City of Clovis Sewage Treatment/Water Reuse Facility Program

Final Environmental Impact Report

City of Clovis Sewage Treatment/Water Reuse Facility Program

Prepared by:

City of Clovis 1033 Fifth Street Clovis, CA 93612 Contact: David E. Fey, AICP 559.324.2338

With technical assistance from:

Jones & Stokes 2841 Junction Avenue, Suite 114 San Jose, CA 95134 Contact: Kate Giberson 408.434.2244

July 2005

Final Environmental Impact Report City of Clovis Sewage Treatment/ Water Reuse Facility Program State Clearinghouse #2004061065

Prepared by: City of Clovis 1033 Fifth Street Clovis, CA 93612 Contact: David E. Fey, AICP 559/324-2338

With Technical Assistance from: Jones & Stokes 2841 Junction Avenue, Suite 114 San Jose, CA 95134-2122 Contact: Kate Giberson 408/434-2244

July 2005

Jones & Stokes. 2005. Final Environmental Impact Report: City of Clovis Sewage Treatment/Water Reuse Facility Program. State Clearinghouse #2004061065. July. (J&S 04377.04.) San Jose, CA. Prepared for City of Clovis, Clovis, CA.

TABLE OF CONTENTS

Section 1. Purpose and Format of the Final EIR ................................................1-1 Project Overview...............................................................................1-1 Purpose of the Final EIR...................................................................1-2 Format of the Final EIR.....................................................................1-2 Section 2. Comments on the Draft EIR and Responses ....................................2-1 Response to Comment Letter I (State Clearinghouse) .....................2-3 Response to Comment Letter II (California Department of Health Services)................................................................2-4 Response to Comment Letter III (California Regional Water Quality Control Board).................................2-5 Response to Comment Letter IV (San Joaquin Valley Air Pollution Control District) ...............................................2-15 Response to Comment Letter V (County of Fresno Department of Community Health) .....................................2-19 Response to Comment Letter VI (Fresno Metropolitan Flood Control District) .........................................................2-20 Response to Comment Letter VII (Clovis Unified School District)....................................................................2-25 Response to Comment Letter VIII (Jeffer Mangels Butler & Marmaro on Behalf of McFarlane & McFarlane)..........................................................................2-26 Response to Comment Letter IX (Gene Borré) ..............................2-27 Response to Comment Letter X (Clovis Planning Commission Meeting Minutes)............................................2-29 Section 3. Errata to the Draft EIR.........................................................................3-1

List of Tables Page 1

List of Commenters ....................................................................................................................... 2-2

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Section 1

Purpose and Format of the Final EIR

Project Overview The City of Clovis (City) proposes to construct and operate a sewage treatment/water reuse facility (ST/WRF) that would provide an alternative solution to its current sewage (wastewater) treatment services capabilities. The City, located in Fresno County, currently maintains an agreement with the City of Fresno to convey Clovis’ wastewater to the Fresno-Clovis Regional Wastewater Treatment Plant (RWTP) southwest of Fresno. The ST/WRF Program (proposed project) would include construction and operation of the following components: an 8.4-million-gallon-per-day (mgd) ST/WRF in the Southeast Urban Center Specific Plan area, additional wastewater collection facilities (pipelines and Sewer Pump Station B), and new recycled water distribution facilities (pipelines, booster pump stations, and storage facilities). In the near term, the ST/WRF would treat all wastewater flows from the Southeast Urban Center Specific Plan area. In the long term, it would treat all wastewater flows from the future Northwest and Northeast Urban Center Specific Plan areas. The recycled water would be distributed throughout the greater Clovis area. The recycled water produced at the ST/WRF would meet Title 22 standards (22 California Code of Regulations [CCR] 60301.230) (California Department of Health Services 2001) for highest and best use of reclaimed water resource use, as well as all federal, state, and local requirements for use without restriction for irrigation. Title 22 is a stringent recycled water regulation that is being used as a model for other states. Recycled water produced under Title 22 regulations and State Water Resources Control Board (SWRCB) requirements can be used without restriction for public open space irrigation, agricultural irrigation, recreation, and many commercial/industrial applications.

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Purpose and Format of the Final EIR

Biosolids resulting from the treatment process would be transported to the Clovis Landfill or other appropriate disposal facility.

Purpose of the Final EIR Under the California Environmental Quality Act (CEQA), the City is required, after completion of a draft environmental impact report (EIR), to consult with and obtain comments from public agencies having jurisdiction by law with respect to the proposed project, and to provide the general public with an opportunity to comment on the draft EIR. The City, as the lead agency, is also required to respond to significant environmental issues raised in the review and consultation process. This final EIR has been prepared to respond to public agency and general public comments received on the draft EIR for the ST/WRF project, which was circulated for public review from April 6 to May 20, 2005, and to respond to verbal comments received at the public meeting, which was held on May 12, 2005.

Format of the Final EIR This document and the draft EIR (March 2005), herein incorporated by reference, constitute the final EIR, as allowed by Section 15088(d) of the State CEQA Guidelines. Both parts of the final EIR are available at the City of Clovis Planning and Development Services Department. In addition to this section describing the purpose and format of the final EIR, the document includes the following sections. Section 2. Comments on the Draft EIR and Responses. Section 2 contains copies of all written comments received on the draft and the responses to these comments. Table 1 lists all parties who prepared written comments on the draft EIR. Each comment letter is numbered with a Roman numeral in the top right corner, and individual comments within the letter are numbered with Arabic numerals in the right margin. Section 3. Errata to the Draft EIR. Section 3 contains errata presenting text from the draft EIR that has been amended as a result of comments received during the draft EIR public review process or for clarification. Changes to the draft EIR are shown with page revisions in the order they appear in the draft EIR. Text in standard print is original text from the draft EIR. Underlined text indicates additions to the original text, and strikeout text indicates deletions to the original text.

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Section 2

Comments on the Draft EIR and Responses

This section contains written and verbal comments received on the draft EIR and responses to those comments. The written comments were received during the draft EIR public review period, from April 6, 2005, to May 20, 2005. The verbal comments were received at the public Clovis Planning Commission meeting held on May 12, 2005. As described in Section 1, each comment and response is identified with corresponding numbers. Each written comment letter is followed by a response to the comments in the letter. The responses are page-numbered, but the comment letters are not. This section also contains the Acknowledgement of Receipt from the California Governor’s Office of Planning and Research, which acknowledges that the State Clearinghouse received the draft EIR and indicates to which agencies it distributed the draft EIR. Table 1 lists the names of the individuals and organizations that provided comments on the draft EIR during the public review period, and the names of the individuals who commented during the public meeting.

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Table 1. List of Commenters

Date

Received From

Letter #

Response Page #

May 20, 2005

Governor’s Office of Planning and Research – State Clearinghouse

I

2-3

April 15, 2005

California Department of Health Services, DWFOB – Merced District

II

2-4

May 23, 2005

California Regional Water Quality Control Board Central Valley Region

III

2-5

May 19, 2005

San Joaquin Valley Air Pollution Control District

IV

2-15

May 16, 2005

County of Fresno Department of Community Health, Environmental Health Division

V

2-19

May 24, 2005

Fresno Metropolitan Flood Control District

VI

2-20

May 23, 2005

Clovis Unified School District

VII

2-25

May 20, 2005

Jeffer Mangels Butler & Marmaro (on behalf of McFarlane & McFarlane)

VIII

2-26

May 18, 2005

Gene Borré

IX

2-27

May 12, 2005

Clovis Planning Commission Meeting Minutes

X

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I

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter I (State Clearinghouse) This letter is for information only and does not contain specific comments on the draft EIR. The letter acknowledges that the State Clearinghouse received the draft EIR for the Clovis Sewage Treatment/Water Reuse Facility Program and that it was distributed to a number of state agencies for possible review and comment. A list of all agencies that received a copy of the draft EIR is provided in the letter. The letter notes that no state agencies submitted comments through the State Clearinghouse by the close of the comment period.

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II

II-1

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter II (California Department of Health Services) Comment II-1. The commenter states that Table 2-2, which shows the filtered water turbidity performance criteria, needs to be corrected to more accurately reflect the Title 22 Water Recycling Criteria. Response: Comment noted. The draft EIR (Table 2-2, which follows page 2-6 in Chapter 2) has been revised to make the clarification suggested by the Department of Health Services. See Section 3, “Errata to the Draft EIR,” for specific changes to Table 2-2 in the draft EIR.

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III

III-1

III-2

III-3

III-3 cont.

III-4

III-4 cont.

III-4 cont

III-5

III-6

III-6 cont.

III-7

III-8

III-9

III-10

III-11

III-11 cont.

III-11 cont.

III-12

III-13

III-13 cont.

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter III (California Regional Water Quality Control Board) The comments begin on page 3 of the comment letter. Comment III-1. The commenter asks the City to address its project capacity (estimated at 21.4 mgd in the Regional Water Quality Control Board [RWQCB] letter) at buildout in 2030. Response: The total wastewater capacity required at buildout of the 1993 Clovis General Plan area by year 2030 is estimated to be 21.7 mgd. (Wastewater Master Plan Update, Phase 1-B. Dated November 20, 1996. Prepared by Blair, Church & Flynn Consulting Engineers 1996). This need would be met through continued participation in the Fresno-Clovis Regional Wastewater Treatment system operated by the City of Fresno and Clovis’ proposed Sewage Treatment/Water Reuse Facility (ST/WRF). Clovis would continue to participate in the regional wastewater system to maximize its use of the existing four trunk sewers that serve Clovis. Per the Joint Powers Agreement between Fresno and Clovis, the City initially purchased 6.3 mgd capacity in the system. Per the Joint Powers Agreement Supplemental Agreement No. 1, dated October 16, 1987, the City of Fresno is obligated to provide an addition 9.8 mgd system capacity to the City of Clovis. Of that additional 9.8 mgd, the City has purchased 3 mgd to date. Therefore, the City will be able to purchase an additional capacity of 6.8 mgd, for a total of 16.1 mgd. This capacity, combined with the proposed ST/WRF capacity (16.1 + 8.4 = 24.5 mgd) would meet and exceed the estimated 21.7 mgd demand by 2030. No changes to the EIR are required. Comment III-2. The commenter makes four primary points. Each point is presented below, followed by a response. 1.

The description of wastewater distribution after treatment is too general to adequately assess potential environmental impacts.

Response: The use of the term “wastewater” is not correct. California law refers to the water as “recycled water” not wastewater. The recycled water distribution system would encompass the entire City of Clovis. Although the larger recycled water transmission mains extending from the ST/WRF would be constructed prior to 2008 when Phase I operation begins, the smaller distribution lines would be installed incrementally during Phases I, II, and III of operation through 2030. As described in Chapter 1 under “Purpose of This EIR” and in Chapter 3 under “Level of Analysis,” the environmental impact analysis of the smaller recycled water distribution pipelines is more general or programmatic because the specific timing is not known and the specific locations are subject to modification as project planning proceeds and design details arise. Therefore, potential impacts and mitigation to reduce the impacts to a lessthan-significant level have been identified to the programmatic level of detail permitted by CEQA. As the recycled water distribution system is installed (smaller lines extending from the larger transmission main), the City will determine whether the smaller pipeline installation Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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projects fall within the purview of this EIR. If they are found to result in new environmental impacts that were not examined in this EIR, additional CEQA review would be required. This approach is allowed under CEQA (State CEQA Guidelines Section 15168). A Program EIR, a type of first-tier document, is prepared for an agency program or series of actions that can be characterized as one large project; and Program EIRs typically analyze environmental issues at a more general level. Once a Program EIR has been prepared, subsequent activities within the program must be evaluated to determine whether an additional CEQA document needs to be prepared. 2.

The description of wastewater distribution after treatment contradicts information provided to the RWQCB staff by Fresno Irrigation District (FID) management about how FID manages their system.

Response: The City is distributing and discharging recycled water suitable for all DHSapproved uses including body contact. The use of the term wastewater blurs the distinction between wastewater and recycled water that has been repeatedly recognized by the Legislature, as noted in the RWQCB’s letter dated February 24, 2004, concerning incidental runoff. Based on the City’s consultation with FID staff, FID recognizes the importance of this project in providing a new source of water for the area. The City is in discussion with FID about incorporating the recycled water into FID’s water management budget. This is a logistics issue that will be resolved prior to the RWQCB issuing a NPDES permit. 3.

Generally, the Fresno Metropolitan Flood Control District (FMFCD) does not allow wintertime discharge to their flood control canals. If FMFCD does not take the water in winter, then the discharge to Little Dry Creek is not really an “option” but a necessity for 2 to 4 months a year, resulting in a substantial amount of water and local groundwater being exported out of its basin of origin.

Response: Based on the City’s consultation with FMFCD staff, FMFCD recognizes the importance of this project in providing a new source of water for the area. The City and FMFCD are in discussion about the logistics involved in the winter-time discharges to their flood control system. These criteria will be identified and provided to the RWQCB with the application for the NPDES permit. Discharge to Little Dry Creek Diversion Channel to Big Dry Creek is an alternative, contingency outfall that would be used only if there is excess recycled water not used by the recycled water users or FID. Incidental recharge from the Friant-Kern Canal currently imports water from outside the local groundwater basin into Clovis’ groundwater basin. The amount of water proposed to discharge into the Little Dry Creek Diversion Channel to Big Dry Creek is approximately 4 to 16 percent of the total new water produced during any year of operation, depending on FID’s Fancher Creek maintenance and irrigation schedule that ranges from weeks to months. This is not a substantial amount of water compared to the amount being supplied to FID that remains in the groundwater basin. Also, the area along the Little Dry Creek Diversion Channel to Big Dry Creek has poor groundwater quality with high nitrate concentrations and a lack of groundwater; any incidental recharge along that channel may be beneficial. Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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4.

Comments on the Draft EIR and Responses

Tulare Lake Basin is water short, and exporting water could result in a potentially significant impact, with several mitigation measures not considered in the draft EIR.

Response: We agree that the Tulare Lake Basin is water short. The proposed project would be an important new source of water for the City of Clovis. Also, the Water Quality Control Plan for the Tulare Lake Basin (referred to as the Tulare Lake Basin Plan) encourages reclamation on irrigated crops wherever feasible and indicates that evaporation of reclaimable wastewater is not an acceptable disposal method where the opportunity exists to replace an existing use or proposed use of fresh water with recycled water (Tulare Lake Basin Plan, pages IV-11 and IV12). The proposed project would provide recycled water as a replacement of fresh water currently used for irrigation. This is considered a beneficial effect of the project. The intent of the project is to maximize the use of recycled water within the City or its immediate neighbors, including California State University (CSU) Fresno and California Department of Transportation (Caltrans). Caltrans is obligated by State law to use recycled water for their highway landscape irrigation when recycled water is available to them. Exporting water will be minimized as much as possible unless a beneficial user is identified that requires the recycled water outside the basin. The Tulare Lake Basin is a major importer of water from the San Joaquin River watershed and other more northerly watersheds. The potential export of part of the recycled water produced by the project is minimal in comparison to the quantities imported into the Tulare Lake Basin. Mitigation measures are not necessary for the limited amount of this new water supply potentially flowing into the San Joaquin River. Comment III-3. The commenter identifies portions of the California Water Code and Title 22 water recycling requirements that are relevant to the proposed project but were not cited in the draft EIR. Response: The EIR (Chapter 2, pages 2-22 and 2-23, and Chapter 3, page 3.3-25) has been modified to reference applicable sections of Title 22 and the Water Code. See Section 3, “Errata to the Draft EIR,” for specific changes to pages 2-22, 2-23, and 3.3-25 in the draft EIR. Comment III-4. The commenter identifies three primary points. Each point is presented below, followed by a response. 1.

The proposed project will need to be consistent with RWQCB plans and policies, including but not limited to the Tulare Lake Basin Plan, the San Joaquin and Sacramento River Basin Plan, SWRCB Resolution 68-16 (the Antidegradation Policy), SWRCB 88-63 (Sources of Drinking Water), the National Toxics Rule, the California Toxics Rule, and Title 22 water recycling requirements.

Response: The City appreciates the input from the RWQCB regarding compliance with RWQCB plans and policies, including the discussion of anticipated effluent limits.

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2.

Comments on the Draft EIR and Responses

The commenter also identifies beneficial uses of the surface waters that could be affected by the proposed project, and clarifies the 303(d) listing for the reach of the San Joaquin River into which Little Dry Creek empties. The commenter notes that the draft EIR states that mixing and dilution studies will be provided to the RWQCB, but that they have not been provided in the National Pollutant Discharge Elimination System (NPDES) permit application to date.

Response: The City intends to obtain an NPDES permit, which will address the relevant water quality policies and regulations. While an initial NPDES permit application has been filed, the project is still in the preliminary stages of design. As a result, many of the details that are ultimately included with such a permit application are not available at this time. As the City moves forward with the design of the SR/WTF, and the SR/WTF’s expected performance from a water quality standpoint becomes better defined, the City will submit the necessary materials as required by the RWQCB to support of issuance of an NPDES permit. Under no circumstances would the City discharge effluent that would violate the NPDES permit. As the RWQCB is aware, all NPDES permits should be designed to result in compliance with relevant plans and policies. 3.

The commenter discusses the lack of available dilution credits when discharging into “effluent dominated water bodies”; discusses likely NPDES permit requirements for effluent discharge; and questions the “significant and unavoidable” determination related to effluent discharge, citing the availability of alternatives and mitigation measures to reduce impacts.

Response: Given the fact that the project is in the preliminary design phase, the draft EIR analyzed the effects of effluent discharge in a programmatic fashion and made worst-case assumptions regarding the impacts of effluent discharge. This is appropriate given the nature of the draft EIR as a Program EIR. Impacts are likely to be smaller than those characterized in the draft EIR, and it is possible that design features or mitigation are available to reduce potential impacts. Given the stage of design, it is not possible to identify such alternatives or mitigation at this time; hence, the determination of a significant and unavoidable impact related to effluent discharge. In summary, the City looks forward to working with the RWQCB through the NPDES permitting process to ensure that effluent discharged from the SR/WTF is consistent with RWQCB plans and policies. The comment does not result in any changes to the draft EIR. Comment III-5. The commenter states that use of the recycled water is a discharge to groundwater, indicating that the definition of agronomic rate includes a fraction of water applied to leach salts from the soil with the water reaching groundwater. The City needs to qualify these impacts in the EIR through an antidegradation analysis. Response: The City agrees that the definition of agronomic rate includes occasionally flushing the salts from the root zone of the vegetation. Best Management Practices limit the amount of flushing to minimize or eliminate salts affecting groundwater. With minimal flushing, the leached salts normally concentrate below the root zone and above groundwater. Based on soil boring data collected within the City, the sediments generally have cementation zones Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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consisting of silica-rich, iron-rich, or calcium-rich deposits. These cementateous deposits create low permeability horizons that impede and restrict the downward percolation of the recycled water to groundwater. These zones are often referred to as hardpan. A comprehensive antidegradation analysis is not typically included in an EIR. As a Program EIR, the impact analysis has been conducted at a conceptual level. Although an antidegradation analysis would provide additional detail, it would be unlikely to change the fundamental conclusions in the draft EIR regarding the potential impacts of the project. In fact, preparation of an antidegradation analysis at this conceptual stage of project design could result in inaccurate or erroneous conclusions. For these reasons, no antidegradation analysis has been, or will be, prepared as part of the EIR. The NPDES permit process is the traditional forum in which to provide this more detailed, scientific analysis, if necessary. A conceptual antidegradation analysis was presented in the Report of Waste Discharge, which was submitted to and accepted by the RWQCB in December 2004 as adequate to initiate the NPDES permit process. The conceptual antidegradation analysis presents conveyance routes for both recycled water outfalls, showing that groundwater beneath both routes are currently degraded and that the recycled water would potentially improve or, at least, not degrade current groundwater conditions. The Water Quality Control Plan (Basin Plan) for the San Joaquin River discusses the necessity for providing information concerning the potential for the discharge to affect surface water or ground water quality in the region in the NPDES permitting process. On page IV-16.00, the Basin Plan states: “The extent of information necessary will depend on the specific conditions of the discharge. For example, use of best professional judgment and limited available information may be sufficient to determine that ground or surface water will not be degraded.” As noted in the waste discharge permit for the Fresno-Clovis RWTP issued by the RWQCB: The Board finds that some degradation of groundwater beneath the (FresnoClovis) WWTF and reclamation and disposal areas is consistent with Resolution 68-16 (Antidegradation Policy) provided that the degradation is confined to a specified area; the Discharger minimizes the degradation by fully implementing, regularly maintaining, and optimally operating best practicable treatment and control (BPTC) measures; the degradation is limited to waste constituents typically encountered in municipal wastewater…; and the degradation does not result in water quality less than that prescribed in the Basin Plan. Considering that the recycled water from the Fresno-Clovis RWTP has been treated to secondary treatment standards and the proposed Clovis ST/WRF recycled water would be treated to tertiary treatment standards plus additional denitrification, degradation of groundwater would be minimal. Waste constituents typically encountered in municipal wastewater usually have some industrial constituents. Because Clovis wastewater has minimal industrial constituents, the recycled water generated by the ST/WRF would result in less impact than discharges from the Fresno-Clovis RWTP. Additionally, both facilities are within the U.S. Environmental Protection Agency sole source aquifer area, as are the treatment plants in communities immediately west and southwest Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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of the regional Fresno-Clovis WWTP. The existing conceptual antidegradation analysis may be sufficient for the NPDES permit process, and its summary is sufficient for this programmatic EIR because of the conceptual nature of the discharge from the proposed ST/WRF. Also, the San Joaquin Basin Plan (Page III-1.00) cites the Porter-Cologne Water Quality Control Act as stating that, in establishing water quality objectives, the RWQCB must consider...the following factors: economic considerations; the need for developing housing within the region; and the need to develop and use recycled water (Water Code Section 13241). Further clarification about antidegradation effects to be evaluated during the NPDES permit process are found in State Water Resources Control Board (SWRCB), Administrative Procedures Update (APU) 90-004, dated July 2, 1990, page 3: …An antidegradation analysis is needed to support all regulatory actions that in the Regional Board’s judgment will result in a significant increase in pollutant loadings. The Regional Boards must consider antidegradation effects and conduct an antidegradation analysis when the proposed activity results in: 1) A substantial increase in mass emissions of a pollutant, even if there is no other indication that the receiving waters are polluted; or 2) Mortality or significant growth or reproductive impairment of resident species. In particular, an antidegradation finding should be made and, if necessary, an analysis should be conducted when performing the following permit activities: 1) Issuance of a permit for any new discharge, including Section 401 certifications; or 2) Material and substantial alterations to the permitting facility, such as relocation of an existing discharge; or 3) Reissuance or modification of permits which would allow a significant increase in the concentration or mass emission or any pollutant in the discharge. SWRCB APU 90-004 indicates that the antidegradation review required in SWRCB Resolution No. 68-16, Statement of Policy with Respect to Maintaining High Quality Waters in California (also referred to as the Antidegradation Policy), can range from an antidegradation finding to a more comprehensive antidegradation analysis and does not necessarily require an antidegradation analysis in the NPDES permit process. Based on the above information, no change in the EIR is necessary. The City will continue to discuss with the RWQCB the appropriate level of information necessary for the NPDES permit process. Comment III-6. The commenter states that the alternatives evaluated in the draft EIR should include using the ST/WRF effluent on agricultural lands overlying groundwater with salinity comparable to or higher than the effluent. The evaluation should include an analysis of the costs associated with the degradation of the groundwater beneath Clovis over the life of the project. This alternative would be consistent with the RWQCB’s recycling policy and with the project’s supporting objectives. Response: This project alternative was considered and dismissed because it did not meet project objectives and because it was costly. Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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Comments on the Draft EIR and Responses

CEQA requires that an EIR consider a “reasonable range” of alternatives to the proposed project or project location. An EIR does not need to consider every conceivable alternative to a project. Rather, the alternatives considered are limited to those that meet most of the basic project objectives, appear to be feasible, and would avoid or substantially lessen at least one of the significant effects. Further, CEQA does not require the alternatives to be evaluated in the same level of detail as the proposed project. The EIR must include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. (State CEQA Guidelines Section 15126.) The City has given extensive consideration to the various alternatives. As described in Chapter 5 of the draft EIR under “Development of Project Alternatives,” the City considered several alternative means for providing service, alternative treatment plant sites, and alternative treatment processes. The discussion in Chapter 5 explains how they identified a preferred alternative (which became the proposed project) and the project alternatives that were evaluated in the draft EIR. No changes to the draft EIR are required. Comment III-7. The commenter identifies the potential water quality and public health impacts of incidental runoff from surface application of reclaimed water and states that the FMFCD’s NPDES permit regulating stormwater discharge does not identify recycled water as one of the sources of runoff. Response: Incidental runoff would be minimized through application of reclaimed water at the agronomic rate of the crop in question. As a result, the frequency and magnitude of surface runoff is anticipated to be minimal. Second, any incidental runoff would consist of highquality, tertiary-treated reclaimed water, which would meet all relevant standards related to bacteriological contamination and water quality, and therefore is not anticipated to pose any public health hazard or have a significant potential to degrade surface water quality. Third, the RWQCB in their letter dated February 24, 2004, state that regional boards should include the following language in water recycling requirements: The incidental discharge of recycled water to waters of the State is not a violation of these requirements if the incidental discharge does not unreasonably affect the beneficial uses of the water, and does not result in exceeding an applicable water quality objective in the receiving water. Further, the RWQCB letter points out that in some instances regional boards assume that any amount of incidental runoff requires the regional board to treat the runoff as a discharge of treated wastewater requiring an NPDES permit (referred to as the ‘one molecule rule’). This approach is problematic for several reasons. Most importantly, this permitting practice renders the use of recycled water undesirable for many parties. Customers are not willing to assume the cost and the potential liability associated with ensuring that no incidental runoff will ever leave the permitted application area. Moreover, this approach does not properly acknowledge that recycled water quality is already regulated by both regional boards and the Department of Health Services, and must meet stringent requirements at the time it is applied to the site.

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Comments on the Draft EIR and Responses

Finally, the prohibition approach blurs the distinction between wastewater and recycled water that has been repeatedly recognized by the Legislature. The City believes that the factors cited above do not necessitate amendment of FMFCD’s NPDES permit, other than noting during the routine renewal process that incidental runoff of recycled water may enter the FMFCD stormwater system. However, if required, the City would work with the FMFCD to amend the permit to identify the incidental runoff of reclaimed water as one of the sources of surface runoff. No changes to the draft EIR are required. Comment III-8. The commenter identifies the potential for degradation of groundwater with salts and other constituents as a result of recycled water application. Response: Deep percolation of recycled water is unlikely because application of recycled water would be limited to the agronomic rate of the crop in question, and incidental percolation is unlikely to reach the underlying aquifer. While quantities of water that exceed the agronomic rate would be applied periodically to provide for flushing of salts from the soil, the quantities of water applied for such a purpose would be limited to the minimum necessary, would percolate only as far as the underlying soil horizon, and would not reach the aquifer. In addition, the salt content of the recycled water is generally anticipated to be at or below the concentrations currently found in groundwater throughout most parts of the basin. In the unlikely event that applied recycled water reached groundwater, it would result in the maintenance or improvement of groundwater TDS levels. For other areas with lower groundwater TDS—or in the case of other water quality constituents, concentrations in the applied water would be low enough and the amount of deep percolation small enough, that measurable degradation of groundwater quality is unlikely; and beneficial uses of groundwater would be maintained. As stated earlier, the draft EIR is a Program EIR; as such, a quantitative evaluation of such impacts is beyond the scope of the document. Such quantitative analyses of effects may be relevant to the NPDES permit process but are not necessary to support the conclusions of the document under CEQA. No changes to the draft EIR are required. Comment III-9. The commenter states that when the canals are not carrying flows, they are linear impoundments of recycled water and should comply with the setback requirements related to domestic water supply wells. Response: The City disagrees with the assertion that the canals constitute linear impoundments under the definition provided in Title 22 Section 60310. The irrigation and diversion canals are designed for conveyance of water. CCR § 6000 specifically addresses this, when it defines an “artificial recharge basin” as “a surface facility, such as an infiltration pond or basin, or spreading ground specifically designed and managed to increase the infiltration of introduced surface water supplies into a ground water basin. …Artificial recharge basin does not include ditches, canals…”. Because the irrigation and diversion canals are not

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impoundments, Title 22 Section 60310(b) does not apply to them. Therefore, the 100-foot setback requirement does not apply. No changes to the draft EIR are required. Comment III-10. The commenter requests that the EIR provide more current information regarding TDS concentrations in the King’s Subbasin. Response: The information that the commenter requests is not required to understand the impacts of the proposed project. Therefore, it has not been provided. No changes to the draft EIR are required. Comment III-11. The commenter states the draft EIR should include an antidegradation analysis and outlines the required contents of such an analysis. Response: Refer to response to Comment III-5. Comment III-12. The commenter states that the draft EIR should discuss the need for a pretreatment program and provide information demonstrating that the City has adequate longterm resources to support the ST/WRF and its pretreatment program. Response: Per the Joint Powers Agreement between the City of Fresno and the City of Clovis, and Addendum No. 7, dated September 23, 2003, the City of Fresno is designated as the agency primarily responsible for implementation of the Fresno-Clovis Metropolitan Regional Wastewater Pretreatment Program. This program covers the entire city of Clovis. It is intended that the program will continue to apply to all areas served by the City of Clovis wastewater system, including the proposed treatment facility. CEQA does not require a draft EIR to demonstrate that funding is available for a proposed project or program, nor does it require the analysis of economic and social effects. Effects analyzed under CEQA must be related to a physical change in the environment. (State CEQA Guidelines Section 15358[b].) This comment does not result in any changes to the draft EIR. Comment III-13. The commenter states that the Clovis Landfill is not permitted to accept Class II wastes, including the biosolids that would be generated by the proposed ST/WRF. The EIR should evaluate alternatives to the proposed biosolids disposal and should include an evaluation of the beneficial uses of the biosolids. Response: As described in Chapter 2 under “Solids Management and Disposal,” the biosolids would be processed on site to be suitable for offsite disposal at the Clovis Landfill. The City is pursuing revisions and updates to the permit and Waste Discharge Requirements (WDRs) for the landfill, and is in the process of preparing an EIR to address associated environmental issues. Among other issues, the EIR addresses the City’s plans to upgrade the facility’s permit/WDRs to allow the disposal of Class II wastes that specifically include biosolids from the ST/WRF. Once the EIR is certified, the City of Clovis will be submitting a Report of Waste Discharge to the RWQCB, in the form of a Joint Technical Document, for revisions and updates to the WDRs for the Clovis Landfill. The projected date for completion of the new Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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permit and WDRs for the landfill is December 31, 2006, which will be well ahead of the projected schedule for commencement of operations of the ST/WRF. The liner system that is currently approved for the Clovis Landfill consists of a textured 60millimeter (-mil) high-density polyethylene (HDPE) geomembrane over a geosynthetic clay liner on the floor of the cells and a single textured 80-mil HDPE liner on all side slopes that exceed a 2 to 1 slope. The City is proposing to continue to use this same liner system under the new permit/WDRs and will submit a performance demonstration prior to the construction of any new cells. If the ST/WRF begins operations prior to completion and acceptance of the performance demonstration, the biosolids will need to be disposed of at one of the alternate disposal sites (Kettleman or Fairmead) until the performance demonstration is complete. The delivery of biosolids to the landfill is not anticipated to begin at least until 2008. The City will pursue performance demonstration approval for the existing cells and obtain approval for the existing cells to accept Class II wastes if the City determines that it is advisable to deliver Class B solids to the landfill prior to the construction of the next cell liner. This would entail accelerating the performance demonstration’s timeline from what is described in the draft Joint Technical Document. The City appreciates the information regarding biosolids disposal. Due to the limited quantity of biosolids that will be produced at the ST/WRF, the City does not anticipate investing in the equipment or facilities required to convert the Class B solids to Class A solids at this time. The project description includes “alternative daily cover” as an alternative to disposal at the Clovis Landfill, whereby the biosolids can be combined with alkaline and acidic materials to produce a soil-like material for use as a daily cover at solid waste landfills (refer to page 2-10 of the draft EIR under “Transport and Disposal”). The City will pursue possible alternative treatment options when available, whereby the Class B solids may be delivered to a third party engaged in composting or other methods of converting the solids from Class B to Class A. Regarding the beneficial uses of biosolids in the draft EIR, the purpose of an EIR is to evaluate the adverse impacts of a proposed project. An evaluation of the beneficial uses of the biosolids is beyond the scope of the EIR and, as such, has not been conducted. The potential impacts of biosolids disposal have been adequately described in the draft EIR, in Section 3.3, “ Hydrology and Water Quality,” under “Impact HYD-5: Minimal Potential for Degradation of Water Quality Resulting from Biosolids Disposal and Reuse.” This comment does not result in any changes to the draft EIR.

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City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter IV (San Joaquin Valley Air Pollution Control District) Comment IV-A. The commenter stated that reviewers could not locate estimates of existing emissions in the draft EIR and they would like to see “projected pollutant emissions related to the increase in project source emissions and vehicle use, along with an analysis of these increases.” They also would like to review input and output files used to model the estimates of emissions for the air quality analysis. Response: Estimates of existing emissions were not provided because there are no existing facilities. The existing locations where project components would be located are currently vacant and unoccupied. These land uses are discussed in Section 3.1, “Land Use and Agriculture,” in the draft EIR. The draft EIR has been revised to include new Appendix G, “Background Information for Air Quality,” and the calculations used to estimate project emissions have been included in this appendix. See Section 3, Errata to the Draft EIR, for new Appendix G. Comment IV-B. The commenter stated that emissions from the disposal of biosolids should be addressed. Response: Comment noted. Estimates of emissions from the disposal of biosolids are summarized in Table 3.6-5 in the draft EIR. No changes are required. Comment IV-C. The commenter stated that the most recent version of the URBEMIS model (version 8.7.0) should be used in place of version 7.5.0. Response: Comment noted. The URBEMIS model was not used to estimate emissions for the proposed project. The URBEMIS model is a comprehensive model typically used when a proposed project would generate a substantial amount of vehicle trips (e.g., residential, commercial, or office developments), which is not the case of the proposed ST/WRF. The URBEMIS model incorporates the EMFAC 2002 model, which is a California Air Resources Board (ARB) model used to calculate motor vehicle emissions. The air quality analysis in the draft EIR used the EMFAC 2002 model directly to determine vehicular emissions. No changes to the draft EIR are required. Comment IV-1. Comment noted. No response is necessary. Commenter IV-2. The commenter states that the Hot Spots Analysis and Reporting Program (HARP) should be used in the screening mode to estimate health risks associated with toxic emissions from wastewater treatment, rather than the SCREEN3 model used in the draft EIR. Response: A screening analysis using HARP indicates that the non-cancer risk is 1.7 in a million, non-cancer chronic risk (hazard index) is 0.018, and the acute risk (hazard index) is 0.0098. These risks are well below the below the District’s thresholds. This information has

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been incorporated into Section 3.6, “Air Quality.” See Section 3, “Errata to the Draft EIR,” for specific changes to pages 3.6-8 and 3.6-13 of the draft EIR. Comment IV-3. The commenter states that the emergency backup diesel generator engines will be subject to the ARB Airborne Toxic Control Measure (ATCM) for Stationary Compression Engines if they are larger than 50 hp. The ATCM will limit diesel particulate matter (DPM) emissions to 0.15 g/hp-hr and non-emergency operation to 50 hours per year. The commenter also states that the carcinogenic and non-carcinogenic chronic risks associated with DPM emissions from operation of the emergency backup diesel generator engines should be assessed. Response: The emergency backup diesel generators are subject to the ARB’s ATCM, as well as to District Rule 4702, which addresses internal combustion engines. District Rule 4702 requires submittal of an Emission Control Plan to the District for all spark-ignited internal combustion engines greater than 50 hp. The draft EIR (Chapter 3.6, page 3.6-2) has been revised to address the requirements of the ARB’s ATCM. Because District Rule 4702 and ARB’s ATCM apply to engines greater than 50 hp, the project description of the draft EIR (Chapter 2, pages 2-5 and 2-20) will be revised to clarify that the emergency backup diesel generators will be rated at >50 hp to ensure that they are subject to District and ARB requirements. Finally, the draft EIR (Chapter 3.6, page 3.6-13) has been revised to reflect that the emergency backup diesel generators are subject to ARB’s ATCM, and that they will be rated at >50 hp to ensure that they are subject to District and ARB requirements. See Section 3, “Errata to the Draft EIR,” for specific changes to pages 2-5, 2-20, 3.6-2, and 3.6-13 of the draft EIR. Comment IV-4. Comment noted. No response is necessary. Comment IV-5. The commenter states that health risks associated with DPM emissions from trucks transporting biosolids within the facility should be assessed. Response: Biosolids would not be transported with trucks within the facility but would be pumped via pipelines within the facility. Therefore, it is not necessary to estimate the health risks associated with DPM emissions from trucks transporting biosolids within the facility. The project description of the draft EIR has been revised to clarify that that biosolids would be pumped via pipelines within the facility. See Section 3, “Errata to the Draft EIR,” for specific changes to page 2-9 of the draft EIR. Comment IV-6. The commenter indicates the District would like to review emissions calculations used to estimate emissions for the air quality analysis. Response: The draft EIR has been revised to include new Appendix G, “Background Information for Air Quality,” and the calculations used to estimate project emissions have been included in this appendix G. See Section 3, “Errata to the Draft EIR,” for new Appendix G. Comment IV-7a. The commenter indicates that a more detailed analysis using representative meteorological data and the HARP model should be undertaken if total risks exceed the significance thresholds.

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Response: Comment noted. Risks do not exceed significance thresholds; therefore, no additional detailed assessment of health risks is necessary. No changes to the draft EIR are required. Comment IV-7b. The commenter indicates that odor impacts should be quantified. Response: Comment noted. The proposed project includes odor-control features that would be incorporated into the project design. As stated in Chapter 2 (page 2-11 under “Odor and Noise Control”): In compliance with the Good Neighbor Policy, all facilities at the ST/WRF site and the pump station sites would be enclosed (tightly covered and well maintained) to minimize noise and avoid uncontrolled odor release. Active odor control units would be located to manage gases from the wet and solids stream treatment processes. The odor control design for the facility would be such that no perceptible odors would be detected immediately adjacent to the ST/WRF boundary or nearest sensitive receptor. Other odor impacts that may be associated with operation of the ST/WRF are addressed on pages 3.6-12 through 3.6-13 in the draft EIR. The draft EIR identified Mitigation Measure AQ-5(a), which will minimize odors from the transmission pipelines to a less-thansignificant level. Because the odor-control features will be incorporated into the design of the facilities “such that no perceptible odors would be detected immediately adjacent to the ST/WRF boundary or nearest sensitive receptor,” and because Mitigation Measure AQ-5(a) would reduce odors from the transmission pipelines to a less-than-significant level, no additional analysis is necessary. No changes to the draft EIR are required. Comment IV-7c. The commenter indicates that emissions of ozone precursors from operation of the ST/WRF should be quantified in the draft EIR. Response: Comment noted. Emissions of ozone precursors from operation of the ST/WRF are summarized in Table 3.6-5 in the draft EIR. Emission factors used in the calculation of air emissions are from the San Joaquin Valley Air Pollution Control District (SJVAPCD) document, Fugitive Air Emission Factors and Concentration Values for Wastewater Treatment Plants. No changes to the draft EIR are required. Comment IV-7d. The commenter indicates that the requirements of Regulation VIII have been paraphrased and do not fully convey the minimal requirements of the rules. Further, the commenter indicates that the requirement for a Dust Control Plan is not addressed in the draft EIR. Response: The proposed project includes dust control measures to protect air quality. Refer to Chapter 2, pages 2-33 and 2-34, and Section 3.6, pages 3.6-10 and 3.6-11, in the draft EIR. Project Description Environmental Measures 3b through 3j were taken directly from the SJVAPCD’s Guide for Assessing and Mitigating Air Quality Impacts (Table 6-2, which summarizes the control measures required by the SJVAPCD at all construction sites to control PM10). Measure 3a was added to further minimize emissions of fugitive dust. Some of the rules Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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comprising Regulation VIII have been revised since the publication of the SJVAPCD’s Guide. Conversation with District staff indicates that the requirements of a Dust Control Plan will satisfy the requirements of Regulation VIII. Consequently, the draft EIR has been revised to identify that a Dust Control Plan must be prepared and implemented to satisfy the requirements of Regulation VIII. See Section 3, “Errata to the Draft EIR,” for specific changes to pages 2-33, 2-34, 3.6-10, and 3.6-11 in the draft EIR. Comment IV-7e. The commenter indicates that the draft EIR should address the following SJVAPCD rules: Rules 2201, 4002, 4101, 4102, 4103, 4601, and 4641. Response: SJVAPCD Rules 4102, 4601, 4641, 4701, and 4702 are discussed in the draft EIR on page 3.6-4. The draft EIR (Section 3.6, page 3.6-4) has been revised to also address Rules 2201, 4002, 4101, and 4103. See Section 3, “Errata to the Draft EIR,” for specific changes to pages 3.6-10 and page 3.6-11 in the draft EIR.

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V-1

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter V (County of Fresno Department of Community Health) Comment V-1. This comment states that, in addition to the City of Fresno, the Fresno County Department of Community Health, Environmental Health Division Emergency Response Team should be notified if a spill involving petroleum products is reportable. Response: Comment noted. The draft EIR (Chapter 2, page 2-31) has been revised as suggested. See Section 3, “Errata to the Draft EIR,” for specific changes to page 2-31 in the draft EIR.

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City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter VI (Fresno Metropolitan Flood Control District) Comment VI-1. The commenter states that their July 8, 2004, letter responding to the Notice of Preparation for the draft EIR is not included in Appendix A. Response: Comment noted. The draft EIR (Appendix A) has been revised to include the FMFCD letter. See Section 3, “Errata to the Draft EIR,” for revisions to Appendix A. Comment VI-2. The commenter states that a portion of the recycled water transmission main is missing from Figures ES-1 and 1-2. Figure 2-5 is correct. Response: Comment noted. The figures have been revised to show the correct route for the recycled water transmission main. It extends along the north and east sides of the Reagan Education Center, not the west and south sides. See Section 3, “Errata to the Draft EIR,” for the revised figures. Comment VI-3. The commenter states that the draft incorrectly identifies the capacity of the proposed ST/WRF as 8.4 mgd, that the actual capacity and maximum discharge is 16.8 mgd, and that failure to accommodate the maximum discharge will result in uncontrolled spills. Response: The ultimate ST/WRF Phase 3 capacity of 8.4 mgd is an “average daily flow” (ADF) value. It means that, on an average day, the ST/WRF can be expected to receive and process 8.4 million gallons (MG) Figures ES-1 and 1-2 of wastewater and to produce a comparable quantity of recycled water. During that same average day, the actual rate of flow into and out of the ST/WRF at any particular point in time can vary significantly from the ADF value of 8.4 mgd. A “peaking factor” (PF) is conventionally used to correlate the expected peak instantaneous rate of flow to the ADF value. For the ST/WRF, a conservative PF (one that can be expected to result in a calculated peak flow that is usually higher than the actual peak flow) of 2.0 has been used. For some ST/WRF design calculations, it is appropriate to use the ADF value of 8.4 mgd, while for other calculations, it is appropriate to use the peak flow value of 16.8 mgd. Pipelines, pumping systems, and other facilities that may be required to convey peak rates of flow will be designed accordingly. The draft EIR (Chapter 2, page 2-3) has been revised to clarify this. See Section 3, “Errata to the Draft EIR,” for specific changes to page 2-3 in the draft EIR. Comment VI-4. The commenter states that the proposed storm drain alignments need to be reviewed and approved by the FMFCD Engineer to verify existing and future storm drain alignments. Response: Comment noted. The City will submit the pipeline plans to the FMFCD Engineer for review and approval. The City will ensure that the design engineer contact the FMFCD Engineer early in the process to review a preliminary design of the wastewater collection facilities and recycled water distribution facilities for verification of existing and future storm drain alignments. Comment VI-5: The commenter states that the 6-day storage bin is needed and requests confirmation that pipelines downstream of the 6-day emergency storage facility be sufficient to Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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allow dewatering to occur while the ST/WRF is in full operation. They recommend a dewatering period of 10 days. Response: Comment noted. The proposed distribution facilities could include a 6-day storage basin. This is described in Chapter 2 (page 2-22 under “Six-Day Storage Basin”) and analyzed in Chapter 3. The Fancher Creek outfall pipeline will be designed to convey recycled water at the expected ultimate peak instantaneous rate of flow received and produced by the ST/WRF, which is 16.8 MGD. If a 6-day emergency storage facility is required and if the facility is filled to ultimate capacity, it will contain approximately 50.4 MG of recycled water. During dewatering of the 6-day emergency storage facility, the Fancher Creek outfall pipeline could be operated at capacity, at a continuous flow rate of 16.8 MGD. Meanwhile, the ST/WRF would continue to produce recycled water at varying rates of flow that would “average out” to its ADF rate of 8.4 MGD. The average net flow out of the 6-day emergency storage facility, then, would be 8.4 MGD. Thus, the facility could be dewatered in as little as 6 days, the same time period required to fill it. No changes to the changes to the draft EIR are required. Comment VI-6. The commenter states that incidental runoff may flow into their stormwater basins and additional monitoring and regulatory requirements may be required by the RWQCB. Response: The SWRCB has responded to the issue of incidental runoff in their letter dated February 24, 2004 stating that: In order to avoid nuisance problems, recycled water applied for irrigation is intended to remain on the irrigated areas. Nonetheless, while incidental runoff or over-spray of minor amounts of recycled water can be minimized, it cannot be completely prevented. Similarly, it is not possible to entirely prevent the runoff of rainwater from areas irrigated with recycled water or from decorative or storage ponds filled with recycled water, particularly during major storm events. A principal water quality concern with recycled water ponds is the presence of locally added pollutants, such as fertilizers and algaecides. These same issues exist with potable water ponds.” Thus, the RWQCB recognizes that incidental runoff of recycled water may occur, and it is not a major concern as long as recycled water users managed their use to minimize any incidental runoff. Recycled water users are required to monitor for incidental runoff and manage it. Also see the response to Comment III-7 concerning incidental runoff. Comment VI-7. The commenter states that when Fancher Creek capacity is fully utilized for storm water conveyance, the Diversion Channel also would likely be discharging to its maximum capacity, and recommends construction of a 6-day emergency storage facility. Response: Comment noted. Given the nature and capacity of the water course, it appears obvious upon inspection that Fancher Creek could not reasonably be called upon to convey Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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excess recycled water produced by the ST/WRF during periods when it is conveying storm water runoff at its capacity. However, it appears possible or likely that the Little Creek Diversion Channel to Big Dry Creek, perhaps with certain modifications or capacity enhancements, could convey excess recycled water produced by the ST/WRF when it is also conveying storm water runoff at its design capacity. Under existing conditions, preliminary calculations indicate that the addition of the ST/WRF peak discharge of 16.8 MGD, or 26.0 cubic feet per second (cfs), would raise Diversion Channel water surface elevations (WSEs) by approximately 2 inches, relative to WSEs corresponding to design capacity. Improvements for Diversion Channel capacity enhancement might include widening of the low-flow channel, raising levees and spillways, Fowler Avenue bridge modifications, or some combination of the foregoing. Even without improvements to enhance the capacity of the Big Dry Creek Diversion Channel to Little Dry Creek, there may be other stormwater management opportunities to mitigate the hydraulic effects of the additional flow that could be introduced by the ST/WRF discharge to the Diversion Channel. The City and FMFCD are discussing potential operational protocols to resolve this logistics issue. If a 6-day emergency storage facility is in due course required by those agencies having jurisdiction over such matters, most notably the Central Valley RWQCB, the City is prepared to include such a facility as part of ST/WRF development. The facility would be reserved for its intended purpose only, namely the short-term storage of recycled water during periods when it cannot otherwise be beneficially used or discharged to the Fancher Creek and Diversion Channel outfalls. No changes to the draft EIR are required as a result of these comments. However, Chapter 2 has been revised to clarify that the ST/WRF onsite facilities include a temporary stormwater basin of undetermined size to detain water prior to discharge to the District’s pipes. See Section 3, “Errata of the Draft EIR,” for specific changes to pages 2-5 and 2-11 in the draft EIR. Comment: VI-8. The commenter correctly indicates that the north end of the recycled water transmission lane alignment shifts northwest, not northeast. Response: Comment noted. The draft EIR has been revised to make this correction. See Section 3, “Errata of the Draft EIR,” for specific changes to page 3.1-5 in the draft EIR. Comment: VI-9. The commenter states that FMCFD did not team with the U.S. Army Corps of Engineers (Corps) in constructing major channel improvements on most of the rural water courses in the project area, as indicated in the draft EIR on page 3.3-4. However, they did work with the Corps on two detention basin projects and improvements to the Big Dry Creek Reservoir. Response: Comment noted. The draft EIR has been revised to make this correction. See Section 3, “Errata of the Draft EIR,” for specific changes to page 3.3-4 in the draft EIR. Comment VI-10. The commenter correctly indicates that the City must obtain coverage under the General Construction Permit, not the contractor, as indicated on page 3.3-17 in the draft EIR.

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Response: Comment noted. The draft EIR has been revised to make this correction. See Section 3, “Errata of the Draft EIR,” for specific changes to page 3.3-17 in the draft EIR. Comment VI-11. The commenter provides information and clarification on the NPDES permitting process. Response: Comment noted. No changes to the draft EIR are required. Comment VI-12. The commenter states that the potential for accidental releases of biosolids during transport is identified on page 3.3-22 in the draft EIR. They recommend mitigation measures be discussed to address this. Response: Comment noted. As described in Chapter 2 of the draft EIR (page 2.10 under “Solids Management and Disposal”), the biosolids generated from the treatment process would be piped to a covered, leak-proof trailer for transport to a properly permitted landfill. The text on page 3.322 has been revised to clarify that this is one of the reasons the impact was determined less than significant. See Section 3, “Errata of the Draft EIR,” for specific changes to page 3.3-22 in the draft EIR. Impacts associated with the landfill, including the potential for water quality degradation, and appropriate mitigation measures have been identified in the environmental documentation for the landfill. Comment VI-13. The commenter clarifies that only the stretch of the San Joaquin River between Mendota and the Delta is included on the 303(d) list, and that this should be clarified on pages 3.5 and 3.3-24 in the draft EIR. Response: Comment noted. The text on page 3.3-24 in the draft EIR has been revised to make this clarification. However, the text on page 3.3-5 correctly states: The 303(d) list breaks up the San Joaquin River into four sections: Mendota Pool to Bear Creek, Bear Creek to Mud Slough, Mud Slough to Merced River, and Merced River to south Delta boundary.” No change is required for this page. Comment VI-14. The commenter states that mitigation should be presented for the significant and unavoidable impact (HYD-7: Decreased Water Quality from Discharge of Recycled Water to Surface Water Bodies). Response: Comment noted. Refer to response to Comment III-4 (3). No changes to the draft EIR are required. Comment VI-15. The commenter states that the City of Clovis, FMFCD, City and County of Fresno, and California State University Fresno are all co-permittees of a municipal stormwater NPDES permit. The commenter provides information about the NPDES permit and other requirements (i.e., drainage fees, construction of Master Plan storm drainage facilities, development agreement, and Drainage Fee Ordinance). Response: Comment noted. No changes to the EIR are required.

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Comment VI-16. The commenter states that permanent drainage service is available for Pump Station B and Reycled Water Booster Pump Station 2, but is not provided for the ST/WRF site and Recycled Water Booster Pump Stations 1 and 3 (and should be). Response: Comment noted. The text in Chapter 2 of the draft EIR has been revised to clarify that temporary drainage facilities should be provided at these sites. See Section 3, “Errata of the Draft EIR,” for specific changes to pages 2-5, 2-11, 2-15, and 2-21 in the draft EIR. Comment VI-17. The commenter states that the proposed ST/WRF, Pump Station B, and Recycled Water Booster Pump Station 2 are not located within a flood-prone area, but Recycled Water Booster Pump Station 3 is. Response: Comment noted. The text in Section 3.3 (page 3.3-4 under “Flooding”) has been revised to make this clarification. See Section 3, “Errata of the Draft EIR,” for specific changes to page 3.3-4 in the draft EIR.

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City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter VII (Clovis Unified School District) Comment VII-1. The commenter requests the opportunity to evaluate the proposed facility design, process approach, and odor control alternatives proposed by the DBO (the term used to refer to the single entity that will design, build, and operate the facility) to ensure no potential impacts on Reagan Educational Center. Response: Comment noted. No changes to the draft EIR are required. Comment VII-2. The commenter states the air quality impacts and mitigation identified in the draft EIR. Response: Comment noted. No changes to the draft EIR are required. Comment VII-3. The commenter believes that the use of recycled water in accordance with Title 22 is safe, beneficial, and supports conservation initiations. Response: Comment noted. No changes to the draft EIR are required.

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VIII

VIII-1

VIII-1 cont.

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter VIII (Jeffer Mangels Butler & Marmaro on Behalf of McFarlane & McFarlane) Comment VIII-1. The commenter states that the original Site E (shown in Figure 5-1 in Chapter 5 of the draft EIR) is outside the 30-acre study area (shown in Figure 2-1 in Chapter 2 and elsewhere in the draft EIR), and that original Site E should be evaluated. Response: Figure 5-1 in Chapter 5 of the draft EIR is incorrect. Site E should be shown further westward, which would be within the 30-acre study area. Therefore, Site E has been evaluated in the draft EIR. The draft EIR (Figure 5-1, following page 5-8) has been revised to show the correct location of Site E and to include an outline of the 30-acre study area suggested. See Section 3, “Errata to the Draft EIR,” for specific changes to Figure 5-1 in the draft EIR.

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IX

IX-1

IX-2

IX-3

IX-4

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter IX (Gene Borré) Comment IX-1. The commenter feels that the draft EIR failed to adequately consider the impact of the facility on air and water quality. Response: Comment noted. The draft EIR includes an extensive discussion of air quality (Section 3.6) and water quality (Section 3.3) issues, and discloses all potential impacts on these resources. No changes to the draft EIR are required. Commenter IX-2. The commenter notes that the following significant and unavoidable impacts have been identified: (1) conversion of important farmland to non-agricultural use, and (2) potential water quality degradation from effluent discharge to surface water. Response: Comment noted. CEQA requires full disclosure of potential impacts, including significant and unavoidable impacts. The draft EIR does this, and no changes are required. After the draft and final EIR have been prepared, CEQA also requires that the decision-making body (City of Clovis) consider the information presented in the draft EIR and final EIR, including the comments received, prior to approving a project. For each significant impact, the City must prepare written “findings of fact” that explains how the significant impact was dealt with by making one of the following findings: •

Changes in the project have been made (including adoption of mitigation measures) to avoid or substantially reduce the magnitude of the impact.

•

Changes to the project are within another agency’s jurisdiction and have been or should be adopted.

•

Specific economic, social, legal, technical, or other considerations make mitigation measures or alternatives infeasible.

When an impact cannot be avoided or reduced to a less-than-significant impact, the City must prepare a “statement of overriding consideration,” which is a written statement explaining why the agency is willing to accept each significant effect. CEQA requires the decision maker to balance the benefits of a proposed project against unavoidable environmental risks when determining whether to approve a project. (Public Resources Code Section 21081; State CEQA Guidelines Sections 15091, 15093, and 15096.) Comment IX-3. The commenter states that the draft EIR fails to address the project’s effects on property values. Response: Economic effects are not considered environmental effects, and agencies are not required to evaluate them in the draft EIR for the proposed project—unless the effects result in physical degradation that could result in environmental effects (State CEQA Guidelines Section 15131). The City determined that this would not be the case. No changes to the draft EIR or new analysis is required. Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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City of Clovis

Comments on the Draft EIR and Responses

Comment IX-4. The commenter would like the City to keep this area in agricultural use. Response: Comment noted. The Southeast Urban Center Specific Plan area was identified for urban uses by the 1993 General Plan and the 2000 Memorandum of Understanding between Clovis and Fresno County, and was finalized by the adoption in 2003 of the Southeast Urban Center Specific Plan. No changes to the draft EIR are required.

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X

X-1

X-2

X-3

City of Clovis

Comments on the Draft EIR and Responses

Response to Comment Letter X (Clovis Planning Commission Meeting Minutes) The Clovis Planning Commission meeting minutes comprise seven pages. The comments on the draft EIR are on page 7. Comment X-1. The commenter (Gene Borré) stated that he was unclear about where the facility would be located. He also stated that the EIR was incorrect with regard to effects on the environment, but he would submit these comments in writing (refer to comment letter VIII). Response: As stated in the project description (Chapter 2, page 2-3 under “Sewage Treatment/Water Reuse Facility), the proposed ST/WRF would be located on an approximately 15-acre site located within the 30-acre study area. Because the specific site has not been identified, a larger 30-acre study area is evaluated. Also refer to responses to comment letter IX. No changes to the draft EIR are required. Comment X-2. The commenter (Jeff Harris, Wilson Homes) stated that he is in support of this facility and agrees with the EIR. Response: Comment noted. No changes to the draft EIR are required. Comment X-3. Commissioner Berg had questions regarding discharge of water to other facilities and whether the project was designed for flood control. The City Engineer answered his questions. No changes to the draft EIR are required.

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Section 3

Errata to the Draft EIR

This section shows the revisions that have been made to the March 2005 draft EIR for the City of Clovis Sewage Treatment/Water Reuse Facility Program project to provide further clarification or in response to comments received on the draft EIR. The revisions have been presented in the consecutive order they appear in the draft EIR. Text in standard print is original text from the draft EIR. Underlined text indicates additions to the original text, and strikeout text indicates deletions to the original text.

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Table of Contents, page iv is hereby modified as follows:

Appendix G, Background Information for Air Quality, has been added at the end to the list of appendices.

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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City of Clovis

Errata to the Draft EIR

Executive Summary, Figure ES-1 is hereby modified as follows:

The figure has been revised to show the correct route for the recycled water transmission main. It extends along the north and east sides of the Reagan Education Center, not the west and south sides. (see next page)

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Executive Summary, Page ES-4, is hereby modified as follows:

Because the City is using a DBO approach for ST/WRF, the facility design has not yet been defined. However, based on the expected influent quality and quantity, effluent requirements to meet Title 22 standards and the City’s performance criteria, size constraints of the expected site, and wastewater technologies in use nationwide, the ST/WRF would likely consist of: a headworks facility, which would include flow metering, fine screens, and grit removal, but no pump station; biological treatment, likely including a conventional activated sludge process, sequencing batch reactor process, or a membrane biological reactor process; filtration, in accordance with filtration requirements of Title 22, as listed in the Treatment Technology Report for Recycled Water; ultraviolet disinfection, in accordance with Title 22 and the Treatment Technology Report for Recycled Water; solids management, odor control, and emergency power equipment; and temporary stormwater basin; and a daily use storage reservoir and pump station to store and deliver the recycled water to the recycled water distribution system.

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LEGEND: CITY OF CLOVIS SPHERE OF INFLUENCE RECYCLED WATER DISTRIBUTION PIPELINE RECYCLED WATER TRANSMISSION MAIN WASTEWATER COLLECTION PIPELNE PROPERTY LINES/RIGHTS OF WAY

04377.04 EIR (6-05)

LIMITS OF SOUTHEAST URBAN CENTER

Source: Blair, Church & Flynn Consulting Engineers (March 1, 2005)

Figure ES-1 Project Overview

City of Clovis

Errata to the Draft EIR

Executive Summary, Table ES-1, Page 2 of 3 (follows Page E-6) is hereby modified as follows:

The table has been revised to include the need for temporary stormwater facilities at the ST/WRF site and Recycled Water Booster Pump Station 3. Recycled water storage reservoirs

The daily use storage reservoir located on the ST/WRF site would hold 27 af of recycled water. Whether it is an enclosed tank or open, it would have an impermeable liner and be constructed in compliance with DHS regulations. If constructed, the 6-day storage basin located southeast of the ST/WRF site would hold approximately 155 af of recycled water. It would be approximately 840 feet long, 650 feet wide, and 15 feet deep. It would have an impermeable liner and be constructed in compliance with DHS regulations. It would be situated to avoid existing irrigation ditches in the vicinity.

Stormwater

Temporary stormwater facilities are needed at the ST/WRF site and the Recycled Water Booster Pump Station 3 site. Sewer Pump Station B and Recycled Water Booster Pump Station 2 have stormwater drainage available.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Executive Summary, Table ES-2, Pages 5 and 10 of 11 (follows Page E-6) are hereby modified as follows:

In the column “Mitigation Measure,” the name of Environmental Measure 3 has been revised: Environmental Measure 3: Dust Control Measures to Protect Air Quality (Regulation VIII)

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 1, Figure 1-2 is hereby modified as follows:

The figure has been revised to show the correct route for the recycled water transmission main. It extends along the north and east sides of the Reagan Education Center, not the west and south sides. (see next page)

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, footers throughout the chapter are hereby modified as follows:

The footer has been revised to show the correct date of the draft EIR as March 2005, not March 2004.

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

LEGEND: CITY OF CLOVIS SPHERE OF INFLUENCE RECYCLED WATER DISTRIBUTION PIPELINE RECYCLED WATER TRANSMISSION MAIN WASTEWATER COLLECTION PIPELNE PROPERTY LINES/RIGHTS OF WAY

04377.04 EIR (6-05)

LIMITS OF SOUTHEAST URBAN CENTER

Source: Blair, Church & Flynn Consulting Engineers (March 1, 2005)

Figure 1-2 Project Overview

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-3 is hereby modified as follows: Table 2-1. Phased Operation of the Sewage Treatment/Water Reuse Program Phase

Operation Time Frame

Operational Capacity

1

2008–2017

2.8 mgd

2

2017–2026

5.6 mgd

3

2026–2030

8.4 mgd

The ultimate capacity of 8.4 mgd is an “average daily flow,” which means the ST/WRF could be expected to receive and process 8.4 mgd of wastewater and produce a comparable quantity of recycled water. During an average day, there could be instantaneous peaks of flow in the system. The ST/WRF pipelines, pump systems, and other facilities would be designed to accommodate a peak flow of 16.8 mgd.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-5 is hereby modified as follows:

Because the City is using a DBO approach for ST/WRF, the facility design has not yet been defined. However, based on the expected influent quality and quantity, effluent requirements to meet Title 22 standards and the City’s performance criteria, size constraints of the expected site, and wastewater technologies in use nationwide, the ST/WRF would likely consist of the following facilities for operation and have a site plan similar to that shown in Figure 2-2. a headworks facility, which would include flow metering, fine screens, and grit removal, but no pump station biological treatment, likely including a conventional activated sludge process, sequencing batch reactor (SBR), or membrane biological reactor (MBR) process filtration, in accordance with filtration requirements of Title 22, as listed in the Treatment Technology Report for Recycled Water (California Department of Health Services 2003) ultraviolet (UV) disinfection, in accordance with Title 22 and the Treatment Technology Report for Recycled Water solids management, odor control, and emergency power equipment temporary stormwater basin a daily use storage reservoir and pump station to store and deliver the recycled water to the recycled water distribution system The ST/WRF facilities would be operated by electricity 24 hours per day. A conservative estimate for the presumed operating load is 3,214 kilovolt-amperes (KVA). The ST/WRF would include two emergency generators so that the plant could continue to operate during power outages. The estimated size of each generator is 1,875 KVA. The effluent pump station would likely have an emergency diesel-powered generator (rated at > 50 hp) as a backup system. Both emergency generation systems would be operated once per month as part of routine maintenance and to confirm operability. To ensure that the backup system is operational, it would be operated monthly for approximately 30 minutes. The total duration maintenance and test operation of both the ST/WRF emergency generator and the effluent pump station would be would be a maximum of approximately 12 hours per year.

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Table 2-2, Page 1 of 3 (following Page 2-6) is hereby modified as follows:

The table has been revised to correct the percentage of filtered water turbidity from 95%. (see next page)

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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Table 2-2. Performance Criteria for ST/WRF Criterion

Page 1 of 3 Parameter Filtration rate

Option 1- filtration of coagulated water through natural undisturbed soils or a bed of filter media

Filtered water turbidity

Filtration (two options)

Value

Description/Notes

< 5 gpm/ft2

For mono, dual, or mixed media gravity, upflow, or pressure filtration systems

< 2 gpm/ft2

For traveling bridge automatic backwash filters

< 2 NTU

On average over a 24-hour period

< 5 NTU

< 5 95% of the time over a 24-hour period

< 10 NTU

At all times

- ORTreatment Process

Option 2— microfiltration, ultrafiltration, nanofiltration, or reverse osmosis

< 0.2 NTU

< 5 95% of the time over a 24-hour period

< 0.5 NTU

At all times

CT

> 450 mg-min./L

“CT” refers to the product of total chlorine residual following filtration and modal contact time (see below) measured at the same point. This CT value is to be maintained at all times.

Modal contact time

> 90 min.

Modal contact time is to be based on peak dry weather design flow.

Filtered water turbidity

Option 1

Disinfection (two options)

- OR-

Option 2

Percent inactivation/removal of plaque-forming units of Fspecific bacteriophage MS2, or polio virus

> 99.999%

The percent-inactivation/removal value is to be based on the combination of filtration and disinfection. A virus that is at least as resistant to disinfection as polio virus may be used for purposes of the demonstration

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-9 is hereby modified as follows:

Management The inorganic objects removed by screening would be washed and dewatered prior to discharge, and would be piped to an enclosed container for trucking and eventual offsite disposal. The WAS would be managed through enclosed units and treatment processes capable of producing a minimum Class B pathogen reduction biosolids in compliance with biosolids regulations per 40 CFR Part 503, EPA’s Standards for the Use or Disposal of Sewage Sludge enacted pursuant to the federal CWA. All solids-processing facilities would be enclosed and the air ventilated directly to odor-control facilities to prevent offsite odors.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-11 is hereby modified as follows:

Odor and Noise Control In compliance with the Good Neighbor Policy (Appendix B), all facilities at the ST/WRF site and the pump station sites would be enclosed (tightly covered and well maintained) to minimize noise and avoid uncontrolled odor release. Active odor control units would be located to manage gases from the wet and solids stream treatment processes. The odor control design for the facility would be such that no perceptible odors would be detected immediately adjacent to the ST/WRF boundary or nearest sensitive receptor.

Stormwater Management A temporary stormwater basin would be constructed at the ST/WRF site to collect stormwater runoff until the FMFCD facilities are available. The size has not been determined but would be adequate to detain water prior to discharge to FMFCD pipelines.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-15 is hereby modified as follows:

The pump station would be enclosed within acoustically designed and insulated structures so that they meet or exceed the City’s standards specified in the Noise Element of the Clovis General Plan at the property line of the nearest noisesensitive land uses. Treatments to reduce noise include constructing enclosures around equipment, locating equipment away from noise-sensitive uses, employing exhaust-muffling devices, and acoustical designing of structures that house pumps and generators. Site improvements would include a paved access road, a parking area, lighting, landscaping, and an irrigation system. Stormwater drainage is available at the site.

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City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-20 is hereby modified as follows:

Booster Pump Station 3, an approximately 15- to 30-hp (total) pump station, would be located on an approximately 0.3-acre site 0.5 mile north of the Nees Avenue/DeWolf Avenue intersection on the east side of DeWolf Avenue. The pump station would be situated in an existing road right-of-way and integrated into a future residential subdivision. The pump station enclosure would be approximately 400 square feet in area and 8–10 feet tall, with a masonry wall on three sides and a gated opening. The pumps at all three booster pump stations would be driven by electric motors, with backup electric power provided by diesel-powered generators (rated at > 50 hp), which would be operated for maintenance purposes at regular intervals. Booster Pump Stations 2 and 3 would have site improvements such as paved access roads, parking, and landscaping.

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-21 is hereby modified as follows:

The pump stations would be enclosed within acoustically designed and insulated structures so that they meet or exceed the City’s standards specified in the Noise Element of the Clovis General Plan at the property line of the nearest noisesensitive land uses. Treatments to reduce noise include constructing enclosures around equipment, locating equipment away from noise-sensitive uses, employing exhaust-muffling devices, and acoustical designing of structures that house pumps and generators. Permanent stormwater drainage is available at Booster Pump Station 2, but temporary drainage facilities would be incorporated into the site plan at Booster Pump Stations 1 and 3.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Pages 2-22 and 2-23 are hereby modified as follows:

The ST/WRF, which would have an ultimate capacity of 8.4 mgd in average day flow and 16.8 mgd in peak flow, would be designed to meet all applicable regulations and permit requirements relating to the design and operation of a wastewater treatment and reclamation facility. The quality of effluent produced would comply with all discharge requirements and regulations governing wastewater treatment processes and recycled water quality contained in Title 22. The Engineering Report for the Production, Distribution, and Use of Recycled Water describes how the ST/WRF would comply with the Title 22 Water Recycling Criteria (22 CCR 60301–60355 60301–60310, 60314, 60323). The City would ensure that all entities involved in distribution and use of its recycled water perform their activities in accordance with all applicable rules and regulations governing implementation of a recycled water program. The City would develop two documents to accomplish this: a recycled water use ordinance, and recycled water system construction and user standards. These documents would include the provision of inspection by the City to enforce the standards and the ordinance, and to implement a cross-connection control program. These documents would cover all design, construction, operations, and maintenance of the recycled water distribution systems and use areas, as well as use area control measures. Specifically, this section would meet all the requirements of the applicable state laws, including the following as compiled in California Health Laws Related to Recycled Water (California Department of Health Services 2001). Health and Safety Code 116800–116820 22 CCR 60303–60310 60301–60310, 60314, 60323 17 CCR 7583–7586, 7601–7605 Additionally, recycled water users would submit a report of water recycling pursuant to CWC 13522.5.

Sewage Treatment/Water Reuse Facility Program Final Environmental Impact Report

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-29 is hereby modified as follows:

Environmental Measure 2: Measures to Protect Water Quality during Construction and Operation 2-1: Implement Erosion and Sediment Control Measures. To reduce or eliminate construction-related water quality effects, implement requirements of the NPDES General Permit for Construction Activities (General Construction Permit). Before onset of any construction activities, the City’s contractor will obtain coverage under the General Construction Permit. The City will be responsible for ensuring that construction activities comply with the conditions in this permit, which will require development of a stormwater pollution prevention plan (SWPPP), implementation of best management practices (BMPs) identified in the SWPPP, and monitoring to ensure that effects on water quality are minimized.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-31 is hereby modified as follows:

The federal reportable spill quantity for petroleum products, as defined in 40 CFR 110, is any oil spill that: violates applicable water quality standards, causes a film or sheen on or discoloration of the water surface or adjoining shoreline, or causes a sludge or emulsion to be deposited beneath the surface of the water or adjoining shorelines. If a spill is reportable, the contractor’s superintendent will notify the City, and and the Fresno County Department of Community Health (Environmental Health Division Emergency Response Team. Tthe City will take action to contact the appropriate safety and clean-up crews to ensure that the SPCCP is followed. A written description of reportable releases must be submitted to the Central Valley RWQCB. This submittal must contain a description of the release, including the type of material and an estimate of the amount spilled, the date of the release, an explanation of why the spill occurred, and a description of the steps taken to prevent and control future releases. The releases would be documented on a spill report form.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 2, Page 2-33 is hereby modified as follows:

Environmental Measure 3: Dust Control Measures to Protect Air Quality (Regulation VIII) To control dust emissions generated during construction of the proposed project, the City’s construction contractor or DBO entity will incorporate the following prepare and submit a Dust Control Plan to the SJVAPCD (Central Region Office at 1990 East Gettysburg Avenue, Fresno, CA 93726) at least 48 hours prior to earth moving, to satisfy the requirements of SJVAPCD Regulation VIII. Control Measures for construction emissions of particulate matter less than or equal to 10 microns in diameter (PM10) are required to be implemented. The requirements of the Dust Control Plan are included in Appendix G. Measures to be included in the Dust Control Plan may include the following.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.1, Page 3.1-5 is hereby modified as follows:

The portion of the alignment beginning at the Leonard Avenue/Bullard Avenue intersection travels through a predominantly residential area with some scattered agricultural uses. At Temperance Avenue, the alignment moves north through both older and newly developed single-family residential areas. As the alignment approaches SR 168, the Clovis Community Medical Center sits east of Temperance Avenue and, except for the entrance driveway, is largely screened by orchards. Before and immediately after crossing under SR 168, land uses along the alignment shift to open fields and orchards. Continuing north on Temperance Avenue, land uses are again dominated largely by newly developed single-family residences and open lots. At the Temperance Avenue/Shepherd Avenue intersection, the alignment leaves the roadway and continues north, traveling past several rural residential uses and open agricultural and grazing land. At the Big Dry Creek Reservoir Dam, the alignment shifts northeast northwest and travels alongside the dam through open land until it reaches the Big Dry Creek Diversion Channel to Little Dry Creek. This area is dominated by open, undeveloped land with scattered dam infrastructure.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.3, Page 3.3-4 is hereby modified as follows:

Locally, the FMFCD provides flood protection to the incorporated area of Clovis (The Planning Center 2002). During the last 4 years, the FMFCD has teamed with the Corps in constructing major channel improvements on most of the rural watercourses surrounding the project area (The Planning Center 2002). These improvements are meant to help control flood flows in the Clovis/Fresno area. According to the FMFCD, the ST/WRF site, Pump Station B site, and Recycled Water Booster Pump Station 2 are not located in a flood-prone area, but Recycled Water Booster Pump Station 3 is (Luna pers. comm.).

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.3, Page 3.3-17 is hereby modified as follows:

Project Description Environmental Measure 2: Measures to Protect Water Quality during Construction and Operation

2-1: Implement Erosion and Sediment Control Measures. To reduce or eliminate construction-related water quality effects, implement requirements of the General Construction Permit. Before onset of any construction activities, the City’s contractor will obtain coverage under the General Construction Permit. The City will be responsible for ensuring that construction activities comply with the conditions in this permit, which will require development of a SWPPP, implementation of BMPs identified in the SWPPP, and monitoring to ensure that effects on water quality are minimized.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.3, Page 3.3-22 is hereby modified as follows:

Impact HYD-5: Minimal Potential for Degradation of Water Quality Resulting from Biosolids Disposal and Reuse (Less than Significant) Implementation of the project would increase the quantity of biosolids that must be managed by the City. These activities could degrade water quality as a result of accidental releases during transport or disposal, or from wind and water erosion and subsequent deposition into nearby waterways. However, as described in Chapter 2 (under “Solids Management and Disposal – Transport and Disposal”), biosolids will be transported offsite in a covered, leak-proof trailer. For disposal, the City will use only sites that are properly permitted and for which all site-specific impacts, including the potential for water quality degradation, have been mitigated thoroughly through either preparation of sitespecific environmental documents or compliance with other federal, state, and local regulations. This impact is considered less than significant. No mitigation is required.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.3, Page 3.3-24 is hereby modified as follows:

As part of project approval, an NPDES permit will need to be obtained as part of compliance with the CWA. The ST/WRF would be a state-of-the-art facility and is anticipated to have low concentrations of most constituents; the permit application would be supported by mixing and dilution studies that show that violations of the CWA will mostly be avoided. In the case of the San Joaquin River, dilution of contaminants may not be an effective way of reducing impacts. This waterway From Mendota to the Delta, the San Joaquin River is listed under CWA Section 303(d) as impaired for chloropyrifos, Group A pesticides, DDT, diazinon, EC, mercury, boron, selenium, and unknown toxicity, meaning that the river has no remaining assimilative capacity or ability to accommodate additional quantities of these contaminants, regardless of concentration. In addition, there may be other constituents for which the mixing and dilution studies are not able to show that CWA standards will be maintained.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.3, Page 3.3-25 is hereby modified as follows:

As part of the project, the City will ensure that all entities involved in distribution and use of its recycled water perform their activities in accordance with all applicable rules and regulations governing implementation of a recycled water program. To accomplish this, the City is developing a recycled water use ordinance and recycled water system construction and user standards. This will include the provision of inspection contractors by the City to enforce the standards and ordinance and to implement a cross-connection control program. These documents will cover all of the design, construction, operations, and maintenance of the recycled water distribution system and use areas, as well as use area control measures. Specifically, the documents will meet all the requirements of the applicable state laws, including the following, as compiled in the June 2001 edition of California Health Laws Related to Recycled Water— “The Purple Book” (California Department of Health Services 2001). Health and Safety Code, Division 104, Part 12, Chapter 5, Article 2 (CrossConnection Control by Water Users), Sections 116800–116820 CCR, Title 22, Division 4, Chapter 3 (Water Recycling Criteria), Sections 60303 60301–60310, 60314, 60323 CCR, Title 17, Division 1, Chapter 5, Group 4 (Sanitation [Environmental]/Drinking Water Supplies), Sections 7583–7586 and 7601– 7605

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Page 3.6-2 is hereby modified as follows:

The ARB oversees the activities of the local air districts, but it does not permit stationary sources of air pollutants, which is the responsibility of the districts. The ARB has the authority for setting vehicle emissions standards for on-road vehicles and for some off-road vehicles. In addition, the ARB identifies and sets control measures for toxic air contaminants (TACs). The ARB’s Airborne Toxic Control Measure (ATCM) for Stationary Compression Engines establishes health-based limits to emissions from and hours of operation for back-up generators of more than 50 hp.

Attainment Status Areas are classified as either attainment or nonattainment with respect to NAAQS and CAAQS. These classifications are made by comparing actual monitored air pollutant concentrations to the state and federal standards. Monitoring data for the project study area are discussed under “Existing Conditions.” The project study area (Fresno County) is currently designated as nonattainment for the federal and state ozone and PM10 standards, as shown in Table 3.6-2.

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City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Page 3.6-4 is hereby modified as follows:

Applicable San Joaquin Valley Air Pollution Control District Rules The proposed project would be subject to the SJVAPCD rules listed below, which have been adopted to reduce emissions throughout the San Joaquin Valley and are required for any projects within the SJVAPCD boundaries. Rule 2201 (New and Modified Stationary Source Review Rule): This rule applies to all new stationary sources and all modifications of existing stationary sources that are subject to the District permit requirements and after construction emit or may emit one or more affected pollutant. Rule 4002 (National Emission Standards for Hazardous Air Pollutants): This rule applies to any portion of an existing building that will be renovated, partially demolished, or removed. Prior to any demolition activity, an asbestos survey of existing structures on the project site may be required to identify the presence of any asbestos-containing building material (ACBM). Any identified ACBM having the potential for disturbance must be removed by a certified asbestos contractor in accordance with CAL-OSHA requirements. Rule 4101 (Visible Emissions): This rule prohibits emissions of visible air contaminants to the atmosphere and applies to any source operation that emits or may emit air contaminants. Rule 4102 (Nuisance): This rule applies to any source operation that emits or may emit air contaminants or other materials. In the event that the project or construction of the project creates a public nuisance, it could be in violation and be subject to SJVAPCD enforcement action. Rule 4103 (Open Burning): This rule regulates the burning of agricultural material. Rule 4103 explicitly states that agricultural material shall not be burned when the land use is converted from agriculture to nonagricultural purposes. Rule 4601 (Architectural Coatings): This rule limits volatile organic compounds (VOC) from architectural coatings. This rule specifies architectural coatings storage, clean up, and labeling requirements. Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving, and Maintenance Operations): If asphalt paving will be used, paving operations will be subject to this rule. This rule applies to the manufacture and use of cutback asphalt, slow cure asphalt, and emulsified asphalt for paving and maintenance operations. Rule 4701 (Internal Combustion Engines – Phase 1): This rule limits the emissions of NOx [oxides of nitrogen], CO, and VOC from internal combustion engines.

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City of Clovis

Errata to the Draft EIR

Rule 4702 (Internal Combustion Engines – Phase 2): This rule limits the emissions of NOx, CO, and VOC from spark-ignited internal combustion engines.

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City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Page 3.6-8 is hereby modified as follows:

A screening-level health risk assessment was performed using the EPA SCREEN3 model. SCREEN3 uses worst-case meteorological conditions to conservatively estimate ground-level pollutant concentrations downwind of the source. The SCREEN3 results were combined with unit risk factors and reference exposure levels obtained from the ARB to evaluate cancer, chronic non-cancer, and acute health risk. ARB Hot Spots Analysis and Reporting Program (HARP). HARP is a tool that assists with the programmatic requirements of the Air Toxics “Hot Spots” Program. HARP is a computer software package that combines the tools of emission inventory database, facility prioritization, air dispersion modeling, and risk assessment analysis. All of these tools are tied to a single database allowing information to be shared and utilized. The modeled cancer, chronic non-cancer, and acute non-cancer risks were modeled for each individual compound and the results added to produce a conservative estimate of risk from all compounds. Table 3.6-4 summarizes the parameters used in the SCREEN3 HARP modeling.

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City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Table 3.6-4 on Page 3.6-9 is hereby modified as follows:

Table 3.6-4. Parameters Used in SCREEN3 HARP Dispersion Modeling Modeling Parameter

Value Used in Model

Emission rate

1 gram per second

1-hour average to annual average persistence factor

0.1

Stack height

12.8 meters (42 feet)

Stack diameter

0.91 meters (3 feet)

Stack exit velocity

3.66 meters per second (10 feet per second)

Stack gas exit temperature

294.3 Kelvin

Land use

Rural

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City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Page 3.6-10 is hereby modified as follows:

The SJVAPCD considers PM10 emissions to be the greatest pollutant of concern when assessing construction-related air quality impacts. As stated, the SJVAPCD has determined that compliance with its Regulation VIII, including implementation of all feasible control measures specified in the Guide for Assessing and Mitigating Air Quality Impacts, constitutes sufficient mitigation to reduce construction-related PM10 emissions to less-than-significant levels and minimize adverse air quality effects. All construction projects must abide by this regulation. Since the publication of the District’s guidance manual, the District has revised some of the rules comprising Regulation VIII. However, guidance from District staff indicates that implementation of a Dust Control Plan would satisfy all of the requirements of SJVAPCD Regulation VIII (Cadrett pers. comm.). These measures have been included as part of the proposed project (see “Environmental Measures” in Chapter 2). Implementation of Environmental Measures 3 and 4, included as part of the proposed project (and described below), would reduce this impact to a less-than-significant level. No additional mitigation is required. Project Description Environmental Measure 3: Dust Control Measures to Protect Air Quality (Regulation VIII) To control dust emissions generated during construction of the proposed project, the City’s construction contractor or DBO entity will prepare and submit a Dust Control Plan to the SJVAPCD (Central Region Office, 1990 East Gettysburg Avenue, Fresno, CA 93726) at least 48 hours prior to earth moving to satisfy the requirements of incorporate the following SJVAPCD Regulation VIII. Control Measures for construction emissions of PM10 are required to be implemented. The requirements of the Dust Control Plan are included in Appendix G. Measures to be included in the Dust Control Plan may include the following.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Page 3.6-13 is hereby modified as follows:

Diesel Generators at Sewage Treatment/Water Reuse Facility and Pump Stations: Diesel engines would be used to power emergency generators at the ST/WRF in the event of an electrical power failure. The emissions from testing these engines (a maximum of 8 hours per year) are summarized in Table 3.6-5. Additionally, as described in Chapter 2 under “Biological Treatment System” and “Odor and Noise Control,” the proposed pump stations (Pump Station B and Booster Pump Stations 1–3) would use electric pumps that would not emit air pollutants. However, diesel-fueled emergency backup generators would be used in the event of an electrical power failure. The generator would be subject to SJVAPCD Rules 4701 and 4702, which regulate internal combustion engines more than 50 hp to limit NOx emissions from internal combustion engines, as well as the ARB’s ATCM for Stationary Compression Engines, which establishes health-based limits to emissions from and hours of operation for back-up generators of more than 50 hp. The emissions associated with the generators would be from periodic testing and emergency operation. Emissions estimates are based on a maximum of 16 hours per year of testing and use. These emissions are summarized in Table 3.6-5. The PM10 emissions from the diesel engines have recently been identified by the ARB as TACs. These emissions would be minimal, the pump stations would be enclosed, and no sensitive receptors are located adjacent to the proposed pump stations. Further, the back-up generators would be rated at 50 hp and are subject to the ARB’s ATCM, which establishes limits to emissions from and hours of operation for back-up generators, and is based on the prevention of health risks associated with exhaust from stationary compression engines. Consequently, there is not expected to be a significant increase in health risk is not expected from the operation and testing of these engines.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 3, Section 3.6, Page 3.6-13 is hereby modified as follows:

Impact AQ-3: Increase in Toxic Air Contaminant Emissions from Operation of the Sewage Treatment/Water Reuse Facility (Less than Significant) Treatment of influent would produce emissions of TACs during reaction or degradation. The annual emissions of TACs from treatment are summarized in Table 3.6-6. A health risk assessment was prepared to analyze cancer, chronic non-cancer, and acute non-cancer health risks from the facility. The location of maximum impact (MEI) was modeled at 400 feet from the property boundary of the ST/WRF study area. At this location, the modeled cancer risk is 1.27 in 1 million, the chronic non-cancer inhalation hazard index is 0.018, and the acute non-cancer inhalation hazard index is 0.00680098. These results are less than the SJVAPCD standards discussed previously. Therefore, the increased health risks from the proposed facility would be less than significant. No mitigation is required.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 5, Figure 5-1 is hereby modified as follows:

The figure has been revised to show that site E should be located further westward and is within the ST/WRF study area. (see next page)

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J&S 04377.04

Del Rey

McCall

Thompson

Highland

Leonard

DeWolf

Shaw

Ed R e u ag C cati an en on te al r

Dog Creek

SC

SE

E Ashlan

H:\GIS\Projects\clovis\04377_04\arcmap\figure5_1_site_selection_03.mxd KK 06.27.05

Dakota

Shields

Clinton

Legend Original Site Selection Study Area

Final Site Selection Study Area

Refined Site Selection Study Area

3 Sites Idenfitied for Cost Comparison Analysis

Proposed ST/WRF Site

Streams and Canals Parcels

±

0.25 0.125

0

0.25

0.5 Miles

Source: Blair, Church and Flynn Consulting Engineers

Figure 5-1 Site Selection Study Area

City of Clovis

Errata to the Draft EIR

Chapter 6, Pages 6-13 and 6-14 are hereby modified as follows:

The following sources were added in alphabetical order under “Personal Communications”: Cadrett, John. CEQA Coordinator. San Joaquin Valley Air Pollution Control District. Modesto, CA June 15, 2005—telephone conversation. Luna, Lisa Ann. Engineer II. Fresno Metropolitan Flood Control District. May 24, 2005—letter to the City.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Chapter 8, Draft Mitigation and Monitoring Program, is hereby modified as follows:

The title of the chapter has been changed to “Draft Mitigation and Monitoring Program,” and the title of the table has been changed to “Mitigation and Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program.” Revisions to the individual environmental measures and mitigation measures in the table are identified below (these revisions also are identified in Chapter 2). Under Environmental Measure 2: Measures to Protect Water Quality during Construction and Operation 2-1: Implement Erosion and Sediment Control Measures. To reduce or eliminate construction-related water quality effects, implement requirements of the NPDES General Permit for Construction Activities (General Construction Permit). Before onset of any construction activities, the City’s contractor will obtain coverage under the General Construction Permit. The City will be responsible for ensuring that construction activities comply with the conditions in this permit, which will require development of a Storm Water Pollution Prevention Plan (SWPPP), implementation of best management practices (BMPs) identified in the SWPPP, and monitoring to ensure that effects on water quality are minimized. Under Environmental Measure 2-2: Develop and Implement a Spill Prevention, Control, and Countermeasure Program for Construction Activities. If a spill is reportable, the contractor’s superintendent will notify the City, and the Fresno County Department of Community Health (Environmental Health Division Emergency Response Team). and t The City will take action to contact the appropriate safety and clean-up crews to ensure that the SPCCP is followed. A written description of reportable releases must be submitted to the Central Valley RWQCB. This submittal must contain a description of the release, including the type of material and an estimate of the amount spilled, the date of the release, an explanation of why the spill occurred, and a description of the steps taken to prevent and control future releases. The releases would be documented on a spill report form. Environmental Measure 3: Dust Control Measures to Protect Air Quality (Regulation VIII) To control dust emissions generated during construction of the proposed project, the City’s construction contractor or DBO entity will incorporate the following SJVAPCD Regulation VIII Control Measures for construction emissions of particulate matter less than or equal to 10 microns in diameter (PM10) are required to be implemented. prepare and submit a Dust Control Plan to the SJVAPCD (Central Region Office at 1990 East Gettysburg Avenue, Fresno, CA 93726) at least 48 hours prior to earth moving, to satisfy the requirements of SJVAPCD Regulation VIII. The requirements of the Dust Control Plan are included in Appendix G. Measures to be included in the Dust Control Plan may include the following.

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J&S 04377.04

City of Clovis

Errata to the Draft EIR

Appendix A, the first page of Comments on Notice of Preparation, is hereby modified as follows:

The following letters or comments were received in response to the notice of preparation. Date

Agency

June 14, 2004

California State Clearinghouse (letter forwarding the NOP to reviewing agencies)

June 21, 2004

California Department of Health Services (Carl Carlucci)

July 8, 2004

Fresno Metropolitan Flood Control District (Jerry Lakeman)

July 14, 2004

California Regional Water Quality Control Board (Jo Anne Kipps)

July 13, 2004

County of Fresno, Department of Public Works (Theresa AcostaMena)

July 9, 2004

Native American Heritage Commission (Rob Wood)

June 15, 2004

Adams Broadwell Joseph & Cardozo (Richard Drury)

(see next page for a copy of the letter)

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City of Clovis

Errata to the Draft EIR

Appendix G, Background Information for Air Quality has been added

This new appendix to the draft EIR includes the San Joaquin Valley Air Pollution Control District Regulation VIII – Fugitive PM10 Prohibitions Dust Control Plan (Dust Control Plan) and the emissions calculations for the proposed project. (see next page)

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Appendix G

Background Information for Air Quality

1.

San Joaquin Valley Air Pollution Control District Regulation VIII – Fugitive PM10 Prohibitions—Dust Control Plan

2.

Emissions Calculations

1.

San Joaquin Valley Air Pollution Control District Regulation VIII – Fugitive PM10 Prohibitions—Dust Control Plan

San Joaquin Valley Air Pollution Control District San Joaquin Valley Air Pollution Control District Regulation VIII – Fugitive PM10 Prohibitions Dust Control Plan Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities requires the owner or operator of a construction project to submit a Dust Control Plan to the District if at anytime the project involves: • • •

Residential developments of ten (10) or more acres of disturbed surface area, Non-residential developments of five (5) or more acres of disturbed surface area, or Relocation of more than 2,500 cubic yards per day of materials on at least three (3) days of the project.

A Dust Control Plan identifies the fugitive dust sources at the construction site and describes all of the fugitive dust control measures that will be implemented before, during, and after any dust generating activity for the duration of the project. One Dust Control Plan may cover a single project or multiple projects at different sites where construction will commence within the following 12 months. The District will review and approve, conditionally approve, or disapprove the Dust Control Plan within 30 days of submittal. Construction activities shall not commence until the Dust Control Plan has been approved or conditionally approved. An owner or operator must also provide written notification to the District via fax or mail within 10 days prior to the commencement of earthmoving activities. A copy of the approved Dust Control Plan must be retained at the project site and made available upon request by a District inspector. At least one key individual representing the owner or operator, or any person who prepares a Dust Control Plan must complete a Dust Control Training Course presented by the District. Please contact the District to find out when courses are being offered. Regardless of whether a District-approved Dust Control Plan is in place or not, the owner or operator is required to comply with all requirements of the applicable rules under Regulation VIII and the District’s Rules and Regulations at all times. Submit the Dust Control Plan to the District’s Compliance Division at the office listed below: For San Joaquin, Stanislaus, and Merced Counties:

Northern Region Office 4230 Kiernan Avenue, Suite 130 Modesto, CA 95356 (209) 557-6400 FAX (209) 557-6475

For Madera, Fresno, and Kings Counties:

Central Region Office 1990 East Gettysburg Avenue Fresno, CA 93726 (559) 230-5950 FAX (559) 230-6062

For Tulare County and the valley portion of Kern County

Southern Region Office 2700 “M” Street, Suite 275 Bakersfield, CA 93301 (661) 326-6900 FAX (661) 326-6985

www.valleyair.org

10/14/2004

Dust Control Plan Section 1 – General Information – Page 1 1-A Project Name and Location Project Name: Project Address: Major X-Streets: City:

County:

Section(s):

Township:

Expected Construction Start Date:

Range: End Date:

1-B Contacts Report the names, addresses, and phone numbers of persons and owners or operators responsible for the preparation, submittal, and implementation of the Dust Control Plan and responsible for the dust generating operation and dust control applications. (Rule 8021 Sec. 6.3.6.1) Property Owner: Address: City / State / Zip: Phone:

Fax:

Developer: Address: City / State / Zip: Contact Person: Phone:

Fax:

General Contractor: Address: City / State / Zip: Contact Person: Phone:

Fax:

This Dust Control Plan was prepared by: Name: Title: Company Name: Address: City / State / Zip: Phone: Date training completed:

Fax: Training Location:

10/14/2004

Section 1 – General Information – Page 2 Project Name:

1-C Contractors Provide the names, addresses, and phone numbers of the contractors involved in dust generating activities or performing dust control as part of this project. (Rule 8021 Sec. 6.3.6.1) 1. 2. 3. 4. 5.

will have the primary responsibility for implementing this Dust Control Plan? 1-D Who (Rule 8021 Sec 6.3.6.1) Property Owner

Developer

Sub-Contractor(s)

Other:

General / Prime Contractor

Primary Project Contact: Title: Company Name: Address: City / State / Zip: On-Site Phone:

Fax:

Mobile Phone:

Pager:

1-E Provide a brief description of the Project’s Operations.

10/14/2004

Dust Control Plan Section 2 – Plot Plan – Page 1 Project Name:

2-A Plot Plan A plot plan identifies the type and location of each project. Attach appropriately sized maps with the project boundaries outlined or use the space in sections 2-B or 2-C to draw a plot plan. Attached maps may include tract maps, site maps, and topographic maps. Use the checklist below to make sure all areas have been identified on the plot plan. (Rule 8021 Sec. 6.3.6.2 & 6.3.6.5) Identify the relative locations of actual and potential sources of fugitive dust emissions. Bulk material handling and storage areas. Paved and unpaved access roads, haul roads, traffic areas, and equipment storage yards. Exit points where carryout and trackout onto paved public roads may occur. Water supply locations if water application will be used for controlling visible dust emissions.

Identify the relative locations of sensitive receptors within ¼ mile of the project. (Rule 4102 Sec. 4.1) No sensitive receptors within ¼ mile of the project. Residential areas, schools, day care, churches, hospitals, nursing facilities, commercial, retail, etc. Freeways, roads, or traffic areas that may be affected by the dust generating activities. Other:

2-B Draw Plot Plan (if one is not attached)

May use the back of this form Include a North Arrow

Plot plan is attached (Skip to 3-A).

10/14/2004

Section 2 – Plot Plan – Page 2 Project Name:

2-C Draw Plot Plan (if one is not attached)

Include a North Arrow

10/14/2004

Dust Control Plan Section 3 – Fugitive PM10 Sources – Page 1 Project Name:

3-A Disturbed Surface Area Report the total area of land surface to be disturbed, the daily throughput volume of earthmoving in cubic yards, and the total area in acres of the entire project site. (Rule 8021 Sec. 6.3.6.3) Total area of land surface to be disturbed:

Acres

Daily maximum throughput volume of earthmoving:

Cubic Yards

Daily average throughput volume of earthmoving:

Cubic Yards

Total area of entire project site:

Acres

Total disturbed areas that will be left inactive for more than seven days:

Acres

3-B Dust Generating Activity Dates The expected start and completion dates of dust generating activities and soil disturbance activities to be performed on site. For phased projects, it may be necessary to report expected start and completion dates separately. (Rule 8021 Sec. 6.3.6.4) Expected start date:

Completion Date:

Phase Project Start – A:

Completion – A:

Phase Project Start – B:

Completion – B:

Phase Project Start – C:

Completion – C:

3-C Other Locations Identify whether any other locations should be included with this plan that are involved with this project. An example may include listing any site where materials will be imported from or exported to. (Rule 8021 Sec. 6.3.2) No other locations are included with this project. (Skip to 3-D) Location 1: No Dust Control Plan Required

Included with this plan

Included with another plan

Included with this plan

Included with another plan

Included with this plan

Included with another plan

Location 2: No Dust Control Plan Required Location 3: No Dust Control Plan Required

10/14/2004

Section 3 – Fugitive PM10 Sources – Page 2 Project Name:

3-D Sources of Fugitive Dust This section describes the minimum requirements for limiting visible dust emissions from activities that cause fugitive dust emissions. (Rule 8021 Sec. 6.3.6.5) Check at least one box under each category.

Structural Demolition. (Rule 8021 Sec. 5.1, 6.3.3, & 6.3.6.5) No demolitions are planned for this project. Asbestos NESHAP notification and fees have been submitted to the District. (Rule 3050 and Rule 4002). Water will be applied to the following areas for the duration of the demolition activities: Building exterior surfaces; Unpaved surface areas where equipment will operate; Razed building materials; and Water or dust suppressants will be applied to unpaved surface areas within 100 feet of structure during demolition.

Pre-Activity. (Rule 8021 Sec. 5.2) Not applicable for this project (Please explain why in Section 3-F). The site will be pre-watered and work will be phased to reduce the amount of disturbed surface area at any one time (Complete Section 4-A).

Active Operations. (Rule 8021 Sec. 5.2) Water will be applied to dry areas during leveling, grading, trenching, and earthmoving activities (Complete Section 4-A). Wind barriers will be constructed and maintained, and water or dust suppressants will be applied to the disturbed surface areas (Complete Sections 4-A or 4-B, and 4-C).

Inactive Operations, including after work hours, weekends, and holidays. (Rule 8021 Sec. 5.2) Not applicable for this project (Please explain why in Section 3-F). Water or dust suppressants will be applied on disturbed surface areas to form a visible crust, and vehicle access will be restricted to maintain the visible crust. (Complete Section 4-A or 4-B, and 4-C)

Temporary stabilization of areas that remain unused for seven or more days. (Rule 8021 Sec. 5.2) Not applicable for this project (Please explain why in Section 3-F) Vehicular access will be restricted and water or dust suppressants will be applied and maintained at all unvegetated areas (Complete Section 4-A or 4-B, and 4-C). Vegetation will be established on all previously disturbed areas (Complete Section 4-C). Gravel will be applied and maintained at all previously disturbed areas (Complete Section 4-C). Previously disturbed areas will be paved (Complete Section 4-C).

Unpaved Access and Haul Roads, Traffic and Equipment Storage Areas. (Rule 8021 Sec. 5.2 and 5.3) Not applicable for this project (Please explain why in Section 3-F) Apply water or dust suppressants to unpaved haul and access roads (Complete Section 4-A or 4-B) Post speed limit signs of not more than 15 miles per hour at each entrance, and again every 500 feet. (Complete Section 4-C) Water or dust suppressants will be applied to vehicle traffic and equipment storage areas (Complete Section 4-A or 4-B).

Wind Events. (Rule 8021 Sec. 5.4) Water application equipment will apply water to control fugitive dust during wind events, unless unsafe to do so. Outdoor construction activities that disturb the soil will cease whenever visible dust emissions cannot be effectively controlled.

10/14/2004

Section 3 – Fugitive PM10 Sources – Page 3 3-E Bulk Materials (Rule 8021 Sec. 6.3.6.6 and Rule 8031) Outdoor Handling of Bulk Materials. (Rule 8031 Sec. 5.0 A) No bulk materials will be handled during this project. Water or dust suppressants will be applied when handling bulk materials. Wind barriers with less than 50 percent porosity will be installed and maintained, and water or dust suppressants will be applied.

Outdoor Storage of Bulk Materials. (Rule 8031 Sec. 5.0 B) No bulk materials will be stored during this project. Water or dust suppressants will be applied to storage piles. Storage piles will be covered with tarps, plastic, or other suitable material and anchored in such a manner that prevents the cover from being removed by wind action. Wind barriers with less than 50 percent porosity will be installed and maintained around the storage piles, and water or dust suppressants will be applied. A three-sided structure (< 50% porosity) will be used that is at least as high as the storage piles.

On-Site Transporting of Bulk Materials. (Rule 8031 Sec. 5.0 C) No bulk materials will be transported on the project site. Vehicle speed will be limited on the work site. All haul trucks will be loaded such that the freeboard is not less than six inches when transported across any paved public access road. A sufficient amount of water will be applied to the top of the load to limit visible dust emissions. Haul trucks will be covered with a tarp or other suitable cover.

Off-Site Transporting of Bulk Materials. (Rule 8031 Sec. 5.0 D) No bulk materials will be transported to or from the project site. The following practices will be performed: (complete Section 5-B) The interior of emptied truck cargo compartments will be cleaned or covered before leaving the site. Spillage or loss of bulk materials from holes or other openings in the cargo compartment’s floor, sides, and tailgates will be prevented. Haul trucks will be covered with a tarp or other suitable cover or will be loaded such that the freeboard is not less than six inches when transported on any paved public access road to or from the project site and a sufficient amount of water will be applied to the top of the load to limit visible dust emissions.

Outdoor Transport using a Chute or Conveyor. (Rule 8031 Sec. 5.0 E) No chutes or conveyors will be used. Chute or conveyor will be fully enclosed. Water spray equipment will be used to sufficiently wet the materials. Transported materials will be washed or screened to remove fines (PM10 or smaller).

3-F

Comments

10/14/2004

Dust Control Plan Section 4 – Dust Control Methods – Page 1 Project Name:

4-A Water Application Complete this section if water application will be used as a control method for limiting visible dust emissions and stabilizing surface areas. Check and answer everything that applies to this project. (Rule 8021 Sec. 6.3.6.6)

Water Application Equipment: Sprinklers:

Describe the activities that will utilize sprinklers:

Minimum treated area:

Square Feet

Acres

Maximum treated area:

Square Feet

Acres

Minimum water flow rate: Water Truck,

Water Trailer,

Duration: Water Wagon,

Other:

Describe the activities that will utilize this equipment:

Number of application equipment available: Application equipment capacity: Application frequency: Application rate:

Gallons per acre per application

Hours of operation: Water application equipment is available to operate after normal working hours, on weekends, and holidays. After-hours contact:

Phone No.:

After-hours contact:

Phone No.:

Water Supply: Include the relative locations of these sources on the plot plan in Section 2. Fire hydrants Number of hydrants available On-Site: Off-Site: Approval granted by the owner or public agency to use their fire hydrants for this project. Owner or Agency: Contact: Storage tanks

Number and capacity:

Wells

Number and flow rate:

Phone No.:

Canal, River, Pond, Lake, etc. Describe: Approval granted by the owner or public agency to use their water source for this project. Owner or Agency: Contact:

Phone No.:

Other:

10/14/2004

Section 4 – Dust Control Methods – Page 2 Project Name:

4-B Dust Suppressant Products Complete this section if a dust suppressant product will be used. These materials include, but are not limited to: hygroscopic suppressants (road salts), adhesives, petroleum emulsions, polymer emulsions, and bituminous materials (road oils). (Rule 8021 Sec. 6.3.6.6) Copy this page if more than one dust suppressant product will be used.

Not Applicable. Only water application will be the control method used. Skip to 4-C. Application Area: Product Name: Contractor’s Name: Application Rate: Application Frequency:

Phone No: Gallons of undiluted material per Applications per

week,

mile or

month,

acre treated.

year

Application Equipment: Number of Application Equipment Available: Application Equipment Capacity: Attach each of the following information that fully describes this product. Use the checklist below to make sure all information is submitted with this plan. Product Specifications (MSDS, Product Safety Data Sheet, etc.) Manufacturer’s Usage Instructions (method, frequency, and intensity of application) Environmental impacts and approvals or certifications related to the appropriate and safe use for ground application.

10/14/2004

Section 4 – Dust Control Methods – Page 3 Project Name:

4-C Other Dust Control Methods Check below the other types of dust control methods that will be employed at the construction site. (Rule 8021 Sec. 5.2)

Physical barriers for restricting unauthorized vehicle access: Fences Gates Posts Berms

Concrete Barriers

Other: Wind barriers Describe: Posted speed limit signs meet State and Federal Department of Transportation standards. (Rule 8021 Sec. 5.3) Posted at 15 miles per hour, Posted at miles per hour (less than 15 MPH) Re-establish vegetation for temporarily stabilizing previously disturbed surfaces. Explain: Apply and maintain gravel: On haul roads On access roads At equipment storage yards At vehicle traffic areas For temporarily stabilizing previously disturbed areas. Explain: Apply pavement: Explain: Other:

4-D Contingencies Contingencies to be implemented if application equipment becomes inoperable, more equipment is needed to effectively control fugitive dust emissions during active and inactive periods, accessibility limitations occur at the water sources, or staff is not available to operate the application equipment. Describe the contingencies that will be in place and when they will be implemented. Attach any additional information if needed. (Rule 4102 and Rule 8021 Sec. 6.3.6.6)

4-E Record keeping (Rule 8011 Sec. 6.2) Records and any other supporting documents for demonstrating compliance must be maintained, but only for those days when a control measure is implemented. The District has developed record keeping forms that may be used for complying with this requirement. Check one or both below: Records will be maintained using the forms developed by the District. Records will be maintained using documents or forms developed by the owner or operator. Explain and include copies:

10/14/2004

Dust Control Plan Section 5 – Carryout and Trackout – Page 1 Project Name:

5-A Treatments for Preventing Trackout Select the control devices that will be used for preventing trackout from occurring onto paved public roads. Trackout is any material that adheres to vehicle tires and is deposited onto a paved public road or the paved shoulder of a paved public road. Check one or a combination that will apply to this project. Grizzly: Rails, pipes, or grates used to dislodge debris off of vehicles before exiting the site. Extends from the intersection with the paved public road surface for the full width of the unpaved exit surface for a distance of at least 25 feet. (Rule 8041 Sec. 5.9.1) Describe:

Gravel Pad: A layer of washed gravel at least one (1) inch or larger in diameter, three (3) inches deep, and extends from the intersection with the public paved road surface for the full width of the unpaved exit surface for a distance of at least 50 feet. (Rule 8041 Sec. 5.9.2) Gravel Size: Pad Width:

Inches Feet

Length:

Feet

Depth:

Inches

Paved Surface: Extends from the intersection with the paved public road surface for the full width of the unpaved access road for at least 100 feet to allow mud and dirt to drop off of vehicles before exiting the site. (Rule 8041 Sec. 5.9.3)

Width: Feet Length: Feet Mud and dirt deposits accumulating on paved interior roads will be removed with sufficient frequency, but not less frequently than once per workday. Cleanup will commence within ½ hour of generating any carryout and trackout. (Rule 8041 Sec. 5.8.2 and 5.9.3) Clean-up Frequency:

Wheel Washer: Uses water to dislodge debris from tires and vehicle undercarriage. (Rule 8011 Sec. 3.73) Describe:

Other: (Rule 8041 Sec. 5.8.1.2)

5-B Treatments for Preventing Carryout Report the required treatments that will be used for preventing carryout from occurring on paved public roads. Carryout occurs when materials from emptied or loaded haul trucks, vehicles, or trailers falls onto a paved public road or paved shoulder of a paved public road. No haul trucks will be routinely entering or leaving the project site.

Emptied Haul Trucks: (Rule 8031 Sec 5.0) Interior cargo compartments will be cleaned before leaving the project site. Cargo compartment will be covered with a tarp or suitable cover before leaving the project site.

Loaded Haul Trucks: Spillage or loss of materials from holes or other opening in the cargo compartment will be prevented when material is transported onto any paved public access road. (Rule 8031 Sec 5.0) Select one or both of the required applications: Haul trucks will be loaded such that the freeboard is not less than six inches with water applied to the top of the load before leaving the project site. Cargo compartment and load will be covered with a tarp or suitable cover before leaving the project site.

Other: 10/14/2004

Section 5 – Carryout and Trackout – Page 2 Project Name:

5-C

Cleaning up Carryout and Trackout

Check and report below the methods and frequency for cleaning up carryout and trackout from the surface and paved shoulders of paved public roads. The use of blower devices, or dry rotary brushers or brooms, for removal of carryout and trackout from paved public roads is prohibited. (Rule 8041 Sec. 5.0). In the event the control device becomes ineffective due to an accumulation of mud and dirt, material must be removed within ½ hour of the generation of carryout and trackout. (Rule 8041 Sec. 5.8.2.) The project is located in: An Urban Area, within an incorporated city boundary or an unincorporated area surrounded by a city. Minimum cleanup frequency will be at the end of the workday and removed immediately if carryout and trackout extends beyond 50 feet. (Rule 8041 Sec. 5.4) A Rural Area, located within an unincorporated area and not surrounded by an incorporated city. The construction project is less than 10 acres in size: minimum cleanup frequency is at the end of the workday. (Rule 8041 Sec. 5.1) Construction projects 10 or more acres in size: minimum cleanup frequency is end of the workday and immediately if carryout and trackout extends beyond 50 feet. (Rule 8041 Sec. 5.5)

Clean up Method: Check the method below that will be used for cleaning carryout and trackout. Manually sweeping and picking up. (Rule 8041 Sec. 5.7.1) Mechanical sweeping with a rotary brush or broom accompanied or preceded by water. (Rule 8041 Sec. 5.7.2) Describe the types of equipment that will used:

Operating a PM10-efficient street sweeper. (Rule 8041 Sec. 5.7.3) Make and Model: Flushing with water: allowed if: (Rule 8041 Sec. 5.7.4) • No curbs or gutters are present. • Using water will not result as a source of trackout and carryout. • Using water will not result in adverse impacts on storm water drainage systems. • Using water will not violate any National Pollutant Discharge Elimination System permit program.

5-D

Record keeping for Cleanup of Carryout and Trackout (Rule 8011 Sec. 6.2)

Records and any other supporting documents for demonstrating compliance must be maintained. The District has developed a record keeping form specific for cleaning carryout and trackout from paved public roads and may be used for complying with this requirement. Check one or both below: Records will be maintained using the form developed by the District. Records will be maintained using documents or forms developed by the owner or operator. Explain and include copies:

10/14/2004

Dust Control Plan Section 6 – Certification Project Name:

6-A Certification I certify that all information contained herein and information submitted in the attachments to this documents are true and correct.

Print Name

Title

Signature

Date

Phone Number

Fax Number

Cell Number

10/14/2004

2.

Emissions Calculations

City of Clovis Sewage Treatment/Water Reuse Facility VOC Emissions from Influent Treatment Average Daily Influent Flow (MM gal/day) Conversion Factor from µg/L and MGD to lb/yr* Annual x/Q from SCREEN3 modeling (1-hour x/Q x 0.1) Max 24-hr x/Q (1-hr x/Q * 0.4)

8.4 3.04 26.96 118.4 Annual-Average Ambient Concs.

Compound

Risk Assessment Averaging Period

Methylene Chloride 1,1,1-TCA Benzene Chloroform TCE Toluene Xylenes 1,4-Dichlorobenzene Ethyl Benzene Phenol Styrene Ammonia Hydrogen Sulfide

Annual, 24 hr Annual Annual, 24 hr Annual, 24 hr Annual Annual, 24-hr Annual, 24-hr Annual Annual Annual, 24-hr Annual, 24-hr Annual, 24-hr Annual, 24-hr

Toxic Influent Concentration (µg/L) 7.8 2.65 0.58 8.1 2.6 4.9 5.86 4.65 2.25 9.8 5 299.5 19.5 TOTAL:

Annual Emissions (pounds)

Annual Emissions (g/s)

199.2 67.7 14.8 206.8 66.4 125.1 149.6 118.7 57.5 250.3 127.7 7648.0 49.8 9081.6

2.86E-03 9.73E-04 2.13E-04 2.98E-03 9.55E-04 1.80E-03 2.15E-03 1.71E-03 8.26E-04 3.60E-03 1.84E-03 1.10E-01 7.16E-04 0.1

SCREEN3 Dispersion SCREEN3 factor (ug/m3) / Annual Ambient Dispersion factor 24-hr Ambient (g/s) Conc. (ug/m3) (ug/m3) / (g/s) Conc. (ug/m3) 26.96 26.96 26.96 26.96 26.96 26.96 26.96 26.96 26.96 26.96 26.96 26.96 26.96

7.72E-02 2.62E-02 5.74E-03 8.02E-02 2.57E-02 4.85E-02 5.80E-02 4.60E-02 2.23E-02 9.70E-02 4.95E-02 2.97E+00 1.93E-02

Notes: Emission factors from SJVAPCD Assumed hydrogen sulfide would be controlled to 90% efficiency with scrubbers or biofilters that are part of the odor control system. *From SJVAPCD methodology

24- Hr Average Ambient Concs.

118.4 118.4 118.4 118.4 118.4 118.4 118.4 118.4 118.4 118.4 118.4 118.4 118.4

3.39E-01 1.15E-01 2.52E-02 3.52E-01 1.13E-01 2.13E-01 2.55E-01 2.02E-01 9.78E-02 4.26E-01 2.17E-01 1.30E+01 8.48E-02

Carcinogenic Risk

Unit Risk Factors 3 (µg/m -1) 1.0E-06 0 2.9E-05 5.3E-06 2.0E-06 0 0 1.1E-05 0 0 0 0 0 TOTAL:

Cancer Risk 7.7E-08 0 1.7E-07 4.3E-07 5.1E-08 0 0 5.1E-07 0 0 0 0 0 1.2E-06

Non-Cancer Risk

Chronic Inhalation REL 400.0 99999999.0 60.0 300.0 600.0 300.0 700.0 800.0 2000.0 200.0 900.0 200.0 10.0

24-hr Chronic Acute (Acute) NonCancer Non-cancer Inhalation Risk Risk REL 0.0002 0.0001 0.0003 0.0000 0.0002 0.0001 0.0001 0.0000 0.0005 0.0001 0.0148 0.0019 1.8E-02

14000 99999999 1300 150 99999999 37000 22000 99999999 99999999 5800 21000 3200 42

0.00002 0.00000 0.00002 0.00235 0.00000 0.00001 0.00001 0.00000 0.00000 0.00007 0.00001 0.00407 0.00202 0.0086

City of Clovis Sewage Treatment/Water Reuse Facility Emissions from Diesel Pump and Emergency Generator Engines ST/WRF Generators Generator Engine Output power (Hp) Hrs per Year of Testing and Operation

Emission Factor (lb/hp-hr) NOx 0.031 CO 6.68E-03 PM10 2.20E-03 TOC* 2.51E-03 *Evaporative and crankcase

3446.6 16

Annual Annual Emissions (lbs) Emissions (tons) 1709.5 0.85 368.4 0.18 121.3 0.06 138.4 0.07

Pump Station Generators Generator Engine Output power (Hp) Hrs per Year of Testing and Operation

Emission Factor (lb/hp-hr) NOx 0.031 CO 6.68E-03 PM10 2.20E-03 TOC* 2.51E-03 *Evaporative and crankcase

536 16

Annual Annual Emissions (lbs) Emissions (tons) 265.9 0.13 57.3 0.03 18.9 0.01 21.5 0.01

Total Generator Emissions

Annual Emissions Annual (lbs) Emissions (tons) NOx CO PM10 TOC*

1975.4 425.7 140.2 159.9

1.0 0.2 0.1 0.1

Notes: Emission factors from AP-42 Chapter 3.3, Table 3.3-1 Gasoline and Diesel Industrial Engines Supplement B, 1996 Annual hours of testing and operation are based on 8 hours per year of testing and 8 hours per year of operation during electric power failure.

City of Clovis Sewage Treatment/Water Reuse Facility Emissions from Disposal Truck Trips Daily Truck Trips Round-trip distance Truck Vehicle Class Analysis Year

NOx CO PM10 ROG

5 26 HHD 2006

EMFAC2002 Emission Daily Emissions Annual Factors (g/mi) (pounds) Emissions (tons) 13.6 3.9 0.71 2.8 0.8 0.15 0.3 0.1 0.02 0.8 0.2 0.04

City of Clovis Sewage Treatment/Water Reuse Facility Program

Mitigation Monitoring Program

Prepared by:

City of Clovis 1033 Fifth Street Clovis, CA 93612 Contact: David E. Fey, AICP 559.324.2338

With technical assistance from:

Jones & Stokes 2841 Junction Avenue, Suite 114 San Jose, CA 95134 Contact: Kate Giberson 408.434.2244

July 2005

Jones & Stokes. 2005. Mitigation Monitoring Program—City of Clovis Sewage Treatment/Water Reuse Facility Program. July. (J&S 04377.04.) San Jose, CA. Prepared for City of Clovis, Clovis, CA.

Mitigation Monitoring Program

This document represents the mitigation monitoring program (MMP) prepared by the City of Clovis for the Sewage Treatment/Water Reuse Facility Program (proposed project). When a lead agency makes findings on significant effects identified in an environmental impact report (EIR), it must also adopt a program for reporting or monitoring mitigation measures that were adopted or made conditions of project approval (Public Resources Code Section 21081.6[a]; State CEQA Guidelines Sections 15091[d], 15097). This MMP includes all measures, including environmental measures (included as part of the proposed project) and mitigation measures (additional measures that were identified in the EIR analysis), required to reduce potentially significant environmental impacts to a less-than-significant level. It also identifies the timing of implementation; the agency responsible for implementing the mitigation; and the agency responsible for monitoring the mitigation. This MMP has been prepared by the City of Clovis, with technical assistance from Jones & Stokes, an environmental consulting firm. Questions should be directed to David E. Fey, AICP, Deputy City Planner, and Steven White, P.E., City Engineer (559/324-2000).

City of Clovis Sewage Treatment/ Water Reuse Facility Program Mitigation Monitoring Program

July 2005

1

J&S 04377.04

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

Environmental Measures Environmental Measure 1: Measures to Minimize Effects of Construction-Related Noise The following noise control measures will be included in the construction contract specifications to reduce and control noise generated from construction-related activities. a.

b.

c.

d.

The normal working day for construction activities, including the delivery of materials, equipment, and supplies, will be between the hours of 7:00 a.m. and 7:00 p.m. on weekdays. Construction could also occur on Saturdays, between 8:00 a.m. and 7:00 p.m., but would not occur on Sundays or holidays or at night without prior written approval from the City Department of Planning and Development Services under special or unique circumstances. Construction equipment will have appropriate mufflers, intake silencers, and noise control features and will be properly maintained and equipped with exhaust mufflers that meet state standards. Vehicles and other gas- or diesel-powered equipment will be prohibited from unnecessary warming up, idling, and engine revving. Residents within 100 feet of construction activities will be notified by the DBO entity in writing (i.e., letter or flyer) at least 5 working days prior to construction activities. The notice will include construction hours, duration, and name and telephone number or email address of the City staff member the public should contact with noise complaints.

Page 1 of 44

Monitoring Notes

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure e.

f.

Timing

Implementation Responsibility

Monitoring Responsibility

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

A sign will be posted at all active construction sites, giving the name and telephone number or email address of the City staff member the public should contact with noise complaints. If necessary due to complaints, the construction contractor will provide additional noise attenuating measures such as sound blankets, additional mufflers, or engine shrouding. (No demolition would occur as part of the proposed project.) Stationary equipment (e.g., generators) will not be located adjacent to any existing residences unless enclosed in a noise attenuating structure, subject to the approval of the Director.

Environmental Measure 2: Measures to Protect Water Quality during Construction and Operation 2-1: Implement Erosion and Sediment Control Measures. To reduce or eliminate constructionrelated water quality effects, implement requirements of the NPDES General Permit for Construction Activities (General Construction Permit). Before onset of any construction activities, the City will obtain coverage under the General Construction Permit. The City will be responsible for ensuring that construction activities comply with the conditions in this permit, which will require development of a Storm Water Pollution Prevention Plan (SWPPP), implementation of best management practices (BMPs) identified in the SWPPP, and monitoring to ensure that effects on water quality are minimized.

Monitoring Notes

Page 2 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure The following erosion and sediment control BMPs will be included in the SWPPP to be included in the construction specifications and project performance specifications, based on standard City measures and standard dust-reduction measures. a.

b.

c.

d.

e.

Cover or apply nontoxic soil stabilizers to inactive construction areas (previously graded areas inactive for 10 days or more) that could contribute sediment to waterways. Enclose and cover exposed stockpiles of dirt or other loose, granular construction materials that could contribute sediment to waterways. Control and contain soil and filter runoff from disturbed areas. This will be done by using berms, silt fencing, straw bales or wattles, plastic sheeting or geofabric, silt/sediment traps and catch basins, silt fencing, sand bag dikes, temporary vegetation or other groundcover, or other means necessary to prevent the escape of sediment from the disturbed area. No earth or organic material shall be deposited or placed where it may be directly carried into a stream, marsh, slough, lagoon, or body of standing water. Prohibit the following types of materials from being rinsed or washed into the streets, shoulder areas, or gutters: concrete, solvents and adhesives, thinners, paints, fuels, sawdust, dirt, gasoline, asphalt and concrete saw slurry, and heavily chlorinated water.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 3 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure f.

g.

h.

Timing

Implementation Responsibility

Monitoring Responsibility

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

Dewatering activities shall be conducted according to the provisions of the SWPPP. No dewatered materials shall be placed in local water bodies or in storm drains leading to such bodies without implementation of proper construction water quality control measures. Drainage facilities in downstream offsite areas will be protected from sediment using BMPs acceptable to Fresno County and the Central Valley RWQCB. Grass or other vegetative cover will be established on the construction site as soon as possible after disturbance.

Final selection of BMPs will be subject to review by the City. The City will verify that a notice of intent (NOI) and SWPPP have been filed before allowing construction to begin. The City or its agent will perform routine inspections of the construction area to verify that the BMPs specified in the SWPPP are properly implemented and maintained. The City will notify its contractors immediately if there is a noncompliance issue and will require compliance. 2-2: Develop and Implement a Spill Prevention, Control and Countermeasure Program for Construction Activities. The contractor will develop and implement a spill prevention, control, and countermeasure program (SPCCP) to minimize the potential for and effects from spills of hazardous, toxic, or petroleum substances during construction activities for all contractors. The SPCCP will be completed before any construction activities begin. Implementation of this measure will comply with state and federal water quality regulations.

Prior to and during construction

Monitoring Notes

Page 4 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure The City will review and approve the SPCCP before onset of construction activities. The City will routinely inspect the construction area to verify that the measures specified in the SPCCP are properly implemented and maintained. The City will notify its contractors immediately if there is a noncompliance issue and will require compliance. The federal reportable spill quantity for petroleum products, as defined in 40 CFR 110, is any oil spill that: violates applicable water quality standards, causes a film or sheen on or discoloration of the water surface or adjoining shoreline, or causes a sludge or emulsion to be deposited beneath the surface of the water or adjoining shorelines. If a spill is reportable, the contractor’s superintendent will notify the City and the Fresno County Department of Community Health (Environmental Health Division Emergency Response Team). The City will take action to contact the appropriate safety and clean-up crews to ensure that the SPCCP is followed. A written description of reportable releases must be submitted to the Central Valley RWQCB. This submittal must contain a description of the release, including the type of material and an estimate of the amount spilled, the date of the release, an explanation of why the spill occurred, and a description of the steps taken to prevent and control future releases. The releases would be documented on a spill report form.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 5 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

If an appreciable spill has occurred and results determine that project activities have adversely affected surface water or groundwater quality, a detailed analysis will be performed by a registered environmental assessor to identify the likely cause of contamination. This analysis will conform to American Society for Testing and Materials standards, and will include recommendations for reducing or eliminating the source or mechanisms of contamination. Based on this analysis, the City and its contractors will select and implement measures to control contamination, with a performance standard that groundwater quality must be returned to baseline conditions. These measures will be subject to approval by the City. 2-3: Develop and Implement a Frac-Out Contingency Plan for Jack-and-Bore Activities. For jack-and-bore tunneling activities that use drilling lubricants, the City or its contractor will prepare and implement a frac-out contingency plan that is intended to minimize the potential for a frac-out associated with tunneling activities; provide for the timely detection of frac-outs; and ensure an organized, timely, and “minimumimpact” response in the event of a frac-out and release of drilling lubricant (i.e., bentonite). The contingency plan will require, at a minimum, the following measures. a.

A full-time monitor will attend all drilling to look for observable frac-out conditions or lowered pressure readings on drilling equipment.

Monitoring Notes

Page 6 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure b.

c.

d.

Timing

Implementation Responsibility

Monitoring Responsibility

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

If a frac-out is identified, all work will stop, including the recycling of drilling lubricant. In the event of a frac-out into water, the pressure of water above the tunnel will keep excess mud from escaping through the fracture. The location and extent of the fracout will be determined, and the frac-out will be monitored for 4 hours to determine whether the drilling lubricant congeals (bentonite will usually harden, effectively sealing the frac-out location). If the drilling lubricant congeals, no other actions will be taken that would potentially suspend sediments in the water column. Surface releases of bentonite will be allowed to harden and then will be removed.The contingency plan will identify additional measures to be taken to contain or remove the drilling lubricant if it does not congeal.

2-4: Obtain NPDES Permit and WDRs for Discharging Dewatered Effluent and Implement Measures Identified by the RWQCB. Before discharging any dewatered effluent to surface water, the City or its contractors will obtain an NPDES permit and WDRs from the Central Valley RWQCB. Depending on the volume and characteristics of the discharge, coverage under the General Construction Permit or General Order for Dewatering and Other Low Threat Discharges to Surface Waters (General Dewatering Permit) is possible. As part of the permit, the permittee will design and implement measures as necessary so that the discharge limits identified in the relevant permit are met. As a performance standard, these measures will be selected to achieve maximum sediment removal and represent the best available technology that is economically achievable.

Monitoring Notes

Page 7 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

During operation

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

Implemented measures may include retention of dewatering effluent until particulate matter has settled before it is discharged, use of infiltration areas, and other BMPs. Final selection of water quality control measures will be subject to approval by the City. The City will verify that coverage under the appropriate NPDES permit has been obtained before allowing dewatering activities to begin. The City or its agent will perform routine inspections of the construction area to verify that the water quality control measures are properly implemented and maintained. The City will notify its contractors immediately if there is a noncompliance issue and require compliance. 2-5: Implement BMPs to Reduce Water Quality Effects from Polluted Runoff. To reduce or eliminate water quality effects from polluted runoff from the ST/WRF, the City or its contractors will implement multiple BMPs in areas with potential to drain to storm drainage systems or surface waters. As a performance standard, these BMPs will be selected to achieve maximum sediment removal and represent the best available technology that is economically achievable. The BMPs may include a combination of source control, structural elements, and treatment systems. BMPs may include the following. a.

For areas where parking lots create new impervious surfaces, to help minimize the amount of pollutants entering the storm drain system, paved project roadways and parking areas will be cleaned regularly using street sweeping equipment. Additionally, litter and debris that may accumulate on the project site will be regularly collected and properly disposed. These measures will be carried out

Monitoring Notes

Page 8 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

b.

c.

d.

e. f.

at least monthly during the rainy season (October through April). Grass strips, high infiltration substrates, and grassy swales will be used where feasible to reduce runoff and provide initial stormwater treatment. This type of treatment would apply particularly to parking lots. Small settling, treatment, or infiltration devices will be installed beneath parking areas to provide initial filtration before discharge into subsequent treatment systems or storm drainage systems. Roof drains will drain to natural surfaces or swales where possible to avoid excessive concentration and channelization of stormwater. Roof drains will be directly connected to the storm drain system if treatment control measures are provided downstream. Permanent energy dissipaters will be installed for drainage outlets. If necessary, retention or detention basins will be designed to provide effective water quality control. Basin features will include the following measures: o maximize retention time for settling of fine particles; o establish maintenance schedules for periodic removal of sedimentation, excessive vegetation, and debris that may clog basin inlets and outlets; and o maximize the retention basin elevation to allow the highest amount of infiltration and settling before discharge.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 9 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

These BMPs will be incorporated into project design before finalization of design and initiation of construction. The City or its agent will perform routine (at least monthly) inspections of the project site to verify that the identified BMPs are properly implemented and maintained. The City will notify its contractors immediately if there is a noncompliance issue and will require compliance. Environmental Measure 3: Dust Control Measures to Protect Air Quality (Regulation VIII) To control dust emissions generated during construction of the proposed project, the City’s construction contractor or DBO entity will prepare and submit a Dust Control Plan to the SJVAPCD (Central Region Office at 1990 East Gettysburg Avenue, Fresno, CA 93726) at least 48 hours prior to earth moving, to satisfy the requirements of SJVAPCD Regulation VIII. The requirements of the Dust Control Plan are included in Appendix G. Measures to be included in the Dust Control Plan may include the following. a.

b.

c.

Water all active construction areas where soil is exposed at least twice daily, and more often if needed, to control dust generation during earthmoving activities. All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, covered with a tarp or other suitable cover or vegetative ground cover. All onsite unpaved roads and offsite unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.

Monitoring Notes

Page 10 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure d.

e.

f.

g.

h.

i.

j.

All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking. With the demolition of buildings up to six stories in height, all exterior surfaces of the building shall be wetted during demolition. When materials are transported off site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least 2 feet of freeboard space from the top of the container shall be maintained. All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday. (The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions.) (Use of blower devices is expressly forbidden.) Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical stabilizer/suppressant. Within urban areas, trackout shall be immediately removed when it extends 50 or more feet from the site and at the end of each workday. Any site with 150 or more vehicle trips per day shall prevent carryout and trackout.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 11 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

Environmental Measure 4: Measures to Control Construction-Related Emissions

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

To comply with guidance from the SJVAPCD, the City will incorporate the following measures into the construction specifications and project performance specifications for the proposed project. a.

b.

c.

d.

e.

The construction contractor will ensure that onsite equipment will be equipped with Tier I or Tier II engines. Tier II engines are preferable, if available as certified by the California Air Resources Board (ARB). Engines built after 1998 are cleaner Tier II engines. Engines certified by the ARB can be found through http://www.aarb.ca.gov/msprog/offroad/cert/cer t.php. The construction contractor will ensure that all diesel engines are shut off when not in use on the premises to reduce emissions from idling. The construction contractor will review and comply with SJVAPCD Rules 8011 to 8081 (Fugitive Dust), 4102 (Nuisance), 4601 (Architectural Coatings), and 4641 (Paving and Maintenance Activities). Current SJVAPCD rules can be found at http://www.valleyair.org/rules/1ruleslist.htm. The construction contractor will use off-road trucks that are equipped with on-road engines, when possible. The construction contractor will use light duty cars and trucks that use alternative fuel or are hybrids, if feasible.

Monitoring Notes

Page 12 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

Environmental Measure 5: Proper Disposal of All Construction Debris

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

The construction contractor will ensure that all construction debris, including roadbed fragments, will be collected and disposed per City specifications at an appropriate disposal facility. Recycling construction debris is encouraged, and appropriate recycling centers are identified in the Resource Guide for the Disposal of Construction and Demolition Debris (Fresno County 2004). Environmental Measure 6: Coordinate Relocation and Interruptions of Service with Utility Providers during Construction The construction contractor will contact Underground Service Alert (800/642-2444) at least 48 hours before excavation work begins to verify the nature and location of existing underground utilities. In addition, the contractor will notify and coordinate with public and private utility providers at least 48 hours before work begins adjacent to any existing utility, unless the excavation permit specifies otherwise. In addition, the service provider will be notified in advance of all service interruptions and will be given sufficient time to notify customers. The timing of interruptions will be coordinated with the providers to ensure that the frequency and duration of interruptions are minimized. Environmental Measure 7: Develop and Implement a Traffic Control Plan In accordance with the City’s policy on street closures and traffic diversion for arterial and collector roadways, the construction contractor will prepare a traffic control plan (to be approved by the city and county engineers) before construction. The traffic control plan will include:

Monitoring Notes

Page 13 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure A street layout showing location of construction activity and surrounding streets to be used as detour routes, including “special signage”; A tentative start date and construction duration period for each phase of construction; The name, address, and emergency contact number for those responsible for maintaining the traffic control devices during the course of construction; and Written approval to implement traffic control from other agencies, as needed. Additionally, the traffic control plan will include the following stipulations. Provide access for emergency vehicles at all times. Maintain access for driveways and private roads, except for brief periods of construction, in which case property owners will be notified. Provide adequate off-street parking or use designated public parking areas for construction-related vehicles not in use through the construction period. Maintain pedestrian and bicycle access and circulation during project construction where safe to do so. If construction encroaches on a sidewalk, a safe detour will be provided for pedestrians at the nearest crosswalk. If construction encroaches on a bike lane, warning signs will be posted that indicate bicycles and vehicles are sharing the roadway. Traffic controls may include flag persons wearing Occupational Safety and Health Administration–approved vests and using a “Stop/Slow” paddle to warn motorists of construction activity.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 14 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure Maintain access to Clovis Transit’s Stageline service and ensure that public transit vehicles are detoured. Post standard construction warning signs in advance of the construction area and at any intersection that provides access to the construction area. Construction warning signs will be posted, in accordance with local standards or those set forth in the Manual on Uniform Traffic Control Devices (Federal Highway Administration 2001) in advance of the construction area and at any intersection that provides access to the construction area. During lane closures, notify the Clovis Fire Department (CFD) and Clovis Police Department (CPD), as well as the Fresno County Sheriff’s and Fire Departments if the area is not annexed, of construction locations to ensure that alternative evacuation and emergency routes are designed to maintain response times during construction periods, if necessary. Provide written notification to appropriate contractors regarding appropriate routes to and from construction sites, and weight and speed limits for local roads used to access construction sites. Submit a copy of all such written notifications to the Clovis Planning Department. Repair or restore the road right-of-way to its original condition or better upon completion of the work.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 15 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

City of Clovis, Planning Division, Deputy City Planner

City of Clovis, Planning Division, Deputy City Planner

Environmental Measure 8: Measures to Protect Undiscovered Cultural and Paleontological Resources 8-1: Retain a Qualified Archaeologist and a Vertebrate Paleontologist to Train Construction Workers on Cultural and Paleontological Resource Issues Prior to Construction. The City will retain a qualified archaeologist and a qualified vertebrate paleontologist to train the construction workers who will be involved in construction of the ST/WRF and recycled water transmission mains. The paleontologist will meet the criteria of the Society of Vertebrate Paleontology (SVP) Conformable Impact Mitigation Guidelines (SVP Committee 1995). The archaeologist will meet the Secretary of Interior’s Professional Standards for archaeologists (48 Federal Register [FR] 22716). The 1- to 2-hour training session, which can be conducted as part of the City’s standard preconstruction conference, will be conducted to help construction workers to: 1) identify potential cultural resource artifacts, human remains, and fossils, and 2) review procedures in the event that a potential artifact, human remain, or fossil is found. Specifically, the training may include a discussion of the following.

Prior to construction

Monitoring Notes

Page 16 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

During construction

Construction contractor

City of Clovis Engineering Division, Special Projects Manager

fossil identification (the paleontologist may present example fossils to the workers); artifact types and their identification; regulations and laws prohibiting collection of artifacts or disturbance to cultural resources; the prohibition of collecting or intentionally disturbing fossils; stopping all excavation and grounddisturbing work within 100 feet of the find procedures for notifying supervisors and site monitoring staff; a discussion of the paleontologist’s and archaeologist’s authority to redirect or stop certain work operations; and an overview of the actions that the paleontologist may take to identify the sensitivity of a fossil and to recover and curate a fossil. 8-2: Stop Work in Case of Accidental Discovery at All Construction Sites. If buried cultural resources, such as chipped or ground stone, historic debris, building foundations, or human bone, are inadvertently discovered during ground-disturbing activities, work will stop in that area and within 100 feet of the find until a qualified archaeologist can assess the significance of the find and, if necessary, develop appropriate treatment measures in consultation with the City and other appropriate agencies. If a vertebrate fossil is discovered during construction, the contractor will stop work immediately in that area and within 100 feet of the find until a qualified professional vertebrate paleontologist can assess the nature and importance of the find and recommend a course of action in consultation with the City and other

Monitoring Notes

Page 17 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure appropriate agencies. If the fossil is determined to be of scientific importance, the course of action will involve preparation, recovery, and museum curation of the fossil. The course of action may also include preparation of a report for publication describing the find. The City will be responsible for ensuring that the recommendations of the paleontologist regarding treatment and reporting are implemented. If human remains of Native American origin are discovered during project construction, it will be necessary to comply with state laws relating to the disposition of Native American burials, which fall within the jurisdiction of the Native American Heritage Commission (NAHC) (PRC 5097). If any human remains are discovered or recognized in any location other than a dedicated cemetery, there will be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until: the Fresno County coroner has been informed and has determined that no investigation of the cause of death is required; and if the remains are of Native American origin, o the descendants of the deceased Native Americans have made a recommendation to the landowner or the person responsible for the excavation work for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in PRC 5097.98, or o the NAHC was unable to identify a descendant or the descendant failed to make a recommendation within 24 hours after being notified by the NAHC.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 18 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Implementation Responsibility

Monitoring Responsibility

Prior to construction

DBO Firm

City of Clovis Engineering Division, Special Projects Manager

Prior to construction

DBO Firm

City of Clovis Engineering Division, Special Projects Manager

Timing

According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100) and disturbance of Native American cemeteries is a felony (Section 7052). Section 7050.5 requires that construction or excavation be stopped in the vicinity of discovered human remains until the coroner can determine whether the remains are those of a Native American. If the remains are determined to be Native American, the coroner must contact the California NAHC. Mitigation Measures Mitigation Measure GEO-1(a): Conduct Geotechnical Investigations for the ST/WRF and Pump Stations and Implement Recommended Design Features and Engineering Practices The DBO Firm will hire a qualified geotechnical engineering firm to conduct geotechnical investigations for the ST/WRF and pump stations. The geotechnical investigation will include specific recommendations for design features and engineering practices in compliance with applicable provisions of the CBSC and other related building codes and regulations. The City will ensure these recommendations are included in the construction contractor specifications. Mitigation Measure AQ-5(a): Design the Wastewater Collection Pipeline System to Avoid Physical or Hydraulic Design Features That Would Impede the Flow of Air above the Wastewater inside the Pipeline The DBO Firm will require the contracted engineer to design the wastewater collection pipelines to provide for free, unrestricted downstream movement of sewer air.

Monitoring Notes

Page 19 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

DBO Firm

City of Clovis Engineering Division, Special Projects Manager

Additionally, Pump Station E (which is not part of the proposed project) will provide for the free unrestricted flow of sewer air from the sewer to the pump station and for deodorization and release to the atmosphere. Examples of design features to avoid include an inverted syphon and a situation where a half-empty pipe merges with a full pipe. Mitigation Measure N-2(a): Acoustically Design and Insulate Pump and Generator Enclosures The DBO Firm will require the contractor to ensure that all pumps and emergency backup generators are treated so that noise levels do not exceed the standards in the Noise Element of the Clovis General Plan (Table 3.7-2) at the property line of the nearest noise-sensitive land uses. Treatments to reduce noise may include constructing enclosures around pumps and generators, locating equipment away from noisesensitive uses, and employing exhaust-muffling devices. After equipment is operational, the contractor will be required to conduct noise measurements at the property line of the nearest noise sensitive land uses to demonstrate that treatments are effective in reducing noise to required levels. If noise exceeds specified levels, the contractor will be required to implement additional treatments until noise is reduced to the required level.

During construction/D uring operation

Monitoring Notes

Page 20 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Mitigation Measure BIO-1(a): Install Temporary Construction Barrier Fencing to Protect Sensitive Biological Resources Adjacent to the Construction Zone

Prior to and during construction

The construction specifications will require that a qualified biologist identify sensitive biological habitat onsite and identify areas to avoid during construction. Sensitive communities in the area that would generally be required for construction, including staging and access, will be fenced off to avoid disturbance in these areas. The City or its contractor will install orange construction barrier fencing to identify environmentally sensitive areas. Sensitive resources that occur in and adjacent to the construction area include the remnant valley oak woodland, emergent wetlands, potential seasonal wetlands, and trees that support nests of sensitive bird species. Before construction, the contractor will work with the project engineer and a resource specialist to identify the locations for the barrier fencing, and will place stakes around the sensitive resource sites to indicate these locations. The protected area will be designated an environmentally sensitive area and clearly identified on the construction specifications. The fencing will be installed before construction activities are initiated and will be maintained throughout the construction period. The following paragraph will be included in the construction specifications:

Implementation Responsibility

Monitoring Responsibility

Construction contractor under the direction of the City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Monitoring Notes

Page 21 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

Construction contractor under the direction of the City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

The Contractor’s attention is directed to the areas designated as “environmentally sensitive areas.” These areas are protected, and no entry by the Contractor for any purpose will be allowed unless specifically authorized in writing by the City of Clovis. The Contractor will take measures to ensure that Contractor’s forces do not enter or disturb these areas, including giving written notice to employees and subcontractors. Temporary fences around the environmentally sensitive areas will be installed as the first order of work. Temporary fences will be furnished, constructed, maintained, and removed as shown on the plans, as specified in the special provisions, and as directed by the project engineer. The fencing will be commercial-quality woven polypropylene, orange in color, and at least 4 feet high (Tensor Polygrid or equivalent). The fencing will be tightly strung on posts with a maximum 10-foot spacing. Mitigation Measure BIO-2(a): Avoid and Minimize Disturbance of Waters of the United States and Nonjurisdictional Wetlands Associated with the ST/WRF Site and the Recycled Water Transmission Main To the extent possible, the City will avoid and minimize impacts on waters of the United States and nonjurisdictional wetlands (e.g., the potentially nonjurisdictional emergent wetland on the ST/WRF site) by implementing the following measures. The specific location of the ST/WRF will avoid direct and indirect impacts on wetlands and drainages, if feasible.

During construction

Monitoring Notes

Page 22 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure Construction activities will be avoided in saturated or ponded wetlands and drainages during the wet season (spring and winter) to the maximum extent possible. Where such activities are unavoidable, protective practices, such as use of padding or vehicles with balloon tires, will be employed. Where determined necessary by resource specialists, geotextile cushions and other materials (e.g., timber pads, prefabricated equipment pads, or geotextile fabric) will be used in saturated conditions to minimize damage to the substrate and vegetation. During construction of the recycled water transmission main, exposed slopes and streambanks will be stabilized immediately upon completion of construction activities. Other waters of the United States will be restored in a manner that encourages vegetation to re-establish to its preproject condition and reduces the effects of erosion on the drainage system.During construction of the recycled water transmission main in highly erodible stream systems, banks will be stabilized using a nonvegetative material that binds the soil initially and breaks down within a few years. If the project engineers determine that more aggressive erosion control treatments are needed, geotextile mats, excelsior blankets, or other soil stabilization products will be used. During construction of the recycled water transmission main, trees, shrubs, debris, or soils that are inadvertently deposited below the OHWM of streams will be removed in a manner that minimizes disturbance of the drainage bed and bank.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 23 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Implementation Responsibility

Monitoring Responsibility

After construction

City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Prior to construction

City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Timing

In-stream construction within the OHWM of natural drainages crossed by a pipeline alignment will be restricted to the low-flow period of April through October. All activities will be completed promptly to minimize their duration and resultant impacts. These measures will be incorporated into contract specifications and implemented by the construction contractor. Mitigation Measure BIO-2(b): Implement Conditions of Federal and State Permits regarding Waters of the United States and Nonjurisdictional Wetlands If waters of the United States and nonjurisdictional wetlands that provide important habitat functions (e.g., ST/WRF site emergent wetlands) are filled as part of the proposed project, the City will compensate for permanent impacts to ensure no net loss of habitat functions and values. The compensation will be determined as part of the state and federal permitting process and may be a combination of onsite restoration/creation, offsite restoration, or mitigation credits. Compensation ratios will be based on site-specific information and determined through coordination with state and federal agencies, as part of the permitting process for the project. Mitigation Measure BIO-5(a): Document Special-Status Plant Populations That Could Occur along the Recycled Water Transmission Main North of Shepherd Avenue The City will retain a qualified botanist to document the presence or absence of special-status plants before project implementation.

Monitoring Notes

Page 24 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

The botanist will conduct a floristic survey that follows the CNPS Botanical Survey Guidelines (revised Nelson 1987 surveys; approved by the CNPS Board on June 2, 2001) in areas that are relatively undisturbed or have a moderate to high potential to support special-status plants. The guidelines require that all species be identified to the level necessary to determine whether they qualify as special-status plants, or are plant species with unusual or significant range extensions. The guidelines also require that field surveys be conducted when special-status plants that could occur in the area are evident and identifiable. To account for different special-status plant identification periods, one or more series of field surveys may be required in spring and summer. Special-status plant populations identified during the field surveys will be mapped and documented as part of the public record. The City will implement Mitigation Measure BIO-5(b) in conjunction with this measure to avoid or minimize significant impacts on special-status plants. Mitigation Measure BIO-5(b): Avoid or Minimize Impacts on Special-Status Plant Populations by Redesigning the Project, Protecting Special-Status Plant Populations, and Developing a Transplantation Plan (if Necessary) The City will implement the following measures to avoid or minimize impacts on special-status plants.

Prior to and during construction

Monitoring Notes

Page 25 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure The project will be redesigned or modified to avoid direct and indirect impacts on specialstatus plants. Special-status plants near the alignment will be protected by installing environmentally sensitive area fencing (orange construction barrier fencing) around special-status plant populations. The fencing will be installed at least 20 feet from the edge of the population. The location of the fencing will be marked in the field with stakes and flagging and shown on the construction drawings. The construction specifications will contain clear language that prohibits construction-related activities, vehicle operation, material and equipment storage, and other surfacedisturbing activities within the fenced area. Coordination will occur with the appropriate resource agencies and local experts to determine whether transplantation is feasible. If the agencies concur that transplantation is feasible, the botanist will develop and implement a transplantation plan through coordination with the appropriate agencies. The special-status plant transplantation plan will involve identifying a suitable transplant site, moving the plant material and seed bank to the transplant site, collecting seed material and propagating it in a nursery, and monitoring the transplant sites to document recruitment and survival rates.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 26 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Mitigation Measure BIO-6(a): Determine Whether California Tiger Salamanders Occur along the Recycled Water Transmission Main Alignment North of Shepherd Avenue

Prior to construction

The City shall retain a qualified biologist to prepare a site assessment and, if necessary, conduct surveys to document the presence or absence of California tiger salamanders before project implementation. The biologist shall implement USFWS’ Interim Guidance on Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander—October 2003 in all suitable aquatic habitat and areas of non-native annual grassland along the recycled water transmission main alignment north of Shepherd Avenue. Because California tiger salamanders use aquatic and upland habitats (up to 1.24 miles from aquatic habitat) during their life cycle, they may be present in either or both habitats on a given property. The biologist will first prepare and submit a site assessment to USFWS to determine whether field surveys are appropriate. If USFWS determines that there is potential for California tiger salamander to occur in aquatic and upland habitat along the recycled water transmission main alignment north of Shepherd Avenue, the City can either assume presence or require surveys to determine presence or absence. The biologist will then conduct surveys to determine presence or support a negative finding.

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Monitoring Notes

Page 27 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure As noted, another option is to forego surveys and assume presence. At sites that contain both upland and potential aquatic breeding habitat (i.e., pools that contain standing water continuously for at least 10 weeks, extending into April), aquatic sampling during two breeding seasons and a drift fence study in the intervening winter will be conducted to support a negative finding. Aquatic sampling surveys are conducted in potential breeding pools and repeated three times each season. Surveys will be conducted once each in March, April, and May. Drift fence surveys are conducted in fall and winter, must be in place by October 15 and until March 15, or until 20 nights of surveying under proper conditions have been completed. Any California tiger salamanders identified during the field surveys will be mapped and documented as part of the public record. The City will implement Mitigation Measure BIO-6(b) in conjunction with this measure to avoid or minimize significant impacts on California tiger salamanders.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 28 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Mitigation Measure BIO-6(b): Avoid or Minimize Impacts on California Tiger Salamander Populations by Protecting Salamander Populations during Construction (if Necessary)

During construction

The City will implement the following measures pursuant to USFWS’ Interim Guidance on Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander—October 2003 to avoid or minimize impacts on California tiger salamanders. Temporary construction disturbances to California tiger salamander habitat will be minimized to the extent practicable. All project-related vehicle traffic will be restricted to established roads, construction areas, and other sensitive biological areas that will be identified during implementation of Mitigation Measure BIO-1(a), “Install Temporary Construction Barrier Fencing to Protect Sensitive Biological Resources Adjacent to the Construction Zone.” A qualified biologist (one that USFWS has agreed is qualified to monitor and move salamanders if necessary) will be on site during all activities that may result in the take of California tiger salamander. The biologist will be given the authority to stop any work that may result in take of this listed species. The biologist will be responsible for ensuring that the exclusion fence installed around the sensitive biological areas that will be identified during implementation of Mitigation Measure BIO-1(a) is inspected before the start of each day and remains intact until project construction is complete.

Implementation Responsibility

Monitoring Responsibility

Construction contractor under the direction of the City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Monitoring Notes

Page 29 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure Plastic mono-filament netting (erosion control matting) or similar material will not be used for erosion control or other purposes in the construction area because California tiger salamander may become entangled or trapped in it. Acceptable substitutes include coconut coir matting or tackified hydroseeding. The City will implement BMPs to prevent sediment from entering suitable California tiger salamander habitat near the pipeline alignment, through the use of measures including silt fencing, sterile hay bales, no cleaning of equipment in drainages or other wetlands, and temporary sediment disposal. A worker training program will be conducted that includes the California tiger salamander for construction personnel before groundbreaking at the project. A 20-mile-per-hour speed limit will be observed within construction areas, particularly on rainy nights when California tiger salamanders are most likely to be moving between their breeding ponds and upland habitat. To the extent possible, nighttime construction will be minimized. Offroad traffic outside designated construction areas will be prohibited.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 30 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure To prevent entrapment of California tiger salamanders during construction, any trenches, holes, or other excavations into which California tiger salamander could fall and become trapped will be covered. The opening will be completely covered at the end of each work day with plywood or other appropriate materials in a manner that prevents the animals from falling into them. Before the trench is filled, it must be thoroughly inspected for trapped animals. If a trapped California tiger salamander is discovered, the onsite biologist will take a photograph, remove it by hand, and place it at the entrance of a suitable rodent burrow within walking distance of the excavation site, but outside the area where the animal could be killed or injured. USFWS will be notified by email within 1 working day. If construction occurs during the onset of fall and winter rains, the onsite biologist will examine the work site for California tiger salamander each morning after any measurable precipitation has occurred. The biologist will search in pipes and beneath vehicles. If a California tiger salamander is found, the biologist will implement the same methods described under the previous paragraph. Runoff from dust control, oil, or other chemicals used in construction activities will be retained on the construction site and prevented from entering any aquatic habitat.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 31 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Planning Division, Deputy City Planner

Upon completion of the project, all California tiger salamander habitat subject to temporary ground disturbances will be recontoured if appropriate in the opinion of the onsite biologist, and revegetated to promote restoration of the area to natural conditions within 2 working days of completion of the project. Appropriate methods and locally collected seeds from native plant species will be used to revegetate these areas. Mitigation Measure BIO-7(a): Conduct Preconstruction Surveys for San Joaquin Kit Fox Dens and, if Necessary, Avoid Disturbance to Dens during Construction Within 30 days before construction begins, qualified wildlife biologists (as defined by USFWS [1999]) will conduct systematic searches for kit fox dens in all suitable habitat (annual grassland) in the construction area and in a 200foot-wide buffer around this area. The biologists will conduct these searches by systematically walking 30- to 100-foot-wide transects throughout the survey area; transect width will be adjusted based on vegetation height and topography (California Department of Fish and Game 1990). When a den is found, the biologists will measure the size; evaluate the shape of the den entrances; and note tracks, scat, prey remains, or recent excavations at the site. Dens will be classified in one of four den-status categories, consistent with those defined by USFWS (1999): Potential Den: Any burrow that has an entrance typically 5–8 inches in diameter for its entire visible length; a collapsed den will not be considered a potential den site.

Prior to construction

Monitoring Notes

Page 32 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure Known Den: Any natural den or artificial structure that is being used or has been used at any time in the past by a San Joaquin kit fox for any activity other than to whelp or rear pups. Fresh excavation alone will not be considered an adequate sign to classify a den as known. Natal or Pupping Den: Any den or artificial structure that is being used or has been used at any time in the past by a kit fox to whelp or rear pups. Atypical Den: Any man-made structure that could become occupied by a San Joaquin kit fox, including pipes, culverts, and diggings beneath slabs and buildings. All dens will be assigned a number and mapped on topographic maps. Den sites will be flagged in the field with pin flags marked with the den number. Potential, known, and natal or pupping dens will be distinguished from each other in the field by the pin flag color. Information on the size and number of openings, signs of activity, surrounding terrain and habitat type, and distance to concentrations of small mammal prey and other den sites will be recorded. Disturbance and destruction of potential or atypical dens will be avoided where possible. However, if potential or atypical dens are located within the proposed work area and cannot be avoided during construction, qualified biologists will remove them by carefully hand-excavating them following the procedures described by USFWS (1999).

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 33 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure The City will provide USFWS with verbal notification of the results of preconstruction den searches and den excavations within 5 days after these activities are completed and before construction begins in the area. The City will notify USFWS immediately if a natal or pupping den is found in the survey area, and the City will provide USFWS with written notification of the results within 30 days after these activities are completed. After preconstruction den searches and den excavations and before construction, biologists will establish exclusion zones around the remaining dens following the procedures described by USFWS (1999). Exclusion zones will be marked in the field with stakes and flagging. The radius of these zones for each type of den will be as follows: Potential and Atypical Den: 50 feet. Known Den: 100 feet. Natal or Pupping Den: Determined in coordination with USFWS. Construction-related activities will be prohibited or greatly restricted within these zones. Essential vehicle operation on existing roads and foot travel will be permitted. All other construction activities, vehicle operation, material and equipment storage, and other surface-disturbing activities will be prohibited within the exclusion zones. The City will remove all stakes and flagging demarcating exclusion zones within 30 days after construction and site restoration have been completed in the area.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 34 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Mitigation Measure BIO-8(a): Avoid Impacts on Nesting Swallows during Construction

During construction

To avoid impacts on nesting swallows, the City will avoid construction activities at the bridge containing swallow nests during the nesting season (March 1–August 31) or until the young have fledged. Outfall construction will occur during the cliff and barn swallows’ nonbreeding season (September–February). The nests will be inspected by a qualified biologist to ensure that no birds are using them. Inspection of the nests between July and September may also reveal that the young have fledged. If all nests are abandoned, they will be removed. If construction activities must occur during the nesting period, the City will implement the following measures. If bridge construction will occur during the cliff and barn swallows’ breeding season (March–August), the nests will be removed before March 1. After nest removals, the underside of the bridge will be covered with 0.5- to 0.75-inch mesh net or poultry wire. All net installation will occur before March 1. The netting will be anchored so that swallows cannot attach their nests to the bridge through gaps in the net. If steps are taken to prevent swallows from constructing new nests, then work may proceed at any time of the year. To avoid damaging active nests, the nests will be removed before egg laying occurs. A permit from DFG and USFWS is required if active nests are to be removed.

Implementation Responsibility

Monitoring Responsibility

Construction contractor under the direction of the City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Monitoring Notes

Page 35 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Planning Division, Deputy City Planner

If netting of the bridge does not occur by March 1, and cliff and barn swallows colonize the bridge, modifications to the bridge will not begin before September 1 or until it is determined that all of the young have fledged. Mitigation Measure BIO-9(a): Conduct Preconstruction Surveys for Active Burrowing Owl Burrows and Implement the California Department of Fish and Game Guidelines for Burrowing Owl Mitigation, if Necessary DFG (1994) recommends that preconstruction surveys be conducted at all construction sites (except paved areas) in the project study area and in a 250-foot-wide buffer zone around the construction site to locate active burrowing owl burrows. The City will retain a qualified biologist to conduct preconstruction surveys for active burrows according to the DFG guidelines. The surveys will include a nesting season survey and a wintering season survey, which is the season immediately preceding construction. If no burrowing owls are detected, then no further mitigation is required. If active burrowing owls are detected the following measures will be implemented by the City. Occupied burrows will not be disturbed during the nesting season (February 1– August 31).

Prior to construction

Monitoring Notes

Page 36 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure When destruction of occupied burrows is unavoidable outside the nesting season (September 1–January 31), unsuitable burrows will be enhanced (enlarged or cleared of debris) or new burrows created (installing artificial burrows) at a ratio of 2:1 on protected lands approved by DFG. Newly created burrows will follow guidelines established by DFG. If owls must be moved away from the project construction area, passive relocation techniques (e.g., installing one-way doors at burrow entrances) will be used instead of trapping. At least 1 week will be necessary to accomplish passive relocation and allow owls to acclimate to alternate burrows. If active burrowing owl burrows are found and the owls must be relocated, the City will offset the loss of foraging and burrow habitat in the project construction area by acquiring and permanently protecting a minimum of 6.5 acres of foraging habitat per occupied burrow identified in the project construction area. The protected lands should be located adjacent to the occupied burrowing owl habitat in the project construction area or at another occupied site near the project construction area. The location of the protected lands will be determined in coordination with DFG. The City will also prepare a monitoring plan, and provide longterm management and monitoring of the protected lands. The monitoring plan will specify success criteria, identify remedial measures, and require an annual report to be submitted to DFG.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 37 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Planning Division, Deputy City Planner

If avoidance is the preferred method of dealing with potential impacts, no disturbance will occur within 160 feet of occupied burrows during the nonbreeding season (September 1–January 31) or within 250 feet during the breeding season. Avoidance also requires that at least 6.5 acres of foraging habitat (calculated based on an approximately 300-foot foraging radius around an occupied burrow), contiguous with occupied burrow sites, be permanently preserved for each pair of breeding burrowing owls or single unpaired resident bird. The configuration of the protected site will be submitted to DFG for approval. Mitigation Measure BIO-10(a): Conduct a Survey for Roosting Bats in Existing Structures at the ST/WRF Site before Building Disturbance or Removal To avoid impacts on roosting bats, a qualified bat biologist will conduct a survey of the existing structures at the ST/WRF, as well as any structures scheduled to be removed, in accordance with recommendations by DFG, before building removal. If roosting bats are found, DFG will be consulted, and an avoidance or mitigation plan will be developed and implemented by the City. Avoidance and mitigation measures could include construction, modification, relocation, or removal outside hibernation and maternal roosting time periods (winter and summer); exclusion of bats from the buildings after they have left the roost to forage at night by closing entrances; and construction of bat boxes to accommodate displaced bats.

Prior to construction

Monitoring Notes

Page 38 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Mitigation Measure BIO-11(a): Avoid Disturbance of Tree-, Shrub-, or GroundNesting White-Tailed Kite, Northern Harrier, Loggerhead Shrike, and Non-Special-Status Migratory Birds and Raptors

During construction

The City will implement one of the following measures, depending on the specific construction timeframe, to avoid disturbance of tree-, shrub- or ground-nesting white-tailed kites, northern harriers, loggerhead shrikes, and non-special-status migratory birds and raptors. If construction activities are scheduled to occur during the breeding season for these species (generally between March 1 and August 15), a qualified wildlife biologist will be retained to conduct the following focused nesting surveys within the appropriate habitat. o Tree- and shrub-nesting surveys will be conducted in riparian and oak woodland habitats within or adjacent to the construction area to look for white-tailed kite, loggerhead shrike, and other nonspecial-status migratory birds and raptors. o Ground-nesting surveys will be conducted in annual grasslands and agricultural lands within and adjacent to the construction area to look for northern harrier and other non-special-status migratory birds. o The surveys should be conducted within 1 week before initiation of construction activities and at any time between March 1 and August 15. If no active nests are detected, then no additional mitigation is required.

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

Monitoring Notes

Page 39 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure If surveys indicate that migratory bird or raptor nests are found in any areas that would be directly affected by construction activities, a no-disturbance buffer will be established around the site to avoid disturbance or destruction of the nest site until after the breeding season or after a wildlife biologist determines that the young have fledged (usually late June to mid-July). The extent of these buffers will be determined by a wildlife biologist, and will depend on the level of noise or construction disturbance, line of sight between the nest and the disturbance, ambient levels of noise and other disturbances, and other topographical or artificial barriers. These factors should be analyzed to make an appropriate decision on buffer distances. If construction activities begin before the breeding season (i.e., begin between August 16 and February 28) (pre-existing construction), then construction can proceed until it is determined that an active migratory bird or raptor nest would be subject to abandonment as a result of construction activities. (Pre-existing construction activities are assumed to be “full force,” including site grading and infrastructure development; activities that technically initiate construction but are minor would not be considered full force.) Optimally, all necessary vegetation removal should be conducted before the breeding season (generally between March 1 and August 15) so that nesting birds or raptors would not occur in the construction area during construction activities.

Timing

Implementation Responsibility

Monitoring Responsibility

Monitoring Notes

Page 40 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

City of Clovis Planning Division, Deputy City Planner

City of Clovis Engineering Division, Special Projects Manager

If any birds or raptors nest in the project vicinity under pre-existing construction conditions, then it is assumed that they are habituated (or will habituate) to the construction activities. Under this scenario, the preconstruction survey described previously should still be conducted on or after March 1 to identify any active nests in the vicinity. and active sites should be monitored by a wildlife biologist periodically until after the breeding season or after the young have fledged (usually late June to midJuly). If active nests are identified on or immediately adjacent to the project site, then all nonessential construction activities (e.g., equipment storage and meetings) should be avoided in the immediate vicinity of the nest site, but the remainder of construction activities may proceed. Mitigation Measure CR-1(a): Conduct Pedestrian Surveys for Cultural Resources (Archaeological and Historical) along the Smaller Recycled Water Distribution Pipeline Alignments before Construction Archaeological and built environment inventories will be conducted along the smaller recycled water distribution pipeline alignments before any project construction. The 2004 record search will be available and applicable unless the alignments have been altered. Archaeological inventories will examine an area no less than 15 meters on either side of the centerlines of existing roadways to locate surface manifestations of subsurface archaeological materials that may extend beneath existing roads.

Prior to construction

Monitoring Notes

Page 41 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

DBO Firm

City of Clovis Planning Division, Deputy City Planner

All resources located as a result of this study will be recorded on applicable California Department of Parks and Recreation (DPR) 523 forms, photographed, and plotted on a USGS 7.5-minute topographic map using data collected with a GPS receiver. Site records will be produced and forwarded to the Southern San Joaquin Valley Information Center at CSU Bakersfield. Impacts on resources located as a result of this inventory will be analyzed and mitigated if they cannot be avoided. Mitigation measures may include archaeological excavation or monitoring. Mitigation Measure VIS-5(a): To the Extent Practicable, Design the Sewage Treatment/Water Reuse Facility to Blend with the Surrounding Environment to the Satisfaction of the Clovis City Planner Although very few structures exist in the project vicinity on which to model the ST/WRF, the DBO Firm will design the facility components in a way that is compatible with the surrounding area. In addition to Good Neighbor Policy aesthetics recommendations and design guidelines of the Southeast Urban Center Specific Plan, building materials, detailing, and colors will be selected for their ability to blend in with and complement the surrounding environment to the extent practicable, as described below. Building finishes will be muted and earth toned, although contrasting trim and accents are encouraged. Building walls will be designed and surfaced to blend with their surroundings and to minimize the visual prominence of large masses. The use of durable weathering surfaces will be considered.

Prior to construction

Monitoring Notes

Page 42 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

DBO Firm

City of Clovis Planning Division, Deputy City Planner

Unarticulated and undifferentiated vertical surfaces will be minimized to be consistent with the relative horizontality of the visual landscape (as evidenced by the agricultural fields and vegetation patterns). Any fencing surrounding the facility will be designed to be minimally intrusive and complementary of the architectural character of the facilities (e.g., black chain-link fencing). Mitigation Measure VIS-6(a): Incorporate Additional Light-Reduction Measures into the Plan and Design of Exterior Lighting where Necessary Where lighting is required or proposed, the DBO Firm will incorporate the following light-reduction measures into the lighting design specifications to reduce light and glare. The lighting design will also meet minimum safety and security standards. Luminaires will be cutoff-type fixtures that cast low-angle illumination to minimize incidental spillover of light onto adjacent properties and open space. Fixtures that project light upward or horizontally will not be used. Luminaires will be focused only where needed (e.g., building entrances) and should not provide a general “wash” of light on building surfaces. Luminaires will be directed away from properties adjacent to the project site. Luminaires will provide good color rendering and natural light qualities. Low-pressure sodium and high-pressure sodium fixtures that are not color corrected shall not be used.

Prior to construction

Monitoring Notes

Page 43 of 44

Mitigation Monitoring Program, City of Clovis Sewage Treatment/Water Reuse Facility Program (continued)

Mitigation Measure

Timing

Implementation Responsibility

Monitoring Responsibility

DBO Firm

City of Clovis Planning Division, Deputy City Planner

Page 44 of 44

Monitoring Notes

Luminaire mountings will be downcast and the height of poles minimized to reduce potential for backscatter into the nighttime sky and incidental spillover of light onto adjacent properties and open space. Light poles will be no higher than 20 feet. Luminaire mountings will have nonglare finishes. Mitigation Measure VIS-7(a): To the Extent Practicable, Design the Pump Stations to Blend with the Surrounding Environment The DBO Firm will design the pump stations in a way that is compatible with the surrounding area. In addition to Good Neighbor Policy aesthetic recommendations, building materials, detailing, and colors, and landscaping will be selected for their ability to blend in with and complement the surrounding environment to the extent practicable, as described below.

Prior to construction

Building finishes will be muted and earth toned, although contrasting trim and accents are encouraged. The use of durable weathering surfaces will be considered. Vegetative buffers will be provided to screen views of the pump stations. Any fencing surrounding the pump stations will be designed to be minimally intrusive (e.g., black chain-link fencing). Notes: “Environmental Measures” are standard practices, established standards, or other measures that have been included as part of the proposed project. “Mitigation Measures” are additional mitigation measures that were identified in the EIR analysis. DBO Firm is the Design-Build-Operate firm that will be selected by the City to implement the proposed project.

Appendix G

Background Information for Air Quality

1.

San Joaquin Valley Air Pollution Control District Regulation VIII – Fugitive PM10 Prohibitions—Dust Control Plan

San Joaquin Valley Air Pollution Control District San Joaquin Valley Air Pollution Control District Regulation VIII – Fugitive PM10 Prohibitions Dust Control Plan Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities requires the owner or operator of a construction project to submit a Dust Control Plan to the District if at anytime the project involves: • • •

Residential developments of ten (10) or more acres of disturbed surface area, Non-residential developments of five (5) or more acres of disturbed surface area, or Relocation of more than 2,500 cubic yards per day of materials on at least three (3) days of the project.

A Dust Control Plan identifies the fugitive dust sources at the construction site and describes all of the fugitive dust control measures that will be implemented before, during, and after any dust generating activity for the duration of the project. One Dust Control Plan may cover a single project or multiple projects at different sites where construction will commence within the following 12 months. The District will review and approve, conditionally approve, or disapprove the Dust Control Plan within 30 days of submittal. Construction activities shall not commence until the Dust Control Plan has been approved or conditionally approved. An owner or operator must also provide written notification to the District via fax or mail within 10 days prior to the commencement of earthmoving activities. A copy of the approved Dust Control Plan must be retained at the project site and made available upon request by a District inspector. At least one key individual representing the owner or operator, or any person who prepares a Dust Control Plan must complete a Dust Control Training Course presented by the District. Please contact the District to find out when courses are being offered. Regardless of whether a District-approved Dust Control Plan is in place or not, the owner or operator is required to comply with all requirements of the applicable rules under Regulation VIII and the District’s Rules and Regulations at all times. Submit the Dust Control Plan to the District’s Compliance Division at the office listed below: For San Joaquin, Stanislaus, and Merced Counties:

Northern Region Office 4230 Kiernan Avenue, Suite 130 Modesto, CA 95356 (209) 557-6400 FAX (209) 557-6475

For Madera, Fresno, and Kings Counties:

Central Region Office 1990 East Gettysburg Avenue Fresno, CA 93726 (559) 230-5950 FAX (559) 230-6062

For Tulare County and the valley portion of Kern County

Southern Region Office 2700 “M” Street, Suite 275 Bakersfield, CA 93301 (661) 326-6900 FAX (661) 326-6985

www.valleyair.org

10/14/2004

Dust Control Plan Section 1 – General Information – Page 1 1-A Project Name and Location Project Name: Project Address: Major X-Streets: City:

County:

Section(s):

Township:

Expected Construction Start Date:

Range: End Date:

1-B Contacts Report the names, addresses, and phone numbers of persons and owners or operators responsible for the preparation, submittal, and implementation of the Dust Control Plan and responsible for the dust generating operation and dust control applications. (Rule 8021 Sec. 6.3.6.1) Property Owner: Address: City / State / Zip: Phone:

Fax:

Developer: Address: City / State / Zip: Contact Person: Phone:

Fax:

General Contractor: Address: City / State / Zip: Contact Person: Phone:

Fax:

This Dust Control Plan was prepared by: Name: Title: Company Name: Address: City / State / Zip: Phone: Date training completed:

Fax: Training Location:

10/14/2004

Section 1 – General Information – Page 2 Project Name:

1-C Contractors Provide the names, addresses, and phone numbers of the contractors involved in dust generating activities or performing dust control as part of this project. (Rule 8021 Sec. 6.3.6.1) 1. 2. 3. 4. 5.

will have the primary responsibility for implementing this Dust Control Plan? 1-D Who (Rule 8021 Sec 6.3.6.1) Property Owner

Developer

Sub-Contractor(s)

Other:

General / Prime Contractor

Primary Project Contact: Title: Company Name: Address: City / State / Zip: On-Site Phone:

Fax:

Mobile Phone:

Pager:

1-E Provide a brief description of the Project’s Operations.

10/14/2004

Dust Control Plan Section 2 – Plot Plan – Page 1 Project Name:

2-A Plot Plan A plot plan identifies the type and location of each project. Attach appropriately sized maps with the project boundaries outlined or use the space in sections 2-B or 2-C to draw a plot plan. Attached maps may include tract maps, site maps, and topographic maps. Use the checklist below to make sure all areas have been identified on the plot plan. (Rule 8021 Sec. 6.3.6.2 & 6.3.6.5) Identify the relative locations of actual and potential sources of fugitive dust emissions. Bulk material handling and storage areas. Paved and unpaved access roads, haul roads, traffic areas, and equipment storage yards. Exit points where carryout and trackout onto paved public roads may occur. Water supply locations if water application will be used for controlling visible dust emissions.

Identify the relative locations of sensitive receptors within ¼ mile of the project. (Rule 4102 Sec. 4.1) No sensitive receptors within ¼ mile of the project. Residential areas, schools, day care, churches, hospitals, nursing facilities, commercial, retail, etc. Freeways, roads, or traffic areas that may be affected by the dust generating activities. Other:

2-B Draw Plot Plan (if one is not attached)

May use the back of this form Include a North Arrow

Plot plan is attached (Skip to 3-A).

10/14/2004

Section 2 – Plot Plan – Page 2 Project Name:

2-C Draw Plot Plan (if one is not attached)

Include a North Arrow

10/14/2004

Dust Control Plan Section 3 – Fugitive PM10 Sources – Page 1 Project Name:

3-A Disturbed Surface Area Report the total area of land surface to be disturbed, the daily throughput volume of earthmoving in cubic yards, and the total area in acres of the entire project site. (Rule 8021 Sec. 6.3.6.3) Total area of land surface to be disturbed:

Acres

Daily maximum throughput volume of earthmoving:

Cubic Yards

Daily average throughput volume of earthmoving:

Cubic Yards

Total area of entire project site:

Acres

Total disturbed areas that will be left inactive for more than seven days:

Acres

3-B Dust Generating Activity Dates The expected start and completion dates of dust generating activities and soil disturbance activities to be performed on site. For phased projects, it may be necessary to report expected start and completion dates separately. (Rule 8021 Sec. 6.3.6.4) Expected start date:

Completion Date:

Phase Project Start – A:

Completion – A:

Phase Project Start – B:

Completion – B:

Phase Project Start – C:

Completion – C:

3-C Other Locations Identify whether any other locations should be included with this plan that are involved with this project. An example may include listing any site where materials will be imported from or exported to. (Rule 8021 Sec. 6.3.2) No other locations are included with this project. (Skip to 3-D) Location 1: No Dust Control Plan Required

Included with this plan

Included with another plan

Included with this plan

Included with another plan

Included with this plan

Included with another plan

Location 2: No Dust Control Plan Required Location 3: No Dust Control Plan Required

10/14/2004

Section 3 – Fugitive PM10 Sources – Page 2 Project Name:

3-D Sources of Fugitive Dust This section describes the minimum requirements for limiting visible dust emissions from activities that cause fugitive dust emissions. (Rule 8021 Sec. 6.3.6.5) Check at least one box under each category.

Structural Demolition. (Rule 8021 Sec. 5.1, 6.3.3, & 6.3.6.5) No demolitions are planned for this project. Asbestos NESHAP notification and fees have been submitted to the District. (Rule 3050 and Rule 4002). Water will be applied to the following areas for the duration of the demolition activities: Building exterior surfaces; Unpaved surface areas where equipment will operate; Razed building materials; and Water or dust suppressants will be applied to unpaved surface areas within 100 feet of structure during demolition.

Pre-Activity. (Rule 8021 Sec. 5.2) Not applicable for this project (Please explain why in Section 3-F). The site will be pre-watered and work will be phased to reduce the amount of disturbed surface area at any one time (Complete Section 4-A).

Active Operations. (Rule 8021 Sec. 5.2) Water will be applied to dry areas during leveling, grading, trenching, and earthmoving activities (Complete Section 4-A). Wind barriers will be constructed and maintained, and water or dust suppressants will be applied to the disturbed surface areas (Complete Sections 4-A or 4-B, and 4-C).

Inactive Operations, including after work hours, weekends, and holidays. (Rule 8021 Sec. 5.2) Not applicable for this project (Please explain why in Section 3-F). Water or dust suppressants will be applied on disturbed surface areas to form a visible crust, and vehicle access will be restricted to maintain the visible crust. (Complete Section 4-A or 4-B, and 4-C)

Temporary stabilization of areas that remain unused for seven or more days. (Rule 8021 Sec. 5.2) Not applicable for this project (Please explain why in Section 3-F) Vehicular access will be restricted and water or dust suppressants will be applied and maintained at all unvegetated areas (Complete Section 4-A or 4-B, and 4-C). Vegetation will be established on all previously disturbed areas (Complete Section 4-C). Gravel will be applied and maintained at all previously disturbed areas (Complete Section 4-C). Previously disturbed areas will be paved (Complete Section 4-C).

Unpaved Access and Haul Roads, Traffic and Equipment Storage Areas. (Rule 8021 Sec. 5.2 and 5.3) Not applicable for this project (Please explain why in Section 3-F) Apply water or dust suppressants to unpaved haul and access roads (Complete Section 4-A or 4-B) Post speed limit signs of not more than 15 miles per hour at each entrance, and again every 500 feet. (Complete Section 4-C) Water or dust suppressants will be applied to vehicle traffic and equipment storage areas (Complete Section 4-A or 4-B).

Wind Events. (Rule 8021 Sec. 5.4) Water application equipment will apply water to control fugitive dust during wind events, unless unsafe to do so. Outdoor construction activities that disturb the soil will cease whenever visible dust emissions cannot be effectively controlled.

10/14/2004

Section 3 – Fugitive PM10 Sources – Page 3 3-E Bulk Materials (Rule 8021 Sec. 6.3.6.6 and Rule 8031) Outdoor Handling of Bulk Materials. (Rule 8031 Sec. 5.0 A) No bulk materials will be handled during this project. Water or dust suppressants will be applied when handling bulk materials. Wind barriers with less than 50 percent porosity will be installed and maintained, and water or dust suppressants will be applied.

Outdoor Storage of Bulk Materials. (Rule 8031 Sec. 5.0 B) No bulk materials will be stored during this project. Water or dust suppressants will be applied to storage piles. Storage piles will be covered with tarps, plastic, or other suitable material and anchored in such a manner that prevents the cover from being removed by wind action. Wind barriers with less than 50 percent porosity will be installed and maintained around the storage piles, and water or dust suppressants will be applied. A three-sided structure (< 50% porosity) will be used that is at least as high as the storage piles.

On-Site Transporting of Bulk Materials. (Rule 8031 Sec. 5.0 C) No bulk materials will be transported on the project site. Vehicle speed will be limited on the work site. All haul trucks will be loaded such that the freeboard is not less than six inches when transported across any paved public access road. A sufficient amount of water will be applied to the top of the load to limit visible dust emissions. Haul trucks will be covered with a tarp or other suitable cover.

Off-Site Transporting of Bulk Materials. (Rule 8031 Sec. 5.0 D) No bulk materials will be transported to or from the project site. The following practices will be performed: (complete Section 5-B) The interior of emptied truck cargo compartments will be cleaned or covered before leaving the site. Spillage or loss of bulk materials from holes or other openings in the cargo compartment’s floor, sides, and tailgates will be prevented. Haul trucks will be covered with a tarp or other suitable cover or will be loaded such that the freeboard is not less than six inches when transported on any paved public access road to or from the project site and a sufficient amount of water will be applied to the top of the load to limit visible dust emissions.

Outdoor Transport using a Chute or Conveyor. (Rule 8031 Sec. 5.0 E) No chutes or conveyors will be used. Chute or conveyor will be fully enclosed. Water spray equipment will be used to sufficiently wet the materials. Transported materials will be washed or screened to remove fines (PM10 or smaller).

3-F

Comments

10/14/2004

Dust Control Plan Section 4 – Dust Control Methods – Page 1 Project Name:

4-A Water Application Complete this section if water application will be used as a control method for limiting visible dust emissions and stabilizing surface areas. Check and answer everything that applies to this project. (Rule 8021 Sec. 6.3.6.6)

Water Application Equipment: Sprinklers:

Describe the activities that will utilize sprinklers:

Minimum treated area:

Square Feet

Acres

Maximum treated area:

Square Feet

Acres

Minimum water flow rate: Water Truck,

Water Trailer,

Duration: Water Wagon,

Other:

Describe the activities that will utilize this equipment:

Number of application equipment available: Application equipment capacity: Application frequency: Application rate:

Gallons per acre per application

Hours of operation: Water application equipment is available to operate after normal working hours, on weekends, and holidays. After-hours contact:

Phone No.:

After-hours contact:

Phone No.:

Water Supply: Include the relative locations of these sources on the plot plan in Section 2. Fire hydrants Number of hydrants available On-Site: Off-Site: Approval granted by the owner or public agency to use their fire hydrants for this project. Owner or Agency: Contact: Storage tanks

Number and capacity:

Wells

Number and flow rate:

Phone No.:

Canal, River, Pond, Lake, etc. Describe: Approval granted by the owner or public agency to use their water source for this project. Owner or Agency: Contact:

Phone No.:

Other:

10/14/2004

Section 4 – Dust Control Methods – Page 2 Project Name:

4-B Dust Suppressant Products Complete this section if a dust suppressant product will be used. These materials include, but are not limited to: hygroscopic suppressants (road salts), adhesives, petroleum emulsions, polymer emulsions, and bituminous materials (road oils). (Rule 8021 Sec. 6.3.6.6) Copy this page if more than one dust suppressant product will be used.

Not Applicable. Only water application will be the control method used. Skip to 4-C. Application Area: Product Name: Contractor’s Name: Application Rate: Application Frequency:

Phone No: Gallons of undiluted material per Applications per

week,

mile or

month,

acre treated.

year

Application Equipment: Number of Application Equipment Available: Application Equipment Capacity: Attach each of the following information that fully describes this product. Use the checklist below to make sure all information is submitted with this plan. Product Specifications (MSDS, Product Safety Data Sheet, etc.) Manufacturer’s Usage Instructions (method, frequency, and intensity of application) Environmental impacts and approvals or certifications related to the appropriate and safe use for ground application.

10/14/2004

Section 4 – Dust Control Methods – Page 3 Project Name:

4-C Other Dust Control Methods Check below the other types of dust control methods that will be employed at the construction site. (Rule 8021 Sec. 5.2)

Physical barriers for restricting unauthorized vehicle access: Fences Gates Posts Berms

Concrete Barriers

Other: Wind barriers Describe: Posted speed limit signs meet State and Federal Department of Transportation standards. (Rule 8021 Sec. 5.3) Posted at 15 miles per hour, Posted at miles per hour (less than 15 MPH) Re-establish vegetation for temporarily stabilizing previously disturbed surfaces. Explain: Apply and maintain gravel: On haul roads On access roads At equipment storage yards At vehicle traffic areas For temporarily stabilizing previously disturbed areas. Explain: Apply pavement: Explain: Other:

4-D Contingencies Contingencies to be implemented if application equipment becomes inoperable, more equipment is needed to effectively control fugitive dust emissions during active and inactive periods, accessibility limitations occur at the water sources, or staff is not available to operate the application equipment. Describe the contingencies that will be in place and when they will be implemented. Attach any additional information if needed. (Rule 4102 and Rule 8021 Sec. 6.3.6.6)

4-E Record keeping (Rule 8011 Sec. 6.2) Records and any other supporting documents for demonstrating compliance must be maintained, but only for those days when a control measure is implemented. The District has developed record keeping forms that may be used for complying with this requirement. Check one or both below: Records will be maintained using the forms developed by the District. Records will be maintained using documents or forms developed by the owner or operator. Explain and include copies:

10/14/2004

Dust Control Plan Section 5 – Carryout and Trackout – Page 1 Project Name:

5-A Treatments for Preventing Trackout Select the control devices that will be used for preventing trackout from occurring onto paved public roads. Trackout is any material that adheres to vehicle tires and is deposited onto a paved public road or the paved shoulder of a paved public road. Check one or a combination that will apply to this project. Grizzly: Rails, pipes, or grates used to dislodge debris off of vehicles before exiting the site. Extends from the intersection with the paved public road surface for the full width of the unpaved exit surface for a distance of at least 25 feet. (Rule 8041 Sec. 5.9.1) Describe:

Gravel Pad: A layer of washed gravel at least one (1) inch or larger in diameter, three (3) inches deep, and extends from the intersection with the public paved road surface for the full width of the unpaved exit surface for a distance of at least 50 feet. (Rule 8041 Sec. 5.9.2) Gravel Size: Pad Width:

Inches Feet

Length:

Feet

Depth:

Inches

Paved Surface: Extends from the intersection with the paved public road surface for the full width of the unpaved access road for at least 100 feet to allow mud and dirt to drop off of vehicles before exiting the site. (Rule 8041 Sec. 5.9.3)

Width: Feet Length: Feet Mud and dirt deposits accumulating on paved interior roads will be removed with sufficient frequency, but not less frequently than once per workday. Cleanup will commence within ½ hour of generating any carryout and trackout. (Rule 8041 Sec. 5.8.2 and 5.9.3) Clean-up Frequency:

Wheel Washer: Uses water to dislodge debris from tires and vehicle undercarriage. (Rule 8011 Sec. 3.73) Describe:

Other: (Rule 8041 Sec. 5.8.1.2)

5-B Treatments for Preventing Carryout Report the required treatments that will be used for preventing carryout from occurring on paved public roads. Carryout occurs when materials from emptied or loaded haul trucks, vehicles, or trailers falls onto a paved public road or paved shoulder of a paved public road. No haul trucks will be routinely entering or leaving the project site.

Emptied Haul Trucks: (Rule 8031 Sec 5.0) Interior cargo compartments will be cleaned before leaving the project site. Cargo compartment will be covered with a tarp or suitable cover before leaving the project site.

Loaded Haul Trucks: Spillage or loss of materials from holes or other opening in the cargo compartment will be prevented when material is transported onto any paved public access road. (Rule 8031 Sec 5.0) Select one or both of the required applications: Haul trucks will be loaded such that the freeboard is not less than six inches with water applied to the top of the load before leaving the project site. Cargo compartment and load will be covered with a tarp or suitable cover before leaving the project site.

Other: 10/14/2004

Section 5 – Carryout and Trackout – Page 2 Project Name:

5-C

Cleaning up Carryout and Trackout

Check and report below the methods and frequency for cleaning up carryout and trackout from the surface and paved shoulders of paved public roads. The use of blower devices, or dry rotary brushers or brooms, for removal of carryout and trackout from paved public roads is prohibited. (Rule 8041 Sec. 5.0). In the event the control device becomes ineffective due to an accumulation of mud and dirt, material must be removed within ½ hour of the generation of carryout and trackout. (Rule 8041 Sec. 5.8.2.) The project is located in: An Urban Area, within an incorporated city boundary or an unincorporated area surrounded by a city. Minimum cleanup frequency will be at the end of the workday and removed immediately if carryout and trackout extends beyond 50 feet. (Rule 8041 Sec. 5.4) A Rural Area, located within an unincorporated area and not surrounded by an incorporated city. The construction project is less than 10 acres in size: minimum cleanup frequency is at the end of the workday. (Rule 8041 Sec. 5.1) Construction projects 10 or more acres in size: minimum cleanup frequency is end of the workday and immediately if carryout and trackout extends beyond 50 feet. (Rule 8041 Sec. 5.5)

Clean up Method: Check the method below that will be used for cleaning carryout and trackout. Manually sweeping and picking up. (Rule 8041 Sec. 5.7.1) Mechanical sweeping with a rotary brush or broom accompanied or preceded by water. (Rule 8041 Sec. 5.7.2) Describe the types of equipment that will used:

Operating a PM10-efficient street sweeper. (Rule 8041 Sec. 5.7.3) Make and Model: Flushing with water: allowed if: (Rule 8041 Sec. 5.7.4) • No curbs or gutters are present. • Using water will not result as a source of trackout and carryout. • Using water will not result in adverse impacts on storm water drainage systems. • Using water will not violate any National Pollutant Discharge Elimination System permit program.

5-D

Record keeping for Cleanup of Carryout and Trackout (Rule 8011 Sec. 6.2)

Records and any other supporting documents for demonstrating compliance must be maintained. The District has developed a record keeping form specific for cleaning carryout and trackout from paved public roads and may be used for complying with this requirement. Check one or both below: Records will be maintained using the form developed by the District. Records will be maintained using documents or forms developed by the owner or operator. Explain and include copies:

10/14/2004

Dust Control Plan Section 6 – Certification Project Name:

6-A Certification I certify that all information contained herein and information submitted in the attachments to this documents are true and correct.

Print Name

Title

Signature

Date

Phone Number

Fax Number

Cell Number

10/14/2004

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