ukiah recycled water project - final is-mnd 5-22-2013
TRANSCRIPT
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City of UkiahRecycled Water Project
Final Initial Study / Mitigated Negative DeclarationSCH #2013032072
Prepared by:
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Table of Contents
Chapter 1 Introduction .........................................................................................................1-1
Chapter 2 Comments Received ...........................................................................................2-1
Chapter 3 Responses to Comments ....................................................................................3-1
Chapter 4 Revisions to the Public Draft IS/MND .................................................................4-1
Chapter 5 CEQA Findings and Determination: ...................................................................5-1
Appendicies
Appendix A Mitigation Monitoring and Reporting Program .............................................. A-1
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Chapter 1 Introduction
Pursuant to the California Environmental Quality Act (CEQA; Public Resources Code Section 21000, etseq. and CEQA Guidelines), the City of Ukiah, California (City) prepared a Public Draft Initial
Study/Mitigated Negative Declaration (IS/MND) to evaluate potential environmental impacts associatedwith the Citys proposed Recycled Water Project (Proposed Project/Action). The purpose of the ProposedProject/Action is to replace/augment existing water supplies in Ukiah Valley. Recycled water use withinthe Ukiah Valley would offset existing and future water demands for irrigation and frost protection ofagricultural land, and in doing so, would support the local agricultural industry. It would also offset urban
irrigation demands, ease storage limitations at the Ukiah Wastewater Treatment Plant (UWWTP) andreduce treated wastewater discharges to the Russian River.
On March 27, 2013, to initiate public review of the Draft IS/MND, the City filed a Notice of Completion(NOC) for the project with the Governors Office of Planning and Research (State Clearinghouse or SCH)
and the County of Mendocino and released the Draft IS/MND for a 30-day public review. The StateClearinghouse identified the project with SCH #2013032072. The 30-day public review period was
established between March 27 and April 26, 2013, with copies of the Draft IS/MND available for reviewat the Citys Public Works Administration Office, at 300 Seminary Avenue, Ukiah, CA 95482; and theMain Branch Library, 105 North Main Street, Ukiah, CA 95482. On March 27, 2013, the Ukiah Daily
Journal published the Notice of Intent/Notice of Availability (NOI/NOA) to adopt a Mitigated NegativeDeclaration for the Proposed Project/Action. A Public Draft of the IS/MND was also posted on the Citys
website athttp://www.cityofukiah.com/ .
This Final IS/MND was prepared according to CEQA Guidelines and considers and incorporates allcomments received by the State Clearinghouse and the City during the 30-day public review period. The
purpose of this document is to clarify facts set forth in the Public Draft IS/MND, as necessary, to ensure
accuracy. This City must consider the IS/MND, together with any comments received, before approvingthe Proposed Project/Action (Public Resources Code Section 21091(f); and CEQA Guidelines Section
15074). The City has no affirmative duty to prepare formal responses to comments on the ProposedProject/Action IS/MND, but should have adequate information on the record explaining why thecomment does not affect the conclusion that there are no potential significant environmental effects. The
City is required to however to notify in writing any commenting agencies of the date of the public
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Chapter 3 Responses to Comments
This chapter evaluates the comments received during the 30-day public review period (March 27 throughApril 26, 2013). The City received a total of four (4) comment letters on the Proposed Project/Action.
The City has reviewed and considered the comments from each agency and provides a response to each ofthose comments as provided for below.
NORTH COAST REGIONAL WATER QUALITY CONTROL BOARD
Comment A-1. Comment Noted. The City also agrees that the activities that occur on each proposed usesite is an integral part of the Proposed Project/Action. Specific end users have not formally signed up for
the Recycled Water Project at this time and therefore specific details regarding those activities are notfully known at this time. The City is in the process of identifying specific end users and developing
agreements with them. It is expected that most of the users will receive the recycled water on demand asmost do not have their own storage. Those with storage will receive recycled water for the irrigationseason and limited times for the frost season use based on conditions of use from the permitting agencies.As part of the permitting process, the City is preparing a Report of Waste Discharge and Recycled WaterTechnical Report that will address these issues more specifically.
Comment A-2. Comment Noted. The City agrees that there are distinct differences between the use ofrecycled water for frost protection and irrigation. As part of the permitting process, the City is preparinga Report of Waste Discharge and Recycled Water Technical Report that will address these issues morespecifically.
Comment A-3.Comment Noted. Specific end users have not formally signed up for the Recycled WaterProject at this time and therefore specific details regarding those activities are not fully known at thistime. The City is in the process of identifying specific end users and developing agreements with them.It is expected that most of the users will receive the recycled water on demand as most do not have their
own storage. Those with storage will receive recycled water for the irrigation season and limited times forthe frost season use based on conditions of use from the permitting agencies. As part of the permitting
process, the City is preparing a Report of Waste Discharge and Recycled Water Technical Report that
will address these issues more specifically In this report detailed figures will be provided to identify all
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proximity of the proposed irrigation area to surface water features. The Citys Report of Waste Discharge
and Recycled Water Technical Report will also provide a detailed analysis to demonstrate that theproposed recycled water irrigation rates will not exceed the most stringent of the nutrient or hydraulicagronomic rate and also demonstrate that ground or surface water will not be degraded.
Comment A-6. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations forProject/Action Facilities has been revised to reflect these comments. Please see changes to the PublicDraft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment A-7. Comment Noted. The page numbering in Chapter 3 has been revised per the commentprovided. Please see changes in to the Public Draft IS/MND in Chapter 4Revisions to the Public Draft
IS/MND.
Comment A-8. Comment Noted. The Comment is a general statement which is acknowledged and with
which the City agrees.
Comment A-9.Comment Noted. The Comment is a general statement which is acknowledged and withwhich the City agrees.
Comment A-10. Comment Noted. Mitigation Measure BIO-6: Obtain Required Authorizations, is also tobe implemented in conjunction with Mitigation Measure BIO-3 Avoid Cutting Through Creeks;
Mitigation Measure BIO-4: Implement Construction Best Management Practices; and MitigationMeasure BIO-5: Develop and Implement a Frac-Out Contingency Plan for Trenchless ConstructionActivities. As a result, we are not simply proposing to conduct studies and obtain permits. We haveidentified mitigation measures to help avoid and reduce potential impacts to wetlands and other sensitiveareas. As part of the permitting process, additional mitigation measures may also be identified and
implemented as project design details become more fully developed.
Comment A-11. The City is in the process of identifying the details regarding the design and constructionof the proposed recycled water storage pond(s). At a minimum, the recycled storage pond(s) will bedesigned to minimize the movement of recycled water and pollutants such as salts and nutrients to
groundwater and/or surface waters The storage pond(s) will have a synthetic liner and will meet all of the
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that ground or surface water will not be degraded. An antidegradation analysis will be prepared and
submitted as part of the Report of Waste Discharge.
Comment A-16. Comment Noted. On page 2-8 in the Public Draft IS/MND, the City identifies a
summary of the operational plans to enforce an irrigation schedule among its users. Additionally, thecomment correctly notes that Mitigation Measure HWQ-2 identifies BMPs that the City proposes toimplement to reduce the potential effects of increased salt loading potential from the use of recycledwater. The City also notes that prior to any permit action related to operation of the recycled watersystem, the City will need to prepare and submit for approval of the Regional Water Board, a recycled
water operations and maintenance plan and recycled water users guide to identify general and site-specificBMPs that will be implemented to ensure that recycled water will be used in a manner that protects
ground and surface water. As requested, the City has revised existing Mitigation Measure HWQ-2 andhas added a new mitigation measure (HQW-3) to identify the preparation of measures to protect againstrecycled water runoff that is not incidental, provide for detection and correction of leaks, and ensure that
pollutants such as salts and nutrients are not discharged at concentrations that could adversely impactgroundwater. The BMPs will also address both agronomic irrigation and frost protection uses. Please see
changes in to the Public Draft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment A-17. Comment Noted. As requested, the City has added a mitigation measure to identify the
preparation of measures to protect against recycled water runoff that is not incidental, provide fordetection and correction of leaks, and ensure that pollutants such as salts and nutrients are not discharged
at concentrations that could adversely impact groundwater. The BMPs will also address both agronomicirrigation and frost protection uses. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-18. Comment Noted. As requested, the City has added a mitigation measure to identify the
preparation of measures to protect against recycled water runoff that is not incidental, provide fordetection and correction of leaks, and ensure that pollutants such as salts and nutrients are not discharged
at concentrations that could adversely impact groundwater. The BMPs will also address both agronomicirrigation and frost protection uses. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
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Comment A-22. Comment Noted. The City agrees and has revised Mitigation Measure HAZ-1 to
reflect this comment. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions tothe Public Draft IS/MND.
Comment A-23. Comment Noted. The City does not believe the Proposed Project/Action would have anyimpacts on temperature in the Russian River or its tributaries as it does not propose any activities where
applied recycled water would run-off into the Russian River or its tributaries, including under frostcontrol measures. The City has revised existing Mitigation Measure HWQ-2 and has added a newmitigation measure (HQW-3) to identify the preparation of measures to protect against recycled waterrunoff that is not incidental, provide for detection and correction of leaks, and ensure that pollutants such
as salts and nutrients are not discharged at concentrations that could adversely impact groundwater andsurface water. The BMPs will also address both agronomic irrigation and frost protection uses. Please seechanges in to the Public Draft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment A-24. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations forProject/Action Facilities has been revised to reflect these comments. Please see changes in to the PublicDraft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment A-25. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations forProject/Action Facilities has been revised to reflect these comments. Please see changes in to the PublicDraft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment A-26. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations forProject/Action Facilities has been revised to reflect these comments. Please see changes in to the PublicDraft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment A-27. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations for
Project/Action Facilities has been revised to reflect these comments. Please see changes in to the PublicDraft IS/MND in Chapter 4Revisions to the Public Draft IS/MND.
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Mitigation Measure BIO-3 to identify setbacks from creeks for starting and ending the drilling activities
and the need to have equipment on site to handle any spills. Please see changes to the Public DraftIS/MND in Chapter 4Revisions to the Public Draft IS/MND.
Comment C-3. Comment Noted. The City will research alternative lubricants to replace bentonite during
construction-related drilling activities. If or when a more suitable substitute is found, we will revise theconstruction plan that correlates with construction-related drilling.
Comment C-4. Comment Noted. Due to the scale of the Project and the maps included in the IS/MNDand the Cultural Resources Investigation report, detailed mapping showing the buffer footprints of theProjects APE would not provide much distinction except for on a much larger scale and on a pipelinesegment by segment basis. Due to the nature of this IS/MND and Cultural Resources Inventory Report,
the City feels the mapping along with the description is more than adequate at this point. Once detaileddesign drawings are developed, the buffers will be displayed at that time.
Comment C-5. Comment Noted. The City agrees and has revised Mitigation Measure HAZ-1 to reflectthis comment. Please see changes in to the Public Draft IS/MND in Chapter 4Revisions to the Public
Draft IS/MND.
Comment C-6. Comment Noted. The City agrees and has revised Mitigation Measure HAZ-1 to reflect
this comment. Please see changes in to the Public Draft IS/MND in Chapter 4Revisions to the PublicDraft IS/MND.
MENDOCINO COUNTY FARM BUREAU
Comment D-1. Comment Noted. The purpose of the Proposed Project/Action is to replace/augment
existing water supplies in Ukiah Valley. Recycled water use within the Ukiah Valley would offsetexisting and future water demands for irrigation and frost protection of agricultural land, and in doing so,would support the local agricultural industry. It would also offset urban irrigation demands, ease storage
limitations at the Ukiah Wastewater Treatment Plant (UWWTP) and reduce treated wastewater dischargesto the Russian River.
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Chapter 4 Revisions to the Public Draft IS/MND
This chapter shows revisions to the March 2013 Public Draft IS/MND, subsequent to the documentspublication and public review. The revisions are presented in the order in which they appear in the Public
Draft IS/MND and are identified by section and page number in respective chapters. These revisions areshown as excerpts from the Public Draft IS/MND, with strikethrough (strikethrough) text in indicatedeletions and underlined (underlined) text to indicate additions.
Chapter 2 Project Description and Alternatives
Detailed below are the changes to the Project Description and Alternatives chapter in the Public DraftIS/MND.
2.1.4 Storage Facilities
On page 2-4 of the Public Draft IS/MND, Section 2.1.4Storage Facilities is hereby revised as follows.
As also shown on Figure 2 and Figure 2a below, the Proposed Project/Action also includes theconstruction and operation of a new single tertiary treated recycled water storage pond at the wastewatertreatment plant sized at a capacity of approximately 1.6 MG and encompassing approximately 5 acres of a43-acre parcel which is owned by the City. The storage pond at the wastewater treatment plant will
accommodate the variation in potential customer demand patterns and also serve as an equalization basinto buffer the potential variation in effluent flow at the WWTP. This storage pond will be setback from theRussian River by approximately 500 feet and will be designed and lined with a synthetic liner to preventthe movement of recycled water and pollutants such as salts and nutrients to groundwater or surfacewaters. In addition to this storage pond, individual farmers will either use their existing storage ponds
and/or develop additional storage ponds on their own which will be designed to the same water qualitydesign standards as the Citysproposed storage pond. These specific farmer activities are not included inthe Proposed Project/Action known at this time, but will be developed once individual agreements aremade with each farmer/individual. These activities will be further identified and explained in the Citys
Report of Waste Discharge and Recycled Water Technical Report that the City will submit to the NorthCoast Regional Water Quality Control Board for approval prior to implementation.
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On page 2-8, Table 4 Regulatory Requirements, Permits, and Authorizations for Project/Action
Facilities is hereby revised as follows.
Table 4: Regulatory Requirements, Permits, and Authorizations for Project/Action Facilities
Agency Type of Approval
U.S. Army Corps of Engineers
Nationwide Permit #12 for ConstructionActivities (or) Section 404 (Wetlands)Permit
Water Quality Certification (401Certification)
Coordination with Federal AviationAdministration (FAA) for permitting of newwastewater storage pond
North Coast Regional Water Quality ControlBoard
National Pollutant Discharge EliminationSystem General Permit for StormwaterDischarge Associated with ConstructionActivities
Waste Discharge Requirements (WDRs) orConditional Waiver of WDRs
General Construction Activity Storm WaterPermit
Low Threat Discharge Permit
Recycled Water Use Permit
California Division of Dam Safety Storage Pond Design, if necessary
California Division of Occupational Safety andHealth
Construction activities in compliance withCAL/OSHA safety requirements
California Department of Fish and Game Wildlife Streambed Alteration Agreements
Title 22 Recycled Water EngineeringReport for Urban Reclamation andrecycled Water Pipe Installation
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is a minimum setback of 100 feet from creeks for the starting and ending of any drilling or
trenchless construction activities. Additionally, the City shall have or require its contractor(s)
have the needed equipment on site to handle any spills.
3.6 Geology and Soils
On Page 3-23, Mitigation Measure: GEO-1: Perform Geotechnical Investigation is hereby revised asfollows.
Mitigation Measure GEO-1: Perform Geotechnical Investigation. The City shall require a design-
level geotechnical study to be prepared prior to project implementation to determine proper design andconstruction methods, including any cathodic protection measures needed for installing the pipelines inthese soils as well as the design of the storage pond(s). The geotechnical study shall evaluate the
potential for impacts to groundwater by determining soil permeability and other characteristics that affect
water movement, in addition to issues related to erosion and seismic hazards.
3.8 Hazards and Hazardous Materials
Page 3-0 has been revised to Page 3-26 and the subsequent pages have been revised to be in their properconsecutive order. In addition, Mitigation Measures HAZ-1 and HAZ-2 below have been hereby revisedas follows.
Mitigation Measure HAZ-1: Store, Handle, Use Hazardous Materials in Accordance with
Applicable Laws. The City shall ensure that all construction-related hazardous materials and hazardouswastes shall be stored, handled, and used in a manner consistent with relevant and applicable federal,state, and local laws and done in a manner that protects surface waters and groundwater. In addition,construction-related hazardous materials and hazardous wastes shall be staged and stored away fromstream channels and steep banks to keep these materials a safe distance from near-by residents and
prevent them from entering surface waters in the event of an accidental release. Additionally, the Cityshall develop a spill contingency plan that addresses measures to address spills and leaks of hazardous
t i l ll i t f d t t t i f t i t
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station, and water quality issues. Generally, excavation, grading, paving, and other construction
activities would expose disturbed and loosened soils to erosion by wind and runoff. Constructionactivities could therefore result in increased erosion and siltation, including nutrient loading andincreasing the total suspended solids concentration. Erosion and siltation from construction have
the potential to impact the creeks and drainage crossings, therefore posing a potentiallysignificant impact to water quality. With the incorporation of the following mitigation, any
potential impacts to water quality are reduced to less-than-significant levels.
Mitigation Measure HWQ-1: Implement Construction Best Management Practices.
To reduce potentially significant erosion and siltation, the City and/or its selectedcontractor(s) shall obtain a Stormwater Pollution Prevention Permit (SWPPP) and
implement Best Management Practices and erosion control measures as required by theNorth Coast RWQCB. Best Management Practices to reduce erosion and siltation shallinclude the following measures: Avoidance of construction activities during inclement
weather; limitation of construction access routes and stabilization of access points;stabilization of cleared, excavated areas by providing vegetative buffer strips, providing
plastic coverings, and applying ground base on areas to be paved; protection of adjacentproperties by installing sediment barriers or filters, or vegetative buffer strips;stabilization and prevention of sediments from surface runoff from discharging into storm
drain outlets; use of sediment controls and filtration to remove sediment from watergenerated by dewatering; and returning all drainage patterns to pre-existing conditions.
In addition, the operation of the Proposed Project/Action and application of recycled water willincrease salts and nutrient loadings on the soils which could result in significant impacts to
adjacent surface and groundwater resources. Agricultural farmers within the area maintain theirown onsite pumping and distribution systems to supply water to their crops. Depending on theiraccess and water rights, they rely on water from the Russian River and its tributaries as well as
groundwater. Groundwater and Russian River are similar in water quality and generally have an
average TDS level of approximately 224 milligrams per liter (mg/l)1
. At build out, the ProposedProject/Action would offset approximately 1,375 afy of that supply with recycled water forirrigation purposes. The proposed new recycled water supply would have an average TDS levelof approximately 345 mg/l
2which would result in an approximately 54 percent increase in salt
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Mitigation Measure HWQ-2: Implement Recycled Water Best Management
Practices. In order to help reduce the potential effects of increased salt loading potentialas a result of using recycled water, the City shall:
Ensure that water is applied consistent with Title 22 requirements and in amounts(frequency and intensity) which meet the demands of the plant (agronomic rates), butnot in excessive amounts such that salts buildup in the soil beyond the root zone
and/or otherwise are leached to groundwater;
Ensure that adequate soil drainage is maintained;
Ensure that salt-sensitive plants are not to be spray wet; and
Addressing sodium and alkalinity concerns through addition of water and soilamendments, including addition of gypsum.
In addition and prior to operation of the recycled water system, the City shall prepare and
submit for approval of the North Coast Regional Water Quality Control Board, a recycledwater operations and maintenance plan and recycled water users guide to identify generaland site-specific BMPs that will be implemented to ensure that recycled water will be
used in a manner that protects ground and surface water. The BMPs shall addressmeasures to protect against recycled water runoff that is not incidental, provide for
detection and correction of leaks, and ensure that pollutants such as salts and nutrients arenot discharged at concentrations that could adversely impact groundwater. The BMPsshall also address both agronomic irrigation and frost protection uses.
Specifically, the recycled water for irrigation BMPs shall include the type of irrigation
system, proper design and operation of the irrigation system, application methods (e.g.,agronomic application, use of repeat start times and multiple water days to increaseirrigation efficiency and reduce runoff potential, no application during precipitation
events), setbacks to surface waters, physical systems to capture runoff and prevent it fromreaching surface waters. BMPs shall also describe how salts and nutrients will be
managed in a manner that protects groundwater quality.
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potential degradation is identified, the analysis shall demonstrate that any degradationis in the best interest of the people of the state and that it will not result in the
exceedance of any groundwater quality objectives. This antidegradation analysis shallbe prepared and submitted as part of a Report of Waste Discharge.
With the implementation of Mitigation Measures HWQ-1, and HWQ-2, and HWQ-3, any
water quality impacts as a result of the use of recycled water will be reduced to less-than-significant levels. No additional mitigation measures or demineralization facilities would be
required.
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Appendix AMitigation Monitoring and Reporting ProgramCity of Ukiah Recycled Water Project
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MITIGATION MONITORING AND REPORTING PROGRAM
City of UkiahRecycled Water Project
Final Initial Study / Mitigated Negative Declaration
SCH #2013032072
Prepared for:
City of Ukiah
Public Works Administration Office300 Seminary Avenue
Ukiah, CA 95482
Prepared by:
SMB Environmental, Inc.
May 2013
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Recycled Water Project City of Ukiah
Mitigation Monitoring and Reporting Program
2
INTRODUCTION
Pursuant to the California Environmental Quality Act (CEQA; PublicResources Code Section 21000, et seq. and CEQA Guidelines), the City ofUkiah, California (City) prepared a Public Draft Initial Study/Mitigated
Negative Declaration (IS/MND) to evaluate potential environmental impactsassociated with the Citys proposed Recycled Water Project (Proposed
Project/Action). The purpose of the Proposed Project/Action is to
replace/augment existing water supplies in Ukiah Valley. Recycled water usewithin the Ukiah Valley would offset existing and future water demands forirrigation and frost protection of agricultural land, and in doing so, wouldsupport the local agricultural industry. It would also offset urban irrigationdemands, ease storage limitations at the Ukiah Wastewater Treatment Plant(UWWTP) and reduce treated wastewater discharges to the Russian River.
CEQA Guidelines require public agencies to adopt a Mitigation Monitoringand Reporting Program (MMRP) for changes to the project which it hasadopted or made a condition of project approval in order to mitigate or avoidsignificant effects on the environment. A MMRP is required for the proposed
project because the IS/MND identifies potentially significant adverse impactsrelated to project implementation, and mitigation measures have beenidentified to reduce those impacts.
On March 27, 2013, to initiate public review of the Draft IS/MND, the City
filed a Notice of Completion (NOC) for the project with the GovernorsOffice of Planning and Research (State Clearinghouse or SCH) and theCounty of Mendocino and released the Draft IS/MND for a 30-day public
review. The State Clearinghouse identified the project with SCH#2013032072. The public review period was established between March 27
and April 26, 2013, with copies of the Draft IS/MND available for review atthe Citys Public Works Administration Office, at 300 Seminary Avenue,Ukiah, CA 95482; and the Main Branch Library, 105 North Main Street,
Ukiah, CA 95482. On March 27, 2013, the Ukiah Daily Journal publishedthe Notice of Intent/Notice of Availability (NOI/NOA) to adopt a Mitigated
Negative Declaration for the Proposed Project/Action. A Public Draft of theIS/MND was also posted on the Citys website athttp://www.cityofukiah.com/ .
In May 2013, the City prepared a Final IS/MND according to CEQAGuidelines and incorporates all comments received by the State
Clearinghouse and the City during the 30-day public review period. As aresult, some of the mitigation measures identified in the Public DraftIS/MND have been revised to reflect those comments. Based on the FinalIS/MND, the Proposed Project/Action would not result in new significantimpacts, substantially increase the severity of previously disclosed impacts,or involve any of the other conditions related to changed circumstances or
new information that can require a subsequent or supplemental EIR underPublic Resources Code section 21166 and CEQA Guidelines section 15162
beyond those impacts and conditions already identified in the Citys PublicDraft IS/MND.
PURPOSE OF MITIGATION MONITORING AND REPORTING
PROGRAM
This MMRP has been prepared to ensure that all required mitigationmeasures are implemented and completed in a satisfactory manner beforeand during project construction and operation. The MMRP may be modified
by the City during project implementation, as necessary, in response tochanging conditions or other refinements. Table A (included at the end ofthis document) has been prepared to assist the responsible parties in
implementing the mitigation measures. The table identifies individualmitigation measures, monitoring/mitigation timing, responsible
person/agency for implementing the measure, monitoring and reportingprocedure, and space to confirm implementation of the mitigation measures.
The numbering of mitigation measures follows the numbering sequencefound in the Public Draft IS/MND.
ROLES AND RESPONSIBILITIES
Unless otherwise specified herein, the City is responsible for taking all
actions necessary to implement the mitigation measures under its jurisdictionaccording to the specifications provided for each measure and fordemonstrating that the action has been successfully completed. The City, atits discretion, may delegate implementation responsibility or portions thereofto a licensed contractor or other designated agent. The City would beresponsible for overall administration of the MMRP and for verifying that
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City staff members and/or the construction contractor has completed thenecessary actions for each measure.
The City would designate a project manager to oversee implementation ofthe MMRP. The City of Ukiahs Public Works Department is primarilyresponsible for implementing the mitigation measures for the ProposedProject as described in this MMRP. Duties of the project manager include thefollowing:
Ensure that routine inspections of the construction site are conducted
by appropriate City staff; check plans, reports, and other documentsrequired by the MMRP; and conduct report activities.
Serve as a liaison between the City and the contractor or projectapplicant regarding mitigation monitoring issues.
Complete forms and maintain reports and other records anddocuments generated by the MMRP.
Coordinate and ensure that corrective actions or enforcementmeasures are taken, if necessary.
The responsible party for implementation of each item would identify the
staff members responsible for coordinating with the City on the MMRP.
REPORTING
The Citys project manager shall prepare a monitoring report, uponcompletion of the project, on the compliance of the activity with the required
mitigation measures. Information regarding inspections and other
requirements shall be compiled and explained in the report. The report shallbe designed to simply and clearly identify whether mitigation measures havebeen adequately implemented. At a minimum, each report shall identify themitigation measures or conditions to be monitored for implementation,whether compliance with the mitigation measures or conditions has occurred,the procedures used to assess compliance, and whether further action isrequired. The report shall be presented to the City Council.
MITIGATION MONITORING AND REPORTING PLAN TABLE
The categories identified in Table A are described below.
Mitigation Measure This column provides the text of themitigation measures identified in the IS/MND.
Timing This column identifies the time frame in which themitigation will take place.
Enforcement
This column identifies the party responsible forenforcing compliance with the requirements of the mitigation
measure.
Dated Signature for Verification of Compliance This column isto be dated and signed by the person (either project manager orhis/her designee) responsible for verifying compliance with therequirements of the mitigation measure.
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
Mitigation Measure Timing Implementation1 Enforcement
1
Dated Signature forVerification of Compliance
3.3 AIR QUALITYMitigation Measure AIR-1: Dust Control. During all phases of construction,
the following dust control procedures shall be implemented:
Water all active construction sites as necessary.
Cover all trucks having soil, sand, or other loose material or maintainat least two feet of freeboard on all trucks.
Apply water as necessary, or apply non-toxic soil stabilizers on all
unpaved access roads, parking areas and staging areas at construction
sites.
Sweep if visible soil material is carried into adjacent streets.
Water or apply non-toxic soil binders to exposed soil stockpiles.
Limit traffic speeds on unpaved areas to 15 mph.
Prior to
construction of
The Proposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mendocino County Air
Quality Management District
3.4 BIOLOGICAL RESOURCES
Mitigation Measure BIO-1: Conduct Breeding/Nesting Surveys. Forconstruction activities that occur between February 1 and August 31,
preconstruction breeding bird surveys shall be conducted by a qualified biologist
prior to and within 10 days o f any initial ground-disturbance activities. Surveysshall be conducted within all suitable nesting habitat within 250 feet of the
activity. All active, non-status passerine nests identified at that time should be
protected by a 50 foot radius minimum exclusion zone. Active raptor or special-status species nests should be protected by a buffer with a minimum radius of
200 feet. CDFW and USFWS recommend that a minimum 500-foot exclusion
buffer be established around active white-tailed kite and golden eagle nests. Thefollowing considerations apply to this mitigation measure:
Survey results are valid for 14 days from the survey date. Should
ground disturbance commence later than 14 days from the survey date,surveys should be repeated. If no breeding birds are encountered, then
work may proceed as planned.
Exclusion zone sizes may vary, depending on habitat characteristics
and species, and are generally larger for raptors and colonial nestingbirds. Each exclusion zone would remain in place until the nest is
abandoned or all young have fledged.
Prior to and duringconstruction of the
Proposed
Project/Action.
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
California Department of Fishand Wildlife
U.S. Fish and WildlifeService
1The City of Ukiahs Public Works Department is primarily responsible for implementing the mitigation measures for the Proposed Project/Action as described in this MMRP.
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
Mitigation Measure Timing Implementation1 Enforcement
1
Dated Signature forVerification of Compliance
The non-breeding season is defined as September 1 to January 31.
During this period, breeding is not occurring and surveys are not
required. However, if nesting birds are encountered during workactivities in the non-breeding season, disturbance activities within a
minimum of 50 feet of the nest should be postponed until the nest isabandoned or young birds have fledged.
Mitigation Measure BIO-2: Conduct A Preconstruction Survey for Western
Pond Turtles and Relocate, if Necessary. A qualified biologist shall conduct apre-construction survey for western pond turtles no more than 30 days prior to
construction in suitable aquatic habitats within the project corridor, including
stream crossings, drainage ditches, and culverts. A combination of visual and
trapping surveys may be performed with authorization from CDFW. If the
species is found near any proposed construction areas, impacts on individuals
and their habitat shall be avoided to the extent feasible. If occupied habitat can be
avoided, an exclusion zone shall be established around the habitat and temporary
plastic fencing shall be installed around the buffer area with Sensitive Habitat
Area signs posted and clearly visible on the outside of the fence. If avoidance isnot possible and the species is determined to be present in work areas, thebiologist with approval from CDFW may capture turtles prior to construction
activities and relocate them to nearby, suitable habitat a minimum of 300 feet
downstream from the work area. Exclusion fencing should then be installed iffeasible to prevent turtles from reentering the work area. For the duration of work
in these areas the biologist should conduct monthly follow-up visits to monitor
effectiveness.
Prior to and during
construction of theProposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
California Department of Fish
and Wildlife
Mitigation Measure BIO-3: Avoid cutting through the creeks. As described
in the Proposed Project/Action description, all of the creek crossings will be
crossed by using trenchless construction techniques in the dry season.
Specifically, no pipeline construction activities shall occur between December 1
and May 31 (a work window identified by the National Marine Fisheries
Service), which is the period when adult and juvenile salmonids are likely tooccur in the Russian River. Construction crews shall avoid entering the stream
channels during installation.
Prior to and during
construction of the
Proposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
North Coast Regional WaterQuality Control Board
National Marine FisheriesService
Mitigation Measure BIO-4: Implement Construction Best ManagementPractices. To reduce potentially significant erosion and siltation, the City and/or
its selected contractor(s) shall obtain a Stormwater Pollution Prevention Permit
(SWPPP) and implement Best Management Practices and erosion controlmeasures as required by the North Coast RWQCB. Best Management Practices
to reduce erosion and siltation shall include, at a minimum, the following
Prior to theconstruction of
the Proposed
Project
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
North Coast Regional WaterQuality Control Board
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
Mitigation Measure Timing Implementation1 Enforcement
1
Dated Signature forVerification of Compliance
measures: Avoidance of construction activities during inclement weather;
limitation of construction access routes and stabilization of access points;
stabilization of cleared, excavated areas by providing vegetative buffer strips,
providing plastic coverings, and applying ground base on areas to be paved;
protection of adjacent properties by installing sediment barriers or filters, or
vegetative buffer strips; stabilization and prevention of sediments from surfacerunoff from discharging into storm drain outlets; use of sediment controls and
filtration to remove sediment from water generated by dewatering; and returning
all drainages to preconstruction conditions. Construction crews shall avoid
entering the stream channels during installation.
Mitigation Measure BIO-5: Develop and Implement a Frac-OutContingency Plan for Trenchless Construction Activities. For trenchless
construction activities that use drilling lubricants, the City or its contractor shall
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 minimum -
impact 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.
Trenchless construction activities to be conducted during a work
window identified by the National Marine Fisheries Service when adultand juvenile salmonids are not present in the project area (June 1
through November 30).
A full-time monitor will attend all drilling to look for observable frac-
out conditions or lowered pressure readings on drilling equipment. 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 frac-out will be determined, and
the frac-out will be monitored for 4 hours to determine whether thedrilling 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 beremoved.
Prior to and duringconstruction of the
Proposed
Project/Action.
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
Mitigation Measure Timing Implementation1 Enforcement
1
Dated Signature forVerification of Compliance
as is and shall not be modified by grading or expanded in width.
Mitigation Measure CR-2: Halt work if cultural resources are discovered. In the event that any prehistoric or historic subsurface cultural resources are
discovered during ground disturbing activities, all work within 100 feet of the
resources shall be halted and after notification, the City shall consult with aqualified archaeologist to assess the significance of the find. If any find is
determined to be significant (CEQA Guidelines 15064.5[a][3] or as unique
archaeological resources per Section 21083.2 of the California Public Resources
Code), representatives of the City and a qualified archaeologist shall meet todetermine the appropriate course of action. In considering any suggested
mitigation proposed by the consulting archaeologist in order to mitigate impacts
to historical resources or unique archaeological resources, the lead agency shall
determine whether avoidance is necessary and feasible in light of factors such as
the nature of the find, project design, costs, and other considerations. If
avoidance is infeasible, other appropriate measures (e.g., data recovery) shall be
instituted. Work may proceed on other parts of the project site while mitigationfor historical resources or unique archaeological resources is carried out.
Upon discovery ofcultural resources
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
Mitigation Measure CR-3: Stop work if paleontological remains arediscovered. If paleontological resources, such as fossilized bone, teeth, shell,
tracks, trails, casts, molds, or impressions are discovered duringground-disturbing activities, work will stop in that area and within 100 feet of the
find until a qualified paleontologist can assess the significance of the find and, if
necessary, develop appropriate treatment measures in consultation with the City.
Before and during
ground-disturbing
activities.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mitigation Measure CR-4: Halt work if human remains are found. If
human remains are encountered during excavation activities conducted for the
Proposed Project/Action, all work in the adjacent area shall stop immediately and
the Mendocino County Coroners office shall be notified. If the Coroner
determines that the remains are Native American in origin, the Native American
Heritage Commission shall be notified and will identify the Most Likely
Descendent, who will be consulted for recommendations for treatment of thediscovered human remains and any associated burial goods.
Upon the
discovery of
suspected human
remains.
City of Ukiah Public
Works Department
For actions taken to satisfy
the requirements of Section
106: the State Historic
Preservation Office (SHPO)
For all project-related
improvements that would belocated within the City of
Ukiah and County of
Mendocino: City of UkiahPublic Works Department and
Mendocino County Coroner
3.6 GEOLOGY AND SOILS
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
Mitigation Measure Timing Implementation1 Enforcement
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Dated Signature forVerification of Compliance
Mitigation Measure GEO-1: Perform Geotechnical Investigation. The City
shall require a design-level geotechnical study to be prepared prior to project
implementation to determine proper design and construction methods, including
any cathodic protection measures needed for installing the pipelines in these soils
as well as the design of the storage pond(s). The geotechnical study shall
evaluate the potential for impacts to groundwater by determining soil permabilityand other characteristics that affect water movement, in addition to issues related
to erosion and seismic hazards.
Prior to
completion of
engineering plans
for the Proposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
3.8 HAZARDS AND HAZARDOUS MATERIALS
Mitigation Measure HAZ-1: Store, Handle, Use Hazardous Materials in
Accordance with Applicable Laws. The City shall ensure that all construction-
related hazardous materials and hazardous wastes shall be stored, handled, and
used in a manner consistent with relevant and applicable federal, state, and local
laws and done in a manner that protects surface waters and groundwater. In
addition, construction-related hazardous materials and hazardous wastes shall be
staged and stored away from stream channels and steep banks to keep these
materials a safe distance from near-by residents and prevent them from entering
surface waters in the event of an accidental release. Additionally, the City shalldevelop a spill contingency plan that addresses measures to address spills andleaks of hazardous materials as well as appropriate use of adequate storage
containers for containment.
Prior to
construction and
operation the
Proposed
Project/Action
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mitigation Measure HAZ-2: Properly Dispose of Contaminated Soil and/or
Groundwater. If contaminated soil and/or groundwater is encountered or if
suspected contaminated is encountered during project construction, work shall be
halted in the area, and the type and extent of the contamination shall be
identified. A contingency plan to dispose of any contaminated soil orgroundwater will be developed through consultation with appropriate regulatory
agencies.
Prior to
construction and
operation the
Proposed
Project/Action
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mitigation Measure HAZ-3: Properly Dispose of Hydrostatic Test Water. Dewatering and of the pipeline during hydrostatic testing in the construction
phase as well as any dewatering needed as a result of operations and maintenance
activities shall be discharged to land and not into any creeks, drainages, or
waterways and shall require prior approval from the North Coast Regional Water
Quality Control Board.
Prior toconstruction and
operation the
Proposed
Project/Action
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
Mitigation Measure HAZ-4: Consult with FAA, Ukiah Municipal Airport,
USFWS, and CDFW. The City shall initiate consultation with the Ukiah
Municipal Airport operations manager as well as with the FAA, USFWS, and
CDFW to disclose plans for developing the new wastewater storage facility and
Prior to
construction and
operation the
Proposed
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Ukiah Municipal Airport
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Dated Signature forVerification of Compliance
seek their input resulting in the development of a specific plan and/or
management activities to avoid or reduce the potential for attracting hazardous
wildlife movement into or across the approach or departure airspace.
Project/Action.
Federal Aviation
Administration
California Department of Fish
and Wildlife
U.S. Fish and Wildlife
Service
Mitigation Measure HAZ -5: Develop and Maintain Emergency AccessStrategies. In conjunction with Mitigation Measure Traffic-1: Develop a Traffic
Control Plan identified below in the Traffic and Transportation section,comprehensive strategies for maintaining emergency access shall be developed.
Strategies shall include, but not limited to, maintaining steel trench plates at the
construction sites to restore access across open trenches and identification of
alternate routing around construction zones. Also, police, fire, and other
emergency service providers shall be notified of the timing, location, and
duration of the construction activities and the location of detours and lane
closures.
Prior to
construction and
operation theProposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
3.9 HYDROLOGY AND WATER QUALITY
Mitigation Measure HWQ-1: Implement Construction Best Management
Practices. To reduce potentially significant erosion and siltation, the City and/or
its selected contractor(s) shall obtain a Stormwater Pollution Prevention Permit
(SWPPP) and implement Best Management Practices and erosion control
measures as required by the North Coast RWQCB. Best Management Practicesto reduce erosion and siltation shall include the following measures: Avoidance
of construction activities during inclement weather; limitation of construction
access routes and stabilization of access points; stabilization of cleared,excavated areas by providing vegetative buffer strips, providing plastic
coverings, and applying ground base on areas to be paved; protection of adjacent
properties by installing sediment barriers or filters, or vegetative buffer strips;
stabilization and prevention of sediments from surface runoff from discharginginto storm drain outlets; use of sediment controls and filtration to remove
sediment from water generated by dewatering; and returning all drainage patterns
to pre-existing conditions.
Develop SWPPP
prior to and
throughout
construction.
City of Ukiah Public
Works DepartmentCity of Ukiah Public Works
Department
North Coast Regional Water
Quality Control Board
Mitigation Measure HWQ-2: Implement Recycled Water Best ManagementPractices. In order to help reduce the potential effects of increased salt loading
potential as a result of using recycled water, the City shall:
Ensure that water is applied consistent with Title 22 requirements and in amounts
Incorporation
measures into
SWPPP prior toconstruction and
implementation
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
North Coast Regional
Water Quality Control Board
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
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Dated Signature forVerification of Compliance
(frequency and intensity) which meet the demands of the plant (agronomic rates),
but not in excessive amounts such that salts buildup in the soil beyond the rootzone and/or otherwise are leached to groundwater;
Ensure that adequate soil drainage is maintained;
Ensure that salt-sensitive plants are not to be spray wet; and
Addressing sodium and alkalinity concerns through addition
of water and soil amendments, including addition of gypsum.
In addition and prior to operation of the recycled water system, the City shall
prepare and submit for approval of the North Coast Regional Water QualityControl Board, a recycled water operations and maintenance plan and recycled
water users guide to identify general and site-specific BMPs that will be
implemented to ensure that recycled water will be used in a manner that protectsground and surface water. The BMPs shall address measures to protect against
recycled water runoff that is not incidental, provide for detection and correction
of leaks, and ensure that pollutants such as salts and nutrients are not discharged
at concentrations that could adversely impact groundwater. The BMPs shall also
address both agronomic irrigation and frost protection uses.
Specifically, the recycled water for irrigation BMPs shall include the type of
irrigation system, proper design and operation of the irrigation system,
application methods (e.g., agronomic application, use of repeat start times and
multiple water days to increase irrigation efficiency and reduce runoff potential,
no application during precipitation events), setbacks to surface waters, physicalsystems to capture runoff and prevent it from reaching surface waters. BMPs
shall also describe how salts and nutrients will be managed in a manner that
protects groundwater quality.
Frost protection BMPs shall include limiting frost protection use to relatively flat
parcels, use of very low application rates for the shortest period possible, pre-season system inspections and testing, regular in-season system checks,
inspection checks during spray events that include checking for ponding and
runoff, logging of spray events, and maintenance of a cover crop between
vineyard rows to provide capacity for retention and limited treatment.
throughout
construction,
as appropriate
Mitigation Measure HWQ-3: Prepare Antidegradation Analysis. Prior to
implementation, the City shall prepare and submit to the North Coast RegionalWater Board an antidegradation analysis as part of its Report of Waste Discharge
that demonstrates that the storage and irrigation of recycled water will not result
in degradation of groundwater or surface water. The analysis shall identify thefate and transport of pollutants of concern, and shall address salts, nutrients, and
Development of
the Report ofWaste Discharge.
City of Ukiah Public
Works DepartmentCity of Ukiah Public Works
Department
North Coast Regional
Water Quality Control Board
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Table AMitigation Monitoring and Reporting Plan for theCity of Ukiahs Recycled Water Project IS/MND
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any other pollutants that could be present in the recycled water at concentrations
that could affect groundwater quality. For the pond(s), the analysis shall
determine the leakage rate through the pond liner and the impact of pond leakage
on groundwater and nearby surface water. The analysis shall determine whether
there are any anticipated increases in pollutant concentrations over background
groundwater quality. If any potential degradation is identified, the analysis shalldemonstrate that any degradation is in the best interest of the people of the state
and that it will not result in the exceedance of any groundwater quality
objectives. This antidegradation analysis shall be prepared and submitted as part
of a Report of Waste Discharge.
3.12 NOISEMitigation Measure NOI-1: Limit Construction Hours. Construction
activities will be limited to the least noise-sensitive times and will comply with
both the City and Mendocino County noise ordinances. Construction, alteration,
repair or land development activities shall be allowed on weekdays between thehours of 7 a.m. and 7 p.m., on Saturdays between the hours of 8 a.m. and 5 p.m.
No construction shall be permitted on Sundays.
Prior to and during
construction of the
Proposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mitigation Measure NOI-2: Locate Staging Areas away from SensitiveReceptors.The Citys construction specification shall require that the contractor
select staging areas as far as feasibly possible from sensitive receptors.
Prior to and during
construction of the
Proposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mitigation Measure NOI-3: Maintain Mufflers on Equipment. The Citysconstruction specifications shall require the contractor to maintain all
construction equipment with manufacturers specified noise-muffling devices.
Prior to and duringconstruction of the
Proposed
Project/Action.
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
Mitigation Measure NOI-4: Idling Prohibition and Enforcement. The City
shall prohibit and enforce unnecessary idling of internal combustion engines. In
practice, this would mean turning off equipment if it will not be used for five or
more minutes.
Prior to and during
construction of the
Proposed
Project/Action.
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
Mitigation Measure NOI-5: Equipment Location and Shielding. The Cityshall require locating all stationary noise-generating construction equipment such
as air compressors as far as possible from homes and businesses.
Prior to and duringconstruction of the
Proposed
Project/Action.
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment
3.17 TRAFFIC AND TRANSPORTATION
Mitigation Measure TRA-1: Prepare and Implement Traffic Control Plan.
As is consistent with existing policy, the City shall require the contractor to
Prior to and during
construction of the
Proposed
City of Ukiah Public
Works Department
City of Ukiah Public Works
Department
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prepare and implement effective traffic control plans in the areas of City and
County streets to show specific methods for maintaining traffic flows. Examples
of traffic control measures to be considered include: 1) use of flaggers to
maintain alternating one-way traffic while working on one-half of the street; 2)
use of advance construction signs and other public notices to alert drivers of
activity in the area; 3) use of positive guidance detour signing on alternateaccess streets to minimize inconvenience to the driving public; 4) provisions for
emergency access and passage; and 5) designated areas for construction worker
parking.
Project/Action.
Mitigation Measure TRA-2: Return Roads to Pre-construction Condition. Following construction, the City shall ensure that road surfaces that are damaged
during construction are returned to their pre-construction condition or better.
Prior to and duringconstruction of the
Proposed
Project/Action.
City of Ukiah PublicWorks Department
City of Ukiah Public WorksDepartment