February 23, 2017 Sent via e-mail to: kaylie@waterboards.ca.gov To: Kaylie Humbert Re: Tentative Order to Adopt Amended Time Schedule Order for City of Mount Shasta, Mount Shasta Waste Water Treatment Plant (WWTP), Waste Discharge Requirements, Order R5-2012- 0086, (NPDES No.CA0078051, Mount Shasta, Siskiyou County Dear Kaylie, These comments are timely submitted on the above-described proposed Tentative Order. I support the City's efforts to achieve a state-of-the art WWTP infrastructure and simultaneously support the cleanest discharge from the existing WWTP to the City's three discharge points as described in their NPDES/WDR permit: the Sacramento River (a water of the US), their on-site leachfield, and the Golf Course. Both are obtainable goals and the question to the WB is does it really serve the public interest and the environment to extend the permit conditions, knowing that even this new 27 May 2020 deadline for ammonia will not be achieved because the City's new WWTP will not complete construction until 2021? The ability of the city to comply are even more doubtful with a 4-month extension (4 October 2017) for copper and zinc. The effluent limitations's deadline for ammonia, zinc, and copper have continued to be extended over nearly a decade with permitting conditions that have allowed interim effluent limits that are in excess of those final limitations. I have read the City's letter requesting the Amended Time Order and feel dismayed by how the public has been depicted. The public is not responsible for the City's loss of EDA grant money nor the City's failure to meet the 2017 ammonia, zinc, and copper effluent limits deadline. This conclusion can only be arrived at if you decide that the public process is seen as something that should not exist nor their concerns addressed by decision-making agencies. However, this is contrary to existing laws. I believe, and I hope you do too, that public comments are an important part of the process. The EDA thought so:

"The public comments have provided EDA with new and relevant information that was not taken into account when EDA issued its original EA and its amended EA. Under these circumstances, EDA has concluded that the intent and purpose and/or economic feasibility of the Project have changed substantially so as to affect significantly the accomplishment of the Project as intended." Emphasis added, see attached EDA Feb 11, 2016 letter

The City of Mount Shasta's Dec 2016 letter to the Water Board --requesting an Amended Time Order Schedule --described the public's participation with animosity and as an 'on-going fight with local activists relative to their perception of the relationship between Crystal Geyser and the State Mandated WWTP that "..incorrectly linked this project [the

EDA grant funding project] to a controversial water bottling facility ." See attached Mt Shasta City 2016 Dec TSO amend request letter. But this statement flies in the face of what the City's stated in their EDA grant application:

The original Project scope of work included expanding the capacity of a main sewer line and improving the Mount Shasta WWTP. The primary beneficiary of the Project was identified as Crystal Geyser, a spring water and beverage bottling and distribution company. Emphasis added, see page 1 and 2 of the Attachment sections of the City of Mount Shasta EDA Funded WWTP Improvements Preliminary Engineering Report ( PER) with Attachment document

and In the City's original 2013 grant application, the City clearly noted that Crystal Geyser was a "Project Beneficiary" and 'to accomodate flows from the water bottling facility and future growth."1 Honestly, I don't think there was a misperception by the public, only a misrepresentation to the public that became obvious once the EDA grant was reviewed. As the WB is aware, grants are not rescinded lightly and not without due cause. The City was not an innocent by-stander in that decision; yet places blame on the 'outcry from local activists' for the EDA's decision to retract the original grant funding in December 2014. 2 See MtShastaCity 2016.12.02.Ammonia. TSO.amend.request In my 20 years of environmental review--including state and federally funded projects that involved the comments and concerns of the public --only one single funding grant was ever rescinded and it was not due to 'public misperception'. It is unfortunate that this public participation has been cloaked in an alternate reality that shames that public participation and blames them for errors that the applicant (in this case the City) could have avoided. Thank you for receiving this comments. Sincerely, Peggy Risch PO Box 882 Mount Shasta, CA 96067 Attachment 1. Mt Shasta EDA termination Feb.11. 2016 letter to the City of Mount Shasta 2. City of Mount Shasta EDA Funded WWTP Improvements Preliminary Engineering Report ( PER) with Attachment 3. MtShastaCity 2016.12.02.Ammonia. TSO.amend.request letter

1 Emphasis added, see page 1 and 2 of the Attachment sections of the City of Mount Shasta EDA Funded WWTP Improvements Preliminary Engineering Report ( PER) with Attachment document 2 See City of Mount Shasta's Dec 2016 letter requesting an Amended Time Order

U. S. DEPARTMENT OF COMMERCEEconomic Developm€nt Administration915 Second Avenue, Roorn 1890Seatrle, wA 98174Fax: 206.220.7669Vorce: 206.220.7660

FEB I I 2016

N'tr. I'aul EckcrlCrti it{anagerCit) ()l'lvlounr Shasla105 \onh Mt. Shasra Boulerard\{ounr Shasta. California 96067

Rc: lll)A Award No.07-79-07000Upgrade of Mounl Shasta Wastcrvarer Treatrnenl Plant

Dear Nlr. Eckert:

This lcttcr is to inlbrm you that becausc thc Economic Development Administration (EDA) hasdctcrntincd that an Ilnvironnrcntal Impact Statement (EIS) under thc National EnvironntentalPolicl'Act ol'1969 (42 U.S.C, g 1321 et seq.) (r\-EPA) musr be preparcd and considcrcd inconnection vrith thc anrcndnrenr of F.DA Award No. 07-7s-0700 (Award) lbr the upgrade ofthcMount Shasta Wastewale r 'l'rcatment Plant (WW1'P), and because of tbc lcngth of time requireolbr suclr a rcr icrr', EDA has dctermincd thal thc Award must be lerminated.

On Septembcr 27. 2013, rhc City ol Mount Shasta (City; acccptcd thc Arvard f'rom IDA to funothe design and oonstruction ol lhe Mount Shasta Sewer Line and Wastewater FacilitiesImprtrvement I)roject (Project). Total costs under the Award were $6,000,000(Fcdcral Sharc $3,000.0001 Recipienr Share 93,000,000). The original Project scopc ofrvorkjncludcd c'xpanding 1hc capacity ol'a rnain scwcr linc and improving thc Mounr Shasta WW'l P.1'hc primarv bcrrcliciary'ol'thc Project was identified as Crystal Geyser., a spring u,atcr andbclcragc bottling and distributing compan) .

'l hc initial EDA [:nvironnrcntal Assessment (EA) for the Projcct was bascd in pan upon the lackol'pLrblic comnlents reccivcd and. hencc. EDA issucd a Mirigated l:inding ol'No Significantlnrpacl (Nfitigalcd I ONSI) conlingcnr upon the cornpletion ofan Lnvironmcntal Impact Report(H[{) urrder the Califbrnia linvilonnrenral Quality Act (CEQA) and a dererminarion that projectirnpacts u'ould not bc signilicant. Rclatcdly, the Arvard also included a spccial award conditionrcqLriring a sullicicnt CEQA anall'sis hel'rrre advertiscment lilr construction bid.

ln Novembcr of 2014. EDA leamed that the Ciry planned to use Award funds ro prcpare rhe ElR.As this was nol an approved cost itenr under the Award's scope ofwo!k, EDA proposedanrr"'nding the'Au,ard, The Cily Council votcd to accept the proposed amcndment inJanuary' 201-<, which consisted of improvemenrs to rhe WW I'P, specilically new liltration andultraviolct disinl'cction facilitics. ln octoher 2015, while in rhs process ol'issuing an amendcdEA and |oNSl |i)r the re-scope. EDA publishcd a ncu'NIPA norice scekins comnlcuts on thc

amended scope of work. EDA received numerous public commcnts concerning theenvironmental impacts of Crystal Geyser's proposed renovation and expansion of the bottlingplant to be serviccd by the WWTP improvements.

Pursuant to CEQA, in November of 2015 the City issued its Proposed Mitigatcd NegativeDeclaration and Initial Study (MND[S) for all improvemenrs ar the WWTP. Sigrificantly,although anticipating tlre need for increased capacity at the WWTP from thc Crystal Geyserfacility, the MNDIS did not addrcss any of the effects of the facility on the environment,

Here, NEPA requires EDA to factor envirou-aenlal considerations into its decision whether toaward linsncial assistance to the City by considering the direct, indirect, and cumulative effectson the environment as a result of the cunent Project, including those linked to the activities ofaProject beneficiary like Crysul Geyser. The public comments have provided EDA with new andrelevant information that was not taken inlo account when EDA issued its original EA and itsamended EA. Among the significant concems identified by the public are: impacts on exislingwaler resources; groundwater extraction and subsequenl impacts to private wells, crceks, andsprings; industrial wastewater disposal; and the strain on WWTP capacity even with theexpansion. Based on the public comments received and notwithstanding the City's MNDASunder CEQA, EDA has determined thar it must withdraw the Mitigatcd FONSI issued for thcProject and that an EIS is required before EDA can determine whether, and upon whstconditions, EDA should amend the Award to upgrade thc Mount Shasta WWTP.

However, the Project development lime table, which is incorporated under the Award, providesthat construction was to have started on Scptember 25, 2015 and must be completed beforc theAward end date, which is September 25,2018. In addition, all Award funds must be used forapproved construction expenses and no funds are available for the preparalion ofan EIS.Moreover, the projected time period required to complete an EIS makes it highly unlikely thatthe City will complete the Project before the Award end datc. Under these circumslances, EDAhas concluded that the intent and purpose and/or cconomic feasibility of the Project havechanged substantially so as to affect significantly the accornplishment ofthe Project as inlended.Therefore, pursuant to Section C.lE.a.(ii) ofthe EDA Standard Terms and Conditions forConstruction Projects (March 12,2013), which were incorporated into the Award, EDA isterminating the Award.

Within 30 calendar days ofthis lctter, please submit a final Form SF-425, as well as a Form SF-271 with suppo(ing documentation, to close out this award. EDA will review and approve alleligible Project costs incurred by the City before the termination in accordance with l5 C.F.R. 024.43(c).

EDA also wishes to emphasize this tcrmination does not impact the City's eligibility orcompetitiveness for future funding consideration. Malinda Matsor\ EDA's EconomicDevelopment Representativc (EDR) for Coastal and No(hcm Califomia, will continue to workwith the City to mect its regional economic development needs.

Thank you for your attention and we look forward to supporting the City in its furure economicdcvelopment eflbns.

Sincerely,tt

t!L/,./ t/ lt/,'r,' i '.ti ,l {o-oqryf* ir'///s' tAj l.conard Smith ' / 'Regionirl I)ireclor

CITY OF MT. SHASTA EDA-FUNDED WASTEWATER TREATMENT PLANT

IMPROVEMENTS PRELIMINARY ENGINEERING REPORT (PER)

1. DESCRIPTION OF PROJECT COMPONENTS

The City of Mt. Shasta proposes to construct filtration and ultra-violet (UV) disinfection

facilities in order to meet State-mandated waste discharge requirements imposed in the

2012 National Pollution Discharge Elimination System (NPDES) permit. The specific

components are described as follows, and shown on Figure 1.

A. Filtration Facilities

The proposed filtration facilities will consist of either, 1) travelling bridge filters, or

2) disk-type (cloth) filters. Final filtration technology selection will be made as part of the

10% Preliminary Design and Development Report (PDDR) effort for this project. The

travelling bridge filters consist of two (2) approximately 16-foot by 46-foot concrete

basins adjacent to one another. Each basin contains about 10 inches of graded filter

sand and have an approximate area of 736 square feet. The filter beds are partitioned

into many smaller cells. A travelling bridge moves slowly across the entire bed,

backwashing one individual partitioned cell at a time. This allows the entire filter (less

one cell) to remain in service at all times – even during backwashing. Each filter has a

peak wet weather flow capacity of approximately 2.0 million gallons per day (MGD) to

accommodate peak wet weather flows. The filters will be covered by a structural steel

enclosure with open sides.

If a disk-type (cloth) filtration system is selected, the overall footprint will be much

smaller because the filtration media consists of circular disks mounted vertically. Both

sides of the disks filter clarified effluent. There are two type of configurations for these

units: 1) clarified effluent enters the outside of the disks, or 2) clarified effluent enters

the disk internally and exists, thereby retaining trapped solids inside the disk. While the

disk-type filters are more expensive, equipment-wise, the overall installation cost may

be comparable to travelling bridges because of the smaller footprint. Each disk filter

1 City of Mt. Shasta 111.54

consists of steel basin that fits within a 15-foot by 8-foot area. If disk-type filters are

selected, consideration will be made to house them in an enclosed, conditioned building

along with the UV facilities.

B. UV Disinfection Facilities

The UV disinfection facilities will consist of two UV channels – one primary and one

back-up. The channels will be below-ground reinforced concrete located adjacent to the

filtration facilities. At full build-out, each UV channel will contain three banks of lamps

delivering a dose of 80,000 micro watts per square centimeter (µWs/cm²). The

approximate footprint of the UV channels is about 46 feet by 20 feet. Both the

disinfection and UV facilities will be housed under an

open-walled enclosure or metal building.

2. STATEMENT OF COMPLIANCE WITH SECTION A.2 OF FORM ED-900

The proposed project encompasses improvements to the City of Mt. Shasta’s

wastewater treatment plant that serves areas within the City and Siskiyou County. The

improvements consist of constructing new effluent filtration and disinfection facilities at

the wastewater treatment plant. These improvements are necessary for the City to

comply with its current National Pollution Discharge Elimination System (NPDES)

permit, adopted in October 2012. Said improvements will allow the City to meet current

regulatory requirements imposed in the 2012 NPDES discharge permit. Refer to

attached Form ED-900, Section A.2, which was provided for the original Interceptor

Sewer Replacement project. The proposed project is shown graphically on attached

Figure 1.

3. COMPLIANCE WITH SECTION B.5 OF FORM ED-900

Reference is made to Form ED-900, Section B.5, attached, submitted as part of the

original project funding application. The project beneficiaries are unchanged from the

original Form ED-900.

4. PROJECT CONSTRUCTIBILITY

Both the filtration and UV disinfection facilities will be constructed within the footprint of

the existing slow sand filters – currently not being used. Both processes will be

2 City of Mt. Shasta 111.54

constructed in the ground so that the working surfaces are at approximately ground

level. If travelling bridge filters are utilized, the depth of excavation will be about eight

feet. Use of disk-type filters will require less excavation. The depth of excavation for

the UV channels is expected to be about six to seven feet.

Since the proposed site is previously disturbed by construction of the slow sand filters,

no difficult excavation is anticipated. It will be critical to perform the 10% PDDR prior to

final placement of the proposed facilities in order to determine design elevations based

on the water hydraulic profile through the entire treatment plant. This will avoid the

need for extraneous pumping when the remaining WWTP processes are designed and

constructed for the State-Mandated project.

5. PROPOSED METHOD OF CONSTRUCTION

The project implementation approach will be by “design-bid-build.” PACE will design

the improvements, prepare bid documents and lead the public bidding process. Public

advertisement will be accomplished in accordance with Public Contract Code

requirements pertaining to local advertisement. In addition, the project will be

advertised on CIPList.com, which is a hosted bid advertisement website used by many

public agencies. The lowest responsive and responsible bidder will be awarded the

construction contract. Construction management and inspection services will be

provided by PACE Engineering, Inc.

6. ANTICIPATED NUMBER OF CONSTRUCTION CONTRACTS

It is anticipated that the proposed facilities will be constructed as part of one contract

with an single Class A-licensed engineering contractor. The Contractor may have

subcontractors at his own discretion, and as long as 50% of the work is completed by

his/her own forces.

7. CONSTRUCTION COST ESTIMATE

The total project cost is estimated to be about $3.03M, see Table 1. Construction is

estimated to be about $2.497M in June 2016 dollars – the time in which bidding is

expected to take place, and includes a 15% contingency. Prior to any design work, it is

appropriate to use a 15% to 20% contingency. When design is nearly complete, it is

3 City of Mt. Shasta 111.54

appropriate to reduce the contingency allowance to 10% to 15% percent. We feel a

15% contingency for this level of planning is appropriate.

Cost are based on proposals from equipment suppliers and our in-house database of

costs observed on recently bid public works projects throughout northern California.

8. PROPERTY ACQUISITION

There are no property or easement acquisitions required to implement the subject

project. All project components reside on City of Mt. Shasta property, refer to Figure 2.

9. PROJECT PERMITS

The typical construction-related permits will be obtained by the Contractor prior to

starting work. The Contract will provide evidence or an OSHA shoring permit, and

construction erosion control permit from the California Regional Water Quality Control

Board. No encroachment or other permits will be required.

10. ESTIMATED PROJECT SCHEDULE

In order to meet the September 25, 2016 deadline to begin construction on the project

using EDA grant funds, the following schedule must be adhered to.

M:\Jobs\0111\0111.54 EDA-Funded WWTP Improvements\Project Re-Scoping\EDA-PER_Report.doc

MILESTONE DURATION COMPLETION

DATE

Obtain EDA approval to proceed with revised project. 1 wk Sep 25, 2015

City authorize PACE to proceed with PDDR & final design. 1-1/2 wks Sep 28, 2015

Design surveys and mapping 3 wks Oct 16, 2015

Preliminary Design and Development Report (PDDR). 18 wks Feb 12, 2016

Advertise for public bids 32 wks Jun 7, 2016

Public bid opening 5 wks Jul 12, 2016

Issue Notice to Proceed to Contractor 6 wks Sep 1, 2016

Construction completed 13 mos Sep 30, 2017

4 City of Mt. Shasta 111.54

FIGURES

PACEENGINEERINGREDDING, CALIFORNIA

PACEENGINEERINGREDDING, CALIFORNIA

TABLES

UNIT CONTRACTDescription QTY UNITS COST AMOUNTSFiltration FacilitiesEquipment and Controls 2 EA $251,000 $502,000Concrete structure 1 LS $416,000 $416,000Structure excavation and backfill 1200 CY $30 $36,000Process and utility piping 240 LF $175 $42,000Steel enclosure 4800 SF $25 $120,000

UV disinfection equipment 1 LS $570,000 $570,000Concrete basin 1 LS $130,000 $130,000Electrical and controls 1 LS $250,000 $250,000

Subtotal Filtration & Disinfection Improvements (June 2014 Dollars): $2,066,000Inflation @ 2.5%/yr for 2 years: $105,000

Contingency Allowance @ 15%: $326,000Total Construction Cost (Including Contingency): $2,497,000

INDIRECT COSTSGrant Administration Cost: $15,000

Environmental (IS/MND): $24,862Survey/Mapping: $25,992

10% Preliminary Design & Development Report: $49,076Design, including geotechnical: $191,420

Contract Services (Bidding/Award/Contract Execution): $19,256Labor Code Compliance Services: $20,504

Construction Administration: $80,541$108,800

TOTAL ESTIMATED PROJECT COST (June 2016 Dollars): $3,032,451

TABLE 1City of Mt. Shasta

EDA-FUNDED WASTEWATER TREATMENT PLANT IMPROVEMENTS

UV Disinfection Facilities

Construction Observation:

ATTACHMENTS