Ukiah Recycled Water Project - Final IS-MND 5-22-2013

8/10/2019 Ukiah Recycled Water Project - Final IS-MND 5-22-2013

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City of UkiahRecycled Water Project

Final Initial Study / Mitigated Negative DeclarationSCH #2013032072

Prepared by:


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City of Ukiah Recycled Water ProjectFinal IS/MND

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-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

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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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3

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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4

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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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.


Works Department


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.


Works Department


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



North Coast Regional WaterQuality Control Board


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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.


Proposed

Project/Action.




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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



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.


Works Department


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.


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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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.


Works Department


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


Works Department


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


Works Department


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



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


Works Department


Department

Ukiah Municipal Airport


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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.


Works Department


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.


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


Works Department


Department

North Coast Regional

Water Quality Control Board


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(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.


Works DepartmentCity of Ukiah Public Works

Department

North Coast Regional

Water Quality Control Board


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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.


Works Department


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.


Works Department


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.


Proposed

Project/Action.



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.


Works Department


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.


Proposed

Project/Action.



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


Works Department


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.


Proposed

Project/Action.



Documents

Ukiah Recycled Water Project - Final IS-MND 5-22-2013