment plant chosen. And for this n ' project we assumed, San Jose/Santa Clara because it was 18 nearer a central market in Santa Clara County. Operation 19 of this alternative removed a portion of the discharge 20 from the Bay for a portion of the year, and solid waste 21 generation would increase and energy and chemical 22 consumption would increase. Energies and chemical 23 consumption for the purposes of treating the water, 24 energy for transporting the water and solid waste sludges 25 in various chemical wastes are produced in removing the 26 materials from the reclaimed water. 27 The capital cost would vary with the treatment 28 and transport system chosen, but has been estimated to be 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 as much as $328 million or approximately four times the Basin Plan Alternative. Operating costs could be as much as for the upgraded treatment and disposal cost would not be significantly reduced. Export and distribution costs could be as much as five to fifteen times the Basin Plan operating costs depending upon the market site, and that means the distance the water has to be transported. That's all I have to say. MR, WALKER: Thank you, Dr. Harper. I'm sure that the County will make a considerable effort to summarize the four volumes in your statements. We appreciate that. Now we are ready to hear from the public. Pursuant to our announced program we will first hear from Mr. Rod Diridon, Supervisor for the County of Santa Clara, Supervisor. MR. DIRIDON: Mr. Walker, I have a presentation from the Board of Supervisors by their consent and unanimous vote. I am also presenting the statement and will be assisted in doing so by Steve Goodman of San Jose District Four, also adopted by unanimous vote, and resolutions from the City of Los Gates and Campbell, each having been adopted by unanimous vote by those communities. Each of these resolutions endorses the No Further Action Alternative presented by Or. Harper just concluded. And the reasons for that conclusion, I think, are very well summarized in the EIR as pertaining to that alternative. I .will mention briefly.a couple of those (A. "STitct S ^Associates CERTIFIED SHORTHAND REPORTERS 586 NO. FIRST ST.. SAN JOSE. CA 99112 TELEPHONE: 4081 8M-OB99 (A 'tfifck & ^Associates CERTIFIED SHORTHAND REPORTERS ue NO. F:RST ST.. SAN JOSE. CA 9511 z TELEPHONE: «08H»a-08M 37 ------- that we stressed in the debate at the various -bodies that took action as I am describing the action to yoj today. First is in regard to environmental impact. It 1s the conclusion of the County Health Department, the County Planning Department that the environmental impact of attempting to construct this long outflow would be much more severe than any impact that could occur from continuing the discharge procedures currently pursued ,and recognizing the effluent .has been upgraded now to tertiary water and does have a marked impact, a point on which I would like to expound in a moment. Therefore, we are opting for a course of action that would minimize the environmental impact. And both in terms of water quality, degradation and in terms of the natural environment destruction that would occur in sanitation and disrupting of the wildlife in the area. The next point is in regard to cost. Sanitation District Four alone has $1.1 million in reserve for this project. If that $1.1 million were freed and could be given back to the users of sanitation services in District Four, which includes the cities, at least the majority of the area encompassed by the cities of Saratoga, Honte Sereno, Los Gatos, Campbell and the un- incorporated area adjacent to, some portions of West San Jose, the reduction in fee would be about forty-five cents per month per user, which is not an Insignificant reduction. That's an alternative that we would like to 1 2 } 4 5 6 7 8 9 10 11 12 1} U 1} 16 17 18 19 20 21 22 23 24 25 26 27 28 28 pursue. I understand that the City of San Jose and the City of Santa Clara both have reserves of some amount, also awaiting decision on this project that could be like- wise freed and used for another purpose, or returned to the taxpayers and users that accumulated the fees originally. I would like to comment now briefly on the sequence that we would encourage in terms of the action being proposed. There is a significant amount of federal funds that have been ear-marked for this project. The County of Santa Clara and Sanitation District Four have both commented frequently on the potential of using a portion of those funds or all of those funds for something that may look like your alternative number five but may not be in the detail of your 'alternative number five. We would hope that in the action ta'ken to abandon the project the funds that have been encumbered by that project would not be released until the potential of using some or all of those funds for an additional reclamation and reuse possibility would be explored. And that procedure I think would be known better by you than by me, the red tape on the federal Is something to behold. I had a chance to look at It last week and I don't want to look at it again for a while. That would conclude my statement. I would be happy to answer any questions and I do have a copy of the resolution, except for the County's resolution, which was 6 ^Associates CERTIFIED SHORTHAND REPORTERS 5H NO. FIRST ST. SAN JOSE. CA 95112 TELEPHONE- ;«Dt>«S-<»9» (A ^Ucli 6 Associates CERTIFIED SHORTHANO RECOHTErtS SW "O FIRST ST.. SAN JOSE. CA »511» TEICPHONE: «M) Stt-tUM 38 ------- 29 1 adopted only yesterday and that would be submitted, ir 2 permissable; It would be offered quickly. 3 MR. WALKER: Than you. Yes, I would like to 4 have copies of the references you referred to and they 5 will be marked as exhibits. That is an interesting 6 thought about the federal funds already ear-marked for 7 this being held. 1 am not at all sure how that can be 8 done. I won't want to hold out a lot of hope to you 9 because that is a pretty sticky thing to do. We are 10 rather rigidly restricted about what we can do and not do II with the current monies. 12 • As you know there is an enormous amount of 13 ' complicated recommendations on that subject but we will 14 certainly address it and see what can be done. 13 MR. DIRIDON: Let me stress a point. We are 16 growing in this valley at an unprecedented rate both in 17 terms of population expansion but less so than in terms IB of industrial expansion. The water that-you'are talking 19 about now pumping out past the Dumbarton narrows and 20 dumping into the Bay has marketability, particularly in 21 terms of agricultural and industrial use. 22 It would seem very logical, maybe a little too 23 logical for government, but very logical if we would take 24 that water and instead of pumping it out into the Bay, 25 use it for washing busses, which we intend to use it in 26 the new county bus yard, use it or agricultural purposes 27 where possible, use it for the other kinds of cleansing . 28 purposes where they don't come in contact with human being 1 2 3 4 5 6 7 B 9 10 11 12 13 H 15 16 17 18 19 20 21 22 23 24 25 26 27 28 30 for the industry that is blossoming dire.ctly adjacent to this area along the peninsula. And if there is a way to accomplish that, 1 know this Board in its good judgment, will attempt to. We are expending literally over maybe hundreds of millions certainly over a hundred million dollars to bring water Into this valley right now, in terms of the San Felipe Project. It seems very peculiar that we would spend a hundred million dollars plus for the various aspects of that project and turn right around and spend another significant number of millions of dollars and pump similar water not quite so pure-but similar water out the Bay. And I would ask your good judgment in abolishing the project arid attempting to pursue some kind of reclamation and recycling device that might be possible that we can retain some of the grant funds. MR. WALKER: We will certainly undertake to pursue it but as you know when you work for a large organization-there are many complex rules and we certainly don't get to make them sometimes. MR. 01RIOON: I understand. Thank you. IW might be that Steve GoodSUf'wil 1 have a comment from ff District Four. MR. GOODW+N: Steve Goodman, Santa Clara County/I District Four. We did submit in the mail an accompanying resolution that was referre'd to by Supervisor Diridon, a series of comments, and unless you felt it was A. "rjifeli 6 ^Ass CERTIFIED SHORTHAND REPORTERS tit HO. FIRST ST., S»N JOSE. C» 9511J TELEPHONE: I«M)SM-W99 9"itcli ft Cf BTIFIEO SHORTHAND REPORTERS MS NO. f IRST SI . SAN JOSE, C« 9S1I2 TELEPHONE: «MIS»5-G»99 39 ------- 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 appropriate to read them Into the record, I would let our written communication stand, Mr. Walker. MR. WALKER: You certainly may let the written communication stand. They will be given every bit as much consideration as the oral comments. Sometimes 1t is even better if we haven't been involved in your format. MR. GOODMAN: He will rest with that. MR. WALKER: Thank you. For the purposes of the record, I have marked the resolution of the Town of Los Gates as Exhibit 21 and the resolution of the City of Campbell as Exhibit 22. (Thereupon, the aforementioned documents were marked Exhibits 21 and 22 respectively for identifica- tion.) MR. WALKER: Your name, sir? MR. FERRARO: Pat Ferraro. Is that who you just called? HR. WALKER: No, my next person to call, 1 will call on you soon, is Dolowries Wulfhorst, Council- member from the City of Sunnyvale. MS. WULFHORST: Thank you, Mr. Chairman. The City of Sunnyvale, the Council met last night in our regular meeting and adopted a resolution, t will read it and present it to you. I will read it but I »ill present the formal parts to you now verbally. The City Council of the City of Sunnyvale reviewed and considered the draft of the EIR/E1S; Now, therefore, the City Council finds that project alternative number two. Ho Further Action of the 1 2 3 4 5 ( 7 8 9 10 11 12 13 U 15 16 17 18 19 20 21 22 2} 24 25 26 27 28 . 32 draft of the EIR/EIS for the South Bay Dischargers Authority Treated Wastewater Disposal Program is superior to all other alternatives for the following reasons: During th'e dry season* the only appreciable amount of freshwater discharged to the sloughs and South Bay 1s the highly treated effluent from the water pollution control plants in Sunnyvale, Palo Alto and San Jose; without this discharge the freshwater marshes would dry up, adversely affecting the unique biological environment that currently exists. Transportation of the effluent by pipeline would have little effect on solving the deficient dissolved oxygen levels in the sloughs and would increase salinity. The pumping station for a pipeline would utilize large amounts of energy that is already in short supply. The degree to wh.ich Increased dilution resulting from a discharge north of the Dumbarton Bridge will mitigate the adverse impacts of toxicants on the biota of the South Bay cannot be predicted. Modeling studies have not shown that a sub- stantial improvement In dissolved oxygen concentrations would result If the discharge were moved north of the Dumbarton Bridge. The viability of future full reclamation Is being Investigated in the Regional Wastewater Reclamation Study. Should such an alternative prove to be feasible, fi (Associates CERTIFIED SHORTHAND HE PORTERS 9MNO. FIRST ST.. SAN JOSE, CAti5t> TELEPKOKE: (tt» VJt-ttm CERTIFIED SHORTHAND REPORTERS 9MNO. FIRSTS!., SAN JOSE. CAM1I2 TELEPHONE: (W»\|9 40 ------- -_ . : 33 1 It would meet the planning requirements of the 'San Fran- 2 Cisco Basin Plan, 3 The City Council recommends to the SBDA and 4 the EPA that -Project Alternative Number 2, No Further 5 Action of the draft and 'urges them to adopt this 6 alternative. 7 This was adopted by all members of the City 8 Council and 1 will hand you a copy of it. 9 MR. WALKER: Thank you. Me will mark a copy 10 of that resolution as Exhibit'23 for the purposes of this 11 record. ' 12 " MS. WULFHORST: Thank you. 13 MR. WALKER: Thank you. 14 (Thereupon, a three-page'document entitled Resolution Ho. 232-79 15 dated'May 15th, 1979, by the City Council of Sunnyvale was marked 16 Exhibit 23 for identification.) 17 MR. WALKER: The next card that I had in the 18 order that we previously announced is Mr. Ronald R. 19 James, Chief Executive Officer of the San Jose Chamber 20 of Commerce. 21 MR. JAMES: Thank you, Mr. Walker. The San 22 Jose Chamber of Commerce supports the recommendation of 2? no project alternative; and from our standpoint, the 24 no project alternative makes a great deal of sense. 25 It appears that there wouTd really be no 26 benefits from the construction of the super sewer which 27 could justify the expenditure of some ninety to a hundred 28 mill ion dollars. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 34 In early 1970 the decision was to ban discharge of sewage into the South Bay and at "that time it looked like a good decision, because water quality was poor. How, however, the water quality levels have improved dramatically and except for the runoff the effluent from the San Jose plant frankly is probably the only steady source of freshwater entering the Bay in this particular area. We believe that the improved water quality not only makes the no project alternative the only course of action, but also lends considerable'logic to lifting the Water quality Control Board's discharge ban . all together. As long as the discharge ban exists", the specter' of a super sewer or its alternatives will still face us. Recycled water is projected to become a major source of water for industrial use within the next twenty years and a new study by the Santa Clara Valley Water District has .indicated that by 1990 valley industries, electronics, paper products and other manufacturing, could be using twenty .thousand acre feet of reclaimed wastewater per year. If this area is going to use a significant amount of reclaimed'wastewater, building a super sewer to transport that.same water out of the area.makes no sense at all. .Finally, these same . industries, along with the canning industry which-employs more than some thirteen thousand people, have been hit hard by increases in sewer 9"tlcl CERTIFIED SHORTHAND REPORTERS MS NO. FIRST ST.. SAN JOS6. CA 9-il IJ TELEPHONE: («M> 9M-M99 CERTIFIED SHORTHAND REPORTERS 586 NO. FIRST ST., SAN JOSE. CA9SM2 TELEPHONE: «Mt«9-0«M 41 ------- 35_ service charges over the past few years In order to pay for the increased water quality that we now all enjoy. At that time those treatment processes were justified in our opinion. However, at this point in time they are not justified and any new rate increases that this investment would bring would have a negative impact on the canning industry in particular. And that industry is particularly important in this area to maintain a balance in our economy, and the canners should be encouraged in every way to remain in the valley. Thank you. MR. WALKER: Thank you, sir. The next card in order of the proceedings previously announced would be Mr. Leo F. Cournoyer, Santa Clara Valley Water District. MR. COURNOYER: My narae is Leo Cournoyer. I am with the Santa Clara Valley Water District. The District has prepared written comments on the report and these comments are in the mail to EPA. At this time 1 would like to simply briefly summarize the main point that we made in our written comments. The alternative that was recommended by EPA and the South Bay Dischargers in their EIS/E1R 1s acceptable on the basis that the South Bay Dischargers agree, one, that while the •dischargers are being made, that significant and extensive monitoring take place so that any significant adverse impacts on the water quality of the South Bay be measured. 1 2 3 4 5 6 7 6 9 10 n 12 13 14 15 16 17 16 19 20 21 22 2} 24 25 26 27 28 Two, that if it is found that, the discharges do cause a significant adverse impact on the water quality of the South Bay, then construction of some other alternative be considered. The third item is that if wastewater reclamation is found feasible, then the use of the water, we strongly recommend that it be strongly considered for reclamation. As I mentioned, these are really a summary of our comments, as I mentioned, and others are in the mail to the EPA. MR. WALKER: Thank you, sir. Mr. Jim Quintal, Santa Clara County Canners Association. HR. QUINTAL: Mr. Walker and members of the South Bay Dischargers Authority, my name is Jim Quintal and I am here tonight to present a statement that has been prepared by the Santa Clara County Canners Association It is in the mail and you people will be receiving it shortly. Our association is a non-profit organization formed forty years ago to provide a forum for discussion of problems and opportunities common to our industry. Currently most of our activities center around the ever expanding load of federal, state and local regulations that adversely effect our capacity to efficiently produce food products. Our association represents eight companies operating fourteen canneries in the Santa Clara Valley, CERTIFIED SHORTHAND REPORTERS Set NO. FIRST ST.. SAN JOSE. CA 95112 TELEPHONE: («tt\| »98-0«M CERTIFIED SHORTHAND REPORTERS SMNO. FIRST ST., SAN JOSE. CA 9S'1Z TELEPHONE: (40U998-OIU9 42 ------- 1 employing approximately twelve thousand people and having 2 a 1.4 billion dollar economic impact on Santa Clara County. 3 So there could be no confusion as to our 4 position, we will state at the outset that we are adamantly 5 opposed to the construction o.f a deep water outfall or 6 any other alternative being evaluated that would force the 7 South Bay into compliance with the State Water Quality B Control Boards resolution 74-73, which bans discharges 9 to the San Francisco Bay south of Dumbarton Bridge. It 10 is th.is resolution which needs evaluation not methods of 11 implementing ft. 12 The discharge ban in question was adopted by 23 the State Board five years ago and is responsible for 14 over 100 million dollars of advanced waste treatment 15 facilities being constructed In the cities of San Jose, 16 Sunnyvale and Palo Alto. Now we are being asked to 17 evaluate an additional 100 million dollars for a pipeline 18 or some other alternative to comply with an arbitrary '9 and 'capricious ruling. 20 The EPA, in order to further evaluate advance 21 waste treatment programs, commissioned the Vertex 22 Corporation of McLean, Virginia, to prepare a report on 23 quote "An Analysis of Planning for Advanced Wastewater 24 Treatment." The report, published in July of 1977, 25 covers the planning that went into decisions to construct 26 advanced wastewater treatment facilities in six areas of 27 the United States, of which San Jose and Santa Clara 28 was one. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ; 38_ We quote from that report: "Costly pollution control projects are commonly built with almost no real knowledge of the waters that are to be protected by the generous investment in treatment facilities." Referring specifically to the South Bay, we quote further from the Vertex Report. "December, 1975, Hydroscience publishes another mathematical model. Like the last (February 1972), 1t is a mosaic of over- simplifications and guesswork." Further quotation, "When the earlier models showed that construction could solve a problem they were accepted at face value.'" However, when the 1975 model showed that no amount of construction would work. State officials began to examine the model for unwarranted assumptions, inadequate verification, and skimpy data. This belated discovery of weaknesses in mathematical models has been costly." "The San Francisco Bay Regional Water Quality Control Board could scarcely be expected to rejoice in Hydroscience's new conclusion; all previous planning for the south bay has been fundamentally wrong. For the first time the Board has critically examined a mathematical model for the South Bay and it is found wanting. Had the Regional Board been equally critical of the earlier models and studies, it might never have gotten into its present fix." Today we find ourselves saddled with advanced wastewater treatment facilities in San Jose that are in ic iA 6 «90-OSW 43 ------- themselves environmentally unsound due to their enormous electrical energy requirements. They consume wore than our fourteen canning factories combined. Much of what has occurred in the South Bay has taken on the appearance of a "Gold Rush" by consultants and municipalities for EPA funds. It is about time we- pause and evaluate the damages and possible benefits that have accrued from this uncoordinated and uncontrolled growth in waste treatment. The Food Preserving and Canning industry has long been a vital and important segment of Santa Clara County's business community. We have actively and supportively participated in the past wastewater programs in San Jose and Sunnyvale; primary treatment in 1956, secondary treatment in 1964 and expanded secondary treat- ment in 1974. In each of these cases the need was apparent and benefits well identified. However, with advanced waste treatment and now this potential "Super Sewer," the need and benefits have never been demonstrated or justified. ' - Thank you. MR. WALKER: Thank you. sir. I note that you have a copy of your remarks. Perhaps you and Mr. Cournoyer can furnish the reporter with a copy of them. stateJ , You pattul itGJ that we are to receive a copy in the mail to be included in the records, 'so I will'not make them exhibits at this time. However, I am sure it will assist the reporter in getting the record straight if you can furnish her with a copy. • • • . • 1 2 3 4 5 6 7 '8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2} 24 25 26 27 28 40 Mr. Cournoyer, would you he able to do the same? MR. COURNOYER: es. MR. WALKER: Thank you. The next card is Kr. Bruce E. Schoppe, S-c-h-o-p-p-e, Santa Clara Chamber of Commerce. •HR. SCHOPPE: Thank you, Mr. Walker. I am Bruce Schoppe, representing this evening the Santa Clara County Chamber of Commerce. We are opposed to the construction of the so-called super sewer and support the conclusion and position, rather, taken by EPA and the South Bay Dischargers Authority favoring the no further action alternative. Measured against the lull of this entire program, that is the improvement of water quality'in the South Bay, it is clear that construction of this pipeline 1s unnecessary. The advanced wastewater treatment capability now or soon to be in operation at all of the municipal treatment facilities involved will for all practical purposes achieve this goal. <• We view this as a situation in which the real benefits must be measured against the real cost. Mathematical modeling has shown that given these advance treatment plants, very little difference will result in South Bay water quality with the project versus no project. In fact, there may very wel-1 be a'net negative result due to the. removal of the fresh water flows from Artesian Slough and the other treatment plant outfalls. The Chamber of Commerce is, of course, an ------- i organization of business people and we recognize that 2 1f constructed, we will pay the costs of this project not 3 only through our businesses but also through our homes 4 and those of our employees. Quite honestly, we don't 5 need another source of additional cost in this inflationary 6 era. Especially when in our view it has been clearly 7 shown that the project is unnecessary. 8 Adoption of the no further action alternative 9 makes a great deal of sense to us, both environmentally 10 and economically. H MR. WALKER: Thank you, Mr. Schoppe. Do you 12 have a copy of your comments for the reporter? I) MR. SCHOPPE: No, I don't, but I will send H them to you. IS HR. WALKER: Thank you. I have neglected to 16 ask the members of the panel 1f they have any questions, v«/ue£4Ht: 17 but I hope they will not be^about purging Js/gi/vy. 18 MRS. HAYES: I am very pleased to say that I 19 was the one that initiated the name of super sewer and 20 I have heard it used here a number of times tonight and 21 I dubbed it that way a number of years ago and I still 22 think it is that way. 23 MR. WALKER: Thank you. It is always nice to 24 be right 1n your own time. 25 The next card that I have is Manny Pearl 26 representing himself. 27 MR. PEARL: I am Manny Pearl, representing 28 - myself, an interested citizen. From 1949 to May of ' 76 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 i; 16 17 18 19 20 21 22 23 24 25 26 27 28 42 was the Santa Clara County Public Health Engineer, and until I retired I was the member of the Advisory Committee that was referred to. I strongly recommend the no further action alternative. HR. WALKER: Thank you, sir. Mr. Merle Brendler. Excuse we. MR. BRENDLER: Mr. Chairman, members of the Board, just for the record, it 1s Mrs. Merle Brendler, I am here tonight to represent the Sunnyvale Chamber of Commerce. I serve on their Board of Directors as Vice President for Governmental Affairs. This is their message and the thoughts they wanted me to convey to you. The Board of Directors of the Sunnyvale Chamber of Commerce at their Executive Committee Meeting of May 8, 1978, and their full Board Meeting of May 15, 1979, unanimously voted to urge that no action beyond currently approved improvements at treatment plants be taken and that the three Santa Clara County treatment plants continue to discharge treated effluent into the South Bay. This position is based on the following key considerations, there are three of them: Number one, actions taken or being taken by the Cities of San Jose, Santa Clara, Sunnyvale and Palo Alto are proving to be highly successful in imp/oving the water quality of the South Bay. It 1s reasonable under these circumstances to defer action on the super sewer CERTIFIED SHORTHAND REPORTERS 586 NO. FIRST ST., SAN JOSE, CA 951'2 TELEPHONE: 1 ------- 1 project, monitor the rate of improvement and subsequently 2 take corrective steps, if necessary. J Number two, given the current and continuing 4 improvement of water quality, the fresh water marshes in 5 the South Bay can be retained and the undesirable 6 transition to salt water marshes and its adverse effect 7 upon existing vegetation and wildlife will be avoided. 8 Number three, the investments made and being '9 made in the wastewater treatment plants of South Bay W cities are proving to be cost effective thus avoiding the 11 cost of constructing and operating the super sewer project. 12 The estimated $86 million for construction, the $320,000 13 annual operating costs and significant energy demands H can all be saved. 15 In conclusion, the Sunnyvale Chamber of 16 • Commerce urges alternative two of the Draft Environmental 17 Impact Report and Statement, Treated Wastewater Disposal 18 Program dated September 1978 be adopted and that no 19 further action be taken at this time. 20 And we do have copies for you. 21 MR. WALKERr Thank you, Mrs. Brendler. We 22 Would appreciate it if you could give a copy to the 23 reporter. 24 MR. JAMES: Mr. Walker, 1 neglected to leave a 25 copy. I would like to supply the Sunnyvale Chamber 2^ with copies of my remarks as well. 27 MR. WALKER: Thank you, sir. 28 ' Also for the record I would like to add that 1 l 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 44 still contend that I am a young person and in tune with all the modern ideas with the subject of nomination of pronouns and whenever ! use a pronoun in the masculine form it is clearly to be understood to be intended to include both sexes, now known as uni-sex. I have three more cards here of people who wish to speak. There may be others who will later on appear. We announced at the outset that we would take a recess for the purpose of having a question and answer period off the record. Also, the stenographer has been beating on that machine for some time now and is entitled to a little respite, so we will now take * little recess for twenty minutes, or until 9:00 o'clock, (Thereupon, a recess was had.) MR; WALKER: The time is now 9:00 p.m. and our recess is over and we can go back to work. The next card that I have is Mr. Bert Martin. MR. MARTIN: Mr. Chairman, members of the Board, my name is Bert Martin. I represent the Citizens Advisory Committee, City of Santa Clara. A few months back we initiated a study on this after we had done much the same thing four or five years ago when the super sewer first came up. We were opposed to it at that time and our feelings haven't changed. After our last study the Committee took a stand in the form of a letter which we had sent to your Board, and 1 have a copy of it here. I am ready to pass it around or can, If you would like to have one now or just put it in your file. iA 6 (Associates i 9"«ci fi CERTIFIED SHORTHAND REPORTERS 586 NO. FIRS1 ST.. SAN JOSE. CA 9V 12 TELEPHONE: (9« CERTIFIED SHORTHAND REPORTERS see NO. f IHST ST.. SN JOSE, c 9si 12 TEIGPHONE: C«08) 9S-08W 46 ------- 45 I We feel that the growth of ,our valley and our 2 district overloads the present plant that we have and we 3 feel that It would serve our Interests better if the 4 water fluid ^nd so forth were returned to our environment 5 In a matter that didn't pollute the environment. We 6 don't feel that pumping partially cleansed water out into 7 the Bay is the answer. We feel that that would be a waste 8 of money. We feel that this money can best be spent by 9 upgrading our present plant so that it could handle our 10 needs for years to come-, bearing in mind that our valley 11 is filling up with people, industry and so forth. 12 . This is our feeling. If there are any questions 13 I would be happy to answer them. 14 MR. WALKER: Any questions from the panel? 15 (Ho response.) 16 MR. WALKER: Thank you, sir. 17 MR. MARTIN: Thank you, Mr. Chairman. 18 MR. WALKER: Mr. Patrick Ferraro. 19 MR. FERRARO: Thank you, Mr. Walker, Fellow 20 members and Councilmen of the South Bay Discharge. I 21 have put before you a letter that 1 wrote to Senator 22 Muskie and copies to our congressional delegates when 1 23 was in Washington about a month or so ago. At that time 24 t was made aware that EPA had before it a proposed 25 regulation change which would eliminate all funding for 26 wastewater reclamation projects that went beyond the needs 27 of, quote, effluent discharge quantities. 28 As I have outlined in that letter, 1 strongly 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2i 22 23 24 25 26 27 28 46_ oppose the EPA grant legislation changes, and not knowing the prospects of successfully reversing these proposed change even with the Congressional power that I am trying to bring to bear by EPA, I think it is crucial that we approach the situation of South Bay Dischargers with extreme care and awareness that all the funding for wastewater reclamation could be lost if it is implied that the receiving waters of the South Bay can now or in the future accept the discharge of the treated effluent of the cities of north and south Santa Clara County. I strongly agree and support the previous statements oade by the Canning Association that whether it be by mathematical models or physical models, we can't absolutely predict the quality of the San Francisco Bay under future conditions, especially since we have the unknowns, including the Delta outflow and whether or not the Peripheral canal will be constructed and when, whether or not that will benefit the south San Francisco Bay. For this reason I do support the continued monitoring with an increased emphasis on the potential for eutrophication of the estuary at its southern extremity. Obviously if algal blooms should occur in the future or become prevalent, all our efforts to assure the high dissolved oxygen content levels in the bay would probably just fail because, as the decaying biomass of the algal blooms is consumed by the'organisms, they would consume the oxygen present which was so dearly guarded and assured by the constructing of millions of dollars of (A. tiE 9M-OB» CERTIFIED SHORTHAND REPORTERS SB6NO. f IRST ST. .SAN JOSE. CA 35112 TELEPHONE: l«e>»M»9» 47 ------- treatment facilities to remove the oxygen level from the waste water. This is algal bloon. If It should occur by some later date it could in effect turn the Bay back to the subject of zero oxygen levels that we did have in the last decade before we constructed our advance waste treatment facilities. Now, while the above position seems to be somewhat implied, If not stated in the environmental impact statement, there is still this continuous pride of people here today supporting the no project alternative and I realize many of them may not be aware of EPA's grant regulations. But if the local monitoring is continued, I fail to see the reason why we have to reach a decision at this point In time and run the risk of forfeiting the construction grants which provide the only logical and feasible method oi financing plant and wastewater reclamation for this county. Since considerable market studies are under way by Santa Clara Valley Mater District in cooperation with the California Department of Water Resources, which is funded primarily by EPA, that 1s to the tune of about a five hundred thousand dollar study, in addition to that there 1s a two million dollar study going on which is beyond Santa Clara County to serve the reclaimed water from the entire San Francisco basin, these two studies both have preliminary conclusions that as was stated before, the costs are competitive with new water supplies. The $328 million figure that the draft E1R/EIS J 4 5 6 7 8 9 10 li 12 13 14 15 16 17 H 19 20 JJ n 2} 24 25 26 27 28 _^____ 18 includes upsets me somewhat, because again, it makes an assumption, I don't know if it's verified, and the verification in my mind is questionable also by the Bay models, of whether or not, if we reclaimed the entire flow for re-use during the Irrigation season, whether or not we have outfall can affect the winter flows to the : north of the Dumbarton Bridge, which is during the winter, we do have a natural outflow from the streams and run off and automatically assume that you have to build a conservation facility on top tf the reclamation facility that would cost in excess of $328 million, which would seem to be a good way to just knock it right out of the ballpark right away. But please don't lock in on that figure, because if we reclaim the water, I think we will cert- ainly find that no Bay outfall north of the Dumbarton Bridge will ever be needed just to handle winter dis-: charge. So in view of the myriad of unknowns regarding both the environmental and economic, as well as the Institutional problems we face in implementing reclamation it seems that the residents of the Santa Clara County, the water users and the water dischargers, would best be served if we did not reach a decision at this point in time, and delay the decision on what our project should . be until such time as we work out some of these questions, especially whether or not the EPA is going to stay locked in and not fund anything which does not meet Affluent th iA CERTIFIED SHOBTHAND REPORTERS MB NO. FIRST ST.. SAN JOSE. CA 951U TELEPHONE: (««\| SM-08M CERTIFIED SHORTHAND REPORTERS 586 NO. FIRST ST.. SAN JOSE, C A 95112 TELEPHONE. i«W-OK» 48 ------- ,_ . ; 49 1 discharge requirements. 2 The alternative may be that we run the risk of } losing reclamation as a potential water service for Santa 4 Clara County. J I will draft my comments "P "d have them in 6 the mail to you tomorrow. 7 HR. WALKER: Thank you, sir. 8 Are there any questions from the panel? • 9 (No response.) 10 HR, WALKER: I have a copy of a subsequent 11 letter addressed to Senator Muskie and for the purposes 12 of this record we will nark tha.t as Exhibit 24. 13 (Thereupon,' a four-page letter dated April 4, 1979, addressed to •14 The Honorable Edmund S. Huske was marked Exhibit 24 for 15 ' identification.) 16 HR. WALKER: Curtis B. Harrison. Is that, 17 H-a-r-r-i-s-o-n? 18 HR. HARRISON: That is correct, Mr. Walker. 19 I am Curtis Harrison. I am a Director of the 20 Cupertino Sanitary District. The District is a tributory 21 agency to the San Jose/Santa Clara treatment plant. The 22 District Board has instructed me to advise you and the 23 EPA that they are in favor of the no project alternative. 24 i think if I were to come up here and say I favored this 25 project, I would be drummed out of the valley by the -6 - sound of things tonight. 27 But all kidding aside, 1 think it is very 28 important that the no project alternative be pursued as ------- 52 I received, they will be considered as part of the.record 2 and final action will be taken on that. 3 The action that will be taken is a colleglal 4 effort. That means that many people on the staff will 5 review all of the transcript, all of the records, all of 6 the comments that have been received and make recommendatio 7 to the Regional Administrator in a briefing document and 8 then he will then do as he sees fit. 9 There-is also in this matter a parallel local 10 action of the South Bay Dischargers Authority. They will 11 have authorities in this subject and they are also 12 going to be required to take action on the subject. 13 Mr. Atkinson, do you have any comments to make 14 at this time. 15 MR. ATKINSON: Yes, 1 would recommend that the 16 South Bay Dischargers Authority continue the hearing on 17 their meeting of July, which will be the second Wednesday 18 in July, at Room 300, at 4:00 o'clock, at San Jose City 19 Hall at North First and Mission Streets, at which time 20 further evidence can be considered and action thereon 21 taken, 22 MR. WALKER: Thank you, sir. 23 MR. ATKINSON: I would like to have a motion 24 by the Board to that effect. 25 MR. GISSLER: Is there a motion-to that effect? 26 Motion by Mayor Hayes, seconded by Mr. Henderson. All 27 those in favor say aye. All those opposed? So ordered. 28 MR. ATKINSON: I'd further like the record to l 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 indicate that South Bay Dischargers Authority, Mr. Estruth, has absented himself at the end of the recess after the 9:00 o'clock continuance and has not come back thus far. MR. GISSLER: What action of the Board do you want? MR. ATKINSON: I just want the record to indicate that. MR. HENDERSON: Does this indicate no meeting at all? MR. ATKINSON: No, it does not indicate that. I conferred with staff and I was told that there was no way that the matter could be gotten together by the June meeting and for that reason the first that we could possibly take any action would be at our July meeting, in fact we may not be able to take action until August, but this at least preserves our action for us. MR. GISSLER: All right. MR. WALKER: A lot of questions were asked to- night for which we don't have answers. He hope we will have some answers by then. MR. GISSLER: That's all we have. MR. WALKER: Thank you. As far as we are concerned this EPA section of the hearing is concluded, Mr. Mayor. MR. ATKINSON: Just tD be careful here, I am sorry to keep interrupting, tut I would also like -- well, I think what we've done is sufficient. Nothing (A 9"ttcfc £ Associates CERTIFIED SHORTHAND REPORTERS UeNO. FIRST ST..SAN JOSE. CA95I1Z TELEPHONE: (4M)Mg-oa» CERTIFIED SHORTHAND REPORTERS 5B6KO. f IHST ST.. SAN JOSE, CA 95U2 TECEPHONE: (406) 936-0899 50 ------- 53 54 1 2 5 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 further. HR. GISSLER: So the South Bay Dischargers Authority will not hold a meeting, then, on June the 13, the next meeting will be in July? MR. ATKINSON: No, you can hold your regular meeting then, that will go forward. HR. GISSLERt So we should adjourn this meeting of the South Bay Dischargers Authority to the 13th? HR. ATKINSON: You could do that, that would be 1n order. Notion by Hr. Gunn and seconded by Mr. Henderson. We are adjourned to June 13. Thank you. oOo — t I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 28 STATE OF CALIFORNIA ) COUNTY OF SANTA CLARA ) I HEREBY CERTIFY: That I was appointed to act as Official Reporter in the within-entitled action.; that 1 reported the same in machine shorthand and thereafter caused the same to be transcribed into typewriting under my direction and supervision as appears • by the foregoing transcript; and that said transcript is a full, true and correct statement of the proceedings and evidence in said matter, to the best of «y ability. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal of office this /fa — day of }/%4^- » 1979. /"~ J£- ntf If ••**-.• /r^^A^-— . 1 v- ' ROTARY TUBLIC In and for the County of Santa Clara, State of California iA "Sued 6 CERTIFIED SHORTHAND REPORTERS US NO. FIRST ST., SAN JOSE. CA SSII2 TELEPHONE: \|4M)998-0899 CERTIF IEO SHORTHAND REPORTERS 586 NO. FIRST ST., SAN JOSE. CASSH2 TELEPHONE: H08UM-089S 51 ------- ------- 1.1 TESTIMONIES REQUIRING NO SPECIFIC RESPONSE Statements by Ms. D. Wulfhorst, City of Sunnyvale and Mr. M. Pearl con- sisted of resolutions of support for selection of the "No Further Action" alternative - the alternative recommended by EPA and SBDA. No issues or questions regarding this or other alternatives were raised. Testimony by Ms. D. Wulfhorst Councilmember, City of Sunnyvale The resolution by the City of. Sunnyvale, recommending No Further Action, has been taken into consideration by EPA and SBDA in making the project selection. 1.1 Testimony by Mr. M. Pearl The recommendation for No Further Action has been taken into consideration by EPA and SBDA in making a project selection. TESTIMONIES REQUIRING NO SPECIFIC RESPONSE 53 ------- ------- 1.2 TESTIMONIES ADDRESSED IN OTHER SECTIONS OF THIS REPORT 1.2 TESTIMONIES ADDRESSED TN OTHER SECTIONS OF THIS REPORT Several individuals summarized, in their testimony, letters of comment previously sent to EPA and SBDA. These letters are addressed in Section 2 of this report, as stated below. Testimony by: Mr. S. Goodman Santa Clara County Sanitation District 4 Letters From County Sanitation District 4, EPA No. (HE-149) 1 and (HE-149) 29, are addressed in Sections 2.2 and 2.3 of this report. Testimony by; Mr. L. F. Cournoyer Santa Clara Valley Water District A letter from the Santa Clara Valley Water District, EPA No. (HE149)15, is addressed in Section 2.2 of this report. Testimony by: Mr. J. Quintal Santa Clara County Canners Association A letter from the Santa Clara County Canners Association, EPA No. (HE-149) 11, is addressed in Section 2.2. of this report. Testimony by: Mr. B. E. Schoppe Santa Clara Chamber of Commerce A letter from the Santa Clara Chamber of Commerce, EPA No. (HE-149H8, is included in Section 2.1 of this report. Testimony by: Mrs. M. Brendler Sunnyvale Chamber of Commerce A letter from the Sunnyvale Chamber of Commerce, EPA No. (HE-149)30, is addressed in Section 2.3 of this report. Testimony by: Mr. B. Martin Citizens Advisory Committee City of Santa Clara A letter from the Citizens Advisory Committee, EPA No. (HE-149)2, is addressed in Section 2.2 of this report. 55 ------- Testimony by Mr. P. Ferraro A letter from Mr. Ferraro, EPA No. (HE-149)22, is addressed in Section 2,2 of this report. Testimony by: Mr. C. Harrison Director, Cupertino Sanitary District A letter from the Cupertino Sanitary District, EPA No. (HE-149)19, is included in Section 2.1 of this report. 56 ------- 1.3 TESTIMONIES REQUIRING RESPONSE Two individuals, Messrs. R. Diridon and R. R. James, gave testimony which raised issues not specifically addressed in Section 2 of this report. These issues have been considered in making Che project selection. Testimony by: Mr. R. Diridon Supervisor, County of Santa Clara A letter from the County of Santa Clara, Board of Supervisor, EPA No. (HE-149)26, is included in Section 2.1 of this report. Transcript page 28, lines B-25^ Funds planned for this SBDA project may only be used for an, alternative of the project. However, the San Francisco Regional Reclamation/Reuse Study may result in a large-scale reclamation project for the area, independently of the SBDA EIR/EIS. TESTIMONIES REQUIRING SPECIFIC RESPONSE Transcript pages 29, lines 15-28. Bus washing and some agricultural irrigation is tht subject of a project now in the facilities planning stage. Several local, small-scale reclamation projects are under study throughout the SBDA service area. Testimony by: Mr. R. R. James Chief Executive Officer, San Jose Chamber of Commerce The recommendation of No Further Action, as supported by the San Jose Chamber of Commerce, has been considered by EPA and SBDA in making ,1 pro- ject selection. Transcript page 34, lines 9-25. Changing the Enclosed Bays and Estuaries Policy or the Basin Plan to alter the prohibition against the discharge south of Dumbarton Bridge is in the purview of thu State Water Resources Control Board (SURCB) and the Regional Water Quality Control Board (RWQCB), respect Ively. These agencies will have to determine conditions for such changes; the data in the Draft EIR/EIS ma_v_, in part, provide information necessary to these Boards to make their decisions. However, the Draft EIR/EIS is not intended to result in such a change. 57 ------- It should be noted that each alternative, discussed as viable in the Draft EIR/EIS, was compatible to some extent with large-scale reclamation (the Basin Plan Alternative and Individual Deepwater Outfalls provide a collection system which can be revised to supply the south valley area with water; Upgraded Treatment, in effect, treats effluent to the same high degree which might be required for highest use of reclaimed water). Transcript pages 34-35, lines 26-28, 1-10. A discussion of the potential economic impact of the disposal system on the canning industry is presented in Chapter II I. 1.3 (Technical Volume, Draft EIR/EIS), Advanced waste treatment (AWT) is not the subject of this draft and mitigation of the negative impact of rates due to implementing AWT is beyond the scope of this study. 58 ------- Sectiot? 2 RESPONSES TO WRITTEN COMMENT RECEIVED DURING THE REVIEW PERIOD ENDING 6 JUNE 1979 ------- ------- Twenty-eight letters of comment were received by SBDA and ICl'A during the review and comment period. These letters are reproduced on the following pages along with specific responses to each point or issue raised or ques- tion asked. SBDA and -EPA appreciate the interest taken by the public^ and agencies in the SBDA treated wastewuter disposal EIR/F.FS. 2.1 LETTERS REQUIRING NO SPECIFIC RESPONSE 2.1 LETTERS REQUIRING NO SPECIFIC RESPONSE The following submittals consisted of resolutions or letters supporting the "No Further Action" alternative - the alternative recommended by SBDA and EPA - or letters raising no specific issues regarding this or other alternatives. SBDA and EPA thank the reviewers for their interest and acknowledge the stated preferences. These letters have been con- sidered in making the project selection. • Office of the Governor, Office of Planning and Research, State Clearinghouse - 7 April 1979 - EPA No. (HE-149) 3 • City of Saratoga - 8 May 1979 - EPA No. (HE-149) 4 • Town of Los Gatos, - 8 May 1979 - EPA No. (HE-149) 5 • City of Milpitas, Milpitas Sanitary District Board of Directors - 14 May 1979 - EPA No. (HE-149) 7 • City of Campbell - 15 May 1979 - EPA No. (HE-149) 10 -< » Paul N. McCloskey, Jr., U.S. Oppress - 16 M;w 1979 - EPA No. (HE-149) 14 U.S. Department of Transportation, Federal Highway Administration, Region Nine -'16 May 1979 - EPA No. (HE-149H6 • Santa Clara Chamber of Commerce - 18 May 1.979 - EPA No. (HE-149) 18 • Cupertino Sanitary District - 21 May 1979 - EPA No. (HE- 149) 19 • Norman Y. Mineta, U.S. Congress - f> June 1979 - EPA No. (HE-149) 25 • County of Santa Clara, Board of Supervisors - 11 June 1979 - EPA No. (HE-149) 26 61 ------- OFFICE OF THE GOVERNOR OFFICE OF PLANNING AND RESEARCH STATE CLEARINGHOUSE 100 - 10TH STRFET SACRAKENTOt CA 91814 U.S. ENVlRONrjMTAL PROTECTION AGENCY 215 FREMONT ST SAN FRJNCISCO CA <>4105 ATTENTION: PAUL DEFALCD RECEtVEO F '•' 4 fi«r<3ION ix 13777 FRUITVALE AVENUE . SARATOGA. CALIFORNIA 8SO7O (408)867-3438 May 8, 1979 ACKNOWLEDGEMENT 0/07/79 REPORT TMD4SA PROJECT NOTIFICATION AMD REVIEW SYSTEM OF THE GOVERNOR (9161 445-0613 -PROJECT: S.UTH =IAY DISCHARGE AUTHORITY STATE CLEARINGHOUSE NU^B£R ------- RESOLUTION 110. 900 A RESOLUTION OF THE CITY OF SARATOGA URGING IMPLEMENTATION OF THE "NO ACTION BEYOND CURRENTLY APPROVED IMPROVEMENTS AT TREAT- MENT PLANTS" ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT REPORT AND STATE- MENT FOR THE TREATED UASTEWATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY WHEREAS, County Sanitation District No, 4 of Santa Clara County, California, provides for the collection, treatment and disposal of the wastewater emanating from the City of Saratoga; and WHEREAS, the District has reviewed the DRAFT ENVIRONMENTAL REPORT AND STATEMENT, SOUTH SAY DISCHARGERS AUTHORITY TREATED WASTEHATER DISPOSAL PROGRAM, commented thereon and requested Implementation of the no action alternative set forth in the said DRAFT REPORT. . • NOW, THEREFORE, BE IT RESOLVED that the City of Saratoga " does hereby concur in the comments and request of the said District and does similarly request that the Environmental Protection Agency and the South Bay Dischargers Authority undertake the appropriate measures to implement the no action alternative set forth in the DRAFT ENVIRONMENTAL REPORT AND STATEMENT. Passed and adopted at a regular meeting of the City Council of the City of Saratoga held on the 2nd day of May 1979, by the following vote: •U.S.E.P.A. REGION 2 COMM CMS HIT II TOWN of LOS GATOS Department of Public Works 354-680 May B, 1979 U. S. Environmental Protection Agency 215 Fremont Street San Francisco, California 94105 Gentlemen: South Bay Dischargers Authority CopBBon Conveyance Facility Attached is a copy of Town Council Resolution No.1979-69 which was adopted May 7, 1979. Please consider these recommendations at your hearing May 16, 1979 concerning the Combined Draft Environmental Impact Statement-Environmental Impact Report for the South Bay Dischargers Authority Facility. Very truly yours. R. L. WARNICK Director of Public Works RLW/Jh Enc. AYES: Councilmen Kalb, !latt«oni, Kraus & Corr NOES: None ABSENT: Councllwoman Callon ATTEST: /•/ Robert F. BflyV MAYOR THIS IS TO CERTIFY THAT THE WITHIN IN- STRUMENT IS A TRU^ANO CORRECT COPY OF THE OWCINAJ--<»/4/FILE Itj- THIS OFFICE. CITY CLERK CIVIC CENTER • 110 EAST MAIN STREET • P.O. BOX 949 • LOS CATOS, CALIFORNIA 95030 63 ------- RESOLUTION NO. 1979-69 A RESOLUTION OF THE TOWN OF LOS GATOS URGING IMPLEMENTATION OF THE "NO ACTION BEYOND CURRENTLY APPROVED IMPROVEMENTS AT TREATMENT PLANTS" ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT FOR THE TREATED WASTEHATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY WHEREAS, County Sanitation District No. 4 of Santa Clara County, California, provides for the collection, treatment and disposal of the wastewater emanating from the Town of Los Gates; and WHEREAS, the District has reviewed the DRAFT ENVIRONMENTAL REPORT AND STATEMENT, SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM, commented thereon and requested implementation of the no action alternative set forth in the said DRAFT REPORT. NOW, THEREFORE, BE IT RESOLVED that the Town of Los Gates does hereby concur in the comments and request of the said District and does similarly request that the Environmental Protection Agency and the South Bay Dischargers Authority undertake the appropriate measures to implement the no action alternative set forth in the DRAFT ENVIRONMENTAL REPORT AND STATEMENT. PASSED AND ADOPTED by the Town Council of the Town of Los Gatos this 7tii day of May , 1979, by the following vote: AYES: COUNCIL MEMBERS Ruth Cannon, Mardi Gualtieri, Peter II. Siemens and Thomas J. Ferrito NOES: COUNCIL MEMBERS None ABSTAIN: COUNCIL MEMBERS Hone ABSENT: COUNCIL MEMBERS Jom axLoefmer SIGNED: ATTEST: CLERK 'OF THE TOWN OF (Ettti of * tlptfas c;iO'» ix ' .-MM. 455 E. Calaveras Blvd. Milpitas, California 95«Q5 1 5 : (408) 262-2310 ™ U May 14, 1979 Environmental Protection Agency Region 9 215 Fremont Street San Francisco, California 94105 ATTN: Hearing Officer SUBJECT: South Bay Dischargers Authority Treated Wastewater Disposal Program EIR/EIS Gentlemen: Enclosed please find a resolution of the Milpitas Sanitary District Board of Directors supporting the "No Action* alternative outlined in the draft EIR/EIS for the subject project. Very truly yours. Wesley D. Smith Director of Planning and Engineering cc: Board of Directors, Milpitas Sanitary District South Bay Dischargers Authority WDS/PHC/law L6S-G, GATOS An Eqml Opportunity Employ* 64 ------- RESOLUTION NO. 499 A RESOLUTION URGING IMPLEMENTATION OF THE "MO ACTION CEYQND CURRENTLY APPROVED IMPROVEMENTS AT TREATMENT PLANTS" ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT FOR THE TREATED WASTEWATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY CITY (IF CAMPBELL 75 NORTH CENTRAL AVENUE CAMPBELL, CALIFORNIA 95008 1409] 378-8141 Deparumnt: CHy Clerk : -.- " ------- (HE-144} 10 RESOLUTION MO. 5590 A RESOLUTION OF THE CITY COUNCIL Of THE CITY OF CAMPBELL URGING IMPLEMENTATION OF THE "NO ACTION BEYOND CURRENTLY APPROVED IMPROVEMENTS AT TREATMENT PLANTS" ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT FOR THE TREATED WASTEHATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY WHEREAS, County Sanitation District No. 4 of Santa Clara County, California, provides for the collection, treatment and disposal of the wastewater emanating from the City of Campbell; and WHEREAS, the District has reviewed the DRAFT ENVIRONMENTAL REPORT AND STATEMENT, SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM, commented thereon and requested implementation of the no action alternative set forth in the said DRAFT REPORT. NOW. THEREFORE, BE IT RESOLVED by the City Council of the City of Campbell that the City of Campbell does hereby concur In the comments and request of the said District and does similarly request that the Environmental Protection Agency and the South Bay Dischargers Authority undertake the appropriate measures to Implement the no action alternative set forth in the DRAFT ENVIRONMENTAL REPORT AND STATEMENT. PASSED AND ADOPTED this 14th day of May. 1979, by the following roll call vote: AYES: counciimen: Doetsch, Manner, Chamberlln, Podgorsefc, Paul NOES: Counciimen: None ABSENT: Counciimen: None taaifitnpton. 39.C. 20515 Kay 16. 1979 14 South Boy Dischargers Authority 610 Mm Street San JuSe. California 95110 Dear Sirs: I Support the recotnnefldation made in the Environmental Impact Report/ Statement prepared by the fnvironmental Protection Agency and the South tony Dischargers Authority, wfth technical assistance fnn> Beehtel inc., that no further action on the proposed deep water pipeline Is necessary at this time. The cost of the pipeline, both in terns of construction and Subsequent Increased energy demand for operation. 1s prohibitive and 1 am satisfied that protection of the South Bay environment, in particular the fresh water marsh, 1$ best served by upgraded treatment of wastewater and con- tinued monitoring of Bay water quality. tt Is my hope thftt the Hater quality Control Board will aflrcc to take no further action on the proposed pipeline. Sincerely, Paul N. KcCloskey. r. APPROVED: Norman Paul, Mayor ATTEST: THE FOIEIOIIM INITHUMENT n >nw AND CORRECT COPY OF THE OHOINAl ON FILE IN TH'8 OFFICE. Phyllis 0. Acker, City Clerk 66 ------- US. DEPARTMENT OF TRANSPORTATION j; FEDERAL HIGHWAY ADMINISTRATION ~ UGIONNINE Two Eabarcadeio Center, Suite 510 San Francisco, California 941ll ,v 16, 1979 HED-09 SANTA CLARA CHAMBER OF COMMERCE 151S EL CAMINO HEAL • SANTA CLARA • CALIFORNIA 408/296-6863 • P.O. BOX 387 • 95052 U S.E ."•• MSIOH? C0MH CHI F. K«ZI Mi. Paul De Falco, Jr. Regional Administrator, Region IX Environmental Protection Agency 215 Fremont Street San Francisco, California 94105 Dear Mr. De Falco: We have reviewed the Draft environmental Impact Statement for the South Bay Dischargers Authority Treated Hastevater Disposal Program in Santa Clara aod San Mateo Counties, California, and have no specific comments to offer. We appreciate this opportunity to review the subject Draft Statement. Sincerely yours. May 18, 1979 Regional Administrator U.S. Environmental Protection Agency Region IX 215 Fremont Street San Francisco, California 94105 Attn: Hearing Office (HE-lXl) Gentlemen: Attached are three copies of the statement of the Santa Clara Chamber of Commerce presented at the public Hearing on the EIR/EIS for the Treated Wastewater Disposal Program, held May 16, 1979 in the Santa Clara City Council Chambers. Sincerely, Bruce E. Schoppe, Vice President Legislative Action Division BS:nb Enclosure 67 ------- 18 SANTA CLARA CHAMBER OF COMMERCE 1515 EL CAMINO REAL • SANTA ClARA • CALIFORNIA 400/296-6663 • P.O. BOX M7 • WOS2 OlITRICT MANADEft-ENBIMCCfl MARK THOMAB ft CO. IHB. JOHN t PLtMIND SEOOftS BTCVCMI CHECK Btve. <4C»} 3SS-7D7I tVTKlCT CDUM«tL PHILIP D. ASBAF A3D N. 0LKN MATCH CHtiv P. o. Box isa BAM MAW, c. V44D1 (415) " CUPERTINO SANITARY DISTRICT BANTA CLARA COUNTY CUPERTINO SANITARY DISTRICT OF SANTA CLARA COUNTY OFFICE OF THE DISTRICT AMD ENGINE en fOOtS ITtvCNB CftCCK LVH. • UlTC 1£K CUKRTINO. CAI-»rOWiA VSOt- •OAttD Or Dlf CTQIM MAURICE r. ukamc. p CURTlV •, MANNIflDN, • EDWARD O. HAHAM1AN DR. AS. F. «OWN HOT M. KUVHTDN May 21, 19J9 File: CuSEi - MOP Oouth Bay Dischargers. Authority I an Bruce E. Schoppe representing the Santa Clara Chamber of Commerce. We are opposed to the construction of the so called "super sewer and support the position of the EPA and South Bay Dischargers Authority favoring the "no further action" al- ternative. ' . ':. ' Measured against the goals of this entire program—that is, the improvement of water quality in the south Bay, it is clear that construction of this pipeline is unnecessary. The advanced wastewater treatment capability now or soon to be' in operation at-the municipal treatment plants involved will, for all pratical purposes, achieve that goal. He view this as a situation in which the real benefits must be measured against the real costs. Mathematical modeling has shown that, given these advanced treatment plants, very little difference in south Bay water quality results with the project vs. no project. In fact, there may well be a net negative result due to the removal of these fresh water flows from Artesian Slough and the other treatment plant outfalls. The Chamber of Commerce is an organization of business people. He recognize that, if constructed, we'll pay the cost of this project through our businesses as well as our homes and those of our employees. Quite honestly, we don't need something else adding to our costs in this inflationary era—especially when, in our view, it has been clearly shown there is no need. Adoption of the "No further action* plan makes a great deal of sense to us—environmentally and economically. Environmental Protection Agency Region IX 215 Fremont Street San Francisco, Ca. 94105 Attens Hearing Office (HE-149) Re: Gentlemen: South Bay Dischargers Authority Conveyance Facility On May 16, 1979, the Cupertino Sanitary District Board' of Directors adopted the enclosed Resolution No. 657, after reviewing the various alternative plans for the South Bay. please keep us informed of future activities on this project. Very truly yours, MARK THOMAS & CO. INC. District Manager-Engineer JEFsdh cc: South Bay Dischargers Authority cc: City of Cupertino cc: Cupertino Chamber of Commerce Enc. Resolution No. 657 tin E. Fleming 68 ------- RESOLUTION NO. 657 A RESOLUTION URGING IMPLEMENTATION OF THE "NO ACTION BEYOND CURRENTLY APPROVED IMPROVEMENTS AT TREATMENT PLANTS" ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT FOR THE TREATED WASTEWATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY CUPERTINO SANITARY DISTRICT WHEREAS, Cupertino Sanitary District, Santa Clara County, California, has reviewed the DRAFT ENVIRONMENTAL REPORT AND STATEMENT FOR THE TREATED WASTEWATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY; and WHEREAS said DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT, dev- elops a strong case for adoption of no further action, beyond currently approved improvements at treatment plants, as an alternative to the Basin Plan. NO?, THEREFORE, BE IT RESOLVED that the Sanitary Board of the Cuper- tino Sanitary District does hereby request that the Environmental Protec- tion Agency and the South Bay Dischargers Authority undertake the appro- priate measures to implement the no action alternative set forth in said DRAFT ENVIRONMENTAL REPORT AND STATEMENT. I hereby certify that the foregoing is a,full, true and correct copy of a resolution which was duly and regularly passed and adopted by the Sanitary Board of the Cupertino Sanitary District, at a meeting thereof held on the 16th day of May, 1979, by the following vote of. the members thereof: AYES, and in favor thereof, Members: Brown, Harrison, Bahamian, LaBrie, Rushton NOES, Members:. None ABSENT, Members: None HAIL6RAM SERVICE CENTER ics IPMSNCZ CSP tree 40S9ft«69«» 6* TORN SAN JOSE C» 109 0»-0* 05«ZP EST ' !! / ui ^ '] ------- County of Santa Clara Offim « «w loM oi lupnvtten County aovmnrant Cen»r. Ewt Wing 79 wesi MMtJina Streel S«n JOM. CllifontU (9110 2M-U2I ATMCOM40B 26 California SuMnn Wilson, District t Dominic L. Conm. txurla 1 Dirt Me Corquodlta. D/«rf« J RoaOHWm. OutricU OmMlrw f. SttMMia,, Offtncf 5 June 11. 1979 South Bay Dischargers Authority c/o Environmental Protection Agency 215 Fremont Street San Francisco, California 94105 Subject: Resolution Re No Action Alternative for South Bay Dischargers Authority Treated Waetewatei Disposal Program • . Gentlepersons : The Board of Supervisors, County of Santa Clara, at its meeting of Hay 15, 1979 adopted a Resolution urging implementation of the "No Action Beyond Currently Approved Improvements at Treatment Plants.' The Board authorized Supervisor oiridon to testify on its behalf at a public hearing on' this matter. Enclosed please find a conformed copy of the captioned Resolution. Sincerely, BOARD OF SUPERVISORS Donald H. Rains, Clerk By « Deputy clerk vas Enclosure CC: County sanitation District Ho. 4 An Eqinl Opportunity Emptom' RESOLUTION RE NO ACTION "ALTERNATIVE FOR SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM WHEREAS, the Draft Environmental Impact Report and Statement for the Treated Hastewater Disposal Program of the South Bay Dischargers Authority has developed a strong case for adoption of a no further action, beyond currently approved improvements at treatment plants, as an alternative to the Basin Plan; and WHEREAS; County Sanitation.District No. 4 has requested that the Environmental Protection Agency and the South Bay Dischargers Authority take whatever steps necessary to. implement the no action alternative set forth in the Draft Environmental Impact Report and Statement; NOW, THEREFORE, BE IT, RESOLVED by the Board of Supervisors of the County of Santa Clara, State of California, that it hereby requests that the Environmental Protection Agency and the South Bay Dischargers Authority undertake appropriate measures necessary to implement the no action alternative as set forth in the Draft Environmental Impact Report and Statement for the South Bay Dischargers Authority Treated Nastewater Disposal Program. PASSED AND ADOPTED by the Board of Supervisors of the County of Santa Clara, State of California, on HAT 1 5 W9 j by the following vote: AYES: Supervisors CORTESE. MeCORQUODALE, «TBIMOC««. DIRIDON. WILSON NOES: Supervisors Vi/MT ABSENT: Supervisors PTBNBEK! Dominic L. Cortese Chairperson, Board of Supervisors ATTEST: SB: no DONALD M. RAINS, Clerk Board of Supervisors Supe 70 ------- 2.2 LETTERS REQUIRING SPECIFIC RESPONSE 2.2 LETTERS REQUIRING SPRCIFIC RESPONSE The following submittals consisted of letters which raised issues or ques- tions about selected alternatives, mitigating measures and/or conclusions drawn in the Draft EIR/EIS. . Each letter is reproduced in the order received, and each is followed by a point by point response to the com- ments. Where more than one letter raises similar issues, the most com- plete response is provided to the first letter received and each response to succeeding letters is referenced to that first letter. Each letter has been considered in making the project selection. • County Sanitation District No. 4, Santa Clara County - 30 April 1979 - EPA No.- (HE-149) 1 • Santa Clara Citizens Advisory Committee - undated - EPA NO. (HE-149) 2 • U.S. Department of Commerce - undated - EPA No. (HE-149) 6 • Drs. Howard S, Shellhammer and H. Thomas Harvey,-San Jose State University - 14 May 1979 - EPA No. (HE-149) 8 • Dr. L. Richard Mewaldt, San Jose State University - 14 May 1979.,- EPA No. (HE-149) 9 • Santa Clara County Canners Association - 15 May 1979 - EPA No. (HE-149) 11 • U.S. Department of Agriculture - 8 May 1979 - EPA No. (HE-149) 12 • San Jose/Santa Clara Water Pollution Control Plant - 16 May 1979 - EPA No. (HE-149) 13 • Santa Clara Valley Water District - 17 May 1979 - EPA No. (HE-149) 15 • Department of Fish and Came - 17 May 1979 - EPA No. (HE-149) 17a • State Water Resources Control Board - 14 May 1979 - EPA No. ' (HE-149) 17b • D. E. Myers, Loma Prieta Chapter, Sierra Club - 23 May 1979 - EPA No. (HE-149) 20 • U.S. Department of Interior, Pacific Southwest Region - 22 May 1979 - EPA No. (HE-149) 21 71 ------- Patrick Forraro, District 2, Santa Clara Valley Water District - 22 May 1979 - EPA No. (HE-149) 22 Regional Water Quality Control Board - 30 May 1979 - EPA No. (HE-U9) 23 ABAC - 1 June 1979 - EPA No. (HE-149) 24 Advisory Council on Historic Preservation - 8 June 1979 - EPA No. (HE-149) 27 72 ------- COUNTY SANITATION DISTRICT NO. 4 OF SANTA CLARA COUNTY 100 East Sunnyoaks Avenue Campbell. California 95008 Jtltpnone 376 ?40' April 30, 1979 :••:•"> 5V .S.W.A ?•'! -3 i (WHS «ESID£NTS OF .-.•,< ^rfWjtftf CAMPBELL " •"^TOA.TOF IOSOATOS CITY OF MONTE SERENO . e);v».) . I Attest: Directors Directors Directors HAYES, CODY. KRAUS, PAUL Secretary o-f the Board T. , .Chairperson of the Board The foregoing instrument is a - correct copy of the original on file in this office COBNTf saHIWlO* BISTBICI10.« iltm. Q^i'cL* Q-W^f . SxrtfuT 73 ------- Connents of County Sanitation district tic. 4 Page 2 ® ® ® COMMENTS OF COUNTY SANITATION DISTRICT NO. 4 OF SANTA CLARA COUNTY, CALIFORNIA, CONCERNING THE DRAFT ENVIRON- MENTAL IMPACT REPORT AND STATEMENT, SOUTH BAY DISCHARGERS TREATED WASTEHATER DISPOSAL PROGRAM The following comments of the County Sanitation' District No. 4 of Santa Clara County, California, concerning the DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT, SOUTH BAY DISCHARGERS TREATED HASTE- HATER DISPOSAL PROGRAM are being submitted to the Environmental Protection Agency pursuant to the Agency's notice of a joint public bearing on Hay 16, 1979. i Statement (EIS/EIR TECHNICAL Page 147); 'The transport project without currently approved treatment improvements would improve water quality in the South Bay, with a corresponding decrease in water quality near the point of discharge north of the Dumbarton Bridge (BASSA, 1975). Since upgraded treatment would accompany the transport system, however, a severe decrease in water quality at the discharge point would not occur (Appendix C). The most drastic alteration in water quality would occur in those sloughs in the South Bay now receiving point source discharges." Comment: There appears to be no assurance that there will be a significant increase in the South Bay water quality as a result of constructing the transport project in addition to the upgraded treatment. Statement (EIS/EIR TECHNICAL Page 147): "However, except for the lower two or three miles of the Bay, the Basin Plan Alternative is not significantly different from a no further action alternative (see also Section IV.2.9), in that DO standards will not be met in all extremities of the Bay. In the lower two or three miles of the Bay, DO concentrations would. be expected to deteriorate somewhat in the headwaters of Artesian Slough, due to lack of flushing (how allowed by wastewater flows) and a resultant expression of background oxygen demand in the sloughs." Comment; Construction and operation' of the Basin Plan Alternative, at a considerable expense, dollars and energy, will not signifi- cantly improve theDO concentration of waters of the South Bay above that provided by the no further action alternative and may cause deterioration of the DO concentrations in the headwaters of major South Bay sloughs. Statement (EIR/EIS TECHNICAL Page148); "The South Bay would lose a significant portion of its annual freshwater input when the treated wastewater is diverted northward. The diversion would result in salinity increases in the South Bay, especially in the southern reaches." ® ® ® ® Comment: The overall quality of the water in the South Bay may be better as a result of discharging treated wastewater simulating natural freshwater "discharges into the major sloughs as compared with their diversion out of the South Bay. Statement (EIR/EIS TECHNICAL Page 118): "The toxicity levels in the South Bay would decrease with the removal of waste loads. Hydroscience (Appendix C) calculate the difference in toxicity with a no further action alternative and implementation of the Basin Plan Alternative to be as much as an order of magnitude (ten times the relative toxicity for no further action as for the Basin Plan Alternative) in the South Bay." Comment-. The magnitude of toxicity resulting from adoption of the no further action alternative could be reduced by improvement of the South Bay dischargers toxicity source control programs. Statement (EIR/EIS TECHNICAL, Page 154): "The presence of the diffuser in the deep water north of Dumbarton Bridge will result in the presence of a mixing zone with salinities ranging from nearly fresh water to saltwater concentrations. While the mixing zone will not significantly affect the salinity of the open waters of the Bay, it may present a barrier to passage of fish not tolerant to salinity variations." Comment: The enhancement of the conditions in the waters of the South Bay for aquatic life may be offset by the aquatic barrier that may be created by the Basin Plan Alternative. Statement (EIR/EIS TECHNICAL Page 165): "An outfall project alone would not impose significant economic cost to individual users or industries. However, further analysis of final outfall users charges together with user charges for advance waste treatment should be made in order to assess the coiriir.ed economic impact." Comment: The full impact of the user charges for fully imple- mented advance waste treatment by the South Bay dischargers to be closely followed by additional user charges for sludge solids handling and disposal facilities has not occurred and the further cost of the Basin Plan Alternative appears to bo unwarranted in light of its questionable bcn.ofits. Statement JEIS/EIR TECHNICAL Page 169): "Discontinuing a signifi- SA ot cant portion of the freshwater inflow into the South Bay will permanently remove the existing freshwater habitat in the area south of Dumbarton Bridge." Comment: This adverse operational effect of the Basin Plan Alter- native provides a significant reason to adopt- the no further action alternative with a monitoring program to determine the effect of the' discharge o£ highly treated effluent into the South Bay. 74 ------- Comment of County Sanitation District-No. 4 Page 3 Statement EIK/EIS TECHSICAL Page 188); "This (no further action) alternative can be viewed as a phase of a 'deferred action' alternative that would allow an interim monitoring program and analysis of the effects of approved upgraded treatment on the Bay environment. Should water quality be shown to improve markedly under this alternative, a case could then be made for no addi- tional action. • If, however, the rate of improvement were not satisfactory to regulatory agencies, additional treatment, recla- mation, or disposal methods could be implemented as needed, and evaluation could be made for each treatment plan separately for SBDA as a joint discharger. During the phasing of treatment and disposal, alternatives not now considered viable may be developed to a level of reliability, cost-effectiveness, and public accep- tance that would allow their implementation." Comment: This statement is fully supported by other statements set forth in the EJ.R/E1S and is fully endorsed by County Sanita- tion District Ho. 4 and serves'as the basis for the request that the proposed Basin Plan Alternative be abandoned and the no further action alternative and South Bay water quality monitoring program be approved 'for' use by the South Bay Dischargers Authority. Submitted by: County Sanitation District No. 4 of Santa Clara County 100 East Sunnyoaks Avenue Campbell, California 95008 Bated: 30 April 1979 Response: SBDA and EPA have noted the attached resolution and have considered it in making a project selection. Specific issues have been raised which require some responses. 1. No response required 2. No response required 3. No response required A. It may be true that source control programs now planned by SBDA would reduce the magnitude of toxicity in the effluent and, hence, the receiving water. However, data on metropolitan wastewaters from several sources indicate that domestic sources, storm severs, and nonpoint sources con- tribute more than half of the heavy metals (which constitute a major portion of the toxicity potential). For example, the Association of Metropolitan Sewerage Agencies (AMSA), in the AMSA Monthly Report. May 1979, Volume 4, Issue 5, page 3, shows that while many member cities confirm the assumption that full-scale industrial pretreatment will eliminate most of these substances from the sewer systems, others (Dallas, Texas; Seattle, Washington; Chicago, Illinois) indicate that domestic, storm runoff, and nonpoint sources may be as significant. Also, Robert Pitt of Woodward- Clyde Consultants, in "Demonstration of Nonpoint Pollution Abatement Through Improved Street Cleaning Practices" (EPA Grant S-804432, May 1979), used the City of San Jose as an example in comparing urban runoff and wasteuater plant effluents (Table 2-1). He indicates that improved treatment nay not SHG/pm April 25, 1979 75 ------- be as cost-effective as street cleaning with regard to heavy metals. Therefore, it may be concluded that source control must be extensive, including nonindustrial sources, and that some sources (nonpoint, for example) may override the Improvement provided by pretreatment and other source control approaches* In addition, regardless of the success of source control, at this time it is not possible to estimate the percentage reduction in toxicity, nor is it possible to predict compliance with the 40 ml/1 toxicity guideline as a result of source control. 5. Ho response required 6. No response required 7. No response required 8. SBDA has not designed a monitoring program. SBDA will, upon completion and approval of the Final EIR/E1S, petition the STOCB in order to establish conditions fot exemption from the prohibitions against discharge expressed in both the Basin Plan and the Enclosed Bays and Estuaries Policy. Infor- mation will be submitted to the Regional Water Quality Control Board and the State Water Resources Control Board to justify such exemption In that petition. 76 ------- TABLE 2-1. COMPARISON OF URBAN RUNOFF AND WASTEWATER TREATMENT PLANT EFFLUENT Runoff Concentration (rag/1 unless otherwise stated) Parameter Ca++ K* M9;+ Na* ci- so,- HC03 N03 BOD5 COD KN OrthoP04 Total Solids TDSe Suspended Sol ids Cd Cr Cu Pb Zn Hg Specific conductance (nmhos/cm) Turbidity (NTU) pH (pH units) TOCf Avg 13 2.7 4.0 15 12 18 54 0.7 24 200 6.7 2.4 350 150 240 0.01 0.02 0.03 0.4 0.18 •cO.OOOl 120 49 -6.7 110 Peak {1-hr) 19 3.5 6.2 27 18 27 150 1.5 30 350 25 18 950 380 850 0.04 0.04 0.09 1.5 0.55 0.0006 660 130 7.6 290 STP. Effluent Concentration (mg/1 unless otherwise stated) Avg. 65 24 35 220 330 150 230 4.9 21 35d 24 19 1000 1000 26 0.002 0.016 0.081 0. 0098 0.087 0.0019 1900 20 7.6 30 Ratio of Avg. Runoff to STP cone. 0.20 0.11 0.11 0.07 0.04 0.12 0.23' 0.14 1.1 5.6 0.28 0.13 0.34 0.15 9.2 5 1.3 0.37 41 2.1 <0.05 0.06 2.5 — 3.5 Ratio of Peak Runoff to Avg. STP cone. 0.29 0.15 0.18 0.12 0.05 0.18 0.66 0.31 1.4 10 1.1 0.92 0.92 0.37 32 20 2.5 1.1 150 6.3 0.32 0.36 6.5 — 9.7 Street Surface • Annual . Runoff" (tons/yr) 350 73 110 410 330 490 1500 19 480 950 17 1.2 9500 4100 4700 0.018 3.5 5.5 36 3.9 0.0032 — -- — 3000 Annual STP Effluentc (tons/yr 8,000 3,200 4,700 30,000 45,000 20,000 32,000 660 2,800 4,700d 3,200 2,600 140,000 ' 140,000 3,500 0.27 2.2 11 1.3 12 0.26 — . -- 4,100 Ratio of Street Surface Runoff to STP Annual Yields 0.040 0.023 0.023 0.014 0.007 0.025 0.047 0.029 0.17 0.20 0.005 0. 0005 0.07 0.029 1.3 0.07 1.6 0.5 28 0.33 0.01 — -- -- 0.73 Secondary sanitary wastewater treatment plant. About 200 people correspond to 1 curb-mile (2880 curb-railes in San Jose/575,000 population). Therefore a population of 850,000 corresponds to about 4250 curb-miles, with about 1100 curb-miles of streets surfaced with oi1 and screens. These annual runoff values were calculated based on a year of the appropriate accumulation rates and these mileage estimates. cAn estimated population of 850,000 is served by the sanitary wastewater treatment facility. Estimated. e Total dissolved solids. Total organic carbon. Source: Pitt, R-, 1979. "Demonstration of Nonpoint Pollution Abatement through Improved Street Cleaning Practices." Woodward-Clyde Consultants for Municipal Environmental Research Laboratory, Office of Research and Development, U.S. EPA, Cincinnati, Ohio. Grant No. S-804432. 77 ------- SANTA CLARA CITIZENS ADVISORY COMMITTEE MAYS 1879 Environmental Protection Agency Attn: Hearing Office, HE-149 Region IX 215 Fremont Street San Francisco, California Gentlemen: I am presenting the following testimony regarding the EIS/EIR for the South Bay Treated Wastewater Disposal Program on behalf of the Citizens Advisory Committee for the City of Santa Clara. Our committee, which is'advisory to the City Council, has long been aware of the proposed pipeline project- In 1975 our representatives attended the workshop held in Sunnyvale regarding the project. At that meeting our former chairman expressed his reservations about the project. , We are grateful to see that the Environmental Protection Agency, along with the South Bay Dischargers Authority, no longer sees the need to construct the pipeline. We also continue to see no need for the project. The money saved by not constructing this pipeline could be applied to improve treatment so the sewage could be reclaimed for a beneficial use. To reach the above decision our committee recently organized a sub-committee specifically to review in detail the summary Envir- onmental Impact Report and Statement. During this review we contacted our city staff {.to obtain further:'information on-the project. As you are probably aware, most of the local agency staff members involved in the project also do not support the pipeline project. Our independent review resulted in a similar viewpoint. Basically, our objections to the project are the same as those noted in the EIR/EIS. Namely: 1. No significant improvement in water quality. It is apparent that the advanced sewage treatment plants recently constructed will significantly improve the water quality in the South Bay. 2. Biological damage to the existing freshwater marshes that would result if the pipeline were put into oper- ation. 3. Cost. The 986 million to construct and another $320,000 to operate could be better applied to a reclamation project. The savings of the operating costs to the citizens could be very helpful in these inflationary periods. 4. Energy. This project would consume about the equiv- alent of 4900 barrels of oil a year to operate. We are already in somewhat of an energy crunch. This project would further the energy problems faced by the country. Baaed on the information in the report, we believe the pipeline project, if constructed, could mean the final end to any pot- ential for a future reclamation project in this area. We believe that since reclamation and reuse is our goal we should continue with an ambitious program to reach that goal. Sincerely, Bert Martin Citizens Advisory Committee bm:mc CITY CLERK CITY OF SANTA CLARA Cltr Hall SANTA CLARA. CALIF. MOW 78 ------- Submitted by: Santa Clara Citizens Advisory Committee Bated: undated Response: SBDA and EFA recognize that energy consumption has become an even more important concern since the issuance of the Draft EIR/EIS and increased energy costs would further increase predicted operation costs for all upgraded treatment alternatives as well as for all alternatives requiring transport of the effluent. It was not intended .to imply no significant improvement in water quality would occur as a result of implementing any of the project alternatives. Rather, the five "viable" alternatives did not appear to be significantly different in predicted dissolved oxygen levels; actual numbers of NPDES permit violations are expected to decrease with the implementation of advanced waste treatment. The location of oxygen depressions varies'with the alternatives, however, and no alternative guaranteed meeting dissolved oxygen goals year-round. Reclamation and reuse of wastewater, as stated in the Draft EIR/EIS (page 195 of Technical Volume), is a goal of the state and federal governments. However, at this time, reclamation cannot be postulated as a complete disposal alternative but the four viable disposal alternatives are all compatible to some degree with limited reclamation. Regional disposal systems are particularly compatible with^large-scale regional reclamation programs. SBDA and its member cities are presently engaged in the Regional Reclamation Study and in several small-scale projects. Therefore, SBDA is continuing to study reclamation as a future option for all or part of the effluent in the area. 79 ------- UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL OCEAN SUHVfv Hockville. Md. 20852 OA/C52x6:JLR MAY 3 1979 TO: PP - Richard Lehman FROM: OA/Cxl SUBJECT: DEIS #7904.04 - Treated Wastewater Disposal Program The subject statement has been reviewed within the areas of NOS responsibility and expertise, and In terms of the impact of the proposed action on NOS activities and projects. The, following conment 1s offered for your consideration. Geodetic control survey monuments may be located in the proposed project area. If there 1s any planned activity which will disturb or destroy these monuments, NOS requires not less than 90 days' notification in advance of such activity in order to plan for their relocation. NOS recommends that funding for this project includes the cost of any relocation required for NOS monuments. 80 Submitted by: U.S. Department of Commerce National Oceanic and Atmospheric Administration National Ocean Survey . Rockvllle, Maryland 20852 Dated: undated Response: No construction activities will occur with the selected project alternative (No Further Action). Therefore, there will be no activity which will dis- turb geodetic control survey monuments. Thank you for calling these• monuments to our attention. ------- S.E.P.- SanJose'State Uniuersity WASHINGTONSOUARE CAN JOSt, CALIFORNIA 1612 SCHOOL OF SCIENCE KvR Mttl Z7T-23SS May 14, 1979 Environmental Protection Agency Attni Hearing Office, HE - 14? , Region IX 215 Fremont Street San Francisco, California ?4l05 Subject! Consents for the Draft EXE, Treated Vtaatewater Disposal Program - for inclusion it> the public record of the Hay 16, 1979 hearing. To numbers of the U. S. Environmental Protection Agency and the South Bay Dischargers Authority. We are two biologists who have long been interested in the biology and environ- mental quality of the San Francisco Bay and especially the southern portions of that bay. Dr. H. Thomas Harvey has been studying the marshes of the Bay since the late JJJ^'s and I have been studying tha Bsamala of those sans marshes since the early 19^0'»• He has carried out the earliest and most of the marsh restoration experiments in the bay while I have specialized in the rodents, especially the endangered Salt marsh harvest mouse. We, and other professors here at San Jose State University,have become aware of how little fresh water Marsh has survived tha lest two hundred years of human occupation. Host of the salt marshes (over 60JJ) and almost all (over 95$) of the freshwater marshes have dissapeared, and with the latter the breeding grounds for such birds as the marsh yellowthroat and the hatching ground for the ducks who atteapt to breed in the Bay area. These ducks require freshwater for their young during the first few days of their lives. With- out it their clutches are dooaed to early deaths. The diversity provided by fresh- water marshes are almost a thing lost and forgotten. There are valuable freshwater or near freshwater areas left such as that at Artesian Slough near Alviso. That area supports large numbers of birds and is freshened by the outfall of the San Jose and Santa Clara Water Quality Control Plant, now an advanced secondary treatment plant. Waters from that plant may soae- day In the future be used alao to create a new freshwater marsh in the Hew Chicago Marahf a portion of the San Francisco Bay Wildlife Refuge located adjacent to their new Alviao area educational center. Waste water cleaned to the extent that the Ssn Jose plant now does with its nitifieation and multistage filtration appear to be adequate for use in the creation of such a freehwater marsh It is for these reasons that we support Option #4 of the Draft EXR which we understand to call for the outfalls to regain as they are at the various South Bay plants while the quality of the waste water is to be upgraded, we assume to the level now at the San Jose plant. We request your decision in favor of this fourth option. Howard S. Sho11 hammer H. Thomas Harvey Professor of Biology Professor of Biology THE CALIFORNIA STATE UNIVERSITY AND COLLEGES Submitted by: Dr. Howard S. Shellhammer and Dr. H. Thomas Harvey School of Science, Department of Biological Sciences San Jose State University Washington Square San Jose, California 95192 Dated: 14 Hay 1979 Response: The selected project alternative {No Further Action) assumes implementation of advanced waste treatment at all member dischargers' facilities which has recently taken place and ensures continued discharge In the area. A further upgrading of treatment (as in Alternative 4 - page 193 of Draft EIR/EIS Technical Volume) could be considered should an approved monitoring program show Insufficient protection of beneficial uses (see•also response- to County. Sanitation District 4, item 8, in Section 2.2). At this time, Alternative 4 has not been selected due to its high cost and slight, if any, improvement in water quality over the other alternatives. Use of San Jose/Santa Clara effluent in the creation of new marshland at the New Chicago tlarsh element of the San Francisco Bay National Wildlife Refuge, or elsewhere, is not -precluded by selecting No Further Action. As mentioned in the response to County Sanitation District 4, this may be defined as a beneficial use. 81 ------- Son Jose'State Uniuersty SAN JOSt. CALIFORNIA MII2 SCHOOL OF SCIENCE Dr. L Richnrd Atowvtdt Avtan Biology Laboratory San Jow St«t» Unlvgrtlty StnJow, CA95I°2 Itoei 377 30l« AvtAM StOLJCMkY 14 May 1979 MEMORANDUM TOi Environmental Protection Agency Attni Hearing Office, HE-149 — Region IX 215 Fremont Street San Francisco, CA 94105 FROMi L. Richard Mewaldt, Ph.D., Professor Emeritus of Zoology, Avian Biology Laboratory, San Jose State University SUBJECTi Resolution No. 73-16 — South Bay Discharges I with several of my co-workers, former students, and students have since 1953 concerned myself with several aspects of the biology of the vertebrates, especially birds, of San Francisco Bay and its surroundina marsh lands. These studies have resulted in many agency reports, theses, and papers published in professional journals. These works were accomplished with the cooperation of the California Department of Fish and Game, The U. S, Fish and Wildlife Service, and the Leslie Salt Company. An overriding concern of these studies has been the acquisition of general and specific Knowledge to better manage the wildlife resources of San Francisco Bay. Our goal has been to maximize biological diversity and wildlife values. We have assumed that inhancement of these values will benefit this and future generations of mankind. During this 25-year period of our concern and hopefully constructive influence, progress, although frustratingly slow at times, has been made toward attainment of some of these goals. However, in the matter of preservation of the primitive and once extensive fresh and brackish water fringe marsh lands of the South Bay and the species of plants and animals which inhabit them, we have continued to lose ground (= marsh). We now have the oppor- tunity to reverse this trend and with careful management restore at least some of the fresh and brackish water marsh lands with the vastly improved quality of water being discharged from the San Jose Sewage Treatment Plant. I strongly urge adoption of Option Four (4) which I understand calls for staying with present outfalls (at least for the present) and for continued up-grading of water quality to at least advanced secondary treatment. This option will permit the several concerned jurisdictions, including the San Francisco Bay National Wildlife Refuge to variously use this reclaimed water for the restoration and enhancement of our wildlife resources and thus the improvement of the quality of the life of the people of the San Francisco Bay Region. a/c THE CALIFORNIA STATE UNIVERSITY AND COLLEGES Submitted by: Dr. L, Richard Mewaldt Professor Emeritus of Zoology Avian Biology Laboratory San Jose State University San Jose, California 95192 Dated: 14 May 1979 Response: SBDA and EPA have selected Alternative 2 (No Further Action) and the present outfall locations will remain in use. The present level of treatment is advanced waste treatment at all SBDA facilities". Alternative 4 (Upgraded Treatment) postulates further upgrading but due to increased costs with little, if any, improvement in water quality, this alternative was not selected. (See also response to Drs. Shellhammer and Harvey in Section 2.2.) 82 ------- SANTA CLAHA COUNTY CAHNERS ASSOCIATION 1007 "L" STREET SACRAMENTO. CALIFORNIA tHIt AREA CODE (lit) 4M-1HO May 15, 1979 U. S. Environmental Protection Agency Region IX Attention Hearing Office (HE-14) 215 Fremont Street San Francisco, California 94105 Gentlemen: The following statement is being submitted by the Santa Clara County Canners Association. Our Association is a non-profit organization formed 40 years ago to provide a forum for discussion of problems and opportuni- ties common to our industry. Currently, most of our activities center around the ever expanding load of federal, state and local regulations that adversely affect our capacity to efficiently produce food products. Our Association represents 8 companies, operating 14 canning factories, employing approximately 12,000 people and having a 1.4 billion dollar economic impact to Santa Clara County. So there can be no confusion as to our position we will state at the outset that we are adamantly opposed to the construction of a deep water outfall, or any other alterna- tive being evaluated that will force the South Bay into compliance with the State Water Quality Control Boards resolution 74-73, which bans discharges to the San Francisco Bay south of Dumbarton Bridge. It is this resolution which needs evaluation not methods of implementing it. The discharge ban in question was adopted by the State Board five (5) years ago and is responsible for over 100 million dollars of advanced waste treatment facilities being construc- ted in the cities of San Jose, Sunnyvale and Palo Alto. Now we are being asked to evaluate an additional 100 million dollars for a pipeline or some other alternative to comply with an arbitrary and capricious ruling. The EPA, in order to further evaluate, advance waste treatment programs, commissioned the Vertex Corporation of McLean, Virginia, to prepare a report on "An Analysis of Planning for Advanced Wastewater Treatment." The report, published in July of 1977, covers the planning that went into decisions to construct advanced wastewater treatment facilities in six (6} areas of the United States, of which San Jose/Santa Clara was one. We quote from that report: "Costly pollution control projects are commonly built with almost no real knowledge of the waters that are to be protected by the generous investment in treatment facilities." Referring specifically to the South Bay, we quote further from the Vertex Report. "December, 197S, Hydroscience publishes another mathematical model. Like the last (February 1972), it is a mosaic of oversimplifications and guesswork." "When the earlier models showed that construction could solve a problem they were accepted at face value. However, when the 1975 model showed that no amount of construction would work, State officials began to examine the model for unwarranted assumptions, inadequate verification, and skimoy data. This belated discovery of weaknesses in mathematical models has been costly." "The San Francisco Bay Regional Water Quality Control Board could scarcely be expected to rejoice in Hydroscience's new conclusion; viz, all previous planning for the south bay has been fundamentally wrong. For the first time the Board has critically examined a mathematical model for the South Bay, and it is found wanting. Had the Regional Board been equally critical of the earlier models and studies, it might never have gotten into its present fix." Today we find ourselves saddled with advanced wastewater treatment facilities in San Jose that are in themselves environ- mentally unsound, due to their enormous electrical energy requirements (more than our 14 canning factories combined). 83 ------- Much of what has occurred in the South Bay has taken on the appearance of a "Gold Rush" by consultants and municipalities for EPA funds. It is about time we pause and evaluate the damages and possible benefits that have accrued from this uncoordinated and uncontrolled growth in waste treatment. The Food Preserving- Canning industry has long been a vital and important- segment of Santa Clara County's business community. 'We have actively and supportively participated in •the past wastewater programs in San Jose and Sunnyvale; i.e., primary treatment in 1956, Secondary treatment in 1964 and expanded Secondary treatment in 1974. In each of these cases the need was apparent and benefits well identified. However, with advanced waste treatment and now this potential "Super Sewer", the need and benefits have never been demon-. strated or justified. Respectfully submitted. Very truly yours, SANTA CLARA COUNTY CANNERS ASSOCIATION Robert Use President cc: File CALIFORNIA CANNERS and GROWERS P. O. Box 60669, Sunnyvale. California 94086 84 Submitted by: Santa Clara County Canners Association 1007 "L" Street Sacramento, California 95814 Dated: 15 May 1979 Response: EPA has evaluated the Vertex report and subsequently initiated the policy that any Advanced Haste Treatment (AWT) project(s) costing in excess of one million dollars must be reviewed by both the EPA Regional and Head- quarters Offices. If recommended, the proposal(s) would then be submitted to the EPA Administrator for his personal consideration and review. This procedure assures that only AWT projects with special need will be consi- dered for funding through the EPA construction grant program. The modeling performed as part of this program provided the data which indicate that no outfall relocation is necessary. Our studies show that possible improvements may result from implementation of the Basin Plan Alternative, but that these improvements may not be significantly greater than with other actions. Therefore, SBDA and EPA have selected "No Further Action." We anticipate that future monitoring of the South Bay will establish the level of improvement gained from AWT facilities and any problems still remaining. ------- United Stitei ; Department of Agriculture Soil Conservation Service UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE »88 CHILES ROAD DAVIS,CAM61« May 8, 1979 Paul DeFalco, Jr. Regional Administrator U.S. Environmental Protection Agency 215 Fremont Street San Francisco, California 94105 Dear Mr. DeFalco: We acknowledge receipt of the draft environmental impact report and environmental impact statement for South Bay Dischargers Authority Treated Wastewater Disposal Program. We have reviewed this document and we find no apparent conflict with any Soil Conservation Service on-going or planned programs or projects. Neither the Basin Plan (Alternative #1) nor Alternatives t2, #3 or 04 will result in the loss of prime agricultural land. However, Alter- native fl5, reclamation of wastewater from the SBDA treatment system, and the reuse of this water could have a further Impact upon prime land and upon existing conservation aystems, beyond that discussed in the EIS. If Alternative #5 is chosen, the EIS should be expanded and specifically describe the wastewater reclamation and reuse project in detail. He appreciate the opportunity to review and comment on this proposed project. Sincerely, FRANCIS C. H.-LUM State Conservationist cc: R. M. Davis, Administrator, BSDA, SCS, Washington, D. C. 20250 Director, Office of Federal'Activities (Kail Code A-104), Environmental Protection Agency, Room 537, West Tower, 401 M Street, S. W., Washington, D. C. 20460 Submitted by: U.S. Department of Agriculture Soil Conservation Service 2828 Chiles Road Davis, California 95616 Dated: 8 May 1979 Response: We have selected the "No Further Action" alternative and this alternative will not affect agricultural land. However, SBDA and EPA will look care- fully into this and other impacts should they become involved in reclamation projects in the future. Thank you for your advice concerning the potential adverse impacts of reclamation and reuse of wastewater on prime agricultural land. 85 ------- SAN JOSE /SANTA CLARA WATER POLLUTION CONTROL PLANT I'.y BV E.p.A IX CENTER ADMINISTERED BY 1C ::i«iA»'79 May 16, 1979 Environmental Protection Agency Region IX Attn: Hearing Office (HE-149) 215 Fremont Street San Francisco, CA 94105 CITY Of SAN JOSE DEPARTMENT OF PUBLIC WORKS CONTRIBUTING AGENCIES Clf V Of SAN JOSE CrTV V «ATA ClAftA COUKTV SANITATION DIST. NO. 7 COUNTV SANITATION OIST. NO 3 COUKTV SAWTATIO Dt$T, NO * eiT<««CM»MLL.U»GAT0l. «OMT« ttMMO M» IMATOCA •UMBANKSANiTAftyfllSTritCT CUPtftTtMQ SANITABY ONtftlCT cnv 0» GVtntHO MILPtTAS SANtTAftV DSTHICT «mr g* Miiriru HMOi SAHIT AliV OATHICT Environmental Protection Agency Page 2 4. Improvements in toxicity levels of the South Bay Waters may be achieved more cost effectively through emphasis on toxicity source control programs. Therefore, in the opinion of the San Jose/Santa Clara Treatment Plant Advisory Committee, there is a minimal cost/benefit relationship for the South Bay Waters to continue the project for construction of transport facilities. The adoption of the "No Action" alternative is recommended. RE; South Bay Dischargers Authority Common Conveyance Facility x~r-~ ---- ^ ^. ^.' • ~ DWARD T. RAMEY, Chairman Treatment Plant Advisory A. R. Turturici, Deputy Executive Director South Bay Dischargers Authority The San Jose/Santa Clara Hater Pollution Control Plant provides wastewater treatment for the Cities of San Jose and- Santa Clara; the Milpitas, Cupertino, Burbank and Sunol Sanitary Districts; and Santa Clara County Sanitation Districts No's. 2, 3 and 4. In accordance with the terms of various contracts, these agencies are represented on a Treatment Plant Advisory Committee which advises the Administering Agency, i.e.. City of San Jose. The Treatment Plant Advisory Committee at its regular meeting on May 9, 1979, by motion, unanimously approved submission of a statement to the Environmental Protection Agency and the South Bay Dischargers Authority recommending implementation of the "No Action Beyond Currently Approved Improvements at the Treatment Plants" alternative as set forth in the "Draft Environmental Impact Report and Statement for the Treated Wastewater Disposal Program of the South Bay Dischargers Authority." A review of the "Draft Environmental Impact Report and Statement, South Bay Dischargers Treated Wastewater Disposal Program," indicates the following: 1. There is no assurance that there will be a significant improvement in South Bay water quality as a result of transporting treated final effluent. 2. Diversion of treated final effluent from the South Bay may result in salinity increases detrimental to the South Bay. (EIS/EIR Technical Page 146) 3. "Discontinuing a significant portion of the freshwater inflow into the South Bay will permanently remove the exist- ing freshwater habitat in the area south of the Dumbarton Bridge." (EIS/EIR Technical Page 169) 7OO (.OS ESTEHOS ROAD SAN JOSE, CA. 95131 TELEPHONE (4081 263 7550 86 ------- Submitted by: San Jose/Santa Clara Water Pollution Control Plant 700 Los Esteros Road San Jose, California 95131 Dated: 16 May 1979 Response: The studies did not indicate "no improvement" in water quality; in fact, the number of depressed dissolved oxygen episodes would decrease with some alternatives. However, a comparison of alternatives shows no significant difference in improvement among them or any guarantee of compliance with Basin Plan oxygen requirements. While source control may reduce toxicity (see response to County Sanitary District 4, item 4, in Section 2.2), there is no way to predict the amount of reduction, if any, or whether or not Basin Plan toxicity guidelines can be met with any alternative. 87 ------- Santa Oofo^ley Water District S7SO ALMAOEN EXPRESSWAY SAN JOSE. CALIFORNIA 9511S TELEPHONE (408) 265-2(00 6 May 17, 1979 Environmental protection Agency Region IX 215 Fremont Street San Francisco, California 9410S » Attention Hearing Office, HE - 149 Gentlemen: In the Draft EIR/EIS for the Treated Wastewater Disposal Program for the South Bay Dischargers, the recommended alternative is the "no project alter- native". It is our understanding that this alternative includes the following recommendations: 1. The present disposal points would continue to be used to discharge the upgraded (nitrified and filtered) wastevater for the time being. 2. While the discharge continues, extensive monitoring would take place to determine if these upgraded discharges have significant adverse effects on the water quality of the South Bay. 3. The viability of reclamation should continue to be investigated in the Regional wastewater Reclamation Study. 4. If it is found that these discharges do cause significant adverse impacts on the water quality of the South Bay, or if reclamation is found feasible, then construction of other disposal or reclamation facilities would be considered. Hhile this fourth recommendation is not stated explicitly, it is implied by the wording of the alternative. This alternative is acceptable as long as the fourth point has, in fact, been agreed to by the members of the South Bay Dischargers' Authority. We agree that the existence of a problem caused by the discharges should be demonstrated before the discharge locations are moved. We also feel that if a problem is demonstrated, then a commitment should exist to move the discharge locations. He, therefore, strongly urge that the final EIR/EIS contain a statement committing the dischargers to take whatever steps are reasonable and necessary to alleviate any substantive problems identified by the monitoring program. On Section V, "Reclamation and Reuse As A Wastewater Management Option" to make the following comments: we wish Environmental Protection Agency -2- May 17, 1979 The main assumption made in this section of the report is that 50,000 acre-feet of wastewater is to be reclaimed from the San Jose/Santa Clara Plant, and by a 1:1 blending with SB A, San Felipe, or Hetch Hetchy water, will create 100,000 acre-feet of blended water, with one-half of the blended water to be sent to agricultural markets in the South Santa Clara Valley or in the Bolsa area of San Benito County and one-half "returned to the current potable water market". Pertaining to a 50,000 acre-foot market for wastewater in South Santa Clara County, this figure was apparently based on a draft report published in 1976 by the State Department of Water Resources. Since that time, a 1978 land use study, conducted by the DBS for the Santa Clara Valley Water Reuse Study (DWR/SCVWD Coop study), indicated that at present there is only, at best, a market for about 20,000 acre-feet in the South Santa Clara Valley and that this market is expected to decrease in the future. In addition, this market includes about 7,000 acres of land comprising parcels of 10 acres or less. It is believed that it would not be cost-effective to extend distribution lines to such parcels. In terms of blending, the DWR studies indicate that a 4:1 blend with San Felipe would be required to meet the quality requirements of the soils in the South County. We question the overall "effectiveness of the alternative of adding acid to your 1:1 blend of SBA or San Felipe water to further reduce the bicarbonates and the SAR of the water and gypsum to the Hetch Hetchy water. Aside from the question of expense, what effect on other water quality parameters would be affected by such treatment? As far as "returning 50,000 acre-feet of blended water to the potable water market", it is not possible to develop reclaimed water for potable use because of public health department concerns. If the intent (not described) ia to use the reclaimed water for acceptable markets thereby releasing potable water for domestic use, we question the location of such a market. The Hetch Hetchy Aqueduct water is used mainly as a potable municipal supply; blended water could not serve as a substitute. In addition, while your indication that "South Bay Aqueduct or San Felipe water could be diverted to supply a portion of the market supplied by Hetch Hetchy water" is physically possible, such an exchange could require either major expansions to the District's import, treatment and distribution system or to the distribution systems of the various retailers now taking Hetch Hetchy water. In the North County, there does not at this time appear to be a feasible market for 50,000 acre-feet of blended water. The District's Hilpitas Reclamation Study identified a maximum potential market of 20,000 acre-feet of direct (unblended) reuse for industrial and landscape irrigation uses, on the assumption that much of the area would be developed with dual water systems. Concerning the economic considerations, the information which the District provided Bechtel on the costs of projects according to the District's pricing policy is accurately presented in the report. The conclusion of the report that the San Felipe Project alternative is less expensive than the reclaimed water alternative - even with 87.5% financing - is still correct. Si: David K. GUI' Water Supply Planning ^Manager AN AFFIRMATIVE ACTION F.MPIOVER 88 ------- Submitted by: Santa Clara Valley Water Distrtct 5750 Almaden Expressway San Jose, California 95118 Dated: 17 Hay 1979 Response: SBDA will, after completion and approval of the Final EIR/EIS, petition both the State Water Resources Control Board (SWRCB) and the Regional Water Quality Control Board (RWQCB) to establish conditions for exemption to the Enclosed Bays and Estuaries Policy and the Basin Flan (see also response to County Sanitary District 4, item 8, in Section 2.2). In the analysis of reclamation/reuse, the Blended Water subalternative would result in 100,000 acre-feet of water, 50,000'of which would be used in either the Santa Clara County or San Benito County markets tentatively identified in Chapter V.3.1 (page 218 of Draft EIR/EIS Technical Volume). We recognize that the remaining 50,000 acre-feet could not, under present restrictions, be placed in a potable water supply. As stated on page 245 of the Draft, this blended water supply would be limited to that portion of the San Felipe market now earmarked for irrigation, or a new market would have to be identified. If the identified Santa Clara Valley market were reduced to only 20,000 acre-feet, then additional markets would have to be selected or the reclamation amount proportionally reduced. (This issue is briefly discussed in Section V.6.4 of the Draft, page 266). Our analyses indicate that 1:1 blending of reclaimed and San Felipe water would be sufficient for most crops now being grown in South Santa Clara County and, in addition, would reduce the cost to the farmer. A 4:1 dilution would further improve water quality but would limit feasibility (see page 245 of Draft Technical Volume) since such a blending would result in 250,000 acre-feet of water limited to irrigation use in an area already limited as discussed above to smaller (about 50,000 acre-feet) markets. With only small decreases in cost due to: • Slight decrease in crop damage or limitation • Slight decrease in cost to the farmer of reclaimed water over subsidized $17.00 per acre-foot estimated for 1:1 blending Since Santa Clara Valley would not likely purchase blended water (see Table V-25, page 262 of Draft Technical Volume), the higher blend ratio does not appear on review to be cost-effective. Addition of acid or gypsum to reduce bicarbonate and adjust the sodium absorption ratio (SAR) allows reduction of the blending ratio to 1:1. In comparing Tables V-9 and V-16 of the Draft Technical Volume (pages 223 and 245, respectively), it can be seen that addition of gypsum to 1:1 Hetch Hetchy blend reduces SAR by half while Ca increases slightly over unblended, untreated waters. Similarly, addition of acid to either 1:1 San Felipe or Hetch Hetchy blends reduces both SAR and bicarbonate signi- ficantly; no increases are noted in other elements of concern. We thank you for your expression of concerns; EPA and SBDA will continue to explore these issues should they ever engage in fulrther reclamation studies. 89 ------- OFFICE OF THE SECftETARV RESOURCES BUIUDING 116 NINTH STREET (9161 W5-5656 ChHUrtnwnt ai fW* ma G* QWprtm«rtl of Forvitry Onrtm»nt of N««iwt)on i OCMR OftVtlOariWIt t)partmnl o) Pi»k» nd R« Department of WM«r Rneur EDMUND G. BROWN JR. GOVERNOR OF CALIFORNIA Httturtc* Centtmtlon i R9ion«J WM.( duality Control Boirdt San rnnclKO Biy COnwvjlWn «Ad OvwtioQnwnt Comnnlwtan Solid vv«t Management Bond StMJ Coaail CODMTVJllCI' Slit 4-n« CommliUon 5t«« RKlMMMQn Boifd $t«t* Wil« AitourcM Control Bo»n3 of California Memorandum To : Huey D* Johnson Secretary for Resources 1416 Ninth Street Sacramento, CA 95814 ."h« Resources Agency THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA Dote: Hay 17, 1979 Attn: L. Frank Good son Projects Coordinator (toportimnt of ffih and Gome MAY 1719B Mr. Paul De Falco, Jr. Regional Administrator Environmental Protection Agency Region IX 215 Fremont Street San Francisco, CA 9^105 Dear Mr. Be Falco: The State of California has reviewed the Summary, Draft, and Appendlcles—Environmental Impact Report and Environmental Impact Statement South Bay Dischargers Authority Treated Wastewater Disposal Program, which was submitted to the Office of Planning and Research (State Clearinghouse) within the Governor's Office. This review Is In accordance with Part II of the U. S. Office of Management and Budget Circular A-95 and the National Environmental Policy Act of 1969. We have attached copy of ell comments received from the Department of Fish and Crme, and the State Water Resources Control Board, Division of Water quality. We appreciate having been given an opportunity to review these documents. Sincerely, Attachment L. FRANK GOODSON Assistant Secretary for Resources Director of Management systems State Clearinghouse Office of Planning and Research l&OO Tenth Street Sacramento, CA 95814 (SCH No. T9040905) Subject: Draft EIR/EIS South Bay District Authority Treated Uastevater Disposal Program, Santa Clara County SCH 79040905 The Department of Fish and Game has reviewed the subject Draft EIR/EIS and finds It to be a well written and complete document vltb regard to potential fish and wildlife Impacts. However, we are concerned with the potential impacts on the South Bay wetlands and that compensation for the impacts of the various alternatives is Insufficient to offset construction and/or operational disturbances* In addition, as proposed, the project may conflict vith the 1976 Wetlands Preservation Act and the Resources Agency(s Basic Wetlands Protection Policy (copies attached). We offer the following specific comments for your consideration: ® ® 1.1.5 ALTERNATIVE ALIGNMENT TO BASIN FLAK ALTERNATIVE (page IS) It Is our understanding that although the estuarine alignment from Sunnyvale northward will not significantly add to project costs. It is not currently proposed due to uncertainties of equipment availability, levee integrity and potential delays in construction. It is further stated that "...maintenance an repair of an underwater pipeline would be more difficult than for a land conveyance...". We certainly recognize and appreciate these considerations, yet since the land route alternative transverses valuable marsh-wetland habitats, the uncertainties fire just as great, if not greater, for the shore- side alignment. Even though the marshes would be restored after construction. It may take years to return them Co their pre-project productivity. With the possibility of periodic maintenance or repair of conveyance facilities, the marshes may never fully recover. For this reason, we recommend further consideration be given to the estuarine alignment. In addition, routing the pipeline through wetland habitat appears to be In conflict with the Basic Wetlands Protection Policy since a less environmentally damaging alternative Is available. 1.2.3 CONSTRUCTION OF THE BASIN PLAN ALTERNATIVE (page 25) "Typically the construction easement would be ISO feet wide, and the trench deep enough to allow four feet of cover over the pipeline. Top soil would be separated and stockpiled for use in restoration of the right-of way after construction is completed." We recommend special consideration be given to 90 ------- Huey D. Johnson -2- May 17, 1979 restricting the construction corridor within tnarsh areas to not more than 50 feet. Areas set aside For the stockpiling of excess spoil construction equipment and materials should be located outside of any wetland area. ® ®l III. 1.1 CONSTRUCTION IMPACTS (page 130) The report states "...The pipeline corridor storage area and access route will be returned as closely as practicable (emphasis added) to original condition at the completion of construction...". He believe that a more thorough discussion of construction and especially restoration techniques to be employed within marsh areas is warranted to better evaluate short- and long-term impacts to marsh residents . flff. J31 - Water Quality Discharge of water from truck dewatering within marsh areas could have a serious impact on fish and invertebrates and thus wildlife as veil. We recommend pre- discharge analyses be conducted to determine necessary measures to prevent further degradation of marsh habitat. Page 134 - Segment I - San Jose/Santa Clara Treatment Plant to Sunnyvale Treatment Plant The need for "destruction" of one acre of salt marsh harvest mouse habitat should be further explained and offsetting mitigation proposed. ------- ft c S7vc* r a :; ;: u ir. ; DjiJ-'uM-ir:.-:1.!. L'i rectors. MKCeutivo Off i cjijn; (;/ Bc&rU.t ;< COi'.;:ii.i snirms !>••»-• • SCiM 9 1377 file Ho.! Subject: Kutiandn Policy for Proposed Construction Proj'..: H' i JV\|>;u-i inon'c Directors, Executive. O;"ficori: of Bourd:; i. -2- •or influeiv.,-i.:!B_—• Secretary fo" Resources 92 ------- CHAPTER 7. WETLANDS PRESERVATION [MflVVJ -. Sec. 0810. Short tiile. f:S>J. Lc?is!,itin' finding-; Mini ilcdrtnttl'in. 5S12. Di'fiuiiit.tis. 5813. AMui'lIion <)f ri-nl \|ir.ii»Tly intcn-xts «>f \ty* Hum do; furttii.'i >>!»•«• of j.liliiie imorvsl ; «Mi>nniii:iir. f-SM. .Ty-%' ; !\:d;.- ; (<"-.^-:-.i.'«o!! -•. ilii <-;!;..>. fo.ifiCu-* .011 l:Um < •>,i-n»i>'~iini : iii;ii»; liriority • : siilijni.-;-k;ii to I'-^i.-sl.-dMN-. r»S!,">. I;.'"Ct-^:it!U»n of ]»!;!»- am; p.'i'in.-iuK of \|.».-:j i.mnrir^; i-o'.»jwi.-i:tv- i!;t-,-!it. r»S,(i. W-U;ll'oV tviltiili or ;tdj.fvnl lo r-visliiJX ;>.ti'!. .-j.-li1!)!: fi-asiltirly uf ::i'in;.-ii- li.ili'< ::< 10 mallaj:, mi'iil. l't..l,Tlioll. iili-.M-rv.il,. .h mul iv.il. &SI7. OjieratiUK «RfCiMlmi;ts utlti l-K:ai aj:<'uci'-s ; eumlititMis; fi!i aud palm- n'U'l- laltoa.-i. f'SlS. Property AcquMUon La\v; aj.jiliraiion to d';• i 5810. Shut title § 5813 (A	y Sjais.i'.itfi, c.-lfti. \|>. 11'Jti. 5 I.I ! 581 1. Legislative tini<{nqs anrt ilcck.ratlon Tins I^-tiisLiinfo l»-i-i-l:».-.ii>fly rrili":i) m>> ..... lii. :»'Mhi.iir, ;n:il >"»-niifir v;ilm' I" I pL-nph1 of I'.-ilifoiuia, :in4 l!);il ihrr-1 i^ )»-i.ft fnc nn jiff jr»n:iliv .imi >Mjs);iiui''l i)iji jioliry r.nil \|ir.i^ri»n 'ii». j» order UKJ\| MH-II u-i-iKujiJ.s v}t;,}i rontiniH- in jt. IJH iuif.v lo iii'-r! Ihi- Ui«l}s of < 5812. Definitions A.s uxi'd it! this t-hajih'r, unN- - (Ic- " liiriuis yU'cnniN, rlinjtui'l-'. );i!:'.>c. r"^«Tv.iir>. i>:tv<. ».-ln:irif<. I:i- Cotni^, lh:its!n-i, jind tlM- J;i:ul> tntil -ilyin^ ;util ::i!jn!!Hii!r sin'b v.::t>'i'N wlirtiit-v l»-riliaU'->lll.v or ihli-i-imllonily v.\|.i»i r^i'il. In liic csl'-lit ll:nl .»!«•!> v.'a!iT.i and IKIH):< support :unl <-i':;lail) si^nit"tr;itil J'ish, \vi)(!lifi-, lcci^:i(h»l:il, .'tc.^lljt'tic. f.r .-rifUtifie rfstiurct'-v (!i) -TVji:n (mi- n(s" luc:ili.< ",!ic \|if\|i:trliiit;il:u!l 1'litl the Ite- imvnncnl «f \|--ish and C!:im.'. (Adtlril hy ,Sl:ll-i.f.l?<;, p. 4CU, )>. 11'JG. 5 l.i Asterisks » • * Indicate deletions hy amemimtr.t 267 cf !-:':!);or nf thr t<>-p;jrluicul!< uuiy :v-i»in- iliti-n^ls n> mil \|ir,']»H-tv lix Uian fro, iii.-)»di:i}:. hill i;.;t Ihuit'-d Ms ar.piisiiiun i>f li'-i'i^-iiiiii''!!! ri^lsH. w:i.-n it ili^ lililH'^ lltrll ar/^iisilii.ii of such li'-ir.T JKh-rt1.-:! vi'iU :.. . i.jjij.HsIl Iti,- \|.'ll'( -v^i-s nf t cha!»f(T itl furt;\|..-l-U?;: llu- jHililir'^ iuloro^l in t}."1 j'ri'Ii'L-lion, jtrrM-rv:it!'.il, rf>t tivn. and ontuuto'inrnf 4(f wclland.-;. (A § 58H, Join! study; cooperation vilth cltis, counties rxriil lai'd cotnmlr-'i'cn; plan; priority sf.itus of firojccia; •>uf)mlss(«>ii to legislature lamls ut M«» ufatn u'h'uj!i arv suf'• 'n'1' >l li>r af-tpnsitjtiii ]-mjs!i:\iit tu Chi;; <i!H\|Mi-r. 't'nn stijtiy vhntl N- NiiUnuuinl In tlu- (,v;ii^l:il«r»' not hn-T ttuiu .htiiMHcy l"», l!7>», :in»l ^IstUi w-1 ft'ttli, fur n>u-jit(t-rittitni (»> jt.f t^-vi^liuur.', :i j.V.tu for (!n> :u"j»ti"'''i. i(l"°" U'Clinn, pVi'St-i-VDlti'ti, rt'Morii'.MiH, -'i^il i-ii!i;ittct'iiu-ut nf \vt't!;tmU, i :;'•!!;• ti:itf flilirl- in^ n-\|iiirri»»'ijls ;t»!l tin: \|>n>ri!.v -l.-d.iis »f si^dfic jii'tifiusctl wHhinils pn-jtcfs. (Au.k-a by st!Us.!!»;n, c, -io-j. i>. i\\>, 31.) 5 -VH5. ftccasfi!t(«?.'t of plj?s n«\| pr.i\|jrnms of local .tfiir-clfls; coopcr.Klrfl means TJ;i> (Icji^rtnit'iU.'N in pivpiirinj; ii:i- »vi-il:u:«l-t ^rinrirv M!:I» iui«i j>r";-.i-,\::i j-iir^uiuU jmd oj(i-;i-;(i;ti'i' itt.-ur; ,nnl j»ri'Tr.i),is oi" 3(w;il n-ii-nt1 Uii.l irj»l»j>ri;ur, iiJ.-iHify :uiil ili-.-L-v «.i.,tM- r.U ivi- («ri»J..'c(ii)!i n.'i-'l \|>rt'S"rv:»thfii cal :i^i-i3c"ri:^ ''.n,'-C wtlMtt. tr ;nJ.i;;t n:t t"t >'\is;iiij: un:!1* ttf thp ti'»» itcCfi"n «iul \|triS"rv;ttum, W4tlm>?l cnvillnjt (AtkUnl by StiUs.tHT«. ami illstrl'is f:u tin- uialla^i i™->rt asnl runtml of vrrlhuubt, -r lull-rest* In vvvl!:iiil i>iii>i"iMI ID tliifs rhapu-r;- \|.r.>\ j.l.-il, t\awcv<-r, tiiai any socli Htfr'.'f-oirul s)ntH riisti.'e Oa! jiru.'.-i lioii ami prr-N-rvatlon o* Jlie \vrMaml, vtntl tin- . the right to I'lf nsi- and (•nji-ymciit uf siicJi wnlnuds by ifce- IH-OI-'H- m' Hi,: stntc; and !»»oviflwl, furihi-r, that any sm-h ;tj:jit'MH'iit rjitrrrnl inui hy ilif T.i(-;::trinit;nt of Ki-h ami Cnnuf \|n!i>-iiane to tills Mt-tlun xlmll \|irmi.ti' as well fiat i^iblic use of lamlx ami !>nll IK- sulijvct «<> (hi- I»mpcrty Aciiiiisitioii ijn»- d'art 11 (cou'.im-iu-ihs with Sccliuu 1".S."4i), iJlvidon •'!. Title 2 of th« InJVfl-WMK-rit r'udl'). (.\i!iUtl bjf Stiits.lPTO, c. 4CL', p. 11W. J 1.) 93 ------- PUBLIC RESOURCES CODE § 5823 CHAPTER 8. MENDOCINO WOODLANDS OUTDOOR CENTER [NEW] Sec. n820. Short title, S821. Legislative findings. B822. Legislative Intent. 5S23. ] icfloitloas. R824. Jurisdiction and control of center ; title to lands and facilities. 5X23. Department plan. SKA. Consultation and cooperation. 5827. OjK'rnting agreements. 0828. Adrlsory committee. 5S29. Sale and cutting of timber. '.'hapter 8 icai atdtd In Stall. lS7t, e. 1301, p. Mij, S J. S 5820. Short title This chapter shall It- known and may bu cited as the Mealociuo VaodlaiuU Out- door f.ViiH-r Act. (Added by Stats.lS7C», c. 13ul, u. ^fS-l, S 1.1 Library Reference \Vt,oOs JjJ Forests C21 t'.J.S. \\'ofi!i and Forests !J 1], 12. § 5821. Legislative findings Tlie If^lnturt fiui!.< t!"i! tliCT.- i llrei! fi.r :•. prutrniin m lli:iblf >!i" rhhilfr.i i,-f :)>e siat* i.. better wmi-r-'icnd tlir outii^ix part:fi!nrl.v ;«u vm:::il :iinl MviMiilc ':n>- pnrT:iJHr of the study, toMSi'Tvutiori, protection. iimi lit The Legislature flirt IHT flllcS that Ilie ii.ratjull iiiit! fip- lands imidHor Outer ;iri. i-sperially woll -uiti-d to wrw iirUiiaciiy us ;iu .iru oducitri'jji (-outer tinder thi- cunirol ;ind mu rtiigetucnt of thr: Pppartnitint of Parks l(ciTi-:itiuii. as u iliiH of tti" sli:ti> purk ^y-iieni lAddcd hy stats. I97r.. >:. i;iui, p. ;»54, s l.i Submitted by: Department of Fish and Game State of California un of i;ntnr:Ll iv~»j':<-ci!i. uf :!!•• .Mi liiiocin-i Wood- 5£22. Leglilatlv Intent Ti.c ;.i'iU!iid:iv hiT. hy for plll>!if ;:•::!;. n-;Ti';U]..iJifi!, (Added hr .Stat>.l9r:irks and U-i-iiio \V(Ki'il!i!:-I- Olit- Miit" nf CT::!ft.:-iii:i i>y !t:uJ t'oiL.srrv;!!-..:; jvir- l for rhv t;t^ffit .-f (ho ..';lufitti(/ii faciilty, i different K:e:inin :uri";. innri- cr H'?s-. -.f stilt- i,wnpd l;iml iinil inirtrDVi-iiiont.^ lf>C:U-.'rt within Ih'f (.'list hr.lf tit the N"-tlici:'..-t liulf of t!u> Southeast Quarter .nr Si'r ;ion T.< of the C:I-;T half :::nl soutliw.-st inmrTi-r of thi- Northeast (jiuirt'T .ir:'! :!]•• f:isl half and Miiithwcst tMtJj.'ter of the Smithen-Jt t>uarier of S- ctiou 1M •.( T. 1T N.. U. IT W.. .\!.U.B.M. : tlr :;orth half and southv.-est quarter of tin; Northv.t'st Qriirti'i' aral the north l.ulf of clu> Nunhtvt Quarter of Scctinn li of, and the went U-ilf of tin- Nirihw .t gin-.rter of SiMtion '.V> of. T. 17 S.. It. 16 W., M.n.B.M. (i^ "Area" menus the Mi-ndocino Woodlunrt- ^ie!al TreiititKT.t Area wtlhin tile Jnokson 8biti> Fore»r, .onsistica of ^,KO ucros, mon- or less, of state-owuod lands If tun n'ithln t:.e sotitli linlf of Section 12 of; the Northwest Quarter, the west half of the Northeast Quarter, the west half of tbe Southeast Quarter, and the Sutith- west Quarter of Section 13 of, the Northeast, Southeast, and Snuuiwest Quarters of SwlioD 14 of, the nurtbeost quarter of the Northeast Quarter of Scctloo ±J of, the north half of Section 23 of, the Northwest quarter, the northwest quarter of tbe Xorthcast Quarter, and the northeast quarter of the Soiithtrest Quarter of Seciion 24 uf. T. 17 X., R. 17 W,. M.D.B.M. ; and the Southwest Quarter of i-ertlou T of ta..' soutlieaijt ujurter uf the Northwest Quarter, the Mouth half of the Northeast Quar- ter, the northwest, northeast, nnd soutlnvest quarters of the Southeast Quarter and the Southwest Quarter of Section 18 of, And the Northwest Quarter and nest half of the (Southwest Quarter of Section lit of. T. IT X., R. 16 W., M.D.B.M. (Added by Stals.l£l70, c. l.»l, p. 5854, i 1.) Dated: 17 May 1979 Response: EPA and SBDA have selected the "No Further Action" alternative and there is no construction associated with this action. Therefore, no impacts on wetlands will occur. 1. In the Sasln Plan Alternative, construction in wetlands would be limited to a total of 1.28 linear miles of salt marsh (Table II1-2, page 135 of Draft EIR/EIS Technical Volume). Portions of that marshland - Alviso marsh, El Dorado Street marsh - have been diked, and current use of the area as a landfill is reducing the marsh drastically. This use alone would likely result in a reroute of the pipeline should it ever be built. Sensitive marshland - Palo Alto Baylands - would be affected, but construction would occur in areas already affected by previous construction. In the alternative Estuarine Alignment, portions of the Palo Alto Baylands would still be affected as would Alviso and El Dorado Street marshes. The decrease in marsh land affected would be about 0.3 miles of previously disturbed, diked marsh in the proposed Bayland Preserve. Additionally, the uncertainty associated with construction in salt ponds and in the Bay (page 185 of Draft EIR/EIS Technical Volume) Indicates that the reported roughly comparable cost of the two alignments may underestimate the Estu- arine Alignment costs. This decrease' in affected marshland, compared with the potential increased cost and potential adverse impacts on Bay and marsh from breaching salt pond A-3, do not appear to be sufficient cause to select the Estuarine Alignment over the Basin Plan Alternative. 2. On pages 134 and 138, we mention that the trench would be limited to 60 feet and 80 feet, respectively, in sensitive marsh lands. This mitigation 94 ------- measure is restated on page 171, Section III.3.1. Stockpiling would not be in sensitive habitats (page 170, Section III.3.1). 3. Revegetation and surface restoration programs would be implemented (page 171, Section III.3.1) after consultation with experts. However, no revegetation program is instantaneous; therefore, there must be a recovery period allowed Cor in such plans. For this reason, we stated that the route would be returned as closely as possible to original condition, recognizing that exact and immediate restoration is not practicable. as a mitigation measure If the Basin Flan Alternative was selected. The quantity of such diversion would have to be worked out between SBDA, Fish and Wildlife Service, and California Fish and Game, and approval of the RWQCB would be required. 7. As stated above, revegetation programs would be formulated should construction be considered, and revegetation would reduce the time for surface restoration. However, complete recovery would not be immediate and would vary with location and the program chosen. 4. Trench dewatering, if required, would result in a stream of water being diverted to holding ponds for percolation or evaporation (page 170). These ponds would not be in marshland and discharges would not be per- mitted to marshes. If treatment were indicated, this option would be considered as an alternative. 5. The acre of Alviso Harsh "destroyed" would be that surface area over- the trench. It is in potential salt marsh harvest mouse habitat, although trapping activities in that marsh failed to Identify any of this endangered species. The degrading character of the marsh due to diking and an encroaching landfill may be responsible for the lack of salt marsh harvest mice; however, Dr. Shellhammer of San Jose University (as reported by Fradfcin, P.L., "The House that Snored," Audubon, Hay 1979, pp 86-93) has recently shown that these mice do occur in places where they have not pre- viously been detected, possibly indicating a highly tolerant nature not previously suspected. Therefore, before any construction would be-under- taken in such an area, a second trapping survey might be planned and, as necessary, rerouting of the pipeline should salt marsh harvest mice be identified. 8. Low oxygen levels during a transition period would result only if the discharge were removed from Artesian Slough, and freshwater adapted vegetation died off. ' A possible mitigation would be harvesting of the freshwater vegetation. Maintaining a discharge as in No Further Action will eliminate this transition period but cannot guarantee that no periods of low oxygen levels would occur. 9. Your suggestions are acknowledged and these mitigation measures will be considered should any construction be contemplated. 10. If SBDA and EPA had selected the Basin Plan Alternative, the partici- pation of Leslie Salt in the project would have been given full consideration. However, selection of No Further Action provides no forum for joint efforts at this time. . 6. On page 173 (Section III.3.2 of the Draft Technical Volume), the possibility of diversion of effluent for maintaining fresh water marsh in Artesian Slough and/or creating fresh water marsh elsewhere is proposed 95 ------- I He - Dat« St«.t» of California Memorandum To : Mr. L. Frank Goodson Project Coordinator Resources Agency 1416 Ninth Street 13th Floor Sacramento, CA 95814 From : STATE WATER RESOURCES CONTROL BOARD DIVISION OF WATER QUA1ITY Subject: REVIEW OF DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT (EIS/EIR) STATE CLEARINGHOUSE NO. 79040905, FOR SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM, PROJECT NO. 1135 This office has reviewed the draft EIS/EIR of this project, dated November, 1978. The Division of Water Quality hereby presents preliminary comments on the draft document. The EIS/EIR analyzes four "viable" alternative solutions to the water quality problems caused by the discharge of treated wastewater to San Francisco Bay south of Dumbarton Bridge. One alternative, the "Basin Plan Alternative", contemplates a large pipeline to collect treated wastewater and discharge it north of Dumbarton Bridge. Other alternatives analyzed are "No action beyond currently approved improvements at treatment plants", "Individual outfalls to Bay south of. Dumbarton Bridge", "Upgraded treatment with continued local discharge" and "Reclamation and Reuse" in Santa Clara or in Santa Clara and San Benito Counties. The EIS/EIR also analyzes a disposal system meant to dilute toxic bitterns from the operation of salt evaporating ponds. THE RfSOURCES AGENCY 17 ® ® Comment. General The EIS/EIR points out that none of the alternatives analyzed, with the possible exception of Alternative 5 (Reclamation and Reuse) will meet all requirements of the Basin Plan. It appears that a reclamation and reuse alternative can meet the national goal set forth in the Clean Water Act of 1977 (PL 95-217) "that the discharge of toxic pollutants in toxic amounts be prohibited." The letter of transmittal quite properly points out that "the viability of future full reclamation is being investigated in the Regional Wastewater Reclamation Study," Comments on the Reclamation and Reuse Alternative are presented below. Comment. Alternative 5 (Reclamation and Reuse) The EIS/EIR analyzes reclamation and reuse in-basin and in the San Benito Counties, not elsewhere. The choice of alternative treatment systems, specifically those parts of system B, C, and D that are meant to comply with the Department of Health Services (DOHS) requirements for spray irrigation crops with reclaimed water, lead to over estimates of the cost of reclaimed water. While it is true that Title 22 of the Admini- strative Code requires coagulation, sedimentation and filtration of effluent for spray irrigation, it also allows for equivalent processes. Hi-. L, Frank Goodson ® (D -2- Based upon the results of the Pomona Virus Study (PVS), DOHS Is accepting in-line coagulation preceding filtration as equivalent. The DOHS accepted alternative system is much less cos'tly both in terms of capital and operations and maintenance than the one used in the EIS. By using the more costly system, the cost of the reclaimed water is over estimated. We request that the appropriate changes be made and costs be reestimated. Comment. No Project Alternative The draft EIS/EIR tentatively recommends a "no project" alternative, or continuing wastewater discharges at the three present locations which are south of the Dumbarton Bridge. The Mater Quality Control Policy for Enclosed Bays and Estuaries adopted by SWRC8 in Kay, 1974, prohibits wastewater discharges to South San Francisco Bay below the Dumbarton Bridge. Although there is no provision for South Bay now, it is con- ceivable, and would be consistent with other portions of the Bays and Estuaries Policy that SWRCB would allow continued discharges of wastewater effluents if it could be demonstrated that each of the three discharges enhanced the water quality of the South Bay. Enhancement is defined as: 1) full uninterrupted protection of all .beneficial uses which could be made of the receiving water body in the absence of all point source waste discharges along with 2) a demonstration by the applicant that the discharge, through the creation of new beneficial uses or a fuller realization, enhances water quality for those beneficial uses which could be made of the receiving water in the absence of all point source discharges. The enhancement of South Bay water quality by continued wastewater discharges should be discussed in the EIS/EIR. Recommendations for" a monitoring program,to demonstrate enhancement should also be included. Comment. Water Quality Model Review of the Hydroscience Water Quality Model by SWRCB staff and Dr. Gerald Orlob has revealed that the model has significant limitations for evaluation of wastewater discharge alternatives. In lieu of the predictions of the water quality model, selection of a project alternative must be based on a comparison of the South Bay with other similar estuaries. It would be beneficial to include in the EIS/EIR a discussion of the long-term impacts of wastewater discharges and removal of wastewater discharges exemplified by other estuaries in the United States or Europe. Comment, Operation Impacts One adverse impact of removing the wastewater discharges from their present locations is the elimination of freshwater flushing and consequently, the disruption of freshwater habitat in the South Bay. What level of flow would be required to maintain this freshwater habitat? 96 ------- Mr. L. Frank Goodson -3- ® Comment. Economic Impacts The service charges listed in Chapter 3 of the EIS/EIR are only for those costs associated with the Basin Plan Alternative. To'understand the full economic impacts on the South Bay area, the existing 'service charges for each SBDA member agency should also be included in the EIS/EIR. As a funding agency the SWRCB reserves the right to make further conments on this report prior to granting an EIS/EIR approval pursuant to the Clean Hater Grant Regulations. Should you have any questions regarding this review, please contact Howard Wright at (916) 322-7734. Dunham Division Chief Manager - Clean Water Grant Program cc: Mr. Bill Helphingstine, EPA, Region IX Submitted by: State Water Resources Control Board Division of Water Quality Dated: 14 May 1979 Response: Thank you for your comments on the Draft EIR/EIS. You have raised several issues which we feel require in-depth response; however, the funding of additional studies which might answer these questions more fully is not appropriate at this time. 1. No response required 2. Section V of the Draft EIR/EIS was meant to expand on the option of partial diversion for reclamation in addition to another disposal system. In Section V, a range of treatment schemes was selected to reflect both Title 22 and agricultural requirements. This selection was not all-inclusive nor could it be in the context of an EIR/EIS. However, it does provide a range of costs and water qualities available in such an option to the extent that the environmental impacts could be identified and disclosed. The DOHS system you describe would be less expensive than subaltematlve B (but not less than subalternative A), reducing the cost of component 2 (Coagulation and Sedimentation Treatment) by some amount less than 20 per- cent of the total capital costs (see Table V-15, page 243, component 2). It would be necessary to redesign and reestimate the DOHS system to provide actual cost reductions as well as expected water quality. This type of calculation would be an integral portion of any SBDA project for reclamation for- Irrigation. SBDA is participating in the Bay Regional Reclamation Study and detailed design, costing, and assessment of acceptable reclamation treat- ment systems will' be a part of that study. In addition, a program to reclaim 2 ngd of San Jose/Santa Clara effluent for irrigation in the Milpitas area (Phase I initiated by SCVWD) has been undertaken and appropriate treatment measures are being considered in this study as well. 97 ------- 3. This EIR/EIS does not define enhancement of beneficial uses, although it does state that the existence of the freshwater marsh in Artesian Slough is a benefit to the San Francisco Bay National Wildlife Refuge. As such, maintaining this marsh might be considered as a condition for exception to the prohibition against discharge south of Dumbarton Bridge for San Jose/ Santa Clara (page 188, Section IV.2.2 in Draft EIR/EIS Technical Volume). SBDA or its member cities, after completion and approval of the Final EIR/ EIS, will have to petition SWRCB and RWQCB for exceptions to the Bays and Estuaries Policy and Basin Flan, respectively. In this petition, a claita of enhancement might be made, and the details of such enhancement would have to be spelled out. No specific monitoring program is being proposed at this time (see also response to County Sanitation District 4, item 8, in Section 2.2). 4. As stated In Exhibit III-l (pages 145-146 of Draft EIR/EIS Technical Volume), there are limitations to using a model to predict the effects of wastewater discharges. The model uses average values for inputs, is two dimensional in a four-dimensional system, and does not predict biolog- ical Interactions. Its use in this EIR/EIS was not intended for prediction; rather, using the same assumptions varied only changes in effluent and in discharge location, it was to be used to compare alternatives. If the assumptions are internally consistent, then the differences between alter- natives might be perceived. In this case, no significant differences could be shown for DO levels. This lack of difference may be due to one of two factors: • The model is not sensitive to the variation of inputs. • The Bay is not sensitive to the variation of effluent (AWT vs Upgraded) or discharge locations. Dr. G.T. Orlob, in a review and evaluation of the model which was conducted under a contract to the SWRCB, makes the following statements about the capabilities and limitations of the model: "The model has many attributes that make it a useful tool, among these ... its utter simplicity and the ease with which it can be applied." This simplicity and ... "the idealizations made in construct- ing the model are limitations in its usefulness for study of South San Francisco Bay." "The most severe restraint state." .. is the assumption of steady "The model is dependent on prejudgment of the patterns of net tidal circulation and on the corresponding water balance assumptions that must be made to satisfy continuity." "The kinetics of the model are much improved (over the 1968 model) and ... are consistent with the best theoretical and empirical evidence available." " ... the tradeoff between benthal demand and reaeration is still In need of resolution." "Calibration of the model to the mean salinity profile does not confirm the general circulation pattern in the South Bay ... since by adjustment of dispersion coefficients one can obtain virtually any profile desired." "Improvements in the techniques of calibration and sensitivity testing are needed so that the relative importance of the various factors affecting model performance can be objectively assessed." "The most serious shortcoming of the model that compromises its usefulness as an analytical tool is its inability to discriminate between alternatives ... simply because the model ... is not sensitive to alternatives in the same way as is its prototype." Therefore, Dr. Orlob has concluded that the model Is not as sensitive to the variation of inputs as is the Bay. However, he also states that there is insufficient information at this time to demonstrate the validity of this contention, and that his professional judgment is that alternative or supplementary techniques could resolve this issue. 98 ------- A literature review was conducted to identify reports of biological and water quality improvements that have occurred in estuaries where waste- water treatment has been upgraded. This search was selective, being tailored to estuaries or bays having physical and chemical characteristics reasonably similar to South Bay. Within this limitation, literature documenting upgrading of water quality and biological conditions is not available. A vast number of studies are available documenting deterior- ation of water quality that has occurred due to urbanization of watersheds and increasing waste discharge. The literature dealing with upgrading does not discuss locations having much in common with South Bay. W.T. Edmondson (1972) described the response of Lake Washington in Seattle, Washington, to removal of secondary sewage effluent. During the period 1941-1963 Lake Washington received increasing amounts of effluent from secondary sewage treatment plants. From 1963-1968, these effluents were diverted in a series of steps, and discharge of effluent to the lake was halted entirely in 1968. The condition of the lake improved rapidly and . sensitively with the changes in waste input. In summer 1971, transparency exceeded the 1950 condition and hypolimnetic dissolved oxygen was close to the level of 1950. The improvement of the lake is greater than demon- strated by data only. Lake Washington and South Bay differ in several respects: salinity, climate, freshwater inflow, and volume of wastewater discharge. The latter two are of particular importance. South Bay experiences a dry season and a rainy season. Average annual precipitation is 13 inches. In Seattle, precipi- tation averages 32 to 48 inches and occurs more evenly throughout the year. The quantity and seasonal distribution of runoff have an important influence on water quality in urbanized watersheds where flood control has reduced surface water discharge and where storm water runoff is typically of poor quality. Finally, wastewater discharge to South Bay comprises 40 percent of the annual freshwater inflow and is the only freshwater inflow in summer. Lake Washington now has no wastewater inflow, and experiences a high degree of natural flushing compared to South Bay. Recovery of the Thames River Estuary has been monitored. A major improve- ment in the quality of waste discharged occurred when a secondary treatment plant was installed. The condition of the middle, most polluted reach of the estuary, as judged by the dissolved oxygen content of the water, showed a marked improvement in 1964, a few years after the installation of the secondary treatment plant. In 1964-65 there was no anaerobic reach established at any time, a situation that had not existed for decades. The Thames Estuary differs considerably from South Bay physically, chemically and biologically. Other types of improvement are discussed by Pryblek (1977) for the Houston Ship Channel and Galveston Bay. In addition to improvement in BOD, dis- solved oxygen, fecal and total coliform, phosphorus, suspended solids, and volatile.solids, waste treatment implemented since 1968 has reduced dis- charges of cyanide, ammonia, phenol, metals, and sulfides. The latter group includes many compounds that exert toxicity on aquatic organisms. Among the effects of waste treatment that have been noted in the Houston Ship Channel is the apparent increase in the variety and abundance of aquatic life. Again, however, there are many dissimilarities between the Houston Ship Channel and South Bay. This report, as well as the others previously cited, may be read as a.general indication of water quality improvements resulting from upgrading of waste discharges. Due to the differences mentioned between these water bodies and South Bay, as well as differences in the nature of the upgrading situations from that of South Bay, predictive interpretation of these reports is not possible. Selected references to which the reader might refer are: • Edmonson, W.T., 1972. "The Present Condition of Lake Washington," Verhandlungen Internationale Vereinigung Limnologie 18: 284-291. 99 ------- • Gameson, A.L.H. and I.C. Hart, 1966. "A Study of Pollution In the Thames Estuary," Chemistry and Industry, p. 2117-2123. • Pryblek, W., 1977. "Texas Waterway Proves Cleanup Tide is Turning,'1 Chemical Engineering 84(17); 98-102. 5. In 1974, the low flow was 6S.1 mgd, occurring in February and in December. The low flow during the dry summer months was 66.0 mgd, occurring in May. (Flows in 1974 were similar to 1971 flows and were down from 1973.) It was at about this time that Bechtel and Fish and Wildlife Service staff noticed the presence of breeding snowy egrets in the rushes. In 1977, August low flows were 75.8 mgd in a 24-hour period, a greater flow which possibly reflects the growth in area water consumption and use by the canners (a seasonal peak) even during a drought period. And in this season, up to 250 pairs each of the black-crowned night herons and snowy egrets were observed (Rigney, personal communication, 16 June 1978). It is evi- dent that the marsh persists in relatively good condition during these low-flow conditions. However, it is not possible to estimate whether or not these are the minimum flows necessary to sustain the habitat. For example, the vegetation now in the Slough is salt tolerant - tidal influx as well as residual salts in the slough sediments subject these plants to "high-salt" conditions. Therefore, the vegetation might be able to with- stand prolonged exposure to salty water without visible loss although the bird colony might not be as tolerant. Therefore, in order to determine minimum flows necessary, flows would have to be reduced in stages over long periods of time, during which observations of colony behavior and on plant species composition could be made. This experimental procedure would likely endanger the well-being of the colony. If a marsh that is in poor condition (e.g. does not contain vigorous plant growth or animal life) were to be converted to a high-quality'marsh, It would be attractive to waterfowl, a host of other migratory birds, and other wildlife. To speed the restoration of such a marsh, such plants as brass buttons (Cotula coronopifola), alkali bulrush (Scripus robustus), and hard stem bulrush (Scripus acutus) might be planted to encourage their establish- ment. Other plants 'such as dock, fat hen, wild radish, other forbes, and grasses would invade parts of the uplands. Pondweeds would become established in the water area. It would be necessary to be able to regulate the water flow, controlling frequency, duration, and depth of flooding. At least 3 to 4 months of flooding, coupled with substantial soil moisture throughout most of the year, would be needed for the marsh,to retain its vigor. The actual amount of water needed would depend on the soil type, salt in the soil, microclimate of the area, the amount of suitable land available, and desired or required detention time. For example, a shallow-water seasonal wetland could be established that would be flooded only during the late fall and winter months. However, it would have wildlife-open space values throughout the year. On the other hand, a permanent marsh, partly or fully contained within dikes, could be created. The water depth would be a minimum of 3 feet, with depths ranging between 4 to 6 feet. This depth is needed to control the growth of cattails and hardstem bulrush. This emergent vegetation would be a fringe marsh at the waterland interface of the dikes, nesting islands, or other upland areas and selected areas. The open water areas would contain pond- weeds, which are excellent waterfowl foods. Widgeon grass also would be common. Some stands of emergent vegetation would occur in selected areas designed for that purpose by modifying the bottom elevation relative to designed water levels. The deep water and narrow interface limits the extent of emergent vegetation, thereby providing suitable conditions for mosquito fish to control mosquitoes. In addition, threadfin shad could be introduced to the area to feed on the zooplankton and phytoplankton as well as provide a cash crop-fish bait. Each diked cell would be a pond-marsh ecosystem. The actual type and extent of vegetation could be controlled by total water management including water level, the salinity of the water in the marsh, and the bottom configuration at time of design and construction. 100 ------- 1C might also be desirable to have both freshwater-type marshes and brackish water-type marshes. The brackish marshes could have a salinity range of between 4 and 8 ppt. The vegetation on the uplands, such as the nesting islands, baffles, and dikes, would be a mixture of pickleweed, dock, fat hen, salt grass, wild radish, gum plant, and thistles. The diversity of terrestrial and aquatic plants and yearlong water supply could provide very good habitat conditions for numerous species of wildlife. 6. The existing service charges and the charges attributed to Basin Flan Alternative are compared for each city in Tables 2-2 through 2-4. These values were calculated using the data presented on pages 162 and 163 (Tables 111-10, III-ll, and 111-12} of the Technical Volume of the Draft EIR/EIS and various rate schedules provided by the cities of: • San Jose. Sewer Service and Use Charge for Fiscal Year 1978-79, dated 2-May 1978 • Santa Clara. Resolution So. 3967 of the City Council, effective 20 June 1978 • Sunnyvale. Resolution No. 413-77 of the Council, adopted 13 December 1977 • Palo Alto. Utility Rate Schedules S-l and S-2, effective 1 July 1979 It should be noted that charges to specific dischargers may vary with quan- tity and quality of waste discharged (see Table 2-4) and may differ from actual yearly billings. However, from the three tables it can be seen that Basin Plan Alternative charges as calculated for the EIR/EIS could account for as much as a 21.9 percent increase in charges (canners in San Jose, not accounting for BOD, SS, or NH. surcharges) or as little as a 0.5 percent increase for commercial users (restaurants) in San Jose, Santa Clara, and Sunnyvale. TABLE 2-2 COMPARISON OF ANNUAL SERVICE CHARGES FOR SAN JOSE, SANTA CLARA, SUNNYVALE AND PALO ALTO - SINGLE FAMILY RESIDENCES 1979 Average User Charge Per Single Family Residence ($) for Sewer and Waste- 1981/1982 Average User Charge Per Single Family Residence ($) for Implementation of City San Jose Santa Clara Sunnyvale Palo Alto water Treatment 40.20 31.20 39,00 39.60 Basin Plan Alternative1 3.05 3.37 4.94 2.24 Only from Table III-10, Technical Volume of Draft EIR/EIS. 101 ------- TABLE 2-3 COMPARISON OF ANNUAL REVENUE REQUIREMENTS FOR SAN JOSE, SANTA CLARA, SUNNYVALE AND PALO ALTO - COMMERCIAL ESTABLISHMENTS City/Category 1979 Charge ($) Per Hundred Cubic Feet of Sewage Discharged 1981/1982 Charge ($) Per Hundred Cubic Feet of Sewage Discharged1 San Jose Total Commercial Restaurant Domestic Laundry Santa Clara Total Commercial Restaurant Domestic Laundry Sunnyvale Total Commercial Restaurant Domestic Laundry Palo Alto Total Commercial Restaurant 6.12 2.76 5.52 2.28 7.80 4.20 3.24, 0.04 0.03 0.04 0.04 0.03 0.04 0.05 0.04 0.04 0.03 0.02 ^Iculated from Table III-ll, Technical Volume of Draft EIR/EIS by converting annual flow to hundred cubic feet and dividing into annual revenue required. 2Total commercial rates not available. TJo breakdown given for commercial users in current rate structure. 102 ------- TABLE 2-4 COMPARISON OF ANNUAL REVENUE REQUIREMENTS FOR SAN JOSE, SANTA CLARA, SUNNYVALE AND PALO ALTO - INDUSTRIAL USERS City/Industry 1979 Charge ($) Per Hundred Cubic Feet Discharge - Noncrltical Users! 1979 Charge ($) Per Hundred Cubic Feet Discharge - Critical Users* 1981/1982 Charge ($) Per Hundred Cubic Feet Discharge^ San Jose Total Industrial Electrical Canneries Santa Clara Total Industrial Electrical Canneries Sunnyvale Total Industrial Electrical Canneries Palo Alto Total Industrial Electrical Canneries 4 3.48 8.28 4 2.28 5.40 3.364 4 4 4 4 1.08 0.12 ^ n f\f u.uo 0.73 . , 0.16 1.96, 0.09 r* n nr . 0.05 0.09 3.03, 0.23 — 0.10 2.78 0.53 4 - . I'H ' 4 65 Includes Industrial Cost Recovery-effective mid-1979. Noncritical user is one who uses less than 50,000 gallons per day or discharges wastes of uniform strength. "Assumes average and annual flows shown in Table 111-12, Technical Volume, Draft:EIR/EIS. • Actual costs would be calculated on a discharger-by-discharger basis and may also include charges for NH_, BOD, sus- pended solids, etc. (these latter charges not included here). A critical user is one who discharges, more than 50,000 gallons per day or wastes of varying strength. Calculated from Table 111-12, Technical Volume, Draft EIR/EIS, by converting annual-flows to hundred cubic feet and dividing into annual revenue required. 4 Values or rates not provided in rate schedules. No canneries in Palo Alto (see Table 111-12 of Technical Volume * Draft EIR/EIS). 103 ------- ENVIROTECH BSP One Oovis Drive Belmont, California 94002 Telephone 41 S/S92.4060 Telex 34- M86 2 0 Letter to Environmental Protection Agency Re: Draft EIR South Bay Discharges May 23, 1979 Page 2 Bay 23, 1979 Environmental Protection Agency Region IX 215 Fremont Street San Francisco, CA 94105 Attention: Hearing Officer HE-149 Subject: Draft EIR South Bay Discharges Dear Sirs: I attended the hearing at Santa Clara on Hay 17, 1979, and heard many points of view as to why this project should not go forward. I would like to offer another, and that is from the viewpoint of the fish. The current situation in the South Bay is that of an estuarine environment. Freshwater from the treatment plants meets with the saltwater of the bay. It is a place where life starts. Small microorganisms thrive and support larger animals such as shrimp and so on up the food chain to major sport fish. Evidence of these fish returning to the South Bay is accumulating. A steel- head was taken at Palo Alto last year and there is evidence of striped bass as far as San Jose. Recent modification of the South Bay sewage treatment plants has significantly improved the water quality of the South Bay. That improvement continues and should be thoroughly evaluated in a stabilized condition over a long period of time before further tinkering with the Bay. Shutting off this major flushing action of freshwater will signi- ficantly affect the salinity and biological activity of the South Bay. This is important to fish. Looking at page 11 of the Sumary EIR to see what the adverse impacts of losing that freshwater flow would be, we find: Environmental Aspect Biology Impact Potential change in Biota in South Bay as a result of changed oxygen levels, salinity Beneficial or Adverse Primary** Undefined From the viewpoint of the fish, we must know the adverse affects. "Undefined" makes this environmental impact report deficient in that this is a very major change which could have disastrous con- sequences. The report indicates salinity will reach that of open water. I don't believe that and neither.do the fish. The South Bay is not open. The tidal flow is not adequate. The salinity in the summer will increase to some unknown level above the sali- nity of open water and the environment will change from that of an estuary to a saline lake. The biological impact is enormous, yet the EIR totally fails to address it. I recently visited the Everglades where I saw the results of this kind of tinkering. A boat channel was opened into an inland fresh- water lake. The tidal saltwater changed the lake to saltwater and the biology changed completely. Then the lake, due to large surface area, became more saline and nearly all species of'life died out except migratory fish tolerant of extra salty water. It took them many years to learn what they bad done. The error is now being reversed and it will take many more years to recover. The fish don't care about money or they might like to make a bet with the person who indicated that short-term impacts will only bt "two weeks at any point along the conveyance" (pg. 8 Summary). If they cared about money they would wince at the heavy price tag for a monstrous facility that has no real benefit and plenty of environmental risk. They would laugh at the logic on page 16 of doing it now because inflation will make it more expensive in the future. They would suggest if you really care about water qua- lity in the Bay you would take the $86 million initial cost and the $320,000 annual cost and buy back tideland from the salt companies to restore the original tidal flushing action. The Loma Prieta Chapter (Santa Clara and San Hateo) of the Sierra Club and all fish urge a no project for the South Bay. Sincerely. Daniel E. Myers Conservation Coomittee/ Sierra Club DH:wp Enc: 2 Copies cc: Olive Mayer Mary Ann Hark Chapter Office 104 ------- Submitted by: D.E. Myers Conservation Committee, Loma Prieta Chapter Sierra Club Dated: 23 May 1979 Response: We appreciate your comments, and your recommendation for "No Further Action" has been considered by EPA and SBDA in project selection. Issues have been raised in this letter and specific responses are noted below. The definition of changed salinities as "Primary, Undefined" was used for the following reasons. While it is clear that freshwater and escuarine species would be lost (page 11 of Summary, Draft EIR/EIS) and that this loss is a direct (primary) effect of removal of effluent flows, the con- clusion as to whether or not this is adverse cannot be made without a. definition of the preferred aquatic system. The change in salinity could be considered beneficial to salt-tolerant vegetation, birds, and marine fishes. It is definitely adverse to freshwater species and to anadromous species such as steelhead and striped bass. In the Technical Volume, Figure III-2 (page 150), it is shown that salinity will increase significantly, particularly during the dry season in the sloughs. This elevated salinity (expressed as greater than 16,000 rag/I chloride) is greater than open water north of Dumbarton Bridge. During wet seasons, the salinity is projected to decrease to a low of 9000 mg/1 chloride in sloughs, resulting in a highly variable environment which would likely be conducive to populations of only the most euryhaline species. The description of "short-tern" (i.e. i...-9-week) effects refers only to construction impacts. Operational effects would be long-term, indeed permanent, unless the system were abandoned at some future date. The discussion under "Ho Further Action" as to the potential increased cost and possible loss of grant subsidies with delay does point out a disadvantage of this alternative. Should monitoring demonstrate continued problems with water quality requiring new construction (treatment or dis- charge) , the SBDA member cities would have to consider cost to their residents of such a corrective action. Therefore, as there are.insufficient data at this time to select an alternative which guarantees protection of beneficial uses, SBDA, its member cities, and the residents of the area are making a project alternative selection based on the assumption that they'will not have to build a new, more costly system at a future date, without state or federal assistance to lessen the burden on the consumers. The U.S. Fish and Wildlife Service now manages many of the Leslie Salt Company ponds on the east side of the Bay and has plans for marsh res- toration and/or creation in some units of the refuge. While this may result in some improvements in habitat quality, Increased tidal flushing would require opening the Dumbarton Narrows where fill has been placed for bridge approaches. In addition, channelization and damming of streams for water supplies in the Santa Clara County area results in reduced stream flows to the Bay, even during the wet season. It is not likely that any modifications could be made to South Bay at this time which vonld restore the original tidal flushing action. This impact is significant although the magnitude of impact can only be qualitatively described and, again, the degree of adversity depends on what the refuge and the public desire to occur In the area. 105 ------- UNITED STATES DEPARTMENT OF THE INTERIOR OFFICE OF THE SECRETARY PACIFIC SOUTHWEST REGION BOX 3BOB8 . 49O GOLDEN GATE AVENUE BAN FRANCISCO, CALIFORNIA B41O2 1415) 556.82OO IX ER 79/324 Mas'22'1979 "SKGCuau: MAY 2 9 1979 ItDSlON DC Paul De Falco, Jr. Regional Administrator Environmental Protection Agency Region IX San Francisco, California Dear Mr. De Falco: We have reviewed the araft EIS for the Treated Wastewater Disposal Program for South Bay Dischargers Authority, Santa Clara County, California, and include the following ocnnents for your consideration. General Ocnnents We are pleased that efforts are continuing to further improve the water quality of South San Francisco Bay. We note that the water quality of the South Bay has inproved significantly in recent years, and it now supports fish species that have been absent for many years. The study mentions a number of existing and proposed park and recreation areas which could be indirectly impacted by one or more of the various construction activities for the proposed alternatives. We suggest that siting ana effluent discharge routes be selected which would minimize such impacts to the fullest extent. It should be noted that both the Mountain View Shoreline Park and the Menlo Park Baylands Area have been funded through the Federal Land and Water Conservation Fund Act (Public Law 88-578, as amended}. Section 6(f) of the Act states, "No property acquired or developed with assistance under this section shall, without the approval of the Secretary (of the Interior), be converted to other than public outdoor recreation uses." If any of the alternatives affects such parks, there should be consultation with Mr. Russell Canill, Director, California Department of Parks and Recreation, who is the State Liaison Officer for the land and Water Conservation Fund in California. His address is 1416 Ninth Street, P.O. Box 2390, Sacramento, California 95814. We notice that the Wastewater Disposal Program should not adversely affect mineral development in the South Bay area. A benefit will accrue to the salt industry by allowing sane disposal of the bitern salts that new are being stockpiled. We observe that implementation of alternative I, the deep water outfall, would preclude any potential for local and national environmental and economic benefits that may accrue from other alternatives. On the other hand, alternative II, continued discharge but with completion of plant inprovements that are underway, may produce improvements in wastewater quality that will provide benefits that will make alternative I unneces- sary. The San Francisco Bay Area Regional Municipal Wastewater Reclamation Study, new underway, may identify wastewater reclamation and reuse projects that will require transport facilities to areas away from the Bay and eliminate a need for a deep water outfall. The national interest would be better served if the funds proposed for the deep water outfall were used to assist in construction of wastewater reclamation and reuse transport and storage facilities. In general, projects that would result in inproved water quality receive our support and encouragement. Occasionally, however, special circum- stances cone into play which complicate our evaluation. The freshwater inflow from the San Jose-Santa Clara Treatment Plant into Artesian Slough is such a case. Mast of the freshwater marshes in the San Francisco Bay area have been lost because of diking, filling, channeli- zation, intensified but short-term runoff froit developed areas, and upstream reservoir storage. The few remaining freshwater wetlands are extremely important because of their scarcity and because several wildlife species depend on this type of habitat for portions of their life cycle. The discharge of treated wastewater to Artesian Slough has resulted in the development of a narrow band of freshwater wetland about 6,000 feet long consisting primarily of bulrush and cattail. This freshwater wetland is one of the few locations in the San Francisco Bay area where ducks have been successful in rearing broods. The combina- tion of adequate cover and a source of freshwater (young ducklings need freshwater until their salt glands develop) is necessary for survival. A rookery used by black-crowned night heron, great blue heron, snowy egret, and common egret within -the Artesian Slough environs is the only rookery, other than the one at Blair Island, in the South Bay. This freshwater marsh is also the breeding area for a rare bird, the salt marsh yellowthroat. In addition, the San Francisco Bay National Wildlife Refuge's master plan includes the development of the New Chicago Marsh Unit near Alviso. The Refuge's Environmental Education Center would be used by local school and environmental groups in marsh and bay ecology as the water progresses from fresh to saline conditions. It is hoped that treated wastewater from the Santa Clara - San Jose Treatment Plant would be available for use in the development of New Chicago Harsh. v Under the selected project alternative, the cessation of wastewater flow to Artesian Slough would result in the return of saline condi- tions. Salt-tolerant plant species would replace the existing 106 ------- vegetation and would provide for a reduced level of habitat diversity. Alternative 4, which calls for upgraded treatment and continued discharge to existing locations, would preserve the freshwater marsh area. This is our preferred alternative assuming the implementation of advanced treatment measures bo meet the 5 mg/1 dissolved oxygen requirement (receiving water minimum) and to eliminate the input of toxicants through source control and pretreatment processes rather than by utilizing the receiving water as part of the treatment process, i.e., discharging wastewater to deepwater locations because of the greater dilution potential. We believe cur view is consistent with the objectives of the Clean Water Act which states that 'It is the national goal that the discharge of pollutants into the navigable waters be eliminated by 1985." We believe the freshwater marsh along Artesian Slough is important to wildlife in terms of productivity and diversity and that the removal of the freshwater source will greatly reduce, if not completely eliminate, the existing values. We believe advanced treatment methods are avail- able and can protect the beneficial uses of the receiving water. In the event that the "basin plan' alternative (discharge north of the Dumbarton Bridge) is selected, provisions for the release of enough freshwater to Artesian Slough to maintain the freshwater marsh should be included. Specific Conroents Appendix J. In reference to cultural resources, we strongly support the reccmnendations of Research Services, Incorporated (Appendix J), particularly that sub-surface examinations be conducted prior to trenching activities in sensitive areas. Also, in the event that historic landings are encountered during excavation, we recommend immediate consultation with the State Historic Preservation Officer, Dr. Knox Mellon. He can be contacted at 1220 K Street, Box 2390, Sacramento, California 95811. Sincerely yours. cc: Patricia Port Regional Environmental Officer Director, OEPR Director, Heritage Conservation and Recreation Service Director, Bureau of Reclamation Director, Bureau of Mines Reg. Dir., HCRS Reg. Dir., BR Reg. Dir., BM cc: Director, Fish & Wildlife Service Director, National Park Service Director, Geological Survey Director, Office of Surface Mining Director, Bureau of land Management Reg. Dir., FWS Reg. Dir., UPS Asst. Dir., GS Reg. Dir., OSH Reg. Dir., BIM SHPO 107 ------- Submitted by: U.S. Department of Interior Pacific Southwest Region 450 Golden Gate Avenue San Francisco, California 94102 Dated: Response: 22 May 1979 Thank you for your comments on the Draft EIR/E1S, in which a number of issues were raised. These issues are addressed below in the context of a decision to select the "No Further Action" alternative. 1. The Basin Plan Alternative routing (both on land and estuarlne) crosses only the proposed Palo Alto Baylands Reserve In an area previously disturbed by the construction of the Mountain View Connecting Sewer. No other park- lands would be affected with those routings, although the alignment is near • a number of proposed parklands. Should EFA or SBDA consider further activities in the area, we will consult with Mr. Cahill as you suggest. also responses to Drs. Shellhanmer and Harvey, California Fish and Game and State Water Resources Control Board in Section 2.2). 5. Modeling studies do not show compliance with the 5.0 ffig/1 oxygen requirement after upgrading treatment of San Jose/Santa Clara (see Figure IV-8, page 194 of Draft EIR/EIS Technical Volume). Additionally, this alternative - Upgraded Treatment - calls for addition of treatment, beyond currently Implemented advanced waste treatment (see responses to Drs. Shellhamner, Harvey, and Mewaldt in Section 2.2). 6. Should any construction be undertaken in this area, the recommendations in Appendix J and, as stated on pages 92-93 of the Draft Technical Volume, will be followed by EPA and SBDA, and contact with Dr. Mellon will be established in the event of any archaeological or historic discoveries. 2. Since no disposal system will be built, it will not be possible for Leslie Salt Company to dispose of bittern through the SBDA system. This is a potential disbenefit to both the company and the San Francisco Bay National Wildlife Refuge unless these entities can arrive at their own independent alternative to stockpiling. 3. The improvements in wastewater quality described for No Further Action would accrue to all alternatives; in fact, Upgraded Treatment and Reclamation/ Reuse would further increase effluent quality in San Jose. However, selection of "No Further Action" precludes action on reclamation/reuse under this grant program. Should SBDA decide to initiate such a program in the future as a disposal alternative, the Authority would have to reapply for funding. 4. Reclamation/reuse in maintaining Artesian Slough or in marsh building or enhancement may be acceptable to the State and Regional Boards (see 108 ------- CMC-iff) 2 2 District: DlE£CCoe., 351 SAW Jose, G&£if 951(6 (406) COMM CNTK Hy ?3 /I tf, • May 22, 1979 REGIONAL HEARING CLERK MAV31 1979 p Environmental Protection Agency Region IX, 21S Fremont Street San Francisco, California 94105 Attention: Mr. Paul DeFalco, Regional Director Dear Mr. DeFalco: Subject: South Bay Dischargers Project Since the Draft EIR/EIS for The Treated Wastewater Disposal Program for South Bay Dischargers Authority is under review at this time, I feel that it is imperative that several broader points be considered concurrently with the finalization of the subject report: 1. As outlined in the attached letter, I have already expressed opposition to the proposed EPA regulation changes concerning the fund- ing of reclamation projects which go beyond the existing effluent discharge requirements. Not knowing the prospects of successfully reversing these proposed funding restrictions, it is crucial that we approach the situation in the South San Francisco Bay with an awareness that all funding for reclamation could be lost if it is implied that the receiving waters can now, or in the future, accept the discharge of treated effluent from the cities of North Santa Clara County. 2. I do not believe the capabilities of the Bay mathematical or physical models can absolutely predict the quality of the Bay under future conditions (including Delta outflow and the Peripheral Canal) that are as yet unknown. For this reason, I support a continued and increased monitoring program with a major emphasis on the potential eutrophication of the estuary at its southern extremity. Obviously if algal blooms became prevalent under future conditions, all the efforts to date to assure high dissolved oxygen levels in the Bay would have failed, as the decaying biomass began to consume all oxygen present, returning the South Bay to a septic condition. 3. While the above position seems to be implied though not stated in the Draft EIR/EIS for the project, a recommendation for a "No Project Alternative" continues to be proposed. While I believe Mr. Paul DeFalco -2- May 22, 1979 that State and local monitoring should continue, I fail to see the need to reach this decision at this point and run the risk of for- feiting the construction grants which provide the only logical and feasible method of financing reclamation of Santa Clara County's treated effluent. Since considerable market studies are underway by the Santa Clara Valley Water District in cooperation-with the California Department of Water Resources, and funded primarily by E.P.A., it appears to be premature to reach a. final conclusion on the ultimate disposition of the treated effluent at this tine. It does however appear that reclamation or land disposal of effluent would be more cost effective than an outfall disposal system or further physical/chemical treatment with its inherent energy demands and sludge disposal problems. Both the County and Regional Recla- mation studies indicate that conveyance of these treated effluents to major markets are competitive with the costs of alternative new water sources. In view of the myriad of unknowns regarding the environmental, economic and institutional problems facing the residents of Santa Clara County's Water Users and Dischargers, I believe it is in the best interest for all that this decision be delayed until a more definitive and positive program can be implemented. Very trul trick T. Ferraro Chairman Board of Directors Attachment cc: Members, South Bay Dischargers Authority Mr. Tom Harris, San Jose Mercury 5 News 7SO Ridder Park Drive, San Jose, CA 95190 District office 5T5O expaessvjty SMI Jose, 95116 2&s-2£>oo 109 ------- Submitted byt Patrick Ferraro Director, District 2 Santa Clara Valley Water District 351 Brookwood Drive San Jose, California 95116 Dated: 22 May 1979 Response: Delay of a decision on disposal alternatives would be in violation of existing NPDES permits for the members of SBDA. In addition, SBDA is participating in the Regional Reclamation Study independent of this EIR/EIS work, as well as several small (2 mgd) local studies including Milpitas irrigation study initiated by SCVWD. This regional study may well find cost-effective markets for wastewater but funding for the disposal system cannot be transferred to such a study. Should SBDA decide to Implement reclamation/reuse as an alternative to disposal, it may reapply for grant funds at that time. 110 ------- Stol. of California Memorandum To i U. S. Environmental Protection Agency Region IX, Attn: Hearing Office (HE-14?) 215 Fremont Street San Francisco, CA 94105 From , Sm frwncbca Bay Regional Water Quality Control Board 1111 J.du.. IMM, Ofldmmi MMT Subjects SB DA EIR/EIS - Treated Wastewater Disposal Program Tho Re»urcs Agency of Callfernlo (He->4i^ 23 Dot,, May 30., 1979 File No. 2428.8056 (HJA) vjw RECEIVED rtPQIONAL HEARING CLERK JUKI 1979 REGION DC We have reviewed the subject draft EIR/EIS, and are not satisfied with the thoroughness of the report with regard to discussion; of the San Francisco Bay Water Quality Control Plan (Basin Plan), heavy metal impacts, botulism, and water quality monitoring. Our concerns regarding the above Issues have been explicitly discussed in previous correspondence (April 21, 1978) to the State Mater Resources Control Board (attached). We cannot accept the current EIR/EIS as being satisfactory until the following issues have been adequately addressed: Conformance With the Basin Plan'(page 4) Our previous comments regarding conformance with the Basin Plan were as follows: "The following requirements are identified in the Basin Plan." "It shall be prohibited to discharge any wastewater which has particular characteristics of concern to beneficial uses: 1) At any point at which the wastewater does not receive a minimum initial dilution of at least 10:1. 2) Into any nontidal water or dead-end slough or similar con- fined water areas or their immediate tributaries. 3) Into San Francisco Bay south of the Dumbarton Bridge." "Exceptions to each of these will be considered where the discharge is approved as part of a reclamation project or where it can be demonstrated that a net environmental benefit will be derived from such a discharge," "We request that the discharge prohibitory as given in the Basin Plan be identified in the EIR/EIS. In addition, as part of the analysis of those alternatives which do not conform to the discharge prohibitions, consideration should be given to the conditions necessary for exceptions to the Basin Plan. Please note that these analyses should be done on an Individual basis for the San Jose/Santa Clara, Palo Alto, and Sunnyvale treatment plants," U. S. Environmental Protection Agency ® - 2 - May 30, 1979 Although the current draft EIR/EIS discusses the prohibitions of discharges identified'in the Basin Plan, no mention is made of the conditions necessary for exceptions to the prohibition'of discharge and now alternatives not conforming to the discharge prohibitions will meet those conditions. He request that your commitment to these exception condi.tions.be Identified and discussed in the final EIR/EIS. Heavy Metals (page 57) Our prior comments regarding heavy metals were: "There is no discussion of heavy metal concentrations and their potential impacts on receiving water biota Included in the EIR/EIS." "The highest concentrations of dissolved metals in the Bay regularly occur below the Dumbarton Bridge. It is estimated that SIX (52 metric tons annually of the heavy metal loading to the Bay south of.Hunters Point is discharged into this area, This corresponds to only about 8% of the water volume of the Bay below Hunters Point." "The metals of principal concern, as expressed by Or, Girvin in a preliminary report to the Regional Board, are copper and silver. It is our recommendation that the level of observed concentrations of heavy metals in the South Bay be compared with chronic toxicity levels identified in the literature and that their potential for biomagnification be assessed." A discussion of heavy metals, similar to our comments, has been included in the current draft EIR/EIS, Nevertheless, the discussion is not sufficient since there is no mention of the relationship of observed concentrations of 'heavy metals in the South Bay and chronic tbxicity levels identified in the literature and their potential for biomagnification by the continued discharge of heavy metals. He request that these issues be discussed in the final EIR/EIS and that necessary mitigation measures be included. These should include a discussion of the source control programs and their costs necessary to reduce the discharge of heavy metals, Botulism (pages 76 and 152^ Our concern about the history of outbreaks of botulism in .the South Bay and the potential causes of avian botulism were expressed in our previous comments. "It is noted in the EIR/EIS that in 1975 a moderately severe outbreak of botulism occureed in Artesian Slough, Coyote Creek, and Mud Slough. About 2000 birds contracted the disease. In 1974 nearly 13,200 water- fowl died. The extent of the discussion of the causes of botulism Is limited to the following sentence; 'No data exist at this time as to the exact cause of botulism outbreaks, although they are clearly related to anaerobic sediment conditions that may be aggravated by waste discharge.1" 111 ------- U. S. Environmental Protection Agency - 3 - May 30, 1979 U. S. Environmental Protection Agency - 4 - Kay 30, 1979 The decision to only Identify the botulism problem and not to discuss its potential causes is apparently based on the fact that the "exact cause of botulism outbreaks" is not known. We do not believe this to be acceptable rational for overlooking the botulism question. A thorough analysis of the potential causes of botulism should be Included In the EIR/EIS." "The following is a brief summary of the available information concerning botulism. A brfef discussion with respect to implications in the South Bay is included.1' ''Botulism is a paralytic disease induced by the ingestion of food which contains toxin from the bacterium Clostirdium Botullnuin. The Bacillus is divided into seven types. Type Cj is a soil bacterium and is responsible for waterfowl botulism found in the western United States. It is an obligate anaerobe. Its optimum growth temperature is generally between 25 & 30°C with production of toxin greatest at 280C. C. botulinum does not grow well in salinities above 30 ppt." ^Decaying anaerobic organic matter is required by C. botulinum for growth and the production of toxin. The organic matter may be vertebrates. Invertebrates, submerged grain, or possibly other decompos- ing bottom material. Birds eat these materials, accumulate the toxin, and die. The important point is that anaerobic conditions roust occur either in a mlcroenvironment such as in the dead bodies of veterbates & invertebrates or in a more widespread environment such as bottom sediments." "The Initial cause of botulism may be an environmental change that kills aquatic invertebrates or fish. The accidental death of a waterfowl or fish from natural causes also can trigger a botulism outbreak. In such cases fly larvae Infest a dead fish or bird, concentrate the toxin and being a favored food of waterfowl result in posioning. Thus death of a single bird can lead to a botulism outbreak as more birds in turn die and are fed upon." '' Besides the proper medium for the growth of Clostridium botulinum, temperature and .salinity are important and may be controlling in the South Bay. As mentioned above a temperature of 25 to 30°C 1s optimal. Also, C. botulinum apparently will not grow well in salinities greater than 30 ppt." %> Outbreaks of botulism in the South Bay have been for the most part localized in Artesian Slough, Mud Slough and the upper end of Coyote Creek. Numerous dead birds have also been'taken from the Sunnyvale oxidation ponds," ® ® "Below the confluence of Hud Slough and Coyote Creek water temperatures consistently average about 20.5°C in August and September. From that point in towards the San Jose outfall water temperature rises at a rate of about 2°C per mile reaching about 27°C at the outfall, the temperature of the San Jose effluent. At the same time low salinity levels are created by the fresh water discharge. It therefore appears that the San Oose discharge may create an environment favorable for the growth of C. botulinum and that it may be a significant factor in the botulism outbreaks which occur in the South Bay. Fresh water in the Sunnyvale oxidation pond may also provide favorable conditions for toxin production." The current EIR/EIS does include a discussion of probable causes of avian botulism which concludes that depressed salinities and dissolved oxygen, elevated temperatures, and treated sewage are factors which may contribute to outbreaks of avian botulism. However, given the factors that are thought to be linked to outbreaks to avian botulism, no attempt has been made to assess how each of the alternatives may influence the probability of future outbreaks af avian boutlism in South San Francisco Bay, We recommend that such an assess- ment be made in the final EIR/EIS and that necessary mitigation measures be identified. Hater Quality Monitoring In the discussion of alternatives to the basin plan (page 181), it is briefly mentioned that for no action beyond currently approved improvements at the treatment plants, a water quality monitoring program would be needed to determine "the effect of the approved upgraded treatment on the Bay environment" (page 188), However, no attempt has been made to elaborate on the scope of such a monitoring program. In order to fully evaluate the impacts on aquatic biota of a continuing waste- water discharge (with upgraded treatment) at the present locations, several questions would need to be answered. For example, what are the acute and chronic (long-term) effects of the discharge on aquatic organisms? What are the effects of the discharge on primary productivity? To what extent are the behavioral patterns (spawning, migration, avoidance reactions) of fish and macroinvertebrates affected by the discharge? What is the potential for bioaccumulation of toxicants by aquatic organisms? To what extent are harbor seals affected by the discharge? Furthermore, no attempt has been made to (1) discuss the physical and biological analyses to be done; (2) estimate the economic costs of conducting an intensive monitoring program of the scope that would be needed to determine the impacts of a discharge of tertiary-treated wastewater on aquatic organisms; (3) estimate the length of time that would be needed for ah'adequate monitoring program in order to make an assessment of the impacts of the discharge; or (4) describe methods of data evaluation. 112 ------- U.S. Environmental Protection Agency - 5 - May '30, 1979 Conclusion The Regional Board staff is of the opinion that the current EIR/EIS is not satisfactory since relevant information regarding heavy metals - the relationship of observed heavy metal concentrations in the South Bay and chronic toxicity levels identified in the literature, and their potential for bioaccumulation associated with the continued discharge of heavy metals - and avian botulism - an assessment of the potential for outbreaks of avian botulism with each of the wa'stewater disposal alternatives - has not been discussed or evaluated. The requested information is essential if an adequate assessment of the impacts of effluent discharges on aquatic biota is to be made. Also, a discussion of the conditions necessary for exceptions to the Basin Plan's prohibition of discharge, and how alternatives which do not conform to • the prohibitions of discharge will meet those conditions, is not Included in the EIR/EIS, The lack of adequate information or commitments on the latter point precludes us from considering exceptions to(he discharge prohibitions in the Basin Plan at this time. Finally, relevant information (i.e., cost, total time devoted to monitoring, data evaluation) regarding water quality monitoring of the effects on aquatic organisms of a discharge of advanced treated wastewater for the "no project alternative" has not been Included in the EIR/EIS, We request that all of our concerns expressed herein be identified and adequately addressed in the final EIR/EIS. Should you have any questions regarding this matter, please contact Mike Aronann at (415) 464-1357 or Steve Morse at (415} 464-0618. FRED H. DIERKER Executive Officer Attachment: Comments of April 21, 1978, to State Board cc: without attachment Neil Dunham, State Water Resources Control Board Kike Rugg, Department of Fish and Game, Yountville U. S. Environmental Protection Agency - 6 - Hay 30, 1979 cc: (continued) City of Sunnyvale City Hall P. 0. Box 607 Sunnyvale, CA 94088 City of Palo Alto 250 Hamilton Palo Alto, CA 94301 City of San Jose City Hall San Jose, CA 95110 City of Santa Clara City Hall 1500 Warburton Avekue Santa Clara, CA 95050 South Bay Dischargers Authority c/o A. R. Turturici Department of Public Works City of San Jose City Hall, Room 408 San Jose, CA 95110 113 ------- TO- Neil Dunhum Chief, Division of Water Quality DATE: _ April 21, 1978 WATER QUAUITV CONTROL B-^RD ,,,N FRANCISCO BAY REGIO.. (Me-»«d) 23 INTERNAL MEMO Tile No, 31.28.8056 (RJli) vjw FROM1 ^rel' "• Eierker, Executive Officer Region 2\ ^^ SIGNATURE: SUBJECT: SBDA EIR/EIS - Treated Wastewater Disposal Program At our meeting of March 29, 1978 with staff of the-Division of Water Quality and the Division of Planning and Research we were requested to provide additional information on the inadequacies of the South Bay Discharge Authority's EIR/EIS. Hopefully this further amplification of our concerns will be useful in the development of the EIR/EIS and will lead to a concensus on the best means of wastewater disposal for the South Bay dischargers. It is our opinion that adequate information with respect to the following items has not been presented in the current draft of the EIR/EIS. We cannot accept the EIR/EIS as being complete until each item has been thoroughly addressed. These include: 1. Conformance with Basin Plan 2. Dissolved oxygen modeling predictions 3. Toxicity ). Heavy metals 5. Botulism Confor-mance with the Basin Plan The following requirements are identified in the Basin Plan. It shall be prohibited to discharge any wastewater which has particular characteristics of concern to beneficial uses: 1) At any point at which the wastewater does not receive a minimum initial dilution of at least 10:1. 2) Into any nontidal water or dead-end slough or similar confined water areas or their immediate tributaries. 3) Into San Francisco Bay south of the Dumbarton Bridge. Exceptions to each of these will be considered where the discharge is approved as part of a reclamation project or where it can be demonstrated that a net environmental benefit will be derived from such a discharge. Neil Dunhum Chief, Division of Water Quality - 2 - April 21, 1978 The prohibition of discharges to San Francisco Bay south of the Dumbarton Bridge has been noted in the EIR/EIS. However, no mention is given of the 10:1 initial dilution requirement or the prohibition of discharges to dead-end sloughs- Also, the conditions required to be granted exceptions to the three discharge prohibitions have not been identified or discussed. We request that the discharge prohibitions as given in the Basin Plan be identified in the EIR/EIS, In addition, as part of €he analysis of those alternatives which do not conform to the discharge prohibitions, consideration should be given to the conditions necessary for exceptions to the Basin Plan. Please note that thes« analyses should be done on an individual basis for the San Jose/Santa Clara, Palo Alto, and Sunnyvale treatment plants. Dissolved Oxygen Modeling Predictions The current draft of the EIR/EIS incorporates without discussion the Hydro- science modeling results for dissolved oxygen. Because dissolved oxygen is of primary importance in the evaluation of alternative disposal sites, it is necessary that the accuracy of predicted D.O. concentrations be carefully delineated. This is of particular importance in the case of the South Bay Dischargers disposal study due to the fact that the type of model used and corresponding assumptions needed to approximate observed D.O.. concentrations in the Bay do not represent the physical system. Of particular significance in this respect is the inability of the model to incorporate tidal effects or biological productivity. It is our recommendation that a discussion of the assumptions and the accuracy of the model be included in the EIR/EIS. The current Hydroscience sensitivity analysis and Dr. Orlob's review of the model are sources of this information. Where used, the modeling results for dissolved oxygen should be carefully qualified. Because use of the Hydroscience modeling is limited, it should not be-used as the sole tool to predict water quality. There is a need, therefore, for a more qualitative evaluation of discharges and their impacts on the South Bay which includes consideration of the factors the water quality model does not address. Dr. Smith's evaluation of his monitoring activities this last summer is one source of such information. Toxieity It is noted in the EIS that "oince segments of the Bay exhibiting relatively greater loxicitico are often areas where major municipal or industrial waste outfalls are located, potential cause and effect relationships exist. Certainly undiluted sewage effluent is toxic to most aquatic animals. Much research is necessary, however, to determine the nature of the potential interaction between the general toxicity of waste effluents and the Bay system." 114 ------- Neil Dunhum Chief, Division of Water Quality April 21, 1978 Further on in the report in section III.1.2., the toxicity question is again addressed. It is stated here that "while there are no water quality standards for toxicity and while components of toxicity cannot be readily defined, if the assumption is made that wastewater contains a certain amount of toxic material and that this toxic material is evenly distributed throughout the wastewater, then the toxicity levels in the South Bay will decrease with the removal of waste loads. Hydroscience calculated the decrease from no action to implementation of the recommended project would be as much as an order of magnitude in the extremities of the South Bay." These two sections include the entire discussion of toxicity in the EIS. The first statement concludes that undiluted wastewater is definitely toxic to most aquatic animals. Ihe/vcond statement indicates that if a series of assumptionc are made concerning the existence of toxicity, a discharge north of the Dumbarton Bridge will reduce toxicity levels in the South Bay. It is apparent that further analysis of toxicity IB needed. To facilitate this discussion background information with respect to the concerns the -Regional Board has regarding toxicity follows. The toxicity of wastewaters is often considered only in terms of the survival of indicator fish in bioassay testing. In many cases, however, the differences are great between lethal concentrations of toxicants and concentrations which will permit reproduction and growth. The correlation between bioassay results based on a single test organism and the actual impact on receiving water biota is further obfuscated by the variety of fish, invertebrate species, and lower food chain organisms found in a receiving water body, each having its own distinct susceptibility to toxicants. In addition, the variability of toxic waste dischargee introduces further uncertainty in the quantificantion of toxic impacts on a receiving water. Toxicity data are generally reported in terms of a median tolerance limit (Tim), the concentration that kills 50 percent of the test organisms within a specified time span, usually in 9& hours. Host bioassays are thus a measurement of acute toxicity. The step from estimation of the acute toxicity of a waste on a tent species to the quantification of its chronic affects on receiving water organisms cannot be made directly. A certain amount of subjective judgement is necessary. This does not provide justification to overlook the toxic effects of a waste discharge but rather requires that careful consideration be given to the subject. It is important to note that while chronic toxicity cannot be precisely quantified, a number of independent investigators have determined the threshold toxic concentrations of municipal wastes at strikingly similar levels. Neil Dunhum Chief, Division of Water Quality April 21, 1978 The toxicity guideline given in the Basin Plan is 40 ml/1 {8.01 toxic units). This was based on work done by Kaiser Engineers in the "San Francisco Bay - Delta Water Quality Control Seport" (1969). Their analysis was based on a correlation between benthic opecies diversity and receiving water conservative toxicity. Threshold effects were noted at a calculated toxicity concentration of O.OU tu in the receiving water. The series of reports titled "A study of Toxicity and Biostimulation in S. F* Bay Delta Waters" prepared by representatives of the Department of Water Resources, Fish and Game, and U. C. Berkeley, generally supported the toxicity limitation recommended by Kaiser Engineers. Dr. Alex Horn's work at SERL as reported in "Long-term Effects of Toxicants and Biostimulants on the Waters of Central San Francisco Bay" O971) showed that toxicity concentrations above 0.12 tu consistently affected aufwuchs growth and that a threshold effect at 0.05 toxic units was often observed. Finally, the National Technical Advisory Committee on Water Quality (1968) recommended that the 2't-hour average concentrations of toxicants after mixing in a receiving water should not exceed l/20th of the 96 hour TIfli for degradable, non-cumulative substances and l/100th for conservative, cumulative or unidentified toxicants. TheGe recommendations are based on wastes in the midrange of relative toxicity and correspond to receiving water toxicity limits of 0.05 to 0.01 toxic units respectively. The Basin Plan toxicity guideline of 0.01! toxic units is thus supported by a substantial body of data which is specific to San Francisco Bay as well as by the judgement of a recognized group of water quality experts with nation- wide experience. The EIS for oil intents and purposes has dismissed toxicity as a significant factor in the analysis of alternative disposal sites. Because the prohibition of discharges to waters south of the Dumbarton Bridge is based largely on high toxicity levels in the South Bay and because no decision as to an appropriate outfall location for the South Bay Dischargers can be made without thorough discussion of toxicity, the EIS will not be complete until that information is provided. Heavy Metals There is no discussion of heavy metal concentrations and their potential impacts on receiving water biota included in the EIR/EIS. The highest concentrations of dissolved metals in the Bay regularly occur below the Dumbarton Bridge. It is estimated that 513» (52 metric tons annually) of the heavy metal loading to the Bay south of Hunters Point is discharged into this area. This corresponds to only about 8# of the water volume of the Bay below Hunters Point. 115 ------- Neil Dunhum Chief, Division of Water Quality - 5 - April 21, 1978 The metals of principal concern, as expressed by Dr. Girvin in a preliminary report to the Regional Board, are copper and silver. It is our recommendation that the level of observed concentrations of heavy metals in the South Bay be compared with chronic toxicity levels identified in the literature and that their potential for biomagnification be assessed. Botulism It is noted in the EIR/EIS that in 1975 a. moderately severe outbreak of botulism occurred in Artesian Slough, Coyote Creek, and Mud Slough. About 2000 birds contracted the disease. In 1971 nearly 13,200 waterfowl died. The extent of the discussion of the Causes of botulism is limited to the follow- ing sentence: "No data exist at this time as to the exact cause of botulism outbreaks, although they are clearly related to anaerobic sediment conditions that may be aggravated by waste discharge." The decision to only identify the botulism problem and not to discuss its potential causes is apparently based on the fact that the "exact cause of botulism outbreaks" is not known. We do not believe this to be acceptable rational for overlooking the botulism question. A thorough analysis of the potential causes of botulism should be included in the EIR/EIS. The following is a brief summary of the available information concerning botulism. A brief discussion with respect to implications in the South Bay is included. Botulism is a paralytic disease induced by the ingestion of food which contains toxin from the bacterium Clostridium Botulinum. The Bacillus is divided into seven types. Type C2 is a'soil bacterium and is responsible for waterfowl botulism found in the western United States. It is an •bligate anaerobe. It's optimum growth temperature is generally between 25 & 30°C with production of toxin greatest at 28°C. C. botulinum does not grow well in salinities above 30 ppt. Decaying anaerobic organic matter is required by C. botulinum for growth and the production of toxin. The organic matter may be vertebrates, invertebrates, submerged grain, or possibly other decomposing bottom material. Birds eat these materials, accumulate the toxin, and die. The important point is that anaerobic conditions must occur either in a nicroenvironment such as in the dead bodies of verterbrates ^invertebrates or in a more widespread environment such as bottom sediments. 116 Neil Dunhum Chief, Division of Water Quality - 6 - April 21, 19?8 The initial cause of botulism may be an environmental change that kills aquatic invertebrates or fish. The accidental death of a waterfowl or fish from natural causes also can trigger a botulism outbreak. In such cases fly larvae infest a dead fish or bird, concentrate the toxin and being a favored food of waterfowl result in posioning. Thus death of a single bird can lead to a botulism outbreak as more birds in turn die and are fed upon. Besides the proper medium for the growth of Clostridium botulinum, temperature and ealenity are important and may be controlling in the South Bay.. As mentioned above a temperature of 25 to JO°C is optimal. Also, C. botulinum apparently will not grow well in salinities greater than JO ppt. Outbreaks of botulism in the South Bay have been for the most part localized in Artesian Slough, Mud Slough and the upper end of Coyote Creek, numerous dead birds have also been taken from the Sunnyvale oxidation ponds. Below the confluence of Hud Slough and Coyote Creek water temperatures consis- tently average about 20-5°C in August and September. From that point in towards the San Jose outfall water temperature rises at a rate of about 2°C per mile reaching about 27°C at the outfall, the temperature of the San Jose effluent. At the same time low salinity levels are created by the fresh water discharge. It therefore nppcars that the San Jose discharge may create an environment favorable for the growth of C. botulinum and that it may bo a significant factor in the botulism outbreaks which occur in the South Bay. Fresh water in the Sunnyvale oxidation pond may also provide favorable conditions for toxin production. Conclusion It is the opinion of the Regional Board staff that the environmental poction of the EIH/EIS is a general summary of existing information. It lacks both depth and interpretive evaluation. Many rather disjointed facts are presented but little attention has been given to interrelating and comparing impacts. The argument against greater detail and interprative judgement is the Bechtel position that incorporation of these would require the EIR/EIS process to become a research project. No research is needed to provide the information that is requested in this memo. What is required, however, is the incorporation of more complete information and, as noted, interperative evaluations of project alternatives based on this information. If you have any questions please contact Bob Roche at 8-561-1255. ------- Submitted by: Regional Water Quality Control Board Dated: 30 May 1979 for both fish and Invertebrates, as well as calculations of Application Factors (AF) and Bloconcentration Factors (BCF) . The May 18, 1979 test procedures were corrected on December 18, 1979 (44 FR 75028). Response: 1. The purpose of the Draft KIR/EIS Is to disclose the environmental Impacts of project alternatives In order to choose among the alternatives. It is not intended that the EIE/E1S provide the basis for exceptions to either the Enclosed Bays and Estuaries Policy or the Basin Plan, although elements in the report might be used as support for a petition for excep- tion. Only after definition of beneficial uses and the evaluation of present and future reclamation activities can SBDA move to meeting such conditions (page 188 includes a statement describing a benefit which night accrue by continued discharge to Artesian Slough; this is not meant to infer claim of enhancement). 2. On Page 56, It Is stated that chronic toxicity cannot be precisely quantified, while page 57 indicates a potential for biomagnification. This' potential would continue, regardless of discharge location since heavy metal concentrations would likely not be reduced by treatment. Further dilution does not preclude biomagnification, although the rate of biomagnification and actual tissue levels of toxic materials may be reduced. It is possible that implementation of pretreatment will eliminate or reduce some industrial sources of heavy metals to the SBDA water pollution control plants. However, the Introduction of heavy metals to the Bay is not a result of an action contemplated or being taken by SBDA (i.e. is not an Impact of a disposal project). It is therefore inappropriate to develop mitigation (i.e. source control methodologies) for heavy metals in this EIR/EIS. (See also response to County Sanitation District 4 in Section 2.2.) On May 18, 1979 (43 FR 21506), the EPA published a series of technical 'guidelines which set forth a methodology for deriving water quality criteria. These guidelines included standards to calculate acute and chronic toxicity Using these guidelines, the EPA began promulgating criteria for the 65 toxic pollutants identified by the Clean Water Act of 1977. On March 15, 1979 (44 FR 15926), criteria for the first 27 toxic pollutants were published. The March 15, 1979 criteria were corrected in notices Issued May 16, 1979 (44 FR 28716) and June 19, 1979 (44 FR 35289). The criteria for an additional 26 pollutants were issued In draft form on July 25, 1979 (44 FR 43660), and the draft criteria for the last 12 substances were Issued on October 1, 1979 (44 FR 56628). On January 3, 1980 (45 FR 803), EFA proposed that ammonia be added to the toxic pollutant list. None of these notices has been finalized at this time. The metal, silver — of critical concern to Dr. Girvin in memorandum dated April 21, 1978 (p. 5 of that memorandum) — Is discussed on pages 15964- 15965 of the Federal Register for March 15, 1979. Both chronic and acute toxicity levels have been developed to protect freshwater and saltwater aquatic life, and a separate concentration is presented to protect human health. Twenty-four hour average values are presented to protect against chronic effects, while the maximum value, based on 96-hour flowthrough LC50 data. Is used to protect against acute effects. The following table summarizes the proposed criteria for silver: Freshwater aquatic life Saltwater aquatic life Chronic (24-Hour Average) 0.0090 ug/fc 0.26 ug/l Acute (Maximum) 1.9 pg/8. 0.58 yg/l The criterion for protection of human health was set at 10 vg/i, based on studies on rats and rabbits. ------- A second metal of concern, identified in the RWQCB Internal memorandum of April 21, 1978, is copper. -This element is discussed on page 43666 oj the Federal Register for July 25, 1979. The following table summarizes proposed criteria for copper: Chronic (24-Hour Average) Acute (Maximum) Freshwater aquatic life (0.65 in {hardness}-l.94) (0.88 in {hardness}-!.03) Saltwater aquatic life 0.79 ug/i 1.8 ug/)[ The criterion for protection of human health was set at 1 pg/H. Although an attempt has been made to standardize data on acute and chronic toxicity, EPA recognises that variability in toxicity levels may be due to conditions that are specific to each water body. In developing water quality standards to be based on these criteria, specific circumstances affecting the toxicity of various compounds in the South Bay, such as synergistic complexes, salinity, pH, and oxygen levels, should be investigated in more detail. How- ever, the proposed EPA guidelines should be available In providing a set of standard methodologies for conducting such studies and in preparing appro- priate implementation plans for the criteria. Full documentation on the summary data from which the criteria were derived is published by the National Technical Information Service (Silver - NTIS #PB 292 441 and Copper - NTIS #PB 296 791). 3. Avian botulism Is discussed in detail on page 76 of the Draft Technical Volume. In this discussion, we state that the cause of outbreaks is not fully understood. However, it should be noted that anaerobic sediment con- ditions persist in the South Bay due to the high organic content, much of which can be attributed to past sewage discharges (untreated as well as treated). Usually, this anaerobic state is shielded from the water column by a thin oxidized surface - hence the need to agitate samples to determine 118 benthic oxygen demand (Appendix H, page H-444). Ducks, like shovelers, may disturb this layer and become exposed (or even ingest) anaerobic muds which may contain toxin from anaerobically respiring C. botulinwa. Ducks may also carry C. botulinum spores in their intestinal tracts, with out- breaks of the disease following death by other causes and decay of the carriers' bodies. It may well be that disturbance to the oxidized layer is induced by increased temperature (resulting in a reducing environment and less oxygen in solution), decreased salinity (resulting in animal die- off with an accompanying oxygen demand), or decreased oxygen levels in the water (equilibrium to be established between water column and muds leading to oxygen demand). It also is possible that discharge of sewage contributes to both decreased oxygen and salinity, although it is not clear that these conditions persist long enough to encourage anaerobic growth of'the bacterium and accumulation of toxin in the sediments. As treatment is improved to the level of AWT, the effect on oxygen by the effluent may be lessened while salinity decreases may continue to be aggravated. However, urban runoff and storm drainage may also result in these changes and, indeed, some of the sloughs studied in Appendix H.3 showed strong salinity and DO variations in the water column without waste discharges occurring (pages H-429 through H-436). A summary of available information on avian botulism indicates that three conditions must be met for optimum growth and toxin formation by C. botulinum: warm temperature (25-30°C) , a suitable animal protein substrate, and a high moisture content. These three conditions may be met in the South Bay during the late summer when temperatures are high and there is a decrease in inver- tebrate populations. Ongoing studies at the Bear River Refuge in Utah by Jensen and Allen confirm the belief that an Increase in Invertebrate mortality preceded an outbreak. In each outbreak studied, a precipitous decline in dipterous larvae and oligochaetes preceded botulism. However, the authors found great variability in the ability of strains of the bacterium to produce toxin and also found that living Invertebrates are sometimes toxic, presumably ------- by having ingested cells of C. botulinum. It has also been found that the death of a bird or fish, and Its subsequent infestation by maggots, may initiate an outbreak. There is presently incomplete information on invertebrate population dynamics in the South Bay, so no conclusions may be drawn concerning the initiation of outbreaks. In many ponds and marshes where other outbreaks have occurred, either recent increases or decreases in water level have been linked with invertebrate dieoffs, but no such indications are avail- able for the South Bay. It may well be that increased summer temperatures, in conjunction with BOD loading from the discharges, might cause a sufficient decrease in oxygen levels in the South Bay to initiate a dleoff of invertebrates but, in that case, we might expect severe outbreaks every year. In fact, available data indicates a decrease in numbers of dead birds from 1974-1978. Although much of this observed decrease in mortality is undoubtedly due to intensive management by the California Department of Fish and Game and the Fish and Wildlife Service in picking up dead and sick birds, there is no clear implication that waste discharge has led to out- breaks of avian botulism in the South Bay. Ho quantitative or qualitative prediction of reduction or stimulation of . botulism outbreaks can be made, from available data. The potential for outbreak may remain, regardless of the alternative chosen. Two recent references may be consulted for more specific information: • Allen, J.P. and S.S. Wilson, 1977: "A Bibliography of References to Avian Botulism." U.S. Department of Interior, Fish and Wildlife Service, Special Scientific Report - Wildlife Ho. 204. - A fairly complete list of literature published through 1975. • Smith, L. DS., 1977. "Botulism:.The Organism, Its Toxins, The Disease." Charles C. Thomas, Springfield, Illinois. 236 pp. - An excellent monograph by a leader in the field of anaerobic bacteriology, with a chapter on botulism in birds. 4. Until definitions of conditions necessary for exemption are agreed •upon, no monitoring program can be delineated. This activity will commence following approval of the Final EIR/EIS, and a selection of conditions will be worked out with SWRCB and RWQCB (see also responses to County Sanitation District 4 and Santa Clara Valley Water District in Section 2.2). 5. Although all of the issues presented In your comments are important to the improvement of the water quality of South San Francisco Bay, and the need for their eventual resolution is acknowledged by SBDA and EPA, the 'funding of studies for their actual resolution is outside the scope of this EIR/EIS. 119 ------- Association of Bay Area Governments Hotel Claremont • Berkeley, California 94705 • (415)641-9730 u 1& HO 13 June 1, 1979 U.S. Environmental Protection Agency Attn: Hearing Office, HE-149 Region IX 215 Fremont Street San Francisco, CA 94105 Dear Sirs: Thank you for the opportunity to review the DEIR/S for the South Bay Dischargers Authority effluent disposal project. ABAG staff has reviewed this document and is forwarding the following comnents. ABAG's Executive Board has not taken a position on this document or the proposed project. The DEIR/S states that facilities will be sized on the basis of the Department of Finance's E-0 population projections. In view of California State Office of Planning and Research's approval of ABAG's population projection for use by the State Mater Quality Control Board, we urge that the latter set of projections be substituted for those now used in the text. Please contact Stan Hoffman, Principal Regional Planner, to obtain the projections for the service area of the project. Thank you again for the opportunity to comment. Sincerely, HEARING JUNG 1979 REQIONIX Charles Q. Forester Director of Planning Representing City and County Governments in the San Francisco Bay Area 120 Submitted by: ABAC Hotel Claremont Berkeley, California 94705 Dated: 1 June 1979 Response: The Draft EIR/EIS description of the Basin Flan Alternative was based on plant capacity approved by the EPA and the State in 1974, and operating at the time of report printing. The cost of the Basin Plan Alternative did use the DOF E-zero basis, the approved number at the time of Step 1 funding. The DOF E-zero wa,s used to allocate nongrant fundable capital costs (see page 160, Table 111-5 in Draft EIR/EIS Technical Volume) since the existing capacity of the water pollution control facilities already exceeded E-zero levels. It was necessary to size the disposal system to fit the water pollution control facilities in order to ensure system compatibility and reliability. Use of another population figure will not alter the disposal system size; it could affect computation and alloca- tion of nongrant fundable costs. Using the ABAC projections (Table 2-5), it can be seen that projections for the service area are declining with 'each revision, reflecting recent declines in average household size, migration rates, and regional employ- ment growth rates. If a disposal system were to be selected and grant funding were to be requested, the required funding would be estimated based on the projection in effect at the time of funding. If such pro- jections continue to decline, the discrepancy between treatment facility capacity and E-zero population will increase, resulting in a porportional increase in ineligible costs for San Jose/Santa Clara (Table 1115, page 156 of Technical Volume, Draft EIR/EIS allocates all ineligible costs due to capacity to San Jose/Santa Clara). It is also possible that Palo Alto and/or Sunnyvale could Incur ineligible costs due to these revisions. As stated on page 21 ot the Technical Volume, these new revisions would be taken into account in the final design phase, should a structural alternative, such as the Basin Plan Alternative, be selected. ------- TABLE 2-5 Projected Population on the SBDA Service Area (in thousands) 1970 1975 1980 1985 1990 1995 2000 DOF1 E-zero DOF/DWR2 D/150 E-rzero ABAG/MTC2 D/150 E-zero 3 DOF revised E-zero 4 ABAC Series 3 Rev E-zero 1047.8 1152.2 1041.0 1041.0 1033.8 1033.8 1145.1 1362.2 1348.0 1273.0 1268.6 1203.7 1270.7 1211.8 1564.2 1909.0 1635.0 . 1751.3 1422.8 1560.7 1324.5 ., 1697.0 1507.0 1528.2 1360.1 1426.1 1429.4 These projections taken from Table 3-2, page 3-6 of Financial Plans and Revenue Programs, Water Pollution Control Facilities in South San Francisco Bay, prepared for SBDA by Bechtel Incorporated March 1, 1974. 2 These projections taken from Table 11-15, page 87, Technical Volume of Draft EIR/EIS (DOF/DWR, 1974; ABAG/MTC, 1974) 3 These projections calculated from text, page 87, Technical Volume of Draft EIR/EIS 4 These projections from Charles Q. Forester, Director of Planning to U.S. EPA Region IX. Personal communication with ABAC: letter dated 23 October 1979. 121 ------- OABAG Association of Bay Area Governments Hotel Ciaremont • Berkeley, California 94705 •(415)641-9730 October 23, 1979 U.S. Environmental Protection Agency Attn: Hearing Office, HE-149 Region IX 215 Fremont Street San Francisco, California 94105 To Whom It May Concern: In our letter of June 6, 1979, we commented upon the DEIR/EIS for the South Bay Dischargers Authority Treated Wastewater Disposal Program. Me informed you that we were revising our population projections and would provide you with the revised projections in the near future. These figures have now been revised and adopted by the ABAG Executive Board. The revised figures follow: Year 1975 1977 1980 1990 2000 Population 1,145,147 1,171,821 1,211,832 1,324,495 1,429,354 Charles Q. Forester Director of Planning •linear interpolation between 1975 and 1980 Representing City and County Governments in the San Francisco Bay Area 122 ------- Advisory Council On Historic Preservation 1522 K Sine* NW. Washington D.C. 20005 Reply to: T. C. For. K'JSS Denver, Col<»ra ------- Submitted by: Advisory Council on Historic Preservation 1522 K Street, NW Washington, D.C. 20005 Bated: 8 June 1979 Response: As stated on page 92 of the Draft EIR/EIS Technical Volume, EPA and SBDA will comply with Executive Order 11593 should any action affect historic, cultural, or archaeological sites. Although "No Further Action" has been selected and this alternative requires no construction, should EPA or SBDA consider any other activity in the area in the future, we will comply with 36 CFR 800.4; 16 U.S.C. Sec. <470f, as amended, 90 Stat, 1320; and ajiy equivalent state, regional, or local regulations. • 124 ------- Sectioi? RESPONSES TO WRITTEN COMMENT RECEIVED AFTER 6 JUNE 1979 . ------- ------- 3. RESPONSES TO WRITTEN COMMENT RECEIVED AFTER 6 JUNE 1971 Three letters of comment were received by EPA and SBDA after the close of the review and comment period. They are included here along with responses because issues were raised in these three letters which warrant comment. • Florence M. LaRivere - 1 July 1979 • County Sanitation District No. 4, Santa Clara County - 3 July 1979 • Sunnyvale Chamber of Commerce - 15 May 1979 127 ------- "^ V'xa IAA o r—^" ,-.^,<•<>• "- "" Tis^as - " __. 7.. -T:X' /"«--• u ^,— \ 4ut >» ^", j ' ^ Jc^-<^^/^ %$£&&$&£& ^^r <<& -^-. / , ±, g^tts^Vu y 7 U'/L L7U^^( -, Yf j--^- AW^^ * ^\- ^m^^fA^^^^-1^ yo^6f ^^rjS^-^f, &avt: ^ . (Retyped from original with Ms LaRivere's permission.) 4S3 Tennessee Lane Palo Alto, California 94306 July I, 1979 - , United States Environmental Protection Agency 215 Fremont San Francisco, California Altn,; Hearing Office HE re: Grant #CA 06-1135 Dear Sir: During the 28 year; we have lived in Palo Alto, we have frequented the shores of the bay for recreation - sailing; hiking, and wild-life enjoying. Since the opening of the dikes many years ago for walking, we have become especially fond of the airport runway dike, where it parallels the Palo Alto sewer out fall. It is quite evident that wildlife is particularly abundant in that area. Gulls, shorebirds and ducks are in heavy concentrations there, and it is apparent from the terns fishing up and down the slough that fish life is rich in it. Fresh water intake to the south bay has been shockingly diminished in the last century, and by some projects (for example. Mountain View Shoreline's blockage of fresh water runoff) within the last few years. Catching those waters in flood basins leads to evaporation. In the bay adjoining runoff areas that have been maintained, steelhead and other fish life persists. It appears to us that the South Bay Discharger Project will most likely lead to deterioration in the water quality of the South Bay. Sincerely, Florence M. LaRiviere 128 ------- Submitted by: Florence M. LaRivere 433 Tennessee Lane • Palo Alto, California 94306 Dated: 1 July 1979 Response: No blockage of natural runoff would occur with any of the viable dispos- al alternatives since each would consist of buried pipelines in existing dikes. However, with selection of the No Further Action Alternative, maintenance of "freshwater" flows into the channel near the Palo Alto Airport would result since the Palo Alto effluent would continue to that channel. .129 ------- COUNTY SANITATION DISTRICT NO. 4 OF SANTA CLARA COUNTY 100 East Sunn/oaks Avenue Campbell. California 95008 Telephone 378-2407 -E5;0«i; ix ..V.M. CENTER J:.l E SERVING RESIDENTS OF CITY OF CAMPBELL TOWN OF LOS 6ATOS CITY OF MONT£ SERENO CITY OF SAN JOSE CITY OF SANTA CLARA CITY OF SARATOGA UNINCORPORATED AREA Submitted by: County Sanitation District Ho. 4 of Santa Clara County 100 East Sunnyoaks Avenue Campbell, California 95003 July 3, 1979 Dated: 3 July 1979 Environmental Protection Agency Region XX Hearing Officer, HE-149 215 Fremont Street San Francisco, CA 94105 Re Governmental Agencies Regional, South Bay Dischargers Authority The Board of Directors of County Sanitation District Ho. 4 of Santa Clara County, California is on record as favoring the "no action alternative" set forth in the DRAFT ENVIRON- MENTAL IMPACT REPORT AND STATEMENT for the SOUTH BAY DIS- CHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM. The District Board of Directors has also dis ssed the feasibility of large volume water reclamation as a partial alternative for disposal of the wastewater discharge from the San Jose/Santa Clara Hater Pollution Control Plant and take the following position with respect to this alternative: o The Clean Hater Act Grant designated•for the South Bay Dischargers Authority Common Conveyance Facility should not be redesignated for use in funding a water reclamation alternative. o The feasibility of large volume water reclamation requires further study, which, with respect to Santa Clara County, should be administered by the Santa Clara Valley water District. o The financing, administration and operation of any systems for the transportation and distribution of large volume water reclamation should also be under the direction of the Santa Clara Valley Hater District. Sincerely Stephen H. Goodman Manager and Engineer SHGskk cc: South Bay Dischargers Authority Room 320, 801 No. First St., San Jose 95110 Frank M. Belick; Board of Directors Response: 1. Clean Water Act Grant funds designated for wastewater disposal cannot be redesignated to reclamation or any other alternative unless it is selected as a disposal alternative. Should a wastewater reclama- tion program be implemented at a later date, SBDA would have to reapply for funding (see also responses to U.S.D.I. and to P. Ferraro in Section 2.2). 2, 3. A feasibility study of large-scale reclamation is now underway. A joint venture, comprised of SBDA, City and County of San Francisco, Central.Contra Costa Sanitary District, Santa Clara Valley Water District, EBDA, Contra Costa County Water District, and EBMUD, has hired the con- sulting firm CH-M Hill to perform the study. Administration, financing, transportation, and distribution of reclaimed water are to be covered in this study. Responses to your earlier letter supporting No Further Action are inclu- ded in Section 2.2. 130 ------- SLNNYVALE CHAMBER OF COMMERCE • 4S9 SOUTH MURPHY AVENUE • TELEPHONE AREA CODE [408) 7364971 SUNNYVALE .CALIFORNIA MOM May 15, 1979 Environmental Protection Agency ATTENTION: Hearing Office, HE-149 Region IX 215 Fremont Street San Francisco, CA 94105 SUBJECT: SUNNYVALE CHAMBER OF COMMERCE POSITION ON THE SOUTH BAY DISCHARGERS AUTHORITY'S TREATED WASTEWATER DISPOSAL PROGRAM The Board of Directors of the Sunnyvale Chamber of Commerce at their Executive Committee Meeting of May 8, 1979 and their full Board Meeting of May 15, 1979 unanimously voted to urge that "no action beyond currently approved improvements at Tredtment Plants" be taken and that the three Santa Clara County treatment plants continue to discharge treated effluent into the South Bay. This position la based on the following key consider- ations: 1. Actions taken or being taken by the Cities of San Jose, Santa Clara, Sunnyvale and Palo Alto are proving to be highly successful in Improving the water quality of the South Bay. It Is reasonable under these circumstances to defer action on the "Super Sewer Project", monitor the rate of Improvement and subsequently take corrective steps, If necessary. 2. Given the current and continuing improvement of water quality, the fresh water marshes in the South Bay can be - retained and the undesirable transition to salt water marshes and its adverse effect upon existing vegetation and wildlife will be avoided. 3. The Investments made and being made in the wastewater treatment plants of South Bay Clttes are proving to be cost effective thus avoiding the cost of constructing and operating the "Super Sewer Project." The estimated $86 million tor construction, $320,000 annual operating costs and significant energy demands can all be saved. - Page 2 - Environmental Protection Agency ATTENTION: Hearing Office, HE-149 In conclusion, the Sunnyvale Chamber of Commerce urges Alternative 2 of the Draft Environmental Impact Report and Statement (Treated Waste- water Disposal Program dated September 1978 be adopted and that no further action be taken at this time. Sincerely, :. H. Millson Executive Director EHMstmb - continued - 131 ------- Submitted by: Sunnyvale Chamber of Commerce 499 South Murphy Avenue Sunnyvale, California 94086 Dated: 15 May 1979 Response: SBDA and EPA have noted your resolution and considered it in making a project selection. Specific issues in your letter do require response: 1. Monitoring and taking subsequent corrective steps, if necessary, is inferred in selection of the No Further Action Alternative. SBL>A will, after completion and approval of the Final EIR/EIS, have to position SWRCB and RWQCB to establish conditions for exemption to the Enclosed Bays and Estuaries Policy and the Basin Plan before monitoring and/or corrective action can be defined. (See also responses to County Sanitation District No. 4 and Santa Clara Valley Water District in Section 2.2.) 2. Retaining a disposal system in Artesian Slough and at Palo Alto will result in maintenance of freshwater marshes or vegetation; conversely, removal of the discharge will result in loss of this vegetation. How- ever, although freshwater marshes are considered a benefit to some (e.g. U.S. Fish and Wildlife Service: Drs. ShelIhawmer, Harvey, and Mewaldt), the transition to saltwater marshes may not be considered undesirable to others. At this time, no definition of the preferred ecosystem has been made by regulatory agencies (see also response to D. E. Myers in Section 2.2). 3. Of the estimated $86 million capital and $320,000 annual operating costs, only that local portion (12.5 percent capital and all operating costs) can be considered "saved." The remaining 75 percent federal and 12.5 percent state shares will likely be committed to another applicant. Energy demands of transport and/or upgraded treatment would be saved although no decrease in energy use is anticipated for "No Further Action. 132 ------- Scctiop 4 ERRATA ------- ------- 4. ERRATA The following typographical and editing errors occurred in the Draft E1R/ E1S. These errors have not been corrected in a reprinted volume; rather, the corrections are noted below with each error as clarification to the reader. Volume, Page Column and Line Error Table 11-1, line 4 punctuation: (SWRCB TECHNICAL, 39 editing: misplaced foot- column 2, lines 14-18 note Correct iiui (SWRCB± 1974) insert lines 14-18 after page 1, column 40 Volume, Page Column and Line TECHNICAL, 8 column 1, line 2 TECHNICAL, 12 column 1, lines 8-9 TECHNICAL, 15 column 1, line 24 TECHNICAL, 24 column 2, line 35 TECHNICAL, 25 column 1, lines 31-32 column 2, line 14 TECHNICAL, 28 column 1, line 9 column 2, lines 15-21 TECHNICAL, 29 column 2, line 2 TECHNICAL, 33 column 1, line 25 TECHNICAL, 36 column 2, line !9 Error spelling: ... criteria, exception dissolved... editing; spacing between lines spelling: ... residentts would be... spelling: ... 16:1 for a conservation ... editing: Figure I-ll shows typical construction details editing:.,, over the pipe- line (Figure 1-10)... spelling: ... .to which Sy_nnyvale Clows... editing: misplaced para- graph editing:... the recom- mended project. . ; spelling: ... forms the surface s^tum along. . . editing: ... become £ plastic when. . . Correction ... criteria, except- . Ing dissolved... close spacing, result- ing in one paragraph .. . residents^ woul d be.. . ... 16:1 for a conser- vat ive... delete sentence: "Figure I-ll presents ... of the project." ... over the pipeline (Figure l-lp..- -- ... to which Sunnyvale flows... insert lines 15-21, after page 26, column , 1, line 28 ... the Basin Plan alternative... ...forms the surface stratum along... ... become plastic when. .. TECHNICAL, 45 Table 11-4 editing: table not com- pletely 1 ined TECHNICAL, 49 editing:... assuming the column 1, lines 17-18 disposal project is noj^ operational. TECHNICAL, 53 column 1, line 34 editing:... in the _lower Bay is column 2, lines 34-40 editing: spacing between lines and indentation of lines 35-40 TECHNICAL, 54 column 2, 1ine 27 TECHNICAL, 56 column 1, lines 35-37 TECHNICAL, 57 column 1, line 8 column 2, line 18 column 2, line 41 TECHNICAL, 58 Table 11-9, line 14 TECHNICAL, 61 Table 11-10 punctuation:... of tin- South BaVj_ (Consovr- Bechtc-1 . . . spelling:... by Dr. Horn at... 1977). Dr. Horn's studies. . . punctuation: ... July, 1978. May be punctuation:..- 1976-77^ (RWQCB. . . punctuation: recreational facil spelling: Nickle editing: Notes (1), (2) and (3) are for Tablt- 11-10 add vert ten 1 liny between the first two columns ... assuming selection of No Further Action or Upgraded Treatment alternatives. ... in the Lower Bay is close spacing, result- ing in one paragraph; adjust left margin of column one space ... uf the Sooth Bay (Consour-Bwhtt'l... ... by Dr. Home at. .. 1977). Dr. Horne's studies... ... July, 1978). May be... ... 1976-77 (RWQCB... ... recreational fac ilit ies Nickel add line below note (3), column 2, line 15, to separate table from text 135 ------- Vo 1 ume, P;i (•<• Column and Linn TECHNICAL, 63 Figure 11-14 TECHNICAL, 64 column 1, 1ine 38 TECHNICAL, 68 column 1, lino 14 column 2, line 25 column 2, line 30 TECHNICAL, 69 column 1, line 2 column 1 , 1 inc. 23 column 1, ]ine 32 column 2, line 23 TECHNICAL, 70 TECHNICAL, 76 column 1, line 25 Error printing page 63 has incorrect yellow pattern editing: ... in Table 11-10;' the... editing: ... include Asychis Elongata. . . editing:. . . or S. Leiantha) . editing:,,. Algal "mats" or "films". editing:... -pickleweed (Sal ic_nrni_a j>j>. ) is , , , spelling:... from the picklewocxl zone. spelling:,,. Alejneda song sparrow. . . punctuation:.,, salt ^ (Dist ichl is. . . editing: Figure number omitted editing: Table 11-11 does not show Coyote Creek st at ions column 2, 1ine 11 spelling: ... dieoff of acquatic invertebrates... Correction replace with new page 63 supplied with EPA transmittal dated 3 July 1979 ... in Table II-U; the.. . ... include Asychis elongata... ... or S. leiantha). .. . iilgal "mats" or films. . . . picklcweed (Salicornia sp.) is... ... from the picklt?- wo_ed zone. ... Alameda song sparrow... ... salt grass (Distichlis. . . add Figure 11-16 to legend replace reference to Station 11, Table II- 11 with stations 1-6, pages H.31 - H.34, H. 79 - H.83, H.109 - H. Ill, H.254 - H.256, H.269 - H.270, H.276 - H.277 and H.284 - H. 285 in Appendix H. ... dieoff of aquatic invertebrates... Vo 1 ume, Pa ge Column and Line column 2, line 35 TECHNICAL, 77 column 1, line 9 TECHNICAL, 82 column 2, line 34 TECHNICAL, 89 column 2, line 25 TECHNIAL, 91 Figure 11-20 TECHNICAL, 92 column 1, line 36 TECHNICAL, 97 Figure 11-22 Error punctuation:... Hunter 1979; Hunter 1969; Hunter... editing: Table 11-11 does not show Cuadalupe Slough station editing:... Slough in San Mateo County... . ..biostraitigraphic... printing: page 91 has incorrect yellow pattern editing: Figure 11-22 does not show the middens printing: page 97 has incorrect yellow pattern editing: Ranch Rincon del Arroyo de San Francisquito TECHNICAL, 98 punctuation: By 1974, column 1, lines 27-32 the.... 30 percent manu- facturing employees in 1974, 102,800... manu- facturing industries TECHNICAL, 103 Figure 11-23 printing: page 103 has incorrect yellow pattern Correction ...Hunter^ 1979; Hunter^ 1969; Hunter., replace reference to station 13, Table ti- ll with Station 14, pages H.39 - H.40, H.87 - H.89, H.260, in Appendix H. ... Slough in Alameda County... .. . biostrat^igraphie. . replace with new page 91 supplied with EPA transmittal dated 3 July 1979 delete: ... (A and B in Figure 11-22). replace with new page 97 supplied with EPA transmittal dated 3 July 1979 Rancho Rinconada del Arroyo de San Francisquito By 1974, the... 30 percent manufacturing employees^ _Tn 1974, 102,800... manufactur- ing industries. replace with new page 103 supplied with EPA transmittal dated 3 July 1979 136 ------- Volume, Page Column and Line Error Correction Volume, Page Column and Line Error Correct ion TECHNICAL, 109 column I, line 18 column 1, lines 32-33 column 2, line 7 TECHNICAL, 110 column 2, lines 15-16 TECHNLAL, HI column 2, ]ine 26 TECHNICAL, 112' column 1, line 18 column 2, lines 35-36 TECHNICAL, 1.1.4 column 2, line 39 TECHNICAL, U5 column 2, line 34 TECHNICAL, 116-117 Figure It-25 TECHNICAL, 118 column 1, line 33 TECHNICAL, 123, column 1, line 4 TECHNICAL, 129 column 2, line 40 editing: ... the Palo Alto Wetland Preserve.. editing:... Palto Alto Flood Retention Basin is. . . editing:... Che Flood Retention Basin is ... editing:... to the pro- posed pipeline outfall north... editing: Figure fI-24 does not show refuge punctuation: ... and enjoyment editing: ... the Flood Retention Basin-to... editing: »'Palo Alto Flood Basin editing: The Palo Alto Flood Retention Basin, printing: Figure 11-25 has incorrect blue pattern spelling: ... is concj"e_ned: editing: Table 11-24 does not show South Bay Aqueduct monthly deliveries editing: ... (see Section III.1.2, Study ... .. . the Palo Alto Baylands Reserve... ... Palo Alto Baylands Reserve is... ... the Baylands Reserve is... ... to the Basin Plan alternative outfall locat ton north... change reference to Figure 11-20 . . . and enjoyment_._ ... the designated Baylands Reserve to... • Palo Alto Baylands Reserve The Palo Alto Baylands Reserve, a... replace with new pages 115-116 supplied with EPA submittal dated 3 July 1979 ... is concerned: change reference to Table 11-25 ... (see Section III. 1.3, Study... TECHNICAL, 130 column 1, line 9 column 1, 1ine 26 TECHNICAL, 133 column 1, line 3 punctuation: ... erosion problems^ removal... punctuation: ... will include ^revegetatinn... editing: ... equipment (Section III.2). column I, lines 32-36 editing: misplact-d footnote TECHNICAL, 148 column 1, line 12 TECHNICAL, 155 column 1, line 39 TECHNICAL, 157 column 2, line 16 TECHNICAL, 167 spelling:... and par- tically insulated,.. spelling: ... xt Santa Clara County. editing:... which the authority operates... editing: misplaced para- column 1, lines 20-36 graph TECHNCIAL, 176 column I, line 3 TECHNICAL, 204 column 1, line 20 TECHNICAL, 206 column 2, line 2 ' TECHNICAL, 207 column 2, line 31 TECHNICAL, 214 column 1, line 17 column 2, lines 34-37 spelling:... violate standard, even... spelling:.. South Bay.. at the spelling:... Bay have. been... spelling:. . County.,. Contra Costs editing: misplaced foot- note editing: the sentence "For detailed..-Bechtel Inc., 1974." is a not to Table V~3 ... erosion problems; remova1... ...will Lncl udi'^ revegetat ion. . . ... equipment (Sort ion II1-2). insert 1 ines 32-36 after line 39, column 2 of page 132 .. .nnd part_tal ly insulated... ...of Santa Clara County. ...which the Authority operates insert lines 20-36, page 168 before column 1 line 1 ...violate standards, even... ...of the South Hav... ...Bay has been,.. ...Contra Costn County... insert after page 213, column 1, line 39 add number (4) to beginning of lines 34-37 137 ------- Volume, Page " Column and Line TECHNICAL, 218 column 2, lines 5-6 and TECHNICAL, 219 column 2, lines 5—42 TECHNICAL, 220 ' ' column i', lines 1-15 • column 1, lines 36-39 column 2, lines 1-4 TECHNICAL. 218 column 2, lines 6—42 antl • - TECHNICAL, 219 ' column 1, lines 1-36 TECHNICAL, 222 column 1, Iine 2 column 1, 1ino 19 TECHNICAL, 224 column 2, line 10 TECHNICAL, 225 column 1, 1ine 1 TECHNICAL, 260 column I, line 12 TECHNICAL, 262 Table V-25, Note (2) Error editing:... irrigable productive lands+ During the design... ...irrigation. Require- ments t are irrigated.:. ...January. ffor irrigation... editing: 5 misplaced paragraphs spelling:... recharged tanks. An... spelling:... domestic recycle^ (e.g., grey... grammar:... effect^ of percolation through the soil iji assumed... punctuation:... alter- natives discussed below) were... editing:... to the SCVWD price of... spel1 ing:... for San FUipe. . . Correction insert lines 6-42, column 2, p 219; 1-15, column 1, p 220; 36-39, column 1, p 220; and 1-3 column 2, p 220 between "... lands" and "During. .'.". close line 5, column 2, page 219 with line 4, column 2, page 220 to read: ...irrigation. Require- ments for irrigation... place lines 6-42, column 2, p 218 and 1-36 column 1, page- 219, after line 14, column 1, page 218 ...recharge tanks. An. .. ... domestic recycling (e.g., grey... ...effects of percola- tion through the soil are assumed ...alternatives dis- cussed below), were... ...to the San Felipe price of. .. .. . for San Felipe. .. Volume, Page Column and Line TECHNICAL, 268 column 1, line 4 TECHNICAL, 272 column 2, lines 7-8 TECHNICAL, 273 column 1, line 22 column 1, line 27 TECHNICAL, 281 column 1, line 12 TECHNICAL, 287 column 2, line 12 APPENDIX, H-l Figure H-l APPENDIX, H-2 Figure H-2 Error spelling:... erosion at the.. . editing:... of the pro- posed disposal project. editing:... pumped to the... editing:... tie-in to the SBDA... editing:... salt marsh song sparrow spelling:... change on present land-use... editing: stations incorrect editing: stations incorrect Correction ...erosion p_f the... of the Basin Plan alternative, and... .. .pumped to a .. .tie-in to a SBDA ...Alamenda song sparrow ...change in present land-use... disregard Figure H-l; use Figure 1, page H-6 instead disregard Figure H-2; use Figure 2, page H-10 instead The arrow O) indicates point of insertion. 138 ------- Sectiop DISTRIBUTION LIST ------- ------- DISTRIBUTION LIST The following distribution list was compiled from an EPA list of required Federal and state recipients and from lists submitted by staffs of agencies represented on the South Bay Dischargers Authority Technical Advisory Committee. In addition, those individuals who have requested copies have been included on this list. FEDERAL AGENCIES U.S. Environmental Protection Agency Office of Legislation A-103 Congressional Affairs Division Washington, D.C. 20460 2 U.S. Environmental Protection Agency Office of Public Affairs A-107 Washington, D.C. 20460 2 U.S. Environmental Protection Agency Office of Water Programs Operations Oil and Special Material Control Division (WH-548) Washington, D.C. 20460 2 U.S. Environmental Protection Agency Office of Federal Activities A-T04 (Attn: Ms. Susan Watkins) Washington, D.C. 20460 U.S. Environmental Protection Agency Region IX, EPA Library 215 Fremont Street San Francisco, CA 94105 U.S. Environmental Protection Agency Public Reference Unit (PM 213) Room 2922 401 M Street, SW Washington, D.C. 20460 U.S. Environmental Protection Region IX - Attn: Ms. Lauren 215 Fremont Street San Francisco, CA 94105 10 >ndanl U.S. Department of Agriculture Office of the Secretary Environmental Quality Activities - P>oom 307A 14th & Independence Avenue, SW Washington, D.C. 20250 2 U.S. Department of Agriculture Soil Conservation Service P.O. Box 1019 Davis, CA 95616 U.S. Department of Agriculture Regional Forester 630 Sansome Street San Francisco, CA 94111 U.S. -Army Corps of Engineers Environmental Resources Branch South Pacific Division 630 Sansome Street San Francisco, CA 94!11 3 U.S. Army Corps of Engineers Environmental Branch 211 Main Street San Francisco, CA 94105 2 U.S. Army Corps of Engineers Executive Direct9r of Civil Works Office of the Chief of Engineers Washington, D.C. 20314 2 U.S. Department of Defense Deputy Assistant Secretary of Defense Environmental Quality OASD (HE), Pentagon Washington, D.C. 20301 U.S. Army Corps of Engineers Sacramento District 650 Capitol Mall Sacramento, CA 95814 U.S. Department of the Interior Assistant Secretary, Program Policy Attn: Office of Environmental Project Review Washington, D.C. 20240 20 141 ------- U.S. Ehvironmental Protection Agency Region IX - Attn: Mr. Chuck Fllppo Public Information Center 215 Fremont Street San Francisco, CA 94105 20 Council on Environmental Quality 722 Jackson Place, NW Washington, B.C. 20006 5 U.S. Department of Agriculture Agricultural Extension Service Attn: Mr. Robert Ayers university of California Berkeley, CA 94705 San Francisco National Wildlife Refuge Attn: Me. Robert Personius 3849 Peralta Blvd. Fremont, CA 94536 U.S. Fish and Wildlife Service Attn: Mr. Rick Breitenbach 800 Cottage Way Sacramento, CA 95825 U.S. Fish and Wildlife Service Bureau of Sport Fisheries P.O. Box 3737 1500 N.E. Irving Street Portland, OR 972CG U.S. Department of the Interior Water and Power Resources Service Attn: Mi:.- Haydn C. Lee, Jr. 2800 Cottage Way Sacramento, CA 95825 Federal Highway Administration Office of Environmental Policy 400-7th Street, SW Washington, D.C. 20590 2 Urban Mass Transportation Administration Office of Program Operations 400-7th Street, SW Washington, D.C. 20590 2 142 U.S. Department of the Interior Western Division P.O. Box 36063 450 Golden Gate Avenue San Francisco, CA 94102 U.S. Department of the Interior Bureau of Sport Fisheries and Wildlife 650 Capitol Mall, Room 40616 Sacramento, CA 95813 Federal Highway Administration Two Bnbarcadero Center - Room 530 San Francisco, CA 94111 Urban Mass Transportation Administration Region IX - Box 36125 45u Golden Gate Avenue San Francisco, CA 94102 Department of Transportation 12th Coast Guard District 630 Sansome Street San Francisco, CA 94126 U.S. Coast-Guard Attn: Mr. N. Bell Marine Environmental Protection Branch Office Aids to Navigation Branch 230 Sansome Street San Francisco, CA 94126 U.S. Department of Transportation Box 36133 450 Golden Gate Avenue San Francisco, CA 94102 2 Dr. Billy Welch SAF/ILE - Room 4C885 Pentagon Washington, D.C. 20330 Mr. Bruce Hildebrand Office of the Asst. Secretary of the Army (Civil Works) - Room 2E567 - Pentagon Washington, D.C. 20310 ------- Mr. Peter McDavitt Special Asst. to the Secretary of the Navy (Installations and Logistics) Crystal Plaza No. 5 22l1 Jefferson Davis Highway Arlington, VA 20360 Department of the Navy Moffett Field Naval Air Station Attn: LCDR W.V. Sayner, Jr. Assistant Public Wbrks Officer Moffett Field, CA 94035 2 Mr. George H. Holdaway NASA Anes Research Center Mail Stop 213-1 Moffett Field, CA 94035 U.S. Department of Defense Office of Health and Environment Attn: Mr. George Marienthal Room 3E172, Pentagon Washington, D.C. 20301 Mr. J. Thompson U.S. Geological Survey 345 Middlefield Road Menlo Park, CA 94025 U.S. Geological Survey Attn: Drs. A. Grantz, F. Nichols, D. McCullough 845 Middlefield Road Menlo Park, CA 94025 U.S. Department of Health, Education and Welfare, Region IX 50 Fulton Street San Francisco, CA 94102 2' U.S. Department of Housing and Urban Development Environmental Clearance Officer One Bnbarcadero Center, Suite 1600 San Francisco, CA 94111 U.S. Department of Housing and Urban Development 450 Golden Gate Avenue San Francisco, CA 94102 2 U.S. General Services Administration Region IX 49 Fourth Street San Francisco, CA 94103 National Commttee of Water Quality Attn: Mr. James Larocca 1111-18th Street, NH P.O. Box 19266 Washington, D.C. 20036 2 Water Resources Council Office of Associate Director 2120 L Street, NW, Suite 800 Washington, D.C. 20037 2 Federal Energy Administration Attn: Environmental Impacts Division New P.O. Building 12th and Pennsylvania Avenue, NW Washington, D.C. 20461 2 U.S. Department of Coimierce Office of Environmental Affairs Conmerce Building, Room 2816 . Washington, D.C. 20230 2 U.S. Food and Drug Administration Attn: Mr. David Alton, Regional Shellfish Consultant 50 Fulton Street San Francisco, CA 94118 Advisory Council on Historic Preservation 1522 K Street Washington, D.C. 20005 ' 2 Advisory Council on Historic Preservation P.O. Box 25085 Denver, CO 80225 ------- LIBRARIES INDIVIDUALS AND PRIVATE GROUPS Documents librarian Santa Clara County Library Research Center 10400 Torre Avenue Cupertino, CA 95014 San Jose Public Library 180 W. San Carlos Street San Jose, CA 95110 Palo Alto Public Library 1213 Newell Road Palo Alto, CA 94303 Santa Clara County library 7387 Rosanna Street Gilroy, CA 95020 Santa Clara County library 78 South Dempsey Road Milpitas, CA 95035 Mauntain View Public Library 585 Franklin Street Mauntain View, CA 94040 library Water Resources Center University of California Berkeley, CA 94720 Santa Clara Public library 2635 Homestead Road Santa Clara, CA 95051 Sunnyvale Public library Attn: Documents librarian 665 West Olive Avenue Sunnyvale, CA 94086 Santa Clara County Library 1095 North 7th Street San Jose, CA 95112 NASA, Anes Research Center Technical library fcfcffett Field Sunnyvale, CA 94040 Northern California Corrmission Environmental Information P.O. Box 761 Berkeley, CA 94701 for California Farm Bureau Federation Attn: J. Goold 2855 Telegraph Avenue Berkeley, CA 94705 California Wildlife Federation and Salmon Unlimited 890 Washington Santa Clara, CA 95050 National California Gomnission for Environmental Information 1828 Hopkins Street Berkeley, CA 94707 Bay Area League of Industrial Associations, Inc. 3640 Grand Avenue Oakland, CA 94612 California Canners and Growers 312 Stockton Avenue San Jose, CA 95126 California ttenufacturers Association 923-12th Street Sacramento, CA 95814 Builders Assn. of Santa Clara and Santa Cruz Counties 345 Saratoga Avenue Santa Clara, CA 95050 Environmental Information Center Environmental Studies Department San Jose State University 125 South 7th Street San Jose, CA 95114 Stanford Conmission for Environmental Information Stanford University lyfedical Center Room M-C Stanford, CA 94301 144 ------- Santa Clara County Landowners Association 1020 Willow Street San Jose, CA 95125 San Jose Chamber of Conmerce Attn: Mr. Jim Tucker 1 Paseo de Antonio San Jose, CA 95114 Central Santa Clara League of Women Voters 1142 South Genevieve Lane N-' San Jose, CA 95128 Sierra Club 1711 Harte Drive San Jose, CA 95124 League of Women Voters of Los Gatos 19224 Dehavilland Drive Saratoga, CA 95070 Ecology Action San Jose City College 2100 Moorpark Avenue San Jose, CA 95114 Central Santa Clara Valley League of Women Voters 1668 Juanita Avenue San Jose, CA 95125 Marshland Development Go. P.O. Box 205 Alviso, CA 95002 Sequoia Audubon Society Attn: Ms. Ruth T. Smith 1231 Hoover Street Menlo Park, CA 94256 Save Our Sloughs c/o Ms. Nancy Holmes 843 Moana Court Palo Alto, CA 94306 League of Women Voters of California 126^Post Street . San Francisco, CA 94108 Peninsula Conservation Center 1176 Emerson Street Palo Alto, CA 94301 Santa Clara Audubon Society 1176 Bnerson Street Palo Alto, CA 94301 Committee for Green Foothills 1176 Bnerson Street Palo Alto, CA 94301 Sierra Club Loma Prieta Chapter 1176 Bnerson Street Palo Alto, CA 94301 The Nature Conservancy Northern California Attn: Ms. Mary Jefferds 2932 Pine Way Berkeley, CA 94705 California Tomorrow Monadnick Building 681 Market Street San Francisco, CA 941.05 Mr. Vemon J. Smith California Wildlife Federation 14690 Wyrick Avenue San Jose, CA 95124 The Adam E. Treganza Anthropology Museum San Francisco State University 1600 Holloway Avenue San Francisco, CA 94132 Conservation Associates 220 Bush Street San Francisco, CA 94104 California Native Plant Society 2490 Channing Way, itoom 317 Berkeley, CA 94704 ' People for Open Space 126 Post Street, foom 607 San Francisco, CA 94108 145 ------- Environmental Defense Fund 2728 Durant Avenue Berkeley, CA 94704 San Francisco Bay Area Council, Inc. World Trade Center San Francisco, CA 94111 Environmental Quality Coordinating Council of San Mateo County P.O. Box 219 Menlo Park, CA 94025 Sierra Club San Francisco Bay Chapter 5608 College Avenue Oakland, CA 94618 Save San Francisco Bay Association P.O. Box 925 Berkeley, CA 94701 P.G.& E. Land Department 77 Beale Street, Poom 1245 San Francisco, CA 94106 Mrs. Wn. McD. Eastman 13221 West Sunset Drive Los Altos Hills, CA 94022 Raychem Corporation Attn: Mr. Dick'Hopkins 300 Constitution Drive Menlo Park, CA 94025 i Coyote Point Museum Coyote Point San Mateo, CA 94401 Environmental Information Center San Jose State University 125 South 7th Street San Jose, CA 95192 San Mateo County Development Association, Inc. 4 West 4th Avenue San Mateo, CA 94403 Santa Clara Audubon Society 14875 Cole Drive San Jose, CA 95124 146 Anerican Society of Civil Engineers 160 Sansome Street San Francisco, CA 94104 Automotive Assembly Division Attn: R.M. Hanselinan P.O. Box 1586 Allen Park, ME 48101 Santa Clara County Canners Association Attn: L.K. Taber, Secty./Treas. 1007 L Street Sacramento, CA 95814 lvt. Carl Harris 3708 Mt. Diablo Blvd. Lafayette, CA 94549 Mr. Ken Boyd 4011 Glenwood Drive Santa Cruz, CA 95060 City of Gilroy Attn: Mr. Scott LaFauer Gilroy, CA 95020 Mr. George Gritton 15045 Sycamore Avenue Morgan Hill, CA 95037 Mr. George Green P.O. Box 1368 Los Gatos, CA 95030 Mr. Neil Neilson P.O. Box 1297 Los Altos, CA 94022 Ms. Roberta Varney 2375 Lida Drive Mountain View, CA 94040 Mr. George Lydon Greater San Jose Homeowners Association 2788 Woodmoor Drive San Jose, CA 95127 Friends of the Earth 529 Conmercial Street San Francisco, CA 94111 ------- Oceanic Society Fort Mason Building, 240 - San Francisco, CA 94123 Regional Parks Association c/o Ms. Alice Q. Howard 6415 Regent Street Oakland, CA 94612 W.W. Dada Dried Fruit Association of California Box 270A Santa Clara, CA 95052 Ms. ^ary Anna Eklund Return Oil & Rerefine 971 Ticonderoga Drive Sunnyvale, CA 94037 Mr. Ronald Gerke Ameron Pipe Products Group Northern California Division P.O. Box 3396 Hayward, CA 94540 A.B.M. Houston, Manager Ford Motor Company Compliance and Liaison Department 1 Parklane Blvd., Suite 628, Parklane Vfest Dearborn,MI 48126 Mr. Dan Chapin c/o Chapco 2200 Sand Hill Road Menlo Park, CA 94025 Mr. John Jost 737 Harvard Sunnyvale, CA 94087 Santa Clara Co. Medical Society Attn: Dr. Kenneth Hayes 700 Bnpey Way San Jose, CA 95128 Mr. Stephen D. Lux 361 Greenpark VJay San Jose, CA 95136 Mr. Jim Quintal California Canners and Growers 182 South Farroaks Avenue Sunnyvale, CA 94086 Mr. Bd Ramey Santa Clara Chamber of Coimierce Industrial Citi2ens Council Santa Clara, CA 95050 M.L. Sellers lockheed Missile and Space Co. P.O. Box 504 Sunnyvale, CA 94088 Me. Eddie Souza 4320 Bassett Street Santa Clara, CA 95054 Ms. Bea Brown Santa Clara Valley Coalition 485 Aspen Way IDS Altos, CA 94022 E.L. Mitchell 312 Stockton Avenue San Jose, CA 95126 R. Ilse and W. Doucett 182 South Fairoaks Avenue Sunnyvale, CA 94086 Anerican Association of Uhiversity Wbraen 1165 Minnesota Avenue San Jose, CA 95125 Ms. Julie Stephenson 1742 McBain Avenue San Jose, CA 95125 People for Open Space 46 Kearny Street, Poora 400 San Francisco, CA 94108 Mr. Thomas 0. Chan,-Sr. Engineer San Francisco Water Department 425 Mason Street San Francisco, CA 94102 147 ------- Ihe Nature Conservancy 215 Market Street San Francisco, CA 94105 Ms. Jane Baron 232 Hillview Avenue Los Altos, GA 94022 Mr. Walter V. Hays 111 W. St. John Street San Jose, CA 95113 J.B. Gilbert & Associates Clareraont Hotel Berkeley, CA 94705 George S. Nolte & Associates Attn: Mr. Charles Hall 1731 N. First Street San Jose, CA 95112 William Spangle & Associates Attn: Mr. George Mader 3240 Alpine Road Portola Valley, CA 94025 H.E. Stone Bay Area League of Industrial Associations P.O. Box 3575 San Francisco, CA 94119 Ford Motor Company P.O. 1T01 San Jose, CA 95108 Mr. Edward Mitchell, President Santa Clara County Canners Association 312 Stockton Avenue San Jose, CA 95126 Ms. Bea Slater, Secretary Textile Service Industries, 958-28th Street Oakland, CA 94608 Inc. Mr. Laurence B. Mitchell, Boardmember Tri-County Apartment Association, Inc. 996 Minnesota Avenue San Jose, CA 95125 Mr. Paul McKeehan 890 Washington Street Santa Clara, CA 95050 Mr. John Sampson 3992 Bibbits Drive Palo Alto, CA 94303 Jan Bridges 615 South Main Street Milpitas, CA 95035 Mr. Patrick T. Ferraro 351 Brookwood Drive San Jose, CA 95116 Mr. Charles Bigelow 873 Santa Cruz Avenue Menlo Park, CA 94025 Marion Softkey 320 Fiicinal Avenue ^nlo Park, CA 94025 Mr. Spense Havlick Environmental Studies Department San Jose State University San Jose, CA 95114 Dr. H.T. Harvey Department of Biological Science San Jose State University San Jose, CA 95114 Brown and Caldwell Attn: Mr. John T. Bovey 1501 N. Broadway Walnut Creek, CA 94596 Rene Fuog 531 Sierra Avenue Mountain View, CA 94041 Dr. R. G. Spicker Civil Engineering San Jose State University San Jose, CA 95114 148 ------- Dr. G.E. Lindsay California Academy of Sciences Golden Gate Park San Francisco, CA 94118 Dr. Itobert E. Selleck Sanitary Engineering Res. lab. U.C. Berkeley Berkeley, CA 94720 Consoer-Townsend & Associates 1671 The Alameda San Jose, CA 95126 Jenks and Adamson 543 Byron Street Palo Alto, CA 94301 Kennedy Engineers 657 Howard Street San Francisco, CA 94105 Metcalf and Eddy 1029 Corporation Way Palo Alto, CA 94303 California Builders Council 925 L Street, Suite 700 Sacramento, CA 95814 Bay Area Clean Waters Conmission 1450 Creekside Drive Walnut Creek, CA 94596 Conservation Coordinators P.O. Box 4161 Woodside, CA 94062 Sierra Club P.O. Box 7472 Stockton, CA 95207 Bay Area Planning Directors Association 835 East 14th Street San Leandro, CA 94577 Ecology Center 2179 Alston Way Berkeley, CA 94704 Assoc. Sportsman of California 2636 Judah Street San Francisco, CA 94122 Stanford University Sponsored Projects Information Center Attn: Ms. Kathy Walby Stanford, CA 94305 Stanford Conservation Group Tresidder Union Stanford University Stanford, CA 94305 California Federation of Labor 995 Market Street San Francisco, CA 94102 Bay Area Clean Water Council 5009 Charles Avenue El Cerrito, CA 94530 South County Ecology Center 18313 Pepper Street Castro Valley, CA 94546 TRI-City Ecology 2754 Olive Avenue Fremont, CA 94538 League of Women Voters P.O. Box 2638 Fremont, CA 94536 California Native Plant Society 2490 Channing Way, Ftoom 317 Berkeley, CA 94705 Sierra Club Air Pollution Task Force 340 Johnson Avenue Los Gatos, CA 95030 Chabot College 2555 Hesperin Blvd. Hayward, CA 94545 Trustees for Conservation 170 Arlington Avenue - Berkeley, CA 94707 149 ------- Ecology Center of San Francisco 13 Columbus Avenue San Francisco, CA 94111 IDS Altos Chamber of Conmerce 321 university Avenue Los Altos, CA 94022 Mountain View Chamber of Coimerce 580 Castro Mountain View, CA 94040 Menlo Park Chamber of Conmerce 1100 Merrill Menlo Park, CA 94025 Palo Alto Chamber of Commerce 2 Palo Alto Square Palo Alto, CA 94304 Sunnyvale Chamber of Conmerce South Murphy Avenue and West Olive Avenue Sunnyvale, CA 94036 Santa Clara Chamber of Coinnerce 1515 El Camino Road Santa Clara, CA 95050 Cupertino Chamber of Conmerce 10300 South Saratoga-Sunnyvale Road Cupertino, CA 95014 San Mateo Co. Historical Museum Association 1700 West Hillsdale Blvd. San Mateo, CA 94402 Historical Heritage Gommssion County of Santa Clara 70 West Hedding Street, Room 524 San Jose, CA 95110 Department of Mthropology Cabrillo College 6500 Sequel Drive Aptos, CA 95003 Mr. Don Sandberg Ruth and Going, Inc. P.O. Box 26430 San Jose, CA 95159 150 Lc>rna Prieta Chapter Sierra Club SBDA Committee 1176 finer son Palo Alto, CA 94301 Mr. Steve Krenselok Environmental Impact Planning Corporation 319-11th Street San Rrancisco, CA 94103 Mr. Michael Filice NCC Food Corporation 570 Race Street San Jose, CA 95126 Assoc. General Contractors of. California, 301 Capitol Mill Sacramento, CA 95814 Ms. Betty Joyce Limysk 956 Trophy Drive Mountain View, CA 94040 Mr. Gary Stevens Biology Department university of San Francisco San Francisco, CA 94117 . Mr. Martin Seldon c/o Varian 611 Hansen Way Palo Alto, CA 94303 Prof. Perry L. l-fcCarty Civil Engineering Department Stanford University Stanford, CA 94305 Mr. Myron Tatarian Public Vforks Department City Hall, toom 260 San Francisco, CA 94102 A.H. Frye, Jr. San Francisco Wkter District 425 Mason Street San Francisco, CA 94102 Inc. ------- Southern Pacific Transportation Company Attn: J.W. Zwick 1 Market Street San Francisco, CA 94105 Leslie Salt Company 7220 Central Avenue Newark, CA 94560 Bechtel, Inc. Attn: Ms. Carol M. Harper 301/4/B10 P.O. Box 3965 San Francisco, CA 94119 Mr. Michael Melanson 3717 Winston Way Carmichael, CA 95608 E.H. Smith and Associates Attn: E.H. Stnith 4090 Harrison Grade Road Sebastopol, CA 95472 15 Hydroscience, Inc. Attn: D. Szunsky 2815 Mitchell Drive Walnut Creek, CA 94598 Pacific Environmental Laboratory Attn: T. Nakamura 657 Howard Street San Francisco, CA 94105 R.C. Harlan and Associates Attn: R.C. Harlan Sharon Building, Suite 401 55 New Montgomery San Francisco, CA 94105 151 ------- STATE AGENCIES California State Office of Intergovernmental Management Attn: Mark Briggs, Room 108 1400 - 10th Street Sacramento, CA 95814 State Water Resources Control Board Attn: Wayne Pierson P.O. Box 100 Sacramento, CA 95801 University of California at Davis Attn: Dr. Robert Hagen Davis, CA 95616 State Attorney General's Office 6000 State Building 350 McAllister Street San Francisco, CA 94102 State Office of Historic Preservation 1416 9th Street Sacramento, CA 95814 20 State Department of Public Health Attn: William Joppling 2151 Berkeley Way Berkeley, CA 94704 Regional Water Quality Control Board San Francisco Bay Region Attn: Robert Scholar 1111 Jackson Street Oakland, CA 94607 State Water Resources Control Board Attn: Curtis Swanson P.O. Box 100 Sacramento, CA 95801 Agricultural Extension Service University of California County of Santa Clara Attn: Peter Lert 215 N. First Street San Jose, CA 95113 152 ------- REGIONAL AGENCIES AND LOCAL GOVERNMENT Bay Area Air Pollution Control District 939 Ellis Street San Francisco, CA 94109 San Francisco Bay Conservation and Development Commission Attn: Patty Weesner 30 Van Ness Avenue San Francisco, CA 94102 Metropolitan Transportation Commission Hotel Claremont Berkeley, CA 94705 Association of Bay Area Governments Attn: Robert Wong Claremont Hotel Berkeley, CA 94705 Santa Clara County Health Department Attn: E.H. Pearl 2220 Moorpark Avenue San Jose, CA 95128 San Benito County Board of Supervisors Attn: George E. Shore, Chairman Courthouse, Boom 204 Hollister, CA 95023 South Bay Dischargers Authority Attn: Mr. A.R. Turturici, Director City of San Jose Public Works Department 801 North First Street San Jose, CA 95110 City of San Jose Attn: City Manager 801 North First Street San Jose, CA 95110 City of San Jose Planning Department 801 North First Street San Jose, CA 95110 City of Santa Clara Attn: Robert R. Mortenson 1500 Warburton Avenue Santa Clara, CA 95059 City pf Hayward Planning Department 22300 Foothill Blvd. Hayward, CA 94541 City of Campbell Planning Department 75 N. Central Avenue Campbell, CA 95008 City of Newark Planning Department 37101 Newark Blvd. Newark, CA 94560 City of Fremont Planning Department 39700 Civic Center Drive Fremont, CA 94538 City of Palo Alto Attn: City Manager 250 Hamilton Street Palo Alto, CA 94301 City of Mountain View Attn: Norman H. Dougee 540 Castro Street Mountain View, CA 94041 City of Sunnyvale Attn: City Manager 456 Olive Avenue Sunnyvale, CA 94088 153 ------- South Santa Clara Valley Water Conservation District Attn: Mike Sheeny 7951-B Wren Avenue Gilroy, CA 95020 Agricultural Extension Service University of California County of San Benito Attn: Edward Lydon P.O. Box 820 Hollister, CA 95023 Santa Clara Valley Water District Attn: Lloyd Fowler, Chief Engineer 5750 Almaden Expressway San Jose, CA 95118 San Jose/Santa Clara Treatment Plant Advisory Committee Waste Pollution Control Plant 700 Los Esteros Road San Jose, CA 95131 East Bay Dischargers Authority Attn: Wayne Bruce 22300 Foothill Blvd. Hayward, CA 94541 Menlo Park Sanitary District 500 Laurel Street Menlo Park, CA 94025 Cupertino Sanitary District 20065 Stevens Creek Blvd. Cupertino, CA 95014 Santa Clara County Sanitation District No. 4 100 E. Sunnyoaks Drive Campbell, CA 95008 Santa Clara County Board of Supervisors Attn: County Executive 70 West Hedding Street San Jose, CA 95110 N. Daniels, General Manager Union Sanitary District 4057 Baine Avenue Fremont, CA 94536 Strategic Consolidation Sewerage Agency 666 Elm Street San Carlos, CA 94020 Santa Clara County Planning Department 70 West Hedding San Jose, CA 95110 Santa Clara County Parks and Recreation Department 70 West Hedding San Jose, CA 95110 San Mateo County Planning Department County Government Center Redwood City, CA 94063 San Mateo County Attn: Henry F. Eich Office of Environmental Health 590 Hamilton Street Redwood City, CA 94063 San Mateo County Parks and Recreation Department County Government Center Redwood City, CA 94063 Santa Clara County Public Works Department 1555 Berger Drive San Jose, CA 95112 154 ------- \\ City pf Santa Clara Planning Department 1500 Warburton Avenue Santa Clara, CA 95050 City of Mountain View Planning Department 540 Castro Street Mountain View, CA 94040 City of Sunnyvale Planning Department P.O. Box 607 456 W. Olive Avenue Sunnyvale, CA 94088 City of Los Altos Planning Department IN. San Antonio Road Los Altos, CA 94022 City of Palo Alto Planning Department Attn: Elizabeth Crowder 250 Hamilton Street Palo Alto, CA 94301 City of Menlo Park Director of Community Development Civic Center Menlo Park, CA 94025 City 9f San Mateo Planning Department 330 W. 20th Avenue San Mateo, CA 94402 City of Redwood City Planning Department 1017 Middlefield Road Redwood City, CA 94063 City 9f Milpitas Planning Department 455 E. Calaveras Blvd. Milpitas, CA 95035 City of Cupertino Planning Department City Hall, 10300 Torre Avenue Cupertino, CA 95014 Town of Los Altos Hills Planning Department 26379 Fremont Road Los Altos Hills, CA 94022 City of Union City Planning Department 1154 Wipple Road Union City, CA 94587 City of Los Gatos Planning Department P.O. BOJ? 949 Los Gatos, CA 95030 City of Monte Sereno Planning Department 18041 Saratoga-Los Gatos Road Monte Sereno, CA 95030 City of Palo Alto Attn: Mr. H.R. Remmel 250 Hamilton Avenue Palo Alto, CA 94301 City of Sunnyvale Attn: D.M. Somers 456 West Olive Avenue P.O. Box 607 Sunnyvale, CA 94088 San Mateo County Board of Supervisors County Government Center Redwood City, CA 94063 155 ------- I / San Mateo County Engineering Department County Government Center Redwood City, CA 94063 Alameda County Planning Department 399 Elmhurst Hayward, CA 94544 County of San Benito" Attri: County Executive Hollister, CA 95023 Mid-Peninsula Regional Park District c/o Herbert Grench 745 Distell Drive Los Altos, CA 94022 Parks and Recreation Department Vasona Park 300 Garden Hill Drive Los Gatos, CA 95030 Bay Area Rapid Transit District 800 Madison Street Oakland, CA 94601 San Benito County Farm Bureau Veterans Memorial Building Hollister, CA 95023 Santa Clara County Grand Jury Attn: Phyllis Austin 26650 St. Francis Drive Los Altos Hills, CA 94022 Santa Clara County Farm Bureau 186 E. Gish Itoad San Jose, CA 95112 LAFCO 1221- Oak Street Oakland, CA 94612 156 San Francisco City and County Board of Supervisors City Hall San Francisco, CA 94102 California Farm Bureau Attn: William Du Bois llth and L Streets Sacramento, CA 95011 Mr. Richard R. Blackburn South Bay Dischargers Authority 801 North First Street San Jose, CA 95110 Mr. Frank Belick, Engineer-Manager San Jose/Santa Clara Water Pollution Control Plant 700 Los Esteros Rjad San Jose, CA 95131 Mr. Don Atkinson, Division Chief Attorney City Attorney's Office 151 West Mission Street, Raom 151 San Jose, CA 95110 Mr. William A. Gissler, Chairman South Bay Dischargers Authority 1500 Warburton Avenue San Jose, CA 95050 Ms. Janet Gray Hayes South Bay Dischargers Authority 801 North First Street San Jose, CA 95110 Ms. Suzanne Wilson South Bay Dischargers Authority 801 North First Street San Jose, CA 95110 Mr. Alan Henderson South Bay Dischargers Authority 765 San Antonio Road, #81 Palo Alto, CA 94303 ------- Mr. Gilbert Gunn South Bay Dischargers Authority 1693 Kitchener San Jose, CA 94087 LEGISLATORS Honorable Alan Cranston United States Senator 452 Senate Office Bldg. Washington, D.C. 20510 Honorable S.I. Hayakawa United States Senator 452 Senate Office Bldg. Washington, D.C. 20515 Honorable Norman Y. Mineta Member of Congress, 13th District 510 Cannon House Office Bldg. Washington, D.C. 20515 Honorable Don Edwards United States Congressman 2240 Rayburn Office House Bldg. Washington, D.C. 20515 Honorable Paul N. McCloskey, Jr. United States Congressman 205 Cannon House Office Bldg. Washington, D.C. 20515 Honorable Edmund Brown, Jr. Governor of California Sacramento, CA 95814 Honorable John Garamendi State State Senator, District 13 State Capitol Sacramento, CA 95814 Honorable Arlen Gregorio State Senator, District 10 State Capitol Sacramento, CA 95814 Honorable Jerry Smith State Senator, District 12 State Capitol Sacramento, CA 95814 Honorable Victor Calvo State Assemblyman, District 21 State Capitol Honorable Leona H. Egeland State Assemblywoman, District 24 State Capitol Sacramento, CA 95814 Honorable Richard D. Hayden State Assemblyman, District 22 State Capitol State Assemblyman, District 25 State Capitol Sacramento, CA 95814 Honorable John Vasconcellos State Assemblyman, District 23 State Capitol Sacramento, CA 95814 157 ------- NEWS MEDIA San Jose Sun Newspapers Attn: Mort Levine 10950 N. Blaney Cupertino, CA 95014 San Jose Mercury and News Attn: Tom Harris 750 Ridder Park Drive San Jose, CA 95113 Menlo-Atherton Recorder 640 Roble Avenue Menlo Park, CA 94025 Suburban Newspapers Attn: Susan Cohen 615 So. Main Street Milpitas, CA 95035 San Mateo Times and News Leader 1080 S. Bayshore Boulevard San Mateo, CA 94402 East San Jose Sun Attn: Tom Gilsenon 615 So. Main Street Milpitas, CA 95035 Palo Alto Times Attn: Bob Burgess Box 300 Palo Alto, CA 94303 San Francisco Chronicle 925 Mission Street San Francisco, CA 94103 San Francisco Bay Guardian 2700 19th Street San Francisco, CA 94132 San Francisco Examiner Attn: Carl Irving Box 3100 San Francisco, CA 94119 Oakland Tribune 13th and Franklin Streets Oakland, CA 94612 KGO TV - Channel 7 277 Golden Gate Avenue San Franisco, CA 94102 KQED - TV Channel 9 1011 Bryant Street San Francisco, CA 94103 Margaret Race KQED - TV Channel 9 500 8th Street San Francisco, CA 94103 KPIX TV - Channel 5 • 2655 Van Ness San Francisco, CA 94109 KBON TV - Channel 4 1001 Van Ness Avenue San Francisco, CA 94119 KNTV - Channel 11 645 Park Avenue San Jose, CA 95126 158 ------- \ ADDITIONS TO THE DISTRIBUTION LIST SINCE THE ISSUANCE OF THE DRAFT EIS/EIR Ms. Janis Arnhols Room 3425 U.S. Department of Commerce Washington, D.C. 20230 Dr. Howard Wright State Water Resources Control Board P.O. Box 100 Sacramento, CA 95801 Mr. Wade Berry Land Department, Rm 2B38 Pacific Gas and Electric 77 Beale Street San Francisco, CA 94106 Mr. Norm Stinman MTC Hotel Claremont Berkeley, CA 94705 Mr. Steve Morse San Francisco Bay Regional Water Quality Control Board 1111 Jackson Street, Rm 6040 Oakland, CA 94607 Office of Congressman Don Edwards Attm Bob Wieckowski Room 2329 Rayburn Building Washington, D.C. 20515 ' Mr. Joe Brecher 506 15th Street Oakland, CA 94612 Ms. Rose Thorogcod Veterans Administration, Attn: 004A 810 Vermont Ave., N.W. Washington, D.C. 20420 Mr. Steve Dalrymple CH2M Hill 555 Capitol Mall Suite 1290 Sacramento, CA 95814 Mr. G. Patrick Settles Corporate Counsel General Development Corporation 1111 South Bayshore Drive Miami, FL 33131 Mr. Brad Barharo David M. Darnbush & Co., Inc. 1736 Stockton Street San Francisco, CA 94133 Mr. Craig Anderson Environmental Quality Supervisor Jefferson Parish 3600 Jefferson Highway Jefferson, IA 20121 Mr. Mark Alpherson ABAC Hotel Claremont Berkeley, CA 94705 Ms. Linda M. Botnick, Librarian Clinton Bogert Associates 2125 Center Avenue Fort Lee, New Jersey 07024 Ms., Sue Lasher 3181 Cecil Avenue San Jose, CA 95117 Mr. Bert Martin 416 Juanita Drive Santa Clara, CA 95050 Mr. Clifford Maurer 2251 Via Maderos LOS Altos, CA 94022 Mr. Daniel Myers 510 Lincoln Avenue Palo Alto, CA 94301 Mr. Stephen T. Hayashi 657 Benvenue Los Altos, CA 94022 159 ------- Ms. Kathy Ryan - Harris 22270 Palm Avenue Cupertino, CA 95014 Ms. Julia R. Raymond 1267 Scott Blvd. Santa Clara, CA 95050 National Resources Defense Council 2345 Yale Palo'Alto, CA 94306 Mr. Jeff Gabe Citizens for Better Environment 88 First Street, Suite 600 San Francisco, CA 94105 Dr. Erman A. Pearson Professor of Sanitary Engineering Department of Civil Engineering University of California Berkeley, CA 94702 Mr. Bill Maddaus J.B. Gilbert Division Brown & Caldwell 1501 N. Broadway Walnut Creek, CA 94596 160 -------


                                        FINAL
                 ENVIRONMENTAL IMPACT
                REPORT AND STATEMENT
           TREATED WASTEWATER  DISPOSAL PROGRAM

                     -v  ^>
U.S. Ei>viroi?rtKi)taI Protection Agei>cy

South Bay Dischargers Authority

-------

-------
                                                              EPA-9-CA-South Bay Dischargers Authority - 80
                                                          FINAL
                                            ENVIRONMENTAL IMPACT REPORT
                                                          AND
                                          ENVIRONMENTAL IMPACT STATEMENT

                                          SOUTH BAY DISCHARGERS AUTHORITY
                                       TREATED WASTEWATER DISPOSAL PROGRAM

                                                        June, 1980
                  Prepared by:
                  U.S. Environmental Protection Agency
                  Region IX
                  215 Fremont Street
                  San Francisco, California 94105

                  With technical assistance from:
                  Bechtel
                  50 Beale Street
                  San Francisco, California 94119
              and
              South Bay Dischargers Authority
              801 North First Street
              San Jose, California 95110
                  Grant No.  CA-06-1135

                  RESPONSIBLE OFFICIALS:
                   3aul De Falco, J
                  Regional Administrator
                  Environmental Protection Agency
                  Region IX
              James A. Alloway £s
              Chief Executive Officer
              South Bay Dischargers Authority
04
3
ENWRONMENW MOrBnONAGMr
WASHINGTON. O.C. 20460

-------

-------
To All Interested Agencies, Public Groups, and Concerned Individuals:
      discharges were  moved  north  of  the  Dumbarton  Bridge.
The Final Environmental Impact Statement (EIS) and Environmental
Impact  Report  (EIR) for the South Bay  Dischargers  Authority
Treated Wastewater  Disposal Program is being  distributed  at  this
time for your review and comment. This program investigated alter-
natives for  providing a wastewater disposal system for the San Jose/
Santa Clara, Sunnyvale, and Palo  Alto wastewater treatment plants,
located  in  the Santa Clara County Baylands along the southeastern
edge of San Francisco Bay. The Final EIR/EIS has been prepared to
conform with  the  requirements  of the National  Environmental
Policy Act  of 1969  and  the California  Environmental Quality  Act
of 1970, as amended.

The Draft EIR/EIS was jointly  issued by the Environmental  Protec-
tion  Agency (EPA), Region  IX, and the South Bay  Dischargers
Authority (SBDA) on March 19, 1979. The Draft EIR/EIS was filed
with the State Clearinghouse (SCH No. 79040905) and with the EPA
Office of Environmental  Review (EIS Order No. 90292), and circu-
lated  for review among various Federal, State, and local agencies as
well as firms, organizations, and concerned individuals.

This document contains a record of the public hearing, responses to
the comments received at the public  hearing, written comments, and
further  information  which has  been  developed concerning the proj-
ect.  This  document,  along with the  Draft  EIR/EIS  (Summary,
Technical,  and Appendices Volumes) constitutes the Final EIR/EIS.

The  project  alternative that has been  selected  is  the "no  project
alternative."  It was selected for the following reasons:

   1.  The  degree  to which  increased dilution resulting  from a dis-
      charge north  of the  Dumbarton Bridge  will mitigate  the
      adverse impacts of  toxicants on the  biota of the  South  Bay
      cannot be predicted.

   2.  Modeling  studies have not shown that a substantial improve-
      ment in dissolved oxygen concentrations  would result if the
  3.  The viability  of future full reclamation  is being investigated
      in the Regional Wastewater Reclamation Study. Should such
      an alternative prove to be feasible, it would meet the planning
      requirements of the San Francisco Bay Basin Plan.

Operation  of  newly constructed advanced  wastewater  treatment
facilities was  begun by  the  San Jose/Santa Clara and Sunnyvale
wastewater treatment plants  in  early 1979.  Palo  Alto's advanced
treatment facilities will be operational by mid-1980. It is anticipated
that the overall water quality in the South Bay will be improved
due to the operation of these facilities. Monitoring programs of the
SBDA member agencies and the San Francisco Bay Regional Water
Quality Control Board (RWQCB) will continue to be evaluated and,
if appropriate, the  selection of the  "no project alternative" will be
reconsidered.

During September,  1979, the San Jose/Santa Clara wastewater treat-
ment plant experienced  an upset  and was  temporarily  unable to
provide full treatment to  all  wastewater flows  prior to  discharge.
This resulted  in extensive pollution of the lower portion of South
San  Francisco Bay  in the vicinity of Coyote  Creek. The RWQCB,
in response to the  wastewater treatment plant upset, issued a cease
and desist order. This order requires that the cities of San Jose and
Santa Clara develop means to protect against future upsets. San Jose
and  Santa Clara are now working to  develop  a  solution to  this
requirement.

Wastewater reclamation was investigated as a  possible  effluent dis-
posal alternative, but was not selected due to its high cost. The three
discharging agencies, as a group and individually, are continuing to
evaluate regional wastewater  reclamation  and  have  implemented
localized reclamation. A  continued commitment in this area  by the
agencies is an  integral factor in the alternative selected at this time.

Written comments sould  be submitted within thirty (30) days of the
issuance of this Final EIR/EIS to:

-------

-------
  U.S. Environmental Protection Agency
  Region IX
  Attn: Hearing Office (HE-141)
  215 Fremont Street
  San Francisco, CA 94105

After review of comments received on this Finat EIR/EIS, EPA will
issue a public record of its decision on the selected project alternative.

The  Final  EIR/EIS may be reviewed at  the  following locations:

  U.S. Environmental Protection Agency
  Region IX
  Library
  215 Fremont Street
  San Francisco, CA 94105

  U.S. Environmental Protection Agency
  Public Reference Unit (P. M. 213)
  401 M Street, S.W., Room 2922
  Washington, D.C. 20460

  Documents Librarian
  Santa Clara County Library
  Research Center
  10400 Torre Avenue
  Cupertino, CA 95014

  San Jose Public Library
  180 W. San Carlos Street
  San jose.CA 95110

  Palo Alto Public Library
  1213 Newell Road
  Palo Alto, CA  94303

  Santa Clara County Library
  7387 Rosanna Street
  Gilroy.CA 95020
Santa Clara County Library
78 South Dempsey Road
Milpitas, CA 95035

Mountain View Public Library
585 Franklin Street
Mountain View, CA 94040

Library
Water Resources Center
University of California
Berkeley, CA  94720

Santa Clara Public Library
2635 Homestead  Road
Santa Clara, CA  95051

Sunnyvale Public Library
Attn: Documents Librarian
665 W. Olive Avenue
Sunnyvale, CA 94086

Santa Clara County Library
1095 North 7th Street
San Jose, CA  95112

NASA Ames Research Center
Technical Library
Moffett  Field
Sunnyvale, CA 94040


City of San Jose
Planning Department
801 North First Street
San Jose.CA  95110

-------

-------
                        FINAL EIR/EIS

This volume provides a brief description of the alternatives for dis-
posal of South  Bay Dischargers Authority (SBDA)  highly treated
wastewater, the impacts of each alternative, the rationale for the
selection of an  alternative (No Further Action), and responses to
comments   on the Draft  Environmental  Report and Statement
(E/R/E/S), the Draft Summary, and Appendices A — L of that draft
EIR/EIS. More detailed analyses of primary and secondary impacts,
both  adverse  and  beneficial, are contained in the Draft EIR/EIS,
which was issued March 19,  1979 for public review and comment.

Since the Draft EIR/EIS is not being reprinted, an errata list for that
report is provided in  this volume {Section  4). This volume and the
Draft EIR/EIS comprise the Final Environmental Report and State-
ment, Treated Wastewater Disposal Program.
     A BRIEF DESCRIPTION OF THE DISPOSAL PROBLEM

 BACKGROUND AND HISTORY

-Prior to  the  formation of the South  Bay Dischargers  Authority
 (SBDA), an information organization consisting of San Jose, Santa
 Clara,  Sunnyvale,  Palo Alto (its member cities) and the Union and
 Menlo Park Sanitary  Districts initiated a study to investigate alter-
 native long-term solutions to  wastewater management programs in
 the  portion of the San T-ancisco Bay south of Dumbarton Bridge
 (South Bay).  A recommended plan  was presented in the Consoer-
 Bechtel (1972) report entitled Water Quality Management Plan for
 South San Francisco Bay. The SBDA was formed on April 1,1973,
 when the cities of San Jose, Santa Clara, Sunnyvale, and Palo Alto
 entered into a Joint  Exercise of Powers Agreement, and  a  second
 study was commissioned.

 Bechtel Incorporated  completed the Overview Facilities Management
 Plan in 1974, which recommended that three subregional plants pro-
vide advanced treatment (AWT) for wastewaters generated within the
SBDA service area. The plants would be at the sites of the existing
secondary plants operated by San Jose/Santa Clara, Sunnyvale, and
Palo  Alto.  It was  further recommended  that treated  wastewaters
from these  three plants be collected  in a regional intercepter for dis-
charge through  a common outfall into deep waters north of Dum-
barton Bridge, in order to meet interim water quality standards that
prohibited discharge south of Dumbarton Bridge or to the dead-end
sloughs tributary to the Bay.

The 1974 report found that even if a different method of effluent
disposal  were chosen, the advanced  level of treatment recommended
would still  be required. On this basis, EPA  in late 1974 issued Nega-
tive Declarations (findings that impacts from proposed  projects will
be insignificant)  on upgrading the three secondary  plants to provide
the advanced treatment. This action allowed the design and  construc-
tion of these facilities to proceed at once.

On May 30, 1975,  EPA issued a Notice of Intent to commence with
the preparation of an EIS on  alternative effluent  disposal systems.
SBDA, as a State-Chartered Agency, entered into an agreement with
EPA to  prepare  a joint EIR/EIS, responsive to both State of Cali-
fornia and  United  States requirements. The common outfall to the
north of Dumbarton Bridge, by that time incorporated in the San
Francisco Bay Water Quality Management Plan (or Basin  Plan) by
the State Water Resources Control Board .(SWRCB) and  Regional
Water Quality Control  Board- (RWQCB) in 1975, was to be consid-
ered as one of these alternatives.

Since that time, the SBDA and its consultant, Bechtel Incorporated,
have been  engaged in the background studies required to generate
sufficient data  for the EIR/EIS. The Draft  EIR/EIS is a result  of
those studies. On April 4, 1979, the EPA issued  a notice of joint
public hearing on the Draft EIR/EIS to be held May  16, 1979. The
hearing  was adjourned and the comment period closed on August 24,
1979. This report  documents  the hearing, comments received, and
information developed in  response to the comments.

-------
WATER QUALITY PROBLEMS AND GOALS OF A DISPOSAL
PROGRAM

Historically, wastewaters from SBDA member  agencies have been
discharged into sloughs draining into the South Bay. This has caused
an increase in pollutants in South Bay waters — the degradation of
water quality  in the South Bay  has been severe. Depression of dis-
solved oxygen concentrations to levels as low as 0.7 milligram-per
liter, high concentrations of toxic  heavy metals in the sediments,
and localized  problems of fish  kills and waterfowl botulism out-
breaks have  all been attributed to the waste load accumulations in
the South Bay. These conditions are thought to be further aggravated
by the lack of freshwater inflow  during the  dry  season and the sub-
sequent reduced flushing of the estuary.

During September  1979, the San Jose/Santa Clara wastewater treat-
ment plant  experienced  an  upset  and was temporarily unable to
provide full treatment to all wastewater flows prior to discharge. This
resulted  in  extensive pollution of the lower portion of South  San
Francisco Bay  in the vicinity of Coyote Creek.

Monitoring during  the first  few days after the upset showed that
many species of fish nearly  disappeared. However, by mid-October
there was some evidence that aquatic life was returning to the South
Bay. This evidence  is not conclusive and new information continues
to be evaluated. While the pollution of the Bay due to the plant
upset resulted in a rapid  loss of water quality in the vicinity of the
discharge, it appears there has been a return  to near normal water
quality conditions.

Uncertainty  exists  about the long-term impact  of  the wastewater
treatment plant upset upon aquatic  biota. It is expected that moni-
toring programs begun since  the upset will provide more  accurate
information about the status of impacts to the Bay.

The RWQCB,  in response to  the wastewater treatment  plant upset,
issued a cease and desist order. This order requires that  the cities of
San Jose and Santa Clara develop means  to protect against future
upsets. San Jose and Santa Clara are now working to develop a solu-
tion to this requirement.

The upset incident has demonstrated the need for reliable treatment
in conjunction  with adequate disposal.  The cities of San  Jose and
Santa Clara are reviewing the plant's treatment capabilities and oper-
ating procedures in an effort to improve treatment reliability.

Operations of  newly  constructed advanced wastewater treatment
facilities was begun  by  the San Jose/Santa Clara and Sunnyvale
wastewater treatment  plants in  early  1979.  Palo  Alto's advanced
facilities will  be operational by mid-1980. It is anticipated that the
overall water quality  in the South Bay will be improved due to the
operation of  these facilities, information obtained from monitoring
programs of the SBDA member agencies and the RWQCB will con-
tinue to be evaluated.

The goal of the Treated Wastewater Disposal Program was to elimi-
nate the discharge of wastewaters to South San  Francisco Bay as re-
quired by the SWRCB's Bays and Estuaries Policy and the RWQCB's
Basin  Plan.  Each alternative discussed  in the Draft  EIR/EIS was
evaluated  with  regard to the achievement of the  water  quality stan-
dards of the SWRCB and RWQCB, the implementation of advanced
waste treatment (AWT), and the environmental impacts and econo-
mic costs expected.

At this time,  it is felt that more information is needed  to fully eval-
uate the  impacts  of the present treatment and disposal  systems
against the standard of a level of environmental protection equal to a
deepwater outfall.  Specific areas of concern over South Bay waste
discharges include: (1) impact on the aquatic biota; (2)  botulism po-
tential;  (3) dissolved oxygen levels;  (4) toxicity levels; and (5) heavy
metal levels in  the  South  Bay. It is recommended that appropriate
monitoring programs  be developed  to  provide the needed informa-
tion base for future reevaluations. The actions that will be taken in
response to the September 1979 upset, together with  the  ongoing

-------
monitoring and  evaluation efforts,  will provide the information for
further evaluation of  either the "no  project alternative" selection
or the existing water quality  standards and  discharge prohibitions.
              SETTING OF THE ALTERNATIVES

The study area considered in the Draft EIS is that portion of the
Santa Clara County Baylands between San Jose and the Dumbarton
Bridge (Figure 1).  This gently  sloping, almost flat,  plain and  the
open waters of the Bay have been extensively developed for urban,
commercial, and institutional uses, including water pollution control
facilities,  sanitary  landfills,  commercial  salt  concentration  ponds,
and recreational areas.

The waters of the South Bay have a moderating effect on the climate
of Santa Clara County; this climate  in  turn influences the suscepti-
bility of the area to air quality problems. The study area is in a crit-
ical  air  basin; the  combination  of strong subsidence  inversions
common along the Pacific Coast and a basin ringed by mountains and
open to the sea results in a high potential for impaired air quality.
During the summer and early fall, when air temperatures are higher,
these conditions result in periods of increased air pollution, primarily
from non-point sources such as automobile traffic. However, disposal
is not growth-related and, since  no increase in treatment capacity is
planned, no secondary  impacts on air quality are expected.

Geologic hazards consist of the potential for major earthquake activ-
ity  along the  San Andreas fault zone to the  west of the Bay and
along the Hayward fault zone to the east. A major earthquake could
affect the structural integrity of a pipeline should the firm Bay Muds
supporting the structure lurch or slide.

One of the most characteristic features of the South Bay is the di-:
verse habitat available  for fish and wildlife. This habitat, designated
as  a  beneficial  use  of the area in  the San Francisco Bay Water
Quality Management Plan, consists of open bay waters, estuarine and
tidal  mud  flats,  fresh and saltwater  marches,  salt concentration
ponds, and grasslands. Although somewhat reduced in  productivity
as a result of water pollution problems and extensive urban develop-
ment  pressures, these Bayland habitats still  support a diverse plant
and animal community, including three resident endangered species
(California  least tern, California clapper rail, and salt marsh  harvest
mouse). Portions of the South  Bay have been designated as part of
the San Francisco Bay National Wildlife Refuge;  in the area south of
Dumbarton  Bridge, the wildlife refuge consists  of the marshlands,
salt ponds, and sloughs from Alviso Slough north on the eastern side
of the Bay.
                ALTERNATIVES CONSIDERED

During the development of the Water Quality Management Plan for
South San Francisco Bay and the Overview Facilities Management
Plan, a number of treatment and disposal alternatives were examined.
In the  Draft  EIR/EIS,  nine  disposal alternatives were evaluated,
some of which were considered in the earlier studies. The criteria for
evaluation  in  the Draft EIR/EIS include legal and  institutional  re-
quirements  as well as  economic, engineering,  and  environmental
(physical, chemical, biological, and  sociocultural)  factors.
BASIN PLAN ALTERNATIVE

The Basin Plan-Alternative consists of a regional conveyance pipeline,
connecting lines, and pumping facilities along the southwestern shore
and  in  the waters of the South  Bay (Figure  2).  The pipeline  is
approximately 16  miles long, extending  from a pumping station at
the existing San  Jose/Santa  Clara  treatment plant to  a discharge
point in the deepwater  channel  approximately one mile north of
Dumbarton Bridge. The  pipeline  varies in diameter from 90 inches
(inside diameter)  at its southern  end to  102 inches at  the outfall.
The three  subregional advanced waste treatment plants (San Jose/
Santa Clara, Sunnyvale, and  Palo Alto) discharge wastewaters into

-------


                                                                       VP^\\W^_^0-,
                                                     ^^^^^^^;rfs-i'i-5-^w^\)f^x^^';v^.v'''V\ . v\
SBDA SERVICE AREA
APPROXIMATE BOUNDARY OF BASIN
PLAN ALTERNATIVE STUDY AREA
Figure 1
STUDY AREA LOCATION
AND PRINCIPAL MUNICIPALITIES

-------
this  conveyance  at pumping stations Jocated  near  the  treatment
plants. The pumping stations could  be modified to accommodate
reversal in  flow  direction  if large-scale regional  reclamation and
reuse programs that require transport of wastewaters southward
are implemented in the future.

The  Basin  Plan Alternative facilities would be located  on the Bay-
lands plain,  roughly between  the Bayshore Freeway  (U.S. High-
way  101) and  the inboard levees of the salt ponds."Where possible,
the  route  follows  existing utility  corridors.  Pumping  stations are
located on  treatment  plant  or  industrial  park  property. However,
due to the nature of the Santa Clara Baylands, approximately 74 per-
cent of the proposed alignment is located  in relatively natural bio-
logical areas.

The  main goal of the Basin Plan Alternative is compliance with the
terms set forth in  the Basin Plan, e.g., general improvement in dis-
solved oxygen levels in  the South  Bay, which  contributes to the
protection of the designated beneficial uses of these waters. Three
wastewater outfalls to the Bay south of Dumbarton Bridge, including
one  in the  San Francisco  Bay National Wildlife Refuge, are elimi-
nated. However,  this  alternative'could  result  in primary  adverse
impacts during construction as well as secondary adverse  impacts
during operation.

Adverse  construction  impacts  could  include alteration  of topog-
raphy, erosion, dust, air pollution,  noise, degraded water quality, and
loss of biological  habitat. All of these impacts are short-term, lasting
only  during  construction  (approximately  two weeks at  any point
along the conveyance)  and a recovery period  immediately following
completion  of construction. Mitigating measures such as route
selection, surface, restoration, stream bank  stabilization, and reveg-
etation  could reduce the  significance  of  these impacts.  The areas
most affected  include the  Palo Alto  discharge canal and the Palo
Alto Baylands Reserve. These areas have been disturbed in  the past
and  are now recovering  from this disturbance;  construction would
slow this  recovery. No known  historical or archaeological  sites are
                                         LEGEND
                                         «•— CONVEYANCE
                                          O  DISCHARGE POINT
                                          •  TREATMENT PLANTS
                                                         MIL
                                                    SJ/SC
                                         SV
         Figure 2 SCHEMATIC-BASIN PLAN ALTERNATIVE,
                ON-LAND
affected; no relocation of residents is anticipated; and no long-term
disruption of aesthetics or access would occur.

Operation of the conveyance contributes to degraded water quality
in two locations. The disposal point is locally affected by pollutants
in the discharge, but no violations of water  quality standards are
anticipated. The headwaters of Artesian Slough could be degraded as
they  become more  saline  with the removal of the  freshwater dis-
charges from the San Jose/Santa Clara treatment plant. The head-
waters are expected to exhibit an increased expression of background
oxygen demands. Reduced.flows also result in increased salinity in
the South Bay  to levels  above those  now occurring north of Dum-
barton Bridge.  Levels of 50  ml/1 of toxicity are expected to occur
in the 1985 dry season  (the toxicity  guidelines are 40 ml/1). These
changes in water quality  in the  South  Bay and its sloughs affect both

-------
biological productivity  and habitat diversity in an adverse and in-
direct manner, particularly in Artesian Slough.

Hazards  to  structural and  operational  integrity of the  Basin,Plan
Alternative  include potential damage by earthquake, plant upsets,
pumping station  malfunctions,  or power  failures.  Each  of  these
could potentially  result in  a  bypass of wastewater to  the South
Bay. The proper selection of pipeline alignment, the use of pilings
placed  in stiff clays in  areas of  soft muds, and backfill with coarse
granular material could  reduce, to  the extent possible, the potential
for earthquake damage. Backup pumping  systems and  power sup-
plies, as well as some storage capacity for bypassed flows at Sunny-
vale, could reduce in-Bay impacts  that  could be caused  by system
failures.

Operation of the.  Basin Plan Alternative would result in electrical
energy consumption in  1981 on the  order of 7.9 million kilowatt-
hours per year; this is equivalent to approximately 4,900 barrels of
crude oil per year.  To place  this in perspective, the same energy
consumption would occur if each of the  residents of Santa  Clara
County  burned two 150-watt  light bulbs for slightly less than one
day  each year.  Capital  costs for the  conveyance and pumping sta-
tions are estimated  to  be  $86  million (1978  dollars escalated to
1980), 87.5  percent of which is covered by federal and  state grant
funds. Annual operating costs (estimated for 1981-1983) of approx-
imately  $320,000  (power consumption, maintenance, and adminis-
tration) would not be grant fundable.

Each user — residential, commercial, institutional, and industrial —
that discharges  into the SBDA sewer system must pay a fair share of
the cost of operating and maintaining a conveyance pipeline. A sys-
tem  of  "user  charges" would  be established  to accomplish this.
In addition,  each  industrial user must pay back to the cities in the
SBDA  its share of the federal funds for capital costs; this is known
as  "industrial  cost recovery."  Annual revenue requirements  for
industrial users, therefore,  could impose a  burden on the individual
industries,  varying with the percentage treatment  capacity of the
system  attributable  to  each  industry. Seasonal large-volume dis-
chargers, such as the canning industry, are likely to  have higher
revenue requirements than year-round and low-volume dischargers.

Alternative (Estuarine) Alignment for the Basin Plan Alternative

This subalternative involves a common conveyance from San Jose to
the discharge point north  of Dumbarton Bridge, with the alignment
being located  primarily  in the waters of the South Bay (Figure 3).
Impacts associated with operation of this subalternative are identical
to those expected from the Basin  Plan Alternative, although more
salt pond, mudfalt, and  open water habitat are affected  by construc-
tion, increased construction time is required, and more dredge spoils
are generated. In addition, construction in  salt ponds is more costly
                                         LEGEND
                                         -+— CONVEYANCE
                                          D  DISCHARGE POINT
                                          •  TREATMENT PLANTS
                                                         MIL
                                                     SJ/SC
         Figure 3  SCHEMATIC-BASIN PLAN ALTERNATIVE,
                 ESTUARIAL

-------
because special techniques have to be developed to avoid disruption
of salt pond operation and  to prevent breaching of the dikes. As a
result, construction costs are slightly greater than those expected for
the proposed project. The estuarine route, then, was eliminated from
full consideration, since, when compared with the  Basin Plan Alter-
native route,  it has a similar impact on water quality,  is not less
costly to construct or operate, and has more adverse environmental
impacts during construction.

Leslie Salt Company Participation in the Basin Plan Alternative

For the past several years, Leslie Salt Company has stored the toxic
residue from evaporative salt production (bittern — the highly con-
centrated fluid that remains after salt  crystallizes out in the salt
                                         LEGEND
                                          a
CONVEYANCE
DISCHARGE POINT
TREATMENT PLANTS
                                                         MIL
                                                     SJ/SC
                                         SV
         Figure 4 SCHEMATIC-BASIN PLAN ALTERNATIVE,
                 LESLIE SALT
ponds). However, this storage is encroaching on the productive salt
ponds at the rate of one per year and, consequently, is reducing the
diversity of the  habitat in the National Wildlife Refuge as well  as
limiting the economic production of salt in the South  Bay.  Since
bittern is highly  toxic and cannot be treated for toxicity, it may  be
discharged only  after dilution of 100:1  concentrations. One source
of water for dilution is the Bay  itself;  however, a  toxic plume  of
wastewater might  affect as much as one-third  of  an acre of Bay
bottom under such conditions. Another source of dilution water is
wastewater from a South Bay discharger. SBDA is a logical choice of
such diluent, and  if  the  Basin Plan Alternative were to be imple-
mented, it would be technically feasible  for Leslie Salt to connect to
the disposal pipeline in order to discharge bittern (Figure 4).

There are institutional constraints to the joint participation of SBDA
and Leslie Salt Company.

     •   SBDA is a chartered municipal discharger  located entirely
         within Santa Clara County, while Leslie Salt is an industry
        .in Alameda County; the  SDBA charter would require
         amendment.
     0   Leslie  Salt  Company would have to arrange payback  to
         state and  federal granting agencies of the pipeline and
         diffuser capacity preempted by its use.
    . •   Leslie  Salt  would  have to arrange  self-monitoring and
         automatic  shutdown of discharge to assure 100:1  dilu-
         tion minimum discharge at the proper flows and discharge
         only at ebb tide in winter.
                       NO ACTION BEYOND CURRENTLY APPROVED IMPROVE-
                       MENTS AT TREATMENT PLANTS

                       Under this, the selected alternative, no further improvements would
                       take place beyond the  recently (1978,1979) implemented advanced
                       waste treatment facilities (Figure 5). Continued discharge at present
                       disposal points retains freshwater flushing in Artesian Slough; water

-------
                                         LEGEND
                                         •*— CONVEYANCE
                                          Q DISCHARGE POINT
                                          • TREATMENT PLANTS
                                                        MIL
                                                    SJ/SC
                                          sv
     Figure 5 SCHEMATIC-NO FURTHER ACTION ALTERNATIVE
                                                                                             PA
                                         LEGEND
                                         «•— CONVEYANCE
                                          O  DISCHARGE POINT
                                          •  TREATMENT PLANTS
                                                                                                                           MIL
                                                                                                                       SJ/SC
          Figure 6 SCHEMATIC-INDIVIDUAL DEEPWATER
                 OUTFALL ALTERNATIVE
quality standards are not,  however, met south of Cataveras  Point
during dry and canning seasons. No  further action does not comply
with Basin  Plan  prohibitions against discharge south of Dumbarton
Bridge or to tributaries on the South Bay, does not guarantee a
10  to 1  dilution rate, and  may  result in toxicity levels of up to
400 ml/1. A  No Further Action alternative could be considered part
of a deferred action program,  however, in which the effects of the
approved AWT  could be monitored and documented, and  the via-
bility  of future  full  reclamation could be investigated further. No
additional costs or  construction impacts are incurred  with this
alternative.   Should  additional   action  be required at some future
date to meet water quality standards, the cost of this new action
is significantly greater than present estimates, and the effects of
inflation  on labor  and materials all  contribute  to  this  increase.
INDIVIDUAL OUTFALLS TO BAY SOUTH OF DUMBARTON
BRIDGE

Using separate  outfalls, dischargers would convey  effluent to the
nearest deep water south of Dumbarton Bridge (Figure 6). Under this
arrangement, effluents from the San Jose/Santa Clara and Sunnyvale
treatment plants are combined and conveyed to a discharge point in
the vicinity  of Calaveras Point; effluent from the Palo Alto plant is
discharged from an outfall in  deep water northeast of its present dis-
charge location.  This system  should meet  dissolved  oxygen require-
ments in open waters of the Bay,  while  discontinuing wastewater
discharge to the sloughs. However, improvement in water quality in
the South Bay is not as great as would  be expected if discharges were
relocated  north  of the Dumbarton  Bridge,  and  the prohibition

-------
against discharge to the Bay south of Dumbarton Bridge is not met.
Toxicity levels of 125 rnl/l could occur and, as with the Basin Plan
Alternative, this  alternative  eliminates freshwater  flushing of the
sloughs during the dry season, endangering the freshwater habitat of
Artesian Slough.

The nature and extent of construction impacts from this alternative
are not significantly different from those of the  Basin Plan Alterna-
tive, although more extensive impacts would occur  on natural habi-
tats, such as marches and salt ponds.

The cost of construction and, the first year of operation is estimated
to be approximately 80 percent of that of the Basin  Plan Alternative,
or  $69 million;  however,  this estimate does not  provide  for the
technical  problems of  construction  in  salt ponds.  These problems
would increase construction time and costs.

This alternative is compatible with local or small-scale reclamation
and reuse projects and  coujd function as an off-season disposal sys-
tem for such projects.  However, this alternative is less compatible
with large-scale  Bay Area reclamation than the Basin Plan Alterna-
tive, since a regional collection system for Santa Clara would not
exist.
UPGRADED TREATMENT WITH CONTINUED LOCAL
DISCHARGE

No new conveyance systems would be built in this alternative; each
treatment  plant  continues  discharging  at  its  present  location
(Figure 7). Treatment levels at San Jose/Santa Clara are further up-
graded, to  include  breakpoint chlorination for residual  ammonia
removal  and  carbon absorption for  removal  of toxicity and for
further removal of oxygen demanding materials.
This alternative should meet dissolved oxygen requirements in open
waters of the Bay. The sloughs would continue to receive flushing
flows, and the freshwater habitat would persist in Artesian Slough.
                                        LEGEND
                                        •— CONVEYANCE
                                         O  DISCHARGE POINT
                                         •  TREATMENT PLANTS
                                                        MIL
                                                    SJ/SC
                                          SV
          Figure 7 SCHEMATIC-UPGRADED TREATMENT
                 WITH CONTINUED LOCAL DISCHARGE
                 ALTERNATIVE
Oxygen depletion in the dry season and the buildup of conservative
elements in the sloughs would continue, however. This alternative
does not'meet the prohibitions against discharge south of Dumbarton
Bridge or to dead-end sloughs, nor does it provide the 10:1 minimum
dilution required by the Basin Plan. Toxicity levels of 400 ml/l are
expected to  occur  in  the  dry season  of  1985  in the South  Bay.

Construction impacts are less extensive for this alternative, limited to
the San Jose/Santa Clara plant site.

The cost of construction and  the  first year of operation is estimated
to be approximately 1.4 times that of the Basin Plan Alternative, or
$121  million: Costs  of operating the advanced treatment facilities are
greater than those of the Basin Plan Alternative primarily due to in-
creased consumption of-chemicals and energy. Reclamation and
                                                                                                                                 9

-------
reuse on a local scale  is compatible with this alternative; however,.it
is4less  compatible with large-scale projects since a regional collector
for Santa Clara County would not exist.
RECLAMATION AND REUSE

Reclamation of wastewater from the SBDA treatment system, and
the reuse of this water, was considered as an alternative to disposal.
Depending on the market location, size, and water quality require-
ments, a reclamation  and reuse alternative might include a reclama-
tion treatment plant  for additional  treatment  of  a  portion of the
SBDA effluent, a distribution system to transport reclaimed waters
to the market area, and  an  off-season disposal system for the dis-
charge of that unreclaimed effluent  (Figure 8). The benefit of this
alternative is conservation  of water  resources by using  reclaimed
wastewaters in place of potable water supplies.

Studies of the viability of reclamation and reuse  in the Bay  Area"have
been  sponsored by  various member cities of SBDA,  by the Depart-
ment of Water Resources, by the Santa Clara Valley  Water District,
by  the State Water Resources Control  Board,  by  the  EPA, by the
State Department of  Water  Resources,  and by the U.S. Bureau of
Reclamation.

Assuming a market  in the Santa Clara Valley for a  portion {67 mgd)
of the San Jose/Santa Clara  effluent, construction impacts  include
those anticipated for an in-Bay  outfall system for off-season dis-
charges as well as  impacts  on water quality, air  quality, habitats,
and  aesthetics in  the  grasslands and  agricultural lands of the Santa
Clara Valley.  The extent of these impacts vary  with  the  market
served (i.e., Santa Clara County only or Santa Clara and San Benito
Counties).

Operational impacts are primarily related to the cost and quality of
the water  in the market area.  Salt buildup in soils, restrictions in
crops, and the high cost of treating wastewaters to acceptable quality
levels are  all factors with potentially adverse impacts. Bay impacts
vary with the disposal  system chosen; generally, improvements in
water quality similar to  those  proposed for the Upgraded Treatment
Alternative would result, if the major  portion of the effluent could
be reclaimed year-round.

The cost of construction  and the first year operation of a 67 mgd
facility  is estimated  to  be  3.8 times that of the Basin Plan Alterna-
tive, or $328 million. Increased  cost  is primarily due to increased
treatment requirements  and the  cost of conveyance to the market.
These  include  significant  increases in energy consumption. Not
included in this calculation are the revenues received for the sale of
reclaimed waters, or the  costs  of an off-season discharge system.

A study to determine the engineering, economic, and environmental
feasibility of reclaiming a smaller portion of SBDA wastewaters for
                                        LEGEND
                                        .<— CONVEYANCE
                                         Q DISCHARGE POINT
                                         • TREATMENT PLANTS
                                                        MIL
     Figures SCHEMATIC-RECLAMATION/REUSE ALTERNATIVE
10

-------
agricultural use in the South Santa Clara Valley and the Bolsa area of
San Benito County was undertaken for this EIR/EIS. As an option
for water resources management, such a small-scale reclamation/
reuse project has the benefits of (1) reducing SBDA discharges by
approximately 10 percent, (2) increasing the amount of irrigation
water without increased use of potable, diverted water supplies,
and/or (3) opening up additional lands for irrigation. Disadvantages
of such a project are primarily economic — depending on the level
of treatment used, reclaimed water costs between $150 and $570 per
acre-foot. If fully subsidized, the cost to the user (the farmer) is
between $9 and $56 per acre-foot. However, in water-short areas, in
drought years, and in areas with low-quality water supplies, such a
water management option may be economically feasible and could
be implemented regardless of the disposal alternative chosen. Such
limited reclamation does not replace the requirement for a disposal
system and, depending on the off-season or partial system chosen,
may not comply with the water quality standard, toxicity guidelines,
prohibition against discharge below Dumbarton Bridge, or a mini-
mum 10:1 dilution.
CONSOLIDATION WITH OTHER DISCHARGE AUTHORITIES

This alternative involves consolidation with other discharger author-
ities in San Mateo County, with discharge north of the San Mateo
Bridge, and has been considered in earlier management programs.
Although it meets water quality requirements in open water, many
of the environmental disadvantages associated with the five pre-
viously described alternatives occurs, such as decreased freshwater
flushing in the sloughs. This alternative has more severe construction
impacts and a higher cost (approximately twice) than the Basin Plan
Alternative. Since many of the other Bay Area discharger author-
ities have completed independent studies and, in some instances,
begun construction of their own improved treatment facilities,
consolidation requires forfeiture of invested funds by these other
authorities, with no guaranteed benefits accruing to these authorities
as a result of that action. For this reason, this alternative was not
given further consideration.
DISCHARGE TO THE OCEAN

This alternative consists of a collection and disposal conveyance from
the Baylands to the Pacific Ocean. A tunnel through the Santa Cruz
Mountains, a deepwater ocean outfall, and a series of pumping sta-
tions are required in addition to the major portion of the on-land
systems of the Basin Plan Alternative. Construction impacts are sig-
nificantly greater than those of in-Bay disposal Alternatives and.
affect additional acreage of grassland, woodland, coastal zone, and
ocean habitat. Water quality in the South Bay is expected to improve
to levels similar to those expected for the Basin Plan Alternative.
Freshwater habitat and flushing in Artesian Slough is lost. However,
it was determined that the increased costs (approximately 2.7 times
that of the Basin Plan Alternative) and construction impacts were
not justified by the small increment in improved Bay water quality,
and this alternative was not given further consideration.
LAND DISPOSAL

Transport of effluent to a land disposal site removes wastewater from
the Bay and improves water quality to levels similar to those ex-
pected for the Basin Plan Alternative. However, suitable land disposal
sites do occur in Santa Clara County, and public acceptance outside
the county appears to be lacking. In addition, construction impacts
for a conveyance, storage, and dispersal system are large. Construc-
tion and operation costs might range as high as eight times that of
the proposed project, and energy usage is significantly greater. There-
fore, this alternative was not considered further.

NONSTRUCTURAL WASTEWATER MANAGEMENT

Nonstructural wastewater management uses phased development of
treatment and disposal facilities to meet water quality criteria. This
alternative entails source control, land-use planning, and enforcement
of environmental regulations to control the quality and quantity of
wastewater. The alternative modes of disposal discussed in this
11

-------
EIR/EIS  were considered as part of ongoing phased development
plan, which in turn was designed  in response to source control, land
use, and  environmental  regulations. For this reason, nonstructural
wastewater management  is not an alternative mode of disposal; it is
a criterion -for disposal and is incorporated as such into the client
alternative disposal systems.
  SELECTION OF THE NO FURTHER ACTION ALTERNATIVE

At the time of issuing the Draft EIR/EIS, no decision had been made
as to  the selected,  or  preferred, alternative. However, at that time,
both  the EPA and  the  SBDA were  recommending  a "no project
alternative" (No Further Action) because:

    1.   The  degree  to which  increased  dilution resulting from
         discharge  north  of  the  Dumbarton Bridge  will  mitigate
         the adverse  impacts of toxicants  on the  biota of the
         South Bay could  not be predicted.
    2.   Modeling  studies had not shown  that a substantial im-
         provement in  dissolved  oxygen  concentrations  would
         result if the discharges  were  moved  out of the sloughs
         (Individual Deep Water  Discharge Alternative) or out of
         South Bay (Basin Plan Alternative).
    3.   The  viability of  future full reclamation  is  now being in-
         vestigated  in a Regional Wastewater  Reclamation Study.
         Several local small-scale programs are in the planning or
         implementation  stage;  however,  these programs do not
         preclude a requirement for disposal of some portion of the
         flow.  The Regional  Wastewater Reclamation  Study and
         smaller programs, if implemented, could meet the planning
         requirements of the San Francisco Bay Basin Plan.

The EPA and SBDA recognize  that many questions have been raised
about  the impact of  treated  effluents on  biota which cannot be
answered with data now available, and  that  the effects of the ad-
vanced waste treatment  (AWT) now being provided at each  plant
have not been documented or confirmed.  However, EPA and SBDA
feel that delay of a decision in order to obtain more data is not an
acceptable approach, particularly since many  of the issues left un-
answered (chronic toxicity; aggravation of avian botulism; degree of
oxygen depletion from presently "polluted" Bay muds, marshes and/
or wastewater;  degree of  flushing  imparted  by wastewater flows)
require special,  beyond state-of-the-art studies which often, in turn,
ask more questions than they answer. Similarly, implementation of
a construction  program  for a disposal or treatment system, which
present data indicate will not guarantee improvement of water qual-
ity  or  the  beneficial  uses  of  the Bay, does  not appear to  be
acceptable.

Comprehensive  monitoring of  the  AWT effluents and present dis-
charge points may confirm the reported  current trend  toward im-
proved biologic conditions, increased biotic diversity, and recovery
of shrimp, striped bass, and  marine species fisheries. In addition,
SBDA and  its  member agencies are committed  to regional  and
local  wastewater  reclamation  investigations.  EPA  and  SBDA  will
continue to reevaluate results of this monitoring program and  re-
clamation studies,  and  will  reconsider  the  disposal  problem,  if
appropriate, after these data are available.
        SUMMARY OF THE COORDINATION PROCESS

During the preparation of the SBDA Draft EIR/EIS, twelve Techni-
cal  Advisory  Committee (TAC)  meetings were held. A  list of the
members of the TAC, as well as the  preparers of  the EIR/EIS,  is
presented  below and in Chapter  VII  of the Draft EIR/EIS. A dis-
tribution list for the Final EIR/EIS is also presented here.
PREPARERS OF THE EIR/EIS

This Environmental Impact  Report and  Statement (EIR/EIS) has
been prepared under  a  joint agreement dated 12 March  1975 be-
12

-------
y;ween the Environmental Protection Agency (EPA), the lead federal
agency for the project, and the South Bay Dischargers Authority
(SBDA), the lead state agency. Pursuant to this agreement, entitled
"Agreement between the U.S. Environmental Protection Agency and
the South Bay Dischargers Authority Regarding the Preparation of
an Environmental Impact Statement and Provision of Payment
Therefor," SBDA engaged Bechtel Incorporated as its consultant to
assist EPA in drafting the EIR/EIS. The EIR/EIS project partici-
pants and their affiliations are presented below:
Technical Advisory Committee

U.S. Army Corps of Engineers

U.S. Geological Survey

Department of the Navy
Moffett Field Naval
Air Station
Col. H. A. Flertzheim, Jr.

D. S. McCulloch

LCDR W. V. Sayner, Jr.,
Ens. C. F. Winsor
Environmental Protection Agency, Region IX
Peter R. Perez
Project
Evaluator
Charles H. Campbell Project
Evaluator

William Helphingstine Project
Evaluator
Lauren Fondahl
Project
Evaluator
Statewater Resources Control Board
F. W. Pierson
Lyndel Melton
Curtis Swanson
Project
Evaluator

Project
Evaluator

Project
Evaluator
South Bay Dischargers Authority
R. R. Blackburn
30 May 1974 to
21 August 1975

21 August 1975 to
4 June 1976

4 June 1976
to 11 April 1980

11 April 1980
to present
30 May 1974 to
8 September 1976

8 September 1976
to 16 September 1979

16 November 1977
to present
City of San Jose, Project
Coordinator
State Water Resources Control
Board
State Department of Fish
and Game III

State Lands Commission

State Department of
Public Health

San Francisco Bay Conservation
and Development Commission

Association of Bay Area
Governments

Bay Area Sewage
Services Agency

Regional Water Quality
Control Board (2)
U.S. Fish and Wildlife Service,
River Basins
Omer Peck, Howard Wright,
Fred Botti, Jim Lee, John Harris,
Bob Brown

Michael Rugg
Gary Horn

William Joppling and
Robert Witt

Patricia Weesner
Waide Egener and Robert Wong
Dan Murphy and Karol Enferadi
Robert Scholar, Robert Roche,
Val Miller, Don Dalke,
A. Van Kleek

R. Breitenbach
13

-------
U.S. Ftsh and Wildlife Service,
San Francisco Bay National
Wildlife Refuge

U.S. Food and Drug
Administration
Richard Nugent, Cathy Osugi,
and Robert Personius
David Alton
Santa Clara Valley Water District Lloyd Fowler, Val Miller

County Executive
Santa Clara County Board
of Supervisors

City of Palo Alto

City of Mountain View

City of Sunnyvale

City of San Jose

City of Santa Clara

State Department of Parks
and Recreation
U.S. Department of the Interior, Haydn C. Lee, Jr.
Bureau of Reclamation
City Manager and H. R. Remmel

Norman H. Lougee

City Manager and D. M. Somers

City Manager, F. Belick,
A. R. Turturici

Robert R. Mortenson
Santa Clara County
Health Department

San Benito County Board
of Supervisors
E. H. Pearl
George E. Shore
U.S. Department of Agriculture, Robert Ayers
Agricultural Extension Service
San Jose/Santa Clara
Treatment Plant

U.S. Coast Guard, Marine
Environmental Protection
Branch

San Mateo County Board
of Supervisors

State Department of
Water Resources
Advisory Committee
(F. Belick, E. Becker)

N. Bell
Country Executive
Donald Finlayson, Hal Higgins,
William Mitchell, jr.
South Santa Clara Valley Water M. Sheeny, D. I. Martin,
Conservation District
J. Jeske
Agricultural Extension Service, Edward Lydon
U.C., County of San Benito

Agricultural Extension Service, Peter Lert
U.C., County of Santa Clara
Bechtel

John A. Peterson

C. M. Spink

R. L. Bardin
University of California, Davis Dr. Robert Hagen
Project
Manager

Project
Manager

Project Engineer,
supervising design
and engineering,
pipeline
30 May 1974 to
February 1976 .

February 1976 to
present
14

-------
C. Cain
Carol M. Harper,
Ph.D.
Project Engineer,
supervising design
and engineering,
treatment

Project Engineer,
supervising EIS
writing and data
gathering
Hsing-Chi Chang, Ph.D. Noise control technology

Walter T. Clark Physical geography

David A. Cobb, Ph.D. candidate Marine biology — benthos
J. A. Coil ill, Ph.D.

G. S. Dhillon,Ph.D.

S. Douglas

R. Eggers

J.W.Gerald, Ph.D. '

E. Goldman

J. D. Gouge

W. S. Gray, Ph.D.

Charles A. Harper, Ph.D.
Aquatic ecology, water
chemistry*

Agriculture, soils

Planning

Fisheries

Environmental monitoring,
chemistry

Marine biology — plankton

Marine biology — amphipods

Terrestrial biology — birds
and arthropods
J. A. Hepper, Ph.D. candidate

R. A. Hughes, Ph.D..

Martha H. Kohler, Ph.D.

Douglas R. Longwell, Ph.D.

Peter F. Mason, Ph.D.

J. J. Meersman

Ramon Nugent

J. L. Owen

F. Z. Patassy'

Max G. Rodel

R. B. Scheibach

Brent P. Sherfey

C. Valentino

John D. Walsh

B. L. Westree

Consultant to Bechtel

Michael Melanson
Economics

Water chemistry

Oceanography and limnology —
sediments

Air chemistry

Urban geography

Water quality

Noise control technology

Terrestrial ecology-botany

Agronomy and reclamation

Water chemistry

Groundwater, geology, water
quality

Economics

Ecology

Meteorology

Marine ecology, estuarine
biology*
Terrestrial biology — mammals
and plants
15

-------
 E. H. Smith and Associates, Sebastopol, CA
 Edmund Smith, Ph.D.
Benthic biological survey and
collection of water samples
(for qualifications of technical personnel, see Appendix H of
DraftEIR/EIS)

Archaeological Consulting and Research Services, Inc.
Mill Valley, CA

                               Archaeological and
                               paleontological survey .

R. C. Harlan and Associates, San Francisco, CA

                               Collection of sediment samples
                               and physical analyses of these
                               sediment samples

Pacific Environmental Laboratory, San Francisco, CA

                               Chemical analyses of sediment and
                               water samples

Hydroscience, Inc., Westwood, New Jersey

                               Mathematical model of water
                               quality for South San
                               Francisco Bay

*On FEIR/EISonly
16

-------
              RESPONSE TO COMMENT
ON SOUTH BAY DISCHARGERS AUTHORITY DRAFT EIR/EIS
                                                                             17

-------
City of Santa Clara
Planning Department
1500 Warburton Avenue
Santa Clara, CA 95050

City of Mountain View
Planning Department
540 Castro Street
Mountain View, CA 94040

City of Sunnyvale
Planning Department
P.O. Box 607
456 W. Olive Avenue
Sunnyvale, CA 94088

City of Los Altos
Planning Department
1 N. San Antonio Road
Los Altos, CA  94022

City of Palo Alto
Planning Department
250 Hamilton Street
Palo Alto, CA  94301
  City of Milpitas
  Planning Department
  455 E. Calaveras Blvd.
  Milpitas, CA 95035

  City of Cupertino
  Planning Department
  City Hall, 10300 Torre Avenue
  Cupertino, CA 95014

  Town of Los Altos Hills
  Planning Department
  26379 Fremont Road
  Los Altos Hills, CA  94022

  City of Los Gatos
  Planning Department
  P.O. Box 949
  Los Gatos, CA 95030

  City of Monte Sereno
  Planning Department
  18041 Saratoga-Los Gatos Road
  Monte Sereno, CA 95030

Please bring this notice to the attention of all persons who would be
interested in this matter.
U.S. Environmental Protection Agency, Region IX
by
     Paul De Falco, Jr.
     Regional Administrator
            South Bay Dischargers Authority
            by  James A. Alloway
                Chief Executive Officer
                                                                                                                 M it*

-------
                          TABLE  OF CONTENTS
            RESPONSE TO COMMENT ON DRAFT EIR/EIS
1    SUMMARY OF COMMENTS PRESENTED AT 16 MAY 1979 PUBLIC HEARING

    •   Transcript of Hearing


1.1  TESTIMONIES REQUIRING NO SPECIFIC RESPONSE


1.2  TESTIMONIES ADDRESSED IN OTHER SECTIONS OF THIS REPORT


1.3  TESTIMONIES REQUIRING RESPONSE
2    RESPONSES TO WRITTEN COMMENT RECEIVED DURING THE REVIEW PERIOD
     ENDING 6 JUNE 1979
2.1  LETTERS REQUIRING NO SPECIFIC RESPONSE


    •   Office of the Governor, Office of Planning and Research,
        State Clearinghouse - EPA No. (HE149)3

    •   City of Saratoga - EPA No. (HE-149)4

    •   Town of Los Gates - EPA No.   (HE-149)5

    •   City of Milpitas, Milpitas Sanitary District Board of
        Directors - EPA No. (HE-149)7

    •   City of Campbell - EPA No. (HE-149)10

    •   Paul N. McCloskey, Jr., U.S.  Congress - EPA No. (HE-149}14

    •   U.S. Department of Transportation - EPA No. (HE-149H6

    •   Santa Clara Chamber of Commerce - EPA No.  (HE-149H8
                                                                      Page
25-51
53
55-56
57-58
62

62-63

63-64


64-65

65-66

66

67

67-68
                                                                     Page
    *   Cupertino Sanitary District  - EPA No.  (HE-149)19              68-69

    •   Norman T. Mineta,  U.S.  Congress - EPA  No.  (HE-149)25     '     69

    »   County of Santa Clara,  Board of Supervisors'-
        EPA No.  (HE-149)26                                           70


2.2  LETTERS REQUIRING SPECIFIC RESPONSE

    •   County Sanitation  District No.  4,  Santa  Clara County
        - EPA No. (HE-149)!                                          73-77

    •   Santa Clara County Citizens  Advisory Committee -
        EPA No.  (HE-149)2                                             78-79

    *   U.S.  Department of Commerce  - EPA No.  (HE-149)6               80

    *   Drs.  Howard S.  Shellhammer and  H.  Thomas Harvey,
        San Jose State University -  EPA No.  (HE-149)8                 81

    •   Dr. L.  Richard Mewaldt,  San  Jose State University
        - EPA No. (HE-149)9                                          82

    •   Santa Clara County Canners Association - EPA No.
        (HE-149H1                                                   83-84

    •   U.S.  Department of Agriculture  - EPA No. (HE-149)12           85

    •   San Jose/Santa Clara  Water Pollution Control Plant -
        EPA No.  (HE-149)13                                          86-87

    *   Santa Clara Valley Water District '- EPA No. (HE-149H5       88-89

    •   California Department of Fish and  Game - EPA No.
        (HE-149)17a                                                 90-95

    •   California Water Resources Control Board - EPA
        No. (HE-149)17b                                             96-103

    •   D.  E.  Myers,  Loma  Prieta Chapter,  Sierra Club -
        EPA No.  (HE-149)20                                          104-105

    •   U.S.  Department of Interior,  Pacific Southwest Region -
        EPA No.  (HE-149)21                                          106-108

    •   Patrick  Ferraro, Santa  Clara  Valley Water District,
        District 2 -  EPA No.  (HE-149)22                              109-110
                                                                                                                                                     19

-------
        Regional Water Quality Control Board, San Francisco Bay
        Region - EPA No. (HE-149)23

        ABAC - EPA No. (HE~149)24

        Advisory Council on Historic Preservation - EPA
        No. (HE-149)27
Page

111-119

120-122


123-124
     RESPONSES TO WRITTEN COMMENT RECEIVED AFTER 6 JUNE 1979

    •   Florence M.  LaRivere - EPA No.  (HE-149)28

    •   County Sanitation District No.  4, Santa Clara County
        EPA No. (HE-149)29

    •   Sunnyvale Chamber of Commerce - EPA No. (HE-149)30
128-129


130

131-132
4    ERRATA

5    DISTRIBUTION LIST
135-138

141-160
20

-------
              Scctiop 1
SUMMARY OF COMMENTS PRESENTED AT
     16 MAY 1979 PUBLIC HEARING

-------

-------
                  RESPONSE TO COMMENTS SUBMITTED BY THE
                  PUBLIC AND BY AGENCIES REGARDING THE
                              DRAFT EIR/EIS
In accordance with the California Environmental Quality Act  (CEQA) and

the National Environmental Policy Act (NEPA), comments from  the public

have been solicited by the South Bay Dischargers Authority (SBDA) and by

Region IX of the Environmental Protection Agency (EPA) on the Treated

Wastewater Disposal Program Draft EIR/EIS.  This solicitation took three

fo rms:

    •   Mailout on 29 March 1979 of Draft EIR/EIS or Summary to
        those individuals or agencies listed in Section VII.4
        (pages 335-353) of the Draft EIR/EIS Technical Volume

    •   Publication of notices in the Federal Register on 30 March
        1979, and in local newspapers

    •   Public Hearing, 16 May 1979, 7:30 p.m., at City of Santa
        Clara


This appendix summarizes the comments received at the public hearing (incl-

uding the transcript of that hearing) as well as copies of,  and responses

to, letters received as a result of public and agency review.
        Ms.  D.  Wulfhorst,  Council  Member,  City of  Sunnyvale
        (transcript  pages  31-33)

        Mr.  R.  R.  James, Chief  Executive  Officer,  San  Jose  Chamber
        of Commerce  (transcript pages  33-35)

        Mr.  L,  F.  Cournoyer,  Santa Clara  Valley Water  District
        (transcript  pages  35-36)

        Mr.  J.  Quintal,  Santa Clara County Canners Association
        (transcript  pages  36-39)

        Mr.  B.  E.  Schoppe,  Santa  Clara  Chamber of  Commerce
        (transcript  pages  40-41)

        Mr.  M.  Pearl  (transcript  pages  41-42)

        Mrs.  M.  Brendler,  Sunnyvale Chamber of Commerce
        (transcript  pages  42-43)

        Mr.  B.  Martin,  Citizens Advisory  Committee,  City  of  Santa
        Clara (transcript  pages 44-45)

        Mr.  P.  Ferraro  (transcript pages  45-49)

        Mr.  C.  Harrison, Director, Cupertino  Sanitary  District
        (transcript  pages  49-50)
Issues raised in this testimony are addressed  on pages  following

the full transcript  of  the  hearing.
               1.  TRANSCRIPT OF 16 MAY  3979 PUBLIC  HEARING

The following individuals testified at the public hearing, held  in May

1979, in the City of Santa Clara Council Chambers:
    •   Mr. R. Diridon, Supervisor, County of Santa  Clara
        (transcript pages 26-30)

    •   Mr. S. Goodman, Santa Clara County District  Four
        (transcript pages 30-31)
                                                                                                                                               23

-------

-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
IS
17
18
19
20
21
22
23
24
25
26
27
28


JOIIIT PUBLIC HEARING
By the
U.S. ENVIRONMENTAL PROTECTION ASEf.'CY
and
THE SOUTH BAY DISCHARGERS AUTHORITY


COMBINED DRAFT ENVIRONMENTAL IMPACT
STATEMENT'EM'mO'lMENTAL IMPACT REPORT

HAY 16, 1979
7:30 p.m.
Q.J< •
Jfff
HICMALL- 5. WALKER, CHAIRMAN











M/Qtc.itc t^A. xJucw £ onfisopifitfs
CEFTtnED SHORTHAND REPOFiTEFiS
,
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
I Q
ID
19
20
21
22
23
24
2i
26
27
28


j
HR. GISSLER: The South Bay Dischargers
Authority started their meeting at 7:00 p.m. and then
adjourned to this time and I would now like to fcii-r.ially
declare the'public hearing on the draft EIR/EIS
for this project officially open.
I would like to turn the meeting over to
Matthew S. Malker a Senior Attorney Hearing Officer for
the Environmental Protection Agency.
MR. WALKER: Thank you, Mayor. Good evening, ( ,
MATT His W IK/
my name is Hicharr S. Walker and I've been appointed />'J
to act as Hearing Officer for the purposes of these
proceedings.
This hearing is a joint hearing between the
Environmental Protection Agency and the South Bay
Dischargers Authority. Pursuant to the federal reaula-
\ ////
tions, a notice of this hearing was published en U
April 2nd, 1979, in Volume 44 of tne^Register at page .-.^ j
19241. As we all know it is the Oc 1 1 o '0-t A tu toi y law I ,.>
m
that everybody readfe 4*- the Federal Register every day,/*/
So in addition to that, a notice of this hearing was aiso
given by publication in newspapers in this vicinity and
I have here a copy of the Notice of Joint Public Hearing
by the U.S. Environmental Protection Agency and the South
Bay Dischargers Authority.
For the purpose of this record I am going to
mark this copy of the Notice as Exhibit 1. We will have
other exhibits later on to talk about.
///
H/QujMe c«A. ijHCt' £ (_A*>SGCiflit2
CERTtFIED SHORTHAND "EPOr.Tgfis
5B6NQ,Flfl$T ST , S*N jO£c. CA9I11?
TELEPHONE: !
-------
 1
 2
 3
 4
 5
 6
 7
 B
 9
10
II
12
13
14
15
16
1?
IB
19
20
21
22
23
24
25
26
27
28
                      (Thereupon, a four-page document
                      entitled Notice of a Joint Public
                      Hearing by the U.S. Environmental
                      Protection Agency was marked  Exhibit
                      1 for identification.)
           MR. WALKER:  This hearing being a joint  hearing
is being held pursuant to two different statutes; the
National Environmental Policy Act of 1969, which is often
called NEPA, requires that a detailed statement be  made
on the environmental impact and effects of any
recommendation or reports of any major federal action.
           The Federal Water Pollution Control Act, also
known as the Clean Water Act, requires the administrator
of the Environmental Protection Agency to encourage waste
treatment management that results in desirable
environmental impact effects to the extent it  is
possible on an area wide basis.
           Title 40 of the Code of Federal Regulations
requires the Environmental Protection Agency  to hold  a
public hearing.  Pursuant to those regulations the
                                               inte/i/tio/v
Regional Administrator publicly announced  the  protection  /
of the Environmental Protection Agency to prepare an
                                             LUltA
environmental impact statement in compliance -of- the'
Section 102 of the  National Environmental  Policy Act.
            In addition to these requirements,' Resolution
Number 73-16 of the South Bay Dischargers Authority
requires preparation of  an environmental  impact report  for
the  SBDA treated water disposal program.   This resolution
further requires that  a  public hearing be  held during
and  before  which any and all  interested  persons shall  be
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
given an opportunity to be heard  on  the  proposed
environmental impact report.
           This is that hearing.   A  combined environmental
impact statement, environmental  impact report,  has been
prepared.  It is entitled "Draft  Environmental  Impact
Report and Statement, Treated  Wastewater Disposal  Program.'
These four volumes constitute  that report,  and  for the
purposes of this record they will  be marked as  Exhibit 2.
                      (Thereupon,  a  report  entitled
                      Draft, Environmental  Impact  Report
                      and Statement, Treated Wastewater
                      Disposal  Program,  Summary, dated
                      September 197B was marked Exhibit 1
                      for identification. )
           MR..WALKER;  This hearing has been called to
receive public comments on this Draft Environmental
Impact Report.  The  notice states that  the  hearing may
be continued  from time to time or to a  different  place
to accommodate the needs of witnesses or the Environmental
Protection Agency.
           In order  to bring the matter  to  some sort of
a conclusion, so that a final  Environmental Impact
Statement can be prepared,  the Environmental Protection
Agency proposes at the end  of  this public hearing to close
the  record for the receipt  of  oral statements,  but to
leave the record open for  three weeks,  that is  fifteen
working  days, for the receipt  of supplemental written
statements.
           Several people  have requested permission  to file
supplemental  written statements.   It is  expected  that the
                                                         fi u4
                                             CERTIFIED SHQBTMANDBEPOf TESS
                                             Xt NO. FIRST ST.. SAN JOSE. C* 95(12
                                                TELEPHONE: 4*03; 0
                                                                                                                  CERTIFIED SHORTHAND REPORTERS
                                                                                                                 SM NO. F tR£T S F , SAN JOSE, CA 951U
                                                                                                                    TCLEP!I01E: «OB| 9994699
26
-------
 l        supplemental  statements will amplify and enlarge the
 2        positions  that  are taken tonight.
 3                    If for any reason the supplemental  statements
 4        take  new  positions, or bring substantially new facts  to
 5        the attention of the hearing bodies, it may  be necessary
 6        to schedule a new public hearing so that everybody  can
 7        have  an opportunity to comment on those statements.
 8                    Now, this being a formal hearing,  we  are
 9        making  a  record of the hearing,  and Mrs. Valerie Fitch
10        of the  firm of Fitch and Associates is  a certified
11        shorthand reporter and is making a stenographic  record  of
12        all  of  the comments made here  tonight.
13                    We are going to  request that all  persons come
14        to the  podium,  use the microphone, tell us  their name
                                         representative.
15        and  if  they are appearing in a  roproocntod  capacity, also
16        tell  us in what capacity they  are appearing.   We win
17        not  entertain questions from the floor, because  it is
18         Impossible to keep an  orderly  record  in such circumstances.
19                    However,  if people  in the  audience feel  the
20         need for It, we will  take a recess after  the hearing
21         has  been going on  for  some  time for a  question and answer
22         period.
23                    Mr.  Helphingstine,  who  is  on my left, will be
24         glad to assist  anyone  in answering  questions that  may
25         occur  to you.   However,  I have to  note that the cdmments
 26         that are made  in  a  question and answer period are   not a
 27        part of  the  official  record and way  not be considered
 28        when the  final  report is  drafted and  prepared.  That
 1
 2
 3
 4
 5
 6
 7
 B
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
question and answer period  is  for  your  assistance  and  help.
However, if anything comes  up  during  that  period that  you
feel should be on the record,  it would  be  necessary  for
you later on to take the  podium and recite it  for  the
record.
           How, I have certain tedious  work to do  here,
and if you will bear with me,  1 will  announce  some of  the
notices that have been received and the publications that
have been made.
           1 have an Affidavit of  Publication  of the
Notice  in the  San Jose Hews on the 12th of April,  which
will be Exhibit 3.
                       (Thereupon,  a  one-page document
                      entitled Proof  of Publication dated
                      Hay 1st, 1979,  was marked Exhibit 3
                      for identification.)
           MR. HALKER:   It  was published in the San Jose
Mercury on the 12th  of April,  and  the Affidavit of
Publication  will  be  Exhibit 4.
                       (Thereupon,  a  one-page document
                       entitled Proof  of Publication dated
                       May 1st, 1979,  was marked Exhibit. 4
                       for identification.)

           MR. WALKER:   It  was published in the San Jose
Sun on April  llth,  and  that Affidavit of Publication will
be  Exhibit  5.
                       (Thereupon,  a one-page document
                       entitled Proof of Publication dated
                       April 11, 1979, was marked  Exhibit 5
                       for identification.)
            MR. WALKER:    It was published  in the East Ssn
                                                     "tTifeli fi Associates
                                              CERTIFIED SHORTHAND REPORTERS
                                              HE NO. FIRST ST.. SAN JOSE. CA 951 '2
                                                 TELEPHONE: 4MB) 996-0699
                                               ie (A 9fifcli 6 (Associates
                                              CERTIFIED SHORTHAND REPORTERS
                                             W6 NO. FIRST ST.. SAN JOSE. CA 95117
                                                TELEPHONE: KM] MBO6»
                                                                                                                                                  27
-------
1
2
3

4

5

6
7
8
9

10

11

12
13
14

15

16

17
IB
19

20

21

22

23
24

25

26
27

28

Jose Sun on the llth of April and that Affidavit-win be
Exhibit 6.
(Thereupon, a one-page document
entitled Proof of Publication dated
April 11, 1979, was marked Exhibit
6 for identification.)


MR. WALKER: It was published in the South
'San Jose Sun on the llth of April and that Affidavit
of Publication will be Exhibit 7.
(Thereupon, a one-page document
entitled Proof of Publication dated
April 11. 1979, was marked Exhibit
7 for identification.)


MR. WALKER: It was published in the Santa
Clara Sun on the 10th of April and that Affidavit will be
Exhibit Number 8.

(Thereupon, a one-page document
entitled Proof of Publication dated
April 10, 1979, was marked Exhibit
8 for identification. )

MR. WALKER: It was published in the Campbell
Press on the 12th of April and that Affidavit of

Publication will be Exhibit 9.

(Thereupon, a one-page document
entitled Proof of Publication dated
April 12, 1979, was marked Exhibit
9 for identification. )

MR. WALKER: It was published in the Cupertino-

Monta Vista Courier on the .10th of April and that

Affidavit of Publication will be Exhibit 10.
(Thereupon, a one-page document
entitled Proof of Publication dated
April 10, 1979, was marked Exhibit
10 for identif i cd tion. )
1
2
3

4

5

6
7
8
9

10

11

12
13
14

15

16

17
18
19

20

21

22

23
24

25

26
27

28

MR. WALKER: It was published, in the Los
Gates Times-Saratoga Observer on the 10th of April, and
.that Affidavit of Publication will be Exhibit. 11.

(Thereupon, a one-page document
entitled Proof of Publication dated
April 10, 1979, was marked Exhibit -
11 for identification. )

MR. WALKER: In the Milpitas Post on the 10th
of April and that Affidavit will be Exhibit 12.
(Thereupon, a one-page document
entitled Proof of Publication dated
April 10, 1979, was marked Exhibit
12 for identification. )

11
MR. WALKER: The Sunnyvale Scribe on the +&th
of April, and that Affidavit will be Exhibit 13.
(Thereupon, a one-page document
entitled Proof of Publication dated
April 11, 1979, was marked Exhibit
13 for identification. )


MR. WALKER: In The Town Crier in Los Altos
on the llth of April and that Affidavit will be Number 14.
(Thereupon, a one-page document
entitled Proof of Publication dated
April 11, 1979, was marked Exhibit
14 for identification.)


MR. WALKER: In the Henlo-Atherton Recorder
^
on the 10th of April and that Affidavit will be Number 15.
'(Thereupon, a one-page document
entitled Affidavit of Publication
dated April 10, 1979, was marked
Exhibit 15 for identification.)

MR. WALKER: The San Mateo Times on the 12th

of April, 1979. and that Affidavit will be Number 16.

                                                                    iA 'EJ'ilck fi  ^Associates
                                                                CERTIFIED SHORTHAND REPORTERS
                                                               MS NO. FIHST ST.. SAM JOSE. CA 9*"2
                                                                    TELEPHONE: <<»» B9B-4U99
          'tJ'Uci  6  Associates
 CERTIFIED SHORTHAND REPORTERS
SEC NO. FIRST ST., SAN JOSE. CA 95112
     TELEPHONE: <«»J B98-08M
28
-------
           MR. WALKER:   In the  Valley  Journal  on the llth
of April, and that Affidavit will  be Number  17.
                       (T.,,.i cupon,  a  one-page document
                       entitled  Proof of Publication dated
                       April 11,  197».  was  marked Exhibit
                       17  for Identification.)
           MR. WALKER:   In the  San Francisco Chronicle
on the 12th of April  and  that Affidavit will be Number 18.
                       (Thereupon,  a  one-page document
                       entitled  Declaration of Publication
                       dated April  13,  1979,  was marked
                       Exhibit  18 for identification.)
            MR.  WALKER:   1  have also a press release that
was  issued  by  the  Environmental Protection Agency and to
keep the  record complete,  that will be Exhibit 19.
                       (Thereupon, a one-page document
                       entitled EPA Environmental Hews.
                       For  Immediate Release, Where Should
                       All  the Wastewater Go, was marked
                       Exhibit 19 for identification.)
            MR.  WALKER:   And there was a notice of this
given by  mailing to a large mailing l.ist of interested
persons,  the publication is dated May 30,  1975?
            MR.  HELPHINGSTINE:  This was a  Notice  of
 Intent to prepare it.
            MR.  WALKER:  Oh. excuse me, this was  the
 Notice of Intent when we were  first starting on  this
journey.   And that will be Exhibit Number  20.
                       (Thereupon, a two-page document
                       entitled To All  Interested  Agencies,
                       Public  Groups and Concerned
                       Individuals dated May 30,  1975,  was
                       marked  Exhibit  20 for identification
            MR. WALKER:  Thank you  for  bearing  with  me  on
                      1
                      2
                      J
                      4
                      5
                      6
                      7
                      8
                      9
                     10
                     11
                     12
                     15
                     14
                     15
                     16
                     17
                     18
                     19
                     20
                     21
                     22
                     23
                     24
                     25
                     26
                     27
                     28
	10
 that.
            Now we have a procedure for  the  Environmental
 protection Agency that we use  in conducting public
 hearings, and in this procedure we take  people more  or
 less In the order in which they have registered.  There
 were certain cards that look like this  (indicating)  as
 you came in the door and you 'may have been  asked  to  sign
 a registration card.  If you wish to make a statement,
 you were asked to check the box.  I have several  cards
 here of people who have checked the boxes,  stating  that
 they want to make a statement.
            Now, in our procedure we ordinarily call  on
 elected officials first.  Thereafter we  call  on  people
 in different groups;  Interested public  citizens, people
 representing public agencies,  people representing
 Chambers of Commerce, people representing industries and
 we rotate the call among those various  groups.
            However, this evening, since  we  don't  have many
 requests for people to be heard, I propose  to take  them
 just in the order in which  the cards were received.   If
 you would like to make a statement, and  I do not  have
 your card, I suggest that you  go to the young lady  at the
 door,  just outside  the door, and ask  to have a card checked
 with the box that says you  would like  to make a  statement.
            Now, what is  goiflg  to happen next? After the
 conclusion of this  oral  part of the public  hearing, the
 Environmental Protection Agency will  receive public comment
 as  I   said,  for  three weeks,  and  that  would be  until the-

fi (Associates
                                        ut.
                                     CERTIFIED SHORTHAND RERORTEPS
                                    SM HO. FIRST ST.. SAN JOSE. CA «! 1 2
                                        TELEPHONE: MM! M34«*
                                                 & (Associate
                                     CERTIFIED SHOATHANO REPORTERS
                                     SMNO. FIRST SI.. S«N JOSE. C* 9*11!
                                        TELEPHONE: («*»
                                                                                                                                         29
-------
                                                                                                                                                   12
 l         6th  of  June.   Any  comments  that  people want to make
 2         subsequent  to  this  oral'part  of  the  hearing must be
 3         received  in  the  Environmental  Protection Agency, 213
 4         Fremont Street,  San' Francisco,  before the close of business
 5         on  the  6th  of  June.   At  that  time  our records will be
 6         closed.  •
 7                    As  1  earlier  mentioned, if the' comments are
 8         in  amplitude or  supplemental  to  the  statements made
 9         tonight,  there will  be no further  part of our public
10         hearing.   The  record will be  closed  and it wiH be reviewed
11         a  staff recommendation will be made, and that will be
12         made to the Regional Administrator who will approve
13         or  disapprove  or take some other action with respect to
14         the environmental  impact statements, so .far as federal
15         action  is concerned.
16                    Other action may be taken by the South  Bay
17         Dischargers Authority, and there will be other comments
18         on that a little later on.
19                    How,  I don't  know whether everybody  knows who
20       '  all the people are  here.   Mr; Mayor, would you  like  to
21         introduce the  people?   I have some  notes here  but  you
22         know them better than I.
23                    MR. GISSLER:  All right,  from the  City  of
24         palo Alto, CounciImember Al Henderson.   From  the  City
25         of San Jose, Mayor  Janet Gray Hayes.  On my  far  left
26         from the City of San  Jose, Councilman Jerry  Estruth.
 27         And next to him from  the City of  Sunnyvale,  still  mayor?
 28                    MR. GUNN:  Yes.
 i
 2
 3
 4
 5
 6
 7
 8
 9
10
II
12
13
U
15
16
17
18
19
20
21
22
23
24
21
26
27
20
           MR. GISSLER:  Mayor  Gil  Gunn.   I  guess  you will
be changing soon, I guess.
           MR. WALKER:  Thank you  very  much.   Mr.
Helphingstine has a brief  statement to  make  about  this,
and then we will call on the consultants  and  then  we will
be calling on the public:  Mr.  Helphingstine?
           MR. HELPHINGSTINE:   Good evening,  ladies and
gentlemen.  My name is Bill Helphingstine.   I am the
Project Officer for the Environmental  Protection Agency.
The Environmental Protection Agency 'and the  South  Bay
Dischargers Authority have jointly prepared  this
Environmental Impact Statement  and Report in order to
disclose  the  impacts of the proposed  project alternatives
for the construction of treated wastewater disposal
facilities to serve the greater Santa Clara  County area.
           I  would like to take this  opportunity to mention
the water  quality problem  in south San Francisco Bay and
to summarize  the purpose  of  this project and the Draft
Environmental Impact  Statement  and Report.
           Waste load  accumulations over the years have
caused  depression of  dissolved  oxygen concentrations,
high concentrations of  toxic  heavy metals in sediments,
and localized problems  of  fish  kills and waterfowl
botulism  outbreaks.   Lack  of  freshwater  inflow during
the dry season  and  subsequent  flushing of the estuary  have
further aggravated  these  conditions.
           The  purpose  of this  project is to provide  a
treated wastewater  disposal  system for the San Jose/
                                                 «A
                                                                                                                                        6 Associates
                                              CEMTIREO SHORTHAND REPORTERS
                                             586 NO. FIRST ST., SAN JOSE. CA9S112
                                                TELEPHONE: ("
                                              CERTIFIED SHORTHAND REPORTERS
                                             SB6NO. FIRSTST., SAN JOSE, CA9S112
                                                 TELEPHONE: HM; mg-OtM
30
-------
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
	LL
 Santa Clara, Sunnyvale and Palo Alto  wastewater treatment
 plants.  These plants presently discharge  their treated
 effluents Into sloughs or a drainage  canal  which drain
 into south San Francisco Bay.
            The treated wastewater  disposal  program was
 initiated because the California Water Quality Control
 Board's Basic Plan prohibits  the discharge  of any plant
 effluents into South San Francisco Bay below the
 Dumbarton Bridge.
           , The Environmental  impact Statement and Report
 has been prepared because significant impacts could
 result from  the  implementation  of  several  of the project
 alternatives.  These alternatives  include  wastewater
 reclamation, further advanced treatment, a long outfall
 extending to north of the Dumbarton Bridge.
             By the way, you  notice  there are some large
 maps to  the  left, my left,  by the  seal.  Those  indicate
 some of  the  major routes considered in this Environmental
 Impact Report and Statement.
             The other alternatives  considered would be
 •individual  outfalls  to  the  South  Bay and a no-project
 alternative.   Environmental  impacts of the basin plan
 alternative would  include  disruption of rare and
 endangered  species;  the  salt marsh harvest mouse,  and
 the  California  clapper  rail1; and also  possible  improve-
 ments  in the beneficial  uses of the South Bay,  such  as
 fishing  and recreation.   These alternatives range  in
 estimated  cost  from  $86 million for a  sixteen  mile
 l
 2
 3
 4
 5
 6
 7
 8
 9
 10
 11
 12
 13
 14
 15
 16
 17
 IB
 19
 20
 21
 22
 23
 24
 2}
 26
 27
• 28
pipeline and outfall to discharge effluent  approximately
one mile north of the Dumbarton Bridge,  to  $323  million
for a water reclamation and reuse alternative.   And  these
costs are based on  a couple of years ago.  The  construction
costs of either of  these alternatives  would now  be
higher to incorporate the  inflation which  has  been  going
on during the last  several years and the next  several
years it would take to actually construct  to get those
alternatives.
           The project alternative  has not  been  selected.
However, the Environmental Protection  Agency and the
South Bay Dischargers Authority recommend  a no  project
alternative because the degree to which increased dilution
resulting from a  discharge north of the Dumbarton Bridge
will mitigate the adverse  impacts of toxicants on the
biota of the South  Bay cannot  be predicted.
                                                          i
           Modeling studies  have not shown that  a
substantial  Improvement  in dissolved oxygen concentrations
would result if the discharge  were  moved north of the
Dumbarton Bridge.
           The viability  of  future  full reclamation is
being investigated  in  the  Regional  Wastewater  Reclamation
Study.   Such an alternative,  if  It  proves  to be feasible,
would meet  the planning  requirements  of the San Francisco
Bay  Basin Plan.
            The Environmental  Protection Agency and  the
South Bay Dischargers  Authority  recognize  that compre-
hensive  receiving water  monitoring  will-be needed to
                                              CERTIFIEDSHOKTHiNO HEPOBTf US
                                             set NO. FIRST ST.. S»N JOSE, c« ssi 12
                                                                                                                    CERTIFIED SHORTHAND REPOPTERS
                                                                                                                    598 NO. FIRST ST., S*N JOSE. C* 9S1,2
                                                                                                                       TELEPHONE: H0819P8-OBW
                                                                                                                                                  31
-------
   ^____	      IS
 1         to document  the  impacts  of wastewater discharges in the
 2         South  Bay.   This  decision Is  being recommended based on
 3         present  knowledge.   However,  if the final selection is
 4         a no  project alternative, we  will  continue to evaluate
 5         results  of  the monitoring program and will reconsider
 6         our  selection,  if appropriate.
 7                    that  concludes my  comments.
 8                    MR. WALKER:   Thank you, Mr. Helphingstine.
 9         1 will say  that  the maps on the wall that have been
10         referred to  in  his statement  are, I am told, reproductions
U         of maps  or  diagrams that earlier appeared in the Draft
12         Environmental Impact Statement Report. For that reason
lj         they will  not be marked  as exhibits or incorporated in
U         the  record  physically.    They are already there in another
J5         form.
16                    Now,  the next person 1 will call on to explain
17         the  project here is Dr.  Carol Harper of Bechtel National,
18         Incorporated.  1 believe you  were representing the con-
19         sultants on this matter.
20                    DR.  HARPER:   Mr. Chairman, I am with the South
21         Bay  Dischargers, my name is Carol Harper  and  I am the
22         Project  Engineer for the Environmental Impact  Statement
23         for  Bechtel  National, Inc., and we  are the consulting
24         firm for the South Bay Dischargers  Authority  on this
»         project.
26                    My purpose tonight  is  to present a  summary  of
27         the Draft Impact Report  and Statement and the  associated
28         work that contributed to  it.
 I
 2
 J
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
           The South Bay Dischargers  Authority has a
service area of Santa Clara  County  and for the most part
encompasses the cities of San  Jose,  Santa Clara, Sunnyvale
and Palo Alto and their tributary agencies.
           These facilities  in 1973 and '74 began work on
advanced waste treatment, for  their three treatment plants.
This Environmental Impact Statement-Environmental Impact
Report is concerned solely with disposal  alternatives
for that advanced treated wastewater.
           At any time the estimates  for  the quantities
of this disposed wastewater  are about 370 million gallons
a day in the year 1995.  And that's a peak flow.
           The alternatives  are described in detail, a
number of alternatives are described  in detail in the
Environmental Impact Statement and  Report which has been
put into the record.    In order to provide a comparative
analysis in this report so a decision can be made, a
number of field studies were initiated.  I would like
to list these off and  indicate who  did these studies.
           The first one was a detailed study on sediment
quality and engineering bearing strength  of the Bay muds
by R.C. Harlan  and Associates.  There were two separate
studies by Mr. Harlan.
           The second  study  was a surface archaeological
survey by Archaeological Co-nsulting and Research Services,
Inc., of Mill Valley.
           The third was a  series  of water quality and
biological surveys by  E.H.  Smith and Associates of
                                                          6 [.Associates
                                              CERTIFIED SHORTHAND fl€ PORTE AS
                                             586 NO. FIRS'! ST.. SAN JOSE. CA Ml 12
                                                TELEPHONE: t«M) 99«-<>aM
                                              jiifi  WS-06*)
32
-------
	    .	  17
 Bodega Bay.
            The fourth was a laboratory  water  quality
 survey by Pacific Environmental  Laboratory  of Kennedy
 Engineering.
            The fifth was a water quality  modeling study
 performed by Hydroscience, Inc.  with  offices  in  Hew Jersey
 and in Walnut Creek, California.
            In addition,  a Technical  Advisory Committee
 was formed consisting of representatives  from thirty-four
 federal, state and  local agencies.   These individuals
 regularly net, reviewed draft  material, commented on this
 material, provided  data and also provided contacts with
 experts  in the area across the country  as well as in
 California.
            I will briefly  refer to some of the maps on
 the wall.  It might be  easier  for you to look at them
 during the recess.   But all  of the alternatives  for
 disposal that were  considered  by us were located in.what
 is considered the Bay  Lands  of San Francisco Bay. -
            The dominant feature of the area  is the  San
 Francisco  Bay, south of  Dumbarton Bridge and the associated
 marshes, mud  flats  and  open  waters.  In  the  past hundred
 years much  of  the marsh  and  mud flat area  has been  filled
 and has  undergone extensive  urban, industrial and govern^
 mental development.  But  the unique qualities of the  bay
 continue to  dominate the  characteristics of  the  area.and
 many  natural  areas  persist in parks and  in open  space
 surrounding the  west side of South San Francisco Bay.
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
a
12
1}
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
                                                            18

              In these areas have been  found as many  as  five
   endangered species and a number of threatened  plants  and
   animals on the federal and state listings.  At  both the
   cities of San Jose and Palo Alto the wastewater discharges
  resulted in the creation of a fresh water aquatic habitat,
   In particular,  wading birds, such as herons and egrets,
   which are considered  species of concern by  official
   wildlife services of  the United States government  and much
   fresh water vegetation are now common in Artesian
   Slough which  is the discharge location for  the City of
   San Jose and  the City of Santa Clara.
              This slough is within the National  Wildlife
                             „,!. refuge  system  and ID  eall/** k
                                                            1'
In. the South San Francisco  Bay  National Wotoi- life  Refuge.
              And the fresh water communities  contribute
   to the diversity within  that  wildlife  refuge.  ,
              In the years  since World  har  II,  as  I
   mentioned, the region  has  changed  markedly  from an
   agricultural center  to  an  industrial center.   And increases
   in population have accompanied this  change  and  contributed
   to the degradation of  water  quality  in the  Bay  such as
   Mr. Helphingstine has  outlined.  Other sources  of
   degradation  include  reduction of flows to the  South Bay
   by the damming, diking  and channelizing  of  various
   natural  waterways and  by the filling of  marshlands thereby
   reducing water surface  area  and  restricting flows south.
              The Bay Water Quality Control Plan  addressed
   the problem  in South San Francisco Bay and  recommended

                                     CERTIFIED SHORTHAND REPORTERS
                                     566 NO FISSTST.. SAN JOSE. CA 95112
                                        TELEPHONE: HC8t*»-OeS9
                                              CERTIFIED SHORTHAND REPORTERS
                                             M6 NO. FIRST ST.. SAN JOSE. C* 95112
                                                TELEPHONE: H081M8.MM
                                                                                                                                             33

-------
   	19
 I         increasing  treatment to the secondary level  and by limiting
 2        wastewater discharges to areas with good mixing and
 3         dilution  potential.
 4                    In  the  Basin Plan  it  was recommended that this
 5         area  be north  of  Dumbarton Bridge.  The South Bay
 6         Dischargers  has complied with the secondary  treatment
 7         limit but they  still have not determined the appropriate
 6         disposal  system to meet the secondary restriction.  And
 9         that,  as  I  mentioned also, is the purpose of this report.
10         '           In  the  study there were five alternatives
11         which were  thought to be cost-effective responses to the
12         state and federal  requirements.   These were:  No further
!3         action,'which  constitutes continuing to dispose at the
14         present treatment  plant sites,  Artesian Slough for San
15         Jose-Santa  Clara,   Guadalupe  Slough for Sunnyvale, and
'6         a  discharge  canal  that comes  out of the Palo Alto Treat-
17         ment  Plant  near Mayfield Slough.
18                    The  second alternative is termed  "The Basin
19         Plan  Alternative"  in the EIS.  This is the plan specified
20         in the study as a  disposal pipeline to the San Francisco
21         Bay  north of Dumbarton Bridge to the deep water area.
22                    The  third alternative was individual deepwater
23         outfalls.   These  will be outfalls to deep water south of
24         Dumbarton Bridge  and would consist of two individual
25         pipelines,  one  from the City  of  Palo Alto and the other
26         a  joint Santa  Clara-San Jose-Sunnyvale pipeline.
27                   The  fourth alternative would be to further
 ZB        upgrade treatment.  In this case it would "include treatment
 2
 3
 4
 5
 6
 7
 B
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
	?D
 beyond the present wastewater treatment  and  1  will  go
 into that in a little more detail  later.   And  the disposal
 would continue at site much like in no further action.
            In the fifth alternative reclamation and  reuse
 where wastewater would be further  treated, or  reclaimed
 and then distributed on a large scale or  on  several
 small scale projects to various users throughout the
 service area or even outside the service  area  for the
 South Bay Dischargers.
            As Mr. Helphingstine has mentioned, no project
 alternative has been selected but  the recommendation
 has been towards a no further action alternative.
 I  can go into more detail on what  the no  further action
 and the other alternatives consist of and 1  can tell you
 what the impacts were determined to be in the  EIS,
            First, the no further action  alternative
 requires no reconstruction and imposes no increased
 Operational costs on the dischargers or  their  service
 areas.  While wastewater would continue  to be  discharged
 to the tributaries of the South Bay, contributing to
 oxygen demand and the potential build-up  of  toxic
 substances, the use of advanced waste treatment at each
 plant will reduce these loadings from past levels.   In
 addition, mathematical modeling has shown that while the
 quantity of wastewater flowing through the tributaries
 as a result of discharge actually  contributes  to the
 flushing,  in South Bay, reducing  the effect of pollutants
 at the discharge site and distributing it over the open
                                              CERTIFIED SHORTHAND REPORTERS
                                             186NO. FIRST ST , SAX JOSE. C» 95' 12
                                                TELEPHONE: ('OBI 96B-OB99
                                              CERTIFIED SHORTHAND REPCflTER£
                                             MS NO. FIRST ST.. S«N JOSE, C* «Stt2
                                                TELEPHONE: ««>OTB MM
34
-------
 1        water  portion of the Bay.   This flushing reduces the
 2        net  effect of the viater discharge by keeping oxygen
 3        levels higher than might occur if there were no flews
 4        in  the tributaries.
 5                    The Basin Plan Alternative consists of a
 6        nominal  ten foot inside diameter concrete pipe connecting
 7        the  three treatment plants and associated pumping
 8        stations and running along one of several alternatives tc
 9        a  discharge point about one mile north of Dumbarton Bridge
10         in  a ship channel,  in  the deep ship channel..  Located
11        entirely within the Baylands, construction of this
12         sixteen mile long pipeline would alter the topography,
13         disrupt biological  systems, temporarily degrade air and
14        water quality and increase noise an«S traffic  levels
15         locally.
16                    The operation of tlie system would  remove  the  .
17         wastewater discharge fro;n the sloughs and the  South  Bay,
IS         decreasing the contribution of pollutants' to  that  area,
19         while reducing the  inflow to  the  Soimth Bay  in  terms  of
20         total water  input.
21                    The mathematical model  indicates that  water
22         quality would improve  in open water slightly  but
23         tributaries  south of the Dumbarton  Bridge would continue
24         to suffer  oxygen  depletion  due  to  the  loss  of flashing.
25                    The capital cost  of  the  system was  estimated   (
26         to be about  $86  million in  1979  dollars.  This was       ^
                                                 8
27         assuming  a midpoint construction  of 19/0 and  tha first
?8         year  operation  of  1981.   As  was  mentioned  earlier, the
                                                               	,	i
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
 27
28
study was started some time ago and this cost would have
to be updated.
           The first year operating costs in 1981 was
estimated to be about $280,000 and the majority of this
cost would be consumption of energy, pumping station
estimated to be about 7.9 million kilowatt-hours in the
year 1985.  This is about forty-nine hundred barrels of oil
consumed.
           The third alternative, individual deepwater
outfalls consists of a joint San Jose/Santa Clara and
Sunnyvale disposal  line running to a location off Coyote
Point and a separate disposal  line for Palo Alto, dis-
charging to the main channel off of their present discharge
location.  The construction of this alternative woul'd have
effects similar to  the Basin Plan Alternative although
more extensive effects would occur in the water  itself,
on the marshes and  the mud flats and in  the open water
habitat and less effects would-occur on  dry land.
           Operation of this alternative would remove
pollutant discharges from the  tributaries but not from
the South Bay  and  improvement  in open waters and the
tributaries would  be no different  than  is  in the Basin
Plan Alternative.
           The capital  investment  is  estimated  to be
about  $69 million  in  1979 dollars.   This is  about 20
million  less  than  the  Basic  Plan Alternative with  the  first
year  cost approximately  the  same,  $280,000.
            The fourth  alternative,  Upgraded  Treatment,

                                                    9"i(cl> 6
                                             CERTIFIED SHORTH AND REPOflieflS
                                             5M NO, FIBSI SI. SAN JOSE r.A 95112
                                                TCUPHONE: «0») WMSW
                                                                   35
-------
        	       23^
         consists of the addition of carbon absorption  to  reduce
         toxicity and oxygen demands and  to breakpoint  chlorination
         for residual ammonia  removal at  the  Santa  Clara/San  Jose
         plant only.  Each treatment plant would continue  to
         dispose at  the present  locations as  in  the No  Further
         Action Alternative and  construction  impacts  would be
         limited to  the San Jose/Santa  Clara  plant  site.
                     Operation  of such a  facility would  improve
         water quality  in  both open water and tributaries  with  the
         amount of  improvements  small compared  to  the increased
         consumption of chemicals and energy  typical  of such  plants.
         In addition, violations of both  dissolved  oxygen
         standards  and  toxicity  guidelines would  still  occur  in the
         tributaries during periods of  stress,such  as high water
         temperatures or  discharges due to  the canning season.
                     The capital  cost  is estimated  to be approxi-
         mately  $120 million  in  1979  dollars, or about $40 million
         more  than  the  Basin  Plan  Alternative and  operating cost
         were  not  estimated,  but are  expected to be greater than
          the Basin  Plan Alternative  due to  increased energy
         consumption.
                  •   The fifth alternative is Reclamation  and
          Reuse and  was  considered  both  as an alternative  to
          disposal,  that is we considered using all of  the pro-
          jected  wastewater,  and  as  a- supplement to any other
          disposal  alternative whereas only a portion of the waste-
          water would be reclaimed  and the remainder disposed through
          a Bay disposal system.
 I
 2
 3
 4
 5
 6
 7
 6
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
	24
            Since the technology is available  to  reclaim
 wastewater for any use excepting drinking water,  because of
 the restrictions of state law  and federal  policy,  the
 cost of reclamation and the existence of an available
 market for the water become the limiting factors  in this
 alternative.
            A number of studies over  the past  six years
 have shown that the cost of reclaiming water  is  more,
 both in terms of energy consumption  and total dollars
 than 1s the cost of treating for disposal only.
 Reclamation treatment would resemble a  freighted treatment
 and you would still have to figure out  some way  to get
 the water to market or to a disposal site,  so you are
 adding a total  treatment to a  disposal  system.
            If the  full capital  and operating  cost of
 developing the  new water supply,  for example, importing
 water  from the  Sierra mountains  to the  Bay  Area, were
 considered,  reclamation  for most  users  is  competitive.
 But we say here the true cost,  the  full  cost, not the
 subsidized cost of developing  the water supplies.
            And  thirdly,  markets  in  the South Bay are
 limited  to Industrial  use,  agricultural  irrigation,  open
 space  irrigation  and  recreational use such  as ponds  or
 parks.   And  a  maximum amount  of water which could  be
 consumed  in  these uses  is  constrained by the seasonal
 variation  in the Bay  area,  the needs are reduced to
 nearly zero  in  the wintertime  for most users and are
 maximized  during the  hot summer months.
                                                 (A 0i(cli fi (Associates
                                              CERTIFIED SHORTHAND REPORTERS
                                             S06NO. FIRST ST., SAN JOSE. CA 95112
                                                TELEPHONE: (>M»M-OM<
                                                    9"Uefi 8
                                              CERTIFIED SHORTHAND REPORTERS
                                             6M NO. FIRST ST.. SAN JOSE, CO 8511 J
                                                 TELEPHONE; (4M) M8-08W
36
-------
I                   A  67  HGD facility would supply the majority  of
2        the identified markets  in Santa Clara County but would
3        only  reduce  the  disposal  requirements by approximately
4        twenty  percent.   In addition, the water would only  be
5        needed  during the summer  dry season and a full  disposal
£        system  would  still  be required.  In order to increase  the
7        market  demands, the reclaimed water would have to be
B        transported  out  of the  San Jose marketing area.  And  this
9        is  the  subject of the Regional Study .that is now being
10        participated  in  by EPA.
II                    The construction  impacts of  the  Reclamation
12        Alternative would include the alterations resulting from
13        construction of a transport  and distribution pipeline,
H        from  wherever the reclamation plant were built  to  where-
15        ever  the water was being used, as well  as construction
16        on  site at the treatment plant chosen.  And for this
n    '    project we assumed, San Jose/Santa Clara  because  it  was
18        nearer  a central market in Santa Clara  County.   Operation
19        of  this alternative removed  a portion of  the discharge
20        from  the Bay for a portion of the year, and solid  waste
21        generation would increase and energy  and chemical
22        consumption would  increase.   Energies and  chemical
23        consumption for the purposes  of  treating  the water,
24         energy  for transporting  the  water  and solid waste  sludges
25         in  various chemical wastes are  produced in  removing the
26        materials from the reclaimed water.
27                   The capital cost  would  vary  with the treatment
28        and transport system chosen, but  has  been  estimated to  be
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
as much as $328 million or approximately  four  times  the
Basin Plan Alternative.  Operating  costs  could  be  as  much
as for the upgraded treatment  and disposal  cost would not
be significantly reduced.  Export and  distribution costs
could be as much as five to  fifteen times the  Basin  Plan
operating costs depending  upon the  market site, and  that
means the distance the water has  to be transported.
           That's all  I have to say.
           MR, WALKER:  Thank  you,  Dr.  Harper.   I'm sure
that the  County will  make a considerable effort to
summarize the four volumes in  your  statements.   We
appreciate that.
           Now we are  ready  to hear from  the public.
Pursuant to our announced  program we will first hear
from Mr. Rod  Diridon,  Supervisor  for the  County of Santa
Clara, Supervisor.
           MR. DIRIDON:  Mr. Walker, I have a  presentation
from the Board of Supervisors  by  their consent and
unanimous vote.   I am  also presenting  the statement and
will be assisted  in doing  so by Steve  Goodman  of San Jose
District Four, also adopted  by unanimous  vote, and
resolutions from  the  City  of Los  Gates and Campbell, each
having been adopted by unanimous  vote  by  those communities.
           Each  of  these  resolutions endorses  the No
Further Action Alternative presented by Or. Harper just
concluded.  And  the reasons  for that conclusion, I think,
are  very well  summarized  in  the EIR as pertaining to that
alternative.   I .will  mention briefly.a couple of those
                                                  (A. "STitct S ^Associates
                                              CERTIFIED SHORTHAND REPORTERS
                                              586 NO. FIRST ST.. SAN JOSE. CA 99112
                                                 TELEPHONE: 4*081 8M-OB99
                                                 (A 'tfifck & ^Associates
                                              CERTIFIED SHORTHAND REPORTERS
                                             ue NO. F:RST ST.. SAN JOSE. CA 9511 z
                                                TELEPHONE: «08H»a-08M
                                                                                                                                                   37
-------
         that we  stressed in the debate at the various -bodies that
         took action as  I am describing the action to yoj today.
                    First is in regard to environmental impact.
         It 1s the conclusion of the County Health Department,
         the County Planning Department that the environmental
         impact of attempting to construct this long outflow would
         be much more severe than any impact that could occur from
         continuing the  discharge procedures currently pursued
        ,and recognizing the effluent .has been upgraded now
         to tertiary water and does have a marked impact,
         a point on which I would like to expound in a moment.
         Therefore, we are opting for a course of action that would
         minimize the environmental impact.  And both  in terms
         of water quality, degradation and  in terms of the natural
         environment destruction that would occur in sanitation
         and disrupting of the wildlife  in  the area.
                    The next point  is in  regard to cost.
         Sanitation District Four alone  has $1.1 million in  reserve
         for this project.   If that $1.1  million were  freed  and
         could be given back to  the users of  sanitation  services
         in District Four, which includes  the cities,  at least
         the majority of the area encompassed by  the cities  of
         Saratoga,  Honte Sereno, Los  Gatos, Campbell  and the un-
         incorporated area adjacent  to,  some  portions  of West
         San Jose,  the  reduction in  fee  would be  about forty-five
         cents per  month per user,  which is not  an  Insignificant
         reduction.
                     That's  an  alternative that  we would like to
 1
 2
 }
 4
 5
 6
 7
 8
 9
10
11
12
1}
U
1}
16
17
18
19
20
21
22
23
24
25
26
27
28
                                                	28
pursue.
           I understand that  the  City  of  San  Jose and
the City of Santa Clara both  have reserves  of some amount,
also awaiting decision on this  project that could be like-
wise freed and used for another purpose,  or returned to
the taxpayers and users that  accumulated  the  fees
originally.
           I would like to  comment now briefly on the
sequence that we would encourage in terms of the action
being proposed.  There is a significant amount of federal
funds that have been  ear-marked for this  project.  The
County of  Santa Clara and Sanitation District Four have
both commented frequently on the potential  of using a
portion of those funds or all of those funds for something
that may look  like your alternative number five but may
not be in  the  detail  of your 'alternative number five.
We would hope  that in the action ta'ken to abandon the
project the  funds  that have been encumbered by that
project would  not  be  released until the potential of
using some or  all  of  those  funds for an additional
reclamation  and  reuse possibility would be explored.
And that procedure  I  think  would be known better by you
than by me,  the  red  tape  on the federal Is something  to
behold.   I had a chance  to  look at It  last week  and  I
don't want to  look at it  again for a while.
            That  would conclude my  statement.   I  would  be
happy  to answer  any  questions and  I do have a  copy  of  the
resolution,  except for the County's resolution,  which  was
                                                         6 ^Associates
                                             CERTIFIED SHORTHAND REPORTERS
                                             5H NO. FIRST ST. SAN JOSE. CA 95112
                                                TELEPHONE- ;«Dt>«S-<»9»
                                                 (A ^Ucli 6 Associates
                                              CERTIFIED SHORTHANO RECOHTErtS
                                              SW "O FIRST ST.. SAN JOSE. CA »511»
                                                 TEICPHONE: «M) Stt-tUM
38
-------
    	29
 1        adopted  only  yesterday and that would be submitted,  ir
 2        permissable;    It would be offered quickly.
 3                    MR.  WALKER:  Than* you.  Yes, I would  like  to
 4        have  copies of  the references you referred to  and  they
 5        will  be  marked  as exhibits.  That is an interesting
 6        thought  about the federal funds already ear-marked for
 7        this  being held.   1 am not at all sure how that can  be
 8        done.   I won't  want to hold out a lot of hope  to  you
 9        because  that is a pretty sticky thing to do.   We  are
10        rather rigidly  restricted about what we can do and not do
II        with  the current monies.
12                  • As you know there is an enormous amount of
13    '    complicated recommendations on that subject but we will
14        certainly address it and see what can be done.
13                    MR.  DIRIDON:  Let me stress a point.   We  are
16        growing  in this valley at an unprecedented rate both in
17        terms of population expansion but less so  than in terms
IB        of industrial expansion.  The water that-you'are  talking
19        about now pumping out past the Dumbarton narrows  and
20        dumping  into the Bay has marketability, particularly in
21        terms of agricultural and  industrial use.
22                    It would seem very  logical, maybe  a little too
23         logical  for government,  but  very  logical  if we would take
24         that water and instead  of  pumping it out  into the Bay,
25         use it  for washing  busses, which  we  intend to use it in
26         the new county bus  yard, use it  *or  agricultural  purposes
 27         where possible,  use it  for the  other  kinds of cleansing  .
 28        purposes  where they don't  come  in contact  with human being
 1
 2
 3
 4
 5
 6
 7
 B
 9
10
11
12
13
H
15
16
17
18
19
20
21
22
23
24
25
26
 27
 28
                                                   	30
for the industry that is blossoming dire.ctly adjacent  to
this area along the peninsula.
           And if there is a way to accomplish  that,  1
know this Board in  its good judgment, will  attempt  to.
We are expending literally over maybe hundreds  of millions
certainly over a hundred million dollars  to bring water
Into this valley right now, in  terms of  the San Felipe
Project.   It seems  very peculiar that we  would  spend  a
hundred million dollars plus  for the various aspects  of
that project and turn right around and  spend another
significant number  of millions  of  dollars and  pump
similar water not quite so pure-but similar water out the
Bay.
           And  I would ask your good judgment  in abolishing
the project arid attempting to pursue some kind  of
reclamation and recycling  device  that  might be  possible
that we can retain  some of the grant  funds.
           MR.  WALKER:  We will certainly undertake to
pursue it but as you  know  when you work for a  large
organization-there  are many complex rules and  we certainly
don't  get to  make  them  sometimes.
           MR.  01RIOON:   I  understand.   Thank  you.   I*W
might  be  that  Steve GoodSUf'wil 1  have  a comment from  ff
District  Four.
           MR.  GOODW+N:   Steve Goodman, Santa  Clara County/I
District  Four.  We did  submit in  the mail an accompanying
resolution  that was referre'd  to by Supervisor Diridon,
a series  of  comments, and  unless  you felt  it was
                                                  A. "rjifeli 6 ^Ass
                                              CERTIFIED SHORTHAND REPORTERS
                                              tit HO. FIRST ST., S»N JOSE. C» 9511J
                                                 TELEPHONE: I«M)SM-W99
                                                    9"itcli ft
                                              Cf BTIFIEO SHORTHAND REPORTERS
                                             MS NO. f IRST SI . SAN JOSE, C« 9S1I2
                                                TELEPHONE: «MIS»5-G»99
                                                                                                                                                  39
-------
                                                                   31
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
appropriate to  read  them Into  the  record,  I  would let
 our written communication  stand,  Mr.  Walker.
           MR.  WALKER:   You certainly  may  let  the written
communication stand.   They  will  be given every bit as
much consideration as  the oral  comments.   Sometimes 1t is
even better if  we haven't been  involved  in your format.
           MR.  GOODMAN:   He will  rest  with that.
           MR.  WALKER:   Thank  you.
           For  the purposes of  the record, I have marked
the  resolution  of  the  Town  of  Los  Gates  as Exhibit 21 and
the  resolution  of  the  City  of  Campbell as  Exhibit 22.
                       (Thereupon,  the  aforementioned
                       documents were marked Exhibits 21
                       and 22 respectively for identifica-
                       tion.)
           MR.  WALKER:   Your name, sir?
           MR.  FERRARO:   Pat Ferraro.   Is that who you
just called?
           HR.  WALKER:   No, my next person to call,  1
will  call  on  you soon,  is Dolowries Wulfhorst, Council-
member from the  City  of Sunnyvale.
            MS.  WULFHORST:  Thank you,  Mr.  Chairman.  The
 City of Sunnyvale,  the Council met last night  in  our
 regular meeting and  adopted a resolution,   t will  read  it
 and present  it  to you.    I will read it but  I »ill  present
 the formal parts to you now verbally.
            The  City Council of the City of  Sunnyvale
 reviewed and considered  the draft of  the  EIR/E1S;
            Now, therefore,  the City Council finds  that
 project alternative number  two. Ho Further  Action of the
 1
 2
 3
 4
 5
 (
 7
 8
 9
10
11
12
13
U
15
16
17
18
19
20
21
22
2}
24
25
26
27
 28
	 .     32
 draft of the EIR/EIS for the South  Bay  Dischargers
 Authority Treated Wastewater Disposal  Program is  superior
 to all other alternatives for  the following  reasons:
            During th'e dry season* the  only appreciable
 amount of freshwater discharged  to  the  sloughs and South
 Bay 1s the highly treated effluent  from the  water
 pollution control plants in Sunnyvale,  Palo  Alto and San
 Jose; without this discharge the freshwater  marshes would
 dry up, adversely affecting the  unique  biological
 environment that currently exists.
            Transportation of the effluent by pipeline
 would have little effect on solving the deficient
 dissolved oxygen levels  in the sloughs and would increase
 salinity.
            The pumping station for  a pipeline would
 utilize large amounts of energy that is already in short
 supply.
            The degree to wh.ich Increased dilution
 resulting from a discharge north of the Dumbarton Bridge
 will  mitigate the adverse  impacts  of toxicants on the
 biota  of the South  Bay cannot  be predicted.
            Modeling  studies  have not shown that a sub-
 stantial improvement In  dissolved  oxygen concentrations
 would  result If  the  discharge  were moved north of the
 Dumbarton Bridge.
            The viability of  future full reclamation  Is
 being Investigated  in  the  Regional  Wastewater Reclamation
 Study.   Should such  an alternative prove to be feasible,
                                                         fi (Associates
                                              CERTIFIED SHORTHAND HE PORTERS
                                             9MNO. FIRST ST.. SAN JOSE, CAti5t*>
                                                TELEPKOKE: (tt» VJt-ttm
                                                                                                                   CERTIFIED SHORTHAND REPORTERS
                                                                                                                   9MNO. FIRSTS!., SAN JOSE. CAM1I2
                                                                                                                      TELEPHONE: (W»|9
40
-------
       -_	.	:    33
 1         It would  meet the planning requirements of the 'San  Fran-
 2         Cisco  Basin Plan,
 3                    The City Council recommends to the SBDA  and
 4         the  EPA that -Project Alternative Number 2, No Further
 5         Action of the draft and 'urges them to adopt  this
 6         alternative.
 7                    This was adopted by all members of the  City
 8         Council and 1 will hand you a copy of it.
 9                    MR. WALKER:  Thank you.  Me will  mark a  copy
10         of  that resolution as Exhibit'23 for the  purposes  of this
11         record.                 '
12            "        MS. WULFHORST:  Thank you.
13                    MR. WALKER:  Thank you.
14                               (Thereupon,  a three-page'document
                                entitled Resolution  Ho.  232-79
15                               dated'May  15th, 1979,  by  the City
                                Council of Sunnyvale was  marked
16                               Exhibit 23 for identification.)
17                    MR. WALKER:  The next card that  I had  in the
18         order that we previously  announced  is Mr.  Ronald  R.
19         James, Chief  Executive  Officer of  the San Jose  Chamber
20         of Commerce.
21                    MR. JAMES:   Thank  you,  Mr. Walker.   The San
22         Jose Chamber  of Commerce  supports  the  recommendation of
2?         no project alternative; and  from our  standpoint,  the
24         no project alternative  makes  a great  deal of sense.
25                     It appears  that there wouTd  really be no
26         benefits from the construction  of  the  super  sewer which
27         could  justify the expenditure of some  ninety to a hundred
28         mill ion  dollars.
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
 26
 27
 28
	     34
            In early 1970 the decision was to ban discharge
 of sewage into the South Bay and at "that time  it looked
 like a good decision, because water quality was poor.
 How, however, the water quality  levels have improved
 dramatically and except for the  runoff the effluent  from
 the San Jose plant frankly is probably the only steady
 source of freshwater entering the  Bay in this  particular
 area.
            We believe that the  improved water  quality
 not only makes the no project alternative the  only
 course of action, but also lends considerable'logic  to
 lifting the Water quality Control  Board's discharge  ban  .
 all together.  As long as the discharge ban exists",  the
 specter' of a super sewer  or its  alternatives will  still
 face us.  Recycled water  is projected to become  a  major
 source of water  for  industrial  use within  the  next twenty
 years and a new  study by  the  Santa Clara Valley  Water
 District has .indicated  that by  1990 valley  industries,
 electronics, paper products and other manufacturing,
 could be using twenty .thousand  acre feet of  reclaimed
 wastewater per year.
            If  this area  is  going to use  a  significant
 amount of  reclaimed'wastewater, building  a  super sewer
 to  transport that.same  water  out of the  area.makes no
 sense at all.
            .Finally,  these same . industries,  along with the
 canning  industry which-employs  more than some thirteen
 thousand  people, have been  hit  hard by  increases  in sewer
                                                     9"tlcl
                                              CERTIFIED SHORTHAND REPORTERS
                                              MS NO. FIRST ST.. SAN JOS6. CA 9-il IJ
                                                 TELEPHONE: («M> 9M-M99
                                              CERTIFIED SHORTHAND REPORTERS
                                             586 NO. FIRST ST., SAN JOSE. CA9SM2
                                                TELEPHONE: «Mt«9-0«M
                                                                                                                                                   41
-------
        	35_
         service  charges  over the past few years In order to pay
         for the increased water quality that we now all enjoy.
         At that time those treatment processes were justified  in
         our opinion.  However, at this point in time they are  not
         justified and any new rate increases that this investment
         would bring would have a negative impact on the canning
         industry in particular.  And that industry is  particularly
         important in this area to maintain a balance in our
         economy, and the canners should be encouraged  in every
         way to remain in the valley.
                    Thank you.
                    MR. WALKER:  Thank you, sir.
                     The next card in order of the proceedings
         previously  announced would be Mr. Leo  F. Cournoyer,
         Santa Clara Valley Water District.
                     MR. COURNOYER:  My narae  is  Leo Cournoyer.   I
         am with  the Santa Clara Valley Water District.  The
         District has  prepared written comments  on the  report  and
         these  comments are  in  the mail to EPA.  At this time  1
         would  like  to simply  briefly  summarize  the main point
         that we  made  in  our written comments.
                     The alternative  that  was  recommended by  EPA
         and  the  South Bay Dischargers  in their EIS/E1R 1s
         acceptable  on the basis  that  the South  Bay  Dischargers
         agree,  one,  that while  the •dischargers  are  being  made,
         that significant and  extensive monitoring  take place  so
         that any significant  adverse  impacts  on the  water  quality
         of the South  Bay be measured.
 1
 2
 3
 4
 5
 6
 7
 6
 9
10
n
12
13
14
15
16
17
16
19
20
21
22
2}
24
25
 26
27
 28
           Two, that  if it  is  found  that, the  discharges
do cause a significant adverse  impact  on the  water
quality of the South  Bay, then  construction of some other
alternative be considered.
           The third  item is that  if wastewater reclamation
is found feasible, then the use of the water, we strongly
recommend that it be  strongly  considered for  reclamation.
           As  I mentioned,  these are really a summary of
our comments,  as  I mentioned,  and  others are  in the mail
to the EPA.
           MR. WALKER:  Thank  you, sir.
           Mr. Jim Quintal, Santa  Clara County Canners
Association.
           HR. QUINTAL:  Mr. Walker and members of the
South  Bay Dischargers Authority, my name is Jim Quintal
and I  am here  tonight to present a statement that has
been prepared  by  the  Santa  Clara County Canners Association
It is  in the mail and you  people will  be receiving it
shortly.
           Our association  is  a non-profit organization
formed forty years ago to  provide  a forum for discussion
of problems and  opportunities  common to our  industry.
Currently most of our activities center around  the ever
expanding  load of federal,  state and local regulations
that adversely effect our  capacity to efficiently  produce
food products.
           Our association represents eight  companies
operating  fourteen  canneries  in the Santa  Clara Valley,
                                             CERTIFIED SHORTHAND REPORTERS
                                            Set NO. FIRST ST.. SAN JOSE. CA 95112
                                               TELEPHONE: («tt| »98-0«M
                                              CERTIFIED SHORTHAND REPORTERS
                                              SMNO. FIRST ST., SAN JOSE. CA 9S'1Z
                                                 TELEPHONE: (40U998-OIU9
42
-------
 1         employing  approximately twelve thousand people and having
 2         a  1.4  billion  dollar economic impact on Santa Clara County.
 3                    So  there could be no confusion as to our
 4         position,  we will  state at the outset that we are adamantly
 5         opposed  to the construction o.f a deep water outfall or
 6         any  other  alternative being evaluated that would force  the
 7         South  Bay  into compliance with the State Water Quality
 B         Control  Boards resolution 74-73, which  bans discharges
 9         to the San Francisco Bay south of Dumbarton Bridge.   It
10         is th.is  resolution which needs evaluation not methods  of
11         implementing ft.
12                    The discharge ban in question was adopted  by
23         the  State  Board five years ago and is responsible  for
14         over 100 million dollars of advanced waste  treatment
15         facilities being constructed In the  cities  of  San  Jose,
16         Sunnyvale  and  Palo Alto.  Now we are being  asked  to
17         evaluate an additional  100 million dollars  for  a  pipeline
18         or some other alternative to comply  with  an  arbitrary
'9         and 'capricious ruling.
20                    The EPA,  in  order  to further evaluate  advance
21         waste treatment programs, commissioned  the  Vertex
22         Corporation of McLean,  Virginia,  to  prepare a  report on
23         quote "An Analysis  of  Planning  for  Advanced Wastewater
24         Treatment."   The report,  published  in  July  of 1977,
25         covers  the  planning that  went  into  decisions  to construct
26         advanced wastewater treatment  facilities in six areas  of
27         the United  States,  of  which  San  Jose and Santa Clara
28         was one.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
                    	;	38_
           We quote  from  that  report:   "Costly  pollution
control projects are commonly  built with  almost no  real
knowledge of the waters  that are  to be  protected by the
generous investment  in treatment  facilities."
           Referring specifically to  the  South  Bay, we
quote  further from  the Vertex  Report.   "December, 1975,
Hydroscience publishes another mathematical model.   Like
the last (February  1972), 1t  is a mosaic  of over-
simplifications and  guesswork."
           Further  quotation,  "When  the earlier models
showed that  construction could solve  a  problem they were
accepted at  face  value.'"  However, when  the 1975 model
showed that  no  amount  of construction would work. State
officials  began to  examine the model  for unwarranted
assumptions,  inadequate  verification, and skimpy data.
This  belated discovery of weaknesses  in mathematical
models has  been costly."
            "The San Francisco Bay Regional Water Quality
Control Board  could scarcely be expected to rejoice  in
Hydroscience's  new conclusion; all previous planning  for
the  south  bay  has been fundamentally wrong.   For the  first
time the Board  has critically examined a mathematical
model for  the South Bay  and it is found wanting.   Had
the  Regional Board been  equally  critical of the  earlier
models and studies, it might never have gotten into  its
 present fix."
            Today  we find ourselves saddled with  advanced
 wastewater treatment  facilities  in San Jose that are in

                                               ic iA
                                                                                                                                        6 «90-OSW
                                                                                                                                                   43
-------
          themselves  environmentally  unsound  due  to  their enormous
          electrical  energy  requirements.   They  consume wore than
          our  fourteen  canning  factories  combined.   Much of what
          has  occurred  in  the  South  Bay  has  taken on the appearance
          of a  "Gold  Rush" by  consultants  and municipalities for
          EPA  funds.   It  is  about  time we- pause  and  evaluate the
          damages  and possible  benefits  that  have accrued from this
          uncoordinated and  uncontrolled  growth  in waste treatment.
                     The  Food  Preserving  and  Canning industry has
          long been  a vital  and important segment of Santa Clara
          County's business  community.   We have  actively and
          supportively  participated  in  the past  wastewater programs
          in San  Jose and  Sunnyvale;  primary  treatment in 1956,
          secondary  treatment  in 1964 and expanded secondary treat-
          ment in  1974.   In  each of  these cases  the  need was
          apparent and  benefits well  identified.   However, with
          advanced waste  treatment and  now this  potential "Super
          Sewer,"  the need and benefits  have never been demonstrated
          or justified.                             '  -
                     Thank you.
                     MR.  WALKER:  Thank  you.  sir.  I note that you
          have a  copy of  your  remarks.   Perhaps  you  and Mr.
          Cournoyer  can furnish the  reporter with a  copy of them.
               stateJ                                            ,
          You  pattul itGJ  that  we are to  receive  a copy  in the mail
          to be included  in  the records, 'so I will'not make them
          exhibits at this time.  However, I am sure it will assist
          the  reporter in getting the record straight if you can
          furnish her with a copy.    •        •   •    .    •
 1
 2
 3
 4
 5
 6
 7
'8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
2}
24
25
26
27
28
                      	 40
           Mr. Cournoyer, would you  he  able to do the same?
           MR. COURNOYER:  *es.
           MR. WALKER:  Thank you.
           The next card  is Kr. Bruce  E.  Schoppe,
S-c-h-o-p-p-e, Santa Clara Chamber  of  Commerce.
           •HR. SCHOPPE:   Thank you,  Mr.  Walker.   I am
Bruce Schoppe, representing this  evening the Santa Clara
County Chamber of Commerce.  We are  opposed to the
construction  of the so-called super  sewer and support the
conclusion and position,  rather,  taken  by EPA and the South
Bay Dischargers Authority favoring  the  no further action
alternative.
           Measured against the  lull of this entire
program,  that is  the  improvement  of water quality'in the
South Bay,  it is  clear  that construction of this pipeline
1s unnecessary.   The  advanced wastewater treatment
capability  now or soon  to be  in  operation at all of the
municipal  treatment facilities  involved will for all
practical  purposes achieve this  goal.
<•            We view this as a  situation in which  the real
benefits  must be  measured against the real cost.
Mathematical  modeling  has shown  that given these advance
treatment plants, very  little  difference will result in
South  Bay water  quality with  the project versus  no  project.
In fact,  there may very wel-1  be  a'net negative  result
due  to  the. removal of the fresh  water flows  from
Artesian  Slough  and  the other treatment  plant outfalls.
            The Chamber  of Commerce  is, of  course, an
                                                -------
 i        organization  of business people and we recognize  that
 2        1f  constructed, we will pay the costs of this  project  not
 3        only  through  our businesses but also through our  homes
 4        and those  of  our employees.  Quite honestly, we don't
 5        need  another  source of additional cost in  this inflationary
 6        era.   Especially when in our view it has been  clearly
 7        shown that the project is unnecessary.
 8                    Adoption of the no further action alternative
 9        makes a great deal of sense to us, both environmentally
10        and economically.
H                    MR. WALKER:  Thank you, Mr. Schoppe.   Do you
12        have  a copy of your comments for the reporter?
I)                    MR. SCHOPPE:  No, I don't, but  I  will  send
H        them  to you.
IS                    HR. WALKER:  Thank you.   I have neglected to
16        ask the members of the panel 1f  they have  any  questions,
                                  v«/ue£4Ht:
17        but I hope they will not be^about purging Js/gi/vy.
18                    MRS. HAYES:  I  am very pleased  to say that  I
19        was the one that  initiated  the name  of  super sewer and
20         I have heard it used here  a number  of  times  tonight and
21         I dubbed  it that  way a number  of years  ago and I still
22         think it  is that  way.
23                    MR. WALKER:  Thank  you.   It  is always nice  to
24         be right  1n your  own time.
25                    The next card  that  I  have is  Manny Pearl
26         representing  himself.
27                    MR.  PEARL:   I  am Manny  Pearl, representing
28     -    myself, an interested  citizen.   From 1949 to  May of ' 76 1
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
i;
16
17
18
19
20
21
22
23
24
25
 26
 27
 28
	        42
 was the Santa Clara County Public Health  Engineer,  and
 until I retired I was the member of  the Advisory  Committee
 that was referred to.
            I strongly recommend the  no further  action
 alternative.
            HR. WALKER:   Thank you,  sir.
            Mr. Merle Brendler.  Excuse we.
            MR. BRENDLER:  Mr. Chairman, members of  the
 Board, just for the record,  it  1s Mrs. Merle Brendler,
 I am here  tonight  to represent the Sunnyvale Chamber
 of Commerce.   I serve on their  Board of  Directors as
 Vice President for  Governmental Affairs.
            This is  their message  and the  thoughts they
 wanted me  to convey to  you.   The  Board  of Directors of
 the Sunnyvale  Chamber of Commerce at their Executive
 Committee  Meeting  of May 8,  1978,  and their full Board
 Meeting  of May  15,  1979, unanimously voted to urge that
 no action  beyond  currently  approved improvements at
 treatment  plants  be taken and that  the  three Santa Clara
 County treatment  plants continue  to discharge treated
 effluent into  the  South Bay.  This  position is based on
 the  following  key  considerations,  there are three of
 them:
             Number  one,  actions  taken or being taken by
  the  Cities of  San  Jose, Santa Clara, Sunnyvale and Palo
 Alto  are proving  to be  highly successful  in imp/oving  the
 water  quality  of  the South Bay.  It 1s reasonable  under
  these  circumstances to defer action on the  super sewer

                                              CERTIFIED SHORTHAND REPORTERS
                                              586 NO. FIRST ST., SAN JOSE, CA 951'2
                                                 TELEPHONE: 1
-------
 1         project,  monitor the rate of improvement and subsequently
 2         take  corrective steps,  if necessary.
 J                    Number two,  given the current and continuing
 4         improvement of  water quality, the fresh water marshes in
 5         the South Bay can be retained and the undesirable
 6         transition to salt water marshes and its adverse effect
 7         upon  existing vegetation and wildlife will be avoided.
 8                    Number three, the investments made and being
'9         made  in  the wastewater treatment plants of South Bay
W         cities  are proving to be cost effective thus avoiding the
11         cost  of  constructing and operating  the super sewer project.
12         The estimated $86 million for construction, the $320,000
13         annual  operating costs and significant energy demands
H         can all  be saved.
15                    In conclusion, the Sunnyvale Chamber of
16      •   Commerce urges alternative two of the Draft Environmental
17         Impact  Report and Statement, Treated Wastewater Disposal
18         Program dated September 1978 be adopted and that no
19         further action be taken at this time.
20                    And we do have copies for you.
21                    MR. WALKERr  Thank you,  Mrs. Brendler.  We
22         Would appreciate  it  if you could give a copy to the
23         reporter.
24                    MR. JAMES:  Mr. Walker,  1 neglected  to  leave a
25         copy.  I would like  to  supply  the  Sunnyvale Chamber
2^        with copies  of my remarks as well.
27                   MR. WALKER:  Thank you,  sir.
28           '         Also  for  the record  I would  like  to  add  that 1
                               l
                               2
                               3
                               4
                               5
                               6
                               7
                               8
                               9
                              10
                              11
                              12
                              13
                              14
                              15
                              16
                              17
                              18
                              19
                              20
                              21
                              22
                              23
                              24
                              25
                              26
                              27
                              28
	44
 still  contend that I am a young  person and in tune with
 all the modern ideas with the  subject of nomination of
 pronouns and whenever  ! use  a  pronoun in the masculine
 form it is clearly to  be understood to be intended to
 include both sexes, now known  as uni-sex.
            I have three more cards here of people who
 wish to speak.  There  may be others who will later on
 appear.  We announced  at the outset that we would take a
 recess for the purpose of having a question and answer
 period off the record.  Also,  the stenographer has been
 beating on that machine for  some time now and is entitled
 to a little respite, so we will  now take * little recess
 for twenty minutes, or until 9:00 o'clock,
            (Thereupon, a recess  was had.)
            MR; WALKER: The  time is now 9:00 p.m. and our
 recess  is over and we  can  go back to work.
            The next card  that I  have is Mr. Bert Martin.
            MR. MARTIN: Mr.  Chairman, members of the Board,
 my name is Bert Martin.   I  represent the Citizens Advisory
 Committee, City of  Santa  Clara.   A few months back we
 initiated a study  on  this  after we had done much the
 same thing four or  five years ago when the super sewer
 first  came up.  We were opposed to  it at  that time and our feelings
 haven't changed.   After  our last  study the  Committee  took
 a  stand in the  form  of a  letter which we had sent  to your
 Board,  and  1  have  a  copy  of it  here.   I  am  ready  to  pass
 it around or  can,  If  you  would  like  to have  one  now  or
 just put  it  in your  file.
iA
                                                          6 (Associates
                                          i 9"«ci fi
                                              CERTIFIED SHORTHAND REPORTERS
                                             586 NO. FIRS1 ST.. SAN JOSE. CA 9V 12
                                                TELEPHONE: (9«
                                                                            CERTIFIED SHORTHAND REPORTERS
                                                                            see NO. f IHST ST.. S*N JOSE, c* 9si 12
                                                                               TEIGPHONE: C«08) *9S-08W
46
-------
                                                         	45
 I                    We  feel  that the growth of ,our valley and  our
 2        district  overloads  the present plant that we have and we
 3        feel  that It would  serve our Interests better  if the
 4        water  fluid ^nd so  forth were returned to our  environment
 5        In  a  matter that didn't pollute the environment.  We
 6        don't  feel  that pumping partially cleansed water out  into
 7        the Bay is  the answer.  We feel that  that would be  a  waste
 8        of  money.  We feel  that this money can best  be spent  by
 9        upgrading our present plant so that it could handle our
10        needs  for years to come-, bearing in mind that  our valley
11        is  filling  up with people, industry and so forth.
12         .           This is our feeling.  If there are  any questions
13        I would be happy to answer them.
14                    MR. WALKER:  Any questions  from the panel?
15                    (Ho response.)
16                    MR. WALKER:  Thank you, sir.
17                    MR. MARTIN:  Thank you, Mr. Chairman.
18                    MR. WALKER:  Mr. Patrick Ferraro.
19                    MR. FERRARO:  Thank you, Mr. Walker,   Fellow
20        members and Councilmen of  the  South Bay Discharge.   I
21         have put before you a  letter  that  1 wrote  to Senator
22         Muskie and copies  to  our congressional  delegates  when 1
23        was in Washington  about a  month  or so ago.   At that time
24         t  was made aware that  EPA  had before  it  a  proposed
25         regulation change  which would eliminate  all  funding for
26         wastewater reclamation  projects  that  went  beyond  the needs
27         of, quote, effluent  discharge quantities.
28                    As  I have  outlined in that letter,  1 strongly
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
2i
22
23
 24
 25
 26
 27
 28
	        46_
 oppose the EPA grant legislation changes,  and  not knowing
 the prospects of successfully reversing  these  proposed  change
 even with the Congressional power  that  I  am  trying to bring
 to bear by EPA, I think it  is crucial  that we  approach  the
 situation of South Bay Dischargers  with  extreme  care and
 awareness that all the funding  for  wastewater  reclamation
 could be lost if it is implied  that the  receiving waters
 of the South Bay can now or in  the  future accept the
 discharge of the treated effluent  of the cities  of north
 and south Santa Clara County.
               I strongly agree  and  support the previous
 statements oade by the Canning  Association that  whether
 it be by mathematical models  or physical models, we can't
 absolutely predict the quality  of  the San Francisco Bay
 under future conditions, especially since we have the
 unknowns, including  the Delta outflow and whether or not
 the Peripheral canal will  be  constructed and when, whether
 or not  that will  benefit the  south San Francisco Bay.
               For this reason  I do support the continued
 monitoring with  an  increased  emphasis on the potential
 for eutrophication of  the  estuary  at its southern extremity.
 Obviously if  algal  blooms  should occur  in the future or
 become  prevalent, all  our  efforts  to assure the high
 dissolved oxygen  content  levels in the bay would probably
 just  fail because,  as  the  decaying biomass of the algal
 blooms  is consumed  by  the'organisms, they would consume
 the  oxygen  present  which  was  so dearly guarded  and
 assured by  the  constructing of millions of dollars of
                                                 (A.
                                                                                                                              tiE 9M-OB»
                                              CERTIFIED SHORTHAND REPORTERS
                                              SB6NO. f IRST ST. .SAN JOSE. CA 35112
                                                 TELEPHONE: l«e>»M»9»
                                                                                                                                                   47
-------
        treatment facilities to remove the oxygen level from
        the waste water.  This is algal bloon.  If It should occur
        by some later date it could in effect turn the Bay back
        to the subject of zero oxygen levels that we did have in the
        last decade before we constructed our advance waste
        treatment facilities.
                  Now, while the above position seems to be
        somewhat implied, If not stated in the environmental
        impact statement, there is still this continuous pride
        of people here today supporting the no project alternative
        and I realize many of them may not be aware of EPA's
        grant regulations.  But if the local monitoring is
        continued, I fail to see the reason why we have to reach
        a decision at this point In time and run the risk of
        forfeiting the construction grants which provide the
        only logical and feasible method oi financing plant and
        wastewater reclamation for this county.
                  Since considerable market studies are under way
        by Santa Clara Valley Mater District in cooperation with the
        California Department of Water Resources, which is funded
        primarily by EPA, that 1s  to the tune of about a five
        hundred thousand dollar study, in addition to that there
        1s a two million dollar study going on which is beyond
        Santa Clara County to serve the reclaimed water from
        the entire San Francisco basin, these two studies both
        have preliminary conclusions that as was stated before,
        the costs are competitive  with new water supplies.
                  The $328 million figure that the draft E1R/EIS
 J
 4
 5
 6
 7
 8
 9
10
li
12
13
14
15
16
17
H
19
20
JJ
n
2}
24
25
26
27
28
	_^____	18
 includes upsets me somewhat, because again,  it  makes
 an assumption, I don't know if it's verified, and  the
 verification in my mind is questionable  also  by the
 Bay models, of whether or not, if we reclaimed  the entire
 flow for re-use during the Irrigation season, whether or
 not we have outfall can affect the winter flows  to the   :
 north of the Dumbarton Bridge, which is  during  the
 winter, we do have a natural outflow from the streams
 and run off and automatically assume that you have to
 build a conservation facility on top tf the reclamation
 facility that would cost in excess of $328 million,
 which would seem to be a good way to just knock  it
 right out of the ballpark right away.
           But please don't lock in on that figure,
 because if we reclaim the water, I think we will cert-
 ainly find that no Bay outfall north of  the Dumbarton
 Bridge will ever be needed just to handle winter dis-:
 charge.
           So in view of the myriad of unknowns  regarding
 both the environmental and economic, as  well as  the
 Institutional problems we face in implementing   reclamation
 it seems that the residents of the Santa Clara  County,
 the water users and the water dischargers, would best be
 served if we did not reach a decision at this point  in
 time, and delay the decision on what our project should   .
 be until such time as we work out some of these  questions,
 especially whether or not the EPA is going to stay locked
 in and not fund anything which does not meet Affluent    th
                                                                                                                               iA
                                             CERTIFIED SHOBTHAND REPORTERS
                                             MB NO. FIRST ST.. SAN JOSE. CA 951U
                                                TELEPHONE: (««| SM-08M
                                             CERTIFIED SHORTHAND REPORTERS
                                             586 NO. FIRST ST.. SAN JOSE, C A 95112
                                                TELEPHONE. i«W-OK»
48
-------
    	,_ .	;	49
 1         discharge requirements.
 2                    The alternative  may  be that we run the risk of
 }         losing reclamation as  a  potential water service  for Santa
 4         Clara County.
 J                    I will draft  my  comments "P *"d have  them in
 6         the mail to you  tomorrow.
 7                    HR. WALKER:  Thank you, sir.
 8                    Are there any questions from the panel?
                                        •
 9                    (No response.)
10                    HR, WALKER:  I have a copy of a subsequent
11         letter addressed to  Senator Muskie and for the  purposes
12         of this  record we will nark tha.t as Exhibit 24.
13                                 (Thereupon,' a  four-page  letter
                                  dated April 4, 1979, addressed  to
•14                                 The Honorable  Edmund S.  Huske
                                  was marked Exhibit 24  for
15                    '             identification.)
16                   HR. WALKER:  Curtis B. Harrison.   Is  that,
17        H-a-r-r-i-s-o-n?
18                   HR.  HARRISON:  That is correct, Mr.  Walker.
19                   I  am  Curtis  Harrison.   I am a  Director  of  the
20        Cupertino  Sanitary District.  The District  is a tributory
21         agency  to  the San Jose/Santa Clara  treatment  plant.   The
22        District Board  has instructed me to advise you  and the
23        EPA  that they are in  favor  of  the  no  project  alternative.
24        i  think  if I  were to  come  up here  and say  I  favored  this
25        project, I would be drummed out  of  the valley by the
-6      -  sound of things  tonight.
27                    But all kidding  aside,  1  think  it  is very
28         important that the no project  alternative  be  pursued  as
                                                  
-------
                                                                                                                                                   52
 I        received,  they will  be  considered  as part of the.record
 2        and  final  action will be  taken  on  that.
 3                    The action that  will  be taken is a colleglal
 4        effort.  That means  that  many  people on  the staff will
 5        review  all  of the  transcript,  all  of the records, all of
 6        the  comments  that  have  been received and make recommendatio
 7        to the  Regional  Administrator  in a briefing document and
 8        then he  will  then  do as he  sees fit.
 9                    There-is  also  in this matter  a parallel local
10        action  of  the South  Bay Dischargers Authority.  They will
11        have authorities  in  this  subject and they are also
12        going to be required to take action on the subject.
13                    Mr. Atkinson,  do you have any comments to make
14        at this  time.
15                    MR. ATKINSON:   Yes,  1 would recommend that the
16        South Bay  Dischargers Authority continue the hearing on
17        their meeting of July,  which will  be the second Wednesday
18        in July, at Room 300,  at  4:00 o'clock, at San Jose City
19        Hall at North  First  and Mission Streets, at which time
20        further evidence can be considered and action thereon
21        taken,
22                    MR. WALKER:   Thank you, sir.
23                    MR. ATKINSON:   I would like to have a motion
24        by the Board to  that effect.
25                    MR. GISSLER:  Is there a motion-to  that effect?
26        Motion by  Mayor  Hayes,  seconded by Mr. Henderson.  All
27        those in favor  say aye.  All those opposed?  So  ordered.
28                    MR.  ATKINSON:  I'd further  like the  record  to
 l
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
indicate that South Bay  Dischargers  Authority, Mr.
Estruth, has absented himself     at  the end of the
recess after the 9:00 o'clock  continuance and has not
come back thus far.
           MR. GISSLER:   What  action of the Board do you
want?
           MR. ATKINSON:   I  just want the record to
indicate that.
           MR. HENDERSON:   Does  this indicate no meeting
at all?
           MR. ATKINSON:   No,  it does not indicate that.
I conferred with staff  and I was told that there was no
way that the matter could be gotten  together by the June
meeting and for  that  reason  the  first that we could
possibly take any  action would be at our July meeting,
in fact we may not be able to take action until August,
but this at least  preserves  our  action for us.
           MR. GISSLER:   All right.
           MR. WALKER:   A lot of questions were asked  to-
night  for which  we don't have answers.  He hope we will
have  some answers  by  then.
           MR. GISSLER:   That's  all  we have.
           MR. WALKER:   Thank you. As far as we are
concerned this EPA section of the hearing is concluded,
Mr. Mayor.
           MR. ATKINSON:  Just tD be careful here,  I
am sorry to keep interrupting, tut  I would also like --
well,  I  think what we've done is sufficient.  Nothing
                                                 (A 9"ttcfc £ Associates
                                              CERTIFIED SHORTHAND REPORTERS
                                             UeNO. FIRST ST..SAN JOSE. CA95I1Z
                                                TELEPHONE: (4M)Mg-oa»
                                              CERTIFIED SHORTHAND REPORTERS
                                             5B6KO. f IHST ST.. SAN JOSE, CA 95U2
                                                TECEPHONE: (406) 936-0899
50
-------
                              53
                                                                                                                                             54
1
2
5
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19

20
21
22
23
24
25
26
27
28
further.
HR. GISSLER: So the South Bay Dischargers
Authority will not hold a meeting, then, on June the 13,
the next meeting will be in July?
MR. ATKINSON: No, you can hold your regular
meeting then, that will go forward.
HR. GISSLERt So we should adjourn this
meeting of the South Bay Dischargers Authority to the 13th?
HR. ATKINSON: You could do that, that would
be 1n order.
Notion by Hr. Gunn and seconded by Mr.
Henderson. We are adjourned to June 13. Thank you.
	 oOo —





t










I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
IB
19

20
21
22
23
24
25
26
27
28
STATE OF CALIFORNIA )
COUNTY OF SANTA CLARA )



I HEREBY CERTIFY: That I was appointed to
act as Official Reporter in the within-entitled action.;
that 1 reported the same in machine shorthand and
thereafter caused the same to be transcribed into
typewriting under my direction and supervision as appears
• by the foregoing transcript; and that said transcript
is a full, true and correct statement of the proceedings
and evidence in said matter, to the best of «y ability.
IN WITNESS WHEREOF, I have hereunto set my
hand and affixed my seal of office this /fa — day of
}/%4^- » 1979.
/"~ J£-
ntf If ••***-.• /r^^A^-— .
1 v- ' ROTARY TUBLIC

In and for the County of Santa Clara,
State of California








                                                                                                                     iA "Sued 6
 CERTIFIED SHORTHAND REPORTERS
US NO. FIRST ST., SAN JOSE. CA SSII2
    TELEPHONE: |4M)998-0899
 CERTIF IEO SHORTHAND REPORTERS
586 NO. FIRST ST., SAN JOSE. CASSH2
     TELEPHONE: H08UM-089S
                                                                                                                                               51
-------
-------
                                            1.1  TESTIMONIES REQUIRING NO SPECIFIC RESPONSE
                                            Statements by Ms.  D. Wulfhorst, City of Sunnyvale and Mr. M.  Pearl con-
                                            sisted of resolutions of support for selection of the "No Further Action"
                                            alternative - the  alternative recommended by EPA and SBDA.  No  issues or
                                            questions regarding this or other alternatives were raised.

                                            Testimony by Ms. D. Wulfhorst
                                                       Councilmember, City of Sunnyvale
                                            The  resolution by  the City of. Sunnyvale, recommending No Further Action,
                                            has  been taken into consideration by EPA and SBDA in making the project
                                            selection.
                                 1.1
Testimony by Mr.  M. Pearl
The recommendation  for No  Further Action has been taken  into consideration
by EPA and SBDA in  making  a project selection.
TESTIMONIES   REQUIRING
  NO   SPECIFIC  RESPONSE
                                                                                                        53
-------
-------
                                                  1.2
TESTIMONIES  ADDRESSED   IN  OTHER
              SECTIONS  OF  THIS   REPORT
1.2  TESTIMONIES ADDRESSED TN OTHER SECTIONS OF THIS REPORT
Several individuals summarized, in their testimony, letters of comment
previously sent to EPA and SBDA.  These letters are addressed in Section
2 of this report, as stated below.

Testimony by:  Mr. S. Goodman
             Santa Clara County Sanitation District 4
Letters From  County Sanitation District 4, EPA No. (HE-149) 1  and (HE-149)
29, are addressed in Sections 2.2 and 2.3 of this report.

Testimony by;  Mr. L. F.  Cournoyer
             Santa Clara Valley Water District
A letter from  the Santa Clara Valley Water District, EPA No. (HE149)15,
is addressed in Section 2.2 of this report.

Testimony by:  Mr. J. Quintal
             Santa Clara County Canners Association
A letter from  the Santa Clara County Canners Association, EPA No. (HE-149)
11, is addressed in Section 2.2. of this report.

Testimony by:  Mr. B. E.  Schoppe
             Santa Clara Chamber of Commerce
A letter from  the Santa Clara Chamber of Commerce, EPA No.  (HE-149H8, is
included in Section 2.1 of this report.

Testimony by:  Mrs. M. Brendler
             Sunnyvale Chamber of Commerce
A letter from  the Sunnyvale Chamber of Commerce, EPA No. (HE-149)30, is
addressed in Section 2.3 of this report.

Testimony by:  Mr. B. Martin
             Citizens Advisory Committee
             City of Santa Clara
A letter from  the Citizens Advisory Committee, EPA No. (HE-149)2, is
addressed in Section 2.2 of this report.

                                                                                                                              55
-------
Testimony by Mr. P. Ferraro

A letter from Mr. Ferraro, EPA No. (HE-149)22, is addressed in Section

2,2 of this report.


Testimony by:  Mr. C. Harrison
               Director, Cupertino Sanitary District

A letter from the Cupertino Sanitary District, EPA No. (HE-149)19, is

included in Section 2.1 of this report.
56
-------
                                                1.3  TESTIMONIES  REQUIRING RESPONSE

                                                Two individuals,  Messrs. R. Diridon and R. R. James, gave testimony which
                                                raised issues not specifically addressed in Section  2 of this report.
                                                These issues have been considered  in making Che project selection.


                                                Testimony by: Mr. R. Diridon
                                                             Supervisor,  County  of Santa Clara

                                                A letter from the County of Santa  Clara, Board of  Supervisor, EPA No.
                                                (HE-149)26,  is included in  Section 2.1 of this report.
                                               Transcript  page 28, lines B-25^

                                                   Funds planned for this SBDA project may only  be used for an,
                                                   alternative of the project.  However, the San Francisco
                                                   Regional  Reclamation/Reuse  Study may result  in a large-scale
                                                   reclamation project for the area, independently of the SBDA
                                                   EIR/EIS.
TESTIMONIES  REQUIRING
        SPECIFIC  RESPONSE
Transcript pages 29,  lines  15-28.

    Bus  washing and some  agricultural  irrigation is tht subject
    of a project now in  the facilities planning stage.   Several
    local, small-scale reclamation projects are under study
    throughout the SBDA  service area.
                                               Testimony  by:  Mr. R. R.  James
                                                             Chief Executive Officer, San  Jose Chamber of Commerce

                                               The recommendation of No  Further Action, as  supported by the San Jose

                                               Chamber of Commerce, has  been considered by  EPA and SBDA in making ,1 pro-
                                               ject selection.

                                               Transcript page 34, lines  9-25.

                                                   Changing the Enclosed  Bays and Estuaries  Policy or the Basin
                                                   Plan  to alter the prohibition against  the discharge south of
                                                   Dumbarton Bridge is in the purview of  thu State Water Resources
                                                   Control Board (SURCB)  and the Regional  Water Quality Control
                                                   Board (RWQCB), respect Ively.  These agencies will have to
                                                   determine conditions for such changes;  the data in the Draft
                                                   EIR/EIS ma_v_, in part,  provide information necessary to these
                                                   Boards to make their decisions.   However, the Draft EIR/EIS is
                                                   not intended to result in such a change.
                                                                                                                57
-------
    It should be noted that each alternative, discussed as viable
    in the Draft EIR/EIS, was compatible to some extent with
    large-scale reclamation (the Basin Plan Alternative and
    Individual Deepwater Outfalls provide a collection system
    which can be revised to supply the south valley area with
    water; Upgraded Treatment, in effect, treats effluent to the
    same high degree which might be required for highest use of
    reclaimed water).
Transcript pages 34-35, lines 26-28,  1-10.

    A discussion of the potential economic  impact of the disposal
    system on the canning industry is presented in Chapter II I. 1.3
    (Technical Volume, Draft EIR/EIS),  Advanced waste treatment
    (AWT) is not the subject of this  draft  and mitigation of the
    negative impact of rates due to implementing AWT is beyond the
    scope of this study.
58
-------
              Sectiot? 2
    RESPONSES TO WRITTEN COMMENT
RECEIVED DURING THE REVIEW PERIOD
             ENDING 6 JUNE 1979

-------
-------
                                             Twenty-eight letters of comment  were  received by  SBDA and ICl'A during the
                                             review and comment  period.  These  letters are reproduced on the  following
                                             pages along with specific responses to each point or issue raised or ques-
                                             tion asked.  SBDA and -EPA appreciate  the interest taken by the public^
                                             and agencies in the SBDA treated wastewuter disposal EIR/F.FS.
                                2.1
      LETTERS  REQUIRING
NO  SPECIFIC  RESPONSE
2.1   LETTERS REQUIRING  NO SPECIFIC RESPONSE
The  following submittals consisted of  resolutions or  letters supporting
the  "No  Further Action" alternative  -  the alternative  recommended  by
SBDA and EPA - or letters raising no specific issues  regarding this or
other alternatives.   SBDA and EPA thank  the reviewers  for their interest
and  acknowledge the  stated preferences.  These letters have been con-
sidered  in making the project selection.
    •   Office of the Governor, Office of Planning and Research,
        State Clearinghouse - 7 April  1979 - EPA No.  (HE-149) 3
    •   City of Saratoga - 8 May 1979  -  EPA No.  (HE-149) 4
    •   Town of Los  Gatos, - 8 May 1979  - EPA No. (HE-149) 5
    •   City of Milpitas, Milpitas Sanitary District  Board of
        Directors -  14  May 1979 - EPA  No. (HE-149) 7
    •   City of Campbell - 15 May 1979 - EPA No. (HE-149) 10
  -<  »   Paul N. McCloskey, Jr., U.S. Oppress - 16 M;w 1979 -
        EPA No. (HE-149) 14
    *   U.S. Department of Transportation, Federal Highway
        Administration, Region Nine  -'16 May 1979 - EPA No.  (HE-149H6
    •   Santa Clara  Chamber of Commerce  - 18 May 1.979 - EPA No.
        (HE-149) 18
    •   Cupertino Sanitary District  -  21 May 1979 - EPA No.  (HE-
        149) 19
    •   Norman Y.  Mineta, U.S. Congress  - f> June 1979 - EPA No.
        (HE-149) 25
    •   County of Santa Clara, Board of  Supervisors - 11 June
        1979 - EPA No.  (HE-149) 26
                                                                                                             61
-------
 OFFICE OF THE GOVERNOR
 OFFICE OF PLANNING AND RESEARCH
 STATE CLEARINGHOUSE
 1*00 - 10TH STRFET
 SACRAKENTOt CA 91814
 U.S. ENVlRONrjMTAL PROTECTION AGENCY
 215 FREMONT ST
 SAN FRJNCISCO    CA <>4105
 ATTENTION: PAUL DEFALCD
   RECEtVEO
F '•' 4 fi«r<3ION ix
                                                                                                  13777 FRUITVALE AVENUE . SARATOGA. CALIFORNIA 8SO7O
                                                                                                  (408)867-3438
                                    May 8,  1979
                             ACKNOWLEDGEMENT                  0*/07/79
                                                          REPORT TMD4SA
                  PROJECT NOTIFICATION AMD REVIEW SYSTEM
                                 OF THE GOVERNOR
                               (9161 445-0613
-PROJECT: S.UTH =IAY DISCHARGE AUTHORITY


 STATE CLEARINGHOUSE NU^B£R  
-------
                    RESOLUTION 110.  900
           A RESOLUTION OF THE CITY OF SARATOGA URGING
           IMPLEMENTATION OF THE "NO ACTION BEYOND
           CURRENTLY APPROVED IMPROVEMENTS AT TREAT-
           MENT PLANTS" ALTERNATIVE AS SET FORTH IN THE
           DRAFT  ENVIRONMENTAL IMPACT REPORT AND STATE-
           MENT FOR THE TREATED UASTEWATER DISPOSAL
           PROGRAM OF  THE SOUTH BAY DISCHARGERS AUTHORITY
     WHEREAS, County  Sanitation District No,  4 of Santa Clara
County, California, provides for the collection, treatment and
disposal of  the wastewater emanating from the City of Saratoga;
and
     WHEREAS, the District has reviewed the DRAFT ENVIRONMENTAL
REPORT AND STATEMENT, SOUTH SAY DISCHARGERS AUTHORITY TREATED
WASTEHATER DISPOSAL PROGRAM, commented thereon and requested
Implementation of the no action alternative set forth in the
said DRAFT REPORT.                         .    •
     NOW, THEREFORE,  BE  IT RESOLVED that the City of Saratoga "
does hereby  concur in the comments and request of the said
District and does similarly request that the Environmental
Protection Agency and the South Bay Dischargers Authority
undertake the appropriate measures to implement the no action
alternative  set forth in the DRAFT ENVIRONMENTAL REPORT AND
STATEMENT.
     Passed  and adopted  at a regular meeting of the City Council
of the City  of Saratoga  held on the  2nd day of May      1979,
by the following  vote:
                                                                                                                                                  •U.S.E.P.A.
                                                                                                                                                   REGION 2
                                                                                                                                                  COMM CMS
                                                                                                                                             HIT II
                                                                                                           TOWN of LOS GATOS
                                                                                                            Department of Public Works
                                                                                                                   354-680
                                                                                     May B, 1979
                                                                                     U. S. Environmental Protection Agency
                                                                                     215 Fremont Street
                                                                                     San Francisco, California 94105
                                                                                     Gentlemen:
                                                                                                            South Bay Dischargers Authority
                                                                                                            CopBBon Conveyance  Facility	
                                                                                     Attached is a copy of Town Council Resolution  No.1979-69 which was
                                                                                     adopted May 7, 1979.  Please consider these  recommendations at your
                                                                                     hearing May 16, 1979 concerning the Combined Draft Environmental
                                                                                     Impact Statement-Environmental Impact Report for the South Bay
                                                                                     Dischargers Authority Facility.
                                                                                     Very truly yours.
                                                                                     R. L. WARNICK
                                                                                     Director of Public Works
                                                                                     RLW/Jh
                                                                                     Enc.
AYES:     Councilmen Kalb,  !latt«oni,  Kraus & Corr
NOES:     None
ABSENT:   Councllwoman Callon
ATTEST:
 /•/ Robert F. BflyV
                                     MAYOR
                                      THIS IS TO CERTIFY THAT THE WITHIN IN-
                                      STRUMENT IS A TRU^ANO CORRECT COPY
                                      OF THE OWCINAJ--<»/4/FILE Itj- THIS OFFICE.
   CITY CLERK
                                                                                 CIVIC CENTER  •  110 EAST MAIN STREET •  P.O. BOX 949 •  LOS CATOS, CALIFORNIA 95030
                                                                                                                                                                63

-------
                           RESOLUTION NO.  1979-69

                  A  RESOLUTION OF THE TOWN OF LOS GATOS URGING
                  IMPLEMENTATION OF THE "NO ACTION BEYOND CURRENTLY
                  APPROVED IMPROVEMENTS AT TREATMENT PLANTS"
                  ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL
                  IMPACT REPORT AND STATEMENT FOR THE TREATED
                  WASTEHATER DISPOSAL PROGRAM OF THE SOUTH BAY
                  DISCHARGERS AUTHORITY
        WHEREAS,  County Sanitation District No. 4 of Santa Clara County,

   California,  provides for the collection, treatment and  disposal of the

   wastewater emanating from the Town of Los Gates;  and

        WHEREAS,  the  District has reviewed the DRAFT ENVIRONMENTAL REPORT AND

   STATEMENT, SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM,

   commented thereon  and requested implementation of the no action alternative

   set forth in the said DRAFT REPORT.

        NOW, THEREFORE, BE IT RESOLVED that the Town of Los Gates does hereby

   concur in the  comments and request of the said District and does similarly

   request that the Environmental Protection Agency  and the South Bay Dischargers

   Authority undertake the appropriate measures to implement the no action

   alternative  set  forth in the DRAFT ENVIRONMENTAL REPORT AND STATEMENT.

        PASSED  AND  ADOPTED by the Town Council of the Town of Los Gatos this  7tii

   day of    May  	, 1979, by the following vote:
        AYES:
                  COUNCIL MEMBERS  Ruth Cannon, Mardi Gualtieri, Peter II.  Siemens and
                                  Thomas J.  Ferrito
        NOES:     COUNCIL MEMBERS  None
        ABSTAIN:  COUNCIL MEMBERS  Hone
        ABSENT:
                 COUNCIL MEMBERS  Jom axLoefmer


                     SIGNED:
   ATTEST:
   CLERK 'OF THE TOWN OF
                        (Ettti of
                             *
                                                                                                                              tlptfas c;iO'» ix
                                                                                                                                '
                                             .-MM.
                           455 E. Calaveras Blvd.
                         Milpitas, California 95«Q5 1 5  :
                             (408) 262-2310 ™ U
                             May  14, 1979
Environmental Protection Agency
Region 9
215  Fremont Street
San  Francisco, California 94105

ATTN:  Hearing Officer

SUBJECT:  South Bay Dischargers Authority Treated
           Wastewater Disposal Program EIR/EIS

Gentlemen:

Enclosed please find a resolution of the Milpitas Sanitary
District Board of  Directors supporting the  "No Action*
alternative outlined in the draft EIR/EIS for  the subject
project.

Very truly yours.
Wesley D.  Smith
Director of Planning and Engineering
cc: Board of Directors,
      Milpitas Sanitary District
    South Bay Dischargers Authority
                                                                                        WDS/PHC/law
                       L6S-G,
                           GATOS
                                                                                                                 An Eqml Opportunity Employ*
64
-------
                     RESOLUTION  NO.  499
 A RESOLUTION URGING IMPLEMENTATION OF THE "MO ACTION CEYQND

     CURRENTLY APPROVED IMPROVEMENTS AT TREATMENT  PLANTS"

 ALTERNATIVE AS SET FORTH  IN  THE DRAFT ENVIRONMENTAL IMPACT

  REPORT  AND STATEMENT FOR THE  TREATED WASTEWATER  DISPOSAL

       PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY
                                                CITY  (IF  CAMPBELL
                                                75   NORTH   CENTRAL   AVENUE
                                                CAMPBELL,    CALIFORNIA   95008
                                                1409]  378-8141
                                                         Deparumnt:  CHy Clerk
                                                                                                                                              : -.-  " 
-------
                                                                 (HE-144}  10
                          RESOLUTION MO.  5590

           A RESOLUTION OF THE CITY COUNCIL Of THE CITY OF CAMPBELL
           URGING IMPLEMENTATION OF THE "NO ACTION BEYOND CURRENTLY
           APPROVED IMPROVEMENTS AT TREATMENT PLANTS" ALTERNATIVE
           AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT REPORT
           AND STATEMENT FOR THE TREATED WASTEHATER DISPOSAL
           PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY
           WHEREAS, County Sanitation District No.  4 of Santa Clara County,
  California, provides for the  collection, treatment and disposal of
  the wastewater emanating from the City of Campbell; and

           WHEREAS, the District has reviewed the DRAFT ENVIRONMENTAL
  REPORT AND STATEMENT, SOUTH BAY DISCHARGERS AUTHORITY TREATED WASTEWATER
  DISPOSAL PROGRAM, commented thereon and requested implementation of the
  no action alternative set forth in the said DRAFT REPORT.

           NOW. THEREFORE, BE IT RESOLVED by the City Council of the
  City of Campbell that the City of Campbell does hereby concur In the
  comments and request of  the said District and does similarly request
  that the Environmental Protection Agency and the South Bay Dischargers
  Authority undertake the  appropriate measures to Implement the no action
  alternative set forth in the  DRAFT ENVIRONMENTAL REPORT AND STATEMENT.

           PASSED AND ADOPTED this 14th day of May. 1979, by the
  following roll call vote:

           AYES:    counciimen: Doetsch, Manner, Chamberlln, Podgorsefc, Paul
           NOES:    Counciimen: None

           ABSENT:  Counciimen: None
                         taaifitnpton. 39.C.  20515

                                       Kay 16. 1979
                                                                                                                                                                       14
South Boy Dischargers Authority
610 Mm Street
San JuSe. California  95110

Dear Sirs:

      I Support the recotnnefldation made in the Environmental Impact Report/
Statement prepared by the fnvironmental Protection Agency and the South
tony Dischargers Authority, wfth technical assistance fnn> Beehtel inc.,
that no further action on the proposed deep water pipeline Is necessary
at  this time.

      The cost  of the pipeline,  both in terns of construction and Subsequent
Increased energy demand for operation. 1s prohibitive and 1 am satisfied
that protection of the South Bay environment, in  particular the fresh
water marsh, 1$ best served by  upgraded treatment of wastewater and con-
tinued monitoring of Bay water  quality.

      tt Is my  hope thftt the Hater quality Control  Board will aflrcc to
take no further action on the proposed pipeline.
                                      Sincerely,
                                                                                                                                   Paul N. KcCloskey.  r.
                                        APPROVED:
                                        Norman Paul, Mayor
  ATTEST:
                                              THE FOIEIOIIM INITHUMENT n >nw
                                              AND CORRECT COPY OF THE OHOINAl
                                              ON FILE IN TH'8 OFFICE.
  Phyllis 0. Acker, City Clerk
66
-------
US. DEPARTMENT OF TRANSPORTATION j;
   FEDERAL HIGHWAY ADMINISTRATION  ~
          UGIONNINE
  Two Eabarcadeio  Center, Suite 510
  San Francisco,  California 941ll
                                                 ,v
16, 1979
                                                     HED-09
                                                                                    SANTA   CLARA
                                                                                    CHAMBER OF COMMERCE
                                                                                    151S EL CAMINO HEAL • SANTA CLARA • CALIFORNIA
                                                                                         408/296-6863 •  P.O. BOX 387 • 95052
                                                                        U S.E ."•*•
                                                                        MSIOH?
                                                                        C0MH CHI F.
                                                                     K«ZI
Mi. Paul De Falco, Jr.
Regional Administrator, Region IX
Environmental Protection Agency
215 Fremont Street
San Francisco, California 94105

Dear Mr. De Falco:

We have reviewed the Draft environmental Impact Statement for the
South Bay Dischargers Authority Treated Hastevater Disposal Program
in Santa Clara aod San Mateo Counties, California, and have no
specific comments to offer.

We appreciate this opportunity to review the subject Draft Statement.

                           Sincerely yours.
                                                May  18,  1979
                           Regional Administrator
                  U.S. Environmental Protection  Agency
                  Region  IX
                  215 Fremont Street
                  San Francisco,  California 94105

                  Attn:   Hearing  Office (HE-lXl)

                  Gentlemen:

                       Attached are three copies of the statement of the
                  Santa Clara Chamber  of  Commerce presented at the public
                  Hearing on  the  EIR/EIS  for the Treated Wastewater Disposal
                  Program, held May 16, 1979 in  the Santa Clara City Council
                  Chambers.

                                                 Sincerely,
                                                                                                        Bruce E. Schoppe, Vice President
                                                                                                        Legislative Action Division
                                                                          BS:nb

                                                                          Enclosure
                                                                                                                                              67
-------
                                                                    18
             SANTA   CLARA
             CHAMBER OF COMMERCE
             1515 EL CAMINO REAL  • SANTA ClARA  • CALIFORNIA
                  400/296-6663 • P.O. BOX M7 • WOS2
OlITRICT MANADEft-ENBIMCCfl

  MARK THOMAB ft CO. IHB.
  JOHN t PLtMIND
  SEOOftS BTCVCMI CHECK Btve.
  <4C»} 3SS-7D7I

 tVTKlCT CDUM«tL
  PHILIP D. ASBAF
  A3D N. 0LKN MATCH CHtiv
  P. o. Box isa
  BAM MAW, c*. V44D1
  (415) "
 CUPERTINO  SANITARY DISTRICT
         BANTA CLARA COUNTY


CUPERTINO SANITARY DISTRICT
  OF SANTA CLARA COUNTY
OFFICE OF THE DISTRICT
       AMD ENGINE en
     fOOtS ITtvCNB CftCCK *LVH.
          • UlTC 1£K
    CUKRTINO. CAI-»rO*WiA VSOt-
•OAttD Or Dl*f CTQIM
  MAURICE r. ukamc. p*
  CURTlV •, MANNIflDN, •
  EDWARD O. HAHAM1AN
  DR. AS. F. «*OWN
  HOT M. KUVHTDN
                                                                                                                      May  21, 19J9
                                                                                                                      File:  CuSEi - MOP
                                                                                                                      Oouth Bay Dischargers.
                                                                                                                            Authority
   I  an Bruce E. Schoppe representing the Santa Clara Chamber
   of Commerce.

   We are opposed to the construction of the so called "super
   sewer* and support the position of the EPA and South Bay
   Dischargers Authority favoring the "no further action" al-
   ternative. '      .                              ':.   '

   Measured  against the goals of this entire program—that is,
   the improvement of water quality in the south Bay, it is
   clear that construction of this pipeline is unnecessary.  The
   advanced  wastewater treatment capability now or soon to be' in
   operation at-the municipal treatment plants involved will,
   for all pratical purposes, achieve that goal.

   He view this  as a situation in which the real benefits must
   be measured against the real costs.  Mathematical modeling
   has shown that, given these advanced treatment plants, very
   little difference in south Bay water quality results with
   the project vs. no project.  In fact, there may well be a
   net negative  result due to the removal of these fresh water
   flows from Artesian Slough and the other treatment plant
   outfalls.

   The Chamber of Commerce is an organization of business people.
   He recognize  that, if constructed, we'll pay the cost of this
   project through our businesses as well as our homes and those
   of our employees.  Quite honestly, we don't need something
   else adding to our costs in this inflationary era—especially
   when, in  our  view, it has been clearly shown there is no need.

   Adoption  of the "No further action* plan makes a great deal
   of sense  to us—environmentally and economically.
         Environmental Protection Agency
         Region IX
         215 Fremont Street
         San Francisco, Ca. 94105

         Attens  Hearing Office (HE-149)
                                       Re:
         Gentlemen:
                                            South Bay Dischargers
                                            Authority Conveyance
                                                   Facility
         On May 16, 1979, the Cupertino Sanitary District Board'
         of Directors adopted the enclosed Resolution No. 657,
         after reviewing the various alternative plans for  the
         South Bay.  please keep us informed of future activities
         on this project.

                                       Very truly yours,

                                       MARK THOMAS &  CO. INC.
                                       District Manager-Engineer
         JEFsdh
         cc:  South Bay Dischargers Authority
         cc:  City of Cupertino
         cc:  Cupertino Chamber of Commerce
         Enc. Resolution No. 657
                                         tin E.  Fleming
68
-------
                              RESOLUTION NO. 657
         A RESOLUTION URGING IMPLEMENTATION OF THE "NO ACTION BEYOND
             CURRENTLY APPROVED IMPROVEMENTS AT TREATMENT PLANTS"
         ALTERNATIVE AS SET FORTH IN THE DRAFT ENVIRONMENTAL IMPACT
          REPORT AND STATEMENT FOR THE TREATED WASTEWATER DISPOSAL
               PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY

                         CUPERTINO SANITARY DISTRICT
     WHEREAS, Cupertino Sanitary District, Santa Clara County, California,

has reviewed the DRAFT ENVIRONMENTAL REPORT AND STATEMENT FOR THE TREATED

WASTEWATER DISPOSAL PROGRAM OF THE SOUTH BAY DISCHARGERS AUTHORITY; and

     WHEREAS said DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT, dev-

elops a strong case for adoption of no further action, beyond currently

approved improvements at treatment plants, as an alternative to the Basin

Plan.

     NO?*, THEREFORE, BE IT RESOLVED that the Sanitary Board of the Cuper-

tino Sanitary District does hereby request that the Environmental Protec-

tion Agency and the South Bay Dischargers Authority undertake the appro-

priate measures to implement the no action alternative set forth in said

DRAFT ENVIRONMENTAL REPORT AND STATEMENT.
     I hereby certify that the  foregoing  is a,full, true  and  correct copy
of a resolution which was duly  and regularly passed and adopted by the
Sanitary Board of the Cupertino Sanitary  District, at  a meeting thereof
held on the 16th day of May, 1979, by the following vote  of. the members
thereof:

     AYES, and in favor thereof, Members:  Brown, Harrison, Bahamian,
                                           LaBrie, Rushton
     NOES,    Members:. None
     ABSENT,  Members:  None
                                                                                    HAIL6RAM  SERVICE CENTER
                       ics  IPMSNCZ CSP tree
 40S9ft«69«» *6*  TORN SAN JOSE C» 109 0»-0* 05«ZP EST ' !!  /
                                                                                                                                               ui ^ ']
-------
      County of Santa Clara
   Offim « «w loM oi lupnvtten
County aov*mnrant Cen»r. Ewt Wing
        79 wesi MMtJina Streel
       S«n JOM. CllifontU (9110
       2M-U2I ATMCOM40B
                                                                                                                                                           26
      California
       SuMnn* Wilson, District t
     Dominic L. Conm. txurla 1
     Dirt Me Corquodlta. D/«rf« J
         RoaOHWm. OutricU
   OmMlrw f. SttMMia,, Offtncf 5
                                             June 11. 1979
              South Bay Dischargers Authority
              c/o Environmental Protection Agency
              215 Fremont Street
              San Francisco, California 94105
              Subject:  Resolution Re  No Action Alternative for South
                        Bay Dischargers Authority Treated Waetewatei
                        Disposal  Program       •        .
              Gentlepersons :
              The Board of Supervisors, County of Santa Clara, at
              its meeting of Hay  15, 1979 adopted a Resolution urging
              implementation of the  "No Action Beyond Currently Approved
              Improvements at Treatment Plants.'  The Board authorized
              Supervisor oiridon  to testify on its behalf at a public
              hearing on' this matter.
              Enclosed please find a conformed copy of the captioned
              Resolution.
                                             Sincerely,
                                             BOARD OF SUPERVISORS
                                             Donald H. Rains, Clerk
                                             By «
                                                  Deputy clerk
              vas
              Enclosure
              CC: County sanitation  District Ho.  4
                                 An Eqinl Opportunity Emptom'
          RESOLUTION RE NO ACTION "ALTERNATIVE FOR SOUTH BAY
      DISCHARGERS AUTHORITY  TREATED WASTEWATER DISPOSAL PROGRAM
     WHEREAS, the Draft Environmental Impact Report and Statement
for the Treated Hastewater Disposal Program of the South Bay
Dischargers Authority has developed a strong case for adoption of
a no further action, beyond  currently approved improvements at
treatment plants, as an alternative to the Basin Plan; and
     WHEREAS; County Sanitation.District No. 4 has requested that
the Environmental Protection Agency and the South Bay Dischargers
Authority take whatever steps  necessary to. implement the no action
alternative set forth in the Draft  Environmental Impact Report and
Statement;
     NOW, THEREFORE, BE IT, RESOLVED by the Board of Supervisors of
the County of Santa Clara, State of California, that it hereby
requests that the Environmental  Protection Agency and the South
Bay Dischargers Authority undertake appropriate measures necessary
to implement the no action alternative as set forth in the Draft
Environmental Impact Report  and  Statement for the South Bay
Dischargers Authority Treated  Nastewater Disposal Program.
     PASSED AND ADOPTED by the Board of Supervisors of the County
of Santa Clara, State of California, on      HAT 1 5 W9	j
by the following vote:
AYES:    Supervisors  CORTESE. MeCORQUODALE, «TBIMOC««. DIRIDON. WILSON
NOES:    Supervisors  Vi/MT
ABSENT:  Supervisors  PTBNBEK!
                                                                                                                              Dominic  L.  Cortese
                                                                                                                      Chairperson,  Board  of Supervisors
                                                                                      ATTEST:
                                                                                      SB: no
                                      DONALD M.  RAINS, Clerk
                                       Board of Supervisors
                                                                                                         Supe
70
-------
                       2.2
LETTERS  REQUIRING
SPECIFIC  RESPONSE
2.2  LETTERS REQUIRING SPRCIFIC RESPONSE

The following submittals consisted  of letters which  raised issues or ques-
tions about selected  alternatives,  mitigating measures and/or conclusions
drawn in  the Draft EIR/EIS. . Each letter is reproduced in the order
received, and each is followed by a point by point  response to the com-
ments.  Where more than one letter  raises similar issues, the most com-
plete response is provided to the first letter received and each response
to succeeding letters is referenced to that first letter.  Each letter has
been considered in making the project selection.

    •  County Sanitation District  No. 4, Santa Clara County -
       30 April 1979 - EPA No.- (HE-149) 1

    •  Santa Clara Citizens Advisory Committee - undated -
       EPA NO. (HE-149) 2

    •  U.S. Department of Commerce - undated - EPA No. (HE-149) 6

    •  Drs. Howard S, Shellhammer and H. Thomas Harvey,-San
       Jose State University - 14 May 1979 - EPA No. (HE-149) 8

    •  Dr. L. Richard Mewaldt, San Jose State University -
       14 May 1979.,- EPA No.  (HE-149) 9

    •  Santa Clara County Canners Association - 15  May 1979 -
       EPA No. (HE-149) 11

    •  U.S. Department of Agriculture - 8 May 1979 - EPA No.
        (HE-149) 12

    •  San Jose/Santa Clara Water Pollution Control Plant -
       16 May 1979 - EPA No.  (HE-149) 13

    •  Santa Clara Valley Water District - 17 May  1979 - EPA No.
        (HE-149) 15

    •  Department of Fish and Came - 17 May 1979 - EPA No.
        (HE-149) 17a

    •  State Water Resources Control Board - 14 May 1979 - EPA
       No. ' (HE-149) 17b

    •  D. E. Myers,  Loma Prieta Chapter, Sierra Club -
       23 May 1979 - EPA No.  (HE-149) 20

    •  U.S. Department of  Interior, Pacific Southwest Region -
       22 May 1979 - EPA No.  (HE-149) 21
                                                                                                       71
-------
    Patrick Forraro,  District 2,  Santa Clara Valley Water
    District - 22 May 1979 - EPA  No.  (HE-149) 22

    Regional Water Quality Control Board - 30 May 1979 - EPA
    No.  (HE-U9) 23

    ABAC - 1 June 1979 - EPA No.  (HE-149) 24

    Advisory Council  on Historic  Preservation - 8 June 1979 -
    EPA  No. (HE-149)  27
72
-------
COUNTY SANITATION  DISTRICT NO. 4
OF SANTA CLARA COUNTY
100 East Sunnyoaks Avenue
Campbell. California 95008
Jtltpnone 376 ?40'
         April 30, 1979
:••:•">  5V .S.W.A
 ?•'! -3 i (WHS «ESID£NTS OF
.-.•,< ^rfWjtftf CAMPBELL
   " •"^TOA.TOF IOSOATOS
     CITY OF MONTE SERENO
       .  e);v».) . I
                           Attest:
               Directors

               Directors

               Directors
                                                      HAYES, CODY. KRAUS, PAUL
                                                                                Secretary o-f  the  Board
                                                       T.  ,    .Chairperson of the Board
                                                       The foregoing instrument is a
                                                    -  correct copy of the original
                                                          on file in this office
                                                     COBNTf saHIWlO* BISTBICI10.«
                                                     iltm. Q^i'cL* Q-W^f .
                                                                SxrtfuT

                                                                                                                                                     73
-------
                                                                             Connents of County  Sanitation district tic. 4
                                                                             Page 2
  ®
  ®
  ®
      COMMENTS OF COUNTY SANITATION DISTRICT NO.  4 OF SANTA
      CLARA COUNTY, CALIFORNIA, CONCERNING THE DRAFT ENVIRON-
      MENTAL  IMPACT REPORT AND STATEMENT, SOUTH BAY DISCHARGERS
      TREATED WASTEHATER DISPOSAL PROGRAM


The  following comments of the County Sanitation' District No. 4 of
Santa Clara  County, California, concerning the DRAFT ENVIRONMENTAL
IMPACT  REPORT AND STATEMENT, SOUTH BAY DISCHARGERS TREATED HASTE-
HATER DISPOSAL PROGRAM are being submitted to the Environmental
Protection Agency pursuant to the Agency's notice of a joint public
bearing on Hay 16, 1979.
 i
Statement (EIS/EIR TECHNICAL Page 147);  'The transport project
without currently approved treatment improvements would improve
water quality in the South Bay, with a corresponding decrease in
water quality near the point of discharge north of the Dumbarton
Bridge  (BASSA, 1975).  Since upgraded treatment would accompany
the  transport system, however, a severe decrease in water quality
at the  discharge point would not occur (Appendix C).

The  most drastic alteration in water quality would occur in those
sloughs in  the South Bay now receiving point source discharges."

Comment:  There appears to be no assurance that there will be a
significant  increase in the South Bay water quality as a result
of constructing the transport project in addition to the upgraded
treatment.

Statement (EIS/EIR TECHNICAL Page 147):  "However,  except for the
lower two or three miles of the Bay, the Basin Plan Alternative is
not  significantly different from a no further action alternative
(see also Section IV.2.9), in that DO standards will not be met in
all  extremities of the Bay.

In the  lower two or three miles of the Bay, DO concentrations would.
be expected  to deteriorate somewhat in the headwaters of Artesian
Slough, due  to lack of flushing (how allowed by wastewater flows)
and  a resultant expression of background oxygen demand in the
sloughs."

Comment;  Construction and operation' of the Basin Plan Alternative,
at a considerable expense, dollars and energy, will not signifi-
cantly  improve theDO concentration of waters of the South Bay
above that provided by the no further action alternative and may
cause deterioration of the DO concentrations in the headwaters of
major South Bay sloughs.

Statement (EIR/EIS TECHNICAL Page148);  "The South Bay would lose
a significant portion of its annual freshwater input when the
treated wastewater is diverted northward.   The diversion would
result  in salinity increases in the South Bay, especially in the
southern reaches."
                                                                          ®
                                                                          ®
                                                                          ®
                                                                          ®
Comment:  The overall quality  of  the water in the South Bay may
be better as a result of discharging treated wastewater simulating
natural freshwater "discharges  into the major sloughs as compared
with their diversion out of  the South Bay.

Statement (EIR/EIS TECHNICAL Page 118): "The toxicity levels in
the South Bay would decrease  with the removal of waste loads.
Hydroscience  (Appendix C) calculate the difference in toxicity
with a no further action  alternative and implementation of the
Basin Plan Alternative to be  as  much as an order of magnitude  (ten
times the relative toxicity  for  no further action as for the Basin
Plan Alternative) in  the  South Bay."

Comment-.  The magnitude of toxicity resulting from adoption of the
no further action alternative could be reduced by improvement  of
the South Bay dischargers toxicity source control programs.

Statement (EIR/EIS TECHNICAL,  Page 154):  "The presence of the
diffuser in  the deep water  north of Dumbarton Bridge will result
in the presence of a mixing zone with salinities ranging from
nearly fresh water to  saltwater concentrations.   While the mixing
zone will not significantly affect the salinity  of the open waters
of the Bay,  it may present  a barrier to passage  of fish not
tolerant to  salinity variations."

Comment:  The enhancement of the conditions in the waters of the
South Bay for aquatic  life  may be offset by the  aquatic barrier
that may be  created by the  Basin Plan Alternative.

Statement (EIR/EIS TECHNICAL Page 165):  "An outfall project alone
would not impose  significant economic cost to individual users
or industries.  However,  further analysis of final outfall users
charges together  with  user  charges for advance waste treatment
should be made  in order to  assess the coiriir.ed  economic impact."

Comment:  The full  impact of the user charges for fully imple-
mented advance  waste treatment by the South Bay dischargers to be
closely followed  by additional user charges for sludge solids
handling and disposal  facilities has not occurred and the further
cost of the Basin Plan Alternative appears to bo unwarranted in
light of its questionable bcn.ofits.

Statement  JEIS/EIR  TECHNICAL Page 169):  "Discontinuing a signifi-
SA
ot
cant portion of  the  freshwater inflow into the South Bay will
permanently remove the  existing freshwater habitat in the area
south of  Dumbarton Bridge."

Comment:  This adverse  operational effect of the Basin Plan Alter-
native provides  a significant reason to adopt- the no further action
alternative with a monitoring program to determine the effect of
the' discharge o£ highly treated effluent into the South Bay.
74
-------
Comment of County Sanitation District-No.  4
Page  3
Statement EIK/EIS TECHSICAL Page  188);   "This (no further action)
alternative can be viewed as a phase of  a  'deferred  action'
alternative that would allow an interim  monitoring program and
analysis of the effects of approved upgraded treatment on the Bay
environment.   Should water quality be shown to improve markedly
under this alternative, a case could then  be made for no addi-
tional action. •  If, however, the  rate of improvement were not
satisfactory  to regulatory agencies, additional treatment, recla-
mation, or disposal methods could be implemented as  needed, and
evaluation could be made for each treatment plan separately for
SBDA as a joint discharger.  During the  phasing of treatment and
disposal, alternatives not now considered  viable may be developed
to a level of reliability, cost-effectiveness, and public accep-
tance that would allow their implementation."
Comment:  This statement is fully supported by other statements
set  forth in  the EJ.R/E1S and is fully endorsed by County Sanita-
tion District Ho. 4 and serves'as the basis for the  request that
the  proposed  Basin Plan Alternative be abandoned and the no
further action alternative and South Bay water quality monitoring
program be approved 'for' use by the South Bay Dischargers Authority.
Submitted by:  County Sanitation District No. 4 of Santa Clara County
             100 East Sunnyoaks Avenue
             Campbell, California  95008
Bated:
             30 April 1979
Response:
SBDA and EPA have noted the attached resolution and have considered it in
making a project selection.  Specific issues have been raised which require
some responses.

1.  No response required

2.  No response required

3.  No response required
                                                                                A.   It may be true that source control programs now planned by SBDA would
                                                                                reduce the magnitude of toxicity  in the effluent and, hence, the receiving
                                                                                water.  However, data on metropolitan wastewaters from several sources
                                                                                indicate that domestic sources, storm severs, and nonpoint sources con-
                                                                                tribute more than half of the heavy metals (which constitute a major
                                                                                portion of the toxicity potential).  For example, the Association of
                                                                                Metropolitan Sewerage Agencies (AMSA), in the AMSA Monthly Report. May 1979,
                                                                                Volume 4, Issue 5, page 3, shows  that while many member cities confirm the
                                                                                assumption that full-scale industrial pretreatment will eliminate most of
                                                                                these substances from the sewer systems, others (Dallas, Texas; Seattle,
                                                                                Washington; Chicago, Illinois) indicate that domestic, storm runoff, and
                                                                                nonpoint sources may be as significant.  Also, Robert Pitt of Woodward-
                                                                                Clyde Consultants, in "Demonstration of Nonpoint Pollution Abatement Through
                                                                                Improved Street Cleaning Practices" (EPA Grant S-804432, May 1979), used
                                                                                the City of San Jose as an example in comparing urban runoff and wasteuater
                                                                                plant effluents (Table 2-1).  He  indicates that improved treatment nay not
SHG/pm
April 25, 1979
                                                                                                                                                 75
-------
 be as cost-effective as street cleaning with regard to heavy metals.
 Therefore, it may be concluded that source control must be extensive,
 including nonindustrial sources, and that some sources (nonpoint, for
 example) may override the Improvement provided by pretreatment and other
 source control approaches*   In addition, regardless of the success of
 source control, at this time it is not possible to estimate the percentage
 reduction in toxicity, nor  is it possible to predict compliance with the
 40 ml/1 toxicity guideline  as a result of source control.

 5.  Ho response required

 6.  No response required

 7.  No response required

 8.  SBDA has not designed a monitoring program.  SBDA will, upon completion
 and approval of the Final EIR/E1S, petition the STOCB in order to establish
 conditions fot exemption from the prohibitions against discharge expressed
 in both the Basin Plan and  the Enclosed Bays and Estuaries Policy.  Infor-
 mation will be submitted to the Regional Water Quality Control Board and
 the State Water Resources Control Board to justify such exemption In that
 petition.
76
-------
                                       TABLE  2-1.    COMPARISON OF URBAN  RUNOFF AND WASTEWATER TREATMENT PLANT EFFLUENT





Runoff



Concentration

(rag/1 unless

otherwise stated)

Parameter
Ca++
K*
M9;+
Na*
ci-
so,-
HC03
N03
BOD5
COD
KN
OrthoP04
Total Solids
TDSe
Suspended Sol ids
Cd
Cr
Cu
Pb
Zn
Hg
Specific conductance
(nmhos/cm)
Turbidity (NTU)
pH (pH units)
TOCf

Avg
13
2.7
4.0
15
12
18
54
0.7
24
200
6.7
2.4
350
150
240
0.01
0.02
0.03
0.4
0.18
•cO.OOOl

120
49
-6.7
110
Peak
{1-hr)
19
3.5
6.2
27
18
27
150
1.5
30
350
25
18
950
380
850
0.04
0.04
0.09
1.5
0.55
0.0006

660
130
7.6
290


STP*. Effluent
Concentration
(mg/1 unless
otherwise stated)

Avg.
65
24
35
220
330
150
230
4.9
21
35d
24
19
1000
1000
26
0.002
0.016
0.081
0. 0098
0.087
0.0019

1900
20
7.6
30

Ratio
of Avg.
Runoff
to STP
cone.


0.20
0.11
0.11
0.07
0.04
0.12
0.23'
0.14
1.1
5.6
0.28
0.13
0.34
0.15
9.2
5
1.3
0.37
41
2.1
<0.05

0.06
2.5
—
3.5

Ratio
of Peak
Runoff
to Avg.
STP cone.


0.29
0.15
0.18
0.12
0.05
0.18
0.66
0.31
1.4
10
1.1
0.92
0.92
0.37
32
20
2.5
1.1
150
6.3
0.32

0.36
6.5
—
9.7

Street
Surface
• Annual .
Runoff"
(tons/yr)


350
73
110
410
330
490
1500
19
480
950
17
1.2
9500
4100
4700
0.018
3.5
5.5
36
3.9
0.0032

—
--
—
3000


Annual
STP
Effluentc
(tons/yr


8,000
3,200
4,700
30,000
45,000
20,000
32,000
660
2,800
4,700d
3,200
2,600
140,000
' 140,000
3,500
0.27
2.2
11
1.3
12
0.26

—
.
--
4,100
Ratio of
Street
Surface
Runoff
to STP
Annual
Yields


0.040
0.023
0.023
0.014
0.007
0.025
0.047
0.029
0.17
0.20
0.005
0. 0005
0.07
0.029
1.3
0.07
1.6
0.5
28
0.33
0.01

—
--
--
0.73
 Secondary sanitary wastewater treatment plant.


 About 200 people correspond to 1 curb-mile (2880 curb-railes in San Jose/575,000 population).   Therefore
 a population of 850,000 corresponds to about 4250 curb-miles,  with about 1100 curb-miles  of streets
 surfaced with oi1 and screens.  These annual runoff values were calculated based on  a year of  the  appropriate
 accumulation rates and these mileage estimates.


cAn estimated population of 850,000 is served by the sanitary wastewater treatment facility.
 Estimated.
                e
                 Total dissolved solids.
Total organic carbon.
 Source: Pitt, R-, 1979. "Demonstration of Nonpoint Pollution Abatement through Improved  Street  Cleaning
 Practices."  Woodward-Clyde Consultants for Municipal Environmental Research Laboratory, Office of Research
 and Development, U.S. EPA, Cincinnati, Ohio.  Grant No. S-804432.
                                                                                                                                                                 77
-------
                           SANTA   CLARA  CITIZENS
                             ADVISORY   COMMITTEE
                                                        MAYS  1879
Environmental Protection Agency
Attn:   Hearing Office, HE-149
Region IX
215 Fremont Street
San Francisco, California

Gentlemen:

I am presenting the following testimony regarding the EIS/EIR
for the South Bay Treated Wastewater  Disposal Program on
behalf of the Citizens Advisory Committee for the City of
Santa Clara.  Our committee,  which is'advisory to the City
Council,  has long been aware of the proposed pipeline project-
In 1975 our representatives attended  the workshop held in
Sunnyvale regarding the project.  At  that meeting our former
chairman expressed his reservations about the project.        ,

We are grateful to see that the Environmental Protection Agency,
along with the South Bay Dischargers  Authority,  no longer sees
the need to construct the pipeline.  We also continue to see no
need for the project.  The money saved by not constructing this
pipeline could be applied to improve  treatment so the sewage
could be reclaimed for a beneficial use.

To reach the above decision our committee recently organized a
sub-committee specifically to review  in detail the summary Envir-
onmental Impact Report and Statement. During this review we
contacted our city staff {.to obtain further:'information on-the
project.  As you are probably aware,  most of the local agency
staff members involved in the project also do not support the
pipeline project.  Our independent review resulted in a similar
viewpoint.  Basically, our objections to the project are the same
as those noted in the EIR/EIS.   Namely:

     1.  No significant improvement in water quality.  It is
         apparent that the advanced sewage treatment plants
         recently constructed will significantly improve the
         water quality in the South Bay.

     2.  Biological damage to the existing freshwater marshes
         that would result if the pipeline were put into oper-
         ation.

     3.  Cost.  The 986 million to construct and another $320,000
         to operate could be better applied to a reclamation
         project.  The savings of the operating costs to the
         citizens could be very helpful in these inflationary
         periods.

     4.  Energy.   This project would consume about  the equiv-
         alent of 4900 barrels of oil a year to operate.  We
         are already in somewhat of an energy crunch.  This
         project  would further the energy problems  faced by
         the country.

Baaed on the information in the report,  we believe  the pipeline
project,  if constructed, could mean the final end to any pot-
ential for a future reclamation project in this area.

We believe that since reclamation and reuse is our  goal we
should continue with an ambitious program to reach  that goal.
                                                                                                     Sincerely,
                                                                                                     Bert Martin
                                                                                                     Citizens Advisory Committee
                                                                             bm:mc
                                                                                  CITY CLERK
                                                                               CITY OF SANTA CLARA
                                                                                     Cltr Hall
                                                                               SANTA CLARA. CALIF. MOW
78
-------
Submitted by:  Santa Clara Citizens Advisory Committee
Bated:
               undated
Response:
SBDA and EFA recognize that energy consumption has become an even more
important concern since the issuance of the Draft EIR/EIS and increased
energy costs would further increase predicted operation costs for all
upgraded treatment alternatives as well as for all alternatives requiring
transport of the effluent.

It was not intended .to imply no significant improvement in water quality
would occur as a result of implementing any of the project alternatives.
Rather, the five "viable" alternatives did not appear to be significantly
different in predicted dissolved oxygen levels; actual numbers of NPDES
permit violations are expected to decrease with the implementation of
advanced waste treatment.  The location of oxygen depressions varies'with
the alternatives, however, and no alternative guaranteed meeting dissolved
oxygen goals year-round.

Reclamation and reuse of wastewater, as stated in the Draft EIR/EIS (page
195 of Technical Volume), is a goal of the state and federal governments.
However, at this time, reclamation cannot be postulated as a complete
disposal alternative but the four viable disposal alternatives are all
compatible to some degree with limited reclamation.  Regional disposal
systems are particularly compatible with^large-scale regional reclamation
programs.  SBDA and its member cities are presently engaged in the Regional
Reclamation Study and in several small-scale projects.  Therefore, SBDA
is continuing to study reclamation as a future option for all or part of
the effluent in the area.
                                                                                                                                                        79
-------
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL OCEAN SUHVfv
Hockville. Md. 20852
                                 OA/C52x6:JLR

MAY   3 1979
 TO:        PP -  Richard Lehman

 FROM:      OA/Cxl

 SUBJECT:   DEIS  #7904.04 - Treated Wastewater Disposal Program
     The subject statement has been reviewed within the areas of NOS
 responsibility and expertise, and In terms of the impact of the proposed
 action on NOS activities and projects.

     The, following conment 1s offered for your consideration.

     Geodetic control survey monuments may be located in the proposed
 project area.  If there 1s any planned activity which will disturb or
 destroy these monuments, NOS requires not less than 90 days' notification
 in advance of such activity in order to plan for their relocation.  NOS
 recommends that funding for this project includes the cost of any relocation
 required for NOS monuments.
80
                                                                                           Submitted by:  U.S. Department of Commerce
                                                                                                          National Oceanic and Atmospheric Administration
                                                                                                          National Ocean Survey
                                                                                                        .  Rockvllle, Maryland  20852
                                                           Dated:
                                                                          undated
                                                           Response:

                                                           No construction activities will occur with the selected project alternative

                                                           (No Further Action).  Therefore, there will be no activity which will dis-

                                                           turb geodetic control survey monuments.  Thank you for calling these•

                                                           monuments to our attention.
-------
                                                 S.E.P.*-
SanJose'State Uniuersity
                     WASHINGTONSOUARE
                CAN JOSt, CALIFORNIA 161*2
 SCHOOL OF SCIENCE
                                           KvR
                                                                       Mttl Z7T-23SS
May 14, 1979

Environmental Protection Agency
Attni Hearing Office, HE - 14? , Region IX
215 Fremont Street
San Francisco, California  ?4l05

Subject!  Consents for the Draft EXE, Treated Vtaatewater Disposal Program - for
          inclusion  it> the public record of the Hay 16, 1979  hearing.


To numbers of the U. S. Environmental Protection Agency and  the South Bay
Dischargers Authority.

We are two biologists who have long been  interested in the biology  and environ-
mental quality of the San Francisco Bay and especially the southern portions
of that bay.  Dr. H. Thomas Harvey has been studying the marshes of the Bay since
the late  JJJ^'s and I have been studying  tha Bsamala of those  sans  marshes since
the early 19^0'»•   He has carried  out the earliest and most  of the  marsh restoration
experiments in the  bay while I have specialized  in the rodents, especially the
endangered Salt marsh harvest mouse.  We, and other professors here at San Jose
State University,have become aware of how little fresh water Marsh  has survived
tha lest  two hundred years of human occupation.  Host of the salt marshes (over 60JJ)
and almost all (over 95$) of the freshwater marshes have dissapeared, and with
the latter the breeding grounds for such  birds as the marsh  yellowthroat and the
hatching  ground for the ducks who  atteapt to breed in the Bay  area. These ducks
require freshwater  for their young during the first few days of their lives.  With-
out it their clutches are dooaed to early deaths.  The diversity provided by fresh-
water marshes are almost a thing lost and forgotten.

There are valuable  freshwater or near freshwater areas left  such as that at
Artesian  Slough near Alviso.  That area supports large numbers of birds and is
freshened by the outfall of the San Jose  and Santa Clara Water Quality Control
Plant, now an advanced secondary treatment plant.  Waters from that plant may soae-
day In the future be used alao to  create  a new freshwater marsh in  the Hew Chicago
Marahf a  portion of the San Francisco Bay Wildlife Refuge located adjacent to
their new Alviao area educational  center. Waste water cleaned to the extent that
the Ssn Jose plant  now does with its nitifieation and multistage filtration appear
to be adequate for  use in the creation of such a freehwater  marsh*  It is for these
reasons that we support Option #4  of the  Draft EXR which we  understand to call
for the outfalls to regain as they are at the various South  Bay plants while the
quality of the waste water is to be upgraded, we assume to the level now at the
San Jose  plant.  We request your decision in favor of this fourth option.
  Howard S. Sho11 hammer                  H.  Thomas Harvey
  Professor of Biology                   Professor of Biology
                    THE CALIFORNIA STATE UNIVERSITY AND COLLEGES
Submitted by:   Dr.  Howard  S. Shellhammer and Dr. H. Thomas Harvey
               School  of Science, Department of Biological Sciences
               San  Jose State University
               Washington  Square
               San  Jose, California  95192
Dated:
               14 Hay  1979
Response:

The selected project  alternative  {No Further Action) assumes implementation

of advanced waste treatment  at  all member dischargers' facilities which

has recently taken place and ensures continued discharge In the area.  A

further upgrading of  treatment  (as in Alternative 4 - page 193 of Draft

EIR/EIS Technical Volume) could be considered should an approved monitoring

program show Insufficient protection of  beneficial uses (see•also response-

to County. Sanitation  District 4,  item 8, in Section 2.2).  At this time,

Alternative 4 has not been selected due  to  its high cost and slight, if

any, improvement in water quality over the  other alternatives.


Use of San Jose/Santa Clara effluent in  the creation of new marshland at

the New Chicago tlarsh element of  the San Francisco Bay National Wildlife

Refuge, or elsewhere, is not -precluded by selecting No Further Action.  As

mentioned in the response to County Sanitation District 4, this may be

defined as a beneficial use.
                                                                                                                                                                        81
-------
Son Jose'State Uniuersty
              SAN JOSt. CALIFORNIA MII2
SCHOOL OF SCIENCE
                                     Dr. L Richnrd Atowvtdt
                                     Avtan Biology Laboratory
                                     San Jow St«t» Unlvgrtlty
                                     StnJow, CA95I°2
                                                            Itoei 377 30l«
AvtAM StOLJCMkY
14  May 1979

MEMORANDUM

TOi    Environmental Protection Agency
       Attni Hearing Office, HE-149 —  Region IX
       215 Fremont Street
       San Francisco, CA  94105

FROMi  L.  Richard Mewaldt, Ph.D., Professor Emeritus of Zoology,
       Avian Biology Laboratory, San Jose  State University

SUBJECTi  Resolution No. 73-16 — South Bay Discharges

     I  with several of my co-workers,  former students, and  students
have since 1953 concerned myself with  several aspects of the biology
of  the  vertebrates, especially birds,  of  San Francisco Bay  and  its
surroundina marsh lands.  These studies have resulted in many agency
reports,  theses,  and papers published  in  professional journals.
These  works were accomplished with the cooperation of the California
Department of Fish and Game, The U. S, Fish and Wildlife Service,
and the Leslie Salt Company.

    An overriding concern of these studies has been the acquisition
of  general and specific Knowledge to better manage the wildlife
resources of San Francisco Bay.  Our goal has been to maximize
biological diversity and wildlife values.  We have assumed  that
inhancement of these values will benefit  this and future generations
of  mankind.  During this 25-year period of our concern and  hopefully
constructive influence, progress, although frustratingly slow at
times,  has been made toward attainment of some of these goals.

    However, in the matter of preservation of the primitive and
once extensive fresh and brackish water fringe marsh lands  of the
South  Bay and the species of plants and animals which inhabit   them,
we  have continued to lose ground (= marsh).  We now have the oppor-
tunity  to reverse this trend and with  careful management restore at
least  some of the fresh and brackish water marsh lands with the
vastly  improved quality of water being discharged from the  San Jose
Sewage  Treatment  Plant.

    I  strongly urge adoption of Option Four (4) which I understand
calls  for staying with present outfalls (at least for the present)
and for continued up-grading of water  quality to at least advanced
secondary treatment.  This option will permit the several concerned
jurisdictions, including the San Francisco Bay National Wildlife
Refuge  to variously use this reclaimed water for the restoration and
enhancement of our wildlife resources  and thus the improvement  of
the quality of the life of the people  of  the San Francisco  Bay
Region.

                              a/c

                THE CALIFORNIA STATE UNIVERSITY AND COLLEGES
                                                                                  Submitted by:  Dr. L, Richard Mewaldt
                                                                                               Professor Emeritus of Zoology
                                                                                               Avian Biology Laboratory
                                                                                               San Jose State University
                                                                                               San Jose, California  95192
                                                                                  Dated:
                                                                                               14 May 1979
                                                                                  Response:

                                                                                  SBDA and EPA have selected Alternative 2 (No Further Action) and the present

                                                                                  outfall locations will remain in use.  The present level of treatment is

                                                                                  advanced waste treatment at all SBDA facilities". Alternative 4  (Upgraded

                                                                                  Treatment) postulates further upgrading but due to increased costs with

                                                                                  little, if any, improvement in water quality, this alternative was not

                                                                                  selected.  (See also response to Drs. Shellhammer and Harvey in Section 2.2.)
82
-------
                SANTA CLAHA COUNTY CAHNERS ASSOCIATION

                           1007 "L" STREET
                      SACRAMENTO. CALIFORNIA tHIt
                        AREA CODE (lit) 4M-1HO


                          May  15, 1979
U. S. Environmental Protection Agency
Region IX
Attention Hearing Office  (HE-14)
215 Fremont Street
San Francisco, California  94105

Gentlemen:

The following statement is being submitted by the
Santa Clara County Canners Association.  Our Association
is a non-profit organization  formed 40 years ago to
provide a forum for discussion of problems and opportuni-
ties common to our industry.

Currently, most of our activities center around the ever
expanding load of federal, state and local regulations that
adversely affect our capacity to efficiently produce
food products.

Our Association represents 8 companies, operating  14 canning
factories, employing approximately 12,000 people and having
a 1.4 billion dollar economic impact to Santa Clara County.

So there can be no confusion as to our position we will
state at the outset that we are adamantly opposed  to the
construction of a deep water outfall, or any other alterna-
tive being evaluated that will force the South Bay into
compliance with the State Water Quality Control Boards
resolution 74-73, which bans discharges to the San Francisco
Bay south of Dumbarton Bridge.  It is this resolution which
needs evaluation not methods of implementing it.

The discharge ban in question was adopted by the State
Board five (5) years ago and is responsible for over 100 million
dollars of advanced waste treatment facilities being construc-
ted in the cities of San Jose, Sunnyvale and Palo  Alto.
Now we are being asked to evaluate an additional 100
million dollars for a pipeline or some other alternative
to comply with an arbitrary and capricious ruling.

The EPA, in order to further evaluate, advance waste
treatment programs, commissioned the Vertex Corporation of
McLean, Virginia, to prepare a report on "An Analysis of
Planning for Advanced Wastewater Treatment."  The report,
published in July of 1977, covers the planning that went
into decisions to construct advanced wastewater treatment
facilities in six (6} areas of the United States, of which
San Jose/Santa Clara was one.

We quote from that report:

"Costly pollution control projects are commonly built with
almost no real knowledge of the waters that are to be protected
by the generous investment in treatment facilities."

Referring specifically to the South Bay, we quote further
from the Vertex Report.

"December, 197S, Hydroscience publishes another mathematical
model.  Like the last (February 1972), it is a mosaic of
oversimplifications and guesswork."
"When the earlier models showed that construction could solve
a problem they were accepted at face value.   However, when
the 1975 model showed that no amount of construction would
work, State officials began to examine the model for unwarranted
assumptions, inadequate verification, and skimoy data.  This
belated discovery of weaknesses in mathematical models has
been costly."
"The San Francisco Bay Regional Water Quality Control Board
could scarcely be expected to rejoice in Hydroscience's new
conclusion; viz, all previous planning for the south bay has
been fundamentally wrong.  For the first time the Board has
critically examined a mathematical model for the South  Bay, and
it is found wanting.  Had the Regional Board been equally
critical of the earlier models and studies, it might never have
gotten into its present fix."

Today we find ourselves saddled with advanced wastewater
treatment facilities in San Jose that are in themselves environ-
mentally unsound, due to their enormous electrical energy
requirements (more than our 14 canning factories combined).

                                                                                                                                         83
-------
 Much of  what has occurred in  the South Bay  has taken  on the
 appearance of a "Gold Rush" by  consultants  and municipalities
 for EPA  funds.  It  is about time we pause and evaluate  the
 damages  and possible  benefits that have accrued from  this
 uncoordinated and uncontrolled  growth in waste treatment.

 The Food Preserving- Canning industry has long been a  vital
 and important- segment of Santa  Clara County's business
 community.  'We have actively  and supportively participated in
•the past wastewater programs  in San Jose and Sunnyvale; i.e.,
 primary  treatment in  1956, Secondary treatment in 1964  and
 expanded Secondary  treatment  in 1974.  In each of these cases
 the need was apparent and benefits well identified.   However,
 with advanced waste treatment and now this  potential
 "Super Sewer", the need and benefits have never been  demon-.
 strated  or justified.
 Respectfully submitted.
                             Very  truly yours,

                             SANTA CLARA COUNTY  CANNERS ASSOCIATION
                             Robert  Use
                             President
 cc:  File
CALIFORNIA CANNERS and GROWERS



P. O. Box 60669, Sunnyvale. California 94086
84
                                                          Submitted by:  Santa Clara County Canners Association
                                                                        1007 "L" Street
                                                                        Sacramento, California  95814
                                                          Dated:
                                                                        15 May 1979
                                                          Response:

                                                          EPA has evaluated  the Vertex report and subsequently initiated  the policy

                                                          that any Advanced  Haste Treatment (AWT) project(s)  costing in excess of

                                                          one million dollars must be reviewed by both the EPA Regional and Head-

                                                          quarters Offices.  If recommended, the proposal(s)  would then be submitted

                                                          to the EPA Administrator for his personal consideration and review.  This

                                                          procedure assures  that only AWT projects with special need will be consi-

                                                          dered for funding  through the EPA construction grant program.
The modeling performed as part of this program provided the data which

indicate that no outfall relocation is necessary.  Our studies show that

possible improvements may result from implementation of the Basin Plan

Alternative, but that these improvements may not be significantly greater

than with other actions.  Therefore, SBDA and EPA have selected "No Further

Action."  We anticipate that future monitoring of the South Bay will

establish the level of improvement gained from AWT facilities and any

problems still remaining.
-------
   United Stitei
  ; Department of
   Agriculture
Soil
Conservation
Service
UNITED STATES DEPARTMENT OF AGRICULTURE
          SOIL CONSERVATION SERVICE
              »88 CHILES ROAD
               DAVIS,CAM61«
                                              May 8, 1979
       Paul DeFalco, Jr.
       Regional Administrator
       U.S. Environmental Protection Agency
       215 Fremont Street
       San Francisco, California 94105

       Dear Mr. DeFalco:

       We acknowledge receipt of the draft environmental impact report and
       environmental impact statement for South Bay Dischargers Authority
       Treated Wastewater Disposal Program.  We have reviewed this document
       and we find no apparent conflict with any Soil Conservation Service
       on-going or planned programs or projects.

       Neither the Basin Plan (Alternative #1) nor Alternatives t2, #3 or 04
       will result in the loss of prime agricultural land.  However, Alter-
       native fl5, reclamation of wastewater from the SBDA treatment system,
       and the reuse of this water could have a further Impact upon prime
       land and upon existing conservation aystems, beyond that discussed
       in the EIS.  If Alternative #5 is chosen, the EIS should be expanded
       and specifically describe the wastewater reclamation and reuse project
       in detail.

       He appreciate the opportunity to review and comment on this proposed
       project.

       Sincerely,
       FRANCIS C. H.-LUM
       State Conservationist

       cc:  R. M. Davis, Administrator, BSDA, SCS, Washington, D. C. 20250
            Director, Office of Federal'Activities (Kail Code A-104),
              Environmental Protection Agency, Room 537, West Tower,
              401 M Street, S. W., Washington, D. C. 20460
                                                                    Submitted by:  U.S. Department of Agriculture
                                                                                   Soil Conservation Service
                                                                                   2828 Chiles Road
                                                                                   Davis, California  95616
                                                                                         Dated:
                                                                                                        8 May 1979
                                                                    Response:

                                                                    We have  selected  the "No Further Action" alternative and this alternative
                                                                    will not affect agricultural land.  However, SBDA and EPA will look care-
                                                                    fully  into this and other impacts should they become involved in reclamation
                                                                    projects in  the future.  Thank you for your advice concerning the potential
                                                                    adverse  impacts of reclamation and reuse of wastewater on prime agricultural
                                                                    land.
                                                                                                                                                                  85
-------
SAN JOSE /SANTA CLARA
WATER POLLUTION CONTROL PLANT
                                    I'.y
                                           BV E.p.A
                                               IX
                                            CENTER
         ADMINISTERED BY
                                       1C   ::i«iA»'79
 May 16, 1979
 Environmental Protection Agency
 Region IX
 Attn:  Hearing Office (HE-149)
 215 Fremont Street
 San Francisco, CA  94105
         CITY Of SAN JOSE

DEPARTMENT OF PUBLIC WORKS


    CONTRIBUTING AGENCIES


             Clf V Of SAN JOSE
           CrTV V «A*TA ClAftA
       COUKTV SANITATION DIST. NO. 7
       COUNTV SANITATION OIST. NO 3
       COUKTV SAWTATIO* Dt$T, NO *
         eiT<««*CM»MLL.U»GAT0l.
         «OMT« ttMMO *M» IMATOCA
        •UMBANKSANiTAftyfllSTritCT
       CUPtftTtMQ SANITABY ONtftlCT
             cnv 0» GVtntHO
        MILPtTAS SANtTAftV DSTHICT
              «mr g* Miiriru
          HMOi SAHIT AliV OATHICT
                                                                                    Environmental Protection Agency
                                                                                    Page 2
    4.  Improvements in toxicity levels of the South  Bay Waters
        may be  achieved more cost effectively through emphasis
        on toxicity  source control programs.

Therefore, in the  opinion of the San Jose/Santa Clara Treatment
Plant Advisory  Committee, there is a minimal cost/benefit
relationship for the South Bay Waters to continue the project for
construction of transport facilities.

The adoption of the  "No Action" alternative is recommended.
 RE;
      South Bay Dischargers Authority
      Common Conveyance Facility
  x*~r-~ ---- ^   ^. ^.'  •  ~
 DWARD  T. RAMEY,  Chairman
                                                                                    Treatment Plant Advisory
                                                                                         A.  R.  Turturici, Deputy Executive  Director
                                                                                         South  Bay Dischargers Authority
 The San Jose/Santa Clara Hater Pollution  Control Plant provides
 wastewater treatment for the Cities of  San Jose and- Santa Clara;
 the Milpitas, Cupertino, Burbank and Sunol Sanitary Districts;
 and Santa Clara County Sanitation Districts No's. 2, 3 and 4.
 In accordance with the terms of various contracts, these agencies
 are represented on a Treatment Plant Advisory Committee which
 advises the Administering Agency, i.e.. City of San Jose.

 The Treatment Plant Advisory Committee  at its regular meeting on
 May 9, 1979, by motion, unanimously approved submission of a
 statement to the Environmental Protection Agency and the South Bay
 Dischargers Authority recommending implementation of the "No
 Action Beyond Currently Approved Improvements at the Treatment
 Plants" alternative as set forth in the "Draft Environmental Impact
 Report and Statement for the Treated Wastewater Disposal Program
 of the South Bay Dischargers Authority."   A review of the "Draft
 Environmental Impact Report and Statement,  South Bay Dischargers
 Treated Wastewater Disposal Program," indicates the following:

     1.  There is no assurance that there  will be a significant
         improvement in South Bay water  quality as a result of
         transporting treated final effluent.

     2.  Diversion of treated final effluent from the South Bay
         may result in salinity increases  detrimental to the
         South Bay.  (EIS/EIR Technical  Page 146)

     3.  "Discontinuing a significant portion of the freshwater
         inflow into the South Bay will  permanently remove the exist-
         ing freshwater habitat in the area south of the Dumbarton
         Bridge."  (EIS/EIR Technical Page 169)
7OO (.OS ESTEHOS ROAD
                             SAN JOSE, CA. 95131
                                                       TELEPHONE (4081 263 7550
86
-------
Submitted by:  San Jose/Santa Clara Water Pollution Control Plant
               700 Los Esteros Road
               San Jose, California  95131
Dated:
               16 May 1979
Response:
The studies did not indicate "no improvement" in water quality; in fact,
the number of depressed dissolved oxygen episodes would decrease with
some alternatives.  However, a comparison of alternatives shows no
significant difference in improvement among them or any guarantee of
compliance with Basin Plan oxygen requirements.

While source control may reduce toxicity (see response to County Sanitary
District 4, item 4, in Section 2.2), there is no way to predict the amount
of reduction, if any, or whether or not Basin Plan toxicity guidelines can
be met with any alternative.
                                                                                                                                               87
-------
                                  Santa Oofo^ley Water District
                                  S7SO ALMAOEN EXPRESSWAY
                                  SAN JOSE. CALIFORNIA 9511S
                                  TELEPHONE (408) 265-2(00
6
May 17, 1979
Environmental protection Agency
Region IX
215 Fremont Street
San Francisco, California  9410S               »

Attention  Hearing Office, HE - 149

Gentlemen:

In the Draft EIR/EIS for the Treated Wastewater Disposal Program for the
South Bay Dischargers, the recommended alternative is the "no project alter-
native".  It is our understanding that this alternative includes the following
recommendations:

     1.   The present disposal points would continue to be used to discharge
the upgraded (nitrified and filtered) wastevater for the time being.

     2.   While the discharge continues, extensive monitoring would take place
to determine if these upgraded discharges have significant adverse effects on
the water quality of the South Bay.

     3.   The viability of reclamation should continue to be investigated in
the Regional wastewater Reclamation Study.

     4.   If it is found that these discharges do cause significant adverse
impacts on the water quality of the South Bay, or if reclamation is found
feasible, then construction of other disposal or reclamation facilities would
be considered.  Hhile this fourth recommendation is not stated explicitly, it
is implied by the wording of the alternative.

This alternative is acceptable as long as the fourth point has, in fact, been
agreed to by the members of the South Bay Dischargers' Authority.  We agree
that the existence of a problem caused by the discharges should be demonstrated
before the discharge locations are moved.  We also feel that if a problem is
demonstrated, then a commitment should exist to move the discharge locations.
He, therefore, strongly urge that the final EIR/EIS contain a statement committing
the dischargers to take whatever steps are reasonable and necessary to alleviate
any substantive problems identified by the monitoring program.
On Section V, "Reclamation and Reuse As A Wastewater Management Option"
to make the following comments:
                                                                         we wish
Environmental Protection Agency
                                                           -2-
                                                         May 17, 1979
The main assumption made in this section of the report is that 50,000 acre-feet
of wastewater is to be reclaimed from the San Jose/Santa Clara Plant, and by
a 1:1 blending with SB A, San Felipe, or Hetch Hetchy water, will create 100,000
acre-feet of blended water, with one-half of the blended water to be sent to
agricultural markets in the South Santa Clara Valley or in the Bolsa area of
San Benito County and one-half "returned to the current potable water market".

Pertaining to a 50,000 acre-foot market for wastewater in South Santa Clara
County, this figure was apparently based on a draft report published in 1976
by the State Department of Water Resources.  Since that time, a 1978 land use
study, conducted by the DBS for the Santa Clara Valley Water Reuse Study
(DWR/SCVWD Coop study), indicated that at present there is only, at best, a
market for about 20,000 acre-feet in the South Santa Clara Valley and that this
market is expected to decrease in the future.  In addition, this market includes
about 7,000 acres of land comprising parcels of 10 acres or less.  It is believed
that it would not be cost-effective to extend distribution lines to such parcels.

In terms of blending, the DWR studies indicate that a 4:1 blend with San Felipe
would be required to meet the quality requirements of the soils in the South
County.  We question the overall "effectiveness of the alternative of adding acid to
your 1:1 blend of SBA or San Felipe water to further reduce the bicarbonates and the
SAR of the water and gypsum to the Hetch Hetchy water.  Aside from the question of
expense, what effect on other water quality parameters would be affected by such
treatment?

As far as "returning 50,000 acre-feet of blended water to the potable water market",
it is not possible to develop reclaimed water for potable use because of public
health department concerns.  If the intent (not described) ia to use the reclaimed
water for acceptable markets thereby releasing potable water for domestic use, we
question the location of such a market.  The Hetch Hetchy Aqueduct water is used
mainly as a potable municipal supply; blended water could not serve as a substitute.
In addition, while your indication that "South Bay Aqueduct or San Felipe water
could be diverted to supply a portion of the market supplied by Hetch Hetchy water"
is physically possible, such an exchange could require either major expansions to
the District's import, treatment and distribution system or to the distribution
systems of the various retailers now taking Hetch Hetchy water.

In the North County, there does not at this time appear to be a feasible market
for 50,000 acre-feet of blended water.  The District's Hilpitas Reclamation
Study identified a maximum potential market of 20,000 acre-feet of direct (unblended)
reuse for industrial and landscape irrigation uses, on the assumption that much of
the area would be developed with dual water systems.

Concerning the economic considerations, the information which the District provided
Bechtel on the costs of projects according to the District's pricing policy is
accurately presented in the report.  The conclusion of the report that the San
Felipe Project alternative is less expensive than the reclaimed water alternative -
even with 87.5% financing - is still correct.

Si:
                                                                                            David K.  GUI'
                                                                                            Water Supply Planning ^Manager
    AN AFFIRMATIVE ACTION F.MPIOVER
88
-------
Submitted by:  Santa Clara Valley Water Distrtct
               5750 Almaden Expressway
               San Jose, California  95118
Dated:
17 Hay 1979
Response:
SBDA will, after completion and approval of the Final EIR/EIS, petition
both the State Water Resources Control Board (SWRCB) and the Regional
Water Quality Control Board (RWQCB) to establish conditions for exemption
to the Enclosed Bays and Estuaries Policy and the Basin Flan (see also
response to County Sanitary District 4, item 8, in Section 2.2).

In the analysis of reclamation/reuse, the Blended Water subalternative
would result in 100,000 acre-feet of water, 50,000'of which would be used
in either the Santa Clara County or San Benito County markets tentatively
identified in Chapter V.3.1 (page 218 of Draft EIR/EIS Technical Volume).
We recognize that the remaining 50,000 acre-feet could not, under present
restrictions, be placed in a potable water supply.  As stated on page 245
of the Draft, this blended water supply would be limited to that portion
of the San Felipe market now earmarked for irrigation, or a new market
would have to be identified.  If the identified Santa Clara Valley market
were reduced to only 20,000 acre-feet, then additional markets would have
to be selected or the reclamation amount proportionally reduced.  (This
issue is briefly discussed in Section V.6.4 of the Draft, page 266).
Our analyses indicate that 1:1 blending of reclaimed and San Felipe water
would be sufficient for most crops now being grown in South Santa Clara
County and, in addition, would reduce the cost to the farmer.  A 4:1
dilution would further improve water quality but would limit feasibility
(see page 245 of Draft Technical Volume) since such a blending would result
in 250,000 acre-feet of water limited to irrigation use in an area already
limited as discussed above to smaller (about 50,000 acre-feet) markets.
With only small decreases in cost due to:
   •   Slight decrease in crop damage or limitation
   •   Slight decrease in cost to the farmer of  reclaimed water
       over subsidized $17.00 per acre-foot estimated  for 1:1
       blending

Since Santa Clara Valley would not likely purchase blended  water  (see
Table V-25, page 262 of Draft Technical Volume),  the higher blend ratio
does not appear on review to be cost-effective.

Addition of acid or gypsum to reduce bicarbonate and adjust the sodium
absorption ratio (SAR) allows reduction of the blending ratio  to  1:1.
In comparing Tables V-9 and V-16 of the Draft Technical Volume (pages 223
and 245, respectively), it can be seen that addition of gypsum to 1:1
Hetch Hetchy blend reduces SAR by half while Ca  increases slightly over
unblended, untreated waters.  Similarly, addition of acid to either 1:1
San Felipe or Hetch Hetchy blends reduces both SAR and bicarbonate signi-
ficantly; no increases are noted in other elements of  concern.

We thank you for your expression of concerns; EPA and  SBDA  will continue
to explore these issues should they ever engage in fulrther  reclamation
studies.
                                                                                                                                                               89
-------
OFFICE OF THE SECftETARV
  RESOURCES BUIUDING
   1*16 NINTH STREET
    (9161 W5-5656
ChHUrtnwnt ai fW* ma G*
QWp*rtm«rtl of Forvitry
O**nrtm»nt of N««iwt)on i
   OCMR OftVtlOariWIt
t)*partm*nl o) Pi»k» *nd R«
Department of WM«r Rneur
EDMUND G. BROWN JR.
   GOVERNOR OF
    CALIFORNIA
                                                                      Httturtc* Centtmtlon i
                              R*9ion«J WM.( duality Control Boirdt
                              San rnnclKO Biy COnwvjlWn «Ad
                                 OvwtioQnwnt Comnnlwtan
                              Solid vv«t* Management Bond
                              StM*J Coaail CODMTVJllCI'
                              Slit* 4-*n«* CommliUon
                              5t«« RKlMMMQn Boifd
                              $t«t* Wil« AitourcM Control Bo»n3
     of California

Memorandum

To    :  Huey D*  Johnson
       Secretary  for Resources
       1416 Ninth Street
       Sacramento, CA 95814
                                                                                                                                                                  ."h« Resources Agency
                         THE RESOURCES AGENCY OF CALIFORNIA
                                 SACRAMENTO, CALIFORNIA
                                                                                                                                                    Dote:   Hay 17, 1979
       Attn:
              L.  Frank Good son
              Projects Coordinator
                                                                                                 (toportimnt of ffih and Gome
                                                             MAY 1719B
     Mr. Paul  De Falco, Jr.
     Regional  Administrator
     Environmental Protection Agency
     Region IX
     215 Fremont Street
     San Francisco, CA  9^105

     Dear Mr.  Be Falco:

     The State of California  has reviewed the  Summary,  Draft,  and
     Appendlcles—Environmental Impact Report  and Environmental
     Impact Statement  South Bay Dischargers Authority Treated  Wastewater
     Disposal  Program, which  was submitted to  the Office of  Planning
     and Research (State Clearinghouse) within the Governor's  Office.
     This review Is In accordance with Part II of the U. S.  Office  of
     Management and Budget Circular A-95 and the National Environmental
     Policy Act of 1969.

     We have attached  copy of ell comments received  from the Department
     of Fish and Crme, and the State Water Resources Control Board,
     Division  of Water quality.  We appreciate having been given an
     opportunity to review these documents.

                                       Sincerely,
      Attachment
                                       L.  FRANK  GOODSON
                                       Assistant Secretary for Resources
           Director  of Management systems
           State Clearinghouse
           Office of Planning and Research
           l&OO Tenth Street
           Sacramento, CA   95814
           (SCH No.  T9040905)
                                                       Subject:  Draft EIR/EIS  South Bay District Authority Treated Uastevater Disposal
                                                              Program,  Santa Clara County  SCH 79040905


                                                              The Department of Fish and Game has reviewed the subject Draft EIR/EIS and
                                                              finds It  to be a well written and complete document vltb regard to potential
                                                              fish and  wildlife Impacts.  However, we are concerned with the potential
                                                              impacts on the South Bay wetlands and that compensation for the impacts of
                                                              the various alternatives is Insufficient to offset construction and/or
                                                              operational disturbances*  In addition, as proposed, the project may conflict
                                                              vith the  1976  Wetlands Preservation Act and the Resources Agency(s Basic
                                                              Wetlands  Protection Policy (copies attached).  We offer the following
                                                              specific  comments for your consideration:
                                                          ®
                                                          ®
       1.1.5  ALTERNATIVE ALIGNMENT TO BASIN FLAK ALTERNATIVE (page IS)

       It Is our understanding that although the estuarine alignment from Sunnyvale
       northward will not significantly add to project costs. It  is not currently
       proposed due to uncertainties of equipment availability, levee integrity
       and potential delays in construction.  It is further stated that "...maintenance
       an repair of an underwater pipeline would be more difficult than for a land
       conveyance...".  We certainly recognize and appreciate these considerations,
       yet since the land route alternative transverses valuable  marsh-wetland
       habitats, the uncertainties fire just as great, if not greater, for the shore-
       side alignment.  Even though the marshes would be restored after construction.
       It may take years to return them Co their pre-project productivity.  With
       the possibility of periodic maintenance or repair of conveyance facilities,
       the marshes may never fully recover.  For this reason, we  recommend further
       consideration be given to the estuarine alignment.  In addition, routing the
       pipeline through wetland habitat appears to be In conflict with the Basic
       Wetlands Protection Policy since a less environmentally damaging alternative
       Is available.


       1.2.3  CONSTRUCTION OF THE BASIN PLAN ALTERNATIVE (page 25)

       "Typically the construction easement would be ISO feet wide, and the trench
       deep enough to allow four feet of cover over the pipeline.  Top soil would
       be separated and stockpiled for use in restoration of the  right-of way after
       construction is completed."  We recommend special consideration be given to
 90
-------
     Huey  D.  Johnson
                                         -2-
                                                                      May  17,  1979
     restricting the  construction corridor within tnarsh areas  to  not more  than
     50 feet.   Areas  set aside For the  stockpiling  of  excess spoil  construction
     equipment  and  materials  should be  located  outside of any  wetland  area.
®
®l
III. 1.1  CONSTRUCTION IMPACTS  (page 130)

The report states "...The pipeline corridor storage area and access route will
be returned as closely as practicable (emphasis added) to original condition at
the completion of construction...".  He believe that a more thorough discussion
of construction and especially restoration techniques to be employed within marsh
areas is warranted to better evaluate short- and long-term impacts to marsh
residents .

flff. J31 - Water Quality

Discharge of water from truck dewatering within marsh areas could have a serious
impact on fish and invertebrates and thus wildlife as veil.  We recommend pre-
discharge analyses be conducted to determine necessary measures to prevent
further degradation of marsh habitat.

Page 134 - Segment I - San Jose/Santa Clara Treatment Plant to Sunnyvale
           Treatment Plant

The need for "destruction" of one acre of salt marsh harvest mouse habitat
should be further explained and offsetting mitigation proposed.
-------
 ft c S7vc* r a :; ;: u ir.

    ; DjiJ-'uM-ir:.-:1.!. L'i rectors. MKCeutivo
      Off i cjijn; (;/ Bc&rU.t ;< COi'.;:ii.i snirms
!>••»-•  •    SCiM 9 1377

file Ho.!

Subject: Kutiandn  Policy for
Proposed  Construction Proj'..:
                                                                                                                                                    H' i
                                 JV|>;u-i inon'c Directors,  Executive.
                                 O;"ficori: of Bourd:; i.
                                                                           -2-
                                                                                     •or influeiv.,-i.:!B_—•
                                                                                                                         Secretary fo" Resources
92
-------
                  CHAPTER 7.  WETLANDS PRESERVATION [MflVVJ     -.
 Sec.
 0810.   Short tiile.
 f:S>J.   Lc?is!,itin' finding-; Mini  ilcdrtnttl'in.
 5S12.   Di'fiuiiit.tis.
 5813.   AMui'lIion <)f ri-nl |ir.ii»Tly  intcn-xts «>f \ty* Hum do;  furttii.'i >>!»•«• of j.liliiie
           imorvsl ; «Mi>nniii:iir.
 f-SM.   .Ty-%'  ; !\:d;.- ;  (<"-.^-:-.i.'«o!! -•. ilii  <-;!;..>. fo.ifiCu-*  .01*1  l:Um < •>,i-n»i>'~iini :  iii;ii»;
           liriority  • :  siilijni.-;-k;ii to I'-^i.-sl.-dMN-.
 r»S!,">.   I;.'"Ct-^:it!U»n of  ]»!;!»-  am; p.'i'in.-iuK  of  |.».-:j  i.mnrir^;  i-o'.»jwi.-i:tv*- i!;t-,-!it*.
 r»S*,(i.   W*-U;ll'oV tviltiili  or ;tdj.fvnl  lo r-visliiJX ;>.ti'!. .-j.-li1!)!:  fi-asiltirly uf ::i'in;.-ii-
           li.ili'<  ::< 10  mallaj:, mi'iil. l't..l,Tlioll. iili-.M-rv.il,. .h mul iv.il.
 &SI7.   OjieratiUK  «RfCiMlmi;ts  utlti  l-K:ai aj:<'uci'-s ;   eumlititMis;  fi*!i aud palm- n'U'l-
           laltoa.-i.
 f'SlS.   Property AcquMUon La\v; aj.jiliraiion to d';•

 i  5810.   Shut title
                                                                                                                               §   5813
 (A

y Sjais.i'.itfi, c.-lfti. |>. 11'Jti. 5 I.I ! 581 1. Legislative tini<{nqs anrt ilcck.ratlon Tins I^-tiisLiinfo l»-i-i-l:».-.ii>fly rrili":i) m>> ..... lii. :»'Mhi.iir, ;n:il >"»-niifir v;ilm' I" I pL-nph1 of I'.-ilifoiuia, :in4 l!);il ihrr-1 i^ )»-i.ft fnc nn jiff jr»n:iliv .imi >Mjs);iiui''l i)iji jioliry r.nil |ir.i^ri»n 'ii». j» order UKJ| MH-II u-i-iKujiJ.s v}t;,}i rontiniH- in jt. IJH iuif.v lo iii'-r! Ihi- Ui«l*}s of < 5812. Definitions A.s uxi'd it! this t-hajih'r, unN-* - (Ic- " liiriuis yU'cnniN, rlinjtui'l-'. );i!:'.>c. r"^«Tv.iir>. i>:tv<. »*.-ln:irif<. I:i- Cotni^, lh:its!n-i, jind tlM- J;i:ul> tntil -ilyin^ ;util ::i!jn!!Hii!r sin'b v.*::t>'i'N wlirtiit-v l»-riliaU'->lll.v or ihli-i-imllonily v.|.i»i r^i'il. In liic csl'-lit ll:nl .»!«•!> v.'a!iT.i and IKIH):< support :unl <-i':;lail) si^nit"tr;itil J'ish, \vi)(!lifi-, lcci^:i(h»l:il, .'tc.^lljt'tic. f.r .-rifUtifie rfstiurct'-v (!i) -TVji:n (mi- n(s" luc:ili.< ",!ic |if|i:trliiit;il:u!l 1'litl the Ite- imvnncnl «f |--ish and C!:im.'. (Adtlril hy ,Sl:ll-i.f.l?<;, p. 4CU, )>. 11'JG. 5 l.i Asterisks » • * Indicate deletions hy amemimtr.t 267 cf !-:':!);or nf thr t<>-p;jrluicul!< uuiy :v-i»in- iliti-n^ls n> mil |ir,']»H-tv lix Uian fro, iii.-)»di:i}:. hill i;.;t Ihuit'-d Ms ar.piisiiiun i>f li'-i'i^-iiiiii''!!! ri^lsH. w:i.-n it ili^ lililH'^ lltrll ar/^iisilii.ii of such li'-ir.T JKh-rt1.-:! vi'iU :.. . i.jjij.HsIl Iti,- |.'ll'( -v^i-s nf t cha!»f(T itl furt;|..-l-U?;: llu- jHililir'^ iuloro^l in t}."1 j'ri'Ii'L-lion, jtrrM-rv:it!'.il, rf>t tivn. and ontuuto'inrnf 4(f wclland.-;. (A § 58H, Join! study; cooperation vilth cltis*, counties rxriil lai'd cotnmlr-'i'cn; plan; priority sf.itus of firojccia; •>uf)mlss(«>ii to legislature lamls ut M«» ufatn u'h'uj!i arv suf'• 'n*'1' >l li>r af-tpnsitjtiii ]-mjs!i:\iit tu Chi;; <*i!H|Mi-r. 't'nn stijtiy vhntl N- NiiUnuuinl In tlu- (,v;ii^l:il«r»' not hn-T ttuiu .htiiMHcy l"», l!*7>», :in»l ^IstUi w-1 ft'ttli, fur n>u-jit(t-rittitni (»> jt.f t^-vi^liuur.', :i j.V.tu for (!n> :u"j»ti"'*'*'i*. i(l"°" U'Clinn, pVi'St-i-VDlti'ti, rt'Morii'.MiH, -'i^il i-ii!i;ittct'iiu-ut nf \vt't!;tmU, i :;'•!!;• ti:itf flilirl- in^ n-|iiirri»»'ijls ;t»!*l tin: |>n*>ri!.v -l.-d.iis »f si^dfic jii'tifiusctl wHhinils pn-jtcfs. (Au.k-a by st!Us.!!»;n, c, -io-j. i>. i\\*>, 31.) 5 -VH5. ftccasfi!t(«?.'t of plj*?s n«*| pr.i|jrnms of local .tfiir-clfls; coopcr.Klrfl means TJ;i> (Icji^rtnit'iU.'N in pivpiirinj; ii:i- »vi-il:u:«l-t ^rinrirv M!:I» iui«i j>r";-.i-,\::i j-iir^uiuU jmd oj(i-;i-*;(i;ti'i' itt.-ur; ,nnl j»ri'Tr.i),is oi" 3(w;il n-ii-nt1 Uii.l i*rj»l»j>ri;ur, iiJ.-iHify :uiil ili-.-L-v «.i.,tM- r.U ivi- («ri»J..'c(ii)!i n.'i-'l |>rt'S"rv:»thfii cal :i^i-i3c"ri*:^ ''.n,'-C wtlMtt. *tr ;nJ.i;;t n:t t"t >'\is;iiij: un:!1* ttf thp ti'»» itcCfi"n «iul |triS"rv;ttum, W4tlm>?l cnvillnjt (AtkUnl by StiUs.tHT«. ami illstrl'is f:u tin- uialla^i i™->rt asnl runtml of vrrlhuubt, -r lull-rest* In vvvl!:iiil i>iii>i"iMI ID tliifs rhapu-r;- |.r.>\ j.l.-il, t\awcv<-r, tiiai any socli Htfr'.'f-oirul s)ntH riisti.'e Oa! jiru.'.-i lioii ami prr-N-rvatlon o* Jlie \vrMaml*, vtntl tin- . the right to I'lf nsi- and (•nji-ymciit uf siicJi wnlnuds by ifce- IH-OI-'H- m' Hi,: stntc; and !»»oviflwl, furihi-r, that any sm-h ;tj:jit'MH'iit rjitrrrnl inui hy ilif T.i(-;::trinit;nt of Ki-h ami Cnnuf |n!i>-iiane to tills Mt-tlun xlmll |irmi.ti' as well fiat i^iblic use of lamlx ami !>nll IK- sulijvct «<> (hi- I»mpcrty Aciiiiisitioii ijn»- d'art 11 (cou'.im-iu-ihs with Sccliuu 1".S."4i), iJlvidon •'!. Title 2 of th« InJVfl-WMK-rit r'udl'). (.\i!iUtl bjf Stiits.lPTO, c. 4CL', p. 11W. J 1.) 93

-------
                     PUBLIC RESOURCES CODE            §  5823
           CHAPTER 8.  MENDOCINO  WOODLANDS OUTDOOR
                            CENTER [NEW]
Sec.
n820.  Short title,
S821.  Legislative findings.
B822.  Legislative Intent.
5S23.  ] icfloitloas.
R824.  Jurisdiction and control of center ;  title to lands and facilities.
5X23.  Department plan.
SKA.  Consultation and cooperation.
5827.  OjK'rnting agreements.
0828.  Adrlsory committee.
5S29.  Sale and cutting of timber.

             '.'hapter 8 icai atdtd In Stall. lS7t, e. 1301, p. Mij, S J.
S 5820.  Short title
  This chapter shall It- known and may bu cited as the Mealociuo VaodlaiuU Out-
door f.ViiH-r Act.
(Added by Stats.lS7C», c. 13ul, u. ^fS-l, S 1.1
Library Reference*
  \Vt,oOs *JjJ Forests C21*
  t'.J.S. \\'of*i!i and Forests !J 1], 12.

§ 5821.  Legislative findings
  Tlie If^lnturt fiui!.< t!"i! tliCT.- i* llrei!  fi.r :•. prutrniin m lli:iblf >!i" rhhilfr.i i,-f
:)>e siat* i.. better wmi-r-'icnd tlir outii^ix part:fi!nrl.v ;«u vm:::il :iinl MviMiilc ':n>-
pnrT:iJHr of the study,  toMSi'Tvutiori, protection. iimi lit
The Legislature flirt IHT flllcS that Ilie ii.ratjull iiiit! fip-
lands  imidHor Outer  ;iri. i-sperially  woll  -uiti-d to wrw iirUiiaciiy  us ;iu .iru
oducitri'jji (-outer tinder thi- cunirol ;ind mu rtiigetucnt of thr: Pppartnitint of Parks
l(ciTi-:itiuii. as u iliiH of tti" sli:ti> purk ^y-iieni
lAddcd hy stats. I97r.. >:. i;iui, p. ;»54, s l.i
                                                                                                 Submitted by:   Department of  Fish  and Game
                                                                                                                   State of  California
                                                    un of i;ntnr:Ll iv~»j':<-ci*!i.
                                                    uf :!!•• .Mi liiiocin-i Wood-
  5£22.  Leglilatlv* Intent
  Ti.c ;.i'iU!iid:iv hiT. hy
                           for plll>!if ;:•::!;. n-;Ti';U]..iJifi!,
 (Added hr .Stat>.l9r:irks and
                                                     U-i-iiio  \V(Ki'il!i!:-I- Olit-
                                                     Miit"  nf CT::!ft.:-iii:i i>y
                                                     !t:uJ t'oiL.srrv;!!-..:; jvir-
                                                    l for rhv t;t^ffit .-f (ho
                                                    ..';lufitti(/ii faciilty,
                                                       i different K:e:inin
 :uri";. innri- cr H'?s-. -.f stilt*- i,wnpd  l;iml iinil inirtrDVi-iiiont.^ lf>C:U-.'rt within Ih'f (.'list
 hr.lf tit the N"-tlici:'..-t liulf of t!u> Southeast Quarter .nr Si'r ;ion
 T.<  of the C:I-;T half :::nl soutliw.-st  inmrTi-r of thi- Northeast (jiuirt'T .ir:'! :!]•• f:isl
 half and Miiithwcst tMtJj.'ter of the Smithen-Jt t>uarier of S- ctiou 1M •.( T. 1T N..  U.
 IT  W.. .\!.U.B.M. :  tlr  :;orth half and southv.-est quarter of tin; Northv.t'st Qriirti'i'
 aral the north l.ulf of clu> Nunhtvt Quarter of Scctinn li of, and the went U-ilf  of
 tin- Nirihw .t gin-.rter of SiMtion '.V> of. T. 17 S.. It. 16 W., M.n.B.M.
  (i^ "Area" menus the Mi-ndocino Woodlunrt- ^i*e!al TreiititKT.t  Area  wtlhin tile
 Jnokson 8biti> Fore»r, .onsistica  of ^,KO ucros, mon- or less, of state-owuod lands
 If tun n'ithln t:.e sotitli linlf of Section 12 of; the Northwest Quarter, the west half
 of  the Northeast Quarter, the west half of tbe Southeast Quarter, and  the Sutith-
 west Quarter of Section 13 of, the Northeast, Southeast, and Snuuiwest Quarters  of
 SwlioD  14 of, the  nurtbeost quarter of the Northeast Quarter of Scctloo ±J of, the
 north half of Section 23 of, the Northwest quarter, the northwest quarter of tbe
 Xorthcast Quarter, and the northeast quarter of the Soiithtrest  Quarter of Seciion
 24  uf. T. 17 X., R. 17  W,. M.D.B.M. ; and the Southwest Quarter of i-ertlou T of ta..'
 soutlieaijt ujurter uf the Northwest Quarter, the Mouth half of the  Northeast Quar-
ter, the northwest, northeast, nnd soutlnvest quarters of the Southeast Quarter and
the  Southwest Quarter of Section 18 of, And the Northwest Quarter and nest half
of the (Southwest Quarter of Section lit of. T. IT X., R. 16 W., M.D.B.M.
(Added by Stals.l£l70, c. l.»l, p. 5854, i 1.)
                                                                                                  Dated:
                                                                                                                   17 May  1979
Response:

EPA and  SBDA  have  selected the "No  Further Action" alternative and there

is  no construction associated  with  this action.   Therefore,  no impacts on
wetlands will occur.


1.   In the Sasln Plan Alternative,  construction  in wetlands  would be

limited  to a  total of 1.28 linear miles of salt marsh  (Table II1-2, page

135 of Draft  EIR/EIS  Technical Volume).  Portions of that marshland -

Alviso marsh, El Dorado  Street marsh -  have  been  diked,  and  current use

of  the area as a landfill is reducing the marsh drastically.  This use

alone would likely result in a reroute  of the pipeline should it  ever  be

built.   Sensitive  marshland -  Palo  Alto Baylands  - would be  affected,  but

construction  would occur in areas already affected by previous construction.


In  the alternative Estuarine Alignment, portions  of the  Palo Alto Baylands

would still be affected  as would Alviso and  El Dorado Street marshes.   The

decrease in marsh  land affected would be about 0.3 miles of  previously

disturbed, diked marsh in the  proposed  Bayland Preserve.  Additionally,  the

uncertainty associated with construction in  salt  ponds and in the Bay

(page 185 of  Draft EIR/EIS Technical Volume)  Indicates that  the reported

roughly  comparable cost  of the two  alignments may underestimate the Estu-

arine Alignment costs.   This decrease' in affected marshland,  compared  with

the potential increased  cost and potential adverse impacts on Bay and  marsh

from breaching salt pond A-3,  do not appear  to be sufficient cause to  select

the Estuarine Alignment  over the Basin  Plan  Alternative.


2.   On pages  134 and  138, we mention that the trench would be limited  to

60  feet  and 80 feet,  respectively,  in sensitive marsh lands.   This mitigation
94

-------
measure is restated on page 171, Section III.3.1. Stockpiling would not
be in sensitive habitats (page 170, Section III.3.1).

3. Revegetation and surface restoration programs would be implemented
(page 171, Section III.3.1) after consultation with experts. However, no
revegetation program is instantaneous; therefore, there must be a recovery
period allowed Cor in such plans. For this reason, we stated that the
route would be returned as closely as possible to original condition,
recognizing that exact and immediate restoration is not practicable.
as a mitigation measure If the Basin Flan Alternative was selected. The
quantity of such diversion would have to be worked out between SBDA, Fish
and Wildlife Service, and California Fish and Game, and approval of the
RWQCB would be required.

7. As stated above, revegetation programs would be formulated should
construction be considered, and revegetation would reduce the time for
surface restoration. However, complete recovery would not be immediate
and would vary with location and the program chosen.
4. Trench dewatering, if required, would result in a stream of water
being diverted to holding ponds for percolation or evaporation (page 170).
These ponds would not be in marshland and discharges would not be per-
mitted to marshes. If treatment were indicated, this option would be
considered as an alternative.

5. The acre of Alviso Harsh "destroyed" would be that surface area over-
the trench. It is in potential salt marsh harvest mouse habitat, although
trapping activities in that marsh failed to Identify any of this endangered
species. The degrading character of the marsh due to diking and an
encroaching landfill may be responsible for the lack of salt marsh harvest
mice; however, Dr. Shellhammer of San Jose University (as reported by
Fradfcin, P.L., "The House that Snored," Audubon, Hay 1979, pp 86-93) has
recently shown that these mice do occur in places where they have not pre-
viously been detected, possibly indicating a highly tolerant nature not
previously suspected. Therefore, before any construction would be-under-
taken in such an area, a second trapping survey might be planned and, as
necessary, rerouting of the pipeline should salt marsh harvest mice be
identified.
8. Low oxygen levels during a transition period would result only if
the discharge were removed from Artesian Slough, and freshwater adapted
vegetation died off. ' A possible mitigation would be harvesting of the
freshwater vegetation. Maintaining a discharge as in No Further Action
will eliminate this transition period but cannot guarantee that no
periods of low oxygen levels would occur.

9. Your suggestions are acknowledged and these mitigation measures will
be considered should any construction be contemplated.

10. If SBDA and EPA had selected the Basin Plan Alternative, the partici-
pation of Leslie Salt in the project would have been given full consideration.
However, selection of No Further Action provides no forum for joint efforts
at this time. .
6. On page 173 (Section III.3.2 of the Draft Technical Volume), the
possibility of diversion of effluent for maintaining fresh water marsh
in Artesian Slough and/or creating fresh water marsh elsewhere is proposed
95

-------
                                                                     I He -
                                                     Dat«
St«.t» of California

Memorandum
To   :  Mr.  L.  Frank Goodson
       Project Coordinator
       Resources  Agency
       1416 Ninth Street
       13th Floor
       Sacramento, CA  95814
From  :  STATE WATER RESOURCES  CONTROL BOARD
       DIVISION OF WATER  QUA1ITY

Subject:  REVIEW  OF  DRAFT ENVIRONMENTAL IMPACT REPORT AND STATEMENT (EIS/EIR)  STATE
       CLEARINGHOUSE NO.  79040905, FOR SOUTH BAY DISCHARGERS AUTHORITY TREATED
       WASTEWATER DISPOSAL PROGRAM, PROJECT NO. 1135


       This office has reviewed the draft EIS/EIR of this project, dated
       November,  1978.  The Division of Water Quality hereby presents
       preliminary comments on the draft document.

       The EIS/EIR analyzes four "viable" alternative solutions to the water
       quality problems caused by the discharge of treated wastewater to
       San Francisco Bay  south of Dumbarton Bridge.  One alternative, the
       "Basin  Plan Alternative", contemplates a large pipeline to collect
       treated wastewater and discharge it north of Dumbarton Bridge.  Other
       alternatives analyzed are "No action beyond currently approved
       improvements at treatment plants", "Individual outfalls to Bay south
       of. Dumbarton Bridge", "Upgraded treatment with continued local
       discharge" and "Reclamation and Reuse" in Santa Clara or in Santa
       Clara and  San Benito Counties.  The EIS/EIR also analyzes a disposal
       system  meant to dilute toxic bitterns from the operation of salt
       evaporating ponds.
                                                                       THE RfSOURCES AGENCY
                                                                                        17
  ®
  ®
Comment. General

The EIS/EIR points out that  none  of the  alternatives analyzed, with
the possible exception of Alternative  5  (Reclamation and  Reuse) will
meet all requirements of the Basin Plan.   It  appears that a  reclamation
and reuse alternative can meet the national goal  set forth in the Clean
Water Act of 1977 (PL 95-217)  "that the  discharge of toxic pollutants
in toxic amounts  be prohibited."   The  letter  of  transmittal  quite
properly points out that "the  viability  of future full  reclamation is
being investigated in the Regional  Wastewater Reclamation Study,"
Comments on the Reclamation  and Reuse  Alternative are presented below.

Comment. Alternative 5 (Reclamation and  Reuse)

The EIS/EIR analyzes reclamation  and reuse in-basin and in the San Benito
Counties, not elsewhere.   The  choice of  alternative treatment systems,
specifically those parts  of  system B,  C,  and  D that are meant to comply
with the Department of Health  Services (DOHS)  requirements for spray
irrigation crops  with reclaimed water, lead to over estimates of the
cost of reclaimed water.   While it is  true that  Title 22  of  the Admini-
strative Code requires coagulation, sedimentation and filtration of
effluent for spray irrigation, it also allows for equivalent processes.
                                                                                             Hi-. L, Frank Goodson
                                                                                         ®
                                                                                         (D
                                                                                                                                  -2-
                                                                                             Based upon the results of the Pomona Virus Study (PVS), DOHS Is accepting
                                                                                             in-line coagulation preceding filtration as equivalent.

                                                                                             The DOHS accepted alternative system is much less cos'tly both in terms of
                                                                                             capital and operations and maintenance than the one used in the EIS.  By
                                                                                             using the more costly system, the cost of the reclaimed water is over
                                                                                             estimated.  We request that the appropriate changes be made and costs be
                                                                                             reestimated.

                                                                                             Comment. No Project Alternative

                                                                                             The draft EIS/EIR tentatively recommends a "no project" alternative, or
                                                                                             continuing wastewater discharges at the three present locations which are
                                                                                             south of the Dumbarton Bridge.  The Mater Quality Control Policy for
                                                                                             Enclosed Bays and Estuaries adopted by SWRC8 in Kay, 1974, prohibits
                                                                                             wastewater discharges to South San Francisco Bay below the Dumbarton
                                                                                             Bridge.  Although there is no provision for South Bay now, it is con-
                                                                                             ceivable, and would be consistent with other portions of the Bays and
                                                                                             Estuaries Policy that SWRCB would allow continued discharges of
                                                                                             wastewater effluents if it could be demonstrated that each of the three
                                                                                             discharges enhanced the water quality of the South Bay.

                                                                                             Enhancement is defined as:  1) full uninterrupted protection of all
                                                                                             .beneficial uses which could be made of the receiving water body in the
                                                                                             absence of all point source waste discharges along with 2) a demonstration
                                                                                             by the applicant that the discharge, through the creation of new
                                                                                             beneficial uses or a fuller realization, enhances water quality for those
                                                                                             beneficial uses which could be made of the receiving water in the absence
                                                                                             of all point source discharges.

                                                                                             The enhancement of South Bay water quality by continued wastewater
                                                                                             discharges should be discussed in the EIS/EIR.  Recommendations for"
                                                                                             a monitoring program,to demonstrate enhancement should also be included.

                                                                                             Comment. Water Quality Model

                                                                                             Review of the Hydroscience Water Quality Model by SWRCB staff and
                                                                                             Dr. Gerald Orlob has revealed that the model has significant limitations
                                                                                             for evaluation of wastewater discharge alternatives.  In lieu of the
                                                                                             predictions of the water quality model, selection of a project
                                                                                             alternative must be based on a comparison of the South Bay with other
                                                                                             similar estuaries.  It would be beneficial to include in the EIS/EIR
                                                                                             a discussion of the long-term impacts of wastewater discharges and
                                                                                             removal of wastewater discharges exemplified by other estuaries in
                                                                                             the United States or Europe.

                                                                                             Comment, Operation Impacts

                                                                                             One adverse impact of removing the wastewater discharges from their
                                                                                             present locations is the elimination of freshwater flushing and
                                                                                             consequently, the disruption of freshwater habitat in the South Bay.
                                                                                             What level of flow would be required to maintain this freshwater
                                                                                             habitat?
96

-------
Mr. L. Frank Goodson
-3-
®
Comment. Economic Impacts
The service charges listed in Chapter 3 of the EIS/EIR are only for those
costs associated with the Basin Plan Alternative. To'understand the full
economic impacts on the South Bay area, the existing 'service charges for
each SBDA member agency should also be included in the EIS/EIR.
As a funding agency the SWRCB reserves the right to make further conments
on this report prior to granting an EIS/EIR approval pursuant to the
Clean Hater Grant Regulations.
Should you have any questions regarding this review, please contact
Howard Wright at (916) 322-7734.
Dunham
Division Chief
Manager - Clean Water Grant Program
cc: Mr. Bill Helphingstine, EPA, Region IX
Submitted by: State Water Resources Control Board
Division of Water Quality
Dated:
14 May 1979
Response:
Thank you for your comments on the Draft EIR/EIS. You have raised several
issues which we feel require in-depth response; however, the funding of
additional studies which might answer these questions more fully is not
appropriate at this time.

1. No response required

2. Section V of the Draft EIR/EIS was meant to expand on the option of
partial diversion for reclamation in addition to another disposal system.
In Section V, a range of treatment schemes was selected to reflect both
Title 22 and agricultural requirements. This selection was not all-inclusive
nor could it be in the context of an EIR/EIS. However, it does provide a
range of costs and water qualities available in such an option to the extent
that the environmental impacts could be identified and disclosed.
The DOHS system you describe would be less expensive than subaltematlve B
(but not less than subalternative A), reducing the cost of component 2
(Coagulation and Sedimentation Treatment) by some amount less than 20 per-
cent of the total capital costs (see Table V-15, page 243, component 2).
It would be necessary to redesign and reestimate the DOHS system to provide
actual cost reductions as well as expected water quality. This type of
calculation would be an integral portion of any SBDA project for reclamation
for- Irrigation. SBDA is participating in the Bay Regional Reclamation Study
and detailed design, costing, and assessment of acceptable reclamation treat-
ment systems will' be a part of that study. In addition, a program to reclaim
2 ngd of San Jose/Santa Clara effluent for irrigation in the Milpitas area
(Phase I initiated by SCVWD) has been undertaken and appropriate treatment
measures are being considered in this study as well.
97

-------
 3.  This EIR/EIS does not define enhancement of beneficial uses, although
 it does state that the existence of the freshwater marsh in Artesian Slough
 is a benefit to the San Francisco Bay National Wildlife Refuge.  As such,
 maintaining this marsh might be considered as a condition for exception to
 the prohibition against discharge south of Dumbarton Bridge for San Jose/
 Santa Clara (page 188, Section IV.2.2 in Draft EIR/EIS Technical Volume).

 SBDA or its member cities, after completion and approval of the Final EIR/
 EIS, will have to petition SWRCB and RWQCB for exceptions to the Bays and
 Estuaries Policy and Basin Flan, respectively.  In this petition, a claita
 of enhancement might be made, and the details of such enhancement would
 have to be spelled out.  No specific monitoring program is being proposed
 at this time (see also response to County Sanitation District 4, item 8,
 in Section 2.2).

 4.  As stated In Exhibit III-l (pages 145-146 of Draft EIR/EIS Technical
 Volume), there are limitations to using a model to predict the effects
 of wastewater discharges.  The model uses average values for inputs, is
 two dimensional in a four-dimensional system, and does not predict biolog-
 ical Interactions.  Its use in this EIR/EIS was not intended for prediction;
 rather, using the same assumptions varied only changes in effluent and in
 discharge location, it was to be used to compare alternatives.  If the
 assumptions are internally consistent, then the differences between alter-
 natives might be perceived.  In this case, no significant differences could
 be shown for DO levels.  This lack of difference may be due to one of two
 factors:

    •  The model is not sensitive to the variation of inputs.
    •  The Bay is not sensitive to the variation of effluent
       (AWT vs Upgraded) or discharge locations.

 Dr. G.T. Orlob, in a review and evaluation of the model which was conducted
 under a contract to the SWRCB, makes the following statements about the
 capabilities and limitations of the model:
       "The model has many attributes that make it a useful tool,
       among these ... its utter simplicity and the ease with which
       it can be applied."
       This simplicity and ...  "the idealizations made in construct-
       ing the model  are limitations in its usefulness for study of
       South San Francisco Bay."
       "The most severe restraint
       state."
..  is the assumption of steady
       "The model is dependent on prejudgment of the patterns of
       net tidal circulation and on the corresponding water balance
       assumptions that must be made to satisfy continuity."
       "The kinetics of the model are much improved (over the 1968
       model) and ... are consistent with the best theoretical and
       empirical evidence available."
       " ... the tradeoff between benthal demand and reaeration is
       still In need of resolution."
       "Calibration of the model to the mean salinity profile does
       not confirm the general circulation pattern in the South Bay
       ... since by adjustment of dispersion coefficients one can
       obtain virtually any profile desired."
       "Improvements in the techniques of calibration and sensitivity
       testing are needed so that the relative importance of the
       various factors affecting model performance can be objectively
       assessed."
       "The most serious shortcoming of the model that compromises
       its usefulness as an analytical tool is its inability to
       discriminate between alternatives ... simply because the
       model ... is not sensitive to alternatives in the same way
       as is its prototype."
Therefore, Dr.  Orlob has concluded that the model Is not as sensitive to
the variation of inputs as is the Bay.  However, he also states that there
is insufficient information at this time to demonstrate the validity of
this contention, and that his professional judgment is that alternative
or supplementary techniques could resolve this issue.
98

-------
A literature review was conducted to identify reports of biological and
water quality improvements that have occurred in estuaries where waste-
water treatment has been upgraded. This search was selective, being
tailored to estuaries or bays having physical and chemical characteristics
reasonably similar to South Bay. Within this limitation, literature
documenting upgrading of water quality and biological conditions is not
available. A vast number of studies are available documenting deterior-
ation of water quality that has occurred due to urbanization of watersheds
and increasing waste discharge. The literature dealing with upgrading
does not discuss locations having much in common with South Bay.

W.T. Edmondson (1972) described the response of Lake Washington in Seattle,
Washington, to removal of secondary sewage effluent. During the period
1941-1963 Lake Washington received increasing amounts of effluent from
secondary sewage treatment plants. From 1963-1968, these effluents were
diverted in a series of steps, and discharge of effluent to the lake was
halted entirely in 1968. The condition of the lake improved rapidly and .
sensitively with the changes in waste input. In summer 1971, transparency
exceeded the 1950 condition and hypolimnetic dissolved oxygen was close
to the level of 1950. The improvement of the lake is greater than demon-
strated by data only.

Lake Washington and South Bay differ in several respects: salinity, climate,
freshwater inflow, and volume of wastewater discharge. The latter two are
of particular importance. South Bay experiences a dry season and a rainy
season. Average annual precipitation is 13 inches. In Seattle, precipi-
tation averages 32 to 48 inches and occurs more evenly throughout the year.
The quantity and seasonal distribution of runoff have an important influence
on water quality in urbanized watersheds where flood control has reduced
surface water discharge and where storm water runoff is typically of poor
quality. Finally, wastewater discharge to South Bay comprises 40 percent
of the annual freshwater inflow and is the only freshwater inflow in summer.
Lake Washington now has no wastewater inflow, and experiences a high degree
of natural flushing compared to South Bay.
Recovery of the Thames River Estuary has been monitored. A major improve-
ment in the quality of waste discharged occurred when a secondary treatment
plant was installed. The condition of the middle, most polluted reach of
the estuary, as judged by the dissolved oxygen content of the water, showed
a marked improvement in 1964, a few years after the installation of the
secondary treatment plant. In 1964-65 there was no anaerobic reach
established at any time, a situation that had not existed for decades.

The Thames Estuary differs considerably from South Bay physically, chemically
and biologically.

Other types of improvement are discussed by Pryblek (1977) for the Houston
Ship Channel and Galveston Bay. In addition to improvement in BOD, dis-
solved oxygen, fecal and total coliform, phosphorus, suspended solids, and
volatile.solids, waste treatment implemented since 1968 has reduced dis-
charges of cyanide, ammonia, phenol, metals, and sulfides. The latter group
includes many compounds that exert toxicity on aquatic organisms. Among
the effects of waste treatment that have been noted in the Houston Ship
Channel is the apparent increase in the variety and abundance of aquatic
life.

Again, however, there are many dissimilarities between the Houston Ship
Channel and South Bay. This report, as well as the others previously
cited, may be read as a.general indication of water quality improvements
resulting from upgrading of waste discharges. Due to the differences
mentioned between these water bodies and South Bay, as well as differences
in the nature of the upgrading situations from that of South Bay, predictive
interpretation of these reports is not possible.

Selected references to which the reader might refer are:
• Edmonson, W.T., 1972. "The Present Condition of Lake Washington,"
Verhandlungen Internationale Vereinigung Limnologie 18: 284-291.
99

-------

    •  Gameson, A.L.H.  and I.C.  Hart,  1966.   "A Study  of  Pollution  In
       the Thames Estuary," Chemistry  and Industry,  p. 2117-2123.
    •  Pryblek, W.,  1977.   "Texas Waterway Proves  Cleanup Tide  is Turning,'1
       Chemical Engineering 84(17);  98-102.
5.  In 1974, the low flow was  6S.1  mgd,  occurring in February and  in
December.  The low flow during the  dry summer months was  66.0 mgd, occurring
in May.  (Flows in 1974 were similar to 1971 flows and were down from 1973.)
It was at about this time that Bechtel and Fish and Wildlife Service  staff
noticed the presence of breeding snowy egrets in the rushes.  In 1977,
August low flows were 75.8 mgd in a 24-hour period, a greater flow which
possibly reflects the growth in area water consumption and use by  the
canners (a seasonal peak) even during a drought period.  And in this  season,
up to 250 pairs each of the black-crowned night herons and snowy egrets
were observed (Rigney, personal communication, 16 June 1978).  It  is  evi-
dent that the marsh persists in relatively good condition during these
low-flow conditions.  However, it is not possible to estimate whether or
not these are the minimum flows necessary to sustain the  habitat.   For
example, the vegetation now in the  Slough is salt tolerant - tidal influx
as well as residual salts in the slough sediments subject these plants to
"high-salt" conditions.  Therefore, the vegetation might  be able to with-
stand prolonged exposure to salty water without visible loss although the
bird colony might not be as tolerant.  Therefore, in order to determine
minimum flows necessary, flows would have to be reduced in stages  over
long periods of time, during which observations of colony behavior and on
plant species composition could be  made.  This experimental procedure would
likely endanger the well-being of the colony.

If a marsh that is in poor condition (e.g. does not contain vigorous  plant
growth or animal life) were to be converted to a high-quality'marsh,  It
would be attractive to waterfowl, a host of other migratory birds, and other
wildlife.  To speed the restoration of such a marsh, such plants as brass
buttons (Cotula coronopifola), alkali bulrush (Scripus robustus),  and hard
stem bulrush (Scripus acutus)  might be planted to encourage their establish-
ment.  Other plants 'such as dock, fat hen, wild radish, other forbes, and
grasses would invade parts of  the uplands.  Pondweeds would become established
in the water area.  It would be necessary to be able to regulate the water
flow, controlling frequency, duration, and depth of flooding.  At least 3 to
4 months of flooding, coupled  with substantial soil moisture throughout most
of the year, would be needed for the marsh,to retain its vigor.

The actual amount of water needed would depend on the soil type, salt in
the soil, microclimate of the  area, the amount of suitable land available,
and desired or required detention time.  For example, a shallow-water seasonal
wetland could be established that would be flooded only during the late fall
and winter months.  However, it would have wildlife-open space values
throughout the year.

On the other hand, a permanent marsh, partly or fully contained within dikes,
could be created.  The water depth would be a minimum of 3 feet, with depths
ranging between 4 to 6 feet.  This depth is needed to control the growth of
cattails and hardstem bulrush.  This emergent vegetation would be a fringe
marsh at the waterland interface of the dikes, nesting islands, or other
upland areas and selected areas.  The open water areas would contain pond-
weeds, which are excellent waterfowl foods.  Widgeon grass also would be
common.  Some stands of emergent vegetation would occur in selected areas
designed for that purpose by modifying the bottom elevation relative to
designed water levels.

The deep water and narrow interface limits the extent of emergent vegetation,
thereby providing suitable conditions for mosquito fish to control mosquitoes.
In addition, threadfin shad could be introduced to the area to feed on the
zooplankton and phytoplankton as well as provide a cash crop-fish bait.  Each
diked cell would be a pond-marsh ecosystem.  The actual type and extent of
vegetation could be controlled by total water management including water level,
the salinity of the water in the marsh, and the bottom configuration at time
of design and construction.
100

-------
1C might also be desirable to have both freshwater-type marshes and
brackish water-type marshes. The brackish marshes could have a salinity
range of between 4 and 8 ppt. The vegetation on the uplands, such as the
nesting islands, baffles, and dikes, would be a mixture of pickleweed, dock,
fat hen, salt grass, wild radish, gum plant, and thistles. The diversity
of terrestrial and aquatic plants and yearlong water supply could provide
very good habitat conditions for numerous species of wildlife.

6. The existing service charges and the charges attributed to Basin Flan
Alternative are compared for each city in Tables 2-2 through 2-4. These
values were calculated using the data presented on pages 162 and 163
(Tables 111-10, III-ll, and 111-12} of the Technical Volume of the Draft
EIR/EIS and various rate schedules provided by the cities of:
• San Jose. Sewer Service and Use Charge for Fiscal Year
1978-79, dated 2-May 1978
• Santa Clara. Resolution So. 3967 of the City Council,
effective 20 June 1978
• Sunnyvale. Resolution No. 413-77 of the Council, adopted
13 December 1977
• Palo Alto. Utility Rate Schedules S-l and S-2, effective
1 July 1979

It should be noted that charges to specific dischargers may vary with quan-
tity and quality of waste discharged (see Table 2-4) and may differ from
actual yearly billings. However, from the three tables it can be seen
that Basin Plan Alternative charges as calculated for the EIR/EIS could
account for as much as a 21.9 percent increase in charges (canners in
San Jose, not accounting for BOD, SS, or NH. surcharges) or as little as
a 0.5 percent increase for commercial users (restaurants) in San Jose,
Santa Clara, and Sunnyvale.
TABLE 2-2
COMPARISON OF ANNUAL SERVICE CHARGES FOR SAN JOSE,
SANTA CLARA, SUNNYVALE AND PALO ALTO - SINGLE FAMILY RESIDENCES
1979
Average User Charge Per
Single Family Residence
($) for Sewer and Waste-
1981/1982
Average User Charge Per
Single Family Residence
($) for Implementation of
City
San Jose
Santa Clara
Sunnyvale
Palo Alto
water Treatment
40.20
31.20
39,00
39.60
Basin Plan Alternative1
3.05
3.37
4.94
2.24
Only

from Table III-10, Technical Volume of Draft EIR/EIS.

101

-------
                                TABLE 2-3

               COMPARISON OF ANNUAL REVENUE REQUIREMENTS
         FOR SAN JOSE, SANTA CLARA,  SUNNYVALE AND PALO  ALTO  -
                       COMMERCIAL ESTABLISHMENTS
City/Category
          1979
 Charge ($)  Per Hundred
  Cubic Feet of Sewage
	Discharged	
       1981/1982
Charge ($) Per Hundred
 Cubic Feet of Sewage
      Discharged1
San Jose
  Total Commercial
    Restaurant
    Domestic Laundry

Santa Clara
  Total Commercial
    Restaurant
    Domestic Laundry

Sunnyvale
  Total Commercial
    Restaurant
    Domestic Laundry

Palo Alto
  Total Commercial
    Restaurant
          6.12
          2.76
          5.52
          2.28
          7.80
          4.20
          3.24,
         0.04
         0.03
         0.04
         0.04
         0.03
         0.04
         0.05
         0.04
         0.04
         0.03
         0.02
 ^Iculated  from Table III-ll, Technical Volume  of  Draft EIR/EIS by
 converting  annual  flow to hundred cubic feet and dividing into  annual
 revenue required.


 2Total commercial rates not available.


 TJo  breakdown  given for commercial users in  current rate structure.
102

-------
TABLE 2-4

COMPARISON OF ANNUAL REVENUE REQUIREMENTS FOR SAN JOSE,
SANTA CLARA, SUNNYVALE AND PALO ALTO - INDUSTRIAL USERS
City/Industry
1979
Charge ($) Per Hundred
Cubic Feet Discharge -
Noncrltical Users!
1979
Charge ($) Per Hundred
Cubic Feet Discharge -
Critical Users*
1981/1982
Charge ($) Per Hundred
Cubic Feet Discharge^
San Jose
Total Industrial
Electrical
Canneries
Santa Clara
Total Industrial
Electrical
Canneries
Sunnyvale
Total Industrial
Electrical
Canneries
Palo Alto
Total Industrial
Electrical
Canneries
4
3.48
8.28
4
2.28
5.40
3.364
4
4
4
4
1.08 0.12
^ n f\f
u.uo
0.73 . , 0.16
1.96, 0.09
r* n nr
. 0.05
0.09
3.03, 0.23
— 0.10
2.78 0.53
4 - . I'H '
4 65

Includes Industrial Cost Recovery-effective mid-1979. Noncritical user is one who uses less than
50,000 gallons per day or discharges wastes of uniform strength.

"Assumes average and annual flows shown in Table 111-12, Technical Volume, Draft:EIR/EIS. • Actual costs
would be calculated on a discharger-by-discharger basis and may also include charges for NH_, BOD, sus-
pended solids, etc. (these latter charges not included here). A critical user is one who discharges,
more than 50,000 gallons per day or wastes of varying strength.

Calculated from Table 111-12, Technical Volume, Draft EIR/EIS, by converting annual-flows to hundred
cubic feet and dividing into annual revenue required.
4
Values or rates not provided in rate schedules.

No canneries in Palo Alto (see Table 111-12 of Technical Volume * Draft EIR/EIS).
103

-------
 ENVIROTECH
BSP  One Oovis Drive
     Belmont, California 94002
     Telephone 41 S/S92.4060
     Telex 34- M86
                  2 0
                                                                                                          Letter to Environmental Protection Agency
                                                                                                          Re:   Draft EIR South Bay Discharges
                                                                                                                                              May 23,  1979
                                                                                                                                              Page 2
             Bay 23, 1979
             Environmental Protection Agency
             Region IX
             215 Fremont Street
             San Francisco,  CA  94105

             Attention:  Hearing Officer  HE-149

             Subject:  Draft EIR South Bay Discharges

             Dear Sirs:

             I attended the hearing at Santa Clara on Hay 17, 1979, and heard
             many points of view as to why this project should not go forward.
             I would like to offer another, and that is from the viewpoint of
             the fish.

             The current situation in the South Bay is that of an estuarine
             environment.  Freshwater from the treatment plants meets with the
             saltwater of the bay.  It is a place where life starts.  Small
             microorganisms thrive and support larger animals such as shrimp
             and so on up the food chain to major sport fish.  Evidence of
             these fish returning to the South Bay is accumulating.  A steel-
             head was taken at Palo Alto last year and there is evidence of
             striped bass as far as San Jose.

             Recent modification of the South Bay sewage treatment plants has
             significantly improved the water quality of the South Bay.  That
             improvement continues and should be thoroughly evaluated in a
             stabilized condition over a long period of time before further
             tinkering with the Bay.

             Shutting off this major flushing action of freshwater will signi-
             ficantly affect the salinity and biological activity of the South
             Bay.  This is important to fish.  Looking at page 11 of the Sumary
             EIR to see what the adverse impacts of losing that freshwater flow
             would be, we find:
                  Environmental
                     Aspect

                  Biology
                    Impact

                    Potential change in Biota
                    in South Bay as a result
                    of changed oxygen levels,
                    salinity
Beneficial or
   Adverse

Primary**
  Undefined
                                                                                       From the viewpoint of the  fish, we must  know the  adverse affects.
                                                                                       "Undefined" makes this environmental  impact report deficient  in
                                                                                       that this is a very major  change which could have disastrous  con-
                                                                                       sequences.  The report indicates salinity will  reach that of  open
                                                                                       water.  I don't believe that  and neither.do the fish.   The South
                                                                                       Bay is not open.  The tidal flow is not  adequate.   The  salinity
                                                                                       in the summer will increase to some unknown level above the sali-
                                                                                       nity of open water and the environment will change from that  of
                                                                                       an estuary to a saline lake.  The biological impact is  enormous,
                                                                                       yet the EIR totally fails  to  address  it.

                                                                                       I recently visited the Everglades where  I saw the results of  this
                                                                                       kind of tinkering.  A boat channel was opened into an inland  fresh-
                                                                                       water lake.  The tidal saltwater changed the lake to saltwater
                                                                                       and the biology changed completely.   Then the lake,  due to large
                                                                                       surface area, became more  saline and  nearly all species of'life died
                                                                                       out except migratory fish  tolerant of extra salty water.  It  took
                                                                                       them many years to learn what they bad done.  The error is now
                                                                                       being reversed and it will take many  more years to recover.

                                                                                       The fish don't care about  money or they  might like to make a  bet
                                                                                       with the person who indicated that short-term impacts will only bt
                                                                                       "two weeks at any point along the conveyance" (pg.  8 Summary).
                                                                                       If they cared about money  they would  wince at the heavy price tag
                                                                                       for a monstrous facility that has no  real benefit and plenty  of
                                                                                       environmental risk.  They  would laugh at the logic on page 16 of
                                                                                       doing it now because inflation will make it more  expensive in the
                                                                                       future.  They would suggest if you really care  about water qua-
                                                                                       lity in the Bay you would  take the $86 million  initial  cost and
                                                                                       the $320,000 annual cost and  buy back tideland  from the salt
                                                                                       companies to restore the original tidal  flushing  action.

                                                                                       The  Loma Prieta Chapter (Santa Clara and San Hateo) of the
                                                                                       Sierra Club and all fish urge a no project for  the South Bay.
                                                                                       Sincerely.
Daniel E. Myers
Conservation Coomittee/
Sierra Club

DH:wp

Enc:  2 Copies

cc:  Olive Mayer
     Mary Ann Hark
     Chapter Office
104

-------
Submitted by: D.E. Myers
Conservation Committee, Loma Prieta Chapter
Sierra Club
Dated:
23 May 1979
Response:
We appreciate your comments, and your recommendation for "No Further Action"
has been considered by EPA and SBDA in project selection. Issues have been
raised in this letter and specific responses are noted below.

The definition of changed salinities as "Primary, Undefined" was used for
the following reasons. While it is clear that freshwater and escuarine
species would be lost (page 11 of Summary, Draft EIR/EIS) and that this
loss is a direct (primary) effect of removal of effluent flows, the con-
clusion as to whether or not this is adverse cannot be made without a.
definition of the preferred aquatic system. The change in salinity could
be considered beneficial to salt-tolerant vegetation, birds, and marine
fishes. It is definitely adverse to freshwater species and to anadromous
species such as steelhead and striped bass.

In the Technical Volume, Figure III-2 (page 150), it is shown that salinity
will increase significantly, particularly during the dry season in the
sloughs. This elevated salinity (expressed as greater than 16,000 rag/I
chloride) is greater than open water north of Dumbarton Bridge. During
wet seasons, the salinity is projected to decrease to a low of 9000 mg/1
chloride in sloughs, resulting in a highly variable environment which would
likely be conducive to populations of only the most euryhaline species.
The description of "short-tern" (i.e. i...-9-week) effects refers only to
construction impacts. Operational effects would be long-term, indeed
permanent, unless the system were abandoned at some future date.

The discussion under "Ho Further Action" as to the potential increased
cost and possible loss of grant subsidies with delay does point out a
disadvantage of this alternative. Should monitoring demonstrate continued
problems with water quality requiring new construction (treatment or dis-
charge) , the SBDA member cities would have to consider cost to their
residents of such a corrective action. Therefore, as there are.insufficient
data at this time to select an alternative which guarantees protection of
beneficial uses, SBDA, its member cities, and the residents of the area
are making a project alternative selection based on the assumption that
they'will not have to build a new, more costly system at a future date,
without state or federal assistance to lessen the burden on the consumers.

The U.S. Fish and Wildlife Service now manages many of the Leslie Salt
Company ponds on the east side of the Bay and has plans for marsh res-
toration and/or creation in some units of the refuge. While this may
result in some improvements in habitat quality, Increased tidal flushing
would require opening the Dumbarton Narrows where fill has been placed for
bridge approaches. In addition, channelization and damming of streams for
water supplies in the Santa Clara County area results in reduced stream
flows to the Bay, even during the wet season. It is not likely that any
modifications could be made to South Bay at this time which vonld restore
the original tidal flushing action.
This impact is significant although the magnitude of impact can only be
qualitatively described and, again, the degree of adversity depends on
what the refuge and the public desire to occur In the area.
105

-------
           UNITED STATES
DEPARTMENT OF THE INTERIOR

        OFFICE OF THE SECRETARY
          PACIFIC SOUTHWEST REGION
    BOX 3BOB8  . 49O GOLDEN GATE AVENUE
       BAN FRANCISCO, CALIFORNIA B41O2
               1415) 556.82OO
                                                                           IX
   ER 79/324
               Mas'22'1979
                                                              "SKGCuau:
                                                             MAY 2 9 1979

                                                               ItDSlON DC
   Paul De Falco, Jr.
   Regional Administrator
   Environmental Protection Agency
   Region IX
   San Francisco, California

   Dear Mr. De Falco:

   We have reviewed the araft EIS for the Treated Wastewater Disposal
   Program for South Bay Dischargers Authority, Santa Clara County,
   California, and include the following ocnnents for your consideration.

   General Ocnnents

   We are pleased that efforts are continuing to further improve the water
   quality of South San Francisco Bay.  We note that the water quality of
   the South Bay has inproved significantly in recent years, and it now
   supports fish species that have been absent for many years.

   The study mentions a number of existing and proposed park and recreation
   areas which could be indirectly impacted by one or more of the various
   construction activities for the proposed alternatives.  We suggest that
   siting ana effluent discharge routes be selected which would minimize
   such impacts to the fullest extent.  It should be noted that both the
   Mountain View Shoreline Park and the Menlo Park Baylands Area have been
   funded through the Federal Land and Water Conservation Fund Act (Public
   Law 88-578, as amended}.  Section 6(f)  of the Act states, "No property
   acquired or developed with assistance under this section shall, without
   the approval of the Secretary (of the Interior), be converted to other
   than public outdoor recreation uses."  If any of the alternatives
   affects such parks, there should be consultation with Mr. Russell
   Canill, Director, California Department of Parks and Recreation, who
   is the State Liaison Officer for the land and Water Conservation Fund
   in California.  His address is 1416 Ninth Street, P.O. Box 2390,
   Sacramento, California 95814.

   We notice that the Wastewater Disposal  Program should not adversely
   affect mineral development in the South Bay area.  A benefit will accrue
   to the salt industry by allowing sane disposal of the bitern salts that
   new are being stockpiled.
We observe that implementation of alternative I, the deep water outfall,
would preclude any potential for local and national environmental and
economic benefits that may accrue from other alternatives.  On the other
hand, alternative II, continued discharge but with completion of plant
inprovements that are underway, may produce improvements in wastewater
quality that will provide benefits that will make alternative I unneces-
sary.  The San Francisco Bay Area Regional Municipal Wastewater
Reclamation Study, new underway, may identify wastewater reclamation and
reuse projects that will require transport facilities to areas away from
the Bay and eliminate a need for a deep water outfall.  The national
interest would be better served if the funds proposed for the deep water
outfall were used to assist in construction of wastewater reclamation
and reuse transport and storage facilities.

In general, projects that would result in inproved water quality receive
our support and encouragement.  Occasionally, however, special circum-
stances cone into play which complicate our evaluation.  The freshwater
inflow from the San Jose-Santa Clara Treatment Plant into Artesian
Slough is such a case.  Mast of the freshwater marshes in the San
Francisco Bay area have been lost because of diking, filling, channeli-
zation, intensified but short-term runoff froit developed areas, and
upstream reservoir storage.  The few remaining freshwater wetlands are
extremely important because of their scarcity and because several
wildlife species depend on this type of habitat for portions of their
life cycle.  The discharge of treated wastewater to Artesian Slough has
resulted in the development of a narrow band of freshwater wetland about
6,000 feet long consisting primarily of bulrush and cattail.  This
freshwater wetland is one of the few locations in the San Francisco Bay
area where ducks have been successful in rearing broods.  The combina-
tion of adequate cover and a source of freshwater (young ducklings need
freshwater until their salt glands develop) is necessary for survival.
A rookery used by black-crowned night heron, great blue heron, snowy
egret, and common egret within -the Artesian Slough environs is the only
rookery, other than the one at Blair Island, in the South Bay.  This
freshwater marsh is also the breeding area for a rare bird, the salt
marsh yellowthroat.

In addition, the San Francisco Bay National Wildlife Refuge's master
plan includes the development of the New Chicago Marsh Unit near
Alviso.  The Refuge's Environmental Education Center would be used by
local school and environmental groups in marsh and bay ecology as the
water progresses from fresh to saline conditions.  It is hoped that
treated wastewater from the Santa Clara - San Jose Treatment Plant
would be available for use in the development of New Chicago Harsh.
                                                            v
Under the selected project alternative, the cessation of wastewater
flow to Artesian Slough would result in the return of saline condi-
tions.  Salt-tolerant plant species would replace the existing
106

-------
vegetation and would provide for a reduced level of habitat diversity.
Alternative 4, which calls for upgraded treatment and continued
discharge to existing locations, would preserve the freshwater marsh
area. This is our preferred alternative assuming the implementation
of advanced treatment measures bo meet the 5 mg/1 dissolved oxygen
requirement (receiving water minimum) and to eliminate the input of
toxicants through source control and pretreatment processes rather
than by utilizing the receiving water as part of the treatment process,
i.e., discharging wastewater to deepwater locations because of the
greater dilution potential. We believe cur view is consistent with
the objectives of the Clean Water Act which states that 'It is the
national goal that the discharge of pollutants into the navigable
waters be eliminated by 1985."

We believe the freshwater marsh along Artesian Slough is important to
wildlife in terms of productivity and diversity and that the removal of
the freshwater source will greatly reduce, if not completely eliminate,
the existing values. We believe advanced treatment methods are avail-
able and can protect the beneficial uses of the receiving water. In
the event that the "basin plan' alternative (discharge north of the
Dumbarton Bridge) is selected, provisions for the release of enough
freshwater to Artesian Slough to maintain the freshwater marsh should
be included.

Specific Conroents

Appendix J. In reference to cultural resources, we strongly support
the reccmnendations of Research Services, Incorporated (Appendix J),
particularly that sub-surface examinations be conducted prior to
trenching activities in sensitive areas. Also, in the event that
historic landings are encountered during excavation, we recommend
immediate consultation with the State Historic Preservation Officer,
Dr. Knox Mellon. He can be contacted at 1220 K Street, Box 2390,
Sacramento, California 95811.

Sincerely yours.
cc:
Patricia Port
Regional Environmental Officer

Director, OEPR
Director, Heritage Conservation and Recreation Service
Director, Bureau of Reclamation
Director, Bureau of Mines
Reg. Dir., HCRS
Reg. Dir., BR
Reg. Dir., BM
cc: Director, Fish & Wildlife Service
Director, National Park Service
Director, Geological Survey
Director, Office of Surface Mining
Director, Bureau of land Management
Reg. Dir., FWS
Reg. Dir., UPS
Asst. Dir., GS
Reg. Dir., OSH
Reg. Dir., BIM
SHPO
107

-------
Submitted by:  U.S. Department of Interior
               Pacific Southwest Region
               450 Golden Gate Avenue
               San Francisco,  California  94102
Dated:
Response:
               22 May 1979
Thank you for your comments on the Draft EIR/E1S,  in which a number of
issues were raised.  These issues are addressed below in the context of
a decision to select the "No Further Action" alternative.

1.  The Basin Plan Alternative routing (both on land and estuarlne)  crosses
only the proposed Palo Alto Baylands Reserve In an area previously  disturbed
by the construction of the Mountain View Connecting Sewer.  No other park-
lands would be affected with those routings, although the alignment is  near  •
a number of proposed parklands.  Should EFA or SBDA consider further
activities in the area, we will consult with Mr. Cahill as you suggest.
also responses to Drs. Shellhanmer and Harvey, California Fish and Game
and State Water Resources Control Board in Section 2.2).

5.  Modeling studies do not show compliance with the 5.0 ffig/1 oxygen
requirement after upgrading treatment of San Jose/Santa Clara (see
Figure IV-8, page 194 of Draft EIR/EIS Technical Volume).  Additionally,
this alternative - Upgraded Treatment - calls for addition of treatment,
beyond currently Implemented advanced waste treatment (see responses to
Drs. Shellhamner, Harvey, and Mewaldt in Section 2.2).

6.  Should any construction be undertaken in this area, the recommendations
in Appendix J and, as stated on pages 92-93 of the Draft Technical Volume,
will be followed by EPA and SBDA, and contact with Dr. Mellon will be
established in the event of any archaeological or historic discoveries.
2.  Since no disposal system will be built,  it  will not be possible for
Leslie Salt Company to dispose of bittern through the SBDA system.   This
is a potential disbenefit  to both the company and the San Francisco Bay
National Wildlife Refuge unless these entities  can arrive at their  own
independent alternative to stockpiling.

3.  The improvements in wastewater quality described for No Further Action
would accrue to all alternatives; in fact, Upgraded Treatment and Reclamation/
Reuse would further increase effluent quality in  San Jose.  However, selection
of "No Further Action" precludes action  on reclamation/reuse under  this grant
program.  Should SBDA decide to initiate such a program in the future as a
disposal alternative, the  Authority would have  to reapply for funding.

4.  Reclamation/reuse in maintaining Artesian Slough or in marsh building
or enhancement may be acceptable to the  State and Regional Boards  (see
108

-------
                                                             CMC-iff) 2 2

                                                              District:
DlE£CCoe.,
351
SAW Jose, G&£if 951(6
(406)
                                            COMM CNTK

                                       H*y ?3  /I tf, •
                                                    May 22, 1979
                                                              REGIONAL HEARING CLERK
                                                                MAV31  1979  p
              Environmental  Protection Agency
              Region IX,  21S Fremont Street
              San Francisco, California  94105

              Attention:   Mr.  Paul DeFalco, Regional Director

              Dear Mr.  DeFalco:

              Subject:   South  Bay Dischargers Project

              Since the Draft  EIR/EIS for The Treated Wastewater Disposal  Program
              for South Bay  Dischargers Authority is under review at this  time, I
              feel that it is  imperative that several broader points be considered
              concurrently with  the finalization of the subject report:

                   1.   As outlined in the attached letter, I have already  expressed
              opposition to  the  proposed EPA regulation changes concerning the  fund-
              ing of reclamation projects which go beyond the existing effluent
              discharge requirements.  Not knowing the prospects of successfully
              reversing these  proposed funding restrictions, it is crucial that
              we approach the  situation in the South San Francisco Bay with an
              awareness that all funding for reclamation could be lost if  it  is
              implied that the receiving waters can now, or in the future, accept
              the discharge  of treated effluent from the cities of North Santa
              Clara County.

                   2.   I do  not  believe the capabilities of the Bay mathematical
              or physical models can absolutely predict the quality of the Bay
              under future conditions (including Delta outflow and the Peripheral
              Canal) that are  as yet unknown.  For this reason, I support  a continued
              and increased  monitoring program with a major emphasis on the potential
              eutrophication of  the estuary at its southern extremity.  Obviously if
              algal blooms became prevalent under future conditions, all the  efforts
              to date to assure  high dissolved oxygen levels in the Bay would have
              failed,  as the decaying biomass began to consume all oxygen  present,
              returning the  South Bay to a septic condition.

                   3.   While the above position seems to be implied though not
              stated in the  Draft EIR/EIS for the project, a recommendation for
              a "No Project  Alternative" continues to be proposed.  While  I believe
                                                                                                             Mr. Paul DeFalco
                                                                                                                                           -2-
                                                                                                                                                                 May 22, 1979
that State and local monitoring should continue,  I  fail to see the
need to reach this decision at this point and run the risk of for-
feiting the construction grants which provide the only logical and
feasible method of financing reclamation of Santa Clara County's
treated effluent.  Since considerable market studies are underway
by the Santa Clara Valley Water District in cooperation-with the
California Department of Water Resources, and funded primarily by
E.P.A., it appears to be premature to reach a. final conclusion on
the ultimate disposition of the treated effluent  at this tine.  It
does however appear that reclamation or land disposal of effluent
would be more cost effective than an outfall disposal system or
further physical/chemical treatment with its inherent energy demands
and sludge disposal problems.  Both the County and  Regional Recla-
mation studies indicate that conveyance of these  treated effluents
to major markets  are competitive with the costs of  alternative new
water sources.

In view of the myriad of unknowns regarding the environmental,
economic and institutional problems facing the residents of Santa
Clara County's Water Users and Dischargers, I believe it is in the
best interest for all that this decision be delayed until a more
definitive and positive program can be implemented.
                                                                                                             Very trul
                                                                                                               trick T. Ferraro
                                                                                                             Chairman
                                                                                                             Board of Directors

                                                                                                             Attachment

                                                                                                             cc:  Members, South Bay Dischargers Authority

                                                                                                                  Mr. Tom Harris,  San Jose Mercury 5 News
                                                                                                                    7SO Ridder Park  Drive, San Jose, CA   95190
District office  5T5O
                                     expaessvjty  SMI Jose,   95116   2&s-2£>oo
                                                                                                                                                                         109

-------
Submitted byt  Patrick Ferraro
               Director, District 2 Santa Clara Valley Water District
               351 Brookwood Drive
               San Jose, California  95116
Dated:
22 May 1979
Response:
Delay of a decision on disposal alternatives would be in violation of
existing NPDES permits for the members of SBDA.  In addition, SBDA is
participating in the Regional Reclamation Study independent of this
EIR/EIS work, as well as several small (2 mgd) local studies including
Milpitas irrigation study initiated by SCVWD.  This regional study may
well find cost-effective markets for wastewater but funding for the
disposal system cannot be transferred to such a study.  Should SBDA
decide to Implement reclamation/reuse as an alternative to disposal, it
may reapply for grant funds at that time.
110

-------
Stol. of California

Memorandum

To   i  U. S. Environmental  Protection Agency
       Region IX, Attn: Hearing Office (HE-14?)
       215 Fremont Street
       San Francisco, CA   94105
From  ,  Sm frwncbca Bay Regional Water Quality Control Board
       1111 J.du.. IMM, Ofldmmi MMT


Subjects  SB DA EIR/EIS - Treated Wastewater Disposal  Program
   Tho Re»urc*s Agency of Callfernlo

                (He->4i^  23


Dot,,     May 30.,  1979

File No. 2428.8056 (HJA)  vjw



          RECEIVED
   rtPQIONAL HEARING CLERK

         JUKI   1979

           REGION DC
       We have reviewed the subject draft EIR/EIS, and are not satisfied with the
       thoroughness of the report with regard to discussion; of the San Francisco Bay
       Water Quality Control  Plan (Basin Plan), heavy metal impacts, botulism, and
       water quality monitoring.  Our concerns regarding the above Issues have been
       explicitly discussed in previous correspondence (April 21, 1978) to the State
       Mater Resources Control Board (attached).

       We cannot accept the current EIR/EIS as being satisfactory until the following
       issues have been adequately addressed:

       Conformance With the Basin Plan'(page 4)

       Our previous comments regarding conformance with the Basin Plan were as follows:

          "The following requirements are identified in the Basin Plan."

          "It shall be prohibited to discharge any wastewater which has particular
           characteristics of concern to beneficial uses:

             1) At any point at which the wastewater does not receive a
                minimum initial dilution of at least 10:1.

             2) Into any nontidal water or dead-end slough or similar con-
                fined water areas or their immediate tributaries.

             3) Into San Francisco Bay south of the Dumbarton Bridge."

          "Exceptions to each of these will be considered where the discharge
           is approved as part of a reclamation project or where it can be
           demonstrated that a net environmental  benefit will be derived
           from such a discharge,"

          "We request that the discharge prohibitory as given in the Basin Plan
           be identified in the EIR/EIS.  In addition, as part of the analysis of
           those alternatives which do not conform to the discharge prohibitions,
           consideration should be given to the conditions necessary for exceptions
           to the Basin Plan.  Please note that these analyses should be done on
           an Individual basis for the San Jose/Santa Clara, Palo Alto, and
           Sunnyvale treatment plants,"
U. S. Environmental Protection Agency
                                   ®
                                                -  2  -
May 30, 1979
Although the current draft EIR/EIS discusses the prohibitions of discharges
identified'in the Basin Plan, no mention is made of the conditions necessary
for exceptions to the prohibition'of discharge and now alternatives not
conforming to the discharge prohibitions will  meet those conditions.  He request
that your commitment to these exception condi.tions.be Identified and discussed
in the final EIR/EIS.

Heavy Metals (page 57)

Our prior comments regarding heavy metals were:

    "There is no discussion of heavy metal concentrations and their
     potential impacts on receiving water biota Included in the
     EIR/EIS."

    "The highest concentrations of dissolved metals in the Bay  regularly
     occur below the Dumbarton Bridge.  It is estimated that SIX (52
     metric tons annually of the heavy metal loading to the Bay south
     of.Hunters Point is discharged into this area,  This corresponds
     to only about 8% of the water volume of the Bay below Hunters Point."

    "The metals of principal concern, as expressed by Or, Girvin in a
     preliminary report to the Regional Board, are copper and silver.
     It is our recommendation that the level of observed concentrations
     of heavy metals in the South Bay be compared with chronic  toxicity
     levels identified in the literature and that their potential for
     biomagnification be assessed."

A discussion of heavy metals, similar to our comments, has been included in the
current draft EIR/EIS,  Nevertheless, the discussion is not sufficient since
there is no mention of the relationship of observed concentrations of 'heavy
metals in the South Bay and chronic tbxicity levels identified  in the
literature and their potential for biomagnification by the continued discharge
of heavy metals.  He request that these issues be discussed in  the final
EIR/EIS and that necessary mitigation measures be included. These should
include a discussion of the source control programs and their costs necessary
to reduce the discharge of heavy metals,

Botulism (pages 76 and 152^

Our concern about the history of outbreaks of botulism in .the South Bay and
the potential causes of avian botulism were expressed in our previous comments.

    "It is noted in the EIR/EIS that in 1975 a moderately severe outbreak of
     botulism occureed in Artesian Slough, Coyote Creek, and Mud Slough.
     About 2000 birds contracted the disease.  In 1974 nearly  13,200 water-
     fowl died.  The extent of the discussion of the causes of  botulism
     Is limited to the following sentence;  'No data exist at  this time as
     to the exact cause of  botulism outbreaks, although they are clearly
     related to anaerobic sediment conditions that may be aggravated by
     waste discharge.1"
                                                                                                                                                                         111

-------
U. S. Environmental Protection Agency
- 3 -
May 30, 1979
U. S. Environmental Protection Agency
- 4 -
Kay 30, 1979
The decision to only Identify the botulism problem and not to discuss
its potential causes is apparently based on the fact that the "exact
cause of botulism outbreaks" is not known. We do not believe this to
be acceptable rational for overlooking the botulism question. A
thorough analysis of the potential causes of botulism should be Included
In the EIR/EIS."

"The following is a brief summary of the available information concerning
botulism. A brfef discussion with respect to implications in the South
Bay is included.1'

''Botulism is a paralytic disease induced by the ingestion of food which
contains toxin from the bacterium Clostirdium Botullnuin. The Bacillus
is divided into seven types. Type Cj is a soil bacterium and is
responsible for waterfowl botulism found in the western United States.
It is an obligate anaerobe. Its optimum growth temperature is
generally between 25 & 30°C with production of toxin greatest at 280C.
C. botulinum does not grow well in salinities above 30 ppt."

^Decaying anaerobic organic matter is required by C. botulinum for
growth and the production of toxin. The organic matter may be
vertebrates. Invertebrates, submerged grain, or possibly other decompos-
ing bottom material. Birds eat these materials, accumulate the
toxin, and die. The important point is that anaerobic conditions roust
occur either in a mlcroenvironment such as in the dead bodies of
veterbates & invertebrates or in a more widespread environment such
as bottom sediments."

"The Initial cause of botulism may be an environmental change that
kills aquatic invertebrates or fish. The accidental death of a
waterfowl or fish from natural causes also can trigger a botulism
outbreak. In such cases fly larvae Infest a dead fish or bird,
concentrate the toxin and being a favored food of waterfowl result in
posioning. Thus death of a single bird can lead to a botulism outbreak
as more birds in turn die and are fed upon."

'' Besides the proper medium for the growth of Clostridium botulinum,
temperature and .salinity are important and may be controlling in the
South Bay. As mentioned above a temperature of 25 to 30°C 1s optimal.
Also, C. botulinum apparently will not grow well in salinities greater
than 30 ppt."

%> Outbreaks of botulism in the South Bay have been for the most part
localized in Artesian Slough, Mud Slough and the upper end of Coyote
Creek. Numerous dead birds have also been'taken from the Sunnyvale
oxidation ponds,"
®
®
"Below the confluence of Hud Slough and Coyote Creek water temperatures
consistently average about 20.5°C in August and September. From that
point in towards the San Jose outfall water temperature rises at a
rate of about 2°C per mile reaching about 27°C at the outfall, the
temperature of the San Jose effluent. At the same time low salinity
levels are created by the fresh water discharge. It therefore appears
that the San Oose discharge may create an environment favorable for
the growth of C. botulinum and that it may be a significant factor in
the botulism outbreaks which occur in the South Bay. Fresh water in
the Sunnyvale oxidation pond may also provide favorable conditions for
toxin production."

The current EIR/EIS does include a discussion of probable causes of avian
botulism which concludes that depressed salinities and dissolved oxygen, elevated
temperatures, and treated sewage are factors which may contribute to outbreaks
of avian botulism. However, given the factors that are thought to be linked
to outbreaks to avian botulism, no attempt has been made to assess how each
of the alternatives may influence the probability of future outbreaks af
avian boutlism in South San Francisco Bay, We recommend that such an assess-
ment be made in the final EIR/EIS and that necessary mitigation measures be identified.

Hater Quality Monitoring

In the discussion of alternatives to the basin plan (page 181), it is briefly
mentioned that for no action beyond currently approved improvements at the
treatment plants, a water quality monitoring program would be needed to
determine "the effect of the approved upgraded treatment on the Bay environment"
(page 188), However, no attempt has been made to elaborate on the scope of
such a monitoring program.

In order to fully evaluate the impacts on aquatic biota of a continuing waste-
water discharge (with upgraded treatment) at the present locations, several
questions would need to be answered. For example, what are the acute and
chronic (long-term) effects of the discharge on aquatic organisms? What
are the effects of the discharge on primary productivity? To what extent are
the behavioral patterns (spawning, migration, avoidance reactions) of fish
and macroinvertebrates affected by the discharge? What is the potential for
bioaccumulation of toxicants by aquatic organisms? To what extent are harbor
seals affected by the discharge? Furthermore, no attempt has been made to
(1) discuss the physical and biological analyses to be done; (2) estimate the
economic costs of conducting an intensive monitoring program of the scope that
would be needed to determine the impacts of a discharge of tertiary-treated
wastewater on aquatic organisms; (3) estimate the length of time that would
be needed for ah'adequate monitoring program in order to make an assessment
of the impacts of the discharge; or (4) describe methods of data evaluation.
112

-------
 U.S. Environmental Protection Agency
                                             -  5 -
May '30, 1979
 Conclusion

 The Regional Board staff is of the opinion that the current EIR/EIS  is not
 satisfactory since relevant information regarding heavy metals  -  the
 relationship of observed heavy metal concentrations in the South  Bay and
 chronic toxicity levels identified in the literature,  and their potential for
 bioaccumulation associated with the continued discharge of heavy  metals - and
 avian botulism - an assessment of the potential for outbreaks of  avian
 botulism with each of the wa'stewater disposal alternatives - has  not been
 discussed or evaluated.  The requested information is  essential if an adequate
 assessment of the impacts of effluent discharges on aquatic biota is to be
 made.

 Also, a discussion of the conditions necessary for exceptions to  the Basin
 Plan's prohibition of discharge, and how alternatives  which do  not conform  to
• the prohibitions of discharge will meet those conditions, is not  Included in
 the EIR/EIS,  The lack of adequate information or commitments on  the latter
 point precludes us from considering exceptions to(he discharge  prohibitions
 in the Basin Plan at this time.

 Finally, relevant information (i.e., cost, total time  devoted to  monitoring,
 data evaluation) regarding water quality monitoring of the effects on aquatic
 organisms of a discharge of advanced treated wastewater for the "no  project
 alternative" has not been Included in the EIR/EIS,

 We request that all of our concerns expressed herein be identified and
 adequately addressed in the final EIR/EIS.

 Should you have any questions regarding this matter, please contact  Mike Aronann
 at (415) 464-1357 or Steve Morse at (415} 464-0618.
                                        FRED H. DIERKER
                                        Executive Officer

 Attachment:  Comments of April 21, 1978, to State Board

 cc:  without attachment
      Neil Dunham, State Water Resources Control Board
      Kike Rugg, Department of Fish and Game, Yountville
U. S.  Environmental  Protection Agency
                                                                                                                                             -  6 -
Hay 30, 1979
                                   cc:   (continued)

                                        City of Sunnyvale
                                        City Hall
                                        P.  0. Box  607
                                        Sunnyvale,  CA    94088

                                        City of Palo Alto
                                        250 Hamilton
                                        Palo Alto,  CA       94301

                                        City of San Jose
                                        City Hall
                                        San Jose,  CA       95110

                                        City of Santa  Clara
                                        City Hall
                                        1500 Warburton Avekue
                                        Santa Clara, CA      95050

                                        South Bay  Dischargers Authority
                                        c/o A. R.  Turturici
                                        Department of  Public Works
                                        City of San Jose
                                        City Hall,  Room 408
                                        San Jose,  CA     95110
                                                                                                                                                                         113

-------
 TO-   Neil Dunhum
      Chief, Division of Water Quality

DATE:  _ April 21, 1978	
                                  WATER QUAUITV CONTROL B-^RD
                           ,,,N  FRANCISCO  BAY REGIO..              (Me-»«d)  23
                                     INTERNAL MEMO  Tile No, 31.28.8056 (RJli) vjw
FROM1  ^rel' "• Eierker,  Executive Officer

        Region 2\     ^^
                                            SIGNATURE:
 SUBJECT:   SBDA EIR/EIS - Treated Wastewater  Disposal Program


       At our meeting of March 29, 1978  with staff of the-Division of Water Quality
       and the Division of Planning and  Research we were requested to provide
       additional information on the inadequacies of the South Bay Discharge
       Authority's EIR/EIS.  Hopefully this further amplification of our concerns
       will be useful in the development of the EIR/EIS and will lead to a concensus
       on the best means of wastewater disposal for the South Bay dischargers.

       It is our opinion that adequate information with respect to the following
       items has not been presented in the current draft of the EIR/EIS.  We cannot
       accept the EIR/EIS as being complete until each item has been thoroughly
       addressed.  These include:

          1.  Conformance with Basin Plan
          2.  Dissolved oxygen modeling  predictions
          3.  Toxicity
          *).  Heavy metals
          5.  Botulism

       Confor-mance with the Basin  Plan

       The following requirements  are identified in the Basin Plan.

          It shall be prohibited to discharge any wastewater which has
          particular characteristics of concern to beneficial uses:

              1)  At any point  at which the wastewater does not receive
                 a minimum initial dilution of at least 10:1.

              2)  Into any nontidal  water or dead-end slough or similar
                 confined water  areas or their immediate tributaries.

              3)  Into San Francisco Bay south of the Dumbarton Bridge.

          Exceptions to each of  these will be considered where the discharge
          is approved as part  of a reclamation project or where it can be
          demonstrated that  a net  environmental benefit will be derived
          from such a discharge.
                                                                                               Neil Dunhum
                                                                                               Chief, Division of Water Quality
                                                                                          - 2 -
                                                                                                                                                        April 21, 1978
                                                   The  prohibition of discharges to San Francisco Bay south of the Dumbarton
                                                   Bridge has been noted in the EIR/EIS.  However, no mention is given of the
                                                   10:1 initial dilution requirement or the prohibition of discharges to
                                                   dead-end sloughs-  Also, the conditions required to be granted exceptions to
                                                   the  three discharge prohibitions have not been identified or discussed.

                                                   We request that the discharge prohibitions as given in the Basin Plan be
                                                   identified in the EIR/EIS,  In addition, as part of €he analysis of those
                                                   alternatives which do not conform to the discharge prohibitions, consideration
                                                   should be given to the conditions necessary for exceptions to the Basin Plan.
                                                   Please note that thes« analyses should be done on an individual basis for the
                                                   San  Jose/Santa Clara, Palo Alto, and Sunnyvale treatment plants.

                                                   Dissolved Oxygen Modeling Predictions

                                                   The  current draft of the EIR/EIS incorporates without discussion the Hydro-
                                                   science modeling results for dissolved oxygen.  Because dissolved oxygen is
                                                   of primary importance in the evaluation of alternative disposal sites,  it is
                                                   necessary that the accuracy of predicted D.O. concentrations be carefully
                                                   delineated.  This is of particular importance in the case of the South Bay
                                                   Dischargers disposal study due to the fact that the type of model used and
                                                   corresponding assumptions needed to approximate observed D.O.. concentrations
                                                   in the Bay do not represent the physical system.  Of particular significance
                                                   in this respect is the inability of the model to incorporate tidal effects
                                                   or biological productivity.

                                                   It is our recommendation that  a discussion of the assumptions and the
                                                   accuracy of the model be included in the EIR/EIS.   The current Hydroscience
                                                   sensitivity analysis and Dr. Orlob's review of the model are sources of
                                                   this information.  Where used,  the modeling results for dissolved oxygen
                                                   should be carefully qualified.   Because use of the Hydroscience modeling
                                                   is limited, it should not be-used as the sole tool to predict water
                                                   quality.  There is a need,  therefore,  for a more qualitative evaluation
                                                   of discharges and their impacts on the South Bay which includes consideration
                                                   of the factors the water quality model does not address.  Dr. Smith's
                                                   evaluation of his monitoring activities this last  summer is one source  of
                                                   such information.

                                                   Toxieity
                                                  It is noted in the EIS  that  "oince  segments  of the  Bay  exhibiting relatively
                                                  greater loxicitico are  often areas  where major municipal or industrial waste
                                                  outfalls are located, potential  cause  and  effect  relationships exist.
                                                  Certainly undiluted sewage effluent is toxic to most  aquatic animals.  Much
                                                  research is necessary,  however,  to  determine the  nature of the potential
                                                  interaction between the general  toxicity of  waste effluents and the Bay
                                                  system."
114

-------
Neil Dunhum
Chief, Division of Water Quality
April 21, 1978
Further on in the report in section III.1.2., the toxicity question is again
addressed. It is stated here that "while there are no water quality standards
for toxicity and while components of toxicity cannot be readily defined, if
the assumption is made that wastewater contains a certain amount of toxic
material and that this toxic material is evenly distributed throughout the
wastewater, then the toxicity levels in the South Bay will decrease with the
removal of waste loads. Hydroscience calculated the decrease from no action
to implementation of the recommended project would be as much as an order of
magnitude in the extremities of the South Bay."

These two sections include the entire discussion of toxicity in the EIS. The
first statement concludes that undiluted wastewater is definitely toxic to
most aquatic animals. Ihe/vcond statement indicates that if a series of
assumptionc are made concerning the existence of toxicity, a discharge north
of the Dumbarton Bridge will reduce toxicity levels in the South Bay. It is
apparent that further analysis of toxicity IB needed. To facilitate this
discussion background information with respect to the concerns the -Regional
Board has regarding toxicity follows.

The toxicity of wastewaters is often considered only in terms of the survival
of indicator fish in bioassay testing. In many cases, however, the differences
are great between lethal concentrations of toxicants and concentrations which
will permit reproduction and growth. The correlation between bioassay
results based on a single test organism and the actual impact on receiving
water biota is further obfuscated by the variety of fish, invertebrate
species, and lower food chain organisms found in a receiving water body,
each having its own distinct susceptibility to toxicants. In addition, the
variability of toxic waste dischargee introduces further uncertainty in the
quantificantion of toxic impacts on a receiving water.

Toxicity data are generally reported in terms of a median tolerance limit
(Tim), the concentration that kills 50 percent of the test organisms within
a specified time span, usually in 9& hours. Host bioassays are thus a
measurement of acute toxicity. The step from estimation of the acute toxicity
of a waste on a tent species to the quantification of its chronic affects on
receiving water organisms cannot be made directly. A certain amount of
subjective judgement is necessary. This does not provide justification to
overlook the toxic effects of a waste discharge but rather requires that
careful consideration be given to the subject. It is important to note
that while chronic toxicity cannot be precisely quantified, a number of
independent investigators have determined the threshold toxic concentrations
of municipal wastes at strikingly similar levels.
Neil Dunhum
Chief, Division of Water Quality
April 21, 1978
The toxicity guideline given in the Basin Plan is 40 ml/1 {8.01* toxic units).
This was based on work done by Kaiser Engineers in the "San Francisco Bay -
Delta Water Quality Control Seport" (1969). Their analysis was based on
a correlation between benthic opecies diversity and receiving water conservative
toxicity. Threshold effects were noted at a calculated toxicity concentration
of O.OU tu in the receiving water.

The series of reports titled "A study of Toxicity and Biostimulation in S. F*
Bay Delta Waters" prepared by representatives of the Department of Water
Resources, Fish and Game, and U. C. Berkeley, generally supported the toxicity
limitation recommended by Kaiser Engineers.

Dr. Alex Horn's work at SERL as reported in "Long-term Effects of Toxicants
and Biostimulants on the Waters of Central San Francisco Bay" O971*) showed
that toxicity concentrations above 0.12 tu consistently affected aufwuchs
growth and that a threshold effect at 0.05 toxic units was often observed.

Finally, the National Technical Advisory Committee on Water Quality (1968)
recommended that the 2't-hour average concentrations of toxicants after mixing
in a receiving water should not exceed l/20th of the 96 hour TIfli for
degradable, non-cumulative substances and l/100th for conservative, cumulative
or unidentified toxicants. TheGe recommendations are based on wastes in the
midrange of relative toxicity and correspond to receiving water toxicity
limits of 0.05 to 0.01 toxic units respectively.

The Basin Plan toxicity guideline of 0.01! toxic units is thus supported by
a substantial body of data which is specific to San Francisco Bay as well as
by the judgement of a recognized group of water quality experts with nation-
wide experience. The EIS for oil intents and purposes has dismissed toxicity
as a significant factor in the analysis of alternative disposal sites.
Because the prohibition of discharges to waters south of the Dumbarton Bridge
is based largely on high toxicity levels in the South Bay and because no
decision as to an appropriate outfall location for the South Bay Dischargers
can be made without thorough discussion of toxicity, the EIS will not be
complete until that information is provided.

Heavy Metals

There is no discussion of heavy metal concentrations and their potential
impacts on receiving water biota included in the EIR/EIS.

The highest concentrations of dissolved metals in the Bay regularly occur
below the Dumbarton Bridge. It is estimated that 513» (52 metric tons annually)
of the heavy metal loading to the Bay south of Hunters Point is discharged
into this area. This corresponds to only about 8# of the water volume of the
Bay below Hunters Point.
115

-------
Neil Dunhum
Chief, Division of Water Quality
- 5 -
April 21, 1978
The metals of principal concern, as expressed by Dr. Girvin in a preliminary
report to the Regional Board, are copper and silver. It is our recommendation
that the level of observed concentrations of heavy metals in the South Bay
be compared with chronic toxicity levels identified in the literature and that
their potential for biomagnification be assessed.

Botulism

It is noted in the EIR/EIS that in 1975 a. moderately severe outbreak of
botulism occurred in Artesian Slough, Coyote Creek, and Mud Slough. About
2000 birds contracted the disease. In 1971* nearly 13,200 waterfowl died. The
extent of the discussion of the Causes of botulism is limited to the follow-
ing sentence: "No data exist at this time as to the exact cause of botulism
outbreaks, although they are clearly related to anaerobic sediment conditions
that may be aggravated by waste discharge."

The decision to only identify the botulism problem and not to discuss its
potential causes is apparently based on the fact that the "exact cause of
botulism outbreaks" is not known. We do not believe this to be acceptable
rational for overlooking the botulism question. A thorough analysis of the
potential causes of botulism should be included in the EIR/EIS.

The following is a brief summary of the available information concerning
botulism. A brief discussion with respect to implications in the South Bay
is included.

Botulism is a paralytic disease induced by the ingestion of food which
contains toxin from the bacterium Clostridium Botulinum. The Bacillus is
divided into seven types. Type C2 is a'soil bacterium and is responsible
for waterfowl botulism found in the western United States. It is an
•bligate anaerobe. It's optimum growth temperature is generally between
25 & 30°C with production of toxin greatest at 28°C. C. botulinum does
not grow well in salinities above 30 ppt.

Decaying anaerobic organic matter is required by C. botulinum for growth and
the production of toxin. The organic matter may be vertebrates, invertebrates,
submerged grain, or possibly other decomposing bottom material. Birds eat
these materials, accumulate the toxin, and die. The important point is that
anaerobic conditions must occur either in a nicroenvironment such as in the
dead bodies of verterbrates ^invertebrates or in a more widespread environment
such as bottom sediments.
116
Neil Dunhum
Chief, Division of Water Quality
- 6 -
April 21, 19?8
The initial cause of botulism may be an environmental change that kills aquatic
invertebrates or fish. The accidental death of a waterfowl or fish from
natural causes also can trigger a botulism outbreak. In such cases fly
larvae infest a dead fish or bird, concentrate the toxin and being a favored
food of waterfowl result in posioning. Thus death of a single bird can lead
to a botulism outbreak as more birds in turn die and are fed upon.

Besides the proper medium for the growth of Clostridium botulinum, temperature
and ealenity are important and may be controlling in the South Bay.. As
mentioned above a temperature of 25 to JO°C is optimal. Also, C. botulinum
apparently will not grow well in salinities greater than JO ppt.

Outbreaks of botulism in the South Bay have been for the most part localized
in Artesian Slough, Mud Slough and the upper end of Coyote Creek, numerous
dead birds have also been taken from the Sunnyvale oxidation ponds.

Below the confluence of Hud Slough and Coyote Creek water temperatures consis-
tently average about 20-5°C in August and September. From that point in
towards the San Jose outfall water temperature rises at a rate of about 2°C
per mile reaching about 27°C at the outfall, the temperature of the San Jose
effluent. At the same time low salinity levels are created by the fresh
water discharge. It therefore nppcars that the San Jose discharge may create
an environment favorable for the growth of C. botulinum and that it may bo a
significant factor in the botulism outbreaks which occur in the South Bay.
Fresh water in the Sunnyvale oxidation pond may also provide favorable conditions
for toxin production.

Conclusion

It is the opinion of the Regional Board staff that the environmental poction
of the EIH/EIS is a general summary of existing information. It lacks both
depth and interpretive evaluation. Many rather disjointed facts are presented
but little attention has been given to interrelating and comparing impacts.
The argument against greater detail and interprative judgement is the Bechtel
position that incorporation of these would require the EIR/EIS process to
become a research project. No research is needed to provide the information
that is requested in this memo. What is required, however, is the incorporation
of more complete information and, as noted, interperative evaluations of
project alternatives based on this information.

If you have any questions please contact Bob Roche at 8-561-1255.

-------
Submitted by:  Regional Water Quality  Control  Board

Dated:         30 May 1979
for both fish and Invertebrates, as well as calculations of  Application
Factors (AF) and Bloconcentration Factors (BCF) .   The May 18,  1979  test
procedures were corrected on December 18, 1979 (44 FR 75028).
Response:
1.  The purpose of  the Draft KIR/EIS  Is  to disclose the environmental
Impacts of project  alternatives  In order to choose among  the alternatives.
It is not intended  that  the EIE/E1S provide the basis  for exceptions to
either the Enclosed Bays and Estuaries Policy or  the Basin Plan, although
elements in  the report might be  used  as  support for a  petition  for excep-
tion.  Only  after definition of  beneficial uses and the evaluation of
present and  future  reclamation activities can SBDA move to meeting such
conditions (page 188  includes a  statement describing a benefit  which night
accrue by continued discharge to Artesian Slough; this is not meant to infer
claim of enhancement).

2.  On Page  56, It  Is stated that chronic toxicity cannot be precisely
quantified,  while page 57  indicates a potential for biomagnification.  This'
potential would continue,  regardless  of  discharge location since heavy metal
concentrations would  likely not  be reduced by treatment.  Further dilution
does not preclude biomagnification, although the  rate  of  biomagnification
and actual tissue levels of toxic materials may be reduced.  It is possible
that implementation of pretreatment will eliminate or  reduce some industrial
sources of heavy metals  to the SBDA water pollution control plants.  However,
the Introduction of heavy  metals to the  Bay is not a result of  an action
contemplated or being taken by SBDA (i.e. is not  an Impact of a disposal
project).  It is therefore inappropriate to develop mitigation  (i.e. source
control methodologies) for heavy metals  in this EIR/EIS.   (See  also response
to County Sanitation  District 4  in Section 2.2.)

On May 18, 1979 (43 FR 21506), the EPA published  a series of technical
'guidelines which set  forth a methodology for deriving  water quality criteria.
These guidelines included  standards to calculate  acute and chronic toxicity
Using these guidelines, the EPA began promulgating criteria for the 65 toxic
pollutants identified by the Clean Water Act of 1977.   On March 15, 1979
(44 FR 15926),  criteria for the first 27 toxic pollutants were published.
The March 15, 1979 criteria were corrected in notices  Issued May 16, 1979
(44 FR 28716) and June 19, 1979 (44 FR 35289).  The criteria for an
additional 26 pollutants were issued In draft form on  July 25, 1979
(44 FR 43660),  and the draft criteria for the last 12  substances were
Issued on October 1, 1979 (44 FR 56628).  On January 3, 1980 (45 FR 803),
EFA proposed that ammonia be added to the toxic pollutant list.  None of
these notices has been finalized at this time.

The metal, silver — of critical concern to Dr. Girvin  in memorandum dated
April 21, 1978 (p. 5 of that memorandum) — Is discussed on pages 15964-
15965 of the Federal Register for March 15, 1979.  Both chronic and acute
toxicity levels have been developed to protect freshwater and saltwater
aquatic life, and a separate concentration is presented to protect human
health.  Twenty-four hour average values are presented to protect against
chronic effects, while the maximum value, based on 96-hour flowthrough
LC50 data. Is used to protect against acute effects.  The following table
summarizes the proposed criteria for silver:
        Freshwater aquatic life
        Saltwater aquatic life
     Chronic
(24-Hour Average)
   0.0090 ug/fc
   0.26   ug/l
  Acute
(Maximum)
1.9  pg/8.
0.58 yg/l

The criterion for protection of human health was set at 10 vg/i, based on
studies on rats and rabbits.

-------
A second metal of concern, identified in the RWQCB Internal memorandum of
April 21, 1978, is copper. -This element is discussed on page 43666 oj the
Federal Register for July 25, 1979. The following table summarizes proposed
criteria for copper:
Chronic
(24-Hour Average)
Acute
(Maximum)
Freshwater aquatic life (0.65 in {hardness}-l.94) (0.88 in {hardness}-!.03)
Saltwater aquatic life 0.79 ug/i 1.8 ug/)[

The criterion for protection of human health was set at 1 pg/H.

Although an attempt has been made to standardize data on acute and chronic
toxicity, EPA recognises that variability in toxicity levels may be due to
conditions that are specific to each water body. In developing water quality
standards to be based on these criteria, specific circumstances affecting the
toxicity of various compounds in the South Bay, such as synergistic complexes,
salinity, pH, and oxygen levels, should be investigated in more detail. How-
ever, the proposed EPA guidelines should be available In providing a set of
standard methodologies for conducting such studies and in preparing appro-
priate implementation plans for the criteria.

Full documentation on the summary data from which the criteria were derived
is published by the National Technical Information Service (Silver - NTIS
#PB 292 441 and Copper - NTIS #PB 296 791).

3. Avian botulism Is discussed in detail on page 76 of the Draft Technical
Volume. In this discussion, we state that the cause of outbreaks is not
fully understood. However, it should be noted that anaerobic sediment con-
ditions persist in the South Bay due to the high organic content, much of
which can be attributed to past sewage discharges (untreated as well as
treated). Usually, this anaerobic state is shielded from the water column
by a thin oxidized surface - hence the need to agitate samples to determine
118
benthic oxygen demand (Appendix H, page H-444). Ducks, like shovelers,
may disturb this layer and become exposed (or even ingest) anaerobic muds
which may contain toxin from anaerobically respiring C. botulinwa. Ducks
may also carry C. botulinum spores in their intestinal tracts, with out-
breaks of the disease following death by other causes and decay of the
carriers' bodies. It may well be that disturbance to the oxidized layer
is induced by increased temperature (resulting in a reducing environment
and less oxygen in solution), decreased salinity (resulting in animal die-
off with an accompanying oxygen demand), or decreased oxygen levels in the
water (equilibrium to be established between water column and muds leading
to oxygen demand). It also is possible that discharge of sewage contributes
to both decreased oxygen and salinity, although it is not clear that these
conditions persist long enough to encourage anaerobic growth of'the bacterium
and accumulation of toxin in the sediments. As treatment is improved to
the level of AWT, the effect on oxygen by the effluent may be lessened while
salinity decreases may continue to be aggravated. However, urban runoff and
storm drainage may also result in these changes and, indeed, some of the
sloughs studied in Appendix H.3 showed strong salinity and DO variations
in the water column without waste discharges occurring (pages H-429 through
H-436).
A summary of available information on avian botulism indicates that three
conditions must be met for optimum growth and toxin formation by C. botulinum:
warm temperature (25-30°C) , a suitable animal protein substrate, and a high
moisture content. These three conditions may be met in the South Bay during
the late summer when temperatures are high and there is a decrease in inver-
tebrate populations. Ongoing studies at the Bear River Refuge in Utah by
Jensen and Allen confirm the belief that an Increase in Invertebrate mortality
preceded an outbreak. In each outbreak studied, a precipitous decline in
dipterous larvae and oligochaetes preceded botulism. However, the authors
found great variability in the ability of strains of the bacterium to produce
toxin and also found that living Invertebrates are sometimes toxic, presumably

-------
by having ingested cells of C. botulinum. It has also been found that the
death of a bird or fish, and Its subsequent infestation by maggots, may
initiate an outbreak.

There is presently incomplete information on invertebrate population
dynamics in the South Bay, so no conclusions may be drawn concerning the
initiation of outbreaks. In many ponds and marshes where other outbreaks
have occurred, either recent increases or decreases in water level have
been linked with invertebrate dieoffs, but no such indications are avail-
able for the South Bay. It may well be that increased summer temperatures,
in conjunction with BOD loading from the discharges, might cause a
sufficient decrease in oxygen levels in the South Bay to initiate a dleoff
of invertebrates but, in that case, we might expect severe outbreaks every
year. In fact, available data indicates a decrease in numbers of dead
birds from 1974-1978. Although much of this observed decrease in mortality
is undoubtedly due to intensive management by the California Department of
Fish and Game and the Fish and Wildlife Service in picking up dead and sick
birds, there is no clear implication that waste discharge has led to out-
breaks of avian botulism in the South Bay.

Ho quantitative or qualitative prediction of reduction or stimulation of .
botulism outbreaks can be made, from available data. The potential for
outbreak may remain, regardless of the alternative chosen.
Two recent references may be consulted for more specific information:
• Allen, J.P. and S.S. Wilson, 1977: "A Bibliography of References
to Avian Botulism." U.S. Department of Interior, Fish and Wildlife
Service, Special Scientific Report - Wildlife Ho. 204.
- A fairly complete list of literature published through 1975.
• Smith, L. DS., 1977. "Botulism:.The Organism, Its Toxins, The
Disease." Charles C. Thomas, Springfield, Illinois. 236 pp.
- An excellent monograph by a leader in the field of anaerobic
bacteriology, with a chapter on botulism in birds.
4. Until definitions of conditions necessary for exemption are agreed
•upon, no monitoring program can be delineated. This activity will commence
following approval of the Final EIR/EIS, and a selection of conditions will
be worked out with SWRCB and RWQCB (see also responses to County Sanitation
District 4 and Santa Clara Valley Water District in Section 2.2).

5. Although all of the issues presented In your comments are important to
the improvement of the water quality of South San Francisco Bay, and the
need for their eventual resolution is acknowledged by SBDA and EPA, the
'funding of studies for their actual resolution is outside the scope of this
EIR/EIS.
119

-------
Association  of  Bay  Area  Governments
         Hotel Claremont • Berkeley, California 94705 • (415)641-9730     u 1& HO  13
 June 1, 1979
U.S. Environmental  Protection  Agency
Attn:  Hearing Office,  HE-149
Region IX
215 Fremont Street
San Francisco, CA  94105
Dear Sirs:
Thank you for the opportunity  to review the DEIR/S for the
South Bay Dischargers Authority effluent disposal project.
ABAG staff has reviewed this document and is forwarding
the following comnents.  ABAG's Executive Board has not
taken a position on this document or the proposed project.
The DEIR/S states that  facilities will be sized on the basis
of the Department of Finance's E-0 population projections.
In view of California State Office of Planning and Research's
approval of ABAG's  population  projection for use by the
State Mater Quality Control Board, we urge that the latter
set of projections  be substituted for those now used in the
text.  Please contact Stan  Hoffman, Principal  Regional
Planner, to obtain the  projections for the service area of
the project.
Thank you again for the opportunity to comment.
Sincerely,
   HEARING
JUNG  1979
  REQIONIX
 Charles Q.  Forester
 Director of Planning
   Representing City and County Governments in the San Francisco Bay Area
120
                               Submitted by:  ABAC
                                              Hotel  Claremont
                                                                                                       Berkeley, California  94705
                                                                                        Dated:
                                                                                                      1 June 1979
                                                                                        Response:
                                                                                        The  Draft  EIR/EIS description of the Basin Flan Alternative was  based on
                                                                                        plant capacity approved by the EPA and the State in 1974,  and operating
                                                                                        at the time of report printing.  The cost of the Basin Plan Alternative
                                                                                        did  use the DOF E-zero basis, the approved number at the time of Step 1
                                                                                        funding.   The DOF E-zero wa,s used to allocate nongrant fundable  capital
                                                                                        costs  (see page 160, Table 111-5 in Draft EIR/EIS Technical Volume)  since
                                                                                        the  existing capacity of the water pollution control facilities  already
                                                                                        exceeded E-zero levels.  It was necessary to size the disposal system to
                                                                                        fit  the water pollution control facilities in order to ensure system
                                                                                        compatibility and reliability.  Use of another population figure will not
                                                                                        alter the  disposal system size; it could affect computation and  alloca-
                                                                                        tion of nongrant fundable costs.
                               Using the ABAC projections  (Table 2-5), it can be seen that projections
                               for the service area  are declining with 'each revision, reflecting recent
                               declines in average household size, migration rates, and regional employ-
                               ment growth rates.  If a disposal system were to be selected and grant
                               funding were to be requested, the required funding would be estimated
                               based on the projection in  effect at the time of funding.  If such pro-
                               jections continue to  decline, the discrepancy between treatment facility
                               capacity and E-zero population will increase, resulting in a porportional
                               increase in ineligible costs for San Jose/Santa Clara (Table 111*5, page
                               156 of Technical Volume, Draft EIR/EIS allocates all ineligible costs
                               due to capacity to  San Jose/Santa Clara).  It is also possible that
                               Palo Alto and/or Sunnyvale  could Incur ineligible costs due to these
                               revisions.  As stated on page 21 ot the Technical Volume, these new
                               revisions would be taken into account in the final design phase,  should
                               a structural alternative, such as the Basin Plan Alternative,  be  selected.

-------
                                            TABLE 2-5

                          Projected Population on the SBDA Service Area
                                         (in thousands)
                         1970
1975
1980
1985
1990
1995
2000
DOF1
E-zero
DOF/DWR2
D/150
E-rzero
ABAG/MTC2
D/150
E-zero
3
DOF revised
E-zero
4
ABAC Series 3 Rev
E-zero
1047.8 1152.2
1041.0
1041.0
1033.8
1033.8

1145.1
1362.2
1348.0
1273.0
1268.6
1203.7
1270.7
1211.8
1564.2
1909.0
1635.0 .
1751.3
1422.8
1560.7
1324.5
.,
1697.0
1507.0
1528.2
1360.1
1426.1
1429.4
 These projections taken from Table 3-2, page 3-6 of Financial Plans and Revenue Programs, Water
 Pollution Control Facilities in South San Francisco Bay,  prepared for SBDA by  Bechtel  Incorporated
 March 1, 1974.
2
 These projections taken from Table 11-15, page 87, Technical Volume of Draft EIR/EIS  (DOF/DWR, 1974;
 ABAG/MTC, 1974)
3
 These projections calculated from text, page 87, Technical Volume of Draft EIR/EIS

4
 These projections from Charles Q. Forester, Director of Planning to U.S. EPA Region IX.  Personal
 communication with ABAC:  letter dated 23 October 1979.
                                                                                                             121

-------
                        OABAG
      Association  of Bay Area Governments
              Hotel Ciaremont • Berkeley, California 94705 •(415)641-9730
October 23, 1979
U.S.  Environmental Protection Agency
Attn:  Hearing Office,  HE-149
Region IX
215 Fremont Street
San Francisco, California   94105

To Whom  It May Concern:

In our letter of June 6, 1979, we commented upon the DEIR/EIS for the
South Bay Dischargers Authority Treated Wastewater Disposal Program.
Me informed you that we were revising our population projections and
would provide you with the revised projections  in the near future.

These figures have now been revised and adopted by the ABAG Executive
Board.
The revised figures follow:
                    Year

                    1975
                    1977*
                    1980
                    1990
                    2000
Population

1,145,147
1,171,821
1,211,832
1,324,495
1,429,354
Charles Q. Forester
Director of Planning
                       •linear interpolation  between 1975 and 1980
         Representing City and County Governments in the San Francisco Bay Area
122

-------
Advisory
Council On
Historic
Preservation
1522 K Sine* NW.
Washington D.C.
20005
Reply to: T. C. For. K'JSS
Denver, Col<»ra
-------
Submitted by: Advisory Council on Historic Preservation
1522 K Street, NW
Washington, D.C. 20005
Bated:
8 June 1979
Response:
As stated on page 92 of the Draft EIR/EIS Technical Volume, EPA and SBDA
will comply with Executive Order 11593 should any action affect historic,
cultural, or archaeological sites. Although "No Further Action" has been
selected and this alternative requires no construction, should EPA or
SBDA consider any other activity in the area in the future, we will comply
with 36 CFR 800.4; 16 U.S.C. Sec. <470f, as amended, 90 Stat, 1320; and
ajiy equivalent state, regional, or local regulations. •
124
-------
Sectioi?
RESPONSES TO WRITTEN COMMENT
RECEIVED AFTER 6 JUNE 1979
.
-------
-------
3. RESPONSES TO WRITTEN
COMMENT RECEIVED AFTER 6 JUNE 1971
Three letters of comment were received by EPA and SBDA after the close
of the review and comment period. They are included here along with
responses because issues were raised in these three letters which warrant
comment.
• Florence M. LaRivere - 1 July 1979
• County Sanitation District No. 4, Santa Clara County -
3 July 1979
• Sunnyvale Chamber of Commerce - 15 May 1979
127
-------
"^ V'xa IAA o r—^"
,*-.^,<•<>•
"- ""
Tis^as - " __. 7.. -T:X' /"«--• u ^,— \
4ut *>*» ^"*, j ' ^ Jc^-<^^/^

%$£&&$&£&

^^r <*<& -^-. / , ±, g^tts^Vu
y 7 U'/L L7U^^( -, Yf j--^- AW*^^ *
^\- ^m^^fA^^^^-1^
yo^6f ^^rjS^-^f, &avt*: ^ .
(Retyped from original with Ms LaRivere's permission.)
4S3 Tennessee Lane
Palo Alto, California 94306
July I, 1979 - ,
United States Environmental Protection Agency
215 Fremont
San Francisco, California

Altn,; Hearing Office HE
re: Grant #CA 06-1135
Dear Sir:
During the 28 year; we have lived in Palo Alto, we have frequented the
shores of the bay for recreation - sailing; hiking, and wild-life enjoying. Since the
opening of the dikes many years ago for walking, we have become especially fond
of the airport runway dike, where it parallels the Palo Alto sewer out fall.

It is quite evident that wildlife is particularly abundant in that area. Gulls,
shorebirds and ducks are in heavy concentrations there, and it is apparent from
the terns fishing up and down the slough that fish life is rich in it.

Fresh water intake to the south bay has been shockingly diminished in the
last century, and by some projects (for example. Mountain View Shoreline's
blockage of fresh water runoff) within the last few years. Catching those waters in
flood basins leads to evaporation. In the bay adjoining runoff areas that have been
maintained, steelhead and other fish life persists.

It appears to us that the South Bay Discharger Project will most likely
lead to deterioration in the water quality of the South Bay.
Sincerely,
Florence M. LaRiviere
128
-------
Submitted by: Florence M. LaRivere
433 Tennessee Lane •
Palo Alto, California
94306
Dated:
1 July 1979
Response:
No blockage of natural runoff would occur with any of the viable dispos-
al alternatives since each would consist of buried pipelines in existing
dikes. However, with selection of the No Further Action Alternative,
maintenance of "freshwater" flows into the channel near the Palo Alto
Airport would result since the Palo Alto effluent would continue to that
channel.

.129
-------
COUNTY SANITATION DISTRICT NO. 4
OF SANTA CLARA COUNTY
100 East Sunn/oaks Avenue
Campbell. California 95008
Telephone 378-2407
-E5;0«i; ix
..V.M. CENTER
J:.l E
SERVING RESIDENTS OF
CITY OF CAMPBELL
TOWN OF LOS 6ATOS
CITY OF MONT£ SERENO
CITY OF SAN JOSE
CITY OF SANTA CLARA
CITY OF SARATOGA
UNINCORPORATED AREA
Submitted by: County Sanitation District Ho. 4 of Santa Clara County
100 East Sunnyoaks Avenue
Campbell, California 95003
July 3, 1979
Dated:
3 July 1979
Environmental Protection Agency
Region XX
Hearing Officer, HE-149
215 Fremont Street
San Francisco, CA 94105

Re Governmental Agencies
Regional, South Bay Dischargers
Authority

The Board of Directors of County Sanitation District Ho. 4
of Santa Clara County, California is on record as favoring
the "no action alternative" set forth in the DRAFT ENVIRON-
MENTAL IMPACT REPORT AND STATEMENT for the SOUTH BAY DIS-
CHARGERS AUTHORITY TREATED WASTEWATER DISPOSAL PROGRAM.

The District Board of Directors has also dis ssed the
feasibility of large volume water reclamation as a partial
alternative for disposal of the wastewater discharge from
the San Jose/Santa Clara Hater Pollution Control Plant
and take the following position with respect to this alternative:

o The Clean Hater Act Grant designated•for the
South Bay Dischargers Authority Common Conveyance
Facility should not be redesignated for use in
funding a water reclamation alternative.

o The feasibility of large volume water reclamation
requires further study, which, with respect to
Santa Clara County, should be administered by the
Santa Clara Valley water District.

o The financing, administration and operation of any
systems for the transportation and distribution of
large volume water reclamation should also be under
the direction of the Santa Clara Valley Hater District.

Sincerely
Stephen H. Goodman
Manager and Engineer

SHGskk
cc: South Bay Dischargers Authority
Room 320, 801 No. First St., San Jose 95110
Frank M. Belick; Board of Directors
Response:

1. Clean Water Act Grant funds designated for wastewater disposal

cannot be redesignated to reclamation or any other alternative unless

it is selected as a disposal alternative. Should a wastewater reclama-

tion program be implemented at a later date, SBDA would have to reapply

for funding (see also responses to U.S.D.I. and to P. Ferraro in Section

2.2).

2, 3. A feasibility study of large-scale reclamation is now underway.

A joint venture, comprised of SBDA, City and County of San Francisco,

Central.Contra Costa Sanitary District, Santa Clara Valley Water District,

EBDA, Contra Costa County Water District, and EBMUD, has hired the con-

sulting firm CH-M Hill to perform the study. Administration, financing,

transportation, and distribution of reclaimed water are to be covered in

this study.

Responses to your earlier letter supporting No Further Action are inclu-

ded in Section 2.2.
130
-------
SLNNYVALE CHAMBER OF COMMERCE •
4S9 SOUTH MURPHY AVENUE • TELEPHONE AREA CODE [408) 7364971
SUNNYVALE .CALIFORNIA MOM
May 15, 1979
Environmental Protection Agency
ATTENTION: Hearing Office, HE-149
Region IX
215 Fremont Street
San Francisco, CA 94105

SUBJECT: SUNNYVALE CHAMBER OF COMMERCE POSITION ON
THE SOUTH BAY DISCHARGERS AUTHORITY'S TREATED
WASTEWATER DISPOSAL PROGRAM

The Board of Directors of the Sunnyvale Chamber of Commerce at their
Executive Committee Meeting of May 8, 1979 and their full Board Meeting
of May 15, 1979 unanimously voted to urge that "no action beyond currently
approved improvements at Tredtment Plants" be taken and that the three
Santa Clara County treatment plants continue to discharge treated effluent
into the South Bay. This position la based on the following key consider-
ations:

1. Actions taken or being taken by the Cities of San Jose,
Santa Clara, Sunnyvale and Palo Alto are proving to be highly
successful in Improving the water quality of the South Bay. It
Is reasonable under these circumstances to defer action on the
"Super Sewer Project", monitor the rate of Improvement and
subsequently take corrective steps, If necessary.
2. Given the current and continuing improvement of water
quality, the fresh water marshes in the South Bay can be
- retained and the undesirable transition to salt water marshes
and its adverse effect upon existing vegetation and wildlife will
be avoided.

3. The Investments made and being made in the wastewater
treatment plants of South Bay Clttes are proving to be cost
effective thus avoiding the cost of constructing and operating
the "Super Sewer Project." The estimated $86 million tor
construction, $320,000 annual operating costs and significant
energy demands can all be saved.
- Page 2 -
Environmental Protection Agency
ATTENTION: Hearing Office, HE-149
In conclusion, the Sunnyvale Chamber of Commerce urges Alternative 2
of the Draft Environmental Impact Report and Statement (Treated Waste-
water Disposal Program dated September 1978 be adopted and that no
further action be taken at this time.
Sincerely,
:. H. Millson
Executive Director
EHMstmb
- continued -
131

-------
Submitted by: Sunnyvale Chamber of Commerce
499 South Murphy Avenue
Sunnyvale, California 94086
Dated:
15 May 1979
Response:
SBDA and EPA have noted your resolution and considered it in making a
project selection. Specific issues in your letter do require response:

1. Monitoring and taking subsequent corrective steps, if necessary, is
inferred in selection of the No Further Action Alternative. SBL>A will,
after completion and approval of the Final EIR/EIS, have to position
SWRCB and RWQCB to establish conditions for exemption to the Enclosed
Bays and Estuaries Policy and the Basin Plan before monitoring and/or
corrective action can be defined. (See also responses to County
Sanitation District No. 4 and Santa Clara Valley Water District in
Section 2.2.)

2. Retaining a disposal system in Artesian Slough and at Palo Alto will
result in maintenance of freshwater marshes or vegetation; conversely,
removal of the discharge will result in loss of this vegetation. How-
ever, although freshwater marshes are considered a benefit to some (e.g.
U.S. Fish and Wildlife Service: Drs. ShelIhawmer, Harvey, and Mewaldt),
the transition to saltwater marshes may not be considered undesirable to
others. At this time, no definition of the preferred ecosystem has been
made by regulatory agencies (see also response to D. E. Myers in Section
2.2).

3. Of the estimated $86 million capital and $320,000 annual operating
costs, only that local portion (12.5 percent capital and all operating
costs) can be considered "saved." The remaining 75 percent federal and
12.5 percent state shares will likely be committed to another applicant.
Energy demands of transport and/or upgraded treatment would be saved
although no decrease in energy use is anticipated for "No Further Action.
132
-------
Scctiop 4
ERRATA

-------
-------
4. ERRATA

The following typographical and editing errors occurred in the Draft E1R/

E1S. These errors have not been corrected in a reprinted volume; rather,

the corrections are noted below with each error as clarification to the

reader.
Volume, Page
Column and Line Error

Table 11-1, line 4 punctuation: (SWRCB

TECHNICAL, 39 editing: misplaced foot-
column 2, lines 14-18 note
Correct iiui

(SWRCB± 1974)

insert lines 14-18
after page 1, column
40
Volume, Page
Column and Line

TECHNICAL, 8
column 1, line 2

TECHNICAL, 12
column 1, lines 8-9

TECHNICAL, 15
column 1, line 24

TECHNICAL, 24
column 2, line 35

TECHNICAL, 25
column 1, lines 31-32
column 2, line 14
TECHNICAL, 28
column 1, line 9

column 2, lines 15-21
TECHNICAL, 29
column 2, line 2

TECHNICAL, 33
column 1, line 25

TECHNICAL, 36
column 2, line !9
Error

spelling: ... criteria,
exception dissolved...

editing; spacing between
lines

spelling: ... residentts
would be...

spelling: ... 16:1 for a
conservation ...

editing: Figure I-ll shows
typical construction
details

editing:.,, over the pipe-
line (Figure 1-10)...

spelling: ... .to which
Sy_nnyvale Clows...

editing: misplaced para-
graph
editing:... the recom-
mended project. . ;

spelling: ... forms the
surface s^tum along. . .
editing: ... become £
plastic when. . .
Correction

... criteria, except-
. Ing dissolved...

close spacing, result-
ing in one paragraph

.. . residents^ woul d
be.. .

... 16:1 for a conser-
vat ive...

delete sentence:
"Figure I-ll presents
... of the project."

... over the pipeline
(Figure l-lp..- --

... to which Sunnyvale
flows...

insert lines 15-21,
after page 26, column ,
1, line 28

... the Basin Plan
alternative...

...forms the surface
stratum along...

... become plastic
when. ..
TECHNICAL, 45
Table 11-4
editing: table not com-
pletely 1 ined
TECHNICAL, 49 editing:... assuming the
column 1, lines 17-18 disposal project is noj^
operational.
TECHNICAL, 53
column 1, line 34
editing:... in the
_lower Bay is
column 2, lines 34-40 editing: spacing between
lines and indentation of
lines 35-40
TECHNICAL, 54
column 2, 1ine 27
TECHNICAL, 56
column 1, lines 35-37
TECHNICAL, 57
column 1, line 8

column 2, line 18
column 2, line 41
TECHNICAL, 58
Table 11-9, line 14

TECHNICAL, 61
Table 11-10
punctuation:... of tin-
South BaVj_ (Consovr-
Bechtc-1 . . .

spelling:... by Dr. Horn
at... 1977). Dr. Horn's
studies. . .

punctuation: ... July,
1978. May be

punctuation:..- 1976-77^
(RWQCB. . .

punctuation: recreational
facil
spelling: Nickle
editing: Notes (1), (2)
and (3) are for Tablt-
11-10
add vert ten 1 liny
between the first two
columns

... assuming selection
of No Further Action
or Upgraded Treatment
alternatives.

... in the Lower Bay
is

close spacing, result-
ing in one paragraph;
adjust left margin of
column one space

... uf the Sooth Bay
(Consour-Bwhtt'l...
... by Dr. Home at. ..
1977). Dr. Horne's
studies...

... July, 1978). May
be...

... 1976-77 (RWQCB...
... recreational
fac ilit ies

Nickel
add line below note (3),
column 2, line 15, to
separate table from text
135
-------
Vo 1 ume, P;i (•<•
Column and Linn

TECHNICAL, 63
Figure 11-14
TECHNICAL, 64
column 1, 1ine 38

TECHNICAL, 68
column 1, lino 14

column 2, line 25
column 2, line 30
TECHNICAL, 69
column 1, line 2

column 1 , 1 inc. 23
column 1, ]ine 32
column 2, line 23
TECHNICAL, 70
TECHNICAL, 76
column 1, line 25
Error

printing page 63 has
incorrect yellow pattern
editing: ... in Table
11-10;' the...

editing: ... include
Asychis Elongata. . .

editing:. . . or S.
Leiantha) .

editing:,,. Algal "mats"
or "films".

editing:... -pickleweed
(Sal ic_nrni_a j>j>. ) is , , ,

spelling:... from the
picklewocxl zone.

spelling:,,. Alejneda
song sparrow. . .

punctuation:.,, salt
^ (Dist ichl is. . .
editing: Figure number
omitted

editing: Table 11-11 does
not show Coyote Creek
st at ions
column 2, 1ine 11
spelling: ... dieoff of
acquatic invertebrates...
Correction

replace with new page
63 supplied with EPA
transmittal dated
3 July 1979

... in Table II-U;
the.. .

... include Asychis
elongata...

... or S. leiantha).
.. . iilgal "mats" or
films.

. . . picklcweed
(Salicornia sp.) is...

... from the picklt?-
wo_ed zone.

... Alameda song
sparrow...

... salt grass
(Distichlis. . .

add Figure 11-16 to
legend

replace reference to
Station 11, Table II-
11 with stations 1-6,
pages H.31 - H.34, H.
79 - H.83, H.109 - H.
Ill, H.254 - H.256,
H.269 - H.270, H.276 -
H.277 and H.284 - H.
285 in Appendix H.

... dieoff of aquatic
invertebrates...
Vo 1 ume, Pa ge
Column and Line

column 2, line 35
TECHNICAL, 77
column 1, line 9
TECHNICAL, 82
column 2, line 34

TECHNICAL, 89
column 2, line 25

TECHNIAL, 91
Figure 11-20
TECHNICAL, 92
column 1, line 36
TECHNICAL, 97
Figure 11-22
Error

punctuation:... Hunter
1979; Hunter 1969;
Hunter...

editing: Table 11-11
does not show Cuadalupe
Slough station
editing:... Slough in
San Mateo County...

. ..biostraitigraphic...
printing: page 91 has
incorrect yellow pattern
editing: Figure 11-22
does not show the
middens

printing: page 97 has
incorrect yellow pattern
editing: Ranch Rincon
del Arroyo de San
Francisquito

TECHNICAL, 98 punctuation: By 1974,
column 1, lines 27-32 the.... 30 percent manu-
facturing employees in
1974, 102,800... manu-
facturing industries
TECHNICAL, 103
Figure 11-23
printing: page 103 has
incorrect yellow pattern
Correction

...Hunter^ 1979;
Hunter^ 1969; Hunter.,
replace reference to
station 13, Table ti-
ll with Station 14,
pages H.39 - H.40,
H.87 - H.89, H.260,
in Appendix H.

... Slough in
Alameda County...

.. . biostrat^igraphie. .
replace with new page
91 supplied with EPA
transmittal dated
3 July 1979

delete: ... (A and B
in Figure 11-22).
replace with new page
97 supplied with EPA
transmittal dated
3 July 1979

Rancho Rinconada del
Arroyo de San
Francisquito

By 1974, the... 30
percent manufacturing
employees^ _Tn 1974,
102,800... manufactur-
ing industries.

replace with new page
103 supplied with EPA
transmittal dated
3 July 1979
136
-------
Volume, Page
Column and Line
Error
Correction
Volume, Page
Column and Line
Error
Correct ion
TECHNICAL, 109
column I, line 18

column 1, lines 32-33
column 2, line 7
TECHNICAL, 110
column 2, lines 15-16
TECHNLAL, HI
column 2, ]ine 26

TECHNICAL, 112'
column 1, line 18

column 2, lines 35-36
TECHNICAL, 1.1.4
column 2, line 39

TECHNICAL, U5
column 2, line 34
TECHNICAL, 116-117
Figure It-25
TECHNICAL, 118
column 1, line 33

TECHNICAL, 123,
column 1, line 4
TECHNICAL, 129
column 2, line 40
editing: ... the Palo
Alto Wetland Preserve..

editing:... Palto Alto
Flood Retention Basin
is. . .

editing:... Che Flood
Retention Basin is ...

editing:... to the pro-
posed pipeline outfall
north...

editing: Figure fI-24
does not show refuge

punctuation: ... and
enjoyment

editing: ... the Flood
Retention Basin-to...

editing: »'Palo Alto
Flood Basin

editing: The Palo Alto
Flood Retention Basin,
printing: Figure 11-25
has incorrect blue
pattern
spelling: ... is
concj"e_ned:

editing: Table 11-24
does not show South Bay
Aqueduct monthly
deliveries

editing: ... (see Section
III.1.2, Study ...
.. . the Palo Alto
Baylands Reserve...

... Palo Alto Baylands
Reserve is...
... the Baylands
Reserve is...

... to the Basin Plan
alternative outfall
locat ton north...

change reference to
Figure 11-20

. . . and enjoyment_._
... the designated
Baylands Reserve to...

• Palo Alto Baylands
Reserve

The Palo Alto Baylands
Reserve, a...
replace with new pages
115-116 supplied with
EPA submittal dated
3 July 1979

... is concerned:
change reference to
Table 11-25
... (see Section III.
1.3, Study...
TECHNICAL, 130
column 1, line 9

column 1, 1ine 26
TECHNICAL, 133
column 1, line 3
punctuation: ... erosion
problems^ removal...

punctuation: ... will
include ^revegetatinn...

editing: ... equipment
(Section III.2).
column I, lines 32-36 editing: misplact-d
footnote
TECHNICAL, 148
column 1, line 12

TECHNICAL, 155
column 1, line 39

TECHNICAL, 157
column 2, line 16

TECHNICAL, 167
spelling:... and par-
tically insulated,..

spelling: ... xt Santa
Clara County.

editing:... which the
authority operates...

editing: misplaced para-
column 1, lines 20-36 graph
TECHNCIAL, 176
column I, line 3

TECHNICAL, 204
column 1, line 20

TECHNICAL, 206
column 2, line 2 '

TECHNICAL, 207
column 2, line 31

TECHNICAL, 214
column 1, line 17

column 2, lines 34-37
spelling:... violate
standard, even...
spelling:..
South Bay..
at the
spelling:... Bay have.
been...
spelling:. .
County.,.
Contra Costs
editing: misplaced foot-
note

editing: the sentence "For
detailed..-Bechtel Inc.,
1974." is a not to Table
V~3
... erosion problems;
remova1...

...will Lncl udi'^
revegetat ion. . .

... equipment (Sort ion
II1-2).

insert 1 ines 32-36
after line 39, column
2 of page 132

.. .nnd part_tal ly
insulated...

...of Santa Clara
County.

...which the Authority
operates

insert lines 20-36,
page 168 before
column 1 line 1

...violate standards*,
even...

...of the South Hav...
...Bay has been,..

...Contra Costn
County...

insert after page 213,
column 1, line 39

add number (4) to
beginning of lines
34-37

137
-------
Volume, Page "
Column and Line

TECHNICAL, 218
column 2, lines 5-6
and
TECHNICAL, 219
column 2, lines 5—42
TECHNICAL, 220 ' '
column i', lines 1-15 •
column 1, lines 36-39
column 2, lines 1-4
TECHNICAL. 218
column 2, lines 6—42
antl • -
TECHNICAL, 219 '
column 1, lines 1-36
TECHNICAL, 222
column 1, Iine 2

column 1, 1ino 19
TECHNICAL, 224
column 2, line 10
TECHNICAL, 225
column 1, 1ine 1
TECHNICAL, 260
column I, line 12

TECHNICAL, 262
Table V-25,
Note (2)
Error

editing:... irrigable
productive lands+ During
the design...
...irrigation. Require-
ments t are irrigated.:.
...January.
ffor irrigation...
editing: 5 misplaced
paragraphs
spelling:... recharged
tanks. An...

spelling:... domestic
recycle^ (e.g., grey...

grammar:... effect^ of
percolation through the
soil iji assumed...

punctuation:... alter-
natives discussed below)
were...

editing:... to the SCVWD
price of...

spel1 ing:... for San
FUipe. . .
Correction

insert lines 6-42,
column 2, p 219; 1-15,
column 1, p 220; 36-39,
column 1, p 220; and
1-3 column 2, p 220
between "... lands"
and "During. .'.".

close line 5, column
2, page 219 with line
4, column 2, page 220
to read:
...irrigation. Require-
ments for irrigation...

place lines 6-42,
column 2, p 218 and
1-36
column 1, page- 219,
after line 14,
column 1, page 218

...recharge tanks.
An. ..

... domestic recycling
(e.g., grey...

...effects of percola-
tion through the soil
are assumed

...alternatives dis-
cussed below), were...
...to the San Felipe
price of. ..

.. . for San Felipe. ..
Volume, Page
Column and Line

TECHNICAL, 268
column 1, line 4

TECHNICAL, 272
column 2, lines 7-8
TECHNICAL, 273
column 1, line 22

column 1, line 27
TECHNICAL, 281
column 1, line 12

TECHNICAL, 287
column 2, line 12

APPENDIX, H-l
Figure H-l
APPENDIX, H-2
Figure H-2
Error

spelling:... erosion at
the.. .

editing:... of the pro-
posed disposal project.
editing:... pumped to
the...

editing:... tie-in to
the SBDA...

editing:... salt marsh
song sparrow

spelling:... change on
present land-use...

editing: stations
incorrect
editing: stations
incorrect
Correction

...erosion p_f the...

of the Basin Plan
alternative, and...

.. .pumped to a

.. .tie-in to a SBDA
...Alamenda song
sparrow

...change in present
land-use...

disregard Figure H-l;
use Figure 1, page
H-6 instead

disregard Figure H-2;
use Figure 2, page
H-10 instead
The arrow O) indicates point of insertion.
138
-------
Sectiop
DISTRIBUTION LIST
-------
-------
DISTRIBUTION LIST

The following distribution list was compiled from
an EPA list of required Federal and state recipients
and from lists submitted by staffs of agencies
represented on the South Bay Dischargers Authority
Technical Advisory Committee. In addition, those
individuals who have requested copies have been
included on this list.
FEDERAL AGENCIES

U.S. Environmental Protection Agency
Office of Legislation A-103
Congressional Affairs Division
Washington, D.C. 20460 2

U.S. Environmental Protection Agency
Office of Public Affairs A-107
Washington, D.C. 20460 2

U.S. Environmental Protection Agency
Office of Water Programs Operations
Oil and Special Material Control Division (WH-548)
Washington, D.C. 20460 2
U.S. Environmental Protection Agency
Office of Federal Activities A-T04
(Attn: Ms. Susan Watkins)
Washington, D.C. 20460

U.S. Environmental Protection Agency
Region IX, EPA Library
215 Fremont Street
San Francisco, CA 94105

U.S. Environmental Protection Agency
Public Reference Unit (PM 213) Room 2922
401 M Street, SW
Washington, D.C. 20460
U.S. Environmental Protection
Region IX - Attn: Ms. Lauren
215 Fremont Street
San Francisco, CA 94105
10
>ndanl
U.S. Department of Agriculture
Office of the Secretary
Environmental Quality Activities - P>oom 307A
14th & Independence Avenue, SW
Washington, D.C. 20250 2

U.S. Department of Agriculture
Soil Conservation Service
P.O. Box 1019
Davis, CA 95616

U.S. Department of Agriculture
Regional Forester
630 Sansome Street
San Francisco, CA 94111

U.S. -Army Corps of Engineers
Environmental Resources Branch
South Pacific Division
630 Sansome Street
San Francisco, CA 94!11 3

U.S. Army Corps of Engineers
Environmental Branch
211 Main Street
San Francisco, CA 94105 2

U.S. Army Corps of Engineers
Executive Direct9r of Civil Works
Office of the Chief of Engineers
Washington, D.C. 20314 2

U.S. Department of Defense
Deputy Assistant Secretary of Defense
Environmental Quality
OASD (HE), Pentagon
Washington, D.C. 20301

U.S. Army Corps of Engineers
Sacramento District
650 Capitol Mall
Sacramento, CA 95814

U.S. Department of the Interior
Assistant Secretary, Program Policy
Attn: Office of Environmental Project Review
Washington, D.C. 20240 20
141
-------
U.S. Ehvironmental Protection Agency
Region IX - Attn: Mr. Chuck Fllppo
Public Information Center
215 Fremont Street
San Francisco, CA 94105 20

Council on Environmental Quality
722 Jackson Place, NW
Washington, B.C. 20006 5

U.S. Department of Agriculture
Agricultural Extension Service
Attn: Mr. Robert Ayers
university of California
Berkeley, CA 94705

San Francisco National Wildlife Refuge
Attn: Me. Robert Personius
3849 Peralta Blvd.
Fremont, CA 94536

U.S. Fish and Wildlife Service
Attn: Mr. Rick Breitenbach
800 Cottage Way
Sacramento, CA 95825

U.S. Fish and Wildlife Service
Bureau of Sport Fisheries
P.O. Box 3737
1500 N.E. Irving Street
Portland, OR 972CG

U.S. Department of the Interior
Water and Power Resources Service
Attn: Mi:.- Haydn C. Lee, Jr.
2800 Cottage Way
Sacramento, CA 95825

Federal Highway Administration
Office of Environmental Policy
400-7th Street, SW
Washington, D.C. 20590 2

Urban Mass Transportation Administration
Office of Program Operations
400-7th Street, SW
Washington, D.C. 20590 2
142
U.S. Department of the Interior
Western Division
P.O. Box 36063
450 Golden Gate Avenue
San Francisco, CA 94102

U.S. Department of the Interior
Bureau of Sport Fisheries and Wildlife
650 Capitol Mall, Room 40616
Sacramento, CA 95813

Federal Highway Administration
Two Bnbarcadero Center - Room 530
San Francisco, CA 94111

Urban Mass Transportation Administration
Region IX - Box 36125
45u Golden Gate Avenue
San Francisco, CA 94102

Department of Transportation
12th Coast Guard District
630 Sansome Street
San Francisco, CA 94126

U.S. Coast-Guard
Attn: Mr. N. Bell
Marine Environmental Protection Branch
Office Aids to Navigation Branch
230 Sansome Street
San Francisco, CA 94126

U.S. Department of Transportation
Box 36133
450 Golden Gate Avenue
San Francisco, CA 94102 2

Dr. Billy Welch
SAF/ILE - Room 4C885
Pentagon
Washington, D.C. 20330

Mr. Bruce Hildebrand
Office of the Asst. Secretary of the Army
(Civil Works) - Room 2E567 -
Pentagon
Washington, D.C. 20310
-------
Mr. Peter McDavitt
Special Asst. to the Secretary of the Navy
(Installations and Logistics)
Crystal Plaza No. 5
22l1 Jefferson Davis Highway
Arlington, VA 20360

Department of the Navy
Moffett Field Naval Air Station
Attn: LCDR W.V. Sayner, Jr.
Assistant Public Wbrks Officer
Moffett Field, CA 94035 2

Mr. George H. Holdaway
NASA Anes Research Center
Mail Stop 213-1
Moffett Field, CA 94035

U.S. Department of Defense
Office of Health and Environment
Attn: Mr. George Marienthal
Room 3E172, Pentagon
Washington, D.C. 20301

Mr. J. Thompson
U.S. Geological Survey
345 Middlefield Road
Menlo Park, CA 94025

U.S. Geological Survey
Attn: Drs. A. Grantz, F. Nichols,
D. McCullough
845 Middlefield Road
Menlo Park, CA 94025
U.S. Department of Health, Education and
Welfare, Region IX
50 Fulton Street
San Francisco, CA 94102 2'
U.S. Department of Housing and
Urban Development
Environmental Clearance Officer
One Bnbarcadero Center, Suite 1600
San Francisco, CA 94111
U.S. Department of Housing and
Urban Development
450 Golden Gate Avenue
San Francisco, CA 94102 2

U.S. General Services Administration
Region IX
49 Fourth Street
San Francisco, CA 94103

National Commttee of Water Quality
Attn: Mr. James Larocca
1111-18th Street, NH
P.O. Box 19266
Washington, D.C. 20036 2

Water Resources Council
Office of Associate Director
2120 L Street, NW, Suite 800
Washington, D.C. 20037 2

Federal Energy Administration
Attn: Environmental Impacts Division
New P.O. Building
12th and Pennsylvania Avenue, NW
Washington, D.C. 20461 2

U.S. Department of Coimierce
Office of Environmental Affairs
Conmerce Building, Room 2816 .
Washington, D.C. 20230 2

U.S. Food and Drug Administration
Attn: Mr. David Alton, Regional Shellfish Consultant
50 Fulton Street
San Francisco, CA 94118

Advisory Council on Historic Preservation
1522 K Street
Washington, D.C. 20005 ' 2

Advisory Council on Historic Preservation
P.O. Box 25085
Denver, CO 80225

-------
LIBRARIES
INDIVIDUALS AND PRIVATE GROUPS
Documents librarian
Santa Clara County Library
Research Center
10400 Torre Avenue
Cupertino, CA 95014

San Jose Public Library
180 W. San Carlos Street
San Jose, CA 95110

Palo Alto Public Library
1213 Newell Road
Palo Alto, CA 94303

Santa Clara County library
7387 Rosanna Street
Gilroy, CA 95020

Santa Clara County library
78 South Dempsey Road
Milpitas, CA 95035

Mauntain View Public Library
585 Franklin Street
Mauntain View, CA 94040

library
Water Resources Center
University of California
Berkeley, CA 94720

Santa Clara Public library
2635 Homestead Road
Santa Clara, CA 95051

Sunnyvale Public library
Attn: Documents librarian
665 West Olive Avenue
Sunnyvale, CA 94086

Santa Clara County Library
1095 North 7th Street
San Jose, CA 95112

NASA, Anes Research Center
Technical library
fcfcffett Field
Sunnyvale, CA 94040
Northern California Corrmission
Environmental Information
P.O. Box 761
Berkeley, CA 94701
for
California Farm Bureau Federation
Attn: J. Goold
2855 Telegraph Avenue
Berkeley, CA 94705

California Wildlife Federation
and Salmon Unlimited
890 Washington
Santa Clara, CA 95050

National California Gomnission for
Environmental Information
1828 Hopkins Street
Berkeley, CA 94707

Bay Area League of Industrial Associations, Inc.
3640 Grand Avenue
Oakland, CA 94612

California Canners and Growers
312 Stockton Avenue
San Jose, CA 95126

California ttenufacturers Association
923-12th Street
Sacramento, CA 95814

Builders Assn. of Santa Clara and
Santa Cruz Counties
345 Saratoga Avenue
Santa Clara, CA 95050

Environmental Information Center
Environmental Studies Department
San Jose State University
125 South 7th Street
San Jose, CA 95114

Stanford Conmission for Environmental Information
Stanford University
lyfedical Center Room M-C
Stanford, CA 94301
144
-------
Santa Clara County Landowners Association
1020 Willow Street
San Jose, CA 95125

San Jose Chamber of Conmerce
Attn: Mr. Jim Tucker
1 Paseo de Antonio
San Jose, CA 95114

Central Santa Clara League of Women Voters
1142 South Genevieve Lane N-'
San Jose, CA 95128

Sierra Club
1711 Harte Drive
San Jose, CA 95124

League of Women Voters of Los Gatos
19224 Dehavilland Drive
Saratoga, CA 95070

Ecology Action
San Jose City College
2100 Moorpark Avenue
San Jose, CA 95114

Central Santa Clara Valley League
of Women Voters
1668 Juanita Avenue
San Jose, CA 95125

Marshland Development Go.
P.O. Box 205
Alviso, CA 95002

Sequoia Audubon Society
Attn: Ms. Ruth T. Smith
1231 Hoover Street
Menlo Park, CA 94256

Save Our Sloughs
c/o Ms. Nancy Holmes
843 Moana Court
Palo Alto, CA 94306

League of Women Voters of California
126^Post Street .
San Francisco, CA 94108
Peninsula Conservation Center
1176 Emerson Street
Palo Alto, CA 94301

Santa Clara Audubon Society
1176 Bnerson Street
Palo Alto, CA 94301

Committee for Green Foothills
1176 Bnerson Street
Palo Alto, CA 94301

Sierra Club
Loma Prieta Chapter
1176 Bnerson Street
Palo Alto, CA 94301

The Nature Conservancy Northern California
Attn: Ms. Mary Jefferds
2932 Pine Way
Berkeley, CA 94705

California Tomorrow
Monadnick Building
681 Market Street
San Francisco, CA 941.05

Mr. Vemon J. Smith
California Wildlife Federation
14690 Wyrick Avenue
San Jose, CA 95124

The Adam E. Treganza Anthropology Museum
San Francisco State University
1600 Holloway Avenue
San Francisco, CA 94132

Conservation Associates
220 Bush Street
San Francisco, CA 94104

California Native Plant Society
2490 Channing Way, itoom 317
Berkeley, CA 94704 '

People for Open Space
126 Post Street, foom 607
San Francisco, CA 94108

145
-------
Environmental Defense Fund
2728 Durant Avenue
Berkeley, CA 94704

San Francisco Bay Area Council, Inc.
World Trade Center
San Francisco, CA 94111

Environmental Quality Coordinating
Council of San Mateo County
P.O. Box 219
Menlo Park, CA 94025

Sierra Club
San Francisco Bay Chapter
5608 College Avenue
Oakland, CA 94618

Save San Francisco Bay Association
P.O. Box 925
Berkeley, CA 94701

P.G.& E. Land Department
77 Beale Street, Poom 1245
San Francisco, CA 94106

Mrs. Wn. McD. Eastman
13221 West Sunset Drive
Los Altos Hills, CA 94022

Raychem Corporation
Attn: Mr. Dick'Hopkins
300 Constitution Drive
Menlo Park, CA 94025
i
Coyote Point Museum
Coyote Point
San Mateo, CA 94401

Environmental Information Center
San Jose State University
125 South 7th Street
San Jose, CA 95192

San Mateo County Development Association, Inc.
4 West 4th Avenue
San Mateo, CA 94403

Santa Clara Audubon Society
14875 Cole Drive
San Jose, CA 95124

146
Anerican Society of Civil Engineers
160 Sansome Street
San Francisco, CA 94104

Automotive Assembly Division
Attn: R.M. Hanselinan
P.O. Box 1586
Allen Park, ME 48101

Santa Clara County Canners Association
Attn: L.K. Taber, Secty./Treas.
1007 L Street
Sacramento, CA 95814

lvt. Carl Harris
3708 Mt. Diablo Blvd.
Lafayette, CA 94549

Mr. Ken Boyd
4011 Glenwood Drive
Santa Cruz, CA 95060

City of Gilroy
Attn: Mr. Scott LaFauer
Gilroy, CA 95020

Mr. George Gritton
15045 Sycamore Avenue
Morgan Hill, CA 95037

Mr. George Green
P.O. Box 1368
Los Gatos, CA 95030

Mr. Neil Neilson
P.O. Box 1297
Los Altos, CA 94022

Ms. Roberta Varney
2375 Lida Drive
Mountain View, CA 94040

Mr. George Lydon
Greater San Jose Homeowners Association
2788 Woodmoor Drive
San Jose, CA 95127

Friends of the Earth
529 Conmercial Street
San Francisco, CA 94111
-------
Oceanic Society
Fort Mason Building, 240 -
San Francisco, CA 94123

Regional Parks Association
c/o Ms. Alice Q. Howard
6415 Regent Street
Oakland, CA 94612

W.W. Dada
Dried Fruit Association of California
Box 270A
Santa Clara, CA 95052

Ms. ^ary Anna Eklund
Return Oil & Rerefine
971 Ticonderoga Drive
Sunnyvale, CA 94037

Mr. Ronald Gerke
Ameron Pipe Products Group
Northern California Division
P.O. Box 3396
Hayward, CA 94540

A.B.M. Houston, Manager
Ford Motor Company
Compliance and Liaison Department
1 Parklane Blvd., Suite 628, Parklane Vfest
Dearborn,MI 48126

Mr. Dan Chapin
c/o Chapco
2200 Sand Hill Road
Menlo Park, CA 94025
Mr. John Jost
737 Harvard
Sunnyvale, CA
94087
Santa Clara Co. Medical Society
Attn: Dr. Kenneth Hayes
700 Bnpey Way
San Jose, CA 95128

Mr. Stephen D. Lux
361 Greenpark VJay
San Jose, CA 95136
Mr. Jim Quintal
California Canners and Growers
182 South Farroaks Avenue
Sunnyvale, CA 94086

Mr. Bd Ramey
Santa Clara Chamber of Coimierce
Industrial Citi2ens Council
Santa Clara, CA 95050

M.L. Sellers
lockheed Missile and Space Co.
P.O. Box 504
Sunnyvale, CA 94088

Me. Eddie Souza
4320 Bassett Street
Santa Clara, CA 95054

Ms. Bea Brown
Santa Clara Valley Coalition
485 Aspen Way
IDS Altos, CA 94022

E.L. Mitchell
312 Stockton Avenue
San Jose, CA 95126

R. Ilse and W. Doucett
182 South Fairoaks Avenue
Sunnyvale, CA 94086

Anerican Association of Uhiversity Wbraen
1165 Minnesota Avenue
San Jose, CA 95125

Ms. Julie Stephenson
1742 McBain Avenue
San Jose, CA 95125

People for Open Space
46 Kearny Street, Poora 400
San Francisco, CA 94108

Mr. Thomas 0. Chan,-Sr. Engineer
San Francisco Water Department
425 Mason Street
San Francisco, CA 94102
147
-------
Ihe Nature Conservancy
215 Market Street
San Francisco, CA 94105

Ms. Jane Baron
232 Hillview Avenue
Los Altos, GA 94022

Mr. Walter V. Hays
111 W. St. John Street
San Jose, CA 95113

J.B. Gilbert & Associates
Clareraont Hotel
Berkeley, CA 94705

George S. Nolte & Associates
Attn: Mr. Charles Hall
1731 N. First Street
San Jose, CA 95112

William Spangle & Associates
Attn: Mr. George Mader
3240 Alpine Road
Portola Valley, CA 94025

H.E. Stone
Bay Area League of Industrial Associations
P.O. Box 3575
San Francisco, CA 94119

Ford Motor Company
P.O. 1T01
San Jose, CA 95108

Mr. Edward Mitchell, President
Santa Clara County Canners Association
312 Stockton Avenue
San Jose, CA 95126
Ms. Bea Slater, Secretary
Textile Service Industries,
958-28th Street
Oakland, CA 94608
Inc.
Mr. Laurence B. Mitchell, Boardmember
Tri-County Apartment Association, Inc.
996 Minnesota Avenue
San Jose, CA 95125
Mr. Paul McKeehan
890 Washington Street
Santa Clara, CA 95050

Mr. John Sampson
3992 Bibbits Drive
Palo Alto, CA 94303

Jan Bridges
615 South Main Street
Milpitas, CA 95035

Mr. Patrick T. Ferraro
351 Brookwood Drive
San Jose, CA 95116

Mr. Charles Bigelow
873 Santa Cruz Avenue
Menlo Park, CA 94025

Marion Softkey
320 Fiicinal Avenue
^nlo Park, CA 94025

Mr. Spense Havlick
Environmental Studies Department
San Jose State University
San Jose, CA 95114

Dr. H.T. Harvey
Department of Biological Science
San Jose State University
San Jose, CA 95114

Brown and Caldwell
Attn: Mr. John T. Bovey
1501 N. Broadway
Walnut Creek, CA 94596
Rene Fuog
531 Sierra Avenue
Mountain View, CA
94041
Dr. R. G. Spicker
Civil Engineering
San Jose State University
San Jose, CA 95114
148
-------
Dr. G.E. Lindsay
California Academy of Sciences
Golden Gate Park
San Francisco, CA 94118

Dr. Itobert E. Selleck
Sanitary Engineering Res. lab.
U.C. Berkeley
Berkeley, CA 94720

Consoer-Townsend & Associates
1671 The Alameda
San Jose, CA 95126

Jenks and Adamson
543 Byron Street
Palo Alto, CA 94301

Kennedy Engineers
657 Howard Street
San Francisco, CA 94105

Metcalf and Eddy
1029 Corporation Way
Palo Alto, CA 94303

California Builders Council
925 L Street, Suite 700
Sacramento, CA 95814

Bay Area Clean Waters Conmission
1450 Creekside Drive
Walnut Creek, CA 94596

Conservation Coordinators
P.O. Box 4161
Woodside, CA 94062

Sierra Club
P.O. Box 7472
Stockton, CA 95207

Bay Area Planning Directors Association
835 East 14th Street
San Leandro, CA 94577

Ecology Center
2179 Alston Way
Berkeley, CA 94704
Assoc. Sportsman of California
2636 Judah Street
San Francisco, CA 94122

Stanford University
Sponsored Projects Information Center
Attn: Ms. Kathy Walby
Stanford, CA 94305

Stanford Conservation Group
Tresidder Union
Stanford University
Stanford, CA 94305

California Federation of Labor
995 Market Street
San Francisco, CA 94102

Bay Area Clean Water Council
5009 Charles Avenue
El Cerrito, CA 94530

South County Ecology Center
18313 Pepper Street
Castro Valley, CA 94546

TRI-City Ecology
2754 Olive Avenue
Fremont, CA 94538

League of Women Voters
P.O. Box 2638
Fremont, CA 94536

California Native Plant Society
2490 Channing Way, Ftoom 317
Berkeley, CA 94705

Sierra Club
Air Pollution Task Force
340 Johnson Avenue
Los Gatos, CA 95030

Chabot College
2555 Hesperin Blvd.
Hayward, CA 94545

Trustees for Conservation
170 Arlington Avenue -
Berkeley, CA 94707
149
-------
Ecology Center of San Francisco
13 Columbus Avenue
San Francisco, CA 94111

IDS Altos Chamber of Conmerce
321 university Avenue
Los Altos, CA 94022

Mountain View Chamber of Coimerce
580 Castro
Mountain View, CA 94040

Menlo Park Chamber of Conmerce
1100 Merrill
Menlo Park, CA 94025

Palo Alto Chamber of Commerce
2 Palo Alto Square
Palo Alto, CA 94304

Sunnyvale Chamber of Conmerce
South Murphy Avenue and West Olive Avenue
Sunnyvale, CA 94036

Santa Clara Chamber of Coinnerce
1515 El Camino Road
Santa Clara, CA 95050

Cupertino Chamber of Conmerce
10300 South Saratoga-Sunnyvale Road
Cupertino, CA 95014

San Mateo Co. Historical Museum Association
1700 West Hillsdale Blvd.
San Mateo, CA 94402

Historical Heritage Gommssion
County of Santa Clara
70 West Hedding Street, Room 524
San Jose, CA 95110

Department of Mthropology
Cabrillo College
6500 Sequel Drive
Aptos, CA 95003

Mr. Don Sandberg
Ruth and Going, Inc.
P.O. Box 26430
San Jose, CA 95159

150
Lc>rna Prieta Chapter
Sierra Club
SBDA Committee
1176 finer son
Palo Alto, CA 94301

Mr. Steve Krenselok
Environmental Impact Planning Corporation
319-11th Street
San Rrancisco, CA 94103

Mr. Michael Filice
NCC Food Corporation
570 Race Street
San Jose, CA 95126

Assoc. General Contractors of. California,
301 Capitol Mill
Sacramento, CA 95814

Ms. Betty Joyce Limysk
956 Trophy Drive
Mountain View, CA 94040

Mr. Gary Stevens
Biology Department
university of San Francisco
San Francisco, CA 94117 .

Mr. Martin Seldon
c/o Varian
611 Hansen Way
Palo Alto, CA 94303

Prof. Perry L. l-fcCarty
Civil Engineering Department
Stanford University
Stanford, CA 94305

Mr. Myron Tatarian
Public Vforks Department
City Hall, toom 260
San Francisco, CA 94102

A.H. Frye, Jr.
San Francisco Wkter District
425 Mason Street
San Francisco, CA 94102
Inc.
-------
Southern Pacific Transportation Company
Attn: J.W. Zwick
1 Market Street
San Francisco, CA 94105

Leslie Salt Company
7220 Central Avenue
Newark, CA 94560

Bechtel, Inc.
Attn: Ms. Carol M. Harper 301/4/B10
P.O. Box 3965
San Francisco, CA 94119

Mr. Michael Melanson
3717 Winston Way
Carmichael, CA 95608

E.H. Smith and Associates
Attn: E.H. Stnith
4090 Harrison Grade Road
Sebastopol, CA 95472
15
Hydroscience, Inc.
Attn: D. Szunsky
2815 Mitchell Drive
Walnut Creek, CA 94598

Pacific Environmental Laboratory
Attn: T. Nakamura
657 Howard Street
San Francisco, CA 94105

R.C. Harlan and Associates
Attn: R.C. Harlan
Sharon Building, Suite 401
55 New Montgomery
San Francisco, CA 94105
151
-------
STATE AGENCIES
California State Office of
Intergovernmental Management
Attn: Mark Briggs, Room 108
1400 - 10th Street
Sacramento, CA 95814
State Water Resources Control Board
Attn: Wayne Pierson
P.O. Box 100
Sacramento, CA 95801

University of California at Davis
Attn: Dr. Robert Hagen
Davis, CA 95616

State Attorney General's Office
6000 State Building
350 McAllister Street
San Francisco, CA 94102

State Office of Historic Preservation
1416 9th Street
Sacramento, CA 95814
20
State Department of Public Health
Attn: William Joppling
2151 Berkeley Way
Berkeley, CA 94704

Regional Water Quality Control Board
San Francisco Bay Region
Attn: Robert Scholar
1111 Jackson Street
Oakland, CA 94607

State Water Resources Control Board
Attn: Curtis Swanson
P.O. Box 100
Sacramento, CA 95801

Agricultural Extension Service
University of California
County of Santa Clara
Attn: Peter Lert
215 N. First Street
San Jose, CA 95113
152
-------
REGIONAL AGENCIES AND LOCAL GOVERNMENT
Bay Area Air Pollution Control District
939 Ellis Street
San Francisco, CA 94109

San Francisco Bay Conservation and
Development Commission
Attn: Patty Weesner
30 Van Ness Avenue
San Francisco, CA 94102

Metropolitan Transportation Commission
Hotel Claremont
Berkeley, CA 94705

Association of Bay Area Governments
Attn: Robert Wong
Claremont Hotel
Berkeley, CA 94705

Santa Clara County Health Department
Attn: E.H. Pearl
2220 Moorpark Avenue
San Jose, CA 95128

San Benito County Board of Supervisors
Attn: George E. Shore, Chairman
Courthouse, Boom 204
Hollister, CA 95023

South Bay Dischargers Authority
Attn: Mr. A.R. Turturici, Director
City of San Jose Public Works Department
801 North First Street
San Jose, CA 95110

City of San Jose
Attn: City Manager
801 North First Street
San Jose, CA 95110
City of San Jose
Planning Department
801 North First Street
San Jose, CA 95110

City of Santa Clara
Attn: Robert R. Mortenson
1500 Warburton Avenue
Santa Clara, CA 95059

City pf Hayward
Planning Department
22300 Foothill Blvd.
Hayward, CA 94541

City of Campbell
Planning Department
75 N. Central Avenue
Campbell, CA 95008

City of Newark
Planning Department
37101 Newark Blvd.
Newark, CA 94560

City of Fremont
Planning Department
39700 Civic Center Drive
Fremont, CA 94538

City of Palo Alto
Attn: City Manager
250 Hamilton Street
Palo Alto, CA 94301

City of Mountain View
Attn: Norman H. Dougee
540 Castro Street
Mountain View, CA 94041

City of Sunnyvale
Attn: City Manager
456 Olive Avenue
Sunnyvale, CA 94088
153
-------
South Santa Clara Valley Water Conservation District
Attn: Mike Sheeny
7951-B Wren Avenue
Gilroy, CA 95020

Agricultural Extension Service
University of California
County of San Benito
Attn: Edward Lydon
P.O. Box 820
Hollister, CA 95023

Santa Clara Valley Water District
Attn: Lloyd Fowler, Chief Engineer
5750 Almaden Expressway
San Jose, CA 95118

San Jose/Santa Clara Treatment Plant
Advisory Committee
Waste Pollution Control Plant
700 Los Esteros Road
San Jose, CA 95131

East Bay Dischargers Authority
Attn: Wayne Bruce
22300 Foothill Blvd.
Hayward, CA 94541

Menlo Park Sanitary District
500 Laurel Street
Menlo Park, CA 94025
Cupertino Sanitary District
20065 Stevens Creek Blvd.
Cupertino, CA 95014

Santa Clara County Sanitation District No. 4
100 E. Sunnyoaks Drive
Campbell, CA 95008

Santa Clara County Board of Supervisors
Attn: County Executive
70 West Hedding Street
San Jose, CA 95110
N. Daniels, General Manager
Union Sanitary District
4057 Baine Avenue
Fremont, CA 94536

Strategic Consolidation Sewerage Agency
666 Elm Street
San Carlos, CA 94020
Santa Clara County
Planning Department
70 West Hedding
San Jose, CA 95110

Santa Clara County
Parks and Recreation Department
70 West Hedding
San Jose, CA 95110

San Mateo County
Planning Department
County Government Center
Redwood City, CA 94063

San Mateo County
Attn: Henry F. Eich
Office of Environmental Health
590 Hamilton Street
Redwood City, CA 94063

San Mateo County
Parks and Recreation Department
County Government Center
Redwood City, CA 94063

Santa Clara County
Public Works Department
1555 Berger Drive
San Jose, CA 95112
154
-------
\\
City pf Santa Clara
Planning Department
1500 Warburton Avenue
Santa Clara, CA 95050

City of Mountain View
Planning Department
540 Castro Street
Mountain View, CA 94040

City of Sunnyvale
Planning Department
P.O. Box 607
456 W. Olive Avenue
Sunnyvale, CA 94088

City of Los Altos
Planning Department
IN. San Antonio Road
Los Altos, CA 94022

City of Palo Alto
Planning Department
Attn: Elizabeth Crowder
250 Hamilton Street
Palo Alto, CA 94301

City of Menlo Park
Director of Community Development
Civic Center
Menlo Park, CA 94025

City 9f San Mateo
Planning Department
330 W. 20th Avenue
San Mateo, CA 94402

City of Redwood City
Planning Department
1017 Middlefield Road
Redwood City, CA 94063
City 9f Milpitas
Planning Department
455 E. Calaveras Blvd.
Milpitas, CA 95035

City of Cupertino
Planning Department
City Hall, 10300 Torre Avenue
Cupertino, CA 95014

Town of Los Altos Hills
Planning Department
26379 Fremont Road
Los Altos Hills, CA 94022

City of Union City
Planning Department
1154 Wipple Road
Union City, CA 94587

City of Los Gatos
Planning Department
P.O. BOJ? 949
Los Gatos, CA 95030

City of Monte Sereno
Planning Department
18041 Saratoga-Los Gatos Road
Monte Sereno, CA 95030

City of Palo Alto
Attn: Mr. H.R. Remmel
250 Hamilton Avenue
Palo Alto, CA 94301

City of Sunnyvale
Attn: D.M. Somers
456 West Olive Avenue
P.O. Box 607
Sunnyvale, CA 94088

San Mateo County Board of Supervisors
County Government Center
Redwood City, CA 94063

155
-------
I /
San Mateo County
Engineering Department
County Government Center
Redwood City, CA 94063

Alameda County Planning Department
399 Elmhurst
Hayward, CA 94544

County of San Benito"
Attri: County Executive
Hollister, CA 95023

Mid-Peninsula Regional Park District
c/o Herbert Grench
745 Distell Drive
Los Altos, CA 94022
Parks and Recreation Department
Vasona Park
300 Garden Hill Drive
Los Gatos, CA 95030

Bay Area Rapid Transit District
800 Madison Street
Oakland, CA 94601

San Benito County Farm Bureau
Veterans Memorial Building
Hollister, CA 95023

Santa Clara County Grand Jury
Attn: Phyllis Austin
26650 St. Francis Drive
Los Altos Hills, CA 94022

Santa Clara County Farm Bureau
186 E. Gish Itoad
San Jose, CA 95112

LAFCO
1221- Oak Street
Oakland, CA 94612
156
San Francisco City and County Board of
Supervisors
City Hall
San Francisco, CA 94102

California Farm Bureau
Attn: William Du Bois
llth and L Streets
Sacramento, CA 95011

Mr. Richard R. Blackburn
South Bay Dischargers Authority
801 North First Street
San Jose, CA 95110

Mr. Frank Belick, Engineer-Manager
San Jose/Santa Clara Water Pollution
Control Plant
700 Los Esteros Rjad
San Jose, CA 95131

Mr. Don Atkinson, Division Chief Attorney
City Attorney's Office
151 West Mission Street, Raom 151
San Jose, CA 95110

Mr. William A. Gissler, Chairman
South Bay Dischargers Authority
1500 Warburton Avenue
San Jose, CA 95050

Ms. Janet Gray Hayes
South Bay Dischargers Authority
801 North First Street
San Jose, CA 95110

Ms. Suzanne Wilson
South Bay Dischargers Authority
801 North First Street
San Jose, CA 95110

Mr. Alan Henderson
South Bay Dischargers Authority
765 San Antonio Road, #81
Palo Alto, CA 94303
-------
Mr. Gilbert Gunn
South Bay Dischargers Authority
1693 Kitchener
San Jose, CA 94087
LEGISLATORS

Honorable Alan Cranston
United States Senator
452 Senate Office Bldg.
Washington, D.C. 20510

Honorable S.I. Hayakawa
United States Senator
452 Senate Office Bldg.
Washington, D.C. 20515

Honorable Norman Y. Mineta
Member of Congress, 13th District
510 Cannon House Office Bldg.
Washington, D.C. 20515

Honorable Don Edwards
United States Congressman
2240 Rayburn Office House Bldg.
Washington, D.C. 20515

Honorable Paul N. McCloskey, Jr.
United States Congressman
205 Cannon House Office Bldg.
Washington, D.C. 20515

Honorable Edmund Brown, Jr.
Governor of California
Sacramento, CA 95814

Honorable John Garamendi
State State Senator, District 13
State Capitol
Sacramento, CA 95814
Honorable Arlen Gregorio
State Senator, District 10
State Capitol
Sacramento, CA 95814

Honorable Jerry Smith
State Senator, District 12
State Capitol
Sacramento, CA 95814

Honorable Victor Calvo
State Assemblyman, District 21
State Capitol

Honorable Leona H. Egeland
State Assemblywoman, District 24
State Capitol
Sacramento, CA 95814

Honorable Richard D. Hayden
State Assemblyman, District 22
State Capitol

State Assemblyman, District 25
State Capitol
Sacramento, CA 95814

Honorable John Vasconcellos
State Assemblyman, District 23
State Capitol
Sacramento, CA 95814
157
-------
NEWS MEDIA

San Jose Sun Newspapers
Attn: Mort Levine
10950 N. Blaney
Cupertino, CA 95014

San Jose Mercury and News
Attn: Tom Harris
750 Ridder Park Drive
San Jose, CA 95113

Menlo-Atherton Recorder
640 Roble Avenue
Menlo Park, CA 94025

Suburban Newspapers
Attn: Susan Cohen
615 So. Main Street
Milpitas, CA 95035

San Mateo Times and News Leader
1080 S. Bayshore Boulevard
San Mateo, CA 94402

East San Jose Sun
Attn: Tom Gilsenon
615 So. Main Street
Milpitas, CA 95035

Palo Alto Times
Attn: Bob Burgess
Box 300
Palo Alto, CA 94303

San Francisco Chronicle
925 Mission Street
San Francisco, CA 94103
San Francisco Bay Guardian
2700 19th Street
San Francisco, CA 94132

San Francisco Examiner
Attn: Carl Irving
Box 3100
San Francisco, CA 94119

Oakland Tribune
13th and Franklin Streets
Oakland, CA 94612

KGO TV - Channel 7
277 Golden Gate Avenue
San Franisco, CA 94102

KQED - TV Channel 9
1011 Bryant Street
San Francisco, CA 94103

Margaret Race
KQED - TV Channel 9
500 8th Street
San Francisco, CA 94103

KPIX TV - Channel 5 •
2655 Van Ness
San Francisco, CA 94109

KBON TV - Channel 4
1001 Van Ness Avenue
San Francisco, CA 94119

KNTV - Channel 11
645 Park Avenue
San Jose, CA 95126
158
-------
\
ADDITIONS TO THE DISTRIBUTION LIST SINCE THE ISSUANCE OF THE DRAFT EIS/EIR
Ms. Janis Arnhols
Room 3425
U.S. Department of Commerce
Washington, D.C. 20230

Dr. Howard Wright
State Water Resources Control Board
P.O. Box 100
Sacramento, CA 95801

Mr. Wade Berry
Land Department, Rm 2B38
Pacific Gas and Electric
77 Beale Street
San Francisco, CA 94106

Mr. Norm Stinman
MTC
Hotel Claremont
Berkeley, CA 94705

Mr. Steve Morse
San Francisco Bay Regional Water Quality
Control Board
1111 Jackson Street, Rm 6040
Oakland, CA 94607

Office of Congressman Don Edwards
Attm Bob Wieckowski
Room 2329
Rayburn Building
Washington, D.C. 20515 '

Mr. Joe Brecher
506 15th Street
Oakland, CA 94612

Ms. Rose Thorogcod
Veterans Administration, Attn: 004A
810 Vermont Ave., N.W.
Washington, D.C. 20420

Mr. Steve Dalrymple
CH2M Hill
555 Capitol Mall
Suite 1290
Sacramento, CA 95814
Mr. G. Patrick Settles
Corporate Counsel
General Development Corporation
1111 South Bayshore Drive
Miami, FL 33131

Mr. Brad Barharo
David M. Darnbush & Co., Inc.
1736 Stockton Street
San Francisco, CA 94133

Mr. Craig Anderson
Environmental Quality Supervisor
Jefferson Parish
3600 Jefferson Highway
Jefferson, IA 20121

Mr. Mark Alpherson
ABAC
Hotel Claremont
Berkeley, CA 94705

Ms. Linda M. Botnick, Librarian
Clinton Bogert Associates
2125 Center Avenue
Fort Lee, New Jersey 07024

Ms., Sue Lasher
3181 Cecil Avenue
San Jose, CA 95117

Mr. Bert Martin
416 Juanita Drive
Santa Clara, CA 95050

Mr. Clifford Maurer
2251 Via Maderos
LOS Altos, CA 94022

Mr. Daniel Myers
510 Lincoln Avenue
Palo Alto, CA 94301

Mr. Stephen T. Hayashi
657 Benvenue
Los Altos, CA 94022
159

-------
Ms. Kathy Ryan - Harris
22270 Palm Avenue
Cupertino, CA 95014

Ms. Julia R. Raymond
1267 Scott Blvd.
Santa Clara, CA 95050

National Resources Defense Council
2345 Yale
Palo'Alto, CA 94306

Mr. Jeff Gabe
Citizens for Better Environment
88 First Street, Suite 600
San Francisco, CA 94105
Dr. Erman A. Pearson
Professor of Sanitary Engineering
Department of Civil Engineering
University of California
Berkeley, CA 94702

Mr. Bill Maddaus
J.B. Gilbert Division
Brown & Caldwell
1501 N. Broadway
Walnut Creek, CA 94596
160
-------