DEIR Appendix A

Appendix A
Scoping Report for the Pure Water Monterey

Groundwater Replenishment Project Environmental
Impact Report
Pure Water Monterey GWR Project

Draft EIR
April 2015
Denise Duffy & Associates, Inc.
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Draft EIR
April 2015
DeniseDuffy&Associates,Inc.
PLANNING AND ENVIRONMENTAL CONSULTING
SCOPINGREPORT
forthe
PUREWATERMONTEREY
GROUNDWATERREPLENISHMENTPROJECT
ENVIRONMENTALIMPACTREPORT
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Preparedby:
InassociationwithValerieYoung,HazenandSawyer
Preparedfor:
MontereyRegionalWaterPollutionControlAgency
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TABLE OF CONTENTS
1. INTRODUCTION ................................................................................................... 1
2. PURPOSE OF SCOPING PROCESS .............................................................................. 1
3. OVERVIEW OF SCOPING PROCESS ............................................................................ 3
3.1 Mailing List .......................................................................................................................................... 3
3.2 Notice of Preparation.......................................................................................................................... 3
3.3 Other Notifications ............................................................................................................................. 3
3.4 Public Scoping Meeting ....................................................................................................................... 4
4. SUMMARY OF SCOPING COMMENTS......................................................................... 4

4.1 List of Letters/Commenters and Acronyms ....................................................................................... 6
List of Commenters at the Public Scoping Meeting .............................................................................. 6
4.2 Comments on General CEQA and Procedural Issues ......................................................................... 7
4.3 Comments on Project Description and Alternatives .......................................................................... 8
4.4 Comments on NEPA Process, including Federal Regulatory Compliance ........................................ 11
4.5 Comments on Permits/Authorizations/Agreements/Rights of Way ............................................... 11
4.6 Comments on Specific EIR Topical Issues......................................................................................... 13
Agriculture and Forestry ..................................................................................................................... 13
Air Quality/Greenhouse Gas ............................................................................................................... 13
Biological Resources............................................................................................................................ 13
Climate Change Effects on Project ...................................................................................................... 14
Cultural Resources .............................................................................................................................. 14
Hazards / Public Health and Safety related to Drinking Water Quality .............................................. 14
Land Use/Consistency with Plans/Policies .......................................................................................... 15
Groundwater Hydrology ..................................................................................................................... 16
Growth Inducing Impacts .................................................................................................................... 16
Hydrology and Water Quality: Surface Water .................................................................................... 16
Traffic during Construction ................................................................................................................. 16
Utilities ................................................................................................................................................ 17
Water Demand/Supplies ..................................................................................................................... 17
Cumulative .......................................................................................................................................... 18
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4.7IssuesNotAnalyzedunderCEQA.....................................................................................................18
Economics/Cost..................................................................................................................................18
5.CONSIDERATIONOFISSUESRAISEDINSCOPINGPROCESS.............................................18
6.SUPPLEMENTTOTHEMAY2013NOTICEOFPREPARATION.........................................23
Tables
1. MatrixofScopingCommentsonProjectDescriptionandAlternatives..................................20
2. SummaryofCommentLettersReceivedonSupplementto2013NOP..................................24
Appendices
A.
B.
C.
D.
E.
F.
MontereyPeninsulaGroundwaterReplenishmentProject(GWR):NoticeofPreparation(NOP)
DistributionListsfortheGWRNOP
GWRPublicScopingMeetingPresentation(June18,2013)
GWRNOPCommentLetters
SupplementtoMay2013NOP
SupplementtoNOPCommentLetters
PureWaterMontereyGWRProject
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1. INTRODUCTION
In accordance with California Environmental Quality Act (CEQA) guidelines, the Monterey Regional
Water Pollution Control Agency (MRWPCA) is preparing a Draft Environmental Impact Report (EIR) for
the Monterey Peninsula Groundwater Replenishment Project (GWR Project or proposed project). The
Draft EIR will assess the potential impacts from the proposed project on the physical environment. On
May 30, 2013, MRWPCA began the CEQA scoping process to help determine issues, mitigation measures
and alternatives to be evaluated in the Draft EIR by issuing a Notice of Preparation (NOP), provided in
Appendix A. The NOP described the proposed project and identified opportunities for agencies and the
general public to submit comments on topics to be considered in the EIR. The MRWPCA also held an inperson scoping meeting on June 18, 2013; the meeting was advertised in local papers and notice also
provided in the circulated NOP. In Section 6 of this report, a summary of the Supplement to the May
2013 NOP is provided and the relevant comments received during that second scoping period are
summarized.
This report provides an overview of the scoping process for the GWR Project, and summarizes the
comments received during the scoping period. Comments from this report that are applicable to a
particular topic in the EIR are described in the introduction to that topical section of the Draft EIR.
This report is intended to summarize and document the comments received during the two scoping
periods: May 30, 2013 to July 2, 2013 and December 9, 2014 through January 8, 2015, including both
verbal and written comments. The MRWPCA will use this report as a tool to ensure that scoping
comments are considered during preparation of the Draft EIR.
2. PURPOSE OF SCOPING PROCESS

CEQA Guidelines Section 15082 specifies that, after deciding that an environmental report is required
for a project, the lead agency must send to the Office of Planning and Research and each responsible
agency and trustee agency a notice of preparation stating that an environmental impact report will be
prepared.
The notice of preparation shall provide the responsible and trustee agencies and the Office of
Planning and Research with sufficient information describing the project and the potential
environmental effects to enable the responsible agencies to make a meaningful response.
Within 30 days after receiving the notice of preparation, each responsible and trustee agency and the
Office of Planning and Research must provide the lead agency with specific detail about the scope and
content of the environmental information related to the responsible or trustee agencys area of
responsibility that must be included in the EIR. At a minimum the response shall identify:
The significant environmental issues and reasonable alternatives and mitigation measures that
the responsible or trustee agency, or the Office of Planning and Research, will need to have
explored in the draft EIR.

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In order to expedite consultation, the lead agency may request one or more meetings between
representatives of the agencies involved to assist the lead agency in determining the scope and content
of the environmental information that the responsible or trustee agency may require.
CEQA Guidelines Section 15083 recognizes that the lead agency may also consult with any person or
organization it believes will be concerned with the environmental effects of the project.
Prior to completing the draft EIR, the Lead Agency may also consult directly with any
person or organization it believes will be concerned with the environmental effects of
the project. Many public agencies have found that early consultation solves many
potential problems that would arise in more serious forms later in the review process.
This early consultation may be called scoping. Scoping will be necessary when
preparing an EIR/EIS jointly with a federal agency.
(a) Scoping has been helpful to agencies in identifying the range of actions, alternatives,
mitigation measures, and significant effects to be analyzed in depth in an EIR and
in eliminating from detailed study issues found not to be important.
(b) Scoping has been found to be an effective way to bring together and resolve the
concerns of affected federal, state, and local agencies, the proponent of the action,
and other interested persons including those who might not be in accord with the
action on environmental grounds.
(c) Where scoping is used, it should be combined to the extent possible with
consultation under Section 15082.
MRWPCA distributed the notice of preparation to responsible and trustee agencies, and to the Office of
Planning and Research, and invited responsible and trustee agencies to a scoping meeting. In addition,
MRWPCA distributed the NOP to interested members of the public and organizations, and opened the
scoping meeting to the public.
The comments provided by the public and agencies during the scoping process will help the MRWPCA
identify issues, methods of analyses, and level of detail of information and analysis in the EIR. The
scoping comments will also assist the MRWPCA in developing a reasonable range of feasible alternatives
that will be evaluated in the EIR.
Scoping comments that pertain to CEQA will be considered during the preparation of the Draft EIR.
Non-CEQA comments will be noted for the record in the final version of this scoping report. The
MRWPCA and the EIR preparers, which includes specialists in each of the environmental subject areas
covered in the EIR, will assess the comments received and determine how they should addressed. This
consideration of scoping comments is intended to ensure that the EIR is both comprehensive and
responsive to issues raised by the public and regulatory agencies, and satisfies all CEQA requirements.
Scoping is not conducted to resolve differences concerning the merits of a project or to anticipate the
ultimate decision on a proposal. Rather, the purpose of scoping is to help ensure that a comprehensive
EIR will be prepared that provides an informative basis for the decision-making process.

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3. OVERVIEW OF SCOPING PROCESS

3.1 MAILING LIST
In preparation for the scoping period, the MRWPCA developed a contact list of potentially affected
persons and agencies that would have an interest in, or jurisdiction over, project-related actions
proposed within the project area. The contact list included all known federal, state, responsible, and
trustee agencies involved in approving or funding the project, as well as relevant local agencies and
special districts with jurisdiction in the project area. The list was developed using the Monterey
Peninsula Integrated Regional Water Management (IRWM) stakeholder list, the MRWPCA noticing
distribution list, Monterey Peninsula Water Management District noticing distribution list, and the
Greater Monterey County IRWM Regional Water Management Group.
3.2 NOTICE OF PREPARATION

A Notice of Preparation was prepared in compliance with the CEQA Guidelines Section 15082 (Appendix
A). The NOP solicited comments on the scope of environmental issues as well as alternatives and
mitigation measures that should be explored in the EIR. The NOP provides background information on
relevant water supply conditions, briefly describes the proposed GWR Project, identifies the location of
the project and describes the probable environmental issue effects of the project to be analyzed in the
EIR. Public agencies were invited to comment on the scope and content of the environmental
information that is relevant to each agencys statutory responsibilities with regard to the proposed GWR
Project. Members of the public were also invited to provide their comments on the scope of the EIR.
The public scoping period began on May 31, 2013 and ended at 5:00 PM on Tuesday, July 2, 2013, which
provided the required 30-day scoping comment period. To initiate the required scoping period, 15
copies of the NOP with the required transmittal, were submitted via overnight mail to the Governors
Office of Planning and Research (OPR) State Clearinghouse. The OPR State Clearinghouse distributes the
NOP to applicable state agencies and departments, including the State Water Resources Control Board,
Division of Financial Assistance, a state agency division that will act as designated lead for federal
environmental regulatory compliance (i.e., CEQA-plus) for the Clean Water State Revolving Fund
Program, which is partially funded by the U.S. Environmental Protection Agency. In addition, the NOP
was distributed electronically and by mail to over 638 government agencies, non-government
organizations, private companies, and individuals (see Appendix B for an overview of NOP recipients).
3.3 OTHER NOTIFICATIONS
Notice of Availability (NOA) of the NOP was published in the following newspapers:
o Monterey Herald on June 2 and 9, 2013
o Californian Salinas on June 5 and 12, 2013
o Coast Weekly, Carmel Pine Cone and Cedar Street Times (various dates June 2012)
NOA was posted at the MRWPCA Office (5 Harris Ct, Monterey, CA 93940) and at the MRWPCA
Wastewater Treatment Plant (14811 Del Monte Boulevard , Marina, CA 93933)
NOP was posted on the MRWPCA GWR Project website

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NOP was sent to the following libraries for public posting:

o Carmel Harrison Library
o Carmel Valley Public Library
o Castroville Public Library
o California State University Monterey Bay Library
o Marina Library
o Monterey Library
o Monterey Peninsula College Library
o Pacific Grove Library
o Salinas Public Library
o Seaside Library
MRWPCA also made additional outreach efforts for the public scoping meeting through print and social
media. A press release was sent to media outlets in the Monterey Bay region identifying the project, the
NOP scoping period and the date and time for the public scoping meeting. An evite event invitation
was also set up on social media for the NOP Public Scoping meeting with a link to the GWR website
reaching approximately 150 people.
3.4 PUBLIC SCOPING MEETING

The MRWPCA held a public scoping meeting on Thursday, June 18, 2013 from 6:00 to 8:00 PM at the
Oldemeyer Center: Dance Hall Room, 986 Hilby Avenue, Seaside, CA 93955. The scoping meeting included
a presentation of the information contained in the NOP, an overview of the CEQA process, and provided
attendees an opportunity to comment on the scope of the EIR (see presentation in Appendix C-1). A total
of 37 people attended the scoping meeting including: government representatives, non-governmental
organizations, and local citizens (see Appendix C-2). Comments received during the scoping meeting were
documented during the meeting on flipcharts (see Appendix C-3), and also summarized in meeting notes
(see Appendix C-4).
4. SUMMARY OF SCOPING COMMENTS

During the scoping period, MRWPCA received comments in the form of personal communication (from
one individual), emails, and letters. Verbal comments were received at the scoping meeting held on
June 18, 2013. This section contains a summary of all verbal and written comments received. The
meeting notes from the scoping meeting are included in Appendix C-3 and C-4 and copies of written
comments are included in Appendix D.
The MRWPCA consultant team and staff reviewed all of the scoping comments, numbered the individual
comments within each letter, prepared a one- to two-sentence summary of each comment, and
grouped the comments into the following issue, and sub-issue categories:
General/Procedural Comments
Comments on Project Description and Alternatives [Note: A matrix of the type of
comment, or sub-issue category, within this general category of comments is also provided.]

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National Environmental Policy Act Process, including Federal Regulatory Compliance

Permits/Authorizations/Agreements/Rights of Way
Comments on Specific EIR Topical Issues
o Agriculture and Forestry
o Air Quality/Greenhouse Gas
o Biological Resources
o Climate Change Effects on Project
o Cultural Resources
o Hazards / Public Health and Safety related to Drinking Water Quality
o Land Use/Consistency with Plans and Policies
o Groundwater Hydrology
o Growth Inducing Impacts
o Hydrology and Water Quality: Surface Water
o Traffic during Construction
o Utilities
o Water Demand/Supplies
o Cumulative Impacts
Issues Not Analyzed under CEQA
o Economics /Cost, except as it may result in indirect physical impacts to the environment
The comment summaries seek to capture the main point of every comment in a way that will facilitate
addressing the comment in the EIR and the CEQA process, more generally. The full version of comment
letters are provided in Appendix D and this Appendix should be reviewed together with this scoping
report. [Some individual comments apply to multiple topical areas, and will be considered in all
pertinent topical areas of the EIR.]

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4.1 LIST OF LETTERS/COMMENTERS AND ACRONYMS

A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
O.
P.
Q.
R.
S.
T.
U.
Eleanor Citen (EC)

Water Plus (WP)
State Water Resources Control Board (SWRCB)
U.S. Army Garrison, Presidio of Monterey, Directorate of Public Works, Master Planning (USA POM)
Department of Parks and Recreation (DPR)
Coalition of Peninsula Businesses (CPB)
Farm Bureau Monterey (FBM)
Monterey County Resource Management Agency (MCRMA)
California State Lands Commission, Division of Environmental Planning and Management (CSLC)
Monterey Regional Waste Management District (MRWMD)
Peter Le (PL)
California Department of Public Health, Drinking Water Program, Environmental Review Unit (CDPH)
Seaside Basin Watermaster (SBW)
Monterey Peninsula Water Management District (MPWMD)
City of Pacific Grove (CPG)
City of Seaside (CSe)
City of Monterey (CM)
Marina Coast Water District (MCWD)
Fort Ord Community Advisory Group (FOCAG)
City of Salinas (CSa)
Bill Carrothers (BC)
List of Commenters at the Public Scoping Meeting

MTG-A.
Bill Carrothers
MTG-B.
Ron Weitzman (these comments were also submitted in written form Letter B)
MTG-C.
George Riley
MTG-D.
Helen Rucker
MTG-E.
Bill Carrothers (a second time)
MTG-F.
Ron Weitzman (a second time)
MTG-G.
Helen Rucker (a second time)

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4.2 COMMENTS ON GENERAL CEQA AND PROCEDURAL ISSUES

C-15: The Water Board staff requests that they receive the draft CEQA document and that they receive notice to
all associated hearings and meetings. (SWRCB)
H-5: Monterey County Resource Management Agency requests a copy of the Administrative Draft EIR.
(MCRMA)
I-1 California State Lands Commission (CSLC) is a trustee agency and if the GWR Project involves work on
sovereign lands, the CSLC will act as a responsible agency. (CSLC)
I-14: Mitigation measures should be specific, feasible and enforceable obligations. (CSLC)
K-9: Requests that MRWPCA staff make a presentation to the MCWD Board on their expectations of the MCWD
roles on this proposed project. (PL)
O-1: The City of Pacific Grove is in support of the goals to expand recycled water uses. (CPG)
O-2: Pacific Grove is developing its own recycled water project, the Pacific Grove Local Water Project, to provide
non-potable water to multiple sources. (CPG)
T-3: City of Salinas believes funding for public outreach is currently inadequate for the scale of the project. Two
large economic entities need to agree and approve the project in addition to multiple local jurisdictions,
agencies and citizen groups, state and federal entities. It is highly visible and controversial making it especially
important that good communication and agreement be attained. A broad array of media platforms need to be
used to communicate the project honestly and transparently and to avoid past mistakes. It is imperative that
the communications strategy be at the highest level of skill and effort. A rethinking of communications strategy
is in order to guarantee success, as will a rethinking of funding. (CSa)
MTG A1-1: This project will need an outstanding hydrologist that is very familiar with the Seaside Basin, a
superb water engineer, and a gifted leader.
MTG-C1: Will the EIR explore or include any of the positive impacts in addition to the negative impacts?
MTG-D1: Concerned about the outreach that was done for this meeting and the project in general; noted that
few residents were in attendance.
MTG-D2: It is important that non-experts are included in the scoping and made aware of project issues.

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4.3 COMMENTS ON PROJECT DESCRIPTION AND ALTERNATIVES

NOTE: Table 1 at the end of this report contains a matrix that summarizes the applicability of the
comment to the following issues: (1) overall project objectives, purpose and need, (2) alternatives
consideration/analysis, (3) project description: mapping / background, (4) relationship to the California
Public Utilities Commissions (CPUCs) EIR on the Monterey Peninsula Water Supply Project (MPWSP),
and (5) the various project description elements/components, including source water, treatment product
water conveyance, concentrate disposal, and injection/recharge.
D-3: The EIR should explain environmental reasons for selecting and eliminating alternative technologies, or
barriers for treatment of water. (USA POM)
F-1: The project description should be amended to establish a clearer project purpose and goal. The projects
relationship and/or inter-relationship with the regional water project pending before the CPUC should be
explained. Whether the GWR Project is intended to be a stand-alone project or as a supplement to Cal-Ams
project should be explained. (CPB)
F-8: The EIR should study the GWR project as an independent source of additional Peninsula water supply.
(CPB)
H-4: The EIR should include alternate locations of facilities to minimize environmental impacts in alternative
analysis. (MCRMA)
I-3: The EIR should provide more detailed project maps and exact locations of injection wells. (CSLC)
I-4: The CSLC identify the project objectives and the project components as described in the NOP. (CSLC)
I-5: The project description should be as precise as possible; it should describe the details of all allowable
activities and the timing and length of activities. (CSLC)
I-11: The EIR should consider the effects of sea level rise both on the project and the rate of saltwater intrusion.
A project alternative should be provided that would be more resilient to sea level rise. (CSLC)
K-2: The EIR should explain why 3,500 AFY is the target amount of water produced. The EIR should show
calculations on this based on this goal number for both existing and future conditions. (PL)
K-3: Will this project utilize the MCWD designs for modified regional treatment plant that were part of the
RUWAP project and will this portion of the GWR project be paid by MCWD? What additional work on the
regional treatment plant that will be done on this project? How does MRWPCA identify and separate all costs for
two different projects? (PL)
K-4: What are the impacts of the GWR project on the MCWD recycled water project? What is the required
separation between MRWPCA recycled pipes and MCWD recycled pipes? (PL)
K-5: The EIR should consider the alternative of recharging the Seaside Aquifer with excess inter flow water from
the Salinas River. (PL)
K-6: How do the discharges of the proposed advanced water treatment plant and secondary source water affect
the MCWD brine disposal capacity and the total capacity of the existing outfalls? (PL)
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M-1: GWR project will not replenish the Seaside Groundwater Basin, as the NOP claims. It will act as an
interim storage basin for the injected water until it is pumped out for municipal use. (SBW)
M-3: The map provided in the NOP does not clearly show were the facilities are to be located; provide detailed
maps of recharge facilities. (SBW)
M-4: The NOP states that Cal Am owns 12 wells within the Seaside Groundwater Basin, this should be changed
to, Cal Am currently operates 12 production wells in the Seaside Groundwater Basin. (SBW)
M-5: The description of the Watermaster should be changed to, The Watermaster Board of Directors consists
of nine entities, one representative from each The next-to-last sentence on page seven should read, Water
levels were found to be below sea level in portions of both (i.e., add portions of) (SBW)
M-6: The secondary goal of assisting in the prevention of seawater intrusion in the Seaside Groundwater Basin
should be removed or clarified, per comment M- 1. (SBW)
M-7: Due to the known contamination in Blanco Drain and Reclamation Ditch waters, the GWR treatment
facilities should be designed to address all potential pollutants to produce water of suitable quality for injection
into the Seaside Groundwater Basin, which is used for potable water supply. (SBW)
M-8: The first sentence on page 17 should be revised to read, With groundwater levels currently below sea
level in portions of both ... (SBW)
O-3: In order to comply with State Water Board requirements for discharges to Areas of Special Biological
Significance, Pacific Grove may divert a portion of (approximately 2,500 gpm to 12,000 gpm) its storm water to
the MRWPCA treatment plant for use in the GWR project. (CPG)
O-4: Address the facilities that would be required to convey additional storm water from Pacific Grove. (CPG)
O-5: The benefits to local MS4 discharges should be acknowledged in the Project Objectives. (CPG)
P-1: Could the project scope be expanded to also consider recharging the Carmel River as either an alternative
or as an option? (CSe)
P-4: Project design is not finalized and the NOP contains language describing possible adverse constraints;
change language to allow flexibility in the final project design to facilitate project implementation. (CSe)
P-5: Please clarify the areas and how much land in the City of Seaside are being referred to as the Coastal
Recharge Facilities and the Inland Recharge Facilities as shown in Figure 2. (CSe)
P-6: Correct or clarify the NOP statement that the proposed inland recharge facilities are within a City-planned
utility corridor; no City-planned utility corridor in the area shown in Figure 2. (CSe)
P-7: Please clarify where the four deep injection wells noted under the description of Inland Recharge Facilities
on page 17 would be built, including well containment, back flush pit, fencing, treatment facility, etc. (CSe)
P-9: Clarify or remove page 17 statement regarding recharge ability of shallower wells in the Coastal Recharge
Facilities. The statement describes the potential facilities but also appears to discount the value of the facilities
when addressing recharge capability. (CSe)
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P-10: Clarify statement on page 17 of NOP regarding available land within the City of Seaside. Suggest The
locations for the proposed coastal recharge facilities were determined based on an analysis of potentially
available land and known aquifer characteristics. (i.e., add potentially) (CSe)
Q-1: Concerns about the process and rationale behind the project definition. In order to ensure an adequate
environmental review the definition and understanding of the project must be clear, for this the scope of the
project might need revision. Lack of clarity behind the background of how the project scope was defined. If
revision is necessary, now is a good time for it. (CM)
Q-2: Has MRWPCA considered sources water from the perspective of dry weather patterns or wet weather
flows from storm drains? Identification of sources is not consistent in the NOP. (CM)
Q-5: Will there be any credits to member entities for flows that go into the GWR and if there are, will there be
any quantification of what those credits will be? (CM)
R-2: Encourages MRWPCA to explore alternative source water volumes above the 3,500 AFY total specified in
the NOP. (MCWD)
R-4: Requests inclusion of potential for use of Marina Coast Water Districts recycled water facilities for
conveyance of GWR water from AWT facility to Seaside Groundwater Basin, given appropriate compensation to
the district for that access. (MCWD)
R-5: Recommends exploration of long-term plan for GWR Project. Will project continue injecting water into the
Seaside Groundwater Basin once the Basin is recharged and operating within protective groundwater elevations
and sustainable yield? Are there other uses for AWT water? Sending AWT water north to combat seawater
intrusion in the Salinas Valley Groundwater Basin is a possibility. (MCWD)
R-6: MCWD encourages MRWPCA to evaluate alternatives that include variable seasonal flow rates of source
waters without the need for including secondary or tertiary effluent sources. The seasonal flow of water
sources for the AWT facility is an operational consideration if the outflow is to be at a single predictable rate.
(MCWD)
T-4: Recommends clarification and emphasis on projects independent justification, purpose and utility. This is
especially true for any desalination project, there is a lot of discussion of them as though they are connected.
(CSa)
T-5: Regarding options A and B pipeline routing, between City of Salinas agricultural wash water settling ponds
and the MRWCPA treatment facilities, please also address the pipeline from City of Salinas pump station to
treatment facilities. (CSa)
T-7: Recommend clarification about whether source waters are from one specific source or a combination of
the following sources and delineate how the determination will be made, and when. (CSa)
T-8: Recommend that MRWPCA remain flexible, if possible, with regard to detail of pipe size, capacity, pump
location and size. That CEQA studies focus on routing and environmental factors rather than system design as
that is not yet finalized. Also, if more than 3,500 AFY can be sourced, would environmental processing need to
be repeated or is it possible to avoid going through the process again if system capacity were to increase? (CSa)
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T-9: Regarding page 13, recommend that MRWPCA consider two conveyance pipelines be laid rather than one,
for both source and recycled water. This would accomplish both cost savings and give MRWPCA a leg up as a
regional source of recycled water. The second pipeline may remain temporarily unused, but could be put to use
later for recycled water or for greater intake of source water and the economics of scale would be very
beneficial in the long term. (CSa)
MTG-C2: Will other alternatives to the project (besides those already included) be addressed in the EIR?
MTG-F1: Is it possible that a larger scale version of the GWR project can solve the entire water supply issue,
therefore eliminating the need for a desalination plant?
4.4 COMMENTS ON NEPA PROCESS, INCLUDING FEDERAL REGULATORY COMPLIANCE

C-3: The CWSRF Program is partially funded by the USEPA, and therefore, it requires CEQA-Plus environmental
documentation and review for project. The Water Board will consult directly with responsible agencies. Any
environmental issues raised by these agencies must be resolved prior to Water Board approval of CWSRF
financing. The project must demonstrate compliance with following environmental regulations (SWRCB):
Endangered Species Act Section 7 (also comment C-4) (SWRCB)

National Historic Preservation Act Section 106 (also comment C-6) (SWRCB)
Federal Clean Air Act conformity (also comment C-8) (SWRCB)
California Coastal Zone Management Act (also comment C-9) (SWRCB)
Clean Water Act Section 404 (also comment C-10) (SWRCB)
Farmland Protection Policy Act (also comment C-11) (SWRCB)
Migratory Bird Treaty Act (also comment C-12) (SWRCB)
Flood Plain Management (also comment C-13) (SWRCB)
Wild and Scenic Rivers Act (also comment C-14) (SWRCB)
T-1: Project may be eligible for federal funding. City of Salinas advises that CEQA could be used to develop
NEPA if done correctly, and assist with federal funding. (CSa)
4.5 COMMENTS ON PERMITS/AUTHORIZATIONS/AGREEMENTS/RIGHTS OF WAY

I-2: The CSLC has jurisdiction and management of Tidelands, submerged lands, and beds of navigable lakes and
waterways. All tidelands and submerged lands, granted or ungranted, as well as navigable lakes and waterways,
are subject to the protections of the Common Law Public Trust. (CSLC)
E-1: The Department is concerned about the installation of the product water pipeline within the TAMC ROW,
and the access that would be taken through FODSP. This access must be coordinated in advance (up to 18
months for temporary construction easements). Department staff should be included in any meetings that
involve the use of FODSP. (DPR)
F-2: If use of CSIP facilities are used as part of the project, the rights landowners for use of reclaimed water up
to the first 19,500 AFY and MRWPCAs right to divert any portion of that water must be explained. (CPB)
F-3: Source waters must be clearly identified and the status of agreements for acquisition must be disclosed.
Legal rights to the use the source water and then the distribution of recycled water need to be clearly
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EIR Scoping Report
March 2015
established and legal disputes must be resolved, and if necessary, water supply must be sufficient to meet the
assurances to the agricultural community and provide water for sale to Cal Am for drinking water. (CPB)
G-2: There must be a clear understanding of what water rights are used for the project. Orange County proved
that technology and science support the benefits of this type of program. (FBM)
G-3: Monterey County Farm Bureau hopes the CEQA process will identify additional water sources that can be
used to, and potential be contracted for, supplying reclaimed water for this program. (FBM)
H-1: This project will require Use Permits and Coastal Development Permits. Monterey County will be the
responsible agency. (MCRMA)
H-6: Monterey County Resource Management Agency recommends that a Pre-Application meeting be
scheduled as soon as possible. (MCRMA)
J-1: The Monterey Regional Waste Management District is responsible for approving the Electric Power
Purchase Agreement as well as approving construction access and right of way easements. (MRWMD)
K-7: What is involved in the cooperation between MRWPCA and MCWD involve as described in page 11 of the
NOP? (PL)
K-8: Has MRWPCA communicated with any staff from MCWD on its proposal to use partially completed recycled
water systems? How does this project affect MCWD access to the acquired Armstrong Ranch property? (PL)
L-1: The CDPH is responsible for issuing water permits when there are changes to water supply. The CDHP will
need to issue a new or amended water supply permit for the proposed project should the project proceed under
the alternatives described. The CDHP will be a responsible agency under CEQA. (CDPH)
L-2: The project must comply with any draft of adopted (groundwater recharge and reuse) regulations.
Frequent communication with CDPH is recommended. (CDPH)
M-10: The permit required from the Watermaster is called, Agreement for Storage and Recovery of on-Native
Water from the Seaside Groundwater Basin. (SBW)
P-2: The project proposes to use storm water as a potential water source. Does it propose to revise the
MRWPCA NPDES Permit to allow storm water to be conveyed and treated by the existing sewer facilities? (CSe)
P-11: The EIR should include Seaside Highlands Homeowners Association in the Potential Permits and
Approvals Required if some of the land being considered for Coastal Injection Wells is within their jurisdiction.
(CSe)
Q-6: Existing and pending regulatory reasons mandate the flow of both dry and some wet weather storm drain
flows to the MRWPCA STP, with the goal of removing pollutants from the receiving water (Monterey Bay). Have
there been any discussions with the State Water Resources Control Board regarding the potential for discharging
filter reject concentrate as described in the NOP into the receiving water that the diversions are intended to
protect? (CM)

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March 2015
R-3: MCWDs senior right to return water from MRWPCAs treatment plant must be recognized when discussing
available plant output. MCWD is willing to consider leasing a portion of those rights for a predetermined period.
(MCWD)
T-2: The project should attain permits as soon as possible. The Water Board can take up to two years for
issuance or revision of permits. Permitting should be done concurrently with environmental study processes.
Recommend consulting with the Water Board early to clarify the process, and to explore the possibility of
Master Permits. (CSa)
4.6 COMMENTS ON SPECIFIC EIR TOPICAL ISSUES

Agriculture and Forestry
C-11: The project must comply with the Farmland Protection Policy Act. (SWRCB)
H-3: If protected trees are to be removed, a Forest Management Plan is required. (MCRMA)
Air Quality/Greenhouse Gas
C-8: The project must be in compliance with Federal Clean Air Act by providing air quality studies. If the project
is in a non-attainment area, it must also provide a summary of estimated emission for the project, and if the
emission are above de minimis levels, but project is sized to meet the needs of the current population, show
how this increase was calculated. (SWRCB)
I-10: The EIR should include a GHG emissions analysis that identifies thresholds, calculates emissions,
determines significance, and identifies mitigation. (CSLC)
Biological Resources
C-3: The project must demonstrate compliance with following environmental regulations (SWRCB):
Endangered Species Act Section 7 (also comment C-4) (SWRCB)

California Coastal Zone Management Act (also comment C-9) (SWRCB)
Clean Water Act Section 404 (also comment C-10) (SWRCB)
Migratory Bird Treaty Act (also comment C-12) (SWRCB)
C-5: The Water Board will consult with USFWS and/or NMFS to determine of the project will have any direct or
indirect effects on federally listed threatened, endangered, or candidate species on the site and surrounding
areas. They will also identity measures to reduce such effects. (SWRCB)
E-2: The Department is concerned about construction equipment on park roads and trails, traffic control needs,
and impacts to natural resources. (DPR)
I-6: The EIR should analyze all potentially significant effects on sensitive species and habitats and identify
mitigation measures. CDFW CNDDB and USFWS Special Status Species databases should be used, and
consultation with these agencies should occur and be documented. (CSLC)
I-7: The EIR should examine if any elements of the Project would favor non-native species. CDFWs Invasive
Species Program can assist with this and help develop mitigation. (CSLC)
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March 2015
I-8: The EIR should evaluate noise and vibration impacts on fish and birds and include mitigation measures for
these impacts. Consultation with CDFW, USFWS, and NOAA is recommended. (CSLC)
I-9: The EIR should evaluate impacts to biological resources associated with frac-out, and include mitigation
measures. CSLC may request documentation of mitigation for frac-out prior to issuing a lease and provides an
example of a Contingency and Resource Protection Plan. (CSLC)
Climate Change Effects on Project
I-11: The EIR should consider the effects of sea level rise both on the project and the rate of saltwater intrusion.
A project alternative should be provided that would be more resilient to sea level rise. (CSLC)
Cultural Resources
C-3/C-6: The EIR should demonstrate compliance with the National Historic Preservation Act Section 106.
(SWRCB)
C-7: The EIR must identify Area of Potential Effects; records search request must include an area larger than the
APE. (SWRCB)
I-12: The EIR should evaluate impacts to submerged cultural resources; contact Pam Griggs (Senior Staff
Counsel) to obtain shipwrecks data. Any submerged archaeological site of submerged historic resource that has
remained in State waters for more than 50 years is significant. (CSLC)
I-13: Title to shipwrecks, archaeological sites and historic resources on or in the tide and submerged lands are
vested in the State and under jurisdiction of the CSLC. (CSLC)
Hazards / Public Health and Safety related to Drinking Water Quality
A-1: Does not support the use of wastewater in the GWR Project because it contains many chemicals. She
supported this statement with various materials from Aquafornia. She suggested that Mr. Holden attend
meetings in Southern California in order to get excess water from their OC project. (EC)
B-1: The EIR should address toxins in each potential water source. Address discharge rate and natural capacity
of Seaside aquifer and flow rate between injection and extraction wells. (WP)
D-1: The EIR should address the quality of recycled water after treatment, questions the effect of injecting
recycled wastewater on Seaside Basin groundwater quality; EIR should be thorough and flawless leaving no
unanswered questions about safe drinking water. (USA POM)
D-3: The EIR should explain the environmental reasons for selecting and eliminated alternative technologies, or
barriers for treatment of water. (USA POM)
F-4: The EIR should include previously conducted studies showing contamination of the source waters. It should
also explain how the contamination will be dealt with to meet California Department of Public Health standards.
Examples of this should be provided. (CPB)
K-7: What is the current residence time of the recharged water as specified by the State? (PL)

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March 2015
M-7: Due to the known contamination in Blanco Drain and Reclamation Ditch waters, the GWR treatment
facilities should be designed to address all potential pollutants to produce water of suitable quality for injection
into the Seaside Groundwater Basin, which is used for potable water supply. (SBW)
R-7: The EIR should confirm with CDPH the required residence time between injection and extraction for all
proposed water sources prior to the publication of the Draft EIR. (MCWD)
R-8: The EIR should confirm that the capacity of the Seaside Groundwater Basin is sufficient, within that
predetermined residence time, for the injection of the GWR project water. (MCWD)
S-1: The EIR scope should include assessing existing hazards to drinking water, potential increasing hazards due
to migration and leaching of toxic chemicals from former training ranges. (FOCAG)
S-2: Fort Ord is a National Superfund Site, with known contamination of area groundwater; consider the
possibility of leaching and migration of chemicals into underground aquifers. Concern for whether the full
extent of contamination, including constituents below thresholds, is known and whether these chemicals are a
health hazard. Are the human health risks known for this level of exposure? What are the synergistic effects of
munitions chemicals and pesticides on organisms? Are there studies available on the effects of low level
exposure to these chemicals? (FOCAG)
S-3: The commenter expressed concerns for public communication, identification, record keeping, reporting,
out-gassing, and clean-up/remediation of chemicals and pesticides at very low levels in training areas,
including Site #39 (including those in Tables 3, 4, 5, and 6 attachment to letter). (FOCAG)
S-4: Review of the cited cleanup documents did not support the Armys claim that presence of pesticides were
evaluated and addressed by clean-up activities. There are several hundred chemicals potentially leaching out of
ordnance into the ground as well as residual chemicals from weapons/ordnance training and pyrotechnics.
Herbicides were widely used. (FOCAG)
S-5: The detection equipment used to clear this site is incapable of detecting nonmetallic, and deeply buried
munitions. Munitions found onsite may not be reliably detected within 4 feet of the surface. (FOCAG)
S-6: a) What is the migration and fate of munitions and pesticide chemicals into this drinking water supply? b)
Where did all the chemicals go? c) What Fort Ord document fully investigated the potential munitions and
pesticide contamination? d) Is there ongoing monitoring and reporting of the potential munitions and pesticide
contamination of the Seaside Groundwater Basin? Where is it? e) What might construction, development, and
irrigating in the area above the Seaside Groundwater Basin do for migrating chemicals? (FOCAG)
Land Use/Consistency with Plans/Policies
H-1: The EIR should include an analysis of the projects consistency with the Monterey County General Plan,
Land Use Plans, Title 20 and Title 21; this analysis should include appropriate maps. (MCRMA)
P-6: The NOP references a location for the proposed inland recharge facilities and states that it is a City planned
utility corridor. This is not accurate as there is no City planned utility corridor in the area shown in Figure 2.
Please clarify this point. (CSe)
R-1: MCWD encourages incorporation of GWR with the Greater Monterey County Integrated Regional Water
Management Plan (IRWMP) and Monterey Peninsula IRWMP. (MCWD)
EIR Scoping Report
15

March 2015
Groundwater Hydrology
(Note: Some of these comments are related to Hazards/Public Health, so are also included in that topical issue.)
B-1: The EIR should address discharge rate and natural capacity of Seaside aquifer and flow rate between
injection and extraction wells. (WP)
K-7: What is the current State-required residence time of recharged water? (PL)
M-1: The GWR project will not replenish the Seaside Groundwater Basin, as the NOP claims. It will act as an
interim storage basin for the injected water until it is pumped out for municipal use. (SBW)
N-1: Monitoring of the Santa Margarita aquifer shows that not all water injected would be expected to be
extracted; this effect should be better understood. (MPWMD)
N-2: The EIR should contain an evaluation of both the travel time and volume of water moved between
injection and extraction sites in order to determine what portion of injected water can be safely extracted and
when. To minimize the potential of seawater intrusion a buffer amount of water could be injected before
extraction occurs. (MPWMD)
R-7: The EIR should confirm with CDPH the required residence time between injection and extraction for all
proposed water sources prior to the publication of the Draft EIR. (MCWD)
R-8: The EIR should provide information on whether the capacity of the Seaside Groundwater Basin is sufficient,
within that predetermined residence time, for the injection of the GWR project water. (MCWD)
R-9: MCWD requests confirmation from CDPH of the horizontal distance required between points of injection
and extraction in the event those two modes of operation are simultaneously occurring, prior to producing the
Draft EIR. Will spacing and limited horizontal distance between recharge facility and Bay preclude the use of the
facility for GWR? (MCWD)
Growth Inducing Impacts
F-7: The EIR should include a review of the growth-inducing impacts associated with this project. (CPB)
Hydrology and Water Quality: Surface Water
K-5: How do the discharges of the proposed advanced water treatment plant and secondary source water affect
the MCWD brine disposal capacity and the total capacity of the existing outfalls? (PL)
Q-7: Existing and pending regulatory reasons mandate the flow of both dry and some wet weather storm drain
flows to the MRWPCA STP, with the goal of removing pollutants from the receiving water (Monterey Bay). Have
there been any discussions with the State Water Resources Control Board regarding the potential for discharging
filter reject concentrate as described in the NOP into the receiving water that the diversions are intended to
protect? (CM)
MTG-E3: The EIR should address the quality of water that would be sent to the outfall location as opposed to
that of the water sent to Seaside for injection.
MTG-E1: The EIR should include information about industrial and environmental hygiene.
Traffic during Construction
EIR Scoping Report
16

March 2015
E-2: The Department of Parks and Recreation is concerned about construction equipment on park roads and
trails, traffic control needs and impacts to natural resources. (DPR)
H-2: Construction staging areas should be described in the project description and temporary construction
impacts should be included in a traffic analysis. (MCRMA)
P-8: The EIR should provide information regarding traffic control and construction to coordinate with the City of
Seaside on the implementation of the underground pipeline within the City. (CSe)
Utilities
P-3: Space is limited in the Product Water Conveyance Alignment (Option 2) right of way that follows Cal-Ams
proposed pipeline alignment. It is a public right of way in the City of Seaside that would be significantly
disruptive. MRWPCA and Cal-Am should coordinate installation to minimize impacts. (CSe)
Water Demand/Supplies
F-2: If use of CSIP facilities are used as part of the project, the rights of landowners for use of reclaimed water
up to the first 19,500 AFY and MRWPCAs right to divert any portion of that water must be explained. (CPB)
F-5: The EIR should project the effect of water conservation measures on the amount of inflow and assess
MRWPCAs ability to produce reclaimed wastewater. (CPB)
F-6: The EIR should address the effect of increased emphasis on water conservation, recycling and reduction in
agricultural and urban runoff on the supply of source water. (CPB)
G-1: The agricultural community asserts that additional sources of water must be obtained in order to satisfy
the desired amount of reclaimed water. Until this issue is settled they reserve their support for the project.
(FBM)
K-1: The EIR needs to analyze if the project will have an effect on the amount of water supplied to the Marina
Coast Water District. If MCWD utilizes it full 2.1 MGD recycled water, will this decrease the amount available for
the project? Similarly, if 19,500 AFY is allotted to the agricultural community, how does this affect the proposed
project? (PL)
M-2: The Watermaster would prefer that additional water be provided to replenish the Seaside Groundwater
Basin to raise groundwater levels to protective elevations. The EIR should address the possible future expansion
of the GWR project to provide this additional water. (SBW)
Q-3: Is the 3,500 AFY limitation a function of source water availability or system capacity? Why was a greater
capacity not considered so that all member entities could contribute all non-storm/dry weather flows as well as
some portion of storm water flows? (CM)
Q-4: How will the member entities ability to convey non-storm and storm water flows be apportioned? Will
enlargements in the conveyance systems need to be made for equitable distribution of apportionment? (CM)
T-6: The scale of the project may be inadequate to process the 9,500 to 12,500 AFY of source water available.
The remaining source water could be recycled and used for irrigation; however, the discussion of this
opportunity has been limited with regard to its processing and distribution. The same applies to the tertiary
treatment. Designing the facility for ease and rapidity of expansion is highly recommended. (CSa)
EIR Scoping Report
17

March 2015
MTG-E2: The EIR should address the potential for operational failures at the Water Treatment Plant.
Cumulative
S-1: The EIR should consider proposed other ground disturbing activities including a horse park. (FOCAG)
P-3: Space is limited in the Product Water Conveyance Alignment Option 2 that follows Cal-Ams proposed
pipeline alignment; that is a public right of way in the City of Seaside that would be significantly disruptive,
MRWPCA, and Cal-Am should coordinate installation to minimize impacts. (CSe)
4.7 ISSUES NOT ANALYZED UNDER CEQA

Economics /Cost
C-1: The State Water Board understands that the MRWPCA may be pursuing CWSRF financing for the GWR
project, and states that they are a funding agency and an agency with jurisdiction by law. (SWRCB)
D-2: Mr. Guidi requests that the EIR analyze the cumulative socio-economic impacts of this project
in conjunction with other regional water projects in the area. He asks that the economic ripple effects of
rate be analyzed. An estimated cost (in AF/yr) should be provided and compared to other water supply projects.
(USA POM)
regional treatment plant that will be done on this project? How does MRWPCA identify and separate all costs for
two different projects? (PL)
T-1: Varied and significant potential funding required for the project, including potential federal funding. City of
Salinas Industrial Wastewater Improvement project is receiving some funding from federal Economic
Development Grant, and possibly Community Development Block Grant as well. City of Salinas advises that
CEQA could be used to develop NEPA, and assist with federal funding.
U-1: Provide costs associated with scaling up the proposal, and what it would cost to design the project to have
the potential for future capacity increases, including (1) cost of storage facility for excess effluent , (2) cost of
solar energy for a desal-only project, (3) amount of required diluent , (4) cost comparison with desal-only
project. (BC)
MTG-G1: Is the cost of the GWR project greater or less than the cost of a typical desalination plant?
MTG-G2: Who will bear the cost of this project; will local residents with lower incomes be able to afford to live
in this area?
5. CONSIDERATION OF ISSUES RAISED IN SCOPING PROCESS

This Scoping Report documents the process and results of soliciting and receiving comments on the scope of the
EIR from interested agencies and the public. The scoping process assists the lead agency in determining those
issues that other agencies, jurisdictions, groups, and public consider to be important to address in the GWR
Project EIR. Every issue that has been raised during the Scoping Process that falls within the scope of CEQA will
be considered in preparation of the EIR and will be addressed to the extent possible.
EIR Scoping Report
18

March 2015
D-3: Explain environmental reasons for selecting and eliminated alternative technologies, or barriers for
treatment of water.
F-1: Amend project description to establish a clearer project purpose and goal. The projects relationship
and/or inter-relationship with the regional water project pending before the PUC, should be explained.
Whether the GWR Project is intended to be a stand-alone project or as a supplement to Cal-Ams project
should be explained.
F-8: Study the GWR project as an independent source of additional Peninsula water supply.
H-4: Include alternate locations of facilities to minimize environmental impacts in alternative analysis.
X
X
X
I-3: Provide more detailed project maps and exact locations of injection wells. [injection]
X
X
X
X
I-4: The CSLC reiterates the project objectives and the project components as described in the NOP.
I-5: Make project description should be as precise as possible; it should describe the details of all allowable
activities and the timing and length of activities.
I-11: The EIR should consider the effects of sea level rise both on the project and the rate of saltwater
intrusion. A project alternative should be provided that would be more resilient to sea level rise.
K-2: Explain why 3,500 AFY is the target amount of water produced. The EIR should show calculations on
this based on this goal number for both existing and future conditions.
regional treatment plant that will be done on this project? How does MRWPCA identify and separate all
costs for two different projects?
K-4: What are the impacts of the GWR project on the MCWD recycled water project? What is the required
separation between MRWPCA recycled pipes and MCWD recycled pipes?
K-5: The EIR should consider the alternative of recharging the Seaside Aquifer with excess winter flow water
from the Salinas River.
K-6: How do the discharges of the proposed advanced water treatment plant and secondary source water
affect the MCWD brine disposal capacity and the total capacity of the existing outfalls?
EIR Scoping Report
19
Injection/ Recharge
Disposal of Reverse
Osmosis Concentrate
Product Water
Conveyance
Treatment
Source Water
Project Description: Mapping

/ Background
Relation to CPUC MPWS
Project
Alternatives Suggested
Overall Purpose, Need,

Objectives
Table 1
Matrix of Scoping Comments on Project Description and Alternatives
Project Description
Component
X
X
X
X
X
X
X
X
March 2015
M-1: GWR project will not replenish the Seaside Groundwater Basin, as the NOP claims. It will act as an
interim storage basin for the injected water until it is pumped out for municipal use.
M-3: The map provided in the NOP does not clearly show were the facilities are to be located; provide
detailed maps of recharge facilities.
M-4: The NOP states that Cal Am owns 12 wells within the Seaside Groundwater Basin, this should be
changed to, Cal Am currently operates 12 production wells in the Seaside Groundwater Basin.
M-5: The description of the Watermaster should be changed to, The Watermaster Board of Directors
consists of nine entities, one representative from each The next-to-last sentence on page seven should
read, Water levels were found to be below sea level in portions of both (i.e., add portions of)
M-6: The secondary goal of assisting in the prevention of seawater intrusion in the Seaside Groundwater
Basin should be removed or clarified, per comment M- 1.
M-7: Due to the known contamination in Blanco Drain and Reclamation Ditch waters, the of the GWR
treatment facilities should be designed to address all potential pollutants to produce water of suitable
quality for injection into the Seaside Groundwater Basin, which is used for potable water supply.
M-8: The first sentence on page 17 should he revised to read, With groundwater levels currently below sea
level in portions of both ...
O-3: In order to comply with State Water Board requirements for discharges to Areas of Special Biological
Significance, Pacific Grove may divert a portion of (approximately 2,500 gpm to 12,000 gpm) its storm water
to the MRWPCA treatment plant for use in the GWR project.
O-4: Address the facilities that would be required to convey additional storm water from Pacific Grove.
O-5: The benefits to local MS4 discharges should be acknowledged in the Project Objectives.
P-1: Could the project scope be expanded to also consider recharging the Carmel River as either an
alternative or as an option?
P-4: Project design is not finalized and the NOP contains language describing possible adverse constraints;
change language to allow flexibility in the final project design to facilitate project implementation.
P-5: Please clarify the areas and how much land in the City of Seaside are being referred to as the Coastal
Recharge Facilities and the Inland Recharge Facilities as shown in Figure 2.
EIR Scoping Report
20
Injection/ Recharge
Disposal of Reverse
Osmosis Concentrate
Product Water
Conveyance
Treatment
Source Water

/ Background
Project

Objectives
Table 1
Project Description
Component
X
X
X
X
X
X
X
X
X
X
X
X
X
X
March 2015
P-6: Correct or clarify the NOP statement that the proposed inland recharge facilities are within a Cityplanned utility corridor; no City-planned utility corridor in the area shown in Figure 2.
P-7: Clarify where the four deep injection wells noted under the description of Inland Recharge Facilities on
page 17 would be built, including well containment, back flush pit, fencing, treatment facility, etc.
P-9: Clarify or remove page 17 statement regarding Coastal Recharge Facilities since it describes potential
facilities but appears to discount the value of the facilities for recharge.
P-10: Clarify statement on page 17 of NOP regarding available land within the City of Seaside. Suggest The
locations for the proposed coastal recharge facilities were determined based on an analysis of potentially
available land and known aquifer characteristics. (i.e., add potentially)
Q-1: Explain the process and rationale behind the project definition. In order to ensure an adequate
environmental review the definition and understanding of the project must be clear, for this the scope of the
project might need revision. Lack of clarity behind the background of how the project scope was defined. If
revision is necessary, now is a good time for it.
Q-2: Has MRWPCA considered sources water from the perspective of dry weather patterns or wet weather
flows from storm drains? Identification of sources is not consistent in the NOP.
Q-5: Will there be any credits to member entities for flows that go into the GWR and if there are, will there
be any quantification of what those credits will be?
R-2: Explore alternative source water volumes above the 3,500 AFY total specified in the NOP.
R-4: Include potential for use of Marina Coast Water Districts recycled water facilities for conveyance of
GWR water from AWT facility to Seaside Groundwater Basin, given appropriate compensation to the district
for that access.
R-5: Recommends exploration of long-term plan for GWR Project. Will project continue injecting water into
the Seaside Groundwater Basin once the Basin is recharged and operating within protective groundwater
elevations and sustainable yield? Are there other uses for AWT water? Sending AWT water north to combat
seawater intrusion in the Salinas Valley Groundwater Basin is a possibility.
R-6: Encourages MRWPCA to evaluate alternatives that include variable seasonal flow rates of source waters
without the need for including secondary or tertiary effluent sources. The seasonal flow of water sources for
EIR Scoping Report
21
Injection/ Recharge
Disposal of Reverse
Osmosis Concentrate
Product Water
Conveyance
Treatment
Source Water

/ Background
Project

Objectives
Table 1
Project Description
Component
X
X
X
X
X
X
X
X

March 2015
the AWT facility is an operational consideration if the outflow is to be at a single predictable rate.
T-4: Recommends clarification and emphasis on projects independent justification, purpose and utility. This
is especially true for any desalination project, there is a lot of discussion of them as though they are
connected.
T-5: Regarding options A and B pipeline routing, address the pipeline from City of Salinas pump station to
treatment facilities.
T-7: Clarify whether source waters are from one specific source or a combination of the following
sources and delineate how the determination will be made, and when.
T-8: MRWPCA should remain flexible, if possible, with regard to detail of pipe size, capacity, pump location
and size. That CEQA studies focus on routing and environmental factors rather than system design as that is
not yet finalized. Also, if more than 3,500 AFY can be sourced, would environmental processing need to be
repeated or is it possible to avoid going through the process again if system capacity were to increase?
T-9: Regarding page 13, MRWPCA should consider two conveyance pipelines be laid rather than one, for
both source and recycled water. This would accomplish both cost savings and give MRWPCA a leg up as a
regional source of recycled water. The second pipeline may remain temporarily unused, but could be put to
use later for recycled water or for greater intake of source water and the economics of scale would be very
beneficial in the long term.
MTG-C2: Will other alternatives to the project (besides those already included) be addressed in the EIR?
MTG-F1: Is it possible that a larger scale version of the GWR project can solve the entire water supply issue,
therefore eliminating the need for a desalination plant?

EIR Scoping Report
22
Injection/ Recharge
Disposal of Reverse
Osmosis Concentrate
Product Water
Conveyance
Treatment
Source Water

/ Background
Project

Objectives
Table 1
Project Description
Component
X
X
X
X

March 2015
6. SUPPLEMENT TO THE MAY 2013 NOTICE OF PREPARATION

As a result of ongoing engineering and technical evaluations and regional coordination efforts that
occurred after the 2013 scoping process was completed, MRWPCA updated the project description and
prepared a Supplement to the May 2013 NOP in December 2014. The purpose of the Supplement to the
NOP was to provide public agencies, interested parties, and members of the public with an opportunity
to comment on the scope of the EIR related to updates to the project description. The Supplement to
the NOP was made available through the same distribution methods that were used for the May 2013
NOP. The public comment period on the Supplement to the NOP ran from December 10, 2014 to
January 8, 2015. A copy of the Supplement to the NOP is included in this scoping report as Appendix E.
MRWPCA received 12 comment documents on the Supplement to the 2013 NOP. A list of the
commenters, the date the comment document was received, and a summary of topics raised in the
comment documents are included in Table 2. As with the comments that were received during the 2013
scoping process, topics that have been raised in the comment documents on the Supplement to the
NOP that fall within the scope of CEQA will be considered in preparation of the EIR and will be addressed
to the extent possible.

EIR Scoping Report
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March 2015
Table 2: Summary of Comment Letters Received on Supplement to 2013 NOP (in date order)
Commenter (type of
document)
California Office of Planning

and Research State
Clearinghouse (letter)
Type of
Commenter
Date of
Comment
State agency
December 9,
2014
Water Plus (email)
Organization
December 8,
2014
California Native American

Heritage Commission (letter)
State agency
December
24, 2014
Comment Summary
Copy of letter transmitting Supplemental NOP to State agencies for 30-day review.
Project must meet State health requirements for injecting recycled water into a
drinking water basin.
Substantiate the claim that the GWR project enhances water supply diversification.
Include energy information on project.
Identify source/quantity of water supply for GWR project and fate of treatment
residuals.
Letter provides recommendations about information and impact analysis to be
included in the EIR relative to archaeological resources; also provides list of Native
American contacts in Monterey County for CEQA consultation.
Provide information on how GWR project would affect recycled water rights of Marina
Coast Water District (MCWD).
Identify additional work at treatment plant needed for the project and cost to MCWD.
Identify the required separation between GWR distribution pipes and MCWD recycled
water pipes.
Consider an alternative of using excess winter flow from Salinas River as recharge
water for the Seaside aquifer.
Discuss effect of project on MCWD brine disposal capacity in MRWPCA outfall.
Discuss how project may affect MCWD access to its property at Armstrong Ranch.
Identify if GWR EIR will use or reference MCWDs RUWAP EIR.
Consider alternatives that avoid or minimize impacts to aquatic life from proposed
Tembladero Slough diversion.
Proposed Lake El Estero diversion site is located within Monterey Airport Influence
Area and must be referred to the Airport Land Use Commission for consistency
determination.
Recommends meeting to further refine details of the Lake El Estero diversion
component of the project, and potential need for a focused watershed study.
Peter Le (email)
Individual
January 4,
2015
Surfrider Foundation (letter)
Organization
January 7,
2015
Monterey Peninsula Airport

District (letter)
Local agency
January 8,
2014
City of Monterey
Department of Plans &
Local agency
January 8,
2015

EIR Scoping Report
24

March 2015
Table 2: Summary of Comment Letters Received on Supplement to 2013 NOP (in date order)
Commenter (type of
document)
Public Works (letter)
Type of
Commenter
Date of
Comment
Comment Summary
California State Water

Resources Control Board
(letter)
California State Department
of Transportation (letter)
California State Lands
Commission (letter)
City of Seaside Resource

Management Services
Provides information on groundwater level and quality data for the shallow aquifer
beneath Lake El Estero.
Diversion of Lake El Estero discharges to the regional treatment plant may provide
environmental benefits for water quality.
Consider impacts to biological resources at Lake El Estero.
Consider impacts to cultural resources at Lake El Estero.
Discuss whether portions of the project are in the Coastal Zone within City of
Monterey.
Identify regulatory permits required for the whole of the project.
State agency
January 8,
2015
Provides information (brochures) on the SRF Program environmental review process

and additional federal requirements.
State agency
January 8,
2015
Advises that any work within State right-of-way will require an encroachment permit
issued from Caltrans.
Provides information on role of State Lands Commission (SLC), and requests more
detailed information on location and extent of proposed facilities within the Salinas
River and sloughs.
Attaches letter sent by SLC on the May 2013 NOP.
Monitoring wells will need to be relocated in the future if City approves development
for the area.
Any proposed above-grade features in Seaside shall be screened to minimize visual
impacts.
Requests that GWR pipelines follow same route used for the Cal Am water supply
project. MRWPCA and Cal Am work within Seaside right-of-way should be performed
concurrently. Try to locate facilities within Seaside to areas classified as Utility
Corridor or Borderlands under the Habitat Management Plan.
State agency
Local agency

EIR Scoping Report
January 8,
2015
February 6,
2015
25

March 2015
APPENDIX A
MONTEREY PENINSULA GROUNDWATER REPLENISHMENT PROJECT
NOTICE OF PREPARATION
MAY 30, 2013
NOTICE OF PREPARATION
Monterey Peninsula Groundwater Replenishment

Project Environmental Impact Report
Introduction
In accordance with the provisions of the California Environmental Quality Act, the Monterey Regional
Water Pollution Control Agency (MRWPCA), as California Environmental Quality Act lead agency, is
preparing an Environmental Impact Report (EIR) for the proposed Monterey Peninsula Groundwater
Replenishment Project (GWR Project). The GWR Project would create a reliable source of water supply
by taking highlytreated water from a new advanced water treatment plant, and recharging the Seaside
Groundwater Basin (or Seaside Basin) with the treated water using a series of shallow and deep injection
wells. Once injected into the Seaside Basin, the treated water would mix with the groundwater present in
the aquifers and be stored for future use. The primary purpose of the GWR Project is to provide 3,500
acre-feet per year (AFY) of high quality replacement water to California American Water Company (or
Cal-Am) for delivery to its customers in the Monterey District service area; thereby enabling Cal-Am to
reduce its diversions from the Carmel River system by this same amount.1 Cal-Am is under a state order
to secure replacement water supplies by December 2016.
This document serves as the Notice of Preparation (NOP) for the EIR for the GWR Project and solicits
comments on the scope of environmental issues as well as alternatives and mitigation measures that
should be explored in the EIR. Public agencies are invited to comment on the scope and content of the
environmental information that is relevant to each agencys statutory responsibilities with regard to the
proposed GWR Project. Members of the public also are invited to provide their comments on the scope
of the EIR. The 30-day public scoping period begins on May 31, 2013 and closes at 5:00 PM on
Tuesday, July 2, 2013. A public scoping meeting will be held on Tuesday, June 18, 2013 from 6:00
to 8:00 PM at the Oldemeyer Center, Dance Room (986 Hilby Avenue, Seaside, CA 93955). This
NOP provides background information on relevant water supply conditions, briefly describes the
proposed GWR Project, and identifies the environmental issue areas that will be analyzed in the EIR.
1 Cal-Am is an investor-owned public utility that serves approximately 38,500 customers in the Monterey Peninsula area. Cal-
Ams Monterey District service area is shown in Figure 1.
Notice of Preparation
Groundwater Replenishment Project EIR
May 30, 2013
Project Location
The GWR Project would be located within northern Monterey County and would include facilities
located within the unincorporated areas of the Salinas Valley and the cities of Marina and Seaside as
shown in Figures 1 and 2. The GWR Project would replenish the Seaside Basin, and would provide a
portion of the replacement water supplies needed for Cal-Ams Monterey District service area.
Project Background
MRWPCA was established in 1979 under a Joint Powers Authority agreement between the City of
Monterey, the City of Pacific Grove and the Seaside County Sanitation District. MRWPCA operates the
regional wastewater treatment plant, including a water recycling facility (collectively known as the
Regional Treatment Plant), a non-potable water distribution system known as the Castroville Seawater
Intrusion Project, sewage collection pipelines, and 25 wastewater pump stations. MRWPCA member
communities include Pacific Grove, Monterey, Del Rey Oaks, Seaside, Sand City, Fort Ord, Marina,
Castroville, Moss Landing, Boronda, Salinas, and other unincorporated areas in northern Monterey
County. See Figure 1.
MRWPCAs Regional Treatment Plant is located two miles north of the City of Marina, on the south side
of the Salinas River, and has a permitted capacity to treat 29.6 million gallons per day (mgd) of
wastewater effluent.2 At the Regional Treatment Plant, water is treated to two different standards: 1)
Title 22 California Code of Regulations standards (tertiary filtration and disinfection) for unrestricted
agricultural irrigation use, and 2) secondary treatment for discharge through the ocean outfall. Influent
flow that has been treated to a tertiary level is distributed to nearly 12,000 acres of farmland in the
northern Salinas Valley for irrigation use (the Castroville Seawater Intrusion Project). The Regional
Treatment Plant primarily treats municipal wastewater, but also accepts some dry weather urban runoff
and other discrete wastewater flows.
2 The Regional Treatment Plant currently treats approximately 19 million gallons per day of municipal wastewater from a total
population of about 250,000 in the northern Monterey County area shown generally in Figure 1.
May 30, 2013
May 30, 2013
May 30, 2013
Seaside Groundwater Basin

The Seaside Basin underlies an approximately 19-square-mile area at the northwest corner of the Salinas
Valley, adjacent to Monterey Bay (see Figure 1). The hydrogeology of the Seaside Basin has been the
subject of numerous studies beginning with a California Department of Water Resources study in 1974.
Monitoring data gathered since 1987 shows that water levels have been trending downward in many areas
of the basin. A steep decline since 1995 in the northern coastal portion of the basin, where most of the
groundwater production occurs, has coincided with increased extraction in that area after the State Water
Resources Control Board required Cal-Am to reduce its Carmel River diversions, and instead maximize
its pumping in the Seaside Basin.3
Groundwater is currently extracted from approximately 37 wells by 20 well owners in the Seaside Basin.
Cal-Am owns 12 wells and pumps approximately 80% of the water produced in the basin. In addition,
Cal-Am and Monterey Peninsula Water Management District operate a Seaside Basin Aquifer Storage
and Recovery system that stores excess Carmel River water supplies during the wet season in the
groundwater basin and recovers the banked water during the following dry season for consumptive use.
The estimated average yield of the existing Aquifer Storage and Recovery facilities is 1,920 AFY, but
varies yearly based on rainfall due to the requirement to maintain adequate Carmel River instream flows.
Historical and persistent low groundwater elevations caused by pumping have led to concerns that
seawater intrusion may threaten the Basins groundwater resources. In 2006, an adjudication process
(Cal-Am v. City of Seaside et al., Case No. M66343) led to the issuance of a court decision that created
the Seaside Basin Watermaster (Watermaster). The Watermaster consists of nine representatives, one
representative from each: Cal-Am, City of Seaside, Sand City, City of Monterey, City of Del Rey Oaks,
Monterey Peninsula Water Management District and Monterey County Water Resources Agency, and
two representatives from landowner groups. The Watermaster has evaluated water levels in the basin and
has determined that while seawater intrusion does not appear to be occurring at present, current water
levels are lower than those required to protect against seawater intrusion. Water levels were found to be
below sea level in both the Paso Robles (the shallower aquifer) and the Santa Margarita aquifers of the
Seaside Basin in 2012; therefore, it is recognized that recharge into both aquifers would be beneficial for
protection against seawater intrusion.
State Orders to Reduce Carmel River Diversions

The 255-square-mile Carmel River Basin is bounded by the Santa Lucia Mountains to the south and the
Sierra del Salinas to the north. The Carmel Valley aquifer, which underlies the alluvial portion of the
Carmel River downstream of San Clemente Dam, is about six square-miles and is approximately 16 miles
long. In the summer and fall, the alluvial aquifer is drawn down by private pumpers that extract
approximately 2,200 to 2,400 AFY, and Cal-Am that pumps approximately 7,880 AFY.4 Historically,
this combined pumping has resulted in dewatering of the lower six miles of the river for several months in
most years and up to nine miles in dry and critically dry years. Recharge of the aquifer is derived mainly
3 See discussion of SWRCB Order No. 95-10 in the following section.

4
This pumping quantity is based on the mean water production from the Carmel Valley Alluvial Aquifer between Water Year
2010 and Water Year 2012.
May 30, 2013
from river infiltration which comprises 85% of the net recharge.5 The aquifer is replenished relatively
quickly each year during the rainy season, except during prolonged periods of extreme drought.
In 1995, the State Water Resources Control Board issued Order No. WR 95-10, which found that Cal-Am
was diverting more water from the Carmel River Basin than it was legally entitled to divert. The State
Board ordered Cal-Am, instead, to maximize diversions (to the extent feasible) from the Seaside Basin.
In addition, a subsequent Cease and Desist Order (SWRCB 2009-0060) issued in 2009 requires Cal-Am
to secure replacement water supplies for its Monterey District service area by December 2016 and reduce
its Carmel River diversions to 3,376 AFY by the 2016-17 timeframe. Cal-Am estimates that it needs
9,752 AFY6 of replacement water supplies to reduce its Carmel River diversions to the degree required by
the Cease and Desist Order and to reduce its pumping in the Seaside Basin in accordance with the
Watermasters pumping mandates.
Cal-Am, working with local agencies, has proposed construction and operation of a Cal-Am owned and
operated desalination project (known as the Monterey Peninsula Water Supply Project)7 either to provide
all of the replacement water needed to comply with the Cease and Desist Order and the Seaside Basin
Adjudication, or part of the replacement water if the GWR Project would be capable of producing the rest
of the replacement water in a timely manner and at a reasonable cost. The California Public Utilities
Commission, as the California Environmental Quality Act lead agency for the Monterey Peninsula Water
Supply Project, published a Notice of Preparation of an EIR in October 2012 and intends to circulate a
Draft EIR in July 2013.
GWR Project Relationship to the Monterey Peninsula Water Supply Project

The GWR Project is designed to provide part of the replacement water needed for Cal-Am to comply with
the Cease and Desist Order and the Seaside Basin Adjudication. The GWR Project could not produce all
of the needed replacement water, but the primary goal of the project is to produce 3,500 AFY to be used
by Cal-Am in order to reduce its Carmel River diversions by that same amount. The GWR Project could
provide this quantity of replacement water regardless of whether the California Public Utilities
Commission approves Cal-Ams application to construct and operate a desalination plant. In other words,
the GWR Project could accomplish its objective, and be useful to reducing Carmel River diversions,
independent from approval of Cal-Ams proposed desalination plant. While the GWR Project could
proceed as an independent project, the GWR Project is related to the Monterey Peninsula Water Supply
Project in that the GWR Project could reduce the size of Cal-Ams proposed desalination plant. Further,
MRWPCA would not construct the GWR Project unless the California Public Utilities Commission
5
U.S. Geological Survey 1984. Analysis of the Carmel Valley Alluvial Aquifer Groundwater Basin, Monterey County,
California. USGS WRI Report 83-4280; see page 13.
Supplemental Testimony of Richard C. Svindland, January 11, 2013, Attachment 1, Application A.12-04-019 (Application of
CAW for Approval of the Monterey Peninsula Water Supply Project and Authorization to Recover All Present and Future
Costs in Rates)
In April 2012, California American Water submitted Application A.12-04-019 (Application of CAW for Approval of the
Monterey Peninsula Water Supply Project and Authorization to Recover All Present and Future Costs in Rates) to the
California Public Utilities Commission that is intended to secure replacement water supplies for the Monterey District
associated with the regulatory orders and legal decisions described in this section. The MPWSP includes many of the same
elements previously analyzed in the Coastal Water Project EIR (CPUC/ESA, 2009); however, key components, including the
seawater intake system and desalination plant, have been relocated and/or modified under the current proposal and the current
proposal is for private (Cal-Am) ownership of the intake system, desalination facility and conveyance pipeline.
May 30, 2013
approves a Water Purchase Agreement that authorizes Cal-Am to purchase the water that is produced by
the GWR Project.
On April 20, 2012, the Monterey Peninsula Water Management District, MRWPCA, and Cal-Am entered
into a Groundwater Replenishment Project Planning Term Sheet and Memorandum of Understanding to
Negotiate in Good Faith to, among other things, enable planning and environmental evaluation of a GWR
project by the following:
to commit themselves to evaluate the ways in which a groundwater replenishment project could
be effectively accomplished;
to commit themselves to negotiate in good faith to reach agreement on such a project, should it be
deemed viable;
for MRWPCA to commit to act as lead agency to achieve California Environmental Quality Act
compliance for such a project, should it be deemed viable;
for Monterey Peninsula Water Management District to assist MRWPCA in providing the
necessary financial support for planning and California Environmental Quality Act compliance;
and
to identify non-binding preliminary terms of a GWR Project agreement.
In its application to the California Public Utilities Commission for approval of the Monterey Peninsula
Water Supply Project, Cal-Am proposed a three-pronged approach to replace most of its Carmel River
diversions, as required by the Cease and Desist Order. The three prongs consist of: (1) desalination, (2)
groundwater replenishment, and (3) aquifer storage and recovery. Cal-Ams application described the
groundwater replenishment prong as follows and identified it as water supply that would reduce the
capacity of the desalination component by 3,500 AFY:
California American Water has entered into a Memorandum of Understanding with the
MRWPCA and MPWMD to collaborate on developing the Groundwater Replenishment Project,
included as Appendix A. If the Groundwater Replenishment Project has reached certain
milestones by the time California American Water begins construction of the desalination plant
(currently estimated to be near the end of 2014) and the cost of the water from it is reasonable,
California American Water will be able to reduce the size of its proposed desalination plant.
California American Water proposes to do this by filing a Tier 2 advice letter.
Project Objectives
The primary objective of the GWR Project is to replenish the Seaside Basin to produce 3,500 acre-feet
per year (AFY) of high quality water that would replace a portion of Cal-Ams water supply as required
by state orders. To accomplish this primary objective, the GWR Project would need to meet the
following objectives:
Be capable of commencing operation, or of being substantially complete, by the end of 2016 or, if
after 2016, no later than necessary to meet Cal-Ams replacement water needs;
Be cost-effective such that the project would be capable of supplying reasonably-priced water;
and
May 30, 2013
Be capable of complying with applicable water quality regulations intended to protect public
health.
Secondary objectives of the GWR Project include the following:
Assist in preventing seawater intrusion in the Seaside Basin;

Assist in diversifying Monterey Countys water supply portfolio;
Provide additional water to the Regional Treatment Plant that could be used for crop irrigation
through the Salinas Valley Reclamation Project and Castroville Seawater Intrusion Project
system.
Proposed Project
MRWPCAs GWR Project proposes to produce and deliver high quality treated water for replenishment
of the Seaside Basin with the goal of enabling Cal-Am to reduce diversions from the Carmel River and its
alluvial aquifer in compliance with the State Water Resources Control Boards Cease and Desist Order
and to comply with the Seaside Basin Adjudication. The location of the GWR Project is shown in Figure
1. The GWR Project would include the following new facilities as shown in Figure 2 and described in
the following sections:
Source Water Conveyance Facilities: diversion and collection facilities, including pipelines and
pump stations to convey source water to the new treatment facilities,
Treatment Facilities: pretreatment facilities, a new Advanced Water Treatment Plant, and
associated facilities at the existing Regional Treatment Plant site to filter and treat the source
water,
Product Water Conveyance Facilities: pipelines, pump stations, and appurtenant facilities along
one of two optional alignments to convey the treated water to the Seaside Basin, and
Replenishment/Recharge Facilities: pipelines, deep injection and shallow (vadose zone) wells,
and backflush facilities to be located at one or both of two optional locations (coastal and/or
inland recharge sites) within the Seaside Basin boundaries.
A process diagram illustrating the operation of the GWR Project is provided in Figure 3. MRWPCA
would construct, own, and operate the GWR Project facilities from source water collection and
conveyance through injection into the Seaside Basin. After the recharged water resides within the
subsurface soils and aquifer for the prescribed amount of time, the water would be extracted by others at
existing municipal water supply wells.
10
May 30, 2013
Figure 3. Overall GWR Project Process Schematic
MRWPCA is coordinating with Cal-Am, Monterey Peninsula Water Management District, the Seaside
Basin Watermaster, the City of Seaside, the City of Salinas, the Marina Coast Water District, Monterey
County Water Resources Agency, and other public agency stakeholders regarding the GWR Project. The
GWR Project would be designed and implemented in compliance with applicable regulatory requirements
to protect public health. In particular, it is anticipated that the California Department of Public Health
may require specific residence times for recharged water within the aquifer prior to extraction, which
would be verified using tracer tests, if required, and groundwater monitoring.
11
May 30, 2013
Source Water Conveyance Facilities

The GWR Project would use a combination of the following source waters as influent to the GWR
Treatment Facilities:
City of Salinas (City) Treatment Plant water,

Blanco Drain water,
Storm water collection systems of the City of Salinas and other MRWPCA member entities,
Secondary or tertiary effluent from the Regional Treatment Plant, and
Reclamation Ditch water.
A combination of these sources may be needed to meet the GWR Project objectives. The characteristics
and availability of these water sources vary seasonally. Therefore, the GWR Project would be designed
to accommodate a variety of flows, water quality characteristics, and delivery schedules. The following
describes the potential source water types and facilities:
City of Salinas (City) Treatment Plant water. The City collects, transports, and treats water
predominantly from food processing facilities within the City. Most of this water originates from the
washing of produce for packaging (such as bagged lettuce). The water passes through existing pipelines
to the City Treatment Plant located on the northwest side of Davis Road adjacent to the Salinas River.
The water is aerated and sent to ponds and drying beds where it percolates into the shallow groundwater
aquifer or evaporates.
If used as source water for the GWR Project, this water source would be collected at the City Treatment
Plant and conveyed using new pipelines and pump stations to the MRWPCAs new GWR Project
treatment facilities at the existing Regional Treatment Plant. One new pump station would be located at
the City Treatment Plant. The maximum capacity of the pump station would be 10 mgd to allow for
maintenance and operational flexibility. The conveyance would be through a new 27-inch diameter
pipeline constructed along one of the following two potential routes between the City Treatment Plant and
the proposed new Blanco Drain pump station (described below and shown on Figure 2):
City Treatment Plant Conveyance Option A. Approximately 30,000 feet of new pipeline that
would follow the farm roads north of and parallel to the Salinas River outside of the riparian
vegetation area to the proposed new Blanco Drain pump station, or
City Treatment Plant Conveyance Option B. Approximately 33,000 feet long of new pipeline that
would follow paved roads (Blanco Road, Cooper Road, and Nashua Road), and some unpaved
farm roads to the new proposed Blanco Drain pump station.
Blanco Drain water. The Blanco Drain is an existing system of dirt ditches and short pieces of pipe that
collects and conveys agricultural tile drain water8 and some storm water from about 6,000 acres of land to
the Salinas River. The drainage area extends approximately from Highway 1 to Highway 68 along the
Salinas River as it crosses Cooper, Blanco, Hitchcock, and Davis Roads. The water flows to an existing
pump station owned and operated by Monterey County Water Resources Agency about 4,100 feet
northwest of the intersection of Nashua and Cooper Roads. At this point, the water is pumped
approximately 600 feet and then discharged to the Salinas River approximately 1,100 feet southeast and
8 Tile drainage is an agriculture practice that removes excess water from soil subsurface.
12
May 30, 2013
upstream of the existing Salinas River Diversion Facility. The Salinas River Diversion Facility is a
seasonal diversion structure operated by the Monterey County Water Resources Agency for the purpose
of augmenting the irrigation water supplies for the Castroville Seawater Intrusion Project agricultural land
areas (see Figure 1 for the location of the Castroville Seawater Intrusion Project and see Figure 2 for the
existing agricultural irrigation supply pipelines).
If Blanco Drain water or City Treatment Plant water is used by the GWR Project as source water, then a
new Blanco Drain pump station (see Figure 2) would be built near the site of the existing Monterey
County Water Resource Agency pump station. A new 9,000-foot long, 30-inch diameter pipeline would
transport water from the proposed new Blanco Drain pump station to the new GWR Project treatment
facilities at the Regional Treatment Plant. Directional drilling would be used to cross under the Salinas
River, and then the pipeline would be placed along the boundary of the Monterey Regional Waste
Management District property to the MRWPCAs existing Regional Treatment Plant site.
Storm water from the City of Salinas and other MRWPCA member entities. Storm water from Salinas and
other member entities may also be used for source water for the GWR Project. Storm water from the
southwestern portions of the City of Salinas currently travels through existing pipelines to an existing
City storm water pump station at the site of MRWPCAs existing Salinas Pump Station (see Figure 2,
Existing Salinas Pump Stations). The water is then conveyed through an existing 66-inch diameter
pipeline to an outfall structure on the Salinas River approximately 1,800 feet southeast of Davis Road (see
Figure 2, Existing Storm Water Outfall).
If this storm water is used as source water for the GWR Project (to augment treated wastewater), then dry
weather and low flows of storm water would be conveyed by a new short, on-site pipeline from the Citys
Salinas storm water pump station to the MRWPCAs Salinas Pump Station and from there to the existing
Regional Treatment Plant site. Alternatively, dry weather and low flows of storm water from the Salinas
storm water pump station could be used directly for the new GWR Project through existing conveyance
systems to the City Treatment Plant near Davis Road adjacent to the Salinas River. Storm water
conveyance may occur using either: (1) the Citys existing 33-inch diameter pipeline, or (2) when
completed, the Citys future proposed 42-inch diameter pipeline, both of which would provide a
connection from the Salinas Pump Station site to the City Treatment Plant.
To capture and use storm water from the southwestern portions of Salinas during storm events (i.e., high
flows), a new extension of the Citys existing 66-inch diameter pipeline would be required to convey the
storm water to the City Treatment Plant. A new, approximately 2,700-foot long, 66-inch diameter
pipeline would be placed along unpaved farm roads adjacent to the Salinas River to convey water
between the storm water outfall and the City Treatment Plant (see Figure 2). A new pump station,
pipelines and appurtenant facilities at or near the City Treatment Plant would allow the GWR Project to
conjunctively operate with the City Treatment Plant process in managing the flow of water through the
ponds systems and, ultimately, to the new GWR Project treatment facilities using one of the City
Treatment Plant conveyance pipelines (see Options A or B as shown on Figure 2 and described above
under City of Salinas (City) Treatment Plant water).
Other MRWPCA member entities could also send storm water to the Regional Treatment Plant for use by
the GWR Project by adding storm water into existing pipelines, manholes, or pump stations within the
MRWPCA wastewater collection system.
13
May 30, 2013
Secondary or tertiary effluent from the Regional Treatment Plant. At the existing Regional Treatment
Plant, water is treated to two different standards: 1) tertiary treatment for unrestricted agricultural
irrigation use, and 2) secondary treatment for discharge through the ocean outfall. If water treated to
secondary standards were used as source water for the GWR Project, then effluent would be withdrawn
from the existing 60-inch diameter secondary effluent pipe at the Regional Treatment Plant. A new pump
station at the Regional Treatment Plant would pump secondary treated water to the new GWR Project
treatment facilities through a new 18-inch diameter pipeline approximately 1,900 feet long. If water
treated to tertiary standards were used as source water for the GWR Project, then effluent would be
withdrawn from an existing filtered effluent pipeline located at the Regional Treatment Plant (between
the Filter Building and the Chlorine Contact Basins). A new pump station would be located adjacent to
the Filter Building and would pump tertiary treated water to the new GWR Project treatment facilities
through a new 18-inch diameter pipeline approximately 600 feet long.
Reclamation Ditch water. The Reclamation Ditch is operated by the Monterey County Water Resources
Agency, and a portion of this ditch is shown on Figure 2 just north of Highway 183. The watershed of the
Reclamation Ditch includes 157 square miles mostly within Monterey County. The watershed drains the
northwestern slopes of the Gabilan Range as well as much of the City of Salinas and its surrounding
lands. The Reclamation Ditch system is a network of excavated earthen channels used to drain surface
runoff generated in the watershed. Urban runoff from the City of Salinas also drains into various
channels of the Reclamation Ditch system via numerous storm water outfalls. The system drains into
Tembladero Slough, then the Old Salinas River Channel, and ultimately into Moss Landing Harbor
through the Potrero Tide Gates. The Reclamation Ditch system conveys and collects storm water and
provides flood control during the winter, but consists mostly of agricultural tile drain water from the land
north and west of the City of Salinas during the summer months.
If this source water is used by the GWR Project, the Reclamation Ditch water would be collected about
500 feet northwest of the intersection of Davis and W. Market/Highway 183 Roads. The water would
enter a new pump station (see Reclamation Ditch Pump Station on Figure 2) constructed at that same
location, and then would be pumped to an existing sewer pipeline that flows to MRWPCAs existing
Salinas Pump Station. From that point, the Reclamation Ditch water would be comingled with sewage,
pumped, and conveyed through an existing pipeline to the Regional Treatment Plant.
Treatment Facilities
The new proposed Advanced Water Treatment Plant would produce water suitable for subsurface
application in the Seaside Basin. Because one or more potential source waters would contain municipal
wastewater, the GWR Project proposes to meet the regulations of the California Department of Public
Health for indirect potable reuse. The Department of Public Health has prepared Draft Groundwater
Recharge Regulations (March 2013) that require full advanced water treatment for projects that intend to
recharge groundwater through injection wells directly into aquifers, including requiring reverse osmosis
membranes used in advanced treatment to have 99% sodium chloride removal. The regulations also limit
the concentration of total organic carbon and total nitrogen values. Specified treatment levels for
pathogen reduction and treatment of chemicals of emerging concern would be required to satisfy
Department of Public Health permitting requirements. The GWR Project would be designed to comply
with the Draft Groundwater Recharge Regulations if final regulations have not been adopted by the time
14
May 30, 2013
of its construction. Once final regulations are adopted, the GWR Project would comply with the final,
adopted regulations. This will ensure that the GWR Project meets or exceeds all standards adopted to
protect public health.
The GWR Project would include pretreatment of source waters, as needed, including pre-screening, ozone
treatment, biological active carbon filtration, and dissolved air flotation. The Advanced Water Treatment
Plant would include microfiltration or ultrafiltration, reverse osmosis, and advanced
oxidation/disinfection using ultraviolet light with hydrogen peroxide. Post treatment and conditioning
would most likely consist of decarbonation and possible introduction of pH adjusting and/or softening
chemicals. Reverse osmosis concentrate would flow through a new concentrate pipeline and receiving
station (allowing for mixing, sampling for water quality and flow rate) both proposed to be located within
the Regional Treatment Plant site.
After mixing and sampling, the concentrate would be discharged into the on-site portion of the existing
Regional Treatment Plant ocean outfall system.9 Filter backwash waste would be routed to the Regional
Treatment Plant headworks for secondary treatment, and if demand exists, tertiary treatment and use in
the Castroville Seawater Intrusion Project system for agricultural irrigation.
Product Water Conveyance Facilities

MRWPCA proposes to construct a pipeline, measuring up to 36 inches in diameter, to convey the
advanced treated (or product) water from the Advanced Water Treatment Plant to the Seaside Basin for
injection, along one of two potential alignments as shown in Figure 2.
Product Water Conveyance Option 1 would follow a portion of the recycled water pipeline
alignment of the previously approved, and partially-constructed, Regional Urban Water
Augmentation Program Recycled Water Project. The pipeline would be located primarily along
paved roadway rights-of-way within urban areas. The Recycled Water Project was approved by
the Marina Coast Water District in 2005; however, only portions of the recycled water
distribution system have been built and no recycled water has been delivered to urban users. If
not committed to use with recycled water for irrigation at the time of GWR Project construction,
the MRWPCA may pursue using a portion or portions of the pipeline originally proposed for the
Recycled Water Project by Marina Coast Water District (i.e., converting the purpose of the
pipeline for use by the GWR Project). MRWPCA is exploring the feasibility of several options,
including shared use of the pipeline with Marina Coast Water District, use of the pipeline by the
GWR Project only, and construction of a new parallel pipeline within the same or a parallel right
of way and easement, including accommodating any regulatory-required separation distances
from pipelines carrying potable and recycled water.
Product Water Conveyance Alignment Option 2 would follow a portion of the potable product
water conveyance pipeline alignment of Cal-Ams proposed desalination project that is currently
the subject of California Public Utilities Commission application A.12-04-019. The pipeline
alignment would start at the northern boundary of the Regional Treatment Plant access road, then
The RTPs existing Waste Discharge Requirements permit allows up to 375,000 gallons per day of concentrate to be disposed
through the outfall without amendment or revision to the permit; the GWR Project would exceed that amount so would
require a permit amendment.
15
May 30, 2013
follow Charlie Benson Road to the west to Del Monte Boulevard. Alternatively, the pipeline to
Del Monte Boulevard could follow the existing MRWPCA outfall pipeline alignment from the
western boundary of the Regional Treatment Plant. This pipeline alignment would turn south on
Del Monte Boulevard and be located either within the roadway or within land owned by the
Transportation Agency for Monterey County adjacent to the roadway. After Del Monte
Boulevard crosses under Highway 1, the pipeline is currently proposed to be within or parallel to
the Transportation Agencys land that follows the former rail line in that location. The pipeline
would continue south past Fort Ord Dunes State Park and into the City of Seaside turning east at
Auto Center Parkway and Del Monte Boulevard. At this point, the pipeline would turn east
following Auto Center Parkway/La Salle Avenue until either Lincoln or Havanna Streets to
connect the pipeline to San Pablo Avenue. For more information about this alignment option, see
the relevant CPUC NOP dated October 2012 at:
www.cpuc.ca.gov/Environment/info/esa/mpwsp/index.html.
Each pipeline alignment option would also require one or more pump stations, flow control valves, and
other appurtenant facilities. In addition, pipelines to connect the above alignment options to the coastal
and/or inland recharge sites (described below) would be required. The selection of the appropriate
pipeline alignment/locations and/or performance standards for determining the locations will be assessed
as part of a feasibility study that MRWPCA is currently conducting.
Replenishment/Recharge Facilities
The GWR Project would include subsurface groundwater recharge facilities, including shallow (or vadose
zone) and deep injection wells located at inland and, if feasible, coastal locations within the Seaside
Basin. The vadose zone wells would inject water into the unsaturated soils overlying the uppermost
aquifer (the unconfined Paso Robles Aquifer), and the deeper wells would directly replenish the confined
Santa Margarita Aquifer. A conceptual diagram of the GWR Project recharge operations is provided in
Figure 4.
Figure 4. GWR Recharge Concept Schematic
16
May 30, 2013
With groundwater levels currently below sea level in both the shallower Paso Robles and deeper Santa
Margarita aquifers, recharge into both aquifers would be beneficial for protection against seawater
intrusion. Most of the existing groundwater pumping for potable use is from wells perforated in the Santa
Margarita Aquifer. Accordingly, the Santa Margarita Aquifer is targeted to receive most of the GWR
Project water through direct injection. The GWR Project may also recharge high quality water into the
Paso Robles Aquifer using shallower vadose zone wells. This proposed configuration of injection wells is
intended to provide maximum flexibility for well operation and for optimizing both short-term
groundwater production and long-term storage in the Basin.
The design for injection wells at each location has been developed based on the current understanding of
the subsurface conditions and typical well capacities. The groundwater modeling evaluation to be
conducted as part of the EIR will be used to optimize the number, type, location, and design of GWR
Project wells. The following sections describe the proposed inland and coastal recharge facilities.
Inland Recharge Facilities. The inland recharge location is assumed to include four deep injection wells
and four vadose zone wells that would be located in an approximate 3,000-foot long strip of land about
1,000 feet south of Eucalyptus Road and east of General Jim Moore Boulevard. MRWPCA has been
working with the City of Seaside and the Fort Ord Reuse Authority to identify an acceptable location for
the proposed inland recharge facilities, and the location that currently appears to be feasible is a Cityplanned utility corridor as shown in Figure 2. Wells would be placed approximately 1,000 feet apart to
minimize pumping interference between the wells. Collectively, the eight wells at the inland location
would be designed to recharge up to approximately 6,000 gallons per minute (gpm) of water into the
Seaside Basin to allow for backup, well maintenance, and other operational benefits (such as optimization
of replenishment effectiveness) while still meeting the annual volume objectives. It is anticipated that
recharge amounts allocated to each well type and target aquifer could readily be adjusted based on basin
conditions that will be determined through ongoing monitoring. Monitoring wells would be constructed
in key locations surrounding the recharge facilities to measure water quality and water levels and to
measure for tracer constituents during tracer tests that may be required by regulatory agencies. Well
operations will be adapted to the results of the monitoring so that the GWR Project continually complies
with applicable regulatory and permitting requirements established to protect human health and water
quality.
Coastal Recharge Facilities. The coastal recharge facilities would include three deep injection wells and
four vadose zone wells located on two undeveloped parcels immediately east of Highway 1 and west of
the Bayonet and Black Horse Golf Course, as shown in Figure 2. Collectively, these wells would be able
to recharge about 3,150 gpm of water. Due to the shallower water table at the coast, vadose zone wells
would be shallower, and the longterm ability of the coastal wells to replenish both the Santa Margarita
and Paso Robles aquifers would likely be less than the replenishment ability of the inland wells. The
locations for the proposed coastal recharge facilities were determined based on an analysis of available
land and known aquifer characteristics. The Seaside Watermaster requested the inclusion of the coastal
recharge facilities in the GWR Project due to the potential benefit they may provide to preventing
seawater intrusion and that organization has begun an analysis of the potential benefits of these facilities
on the Seaside Basin.
17
May 30, 2013
Maintenance and Monitoring Characteristics. As previously described, the GWR Project would be
operated based on a total annual recharge volume of 3,500 AFY to replace water supplies for Cal-Ams
Monterey District service area. It is anticipated that well maintenance and rehabilitation would occur on
an as-needed basis. A monitoring program, including tracer tests if required by regulatory agencies,
would be implemented and coordinated with other ongoing monitoring programs in the Seaside Basin to
allocate water between vadose zone and deep injection wells, and to ensure adequate residence time of the
GWR Project water in the Seaside Basin in compliance with regulatory and permitting requirements
adopted to protect public health. The GWR Project would be designed to allow for operational flexibility,
allowing variation in the amounts of recharge by well over time.
Extraction
After the GWR Project water achieves residence time in the Seaside Basin in accordance with regulatory
requirements, extraction of groundwater that includes GWR Project water would occur using existing
potable wells, disinfection treatment processes, and distribution systems. No new extraction wells are
proposed as part of the GWR Project. Because the GWR Project water would be produced in accordance
with California Department of Public Health requirements which are protective of public health, and
because the water would meet the applicable residence time requirements within the groundwater basin,
no additional treatment beyond current operations would be required after the water is extracted. The
amount and quality of water to be extracted and used would be monitored pursuant to applicable
regulatory requirements.
Construction Methods and Schedule

The GWR Project is proposed to be constructed with typical construction methods and equipment,
although directional/horizontal drilling may be used for potential source water pipeline crossing(s) of the
Salinas River and installation through major intersections along the pipeline corridor. A schedule has
been developed for the planning, design, and construction components of the project with a target date of
December 2016 for initial groundwater recharge activities to commence.
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May 30, 2013
Permits and Agreements Anticipated to be Required

As previously discussed, the Monterey Peninsula Water Management District, MRWPCA, and Cal-Am
jointly entered into a Groundwater Replenishment Project Planning Term Sheet and Memorandum of
Understanding to Negotiate in Good Faith on April 20, 2012. MRWPCA would need to enter into other
agreements with entities/agencies who may control the source waters and rights of way, including but not
limited to: 1) Monterey County Water Resources Agency to obtain water from Blanco Drain and
Reclamation Ditch sources; 2) Monterey County Water Resources Agency, Marina Coast Water District,
or both, for use of Regional Treatment Plant effluent and use of various water conveyance facilities and
rights of way; and 3) the City of Salinas for source water from its Treatment Plant and stormwater system,
and for possible electrical power purchase. MRWPCA would also need to enter into a water purchase
agreement with the Monterey Peninsula Water Management District (contingent on a water purchase
agreement between Cal-Am and the Monterey Peninsula Water Management District) for the GWR
Project water. Other agreements not currently identified may also be required.
Table 1 is an initial list of agencies and entities that may be involved in permitting and/or approving one
or more aspects of the GWR Project. This list is preliminary and may require revision as the GWR
Projects design, including construction and operational characteristics, are further developed.
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May 30, 2013
Table1:PotentialPermitsandApprovalsRequired
Agency/Entity
PermittingRegulation/ApprovalRequirement
FederalAgencies
U.S.EnvironmentalProtectionAgency
MontereyBayNationalMarineSanctuary
U.S.FishandWildlifeService
U.S.Dept.ofInterior:NOAAFisheries
ArmyCorpsofEngineers
FederalAviationAdministration
ClassVUndergroundInjectionControlProgram(PartC,SafeDrinkingWaterAct[SDWA])
ReviewandcoordinationofallRWQCB404,Section10,andNPDESpermits
EndangeredSpeciesActcompliance(ESASection7consultation)
FishandWildlifeCoordinationAct(16USC661667e;ActofMarch10,1934;ch.55;48stat.401)
EndangeredSpeciesActcompliance(ESASection7consultation)
NationwideSection404Permit(CleanWaterAct,33USC1341)
Section10,RiversandHarborsActPermit(33U.S.C.403)
FormSF74601NoticeofProposedConstruction&AlterationforAirportAirspaceAeronautical
StateAgencies
CaliforniaPublicUtilitiesCommission
CoordinationregardingtheMPWSPCertificateofPublicConvenienceandNecessity(Application
No.1204019)
StateWaterResourcesControlBoard,
GeneralConstructionActivityStormWaterPermit(WQO9908DWQ)
RegionalWaterQualityControlBoard
Waterrightspermitfordevelopmentofnewsurfacewaterdiversions
WasteDischargeRequirements (WaterCode13000etseq.)
401WaterQualityCertification(CWASection401)
NationalPollutantDischargeEliminationSystem(NPDES)Permit(CWASection402)
CaliforniaStateLandsCommission
RightofWayPermit(LandUseLease) (CaliforniaPublicResourceCodeSection1900);Lease
amendment
CaliforniaDepartmentofFishandWildlife IncidentalTakePermits(CAEndangeredSpeciesAct Title14,Section783.2)
StreambedAlterationAgreement(California FishandGameCodeSection1602)
CaliforniaCoastalCommission
CoastalDevelopmentPermit (PublicResourcesCode30000etseq.)
CaliforniaDepartmentofPublicHealth
PermittoOperateaPublicWaterSystem(California HealthandSafetyCodeSection116525)
ApprovalforRechargeofHighlyTreatedWater
CaliforniaDepartmentofTransportation
EncroachmentPermit(StreetsandHighwayCodeSection660)
CaliforniaStateHistoricPreservationOfficerSection106Consultation,NationalHistoricPreservationAct(16USC470)
CaliforniaStateUniversityMontereyBay RightofWayAgreementsand/orEasements
Regional/LocalAgencies
CityofSalinas
CitiesofSeasideandMarina,SandCity,
Salinas(potential)
FortOrdReuseAuthority
MontereyBayUnifiedAirPollutionControl
District
MontereyCountyHealthDepartment,
EnvironmentalHealthDivision
ElectricityPowerPurchaseAgreement
UsePermits,encroachment/easementpermits,gradingpermitsanderosioncontrolpermitsmay
berequiredpursuanttolocalcity/Countycodes.
CoordinationwithFORAforRightofEntry
AuthorityToConstruct(Localdistrictrules,perHealthandSafetyCode42300etseq.) andPermit
ToOperate(Localdistrictrules)
Well ConstructionPermit(MCC,Title15Chapter15.08,WaterWells)
HazardousMaterialsBusinessPlan(HealthandSafetyCodeChapter6.95)
HazardousMaterialsInventory(HealthandSafetyCodeChapter6.95)
ReviewofDischarges/WDRmodifications
VariationonMontereyCountyNoiseOrdinance(MCC10.60.030)
MontereyCountyPublicWorksDepartment EncroachmentPermit(MontereyCountyCode(MCC)Title14Chapter14.040)
MontereyCountyResourceManagement UsePermit(MCCChapter21.72Title21) mayberequiredpursuanttoCountycodes.
Agency
CoastalDevelopmentPermit.(PublicResourcesCode30000etseq.)
GradingPermit(M.C.C.,GradingandErosionControlOrdinance,Chapter16.08 16.12)
ErosionControlPermit(MCC,GradingandErosionControlOrdinance,Chapter16.08 16.12)
MontereyCountyWaterResourceAgency Coordination/agreementsforcomponentswithinMCWRAcontrolledwaterwaysandinvolvingthe
CastrovilleSeawaterIntrusionProjectandSalinasValleyReclamationProject
MontereyPeninsulaWaterManagement WaterSystemExpansionPermit(MontereyPeninsulaWaterManagementDistrict Boardof
District
DirectorsOrdinance96)
MontereyReg.WasteManagementDistrict ElectricPowerPurchaseAgreement
SeasideBasinWatermaster
PermitforInjection/Extraction
TransportationAgencyofMontereyCounty Easement
WaterAgencies(other)
Participation/purchaseagreements
PrivateEntities
Landowners
CaliforniaAmericanWaterCompany
PG&E
Landlease/sale;easementsandencroachmentagreements
WaterpurchaseagreementwithMontereyPeninsulaWaterManagementDistrict
ElectricPowerWillServeLetter/PurchaseAgreement
20
May 30, 2013
Environmental Effects to be Analyzed

The GWR Project EIR will evaluate potential environmental effects associated with construction,
operation, and maintenance activities. The EIR will assess the following issues of potential
environmental effect:
Aesthetic Resources: Project facilities would be sited in potentially scenic and open space areas; however
most facilities would be underground or located on existing water and wastewater facility sites. Those
facilities that are not located on existing water and wastewater facility sites would be designed to visually
blend into the environment through use of vegetative screening and/or appropriate paint colors. The EIR
will evaluate visual/aesthetic impacts related to the GWR Projects above-ground facilities.
Air Quality and Greenhouse Gas Emissions: The EIR will evaluate construction- and operation-related
emissions of criteria air pollutants. The GWR Project will be evaluated in accordance with all applicable
federal, state, and regional rules and guidelines. Potential human health risks at nearby sensitive receptors
from emissions of diesel particulate matter and toxic air contaminants during construction and operations
will be addressed. The EIR will also address greenhouse gas (GHG) emissions during construction and
operations, and describe any potential conflict the GWR Project may have with an applicable plan, policy,
or regulation adopted for the purpose of reducing the emissions of GHG.
Biological Resources: The EIR will evaluate potential impacts on terrestrial special-status animal and
plant species, sensitive habitats, mature native trees, and migratory birds believed to occur in the GWR
Project area. The GWR Project may result in changes to the quantity and quality of the treatment plant
effluent discharged through the existing MRWPCA outfall to Monterey Bay; therefore, potential effects
on marine resources will be evaluated. The EIR will include a summary of the federal Endangered
Species Act Section 7 compliance activities and will recommend feasible mitigation measures to reduce
significant impacts on biological resources.
Cultural Resources: The EIR will review cultural resource records and evaluate potential impacts on
historic, archaeological, and paleontological resources, and human remains in the Project area. The EIR
will include a summary of the National Historic Preservation Act Section 106 compliance activities.
Standard mitigation measures to protect cultural resources will be included in the EIR.
Geology and Soils: Construction and operation will occur in a seismically active region. As such, the
proposed GWR Project structures could be subject to potential seismic and geologic hazards. The EIR
will identify potential seismic, liquefaction, landslide, soil erosion, and expansive soil impacts expected to
result from development of the proposed GWR Project. Standard building requirements would be
included to protect buildings and structures from seismic risks.
Hazards and Hazardous Materials: The EIR will summarize documented soil and groundwater
contamination in the Project area, and evaluate the potential for hazardous materials to be encountered
during construction. The analysis will also consider the proper handling, storage, and use of hazardous
chemicals that may be used during construction and operation. Existing hazardous materials regulatory
requirements would be followed to protect workers and the public from exposure to hazardous materials.
Airport safety hazards will also be addressed.
Hydrogeology and Groundwater Quality: Construction and operation of the Project could affect
groundwater levels and quality in the Seaside, Carmel Valley, and Salinas Valley Groundwater Basins.
21
May 30, 2013
Through the use of groundwater modeling and hydrogeologic analyses, the EIR will evaluate changes in
local groundwater quality, storage, and levels within the groundwater basins as a whole and their
subbasins, as appropriate. Potential effects on the seawater/freshwater interface (i.e., seawater intrusion)
will also be evaluated. The project would be designed to comply with California Department of Public
Health and Regional Water Quality Control Board standards and requirements to protect public health and
water quality.
Hydrology and Surface Water Quality: Construction and operation of the Project could affect surface
water quality and hydrologic systems/processes in the construction areas. Potential impacts to be
evaluated include alteration of drainage patterns and increase in stormwater flows due to increase in the
amount of impervious surfaces, and degradation of surface water quality as a result of erosion and
sedimentation, hazardous materials release during construction, and construction dewatering discharges.
The project would be designed to comply with standard construction and operational requirements and
permits under the National Pollutant Discharge Elimination System and Waste Discharge Requirements.
Land Use and Planning: Implementation of the proposed GWR Project includes construction and
operation of new facilities and water supply infrastructure. The EIR will evaluate the proposed GWR
Project for consistency with established plans, policies, and regulations, as well as compatibility with the
existing and future land use patterns in the GWR Project area, including adjacent land uses. The proposed
GWR Projects functional and physical compatibility with surrounding uses will also be analyzed.
Because most conveyance facilities will be underground, and because the proposed treatment facilities
would be located at the existing Regional Treatment Plant, significant effects on land use patterns are not
anticipated.
Noise: The EIR will evaluate construction- and operation-related noise and vibration increases and
associated effects on ambient noise levels, relative to applicable noise standards, and will address the
potential for impacts to nearby sensitive land uses.
Population and Housing: Implementation of the proposed GWR Project would enhance the reliability of
the water supply within the Monterey Peninsula area, but the project would provide replacement water
rather than new water to serve growth. The EIR will describe the relationship of water supply to
population growth in the area. The EIR will identify current population and employment projections and
identify local planning jurisdictions with the authority to approve growth and mitigate secondary effects
of growth.
Transportation and Traffic: The EIR will generally describe the types of construction activities that
would generate temporary increases in traffic volumes along local and regional roadways. The
installation of pipelines within or adjacent to road rights-of-way could result in temporary lane closures
and traffic delays. The analysis will use information about construction activities (e.g., the numbers of
trucks and workers) to the extent such information is available. The analysis will generally describe the
types of traffic control plan measures that would be used to reduce impacts to vehicular traffic, traffic
safety hazards, public transportation, and other alternative means of transportation.
Other Environmental Issues: Other environmental issues that will be evaluated in the EIR include the
Projects potential impacts on public services and utilities, including the Projects beneficial effect on
water supply reliability; water rights for project source water; effects on energy delivery systems due to
fossil-fuel resource use; and effects on agricultural, mineral, and forest resources. The EIR also will
evaluate potential growth-inducing impacts that could result from implementation of the Project. The EIR
22
May 30, 2013
will address whether the Project could result in impacts that would be significant when combined with the
impacts of other past, present and reasonably foreseeable future projects (i.e., cumulative impacts).
Alternatives: California Environmental Quality Act requires that an EIR evaluate a reasonable range of
feasible alternatives to the project, or to the location of the project, that would attain most of the basic
project objectives but that could avoid or substantially lessen any of the significant effects of the project.
The EIR will identify the potentially significant impacts of the proposed Project. The findings of the EIR
impact analysis will guide the refinement of an appropriate range of feasible alternatives to be evaluated
in the EIR that would avoid or substantially lessen significant impacts, while still meeting the project
objectives. MRWPCA is seeking comments from agencies, stakeholders and the public regarding feasible
alternatives for evaluation in the EIR. The EIR will include, at a minimum, a discussion of impacts
associated with the No Project Alternative.
Environmental Review Process

The MRWPCA has determined that the GWR Project may have a significant effect on the environment
and an EIR is required. The MRWPCA is the Lead Agency for California Environmental Quality Act
purposes. The MRWPCA anticipates seeking State Revolving Fund funding from the California State
Water Resources Control Board. Therefore, the requirements of California Environmental Quality ActPlus will be met and the analysis in the EIR will be conducted in compliance with those requirements.
Currently, the potential for federal funding or permitting for the project is unknown; however, if a federal
agency must issue a discretionary permit for the GWR project or approve some component of the project
such as funding, compliance with the National Environmental Policy Act may be necessary.
The first step in the environmental review process is the formal public scoping process, for which this
NOP has been prepared. Following the public scoping period, the Draft EIR will be prepared and
circulated for a 45-day public review period. Public comments on the Draft EIR will be accepted in
writing during the review period or verbally at a formal public meeting to be held by the MRWPCA. The
MRWPCA will then prepare written responses to the comments on environmental issues raised during the
public review period, and a Response to Comments document will be prepared. That document will be
considered by the MRWPCA, along with the Draft EIR and any revisions to the draft based on responses
to comments, for certification as the Final EIR.
23
May 30, 2013
Scoping and Public Meeting

The California Environmental Quality Act mandates that a scoping meeting be held for projects of
statewide, regional or area-wide significance. To ensure that the public and regulatory agencies have an
opportunity to ask questions and submit comments on the scope and content of the EIR, a scoping
meeting will be held during the NOP review period. The location and date of the scoping meeting is:
Date: Tuesday, June 18, 2013
Time: 6:00-8:00 PM
Location: Oldemeyer Center, Dance Room (986 Hilby Avenue, Seaside, CA 93955)
The scoping meeting will start with a brief presentation providing an overview of the proposed GWR
Project. Following the presentation, interested parties will be provided an opportunity to interact with
MRWPCA staff and its technical consultants. Participants are encouraged to submit written comments;
comment forms will be supplied at the scoping meeting. Written comments may also be submitted
anytime during the NOP scoping period to the mailing address, fax number, or email address listed below.
Due to the time limits mandated by State law, your response must be sent at the earliest possible date, but
not later than 30 days after receipt of this notice. The scoping comment period will close at 5:00 PM on
Tuesday, July 2, 2013. Please include a name, address, email address, and telephone number of a
contact person in your agency for all future correspondence on this subject. Please send your comments
to:
Monterey Regional Water Pollution Control Agency
ATTN: Bob Holden
5 Harris Court, Bldg D
Monterey, CA 93940
Phone: (831) 372-3367 or (831) 422-1001
Fax: (831) 372-6178
E-mail: GWR@mrwpca.com
This Notice of Preparation is available electronically at the MRWPCA website:

www.mrwpca.org.
24
May 30, 2013
APPENDIX B
DISTRIBUTION LISTS FOR THE NOTICE OF PREPARATION
MAY 30, 2013
Monterey Peninsula Groundwater Replenishment Project

NOP Distribution by Category (May 30, 2013)*
*Notice sent to one or more individuals at each group/institution listed below.
Academic/Education
California State University Monterey Bay: Division of Science & Environment Policy
Carmel Unified School District
Center for Ocean Solutions
CSUMB
Marine Pollution Studies Lab - UC Davis
Monterey Bay Aquarium Research Institute
Monterey Peninsula Unified School District
Monterey School Board
Moss Landing Marine Laboratories
Stanford University- Hopkins Marine Station
UC Berkeley Hastings Reserve
UCMBEST
Watershed Institute at CSUMB
York School
City
City of Carmel-by-the-Sea
City of Del Rey Oaks
City of Greenfield
City of Marina
City of Monterey
City of Monterey/MPRWA
City of Pacific Grove
City of Salinas
City of Seaside and Seaside County Sanitation District
City of Soledad
City of Gonzales
King City
Monterey Peninsula Chamber of Commerce
CPUC EIR Team
CPUC
ESA
Sedgwick, LLP
DAC/Social equity
California Rural Legal Assistance League
Center for Community Advocacy
CHISPA (Community Housing Improvement Systems and Planning Association)
Environmental Justice Coalition for Water
Ford Ord Environmental Justice Network
Foundation for Housing Assistance of Monterey County
LEAGUE OF UNITED LATIN AMERICAN CITIZENS
Military and Veterans Affairs
Monterey County Department of Health Services
Monterey County Housing Authority
Monterey County Social Services Department
Monterey County Welfare Department
Monterey Senior Center
National Association for the Advancement of Colored People
Oldemeyer Senior Center
Rural Communities Assistance Corporation
Seaside Family Health Center

Shelter Outreach Plus/ I Help Program
Federal
Department of Interior, Bureau of Reclamation
Monterey Bay National Marine Sanctuary
National Oceanic and Atmospheric Administration Fisheries
U.S. Army
U.S. Army Corps of Engineers
U.S. Army Corps of Engineers - BRAC office
U.S. Army, DPW
U.S. Army, Master Plans
U.S. Department of Interior, Bureau of Reclamation
U.S. Department of Agriculture Natural Resources Conservation Service
U.S. Fish and Wildlife Coastal Program
U.S. Fish and Wildlife Service
U.S. Forest Service
U.S. Geological Survey
U.S. Navy
GMC IRWM
Individual
Monterey County
GWR Consultant Team
Archaeological Consulting
Brezack & Associates
GHD
Illingworth & Rodkin
Independent Consultant
Nellor Environmental Associates
Perkins Coie
SPI
Todd Engineers
Trussel Technologies
Valerie Young Consultants
Library
Carmel Harrison Library
Carmel Valley Public Library
Castroville Public Library
CSUMB Library
Marina Library
Monterey Library
Monterey Peninsula College Library
Pacific Grove Library
Salinas Public Libraries
Seaside Library
Native American
Press/Media
Cedar Street Times
Coast Weekly
Monterey Herald
Salinas Californian
Private Company/Individual
Regional/County/Special District
Agriculture Water Quality Alliance

Association of Monterey Bay Area Governments
Carmel Area Wastewater District
County Clerk
County of Monterey and Clerk's Office
Fort Ord Reuse Authority
Marina Coast Water District
Marina Coast Water District
Monterey Peninsula Water Management District
Monterery Peninsula Water Management District
Monterey Bay Unified Air Pollution Control District
Monterey County
Monterey County Ag Commissioner's Office
Monterey County Environmental Health
Monterey County Farm Bureau
Monterey County Health Dept., Division of Environmental Health
Monterey County Local Agency Formation Commission
Monterey County Office of Emergency Services
Monterey County Public Works
Monterey County Public Works
Monterey County Public Works/Monterey County Service Area 50
Monterey County Resource Conservation District
Monterey County Resource Management Agency
Monterey County Water Resources Agency
Monterey Peninsula Airport District
Monterey Peninsula Regional Park District
Monterey Regional Waste Management District
Moss Landing Harbor District
Pebble Beach Community- Service District
Pebble Beach Community Service District (also, PGUSD)
Santa Lucia Preserve
Seaside Basin Watermaster
Transportation Agency for Monterey County
State
California Coastal Commission
California Coastal Commission
California Coastal Conservancy
California Department of Fish & Game: Fisheries
California Department of Fish and Game
California Department of Fish and Wildlife
California Department of Parks and Recreation
California Department of Public Health
California Department of Public Health: Drinking Water
California Department of Transportation
California Department of Water Resources
California State University Monterey Bay
California State Water Resources Control Board
California State Water Resources Control Board: Division of Water Rights
Central Coast Regional Water Quality Control Board
Surrounding Counties
Fresno County Clerk
San Benito County, Office of the County Clerk
San Luis Obispo County
San Luis Obispo County, Department of Planning and Building

Santa Cruz County
Monterey Peninsula Regional Water District List
Monterey Peninsula Water Management District List
Non-Governmental Organizations
Ag Land Trust
Big Sur Land Trust
Bike RacingCCCX Cycling
California Native Plant Society, Monterey Chapter
Carmel River Watershed Conservancy
Carmel Valley Association
Central Coast Agricultural Water Quality Coalition
Central Coast Water Quality Preservation, Inc
Central Coast Wetlands Group
Citizen
Citizen Watershed Monitoring Network
Citizens for Public Water
Citizens for Responsible Growth
Coastal Watershed Council
Conserve Collaborate
Del Monte Forest Foundation
Del Monte Forest Property Owners
Ecology Action
Elkhorn Slough Foundation
FORT Friends (Fort Ord Recreation Trails Friends)
Fort Ord Recreation Users
Friends of Fort Ord Warhorse
Friends of the River
Greater Monterey County IRWMP
Keep Fort Ord Wild
LandWatch Monterey County
League of Women Voters of the Monterey Peninsula
Marina Equestrian Center
Monterey Bay Citizen Watershed Monitoring Network
Monterey Bay Conservancy
Monterey Bay Youth Camp
Monterey Coastkeeper/The Otter Project
Monterey County Hispanic Chamber of Commerce
Monterey County Hospitality Association
Monterey County Vintner & Grower Association (MCVGA)
Monterey Search and Rescue Dogs, Inc.
MORCA (Monterey Off-Road Cycling Association, a Chapter of IMBA)
NAACP, Monterey County
Planning and Conservation League
Policy Link
Salinas River Channel Coalition
Sand City
Santa Lucia Conservancy
Save Our Shores
Save The Whales
Sierra Club
Step Up 2 Green / Sustainability Academy
Surfrider Foundation
Sustainable Marina (residents group)
Sustainable Seaside (residents group)

The Nature Conservancy
The Otter Project
Trout Unlimited
U.S. Green Building Council
Ventana Wilderness Alliance
Ventana Wildlife Society
Political Entity
Private Individual Companies
Grand Total
Monterey Peninsula Groundwater Replenishment Project NOP

Certified Mail Receipts
Delivered by June 1, 2013 June 4, 2013
California Department of Transportation
California State University Monterey Bay Library
Carmel Harrison Library
Community Housing Improvement Systems and Planning Association, Inc.
Foundation for Housing Assistance of Monterey County
Marina Library
Mayor Fred Ledesma, Soledad
Mayor Joe Gunter, Salinas
Mayor John Huerta Jr., Greenfield
Mayor Robert Cullen, King City
Monterey County Clerk
Monterey County Department of Health Services
Monterey County Housing Authority
Monterey County Military and Veterans Affairs
Monterey County Social Services Department
Monterey County Welfare Department
Monterey Library
Monterey Peninsula College Library
Monterey Senior Center
Monterey, City of
Oldemeyer Senior Center
Pacific Gas & Electric Local Office
Pacific Gas & Electric Service Planning Office
Pacific Grove Library
Sand City, City of
Seaside Family Health Center
Seaside Library
Seaside, City of
Shelter Outreach Plus/I Help Program
APPENDIX C-1
GWR PUBLIC SCOPING MEETING - PRESENTATION
JUNE 18, 2013
Monterey Peninsula
Groundwater Replenishment
(GWR) Project
ENVIRONMENTAL IMPACT REPORT
SCOPING MEETING
Tuesday, June 18, 2013
Oldemeyer Center, Seaside
6:00 - 8:00 PM
Agenda
1) Introductions
2) Overview of Groundwater
Replenishment Project
3) Overview of CEQA / Scoping
Requirements
4) EIR Environmental Issues / Topics
5) Agency and Public Comments
GWR CEQA & Technical Teams

Lead Agency
Project Partner Agency
CEQA Consultants
Denise Duffy & Associates, Inc. (EIR consultants)
Valerie Young, AICP (CEQA Oversight)
Perkins Coie LLP (CEQA Attorney)
Technical Consultants
Treatment design and technology,
hydrogeology/groundwater, regulatory specialists, funding
and feasibility studies, civil engineering, noise, air quality,
cultural resources, public health, biologists, hydrologists,
wetland scientists
GWR CEQA Process

Lead Agency
EIR Determination
/Scoping
30-day NOP
Comment Period
(through July 2, 2013)
Today
Draft EIR
45-day Public
Review Period (Winter 2014))
Final EIR
Review of Final EIR
(Summer 2014)
EIR Certification/
Project Approval
Summer
2014
GWR Overview
To produce and deliver 3,500 AFY high quality
treated water for replenishment of the Seaside
Basin to reduce Cal-Am diversions from the Carmel
River alluvial aquifer.
Facilities would include:
Source Water Conveyance Facilities
Treatment Facilities
Product Water Conveyance Facilities
Replenishment/Recharge Facilities
About MRWPCA
Operates the regional wastewater treatment plant

Maintains 25 wastewater pump stations
Manages the water recycling facility
Operates the distribution system that provides
irrigation water to 12,000 acres of farmland.
The agency serves Del Rey Oaks, Monterey, Pacific

Grove, Salinas, Sand City, Seaside, Boronda,
Castroville, Moss Landing, Fort Ord, Monterey
County, and Marina.
Project Location Overview
State and Judicial Orders Reduce

Cal-Am Water Supply
State Water Resources Control Board Order No.

WR 95-10 found Cal-Am was diverting more
Carmel River water than allowed.
Cease and Desist Order (CDO) follows that
requires new water supply by the end of 2016.
Seaside Basin Adjudication in 2006 found basin
overdraft may result in seawater intrusion;
requires reduction in pumping.
GWR Relationship to Monterey

Peninsula Water Supply Project
Can provide part of the replacement water
needed for Cal-Am for CDO and Adjudication.
Primary goal is to produce 3,500 AFY to
reduce Cal-Ams Carmel River diversions.
Independent project; can be implemented
with or without Monterey Peninsula Water
Supply Project, but if built reduces the size of
the desalination plant needed.
Primary Project Objectives

Replenish the Seaside Basin with 3,500 AFY of high
quality water that would replace a portion of Cal-Ams
water supply by meeting the following objectives:
Commence operation, or be substantially complete,
by end of 2016 or, if after 2016, no later than
necessary to meet Cal-Ams replacement water
needs;
Be cost-effective and capable of supplying
reasonably-priced water; and
Comply with applicable water quality regulations
intended to protect public health.
Secondary Project Objectives

Assist in preventing seawater intrusion in
Seaside Basin;
Diversify regions water supply portfolio; and
Provide additional water for crop irrigation
through the Salinas Valley Reclamation Project
and Castroville Seawater Intrusion Project
system.
Overview of GWR Facilities

Source Water Conveyance Facilities:
pipelines/pump stations to convey source water to
treatment facilities,
Treatment Facilities: pretreatment facilities, a new
Advanced Water Treatment Plant at the existing
WWTP,
Product Water Conveyance Facilities: to convey
water to the Seaside Basin, and
Replenishment/Recharge Facilities: pipelines,
deep and shallow (vadose zone) injection wells,
and backflush facilities at coast and/or inland
within Seaside Basin.
Source Water Collection

A combination of the following will be processed by
the Advanced Water Treatment Plant:
City of Salinas Treatment Plant water
Blanco Drain water
Storm water collection systems of the City of
Salinas and other MRWPCA member entities
Reclamation Ditch water
Secondary or tertiary effluent from the Regional
Treatment Plant

Salinas
Blanco Drain
Existing
Salinas
Pump
Station
Salinas
Treatment Plant
and Ponds
Storm
water
outfall
Salinas Treatment Plant Ponds
Blanco Drain
Salinas Storm Water Outfall
Salinas Pump Station
Reclamation Ditch
GWR Treatment Plant Site
Advanced
Treatment
Pre-treatment
Bob
Product Water Conveyance
OPTION 2: Follows
MPWSP Route
OPTION 1: Follows
Recycled Water Route
GWR Recharge Concept Schematic
California Environmental Quality

Act Purpose
CEQA Guidelines 15002(a)
Inform decision-making
Prevent significant damage to
environment
Public disclosure
Environmental Impact Report

Purpose
CEQA Guidelines 15121
Disclose the environmental effects

of a proposed project
Identify mitigation measures to
avoid, reduce, minimize significant
environmental effects
Evaluate reasonable alternatives
Key Topics in EIR
Surface Water Hydrology/Quality

Groundwater Hydrology/Quality
Water Supply Quality/Public Health
Construction vs. Operational Impacts
Direct and Indirect Adverse Impacts
Other CEQA-required issues
Purpose of Meeting: Define

Scope/Content of EIR
Verbal comments and comment cards accepted
after presentation tonight
Please follow-up with written comments today
or through July 2nd at 5:00 PM.
EIR scope /content may be modified per
comments
All comments to be assembled in scoping
memo and addressed in EIR
GWR CEQA Process

Lead Agency
EIR Determination
/Scoping
30-day NOP
Comment Period
(through July 2, 2013)
Today
Draft EIR
45-day Public
Review Period (Winter 2014))
Final EIR
Review of Final EIR
(Summer 2014)
EIR Certification/
Project Approval
Summer
2014
For More Information

Monterey Peninsula Water Pollution
Control Agencys
Groundwater Replenishment
Website:
http://www.mpwaterreplenishment.org/
Comments on Scope of EIR

Please provide comments that focus on the scope
and content of the EIR.
Comments Due: 5:00 pm on July 2, 2013
Ways to comment:
1. provide verbal comments tonight,
2. transmit tonight on comment cards, or
3. send to Bob Holden at:
gwr@mrwpca.com or
Monterey, CA 93940
Public Comments
APPENDIX C-2
GWR PUBLIC SCOPING MEETING - SIGN-IN SHEET
JUNE 18, 2013
Attendee List for GWP Scoping Meeting on 6-18-13
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
Name
Roger Masuda
Jim Cullem
Bob Schubert
Eric Zigas
Ken Ekelund
George Riley
Robert Guidi
Joe Oliver
Helen Rucker
Gary Pelear
David Chardavoyne
Dave Pacheco
Judi Lehman
Robert Johnson
Kenneth Mishi
Terry Applebury
Peter Le
Rudy Fischer
Jonathan Lear
Kelly Nix
Ron Weitzman
Brain True
Bill Carrothers
Carmelita Garcia
Keith Israel
Bob Holden
Mike McCullough
Chayito Ibarra
Dave Stoldt
Denise Duffy
Alison Imamura
Michael Gonzales
Rayanne Bethke
Diana Buhler
Valerie Young
Company
Marina Coast WD
MPRWA Executive Director
Monterey County Planning
ESA
MCWRA Board of Directors
Citizens for Public Water
Department of Army
MPWMD
City of Salinas
E-mail
rmasuda@calwaterlaw.com
jcullem@harris-assoc.com
schubert@co.monterey.ca.us
ezigas@esassoc.com
kenekelund@redshift.com
georgetriley@gmail.com
robert.g.guidi.civ@mail.mil
Joe@mpwmd.net
hrucker@mpusd.k12.ca.us
MCWRA
City of Seaside
MPWMD
MCWRA
chardavoyneDE@co.monterey.ca.us
dpacheco@ci.seaside.ca.us
jlehman@redshift.com
johnsonr@co.monterey.ca.us
APT
MRWPCA
MPWMD
Carmel Pine Cone
Water Plus
MCWD
MRWPCA
MRWPCA
MRWPCA
MRWPCA
MPWMD
DD&A
DD&A
DD&A
DD&A
DD&A
peter381@sbcglobal.net
rudyfischer@earthlink.net
jlear@mpwmd.net
kelly@carmelpinecone.com
ronweitzman@redshift.com
btrue@mcwd.org
cih5102@earthlink.net
keith@mrwpca.com
bobh@mrwpca.com
mikem@mrwpca.com
chayito@mrwpca.com
dstoldt@mpwmd.dst.ca.us
dduffy@ddaplanning.com
aimamura@ddalanning.com
mgonzales@ddaplanning.com
rbethke@ddaplanning.com
dbuhler@ddaplanning.com
valerieyoung@rcn.com
APPENDIX C-3
GWR PUBLIC SCOPING MEETING VERBAL COMMENTS OF FLIPCHARTS
JUNE 18, 2013
APPENDIX C-4
GWR PUBLIC SCOPING MEETING MEETING NOTES
JUNE 18, 2013
GROUNDWATER REPLENISHMENT (GWR) PROJECT

NOP SCOPING MEETING NOTES
OLDEMEYER CENTER
986 HILBY AVENUE
SEASIDE, CA 93955
TUESDAY , JUNE 18, 2013
6:00 P.M. - 8:00 P.M.
MEETING PRESENTERS
Keith Israel
Denise Duffy
Bob Holden
Alison Imamura
MEETING ATTENDEES
(See attached attendee list)
MEETING NOTES
PRESENTATION OUTLINE (COPY OF PRESENTATION IS ATTACHED )
(Keith Israel)
Title Slide and Introduction
(Dave Stoldt, MPWMD)
MPWMD role, costsharing
(Denise Duffy)
GWR CEQA & Technical Teams
(Bob Holden)
GWR CEQA Process
GWR Overview
About MRWPCA
Project Location Overview
State and Judicial Orders Reduce Cal-Am Water Supply
GWR Relationship to Monterey Peninsula Water Supply Project
Primary Project Objectives
Secondary Project Objectives
Overview of GWR Facilities
Salinas Treatment Plant Ponds
Denise Duffy and Associates, Inc.
Updated: June 27, 2013
Blanco Drain
Salinas Storm Water Outfall
Salinas Pump Station
Reclamation Ditch
GWR Treatment Plant Site
Proposed Water Purification Process
Product Water Conveyance
GWR Recharge Concept Schematic
(Alison Imamura)
California Environmental Quality Act Purpose
Environmental Impact Report Purpose
Key Topics in EIR
Purpose of Meeting: Define Scope/Content of EIR
GWR CEQA Process
For More Information
(Denise Duffy)
Comments on Scope of EIR
PUBLIC COMMENTS
1.
Bill Carrothers
2.
This project will need an outstanding hydrologist that is very familiar with the Seaside Basin.
This project with also need a superb water engineer.
A gifted leader will be essential Keith Israel (MRWPCA)
Ron Weitzman, WaterPlus (these comments were also submitted in written form)
WaterPlus suggest that the EIR for the GWR address the following items:
1. Toxins in each potential water source
2. Discharge rate and natural capacity of Seaside aquifer
3. Cost of storage facility for excess effluent
4. Cost of solar energy for a desal-only project
5. Amount of required diluent
6. Flow rate of injection & extraction wells
7. Cost comparison with desal-only project
Justification:
Items 1, 5, and 6 are important because the currently proposed GWR project includes sources of supply water
besides sewer water, the principal source in previous versions of the project proposal. These additional
sources, as well as sub-surface injection for potable use (rather than to retard saltwater intrusion), go beyond
the precedent of Orange County and include pollutants not addressed there. Public Health concerns are a
major issue of the project as currently proposed.
Item 2 is important because GWR involves storage of water over time in the Seaside aquifer, which is
considered to be quite porous. The capacity of the aquifer and its discharge rate must be determined to
estimate the amount of injected water that may be lost prior to extraction. Will this amount this is will
adversely affect efforts to retard saltwater intrusion?
Items 3 and 4 are important because a storage facility for excess effluent and solar energy powering
desalination are environmentally-friendly alternatives to GWR for the EIR to evaluate. The cost of the storage
facility, which would allow farmers to use excess winter effluent in the summer, or the cost of solar energy for
desalination may be considerably less than the cost of GWR.
Item 7 is important for the reason just given: Alternatives to GWR that are equally environmentally friendly,
while affording lower risk to public health, may cost less than GWR.
3.
George Riley, Citizens for Public Water
4.
Helen Rucker, City of Salinas
5.
Suggested that the EIR include information about industrial and environmental hygiene.
Suggested that the EIR address the potential for operational failures at the Water Treatment
Plant.
Asked about the quality of water that would be sent to the outfall location as opposed to that of
the water sent to Seaside for injection.
Ron Weitzman (a second time)
7.
Concerned about the outreach that was done for this meeting and the project in general, as she
was surprised that more residents were not in attendance.
It is important that non-experts are included in the scoping and made aware of project issues.
Bill Carrothers (a second time)
6.
Will the EIR explore or include any of the positive impacts (benefits) in addition to the negative
impacts?
Will other alternatives to the project (besides those already included)be addressed in the EIR?
Is it possible that a larger scale version of the GWR project can solve the entire water supply
issue, therefore eliminating the need for a desalination plant?
Helen Rucker (a second time)
Is the cost of the GWR project greater or less than the cost of a typical desalination plant?
Who will bear the cost of this project; will local residents with lower incomes be able to afford to
live in this area?
APPENDIX D
NOP COMMENT LETTERS
SORTED BY DATE RECEIVED AND BRACKETED BY SUB-COMMENT
MAY 30, 2013 THROUGH JULY 2, 2013
Letter A
From: Bob Holden [mailto:bobh@mrwpca.com]

Sent: Mon 6/17/2013 4:42 PM
To: GWR; Alison Imamura; Valerie J. Young; Denise Duffy
Cc: Mike McCullough; Karen Harris
Subject: Eleanor Citen
All,
Ms. Eleanor Citen, PO Box 2428, Carmel, CA 93921, came to 5 Harris Court, Bldg. D this afternoon about
3:40 PM. She wanted to talk about GWR. She indicated that she will not attend the scoping meeting
tomorrow. She doesn't want to drink recycled water. She gave me materials she purchased from
Aquafornia (Water Education Foundation) for my education (Bay-Delta Tours, 2013 Water Tours,
Western Water magazines, and Viewer's Guide: Drinking Water-Quenching the Public Thirst) . She knew
about OCWD and how they are expanding. I told her that I drank water at Orange County. She said she
has heard of others drinking it and that it tastes ok. However, she did not think it was safe as it had
chemicals from the fields in it. I told her that the California Department of Public Health believes it is
safe and that they are looking into direct potable reuse. I explained how direct potable took the
advanced treated water and either put it into the drinking water treatment plant or directly into a pipe
to the consumers. She wants a project to be built to provide water. She does not want it to include
water of wastewater origin. She would like me to go to meetings and get some of the water that
Southern California will no longer need for us locally.
She thanked me for listening to her and gave me her card.
Thanks,
Bob
A-1
Letter B
From: Ron Weitzman [mailto:ronweitzman@redshift.com]

Sent: Tuesday, June 18, 2013 4:40 PM
To: GWR
Subject: Items Suggested by WaterPlus for Inclusion in the EIR for GWR
ATTN: Bob Holden, Principal Engineer, MRWPCA

WaterPlus suggests that the EIR for GWR address the following
items:
Toxins in each potential water source
1.
2.
Discharge rate and natural capacity of
Seaside aquifer
3.
Cost of storage facility for excess
effluent
4.
Cost of solar energy for a desal-only
project
Amount of required diluent
5.
6.
Flow rate between injection &
extraction wells
7.
Cost comparison with desal-only project
Justification:
Items 1, 5, and 6 are important because the currently
proposed GWR project includes sources of supply water in
addition to sewer water, the principal source in previous
versions of the project proposal. These additional sources, as
well as sub-surface injection for potable use (rather than to
retard saltwater intrusion), go beyond the precedent of Orange
County and include pollutants not addressed there. Public
B-1
Letter B (cont)
Health concerns are a major issue of the project as currently

proposed.
B-1
cont.
Item 2 is important because GWR involves storage of water

over time in the Seaside aquifer , which is considered to be
quite porous. The size of the aquifer and its discharge rate
must be determined to estimate the amount of injected water
that may be lost prior to its extraction. Whatever amount this
is will adversely affect efforts to retard saltwater intrusion.
B-2
Items 3 and 4 are important because a storage facility for

excess effluent or solar energy powering desalination are
environmentally-friendly alternatives to GWR for the EIR to
evaluate. The cost of the storage facility, which would allow
farmers to use excess winter effluent in the summer, or the
cost of solar energy for desalination may be considerably less
than the cost of GWR.
B-3
Item 7 is important for the reason just given: Alternatives to

GWR that are equally environmentally friendly, while affording
lower risk to public health, may cost less than GWR.
B-4
--Ron Weitzman, for WaterPlus
Letter C
C-1
C-2
C-3
C-4
Letter C (cont)
C-5
C-6
C-7
C-8
C-9
C-10
Letter C (cont)
C-11
C-12
C-13
C-14
C-15
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter C (cont)
Letter D
From: Guidi, Robert G CIV (US) [mailto:robert.g.guidi.civ@mail.mil]
Sent: Wednesday, June 19, 2013 12:05 PM
To: GWR
Cc: Elliott, John H CIV (US); Grover-Bullington, Lenore R CIV (US); Preciado, Rogelio E CIV (US)
Subject: GWR EIR Scoping
Dear Bob,
Thank you for the opportunity to provide input on the Monterey Peninsula GWR EIR. Undoubtedly this
proposed project and associated environmental analysis will receive a substantial amount of scrutiny.
Having listened to the various presentations and read the NOP for the EIR here are a few initial
comments for consideration during the CEQA public scoping process as follows:
1.
2.
3.
Water Quality MRWPCA and DDA are planning to address the potential environmental
impacts thereof. The depth or extent of that analysis is critical because of the safety concerns
associated with the proposed technology. People must be highly assured the groundwater
pumped out the aquifer is safe for consumption. The effluent from the six sources of recovered
water is an initial concern. These sources vary significantly in concentrations and types of
contaminates. Once these source waters are pumped and treated at the regional wastewater
treatment facility the quality of the product water injected into the Seaside Basin Groundwater
Aquifer comes into question (e.g. potential to contaminate the existing groundwater aquifer).
Likewise, there are concerns about the quality of the mixed groundwater being provided for
reuse. Bottom line this environmental analysis must be thorough and flawless leaving no
unanswered questions about safe drinking water.
Socio-economic This proposed project will probably add another water user fee to
overburdened business and property owners. The costs of not only this project bit also the
cumulative socio-economic impacts of multiple regional water projects need to be analyzed in
detail. Various financial impacts, both adverse and beneficial must be explained clearly. The
economic ripple effects throughout the communities from water rate increases such as higher
costs for goods/services and gains/losses in jobs must be fully analyzed. The estimated range of
the per unit costs in AF/yr for this proposed new source of water should be assessed against
other proven supplemental water supplies and clearly explained to the water rate payers .
Biological impacts Three barriers have been identified for the treatment of the
groundwater. Other types of barriers such as exposure to high intensity ultra-violet light
combined with H2O2 should be addressed. Explaining the environmental reasons for selecting
and eliminating alternative technologies provides a better analysis.
Hopefully these initial comments are helpful in the scoping the EIR. Please keep POM DPW informed of
any upcoming meetings and the availability of the Draft EIR.
Robert Guidi
USAG POM DPW
Master Planning
831-242-7928
D-1
D-2
D-3
Letter E
E-1
E-2
Letter F
Coalition of Peninsula Businesses

A coalition of the Monterey County Hospitality Association, Monterey Commercial Property Owners'
Association, Monterey Peninsula Chamber of Commerce, Carmel Chamber of Commerce, Pacific Grove
Chamber of Commerce, Monterey County Association of Realtors, Community Hospital of the Monterey
Peninsula, Associated General Contractors Monterey District
to resolve the Peninsula water challenge to comply with the CDO at a reasonable cost
June 27, 2013

Bob Holden
#5 Harris Court, Building D
Monterey, California 93940
Transmitted by e-mail to GWR@mrwpca.org
Dear Mr. Holden:
The Coalition of Peninsula Businesses (CPB) submits these comments on the Notice of Preparation (NOP)
for the Monterey Groundwater Replenishment Project Environmental Impact Report.
Purpose of project
The project description should be more specific as to the purpose of the project; it is variously described as
intended to help resist Seaside Basin seawater intrusion, as a source of replenishment water to help Cal
Am meet its water needs with other than its illegal pumping of Carmel River Basin water and Seaside
Basin water in excess of the water master-determined safe yield limits, and as a means to reduce the desal
plant size of Cal Ams Monterey Peninsula Water Supply Project.
The project description needs to be amended to establish a clearer project purpose, explain the projects
relationship or inter-relationship with the regional water project pending before the PUC, and to provide a
clearer definition of its intended goal. Whether the Groundwater Replenishment Project is intended to be
a stand-alone project or as a supplement to Cal Ams project should be spelled out clearly. The NOP seems
to be geared to Peninsula water supply replacement only but it is not clear how or when or why that
decision was made, if in fact a decision had been made.
F-1
Inter-relationship with the CSIP project

MRWPCA apparently intends to use or build upon the facilities built for and financed by the landowners in
the CSIP area. The rights of those landowners for use of reclaimed water up to the first 19,500 AFY and
MRWPCAs right to divert any portion of that reclaimed water to another use must be explained.
F-2
Source water
Sources of water to be reclaimed clearly must be spelled out, the status of agreements for acquisition and
transportation of source water must be disclosed and legal rights to the use the source water and then to
distribute recycled water need to be clearly established. The legal dispute between MRWPCA and ag
interests as to rights to recycled water and the quantity of recycled water assured to ag interests must be
resolved. If necessary, the sources of water to be recycled must be sufficient to meet the assurances to ag
interests and provide water for sale to Cal Am for drinking water.
OCEAN & MISSION SUITE 201 P.O. BOX 223542 CARMEL, CA 93922
PHONE: 831-626-8636 FAX: 831-626-4269 EMAIL: jrbobmck@gmail.com or badams@adcomm4.com
F-3
Letter F (cont.)
Quality of source water
Rec ditch and other ag sources of water to be recycled are mentioned as possibilities. The Monterey
County Water Resources Agency has conducted several studies of the quality of rec ditch and other ag
runoff waters and found those waters to be highly polluted and contaminated. The instant EIR should
reflect those prior studies and explain in some detail how the pollution and contamination will be dealt
with to elevate the recycled water to California Department of Public Health standards. Specific examples
of where source water of this quality has been successfully reclaimed to drinking water standards and at
what cost should be provided.
F-4
Reliability of the continuing quantity of source water

Due to highly increased water conservation measures throughout MRWPCAs service area, the amount of
inflow has decreased over the last several years. This trend should be projected and the effect on
MRWPCAs ability to produce reclaimed wastewater assessed.
F-5
The same question should be answered in light of the proposed source water given the increased emphasis
on water conservation, recycling and reduction in ag and urban runoff.
F-6
Growth and growth-inducing impacts

The cities and county areas served by Cal Am already have adopted and EIR-certified General Plans that
address growth issues and mitigation measures. The instant EIR should review and reflect those
documents.
F-7
Alternatives
If it is clearly established that the GWR project is intended as a supplement to Cal Ams project or as a
Peninsula water supply replenishment-only project, study of a GWR project as an independent source of
additional Peninsula water supply must be studied.
F-8
Thank you for your attention to our concerns.

Sincerely,
Coalition of Peninsula Businesses
John Narigi, Co-chair
Bob McKenzie, Consultant
Coalition of Peninsula Businesses GWR NOP Comments - June 27, 2013
Letter G
G-1
G-2
G-3
Letter H
H-1
H-2
H-3
H-4
H-5
Letter H (cont)
H-6
Letter I
I-1
I-2
Letter I (cont)
I-2
cont
I-1
I-3
I-4
Letter I (cont)
I-2
I-5
I-3
I-6
I-4
I-7
I-5
I-8
Letter I (cont)
I-9
I-6
I-7
I-10
I-8
I-11
Letter I (cont)
I-11
cont
I-9
I-12
I-13
I-10
I-11
I-14
Letter I (cont)
Letter J
J-1
Page 1 of 1
Letter K
Michael Gonzales
From:
Mike McCullough [MikeM@mrwpca.com]
Sent:
Tuesday, July 02, 2013 3:51 PM
To:
Michael Gonzales; Alison Imamura; Denise Duffy; valerieyoung@rcn.com
Cc:
Brad Hagemann; Keith Israel
Subject: Comments from an individual - Peter Le
July 1, 2013
I have the following comments on the scope and contents of the GWR EIR prepared by MRWPCA:
The EIR needs to analyze thoroughly how the proposed project affects the agreed recycled water
capacity of the MCWD in the approximate amount of 2.1 MGD. If MCWD utilizes it full 2.1 MGD
K-1
recycled water, how much treated water the proposed project can provide.
Similarly, if the farmers insist on their share of 19,500 AFY of recycled water, how does this affect the
proposed project?
How does the 3,500 AFY arrive at? The EIR needs to show calculations on this proposed quantity for
K-2
the existing and future conditions.
The MRWPCA claimed that it has spent about 3 million dollars on modifying the regional treatment
plant to provide recycled water to MCWD under the 2009 RUWAP agreement. Will this project utilize
the MCWD designs or modified regional treatment that will be paid by MCWD for this project? What K-3
additional work on the regional treatment plant that will be done on this project? How does MRWPCA
identify and separate all costs for two different projects, MCWD and GWR?
K-4 [What impacts does this proposed project affect the MCWD recycled water project?][What is the required K-4/K-5
separation between MRWPCA recycled pipes and MCWD recycled pipes? ] K-5
The EIR needs to consider the alternative of pumping excess winter flow from the Salinas River, treat it,
and recharge the Seaside Aquifer.
How do the discharges of the proposed advanced water treatment plant and secondary source water
K-6
affect the MCWD brine disposal capacity and the total capacity of the existing outfalls?
How does the cooperation between MRWPCA and MCWD involve as described in page 11 of the
K-7
NOP?
MRWPCA proposes to use the partially MCWD completed recycled water system for this GWR project
as described on page 15. Has MRWPCA discussed with any Director or staff on this proposal?
K-8
How does this project affect MCWD access to the acquired Armstrong Ranch property?
What is the current residence time of the recharged water as specified by the State?
I would like to ask MRWPCA to make a presentation to the MCWD Board on their expectations of the
K-9
MCWD roles on this proposed project.
The above comments are mine and they do not represent the official comments from MCWD. Let me
know if you have any questions.
Sincerely,
Peter Le
7/9/2013
Letter L
L-1
L-2
L-1
Letter M
M-1
M-2
M-3
Letter M (cont)
M-3
cont
M-4
M-5
M-6
M-7
M-8
M-9
Letter N
~c_e)vJ... Svt.~ 2.( ~o

July 1, 2013
~JdA~

Administration Office
ATTN: Mr. Bob Holden, Principal Engineer
5 Harris Court, Building D
Monterey, CA 93940
SUBJECT:
Notice of Preparation of Environmental Impact Report for the Monterey

Peninsula Groundwater Replenishment Project, May 30, 2013
Dear Mr. Holden:

At its June 17, 2013 meeting, the Monterey Peninsula Water Management District (MPWMD)
Board of Directors reviewed the Notice of Preparation (NOP) for the Monterey Peninsula
Groundwater Replenishment (GWR) Project Environmental Impact Report.
In addition,
MPWMD staff have worked with you during the development of the NOP. As you know,
MPWMD is strongly in favor of moving ahead with this EIR and a project that allows 3,500 acrefeet per year (AFY) to be extracted from the Seaside Groundwater Basin (SGB) for municipal use.
We have the following comment on the NOP and recommendation for the EIR:
Water injection and subsequent extraction in the Seaside Groundwater Basin

Page 17 of the NOP states:
"It is anticipated that recharge amounts allocated to each well type and target aquifer could
readily be adjusted based on basin conditions that will be determined through ongoing
monitoring."
MPWMD monitoring of the Santa Margarita aquifer suggests that not all water injected by the
GWR Project would be expected to be extracted at existing municipal supply wells completed in
the aquifer. While a bypassed portion of injected water may not be "lost" to the aquifer and could
eventually help stabilize water levels, it is important that this effect should be better understood
with respect to the GWR Project.
MPWMD recommends that the EIR contain an evaluation of both the travel time and volume of
water moved between injection and extraction sites in order to determine what portion of injected
water can be safely extracted and when. It is possible that in the initial stages of the GWR Project
more than 3,500 AFY will need to be injected into the basin in order to provide a net of 3,500
AFY without temporarily or permanently exacerbating the potential for seawater intrusion at
extraction sites. An alternative approach could be to develop an operating rule for the basin that
would define what period of time must pass between the initiation of injection operations and the
5 Harris Court, Building G, Monterey, CA 93940 P.O. Box 85, Monterey, CA 93942-0085
831-658-5600 Fax 831-644-9560 http://www.mpwmd.dst.ca.us
N-1
N-2
Letter N (cont)
Mr. Bob Holden
July 1, 2013
Page 2 of2
initiation of extraction operations. In other words, there could be a "buffer" amount of water that
is injected into the basin that would increase water levels at extraction sites to a condition that is
determined to be "safe" for initiating extraction.
I appreciate the work done over the past several years by the Monterey Regional Water Pollution
Control Agency to develop this project and look forward to working with you in the future. If you
have questions or comments about this letter, please contact me at (831) 658-5650.
Sincerely,
David J. Stoldt, General Manager

cc: MPWMD Board of Directors
U:\Lany\WaterSupplyPianning\Groundwater Replenislunent\EIR\MPWMD-comments-NOP-2July20 13 .docx
N-2
(cont)
Letter O
CITY
C
OF PACIFIC
P
G
GROVE
300 Forest Avenuee Pacific Groove, California
July 2, 2013
Monterrey Regionaal Water Polllution Contro
ol Agency
ATTN: Bob Holdeen
5 Harriis Court, Bld
dg D
Monterrey, CA 939
940
RE: Comments
C
on
n Notice of Preparation
n Montereey Peninsulla Groundw
water
Replen
nishment Prroject Envirronmental Impact
I
Repoort (EIR)
Dear Mr.
M Holden:
to commentt on the Notice of
o
The Ciity of Pacificc Grove apprreciates the opportunity
Preparaation for the Groundwatter Replenish
hment Projecct (GWR) EIIR. As a fouunding
membeer of the Monterey Regio
onal Water Pollution
P
Coontrol Agenccy (MRWPC
CA), we are
supporrtive of the Agencys
A
goaals to expand
d recycled w
water uses to the GWR annd reduce orr
eliminaate winter diischarges to the Montereey Bay. Paciific Grove hhas similar gooals to
maxim
mize recycled
d water oppo
ortunities and
d eliminate w
wastewater ddischarges too the Monterrey
Bay.
Becausse of the City
ys distance from the reg
gional treatm
ment plant, thhe urban areeas between,
the natture of the lo
ocal topograp
phy, and the resulting pooor cost effecctiveness forr extending
recycleed water deliivery, MRW
WPCA has no
ot previouslyy consideredd opportunityy sites withinn
Pacificc Grove as feeasible to serrve recycled water. Therrefore, Paciffic Grove is independenttly
develop
ping a non-p
potable recyccled water su
upply projecct for irrigatiion of the Paacific Grove
Golf Links, El Carm
melo Cemettery, and oth
her potential opportunitiees for recycleed water usee
nearby
y on the Mon
nterey Peninssula. The Paacific Grovee Local Wateer Project (L
LWP) includees
constru
uction of a new satellite recycled waater treatmennt facility at tthe existing Point Pinos
wastew
water treatmeent plant sitee to produce an initial 1225 acre feet pper year. Thhe City planss to
reclaim
m its wastewater from thee Citys sew
wage collectioon system, oover which thhe City has
sole co
ontrol and ow
wnership.
In addiition, Pacificc Grove facees significantt challenges in meeting tthe State Waater Resourcces
Contro
ol Boards requirements for
f discharges to the Paccific Grove A
Area of Speccial Biologiccal
Signifiicance (ASB
BS). As prev
viously perm
mitted by MR
RWPCA and noted in thee NOP, the
City off Pacific Gro
ove has alreaady constructted portions of a dry weather storm water
diversiion system in
n order to meeet the ASBS discharge regulations,, which prohhibit dry
weatheer dischargess. The LWP
P is evaluatin
ng the redirecction of dry weather storrm water floows
from itts current pu
umping to thee MRWPCA
A regional treeatment plannt.
Phone
P
(831) 648-5722 www
w.ci.pg.ca.us
O-1
O-2
O-3
Letter O (cont)
We sup
pport the NO
OP statementt that MRWP
PCA membeer entities coould send stoorm water too
the Reg
gional Treatm
ment Plant for
f use in thee GWR Proj ect. In collaaboration with the City oof
Monterrey, the City
y is refining its
i investigattion of alternnative means of divertinng and
potentiially treating
g wet weatheer storm wateer flows as ppart of a com
mpliance projject for the
ASBS. The ASBS
S/Stormwaterr Reuse Projject is includded within thhe Montereyy Bay
Integraated Regionaal Water Man
nagement Pllan (IRWM
MP) project and has obtaained fundinng
through
h the IRWM
MP program. These invesstigations aree analyzing tthe feasibilitty of optionss
for locaalized storag
ge at the California Ameerican Waterr-owned Davvid Avenue R
Reservoir annd
convey
yance of storrmwater to th
he regional treatment
t
plaant operatedd by MRWPC
CA. Initial
modeliing of wet weather
w
disch
harges has id
dentified totaal flows rangging from 2,5500 gallons pper
minutee (gpm) in an 85th perccentile storm
m event to 122,000 gpm inn a 1-year storm
event. These flowss may be parrtially divertted to the PG
GLWP and reelated facilitties, or to
MRWP
PCA as an ad
dditional sup
pply source to the GWR
R. Average aannual volum
mes that coulld
be diveerted are stilll being deterrmined.
RWPCA mov
ves forward with the GW
WR, we hopee to continuee to coordinaate our
As MR
respecttive efforts and
a projects. We anticip
pate the needd to further ddiscuss the caapacity of thhe
MRWP
PCA convey
yance and treeatment systeems to be abble to acceptt wet weatheer storm flow
ws
and thee total flows from Pacificc Grove to serve
s
the GW
WR Project. The GWR ffacilities
requireed to convey
y and inject th
he additionaal storm wateer volume avvailable from
m the Cities
should be addresseed in the GW
WR EIR. Theese issues arre more projeect-design reelated yet are
likely to
t also produ
uce environm
mental effectts requiring additional reeview. The City believees
that thee GWR Project EIR shou
uld also consider the loccally proposeed projects, pparticularly in
its anallysis of cumulative effeccts.
The GW
WR Project, particularly
y if augmenteed by storm water flowss and eliminaation of
discharrges to the Monterey
M
Bay
y, has poten
ntial benefits to local MS
S4 dischargerrs that shoulld
be ackn
nowledged in
i the Projecct Objectivess. The Seasi de Groundw
water Basin hhas adequatee
storagee capacity an
nd need for replenishmen
r
nt that the oppportunity too cost effectiively
incorpo
orate wet weeather storm flows shoulld be fully exxplored and maximized.
Sincereely,
Thomaas Frutchey, City Manag

ger
City off Pacific Gro
ove
cc:
Sarah Hard
dgrave, Envirronmental Prrograms Maanager
James Brezzack, Brezack and Assocciates Planniing
Page 2
O-3
(cont)
O-4
O-5
Letter P
P-1
P-2
P-3
P-4
P-5
P-6
P-7
P-8
P-9
P-10
P-11
P-12
Letter Q
Q-1
Q-2
Q-3
Q-4
Letter Q
Q-5
Q-6
Letter R
R-1
R-2
R-3
Letter R (cont)
R-4
R-5
R-6
R-7
R-8
R-9
Letter R (cont)
Letter S
Fort Ord Community Advisory Group (FOCAG)

P.O. Box 969
Seaside, CA 93955
Phone: 831-484-6659
Email: focagemail@yahoo.com
The "Fort Ord Community Advisory Group is a public interest group formed
to review, comment and advise on the remediation (cleanup) of the Fort Ord
Army Base, Superfund Site, to ensure that human health, safety and the
environment are protected to the greatest extent possible." - Mission
Statement.
Monterey Regional Water Pollution Control Agency (MRWPCA)

ATTN: Bob Holden
Monterey, CA 93940
Via E-mail: GWR@mrwcpa.com, hard copy to follow via U.S. Mail
Re: Notice of Preparation, Scoping Comments
Monterey Peninsula Groundwater Replenishment Project Environmental
Impact Report
July 2, 2013
Dear Bob Holden,
The Fort Ord Community Advisory Group (FOCAG) offers the following
comments on the scope of environmental issues. The scope should include
existing hazards to drinking water and potential increasing hazards to the
drinking water supply due to the migration and leaching of toxic chemicals
from former Army training ranges. These would include proposed ground
S-1
disturbing activities including a horse park. The Seaside Aquifer lies directly
beneath the Army Training Ranges, known as Site #39 of former Fort Ord.
This area includes the area known as Parker Flats that had, among other
uses, Army tank training areas.
Fort Ord is a National Superfund Site, first put on the National Superfund
Priority List because of discovered contamination of area groundwater.
S-2
Letter S (cont)
Page 2
There have been multiple issues with the Upper 180, the Lower 180, and the
400-foot aquifers beneath areas of former Fort Ord. Site #39, perhaps the
largest munitions impact/training area in the country, sits over the Seaside
Groundwater Basin. This should be of concern to MRWPCA and others for
the possibility of leaching and migration of chemicals into underground
aquifers.
S-2
cont
It is understood residual munitions chemicals from 77-years of munitions

use, remain in Fort Ord training areas, including Site 39. The cleanup thus
far, has concentrated on remaining unexploded munitions, but failed to
identify many munitions constituents even though numerous munitions
chemistry books were and are readily available. How can the extent of
contamination be known unless all known munitions constituents are looked
for? The cleanup has used a sampling rationale of looking for a few
constituents but only reporting levels above a certain threshold. There
potentially are hundreds of chemicals below threshold levels. For example,
hypothetically, if there are two hundred chemicals each at 2 ppm, well below
the reporting level, there potentially could be a toxic chemical brew of 200400 ppm. Could the cumulative, low levels of chemicals potentially be
a health hazard? Are the human health risks known for this level of
exposure? What are the synergistic effects of munitions chemicals and
pesticides on organisms? Are there studies available on the effects of lowlevel exposure to these chemicals?
Hundreds of munitions chemicals and pesticides at very low levels may be a
potential toxic brew creating a health and safety hazard in the underground
water aquifers. The cleanup has failed to make the public aware of the actual
levels of munitions and pesticide contaminates throughout training areas.
a) What might be the justification for the cleanup failing to identify all the
munitions and pesticide chemicals in Tables 3,4,5, and 6? (See Attachment
2, Tables 1-7). The Army BRAC has been asked the following questions:
b) Because the Army kept abysmal records of training ranges, training areas
and specific activities, what is the justification for failing to look for all
munitions chemicals and pesticides in all training areas, including Site #39?
c) What is the justification for the cleanup failing to include all the
munitions and pesticide chemicals identified in Attachment 2, Tables 3,4,5,
and 6?
d) What is the extent of out-gassing from munitions and pesticide chemicals
S-3
Letter S (cont)
Page 3
in former training areas?
e) What is the justification for failing to report the actual levels of munitions
and pesticide chemicals in all training areas?
S-3
cont
On 3-24-10 (fortordcleanup.com, Document BW-2532), and 2-7-11

(fortordcleanup.com, Document BW-2557), the FOCAG raised questions
regarding pesticide use at Fort Ord and in training areas. The
2-7-11 FOCAG letter specifically addresses Armys failure to thoroughly
investigate pesticides in training areas. Despite Armys claim that it has
thoroughly investigated pesticides in training areas, our review of the cited
cleanup documents did not support the Armys claim. The only sampling
we have found for pesticides in the Parker Flats and Site 39 training areas
was for a total of 4 sample locations that only looked for 8 organochlorine
pesticides.
It is our understanding Army BRAC remains responsible for identifying and
sampling for chemicals potentially used in training areas, including Site 39.
However, the chemicals being looked for in former Army training sites is
woefully inadequate. The FOCAG includes, with this letter, 7 Tables
of munitions chemicals and pesticides potentially found in former Fort Ord
including a list of Training Areas and the chemicals actually being looked
for in. (See attachment 2, Tables 1-7)
There are several hundred chemicals potentially leaching out of ordnance
into the ground as well as residual chemicals from decades of
weapons/ordnance training and pyrotechnics. Herbicides were used to keep
vegetation down and minimize threats of wildfires from munitions training
exercises. Attached are 6 Tables identifying munitions chemicals and
pesticides used in training areas include Table 1, is the Fort Ord Cleanup
1994 list of potential Training Range chemicals. Table 2 is the Fort Ord
Cleanup 2003 Sampling and Analysis list of potential Training Range
chemicals. Tables 3, and 4 are lists of munitions constituents found in
munitions chemistry books, many of which the cleanup has not included in
its list(s). Tables 5, and 6 are lists of pesticides; known and suspected as
being used at Fort Ord. Particularly alarming is Table 5 that identifies 23
munitions chemicals also known to be pesticides. This may explain why
some training areas are virtually devoid of insects and birds. Not only has
S-4
Letter S (cont)
Page 4
the cleanup thus far failed to identify all munitions chemicals and pesticides;
it has also failed to extensively look for all munitions chemical and
pesticides in all training areas.
S-4
cont
The FOCAG is not aware of any Basewide training maps pre-1940. We do

know the entire pre-1940 Fort Ord footprint was the Gigling Artillery Range
1917-1940. It is understood this artillery range primarily trained with 37mm,
75mm, 105mm, and 155mm projectiles. These projectiles are found
throughout most of the pre-1940 footprint. One of the known impact areas
for the pre-1940s 37mm and 75mm projectiles is "Artillery Hill". This area,
OE-50 and OE-53 (Veterans Cemetery and Endowment Parcels), when
sampled and cleared to a depth of 4' discovered significant amounts of
37mm and 75mm fragments and unexploded projectiles. According to the
Archives Search Report and interviews with range control personnel, these
Sites were target areas for rifle grenades and shoulder launched projectiles in
the 1940s, 1950s and 1960s. Other projectiles found include 60mm,
81mm, 3 inch stokes, and 4.2 inch mortars, and Levins projectors. The latter
ground tube launched munitions range(s) was not known prior to the
sampling and removal actions. The FOCAG is unaware of historical
training maps showing the firing points, range fans, or target areas of any of S-5
the ranges within or firing out of Sites OE-50 and OE-53 yet these areas
were obviously extensively used for munitions training.
The proposed Veteran's Cemetery site among other uses was a former 192030s; 37mm and 75mm artillery target range known as Artillery Hill. The
Veteran's site also includes a Chemical, Biological, Radiological, (CBR)
site. Training devices and munitions discovered nearby include non-metallic
landmines and Chemical Agent Identification Sets (CAIS) in glass vials. The
detection equipment used to clear this site is incapable of detecting nonmetallic, and deeply buried munitions. Although the munitions cleanup was
to a depth of 4.0, the 37mm has a maximum detection depth of 0.9 and the
75mm has a maximum detection depth of 2.5. There are other munitions
found onsite that cannot be reliably detected within 4 of the surface.
Again, there have been multiple issues with the Upper-180, the Lower-180,
and the 400-foot aquifers beneath areas of former Fort Ord. Site 39, perhaps
the largest munitions impact/training area in the country, sits over the
Seaside Groundwater Basin. This should be of concern to MRWPCA and
S-6
Letter S (cont)
Page 5
others for the possibility of leaching chemicals into underground aquifers.
Project Scoping should include:
a) What is the migration and fate of munitions and pesticide chemicals into
this drinking water supply?
b) Where did all the chemicals go?
c) What Fort Ord document fully investigated the potential munitions and
pesticide contamination?
d) Is there ongoing monitoring and reporting of the potential munitions and
pesticide contamination of the Seaside Groundwater Basin? Where is it?
e) What might construction, development, and irrigating in the area above
the Seaside Groundwater Basin do for migrating chemicals?
Thank you for the opportunity to comment on this NOP/Scoping for the
EIR for the proposed Monterey Peninsula Groundwater Replenishment
Supply.
Respectfully,
Mike Weaver
Co-Chair, FOCAG
Attachment #1
Reference the following link:
http://fortordcleanup.com/adminrec/ar_pdfs/AR-ESCA-0100/ESCA0100.PDF
This link is regarding Site 39. August 12, 2008, Fort Ord Community
Advisory Group Position Paper
80-pages of research, statistics, commentary, analysis, and questions.
Attachment #2
(Reference the attachment to this letter sent via email. Hard copy to follow.)
Tables 1-7 (34 pages total)
Fort Ord known and suspected Munitions and Pesticide Chemicals used in
Training Areas
S-6
cont
Letter S (cont)
Test Method/Analyte Name

EPA 8080
Gamma - BHC
Heptachalor epoxide
Dieldrin
4,4' -DDE
Endrin
4,4' -DDD
4,4' -DDT
Chlordane
EPA 9060
Total Organic Carbon
Salinas
34
35
36
37
38
PARKER FLATS
39
41
40
48
50
49
47
SITE 39
46
45
44
43
42
Approximate On Base Soil Sample Locations

Note: Map generated from Fort Ord cleanup documents
Pesticide Sampling
Fort Ord RI/FS 1995, Vol II - Remedial Investigation
Basewide Background Soil Investigation
BW-1283E
Fort Ord Community Advisory Group (FOCAG) 7-6-2010
SEASIDE GROUNDWATER BASIN / SITE 39 IMPACT AREA
Letter S (cont)
Basewide Hydrogeologic Characterization
BW-0608 PLATE 3
NORTHERN SEASIDE BASIN BOUNDRY
SEASIDE GROUNDWATER BASIN
SITE 39
EASTERN
SEASIDE
BASIN
BOUNDRY
SOUTHERN SEASIDE BASIN BOUNDRY
SITE 39 BOUNDRY (8000 Acres, one of the countries largest munitions training areas.)
SEASIDE GROUNDWATER BASIN BOUNDRY (Supplies City of Seaside drinking water.)
Where did all the munitions chemicals go? What chemicals where looked for? What where the actual chemical detection levels?
Letter S (cont)
Fort Ord known and suspected Munitions and Pesticide

Chemicals used in Training Areas
Table 1:
List of munitions chemicals compiled from 1994 Site 39 Remedial Investigation

Note: very few are being looked for in training areas.
Table 2:
List of munitions chemicals compiled from 2003 Sampling and Analysis Plan
Note: very few are being looked for in training areas.
Table 3:
List of munitions chemicals Military Explosives (Chemistry) 30 September 1984

Note: many of these munitions chemicals are not included in Tables 1 & 2
Table 4:
List of munitions chemicals found in practice and pyrotechnic

Note: many of these munitions chemicals are not included in Tables 1 & 2
Table 5:
List of 23 pyrotechnic chemicals also used as Pesticides

Note: may explain why some training areas appear to be devoid of life
(very few bugs, birds, ground squirrels, etc.)
Table 6:
List of 48 pesticides used at Fort Ord

Note: none of these chemicals have been looked for in training areas.
Table 7:
Munitions Chemicals looked for in transferred training areas FORA ESCA

RP parcels
Note: in training areas, very few and in some sites no munitions chemicals have been
looked for. No Training areas have been tested for pesticide chemicals.
Letter S (cont)
Table 1:
Munitions Chemicals identified by the Fort Ord Superfund cleanup;

1994 RI/FS BW-1283K Tables
Phenol
Bis(2-chloroethyl) ether
2-Chlorophenol
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Benzyl alcohol
1,2-Dichlorobenzene
2-Methylphenol
4-Methylphenol
n-Nitrosodipropylamine
Hexachloroethane
Nitrobenzene
Isophorone
2-Nitrophenol
2,4-Dimethylphenol
Benzoic acid
Bis(2-chloroethox)methane
2,4-Dichlorophenol
1,2,4-Trichlorobenzene
Naphthalene
4-Chloroaniline
Hexachlorobutadiene
4-Chloro-3-methylphenol
2-Methlnaphthalene
Hexachorocyclopentadiene
2,4,6-Trichlorophenol
2-Chloronaphthalene
2-Nitroaniline
Dimethl phthalate
Acenaphthylene
2,6-Dinitrotoluene
3-Nitroaniline
Acenaphthene
2,4-Dinitrophenol
4-Nitrophenol
Dibenzofuran
2,4-Dinitrotoluene
Diethyl phthalate
4-Chlorophenyl phenylether
Fluorene
4-Nitroaniline
4,6-Dinitro-2-methyl phenol
n-Nitrosodiphenylamine
4-Bromophenylphenylether
Hexachlorobenzene
Letter S (cont)
Pentachlorophenol
Phenanthrene
Anthracene
Di-n-butlphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
3,3-Dichlorobenzidine
Benzo(a)anthracene
Chrysene
Bis(2-ethlhexyl)phthalate
Di-n-octyIphthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Dibenzo(a,h)antkracene
Benzo(ghi)perylene
Bis(2-chloroisopropyl)ether
TPH-Diesel
TPH-Extractable Unknown Hydrocarbon
TPH-Gasoline
TPH-Purgeable Unknown Hydrocarbon
Benzene
Ethylbenzene
Toluene
Xylenes
HMX
RDX
1,3,5-Trinitrobenzene
1,3-Dinitrobenzene
Tetryl
Nitrobenzene
2,4,6-Trinitrotoluene
2,4-Dinitrotoluene
2,6-Dinitrotoluene
o-NitroToluene
m-NitroToluene
p-ilitrotoluene
2-Amino-dinitrotoluene
Nitroalvcerin
Picri;-hcid
Nitroguanidine
PETN
Letter S (cont)
Table 2:
Munitions Chemicals identified by the Superfund cleanup: 2003 Sampling and

Analysis Plan, Revision 0; Fort Ord, California; BW-2214D
Gasoline (C -C )
4-Bromofluorobenzene
Diesel (C -C )
Motor Oil (C -C )
ortho-terphenyl
Acetone
Benzene
Bromobenzene
Bromochloromethane
Bromodichloromethane
Bromoform
Bromomethane
2-Butanone
n-Butylbenzene
sec-Butylbenzene
tert-Butylbenzene
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
2-Chlorotoluene
4-Chlorotoluene
Dibromochloromethane
1,2-Dibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Dichlorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
cis-1,2-Dichloroethene
trans-1,2-Dichloroethene
1,2-Dichloropropane
1,3-Dichloropropane
2,2-Dichloropropane
1,1-Dichloropropene
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethylbenzene
8006-61-9
460-00-4
68334-30-5
ADR-02-001
84-15-1
67-64-1
71-43-2
108-86-1
74-97-5
75-27-4
75-25-2
74-83-9
78-93-3
104-51-8
135-98-8
98-06-6
75-15-0
56-23-5
108-90-7
75-00-3
110-75-8
67-66-3
74-87-3
95-49-8
106-43-4
124-48-1
96-12-8
106-93-4
74-95-3
95-50-1
541-73-1
106-46-7
75-71-8
75-34-3
107-06-2
75-35-4
156-59-2
156-60-5
78-87-5
142-28-9
594-20-7
563-58-6
10061-01-5
10061-02-6
100-41-4
Letter S (cont)
Hexachlorobutadiene
2-Hexanone
Isopropylbenzene
p-Isopropyltoluene
Methyl tert-butyl ether
Methylene chloride
4-Methyl-2-pentanone
n-Propylbenzene
Styrene
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Trichlorofluoromethane
1,2,3-Trichloropropane
1,1,2-Trichloro-1,2,2-trifluoroethane
1,2,4-Trimethylbenzene
1,3,5-Trimethylbenzene
Vinyl acetate
Vinyl chloride
m,p-Xylene
o-Xylene
4-Bromofluorobenzene
Dibromofluoromethane
1,2-Dichloroethane-d4
Toluene-d8
Acenaphthene
Acenaphthylene
Anthracene
Benzoic acid
Benzo[a]anthracene
Benzo[b]fluoranthene
Benzo[k]fluoranthene
Benzo[g,h,i]perylene
Benzo[a]pyrene
Benzyl alcohol
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butylbenzylphthalate
Carbazole
87-68-3
591-78-6
98-82-8
99-87-6
1634-04-4
75-09-2
108-10-1
103-65-1
100-42-5
630-20-6
79-34-5
127-18-4
108-88-3 75-125
87-61-6
120-82-1
71-55-6
79-00-5
79-01-6
75-69-4
96-18-4
76-13-1
95-63-6
08-67-8
108-05-4
75-01-4
1330-20-7
95-47-6
1868-53-7
460-00-4
17060-07-0
2037-26-5
83-32-9
208-96-8
120-12-7
65-85-0
56-55-3
205-99-2
207-08-9
191-24-2
50-32-8
100-51-6
111-91-1
111-44-4
108-60-1
117-81-7
101-55-3
85-68-7
86-74-8
Letter S (cont)
4-Chloroaniline
4-Chloro-3-methylphenol
2-Chloronaphthalene
2-Chlorophenol
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
3,3'-Dichlorobenzidine
Dibenzofuran
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
Diethylphthalate
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butylphthalate
4,6-Dinitro-2-methylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Fluoroanthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
2-Methylnaphthalene
2-Methylphenol
3-Methylphenol
4-Methylphenol
Naphthalene
2-Nitroaniline
3-Nitroaniline
4-Nitroaniline
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
N-Nitroso-di-n-butylamine
N-Nitrosodiethenolamine
N-Nitrosodiphenylamine
N-Nitroso-di-n-propylamine
Pentachlorophenol
Phenanthrene
Phenol
106-47-8
35421-08-0
91-58-7
95-57-8
7005-72-3
218-01-9
53-70-3
91-94-1
132-64-9
95-50-1
541-73-1
106-46-7
120-83-2
84-66-2
105-67-9
131-11-3
84-74-3
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
193-39-5
78-59-1
91-57-6
95-48-7
108-39-4
106-44-5
91-20-3
88-74-4
99-09-2
100-01-6
98-95-3
88-75-5
100-02-7
924-16-3
1116-54-7
86-30-6
621-64-7
87-86-5
85-01-8
108-95-2
Letter S (cont)
Pyrene
Pyridine
2,4,6-Tribromophenol
2-Fluorobiphenyl
2-Fluorophenol
Nitrobenzene-d5
Phenol-d6
Terphenyl-d14
HMX
sym-Trinitrobenzene
RDX
1,3-Dinitrobenzene
Nitrobenzene
Tetryl
2,4-Dinitrotoluene
2,6-Dinitrotoluene
2-Am-DNT
4-Am-DNT
2-Nitrotoluene
3-Nitrotoluene
4-Nitrotoluene
Nitroglycerin
1,4-Dinitrobenzene
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Molybdenum
Nickel
Potassium
Selenium
Silver
Sodium
Strontium
129-00-0
110-86-1
120-82-1
95-95-4
88-06-2
118-79-6
321-60-8
367-12-4
20810-28-0
4165-62-2
98904-43-9
2691-41-0
99-35-4
121-82-4
99-65-0
98-95-3
118-96-7
479-45-8
121-14-2
606-20-2
35572-78-2
1946-51-0
88-72-2
99-08-1
99-99-0
55-63-0
100-25-4
7429-90-5
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-70-2
7440-47-3
7440-48-4
7440-50-8
7439-89-6
7439-92-1
7439-95-4
7439-96-5
7439-98-7
7440-02-0
7440-09-7
7782-49-2
7440-22-4
7440-23-5
7440-24-6
Letter S (cont)
Thallium
Titanium
Vanadium
Zinc
Mercury
Perchlorate
1314-32-5
7440-32-6
7440-62-2
7440-66-6
7439-97-6
14797-73-0
Letter S (cont)
Table 3. Munitions Chemical Compositions
Explosives, Propellants, Pyrotechnics

Military Explosives (Chemistry) 30 September 1984
Letter S (cont)
Explosives
Chapters 7 & 8
Lead Azide: Pb(N3)2, is a salt of hydrazoic acid, HN3. The compound is white,
has a nitrogen content of 28.86 percent and a molecular weight of 291.26. At the
melting point, 245C to 250C, decomposition into lead and nitrogen gas occurs.
The pure compound has two crystal modifications: an orthorhombic form and a
monoclinic form. The orthorhombic form, which is also called the alpha form, has
a density of 4.68 grams per cubic centimeter and unit cell dimensions of a = 11.31
Angstroms, b = 16.25 Angstroms, and c = 6.63 Angstroms. The monoclinic form,
which is also called the beta form, has a density of 4.87 grams per cubic
centimeter and unit cell dimensions of a = 18.49 Angstroms, b = 8.84 Angstroms,
and c =5.12 Angstroms. The compound is usually prepared as colorless,
needlelike crystals.
Other Lead Azide Types:
Dextrinated Lead Azide (DLA)
Service Lead Azide (SLA)
Colloidal Lead Azide (CLA)
Polyvinylalcohol Lead Azide (PVA-LA)
RD-1333 lead azide
Dextrinated Colloidal Lead Azide (DCLA)
Mercury Fulminate Hg(ONC)2, is a salt of fulminic or paracyanic acid. The acid
undergoes polymerization very rapidly in both aqueous and ethereal solutions,
and so cannot be isolated. The structure of fulminic acid, and thus the salts of this
acid, is undetermined. Mercury fulminate has an oxygen balance to CO2 of-17
percent, an oxygen balance to CO of -5.5 percent, a nitrogen content of 9.85
percent, and a molecular weight of 284.65. When mercury fulminate is crystallized
from water, a hydrate, Hg(ON: C).1/2 H20, is formed that has a nitrogen content of
9.55 percent and a molecular weight of 293.64. The anhydrous form, which is
crystallized from alcohol, is white when pure but normal manufacturing yields a
gray product of only 98 to 99 percent purity. The crystals formed are octahedral
but are usually truncated. Only the smaller crystals are fully developed. The
crystal density is 4.43 grams per cubic centimeter.
Diazodinitrophenol (DDNP) This explosive is also known as 4,5-dinitrobenzene2-diazo-1-oxide, dinol, diazol and may be referred to as DADNP. The compound
is a greenish yellow to brown solid with tabular crystals. DDNP has a crystal
density of 1.63 to 1.65 grams per cubic centimeter at 25C and a molecular weight
of 210.108. DDNP is not dead pressed even at a pressure of 896,350 kilopascals
(130,000 pounds per square inch).
Lead Styphnate Two forms of lead styphnate are used as primary explosives:
basic and normal. Basic lead styphnate has a nitrogen content of six percent and
a molecular weight of 705.53.
1
Letter S (cont)
The compound has two crystal forms: yellow needles with a density of 3.878
grams per cubic centimeter and red prisms with a density of 4.059 grams per
cubic centimeter. The apparent density is 1.4 to 1.6 grams per cubic centimeter.
Normal lead styphnate has a nitrogen content of nine percent and the
monohydrate has a molecular weight of 468.38.
Tetracene is also known as guanyldiazoguanyl tetrazene and 4-guanyl-1 (nitrosoaminoguanyl)-1tetrazene. The compound is a colorless to pale yellow,
fluffy material with needle crystals, an oxygen balance to CO2 of-57.6 percent, an
oxygen balance to CO of-43 percent, a nitrogen content of 74.4 percent, and a
molecular weight of 188.15. Tetracene forms a hydrate with three molecules of
water. The melting point of the pure compound is between 140C and 160C
accompanied by decomposition and explosion. The apparent density is only 0.45
grams per cubic centimeter. When compressed at 20,685 kilopascals (3,000
pounds per square inch), the density is 1.05 grams per cubic centimeter. The
crystal density is 1.7 grams per cubic centimeter. The compound can be easily
dead pressed. Tetracene is practically insoluble in water and ethanol and so can
be stored wet with water or a mixture of water and ethanol. The compound is also
insoluble in ether, benzene, acetone, carbon tetrachloride, and ethylene
dichloride. Tetracene is soluble in dilute nitric acid or strong hydrochloric acid. In a
solution with hydrochloric acid, the hydrochloride is precipitated by the addition of
ether. Tetracene may then be recovered by treatment with sodium acetate or
ammonium hydroxide. The heat of formation is 270 calories per gram and the heat
of detonation is 658
Potassium Dinitrobenzofuroxane (KDNBF) is a red crystalline solid with a
nitrogen content of 21.21 percent and molecular weight of 264.20. The oxygen
balance of the compound to CO2, H2O, and K2O is -42.4 percent. The anhydrous
salt has a density of 2.21 grams per cubic centimeter and a melting point, with
explosive decomposition, of 210C. KDNBF is soluble to the extent of 0.245
grams per 100 grams of water at 30C. Between the temperatures of 50C to 50C
the specific heat is 0.217 calories per gram per degree centigrade. KDNBF is used
in primary compositions.
Lead Mononitroresorcinate (LMNR) has a nitrogen content of 3.89 percent, an
NO2 content of 12.77 percent, a lead content of 57.51 percent, and a molecular
weight of 360.30. The compound forms microscopic reddish brown crystals.
LMNR has slow burning properties and a low combustion temperature. The
compound is used in electric detonators with DLA as the spot charge to initiate a
PETN base charge, as an upper charge, and as an ingredient in primary
compositions.
Primary Compositions are mixtures of primary explosives, fuels, oxidizers, and
other ingredients used to initiate detonation in high explosive charges or ignite
propellants and pyrotechnics. The ingredients and the portions of the ingredients
for individual priming compositions are determined empirically from the use the
composition is intended for. Fuels commonly used in priming compositions are
lead thiocynate, antimony sulfide, and calcium silicide. The last two also serve to
Letter S (cont)
sensitize the composition to friction or percussion. Oxidizing agents include

potassium chlorate and barium nitrate. Other ingredients include primary
explosives and binders. The major determining factor in ingredient selection is the
impetus which is to detonate the priming composition. The types of impetus
commonly used are percussion and electrical.
Percussion Priming Compositions FA959, FA982, FA956, Compounds:
Normal lead styphnate
Tetracene
Barium nitrate
Antimony sulfide
Powdered zirconium
Lead dioxide
PETN
Aluminum
Gum Arabic
Stab Detonator Priming Compositions NOL130, PA101, NOL 60,
Compounds:
Lead azide
Basic lead styphnate
Tetracene
Barium nitrate
Antimony sulfide
Powdered aluminum
Electric Priming Compositions I, II, III, IV, V, VI,
Compounds:
Potassium chlorate
Lead mononitroresorcinate
Nitrocellulose
Lead thiocynate
DDNP
Charcoal
Nitrostarch
Titanium
Aluminum
Aliphatic Nitrate Esters compounds in this class are prepared by O-type nitration
in which a nitro group is attached to an oxygen atom of the compound being
nitrated.
1,2,4-Butanetriol Trinitrate (BTN) This explosive is also known as a, b, gtrihydroxybutane trinitrate and is sometimes referred to as BTTN. The compound
is a light yellow liquid with a density of 1.520 at 20C, a molecular weight of 241, a
melting point of -27C, an oxygen balance to CO2 of 17 percent, and a refractive
index of 1.4738 at 20C. The liquid has a viscosity of 62 centipoises at 20C.
1,2,4- Butanetriol trinitrate is slightly soluble in water, miscible with alcohol, ether,
acetone, and a solution of 2 parts ether and 1 part alcohol. BTN has a heat of
3
Letter S (cont)
formation of 368 calories per gram, a heat of combustion of 2,167 calories per
gram, and a heat of detonation of 1,458 calories per gram. This compound is a
good gelatinizer for nitrocellulose and can be used as a substitute for nitroglycerin
in double-base propellants. Heat, vacuum stability, and volatility tests indicate
more stability than nitroglycerin. Impact sensitivity is about the same as for
nitroglycerin. Brisance, as measured by the sand test, is about the same: 49
grams crushed versus 51.5 grams for nitroglycerin or 47 grams for TNT. The five
second explosion temperature is 230C versus 220C for nitroglycerin. BTN can
be manufactured by the nitration of 1,2,4-butanetriol with a mixture of nitric and
sulfuric acids.
Diethyleneglycol Dinitrate (DEGN) This explosive is also known as
dinitrodiglycol or 2,2'-oxybisethanol dinitrate and is sometimes referred to as
DEGDN. The compound is a clear, colorless, odorless liquid with a nitrogen
content of 14.29 percent, a theoretical maximum density of 1.39 grams per cubic
centimeter, an oxygen balance to C02 of-41 percent, and a molecular weight of
196. DEGN boils between 160 and 161C and can, upon cooling, form a stable
solid with a melting point of 2C or remain liquid to a freezing point of -11.2 to
11.40C. Other characteristics of the liquid are: refractive index at 20C with
sodium light, 1.450; viscosity at 20C, 8.1 centipoises; vapor pressure at 20C,
0.0036 torr; vapor pressure at 25C, 0.00593 torr; vapor pressure at 600C, 0.130
torr; specific gravity, 1.385. At 60C DEGN has a volatility of 0.19 milligrams per
square centimeter per hour. At constant pressure, the heat of combustion is 2,792
calories per gram. The heat of formation is-99.4 kilogram calories per mole. The
heat of detonation is 1,161 calories per gram. DEGN is readily soluble in ether,
acetone, chloroform, benzene, nitrobenzene, toluene, nitroglycerin, and glacial
acetic acid but is insoluble in ethanol, carbon tetrachloride, and carbon disulfide.
Solubility in water at 25C and 60C is 0.40 and 0.46 gram per 100 grams,
respectively. DEGN's chemical reactivity is similar to nitroglycerin's, but is less
subject to hydrolysis and is not readily saponified by alcoholic sodium hydroxide.
DEGN can be used as an explosive and can be used in propellants as a colloiding
agent for nitrocellulose. Propellants based on DEGN and nitrocellulose develop
relatively low temperatures and cause relatively little erosion of guns, but are
unduly volatile.
Nitrocellulose (NC) or cellulose nitrate is a mixture of nitrates obtained by
nitrating cellulose. Cellulose is a long chain polymer of anhydroglucose units
(C5H10O5). The number of anhydroglucose units or degree of polymerization
(DP) is variable. Cellulose used for preparation of military grades of nitrocellulose
have a DP of approximately 1,000 to 1,500. Cellulose threads possess micellar
structure and consist of numerous rod-like crystallites oriented with their long axis
parallel to the thread axis, thus forming a fiber. Almost pure cellulose is found in
the pith of certain plants, in absorbent cotton, and in some filter papers. Pure
cellulose is most readily obtained from cotton by treating with a dilute acid or base
solution then thoroughly washing with water. At the present time most of the
cellulose for nitrocellulose preparation is obtained from coniferous wood, which is
50 to 60 percent cellulose. Another source is straw, which is 30 to 40 percent
cellulose. The nitration of cellulose involves replacement of the hydrogen in the
Letter S (cont)
three hydroxyl (OH) groups in the anhydroglucose units with NO2 groups. A
representative formula for the nitrated cellulose may be written as C6H7(OH)x
(ONO2) y where x+ y=3. The mononitrate, x =2 and y =1, has a nitrogen content
of 6.76 percent; the dinitrate, x=1 and y =2, has a nitrogen content of 11.11
percent; the trinitrate, x =0 and y =3, has a nitrogen content of 14.14 percent. As a
practical matter, however, any desired degree of nitration up to 14.14 percent may
be obtained by adjusting the composition of the mixed acid used for nitration, the
acid to cellulose ratio, the time of nitration, or the temperature of nitration. In
nitrocellulose with less than 14.14 percent nitrogen, the NO2 groups are
distributed randomly along the entire length of the cellulose polymer, so x and y
should be regarded as average values over the entire length of the chain. The
nitrogen content determines the chemical and physical properties of any particular
nitrocellulose. The five grades of nitrocellulose listed below are recognized and
used.
Other Nitrocellulose Types:
Pyroxylin or collodion,
Pyrocellulose
Guncotton
High nitrogen nitrocellulose
Blended nitrocellulose
Nitroglycerin (NG), glycerol trinitrate, or 1,2,3-propanetriol trinitrate, is a clear,
colorless, odorless, oily liquid with a theoretical maximum density of 1.596 grams
per cubic centimeter. Nitroglycerin has a sweet, burning taste and a molecular
weight of 227.1. Nitroglycerin is soluble in one liter of water to the extent of only
0.173, 0.191, 0.228, and 0.246 gram at 20, 30, 50 and 60C, respectively and
is essentially nonhygroscopic when exposed to atmospheric humidity.
Nitrostarch (NS) is a mixture of nitrates obtained by nitrating starch. The general
formula for starch is C6H10O5. The structure of starch is the same as for
nitrocellulose, with the exception that the polymer chains are spiral rather than
straight. The starch molecule consists of approximately 1,000 anhydroglucose
units. The nitration of starch involves replacement of the hydrogen in the three
hydroxyl (OH) groups in the anhydroglucose units with NO2 groups. A
representative formula for the nitrated starch may be written as
C6H7(OH) x (ONO2)y where x +y =3. The NO2 groups are distributed randomly
along the entire length of the starch molecule, so x and y should be regarded as
averages over the entire length of the chain. The following empirical formula can
be employed to obtain y as a function of the nitrogen content N: y=162N/(140045N)
Pentaerythritol Tetranitrate (PETN) is also known as 2,2-bis [(nitrooxy) methyl]1,3-propanediol dinitrate; penthrite; or nitropenta and may be referred to as TEN.
The compound is a white solid with a molecular weight of 316.2. PETN has two
polymorphs: one with a tetragonal crystalline structure and the other with an
orthorhombic crystalline structure. The phase change between the two
Letter S (cont)
polymorphs occurs at 130C. The tetragonal crystals have a density of 1.778
grams per cubic centimeter and the orthorhombic crystals have a density of 1.716
grams per cubic centimeter. Normal manufacturing yields tetragonal crystals. The
unit cell dimensions of the tetragonal crystals are a=9.38 Angstroms, b=9.38
Angstroms, and c =6.71 Angstroms. The dimensions for the orthorhombic crystals
are a=13.29 Angstroms, b = 13.49 Angstroms, c = 6.83 Angstroms. There are two
molecules per cell in the tetragonal form and four molecules per cell in the
orthorhombic form. The interatomic distances have been determined as 1.50
Angstroms for the C-C bonds, 1.37 Angstroms for the C-O bonds, 1.36 Angstroms
for O-N bonds, and 1.27 Angstroms for N-O bonds. PETN melts at 141.3C. The
boiling point is 160C under a pressure of 2 torr; 180C under a pressure of 50
torr. Under atmospheric pressure at temperatures above 21 0C, PETN
decomposes rapidly and in some cases detonates. The vapor pressure of solid
PETN can be found by the empirical equation: log p = 16.73 -7750/T. PETN is
more sensitive to initiation than nitrocellulose, RDX, or tetryl, as judged by the
sand test. This is shown, also, by the fact that PETN with 35 percent of water
present can be detonated by a No. 6 electric blasting cap, whereas RDX fails to
explode if more than 14 percent of water is present. PETN is one of the most
sensitive of the standardized military explosives.
Triethylene Glycoldinitrate (TEGN) This explosive is also referred to as TEGDN.
The compound is a light yellow, oily liquid with a nitrogen content of 11.67 percent,
a molecular weight of 240.20, and an oxygen balance to CO2 of -66.6 percent.
The melting point of the solid is - 19C. Other characteristics of the liquid are:
refractive index, 1.4540; viscosity at 20C, 13.2 centipoises; vapor pressure at
25C, less than 0.001 torr; volatility at 60C, 40 milligrams per square centimeter
per hour; and density, 1.335 grams per cubic centimeter. At constant pressure,
TEGN's heat of combustion is 3428 calories per gram, heat of explosion is 725
kilocalories per kilogram, and heat of formation is -603.7 kilocalories per kilogram.
TEGN is very soluble in acetone, ether, and a solution of 2 parts ether and 1 part
ethanol. TEGN is soluble in carbon disulfide and slowly soluble in water. The
primary use of TEGN is as a gelatinizing agent for nitrocellulose in propellants, but
TEGN can also be used as a component in a liquid explosive, a plasticizer in the
fabrication of flexible explosive sheets, and as a plasticizer in pytrotechnic flares.
1,1,1 Trimethylolethane Trinitrate (TMETN) This explosive is also known as
metriol trinitrate and is sometimes referred to as MTN. The compound is a slightly
turbid, viscous oil with a nitrogen content of 16.41 percent and a molecular weight
of 255.15. TMETN has a melting point of -3C and an apparent boiling point of
182C, but this is merely the temperature at which decomposition becomes
vigorous enough to resemble boiling. Other properties of the liquid are a density of
1.47 grams per cubic centimeter at 22C and a refractive index of 1.4752 at 25C.
TMETN is practically insoluble in water. Less than 0.015 grams dissolved per 100
grams of water at up to 60C. TMETN is soluble in alcohol and many other
organic solvents. At 60C TMETN's volatility is 24 milligrams per square
centimeter. The heat of formation is 422 calories per gram at constant volume and
446 calories per gram at constant pressure. The heat of combustion is 2,642
calories per gram at constant volume with the water being liquid. In an acid bath,
Letter S (cont)
TMETN is hydrolyzed to the extent of 0.018 percent in 10 days at 220C and
0.115 percent in 5 days at 60C. TMETN can be used as a flash and erosion
reducing additive in propellants and an ingredient of commercial explosives.
TMETN alone does not gelatinize nitrocellulose unless the temperature is raised
to 100C, which would be dangerous. But if mixed with only 8 percent of metriol
triacetate, gelatinization takes place at 80C. When TMETN is mixed with
nitroglycerin, the mechanical properties of double-base cast propellants are
improved. Combinations with triethylene glycol dinitrate are used as plasticizers
for nitrocellulose.
Cyclotetramethylenetetranitramine (HMX) is also known as: octahydro-1,3,5,7tetranitro-1 ,3,5,7-tetrazocine; 1,3,5,7-tetranitro-1 ,3,5,7-tetrazacyclooctane;
cyclotetramethylene tetranitramine; or octogen. HMX is a white, crystalline solid
with a nitrogen content of 37.84 percent, a theoretical maximum density of 1.905
grams per cubic centimeter, a nominal density of 1.89 grams per cubic centimeter,
a melting point of 285C, and a molecular weight of 296.17. There are four
polymorphs of HMX: an alpha, beta, gamma, and delta form. Each polymorph has
a range of stability and there are differences among them in physical properties
such as density, solubility, and refractive index. The most common polymorph is
the beta form. The term HMX without an alpha, gamma or delta qualifier refers to
the beta form throughout the rest of this text. The crystalline structure of beta HMX
is monoclinic with a density of 1.903 grams per cubic centimeter. The unit cell
dimensions are a=6.54 Angstroms, b=11.05 Angstroms, and c=8.70 Angstroms.
Beta HMX is stable to about 102C to 104.5C, when the crystalline structure is
converted to the alpha form. The crystals of the alpha form are orthorhombic with
a density of 1.82 grams per cubic centimeter. The unit cell dimensions
are a=15.14 Angstroms, b =23.89 Angstroms, c = 5.91 Angstroms. At
approximately 160C to 164C the meta stable gamma form exists. The crystals of
the gamma form are monoclinic with a density of 1.76 grams per cubic centimeter.
The unit cell dimensions are a=10.95 Angstroms, b =7.93 Angstroms, and c =
14.61 Angstroms. Above the 160C to 164C range to the melting point, the delta
form exists. The crystals of the delta form are hexagonal with a density of 1.80
grams per cubic centimeter. The unit cell dimensions are a=7.71 Angstroms and
b=32.55 Angstroms. The polymorphs may also be prepared by precipitation from
solution under various conditions. The beta form is precipitated from a solution of
HMX in acetic acid, acetone, nitric acid, or nitrometrane with very slow cooling.
The alpha form is precipitated from the same solution with more rapid cooling and
the gamma form is precipitated with even more rapid cooling. The delta form is
crystallized from solution such as acetic acid orbetachloroethyl phosphate, in
which HMX is only slightly soluble. Very rapid chilling of the solution is required.
Cyclotrimethylenetrinitramine (RDX) This explosive is also known as:
hexahydro-1,3,5-trinitro-1,3,5-triazine; 1,3,5-trinitro1,3,5-triazacyclohexane;
cyclotrimethylene trinitramine; hexogen; cyclonite; or 1,3,5-trinitrotrimethylenetriamine.The compound is a white solid with a density of 1.806 grams per cubic
centimeter, a nitrogen content of 37.84 percent, and a molecular weight of 222.13.
RDX has orthorhombic crystals with a wide variety of habits; from needles when
precipitated from HNO3, to plates when precipitated from acetic acid, to a massive
Letter S (cont)
form when precipitated from nitroethane or acetone. The unit cell dimensions are
a=13.18 Angstroms, b = 1 1.57 Angstroms, and c = 10.71 Angstroms, and there
are eight molecules per cell unit. On the Moh's scale RDX has a scratch hardness
of 2.5. Other properties of pure RDX include a specific heat as shown in table 815 and a heat of combustion at constant pressure of 2,307.2 calories per
gram. The heat of formation value is + 14.71 kilocalories per mole. RDX has an
extremely low volatility. Pure RDX is used in press loaded projectiles but not in
cast loaded projectiles because of extensive decomposition at the melting point.
Cast loading is accomplished by blending RDX with a relatively low melting point
substance. Compositions in which the RDX particles are coated with wax are
called Composition A, in mixtures with TNT, Composition B, and blends with a
nonexplosive plasticizer, Composition C. Straight RDX is used as a base charge in
detonators and in some blasting caps, and as an oxidizer in specialized gun
propellant.
Ethylenediamine Dinitrate (EDDN) This explosive is also designated EDD or
EDAD. The compound is composed of white crystals with a specific gravity of
1.595 at 25/40, a nitrogen content of 30.10 percent, an oxygen balance to C02 of25.8 percent, a melting point of 185 to 187C, and a molecular weight of 186.13.
The compound is soluble in water, but insoluble in alcohol or ether. EDDN has a
heat of combustion of 374.7 kilocalories per mole at constant pressure, a heat of
formation of 156.1 kilocalories per mole, and a heat of explosion of 127.9 to 159.3
kilocalories per mole. Eutectics are formed with ammonium nitrate, but EDDN is
immiscible with molten TNT. An aqueous solution of EDDN is distinctly acidic.
EDDN has been used to a limited extent as a bursting charge pressed in shells
and as a cast charge in eutectic mixtures with ammonium nitrate. Mixtures
with wax were used in boosters during World War II by the Germans.
Ethylenedinitramine (Haleite) This compound is also known as N N'dinitroethylene diamine; ethylene dinitramine; or 1,2-dinitrodiaminoethane, and is
sometimes designated EDNA. The name Haleite is in recognition of the
development of this compound as a military explosive by the late Dr. G. C. Hale of
Picatinny Arsenal. The compound is white with an orthorhombic crystal structure,
a nitrogen content of 37.33 percent, anoxygen balance to CO2 of-32 percent, an
oxygen balance to CO of-10.5 percent, and a molecular weight of 150.10. The
density of the crystals vary from 1.66 to 1.77 depending on the solvent from which
the crystallization took place.
Nitroguanidine (NQ) This explosive is also known as picrite or guanylnitramine.
The compound has a nitrogen content of 53.84 percent, an oxygen balance to
CO2 of -30.8 percent, a theoretical maximum density of 1.81 grams per cubic
centimeter, a nominal density of 1.55 to 1.75 grams per cubic centimeter, and a
molecular weight of 104.1. The melting point of nitroguanidine varies somewhat
with the rate of heating. The pure material melts with decomposition at 232C, but
values from 220C to 250C are obtainable with various heating rates. At least two
crystalline forms exist for nitroguanidine; alpha and beta.
Letter S (cont)
2, 4,6Trinitrophenylmethylnitramine (Tetryl) This explosive is also known as:
2,4,6tetranitro-N-methyl aniline; N-methyl-N,2,4,6tetranitro-benzenamine; 2,4,6trinitrophenylmethylnitramine; tetranitromethylamulene; or picrylmethylnitramine
and is sometimes referred to as pyronite, tetrylit, tetralite, tetralita, or CE. The
compound is colorless when freshly prepared and highly purified, but rapidly
acquires a yellow color when exposed to light. Tetryl has a nitrogen content of
24.4 percent, an oxygen balance to CO2 of-47 percent, a nominal density of 1.71
grams per cubic centimeter with a theoretical maximum density of 1.73 grams per
cubic centimeter, and a molecular weight of 287.15. The melting point of the pure
substance is 129.45C and of the technical grade, 129C.
Nitroaromatics. Compounds in this class are prepared by C-type nitration in
which a nitrogroup is attached to a carbon atom of the compound being nitrated.
Ammonium Picrate This explosive is also known as ammonium 2,4,6trinitrophenolate, explosive D, and Dunnite. The compound has a nitrogen
content of 22.77 percent, an oxygen balance to C02 of- 52 percent, a maximum
crystal density of 1.717 grams per cubic centimeter, a nominal density of 1.63
grams per cubic centimeter, a melting point with decomposition
of about 280C and a molecular weight of 246. Ammonium picrate exists in a
stable form as yellow,
monoclinic crystals and a meta stable form as red, orthorhombic crystals. The unit
cell dimensions are a =13.45 Angstroms, b
1,3-Diamino-2,4,6-Trinitrobenzene (DA TB) This explosive is also known as
2,4,6trinitro-1,3-diaminobenzene; 2,4,6-trinitro-7,3benzenediamine trinitro-mphenylenediamine; or 2,4,6-trinitro-1 ,3-diaminobenzol and may be referred to as
DATNB. The compound is a yellow, crystalline solid with a nitrogen content of
28.81 percent, a melting point of 2860C to 301C with decomposition, and a
molecular weight of 243.14.
1,3,5Triamino-2, 4,6Trinitrobenzene (TA TB) This explosive is also known as
2,4,6trinitro-1,3,5-benzenetriamine and may be referred to as TATNB. TATB has a
nitrogen content of 32.56 percent, an oxygen balance to C02 of -55.78 percent,
and a molecular weight of 258.18. TATB is yellow but exposure to sunlight or
ultraviolet light causes a green coloration which, with prolonged exposure, turns
brown. The compound has a theoretical maximum density of 1.937 grams per
cubic centimeter and a nominal density of 1.88 grams per cubic centimeter. An
instantaneous hot bar decomposition temperature of 450C to 451 C was
reported with rapid thermal decomposition above 320C. The structure of the
crystalline lattice of TATB contains many unusual features. Some of these are the
extremely long C-C bonds in the benzene ring, the very short C-N bonds, amino
bonds, and the six furcated hydrogen bonds. Evidence of a strong intermolecular
interaction, hydrogen bonds, in TATB is indicated by the lack of an observable
melting point and very low solubility. The intermolecular network results in a
graphite-like lattice structure with the resulting properties of lubricity and
intercalaction.
Letter S (cont)
2,4,6-Trinitrotoluene (TNT) This explosive is also known as trotyl, tolit, triton,
tritol, trilite, and 1-methyl-2,4,6-trinitrobenzene. TNT has been the most widely
used military explosive from World War I to the present time. The advantages of
TNT include low cost, safety in handling, fairly high explosive power, good
chemical and thermal stability, favorable physical properties, compatibility with
other explosives, a low melting point favorable for melt casting operations, and
moderate toxicity. There are six possible ring nitrated TNT isomers. The alpha
isomer, which is the one of military interest is symmetrical and will be referred to
as TNT. The other five meta isomers will be identified by the Greek letters beta
through eta excluding zeta. TNT is a yellow, crystalline compound with a nitrogen
content of 18.5 percent, an oxygen balance to CO2 of-73.9 percent, a molecular
weight of 227.13, and a melting point of 80C to 81C. TNT shows no deterioration
after 20 years storage in a magazine.
Impurities Present in TNT
2,6-Dinitrotoluene
2,4-Dinitrotoluene
2,3-Dinitrotoluene
2,5-Dinitrotoluene
3,4-Dinitrotoluene
3,5-Dinitrotoluene
1,3-Dinitrobenzene
2,4,6-Trinitrobenzyl alcohol
2,4,6-Trinitrobenzaldehyde
2,4,6-Trinitrobenzoic acid
Alpha-nitrato-2,4,6-trinitrotoluene
Tetranitromethane
2,2'-Dicarboxy-3,3',5,5'-tetranitroazoxybenzene (white compound)
2,2',4,4',6,6'-Hexanitrobibenzyl (HNBB)
3-Methyl-2',4,4',6,6'-pentanitrodiphenylmethane(MPDM)
3,3',5,5'-Tetranitroazoxybenzene
Compositions are explosives in which two or more explosive compounds are
mixed to produce an explosive with more suitable characteristics for a particular
application. Generally, the characteristics of the composition are intermediate
between the characteristics of the individual explosive ingredients. For example,
the addition of TNT to RDX reduces brisance somewhat but considerably
improves sensitivity. The composition explosives are categorized by the number of
ingredients contained in the mixture.
Binary Mixtures
10
Letter S (cont)
Amatols are binary mixtures of ammonium nitrate and TNT. The percentages of
ammonium nitrate and TNT are reflected in the nomenclature for each mixture, for
example, 80/20 amatol consists of 80 percent ammonium nitrate and 20 percent
TNT. Ammonium nitrate is insoluble in TNT. The chemical and physical properties
of the constituents determine the properties of the amatol. The mixture begins to
melt at TNT's melting point but the ammonium nitrate, which has a higher melting
point, remains solid.
Composition A explosives consist of a series of formulations of RDX and a
desensitizer. Compositions A and A2 contain the same percentages of materials
as composition A3 but the type of wax used and the granulation requirements for
the RDX are different. Composition A contains beeswax, while composition A2
contains a synthetic wax. Compositions A and A2 are no longer used. All of the
composition A explosives are press loaded. The density of composition A3 is 1.47
and 1.65 grams per cubic centimeter when pressed to 20,685 kilopascals (3,000
pounds per square inch) and 82,740 kilopascals (12,000pounds per square inch),
respectively.
Composition B type explosives are mixtures of RDX and TNT. Composition B
refers to mixtures of approximately 60 percent RDX and 40 percent TNT. Other
portions of RDX and TNT are called cyclotols.
Composition C During World War II, the British used a plastic demolition
explosive that could be shaped by hand and had great shattering power. As
standardized by the United States, this explosive was designated as composition
C and contained 88.3 percent RDX and 11.7 percent of a nonexplosive oily
plasticizer. Included in the plasticizer was 0.6 percent lecithin, which helped to
prevent the formation of large crystals of RDX which would increase the sensitivity
of the composition.
Ednatols are mixtures of halite (ethylene dinitramine) and TNT. The most used
haleite/TNT portions are 60/40, 55/45, and 50/50. Ednatols are yellowish, uniform
blends with a melting point of 80C. The eutectic temperature is about 80C. In an
extrudation test at 65C there was no extrudate. Ednatols are considered
satisfactory for bursting charges in ammunition. All of the following data in the
discussion of the properties of ednatol refer to the 55/45 mixture. 55/45 Ednatol
has an oxygen balance to carbon dioxide of -51 percent and to carbon monoxide
of - 17 percent. The density of the cast explosive is 1.62 grams per cubic
centimeter, which is four percent greater than that of cast TNT or haleite pressed
under 206,850 kilopascals (30,000 pounds per square inch).
LX-14 is an explosive which consists of 95.5 percent HMX and 4.5 percent estane
5702-F1. The mixture is a white solid with violet spots. LX-14 has a theoretical
maximum density of 1.849 grams per cubic centimeter, a nominal density of 1.83
grams per cubic centimeter, and a melting point of greater than 270C, with
decomposition. The heat of formation is 1.50 kilocalories per mole. The calculated
heats of detonation are 1.58 kilocalories per gram with liquid water and 1.43
kilocalories per gram with gaseous water. At a density of 1.835 grams per cubic
centimeter the detonation velocity is 8,830 meters per second.
11
Letter S (cont)
Octols are mixtures of HMX and TNT. Octol is used as an oil well formation agent
and in fragmentation and shaped charges. In fragmentation tests using a 105
millimeter M1 shell, 15 percent more fragments are produced and the average
velocity of the fragments is 100 meters per second faster than with a similar shell
loaded with composition B. This improvement is attributed to both the higher rate
of detonation of octol and the greater density of octol which permits a greater
weight of explosive in the same volume.
Pentolite are castable explosive mixtures containing PETN and TNT. The most
commonly used blend consists of 50/50 PETN/TNT. Other blends such as 75/25,
40/60, 30/70, and 10/90 have been occasionally employed but the 50/50 blend is
superior in the characteristics of sensitivity to initiation, brisance, and suitability for
melt loading. 87 percent TNT and 13 percent PETN form a eutectic with a freezing
point of 76.7C. Cast 50/50 pentolite, therefore, consists of 42.2 percent PETN,
and 57.8 percent of the eutectic mixture.
Picratol is a mixture of 52 percent ammonium picrate and 48 percent TNT. Molten
TNT has little or no solvent action on ammonium picrate, and consequently, cast
picratol consists essentially of a physical mixture of crystals of the two explosives.
The density of cast picratol is 1.61 to 1.63. This permits a weight of charge almost
equal to that
Tetrytols are light yellow to buff mixtures of TNT and tetryl. As is the case for
tetryl, tetrytols are no longer used by the United States but are still being used by
other nations including various NATO allies. Tetrytols resemble tetryl more closely
than they resemble TNT. They are more powerful but less sensitive than TNT.
Tetrytols can be cast into munitions, which is an advantage over press loading.
Table 8-73 compares the physical characteristics of various detritus compositions.
Ternary Mixtures
Amatex 20 The mixture has a nominal density of 1.61 grams per cubic centimeter
and is used as a filler in ammunition items.
Amatex 20 consists of:
RDX
40 percent
TNT
40 percent
Ammonium nitrate 20 percent
Ammonal
Ammonals are mixtures containing, as principle ingredients, ammonium nitrate
and powdered aluminum incorporated with high explosives such as TNT, DNT,
and RDX. Powdered carbon was also used in earlier ammonals. In the ammonals
that do not contain carbon, the mixture of ammonium nitrate and high explosive
detonates developing a very high temperature which causes volatilization of the
aluminum powder. In general, ammonals are fairly insensitive and stable mixtures
but are hygroscopic due to the presence of ammonium nitrate. In the presence of
12
Letter S (cont)
moisture, ammonals react with the same metals as amatols: copper, bronze, lead,
and copper plated steel.
(HTA-3) are mixtures of HMX, TNT, and aluminum
Minol-2 are mixtures of TNT, ammonium nitrate, and aluminum.
Torpex is a silvery white solid when cast. The composition of torpex is 41.6
percent RDX, 39.7
percent TNT, 18.0 percent aluminum powder, and 0.7 percent wax.
Quanternary Mixtures
Depth bomb explosive (DBX) is the only explosive covered under quanternary
mixtures. DBX consists of:
TNT
40 percent
RDX
21 percent
Ammonium nitrate 21 percent
Aluminum
18 percent
Industrial Explosives
Dynamites Military operations frequently necessitate excavation, demolition, and
cratering
operations for which the standard high explosives are unsuited. Recourse is made
to commercial and special compositions. Commercial blasting explosives, with the
exception of black powder, are referred to as dynamites although in some cases
they contain no nitroglycerin.
Ammonium nitrate fuel oil explosives (ANFO) When ammonium nitrate is
mixed with
approximately 5.6 percent of a combustible material such as fuel oil, the heat
liberated on detonation is increased by almost three-fold.
13
Letter S (cont)
Propellants
CHAPTER 9
UNITED STATES PROPELLANTS
Introduction Selection of a propellant for an application is made on the basis of

the requirements of that specific application. In general, guns are designed to
meet specified performance standards and withstand a specific pressure in the
barrel. With a knowledge of the properties of the constituents normally used for
propellants, the propellant designer creates a formulation to satisfy the
performance standards and limitations of the gun. When ignited, the propellant
produces large quantities of hot, gaseous products. Complete combustion or
deflagration of the propellant occurs in milliseconds in guns and the pressure
produced accelerates the projectile down the barrel.
Single-base propellants M1, M6, M10, and IMR.
Double-base gun propellants M2, M5, M8 and M18.
Triple-base gun propellants contain nitroguanidine as additional energizer which
increases the energy content of the formulation without raising the flame
temperature.
Composite propellants, used in solid fuel rockets, contain a polymer binder, a
fuel, and an oxidizer.
Ball Propellants
Propellants Compounds: M1, M2, M5, M6, M8, M10, M31, M30, IMR, M18
Nitrocellulose (NC)
Nitrogen
Nitroglycerin
Barium nitrate
Potassium nitrate
Potassium sulfate
Lead carbonate
Nitroguanidine
Dinitrotoluene
Dibutylphthalate
Diethylphthalate
Diphenylamine
Ethyl centralite
Graphite
Cryolite
Ethyl alcohol (residual)
14
Letter S (cont)
Diphenylamine, (C6H5)2NH, is an ammonia derivative in which two of the
hydrogens have been replaced by phenyl groups. Each phenyl ring has three
hydrogens which can be replaced with nitro groups. Therefore, DPA can be
nitrated to the hexanitrate by absorbing the nitrogen oxides produced during the
decomposition of nitrocellulose. DPA is nitrated relatively easily and the reaction is
not exothermic. During the decomposition of nitrocellulose, DPA nitrates to the
following compounds in succession.
N-nitrosodiphenylamine
2-nitrodiphenylamine
4-nitrodiphenylamine
N-nitroso-2-nitrodiphenylamine
N-nitroso-4-nitrodiphenylamine
4,4', 2,4', 2,2', and 2,4-dinitrodiphenylamines
N-nitroso-4, 4'-dinitrodiphenylamine
N-nitroso-2, 4'-dinitrodiphenylamine
2, 4, 4' and 2, 2', 4-trinitrodiphenylamines
2,2', 4,4'-tetranitrodiphenylamine
2,2', 4,4', 6-pentanitrodiphenylamine
Hexanitrodiphenylamine
The propellant does not start to become unstable until most of the diphenylamine
has been converted to hexanitrodiphenylamines. A very accurate test to measure
the remaining safe storage life in a propellant lot is to analyze the distribution
profile of the nitro DPAs. Only about one percent DPA can be added to a
propellant because its nitrated products change the ballistic properties.
Centralite I (which is also called ethyl centralite or symmetrical
diethyldiphenylurea), OC [N-(C2H5) (C6H5)]2, was developed in Germany for use
in double base propellants. The compound acts as a stabilizer, gelatinizer, and
waterproofing agent. Unlike diphenylamine, centralite can be used in relatively
large proportions and some propellant compositions contain as much as eight
percent of this material. Like diphenylamine, centralite is nitrated by the products
of nitrocellulose decomposition. The following compounds are formed
successively, as many as four being present simultaneously, as deterioration of
the powder proceeds.
4-nitrocentralite
4,4' dinitrocentralite
N-nitroso-N-ethylaniline
N-nitroso-N-ethyl-4-nitraniline
2,4, dinitro-N-ethyl-aniline
Centralite II (which is also called methyl centralite or symmetrical dimethyl
diphenylurea), OC[N(CH3) (C6H5)]2, also has been used as a stabilizer but is not
considered to be as effective as the ethyl analogue
Three akardites, or acardites, are used to stabilize propellants. Akardite II is often
used in DEGN containing propellants.
15
Letter S (cont)
Pyrotechnic Devices
Military Explosives (Chemistry) 30 September 1984
CHAPTER 10
UNITED STATES PYROTECHNICS
Pyrotechnics are used to send signals, to illuminate areas of interest, to simulate

other weapons during training, and as ignition elements for certain weapons.(1)
All pyrotechnic compositions contain oxidizers and fuels. Additional ingredients
present in most compositions include binding agents, retardants, and
waterproofing agents. Ingredients such as smoke dyes and color intensifiers are
present in the appropriate types of compositions.
Oxidizers: are substances in which anoxidizing agent is liberated at the high
temperatures of the chemical reaction involved.
Fuels: include finely powdered aluminum, magnesium, metal hydrides, red
phosphorus, sulfur, charcoal, boron, silicon, and suicides. The most frequently
used are powdered aluminum and magnesium.
Binding agents: include resins, waxes, plastics, and oils. These materials make
the finely divided particles adhere to each other when compressed into
pyrotechnic items.
Retardants are materials that are used to reduce the burning rate of the fueloxidizing agent mixture, with a minimum effect on the color intensity of the
composition.
Waterproofing agents are necessary in many pyrotechnic compositions because
of the susceptibility of metallic magnesium to reaction with moisture, the reactivity
of metallic aluminum with certain compounds in the presence of moisture, and the
hygroscopicity of nitrates and peroxides.
Color intensifiers:
hexachloroethane (C2CI6)
hexachlorobenzene (C6CI6)
polyvinyl chloride
dechlorane (C1oCI12).
Smoke dyes are azo and anthraquinone dyes. These dyes provide the color in
smokes used for signaling, marking, and spotting.
Flares and Signals The illumination provided by a flare is produced by both the
thermal radiation from the product oxide particles and the spectral emission from
excited metals.
16
Letter S (cont)
Infrared Flare Formulas:

Silicon
KNO3
CsNO3
RbNO3
Hexamethylene
tetramine
Epoxy resin
Red-Green Flare System:
Barium nitrate
Strontium nitrate 13
Potassium perchlorate
Magnesium
Dechlorane
Polyvinyl acetate resin
Signal flares are smaller and faster burning than illuminating flares. Various
metals are added these compositions to control the color of the flame.
Colored and White Smoke The pyrotechnic generation of smoke is almost
exclusively a military device for screening and signaling. Screening smokes are
generally white because black smokes are rarely sufficiently dense. Signal
smokes, on the other hand, are colored so as to assure contrast and be distinct in
the presence of clouds and ordinary smoke.
Venturi thermal generator type. The smoke producing material and the
pyrotechnic fuel block required to volatilize the smoke material are in separate
compartments. The smoke producing material is atomized and vaporized in the
venturi nozzle by the hot gases formed by the burning of the fuel block.
Burning type. Burning type smoke compositions are intimate mixtures of
chemicals. Smoke is produced from these mixtures by either of two methods. In
the first method, a product of combustion forms the smoke or the product reacts
with constituents of the atmosphere to form a smoke. In the second method, the
heat of combustion of the pyrotechnic serves to volatilize a component of the
mixture which then condenses to form the smoke. White phosphorus, either in
bulk or in solution, is one example of the burning type of smoke generator.
Explosive dissemination type. The smoke producing material is pulverized or
atomized and then vaporized, or a preground solid is dispersed by the explosion
of a bursting charge. The explosive dissemination smoke generator may contain
metallic chlorides which upon dispersal, hydrolyze in air. Examples are titanium,
silicon, and stannic tetrachloride.
Smoke Agent Mixtures:
White phosphorus
Sulfur trioxide
17
Letter S (cont)
FS agent
HC mixture
FM agent
Crude oil
The preferred method of dispersing colored smokes involves the vaporization
and condensation of a colored organic volatile dye. These dyes are mixed to the
extent of about 50 percent with a fuel such as lactose (20 percent) and an oxidizer
(30 percent) for which potassium chlorate is preferred.
Tracers and Fumers The principal small arms application of military pyrotechnics
is in tracer munitions where they serve as incendiaries, spotters, and as fire
control. Two types of tracers are used. The difference between the two types is
the method of tracking. The more frequently used tracer uses the light produced
by the burning tracer composition for tracking. Smoke tracers leave a trail of
colored smoke for tracking. Red is the flame color most often employed in tracers.
Igniter and Tracer Compositions
Strontium peroxide
Magnesium
1-136 Igniter
Calcium resinate
Barium peroxide
Zinc stearate
Toluidine red (identifier)
Strontium nitrate
Strontium oxalate
Polyvinyl chloride
Incendiaries Two types of incendiaries are commonly used. The traditional type is
a bomb containing a flammable material. These materials include thermite
(a mixture of aluminum and rust), phosphorus, and napalm. In addition, the case
of the bomb may be constructed of a material such as magnesium that will burn at
a high temperature once ignited.Depleted uranium is used extensively in
pyrotechnics which have armor piercing capabilities.
Depleted uranium deficient in the more radioactive isotope U235, is the waste
product of the uranium enrichment process. The depleted uranium is formed into
projectiles that can penetrate armor because of their high density and mechanical
properties. The impact of the projectile causes the uranium to form many
pyrophoric fragments which can ignite fuel and munition items.
Pyrophoric Metals
U
Uranium
Th
Thorium
Zr
Zirconium
Hf
Hafnium
18
Letter S (cont)
Ce
La
Pr
Nd
Sm
Y
Ti
Cerium
Lanthanum
Praseodymium
Neodymium
Samarium
Yttrium
Titanium
Delays and Fuses Delay compositions are mixtures of oxidants and powdered
metals which produce very little gas during combustion.
Photoflash Compositions Photoflash compositions are the single most
hazardous class of pyrotechnic mixtures. The particle size of the ingredients is so
small that burning resembles an explosion. The various photoflash devices are
similar, differing principally in size and the amount of delay.
Colored smokes:
Yellow: Auramine hydrochloride
Green: 1,4-Di-p-toluidinoanthraquinone with auramine hydrochloride
Red:
1-Methylanthraquinone
Blue:
Not suitable for signaling because of excessive light scatter.
Currently used dyes:
Orange: 1-(4-Phenylazo)-2-naphthol
Yellow: N, N-Dimethyl-p-phenylazoaniline
Blue:
1,4-Diamylaminoanthraqdinone
Black Powders Used in Pyrotechnics
Potassium nitrate
Sodium nitrate
Charcoal
Coal (semibituminous)
Sulfur
Ignition Mixtures Components
Aluminum (powdered)
Ammonium dichromate
Asphaltum
Barium chromate
Barium peroxide
Boron (amorphous)
Calcium resinate
Charcoal
Diatomaceous earth (See also superfloss)
Fe203 (Red)
Fe304 (Black)
Potassium nitrate
19
Letter S (cont)
Laminac
Magnesium (powdered)
Sodium nitrate
Nitrocellulose
Parlon (chlorinated rubber)
Pb02 Pb304
Sr peroxide
Sugar
Superfloss
Titanium
Toluidine red toner
Vegetable oil
Vistanex (polyisobutylene)
Zinc Stearate
Zirconium
20
Letter S (cont)
Table 4.
Pyrotechnic Munitions Chemicals
Chemicals found in practice and pyrotechnic munitions 1 2

Aluminum
Ammonium chloride
Ammonium perchlorate
Amorphous boron
Antimony sulfide
Antimony metal powder
Anthracene
Asphaltum
Barium nitrate
Barium chromate
Barium chlorate
Barium peroxide
Barium sulfate
Bismuth tetroxide
Butyl rubber
Calcium resinate
Calcium fluoride
Calcium metal
Cobalt naphthenate
Copper carbonate
Zirconium hydride
Polychlorotrifluoroethylene
Lead monoxide
Saltpeter
Calcium Resinate
Red Gum
Dextrin
Auramine Hydrochloride
Copper powder
Chlorinated rubber (Parlon)
Cupric oxide
Cuprous chloride
Calcium silicide
Cellulose-nitrate-plastic
Dichloromethane
Gilsonite
Graphite
Hexachlorobenzene
Hexachloroethane (HC)
Iron oxide
Infusorial earth
Lead dioxide
Lithium peroxide
Lithium perchlorate
Magnesium
Magnese dioxide
Mercurous chloride
Polyisobutylene (vistanex)
Potassium iodate
Zinc stearate
Manganese
Lead chromate
Cupric Oxide
Sulphur
Barium Oxalate
Ammonium Nitrate
Stearin
Dyes
1-(2-Methoxyphenylazo)-2-Napthol Sudan Red G
1, 4 Dimethylamino Anthraquinone Fast Blue B
2-(4-Dimethylamino Phenylazo) Napthalene
Indanthrene Dye Golden Yellow GKAC
1
2
Potassium chromate
Potassium chlorate
Polyvinyl acetate
Polyvinylchloride (PVC)
Perchlorate
Potassium dichromate
Resin (laminac)
Red phosphorous
Selenium
Sodium oxalate
Sodium bicarbonate
Stearic acid
Strontium nitrate
Strontium carbonate
Strontium nitrate
Strontium peroxide
Shellac
Tellurium
Titanium
Tungsten
White phosphorous
Magnesium aluminum
Diatomaceous Earth
Charcoal
Calcium Phosphide
Adhesive, Dextrin
Orange Shellac
Arsenic Disulphide
4-Dimethylamino Azobenzene
1, 4 Diphenyl Toluidino Anthraquinone
1-Amino Anthraquinone Fast Red A1
4-Methylamino Anthraquinone
Book: Military Pyrotechnics, 1919; Henry B. Faber; Dean of Pyrotechnic Schools Ordnance Department U.S. Army
Book: Military and Civilian Pyrotechnics, 1968; Dr. Herbert Ellern
Fort Ord Community Advisory Group (FOCAG): www.fortordcag.org Training Area Munitions Chemicals
Letter S (cont)
Table 5.
23 Pyrotechnic munitions chemicals

also used as Pesticides
Chemical
CAS
Pesticide/Biocide/Repellant
12612-21-4
Herbicide, Insecticide, Rodenticide
Ammonium Nitrate
6484-52-2
Microbiocide, Rodenticide
Ammonium Chloride
12125-02-9
Algaecide, Microbiocide
Anthracene
120-12-7
Herbicide, Insecticide, Rodenticide
Barium nitrate
10022-31-8
Repellant
Calcium phosphide
1305-99-3
Rodenticide
56-23-5
Fumigant,
Cobalt naphthenate
61789-51-3
Fungicide, Insecticide
Copper powder
7440-50-8
Fungicide,
Copper carbonate
12069-69-1
Algaecide, Fungicide, Insecticide
Cupric oxide
1317-38-0
Cuprous chloride
7758-89-6
Fungicide
Dichloromethane
75-09-2
Dog and Cat Repellant
Diatomaceous Earth
61790-53-2
Insecticide, Molluscicide
Iron oxide
1309-37-1
Herbicide
Potassium chlorate
3811-04-9
Defoliant, Herbicide, Microbiocide
Saltpeter
7757-79-1
Microbiocide, Rodenticide
Sodium bicarbonate
144-55-8
Fungicide
Sodium oxalate
62-76-0
Microbiocide
Sulphur
7704-34-9
Stearic acid
57-11-4
Adjuvant
Naphthalene (smoke dye)
91-20-3
Insecticide, insect repellant
Anthraquinone (smoke dye)

(found in 4 smoke dye formulas)
84-65-1
Bird Repellant
Arsenic sulfide
12344-68-2
Note: May explain why training areas are devoid of a robust insect and bird population.
Pesticide Use Information Source:
Pesticide Action Network North America: www.pesticideinfo.org/Search_Chemicals.jsp
Fort Ord Community Advisory Group (FOCAG): www.fortordcag.org Training Area Munitions Chemicals
Letter S (cont)
Table 6
Pesticides used at Fort Ord
48 Pesticides known as used at Fort Ord

Calcium Cyanide Gas
DDD
Malathion
Warfarin
Altosid SR-10
Sevin (Carbyrl Dust)
Chlorophacinone
Heptachlor Epoxide
Derzvan
Pyrethrum
Gophercide
Monuron
Aertex
Trexsan
Diquat
Enide
Mercury
DDE
Chlordane
Diazinon
Tordon 101
1080
Zinc Phosphide
Gamma-BHC
Methyl Bromide
Permaguard
Diphacin
Ded-Weed Silvex LV
Paraquat CL, Banvel
Amino Triazole
Tok-E-25
Metalde HTDE
DDT
2,4-D
Dieldrin
Baygon
Hyvar X
Diphacinone
Endrin
Derzan-T
Cyntroid 3-EC
Ficam W
Weed-Rhap LY-4P
Simazine
Betasan
Amitrol-T
Surflan
Arochlor 1254
Note: Pesticides where applied to training areas for decades. Pesticides where applied by
air and ground to manage pests (rodents, insects, fungi, and vegetation) the extent of which
is not known.
Former Fort Ord Pesticide Use; Research Documents:

Available at Fort Ord Administrative Record ; http://fortordcleanup.com/adminrec/arsearch.asp
enter record number, example: BW-0013
1) Fort Ord Installation Assessment 1983; BW-0013, pesticide types and uses
2) Fort Ord Base Closure Preliminary Assessment1990; BW-2427, pesticide types and uses
3) Fort Ord Literature review and Base Inventory Report Vol I, 1991; RI/FS BW-0136
4) Fort Ord Basewide Background Soil Investigation draft 1992; BW-0289
5) Fort Ord Basewide Background Soil Investigation draft final 1993; BW-0352
6) Fort Ord Basewide Background Soil Investigation final 1995; BW-1283E Basewide RI/FS
7) Fort Ord 2003 Burn ATSDR Health Consultation; OE-0522
Fort Ord Community Advisory Group (FOCAG): www.fortordcag.org Training Area Pesticides
Letter S (cont)
Table 7. Munitions Chemicals looked for in training areas transferred

to the Fort Ord Reuse Authority (FORA) for development
All these development parcels are known training areas
Historical Area (HA) Training Areas and total chemicals looked for:
HA-161,CSUMB
TPH-Diesel
TPH-Gasoline
Antimony
Cadmium
HA-175, OE-45
Booby Traps, Mines, Projectiles, Pyrotechnics - Development

TPH-Motor Oil
Di-n-butyl phthalate
Copper
Bis(2-ethylhexyl)phthalate
Di-n-octylphthalate
Lead
Tactical Training Area - Development
No Sampling Required
HA-103, OE-13B
Mortar Range / Parker Flats portion - MST/Horse Park Development
No Sampling Required: based on off-site sampling results

HA-110, DRO.1
Site 39 Multi-use Training/Impact Area - Del Rey Oaks Development

HA-111, DRO.2
Site 39 Multi-use Training/Impact Area - Del Rey Oaks Development

HA-112, SEA.1
Site 39 Multi-use Training/Impact Area - Seaside Development
No Sampling Required: based on no stressed vegetation or impacts to soil

HA-112, SEA.2

HA-112, SEA.3
Letter S (cont)
HA-112, SEA.4

HA-116, MOCO1 Site 39 Multi-use Training/Impact Area - Monterey Co Development
No Sampling Required: based on no MEC was identified during sampling
HA-117, MOCO2 Site 39 Multi-use Training/Impact Area - Monterey Co Development
Antimony
HA-118, Site 39
Copper
Site 39 Impact Area - Habitat Management Area
HMX
Tetryl
Note:
Lead
2-Amino-trinitrotoluene
RDX
Pyrotechnics were used day and night, over a 77 year period. Pyrotechnics were
used for all types of troops training including non-live fire, live-fire, bivouac,
and maneuvers activities.
Compiled from Fort Ord documents AR BW-2300J, Basewide Range Assessment Reports
Final 2009
Letter T
T-1
T-2
T-3
Letter T (cont)
T-3
cont
T-4
T-5
T-6
T-7
Letter T (cont)
T-8
T-9
Page 1 of 1
Letter U
Bill Carrothers Comment - my only comment on the GWR Project is the same as George Riley's. He
and I are both interested in the costs associated with scaling up the proposal, and what it would cost
to design the project to have the potential for future capacity increases.
7/2/2013
U-1
APPENDIXE
SUPPLEMENTTOMAY2013NOP
SUPPLEMENT TO THE MAY 2013 NOTICE OF PREPARATION FOR THE

MONTEREY PENINSULA GROUNDWATER REPLENISHMENT (PURE WATER MONTEREY) PROJECT
ENVIRONMENTAL IMPACT REPORT
_________________________________________________________
TO:
Agencies, Interested Parties, and Members of the Public
DATE:
December 8, 2014
SUBJECT:
Supplement to May 2013 Notice of Preparation of an EIR
PROJECT TITLE: Pure Water Monterey Groundwater Replenishment Project
PROJECT LOCATION: Northern Monterey County, California
LEAD AGENCY: Monterey Regional Water Pollution Control Agency
5 Harris Court, Building D
Monterey, CA 93940
Staff contact: Mr. Bob Holden, Principal Engineer
Phone: (831) 372-3367 Fax: (831) 372-6178
Email: gwr@mrwpca.com
The Monterey Regional Water Pollution Control Agency (MRWPCA) is the Lead Agency for preparation
of an Environmental Impact Report (EIR) under the California Environmental Quality Act (CEQA) for the
Monterey Peninsula Groundwater Replenishment Project (now called the Pure Water Monterey GWR
Project). MRWPCA commenced the CEQA process for the proposed project on May 31, 2013 when a
Notice of Preparation (NOP) of an EIR was circulated for a 30-day public review period (SCH#
2013051094). MRWPCA considered and incorporated comments on the May 2013 NOP, and the Draft
EIR for the project is well underway. On a parallel track, as a result of ongoing engineering and technical
evaluations and regional coordination efforts, MRWPCA has updated the project description.
To provide public agencies, interested parties and members of the public with an opportunity to
comment on the scope of the EIR related to updates to the project description, MRWPCA has decided to
supplement the May 2013 NOP.
Comment Period for Supplement to NOP
MRWPCA invites public agencies, organizations and members of the public to submit written comments
providing specific details about the scope and content of the environmental information in the EIR
related to the updates to the project description. If commenting on behalf of a responsible or trustee
agency, please also identify your specific areas of statutory responsibility. The public comment period
on the Supplement to the NOP begins on December 10, 2014 and ends on January 8, 2014. Please send
your written comments to Mr. Bob Holden at the address identified above, including your name,
address, and contact information. If a response is not received from you within 30 days, the Lead
Pure Water Monterey GWR Project Supplement to NOP
December 2014 page 1
Agency will assume, in accordance with CEQA Guidelines section 15082(b)(2) that you have no
comments on the Supplement to the NOP.
Project Location and Background
The Pure Water Monterey GWR Project would be located within northern Monterey County, and would
include new facilities located within the unincorporated areas of the Salinas Valley and the cities of
Salinas, Marina, Seaside, Monterey, and Pacific Grove. Figure 1 shows the proposed location of project
facilities; locations that have been updated since publication of the May 2013 NOP are indicated by red
dashed-line circles.
The Pure Water Monterey Groundwater Replenishment Project would create a reliable source of water
supply for northern Monterey County. The project would provide purified water for recharge of the
Seaside Groundwater Basin, and recycled water to augment the existing Castroville Seawater Intrusion
Projects (CSIP) agricultural irrigation supply. The project is jointly sponsored by the MRWPCA and the
Monterey Peninsula Water Management District (Water Management District).
The sources of water proposed to be recycled, treated and reused by the project are the same as those
presented in the May 2013 NOP: municipal wastewater, industrial wastewater, urban stormwater
runoff, and surface water diversions from the Blanco Drain and Reclamation Ditch. The source waters
would be conveyed to the Regional Treatment Plant, which is located two miles north of the City of
Marina and operated by MRWPCA.
The project objectives also have not changed. The primary objective of the project is to produce 3,500
acre-feet per year (AFY) of high quality replacement water to California American Water Company
(CalAm) for delivery to its customers in the Monterey District Service area; thereby enabling CalAm to
reduce its diversions from the Carmel River system by this same amount. CalAm is under a state order
to secure replacement water supplies to reduce its Carmel River diversions by December 2016. CalAm
also is required to reduce its pumping in the Seaside Groundwater Basin in accordance with the
Watermasters pumping mandates. Under the proposed project, highly treated water would be injected
into the Seaside Basin. This highly-treated water would be produced from a new advanced water
treatment facility that would be constructed at the Regional Treatment Plant and would treat the source
waters identified above. The product water from the advanced treatment plant would be conveyed to
and injected into the Seaside Basin via a new pipeline and new well facilities. The highly-treated water
would then mix with the existing groundwater and be stored for future urban use by CalAm.
Another purpose of the project is to provide additional recycled water for crop irrigation in the CSIP
area. Currently, the only sources of supply for the existing water recycling facility at the Salinas Valley
Reclamation Plant (located at the Regional Treatment Plant site) are municipal wastewater and small
amounts of urban dry weather runoff. Municipal wastewater flows have declined in recent years due to
aggressive water conservation efforts by the MRWPCA member entities. By increasing the amount and
type of source waters entering the wastewater collection system, additional recycled water can be
provided for use in the CSIP area.
Updates to the Pure Water Monterey GWR Project Description
As noted above, ongoing engineering and technical evaluations and regional coordination efforts have
resulted in some updates to the project description since the May 2013 NOP was issued. The full
original project description is included in the Monterey Peninsula Groundwater Replenishment Project
Environmental Impact Report Notice of Preparation (May 2013), and is available for review at the
MRWPCA Administrative Offices (5 Harris Court, Building D, Monterey, CA 93940) and on the project
website: www. purewatermonterey.org. Following is a description of the project description updates.
Source waters: All of the source waters identified in the May 2013 NOP are still being evaluated
in the EIR as potential sources for the project. Ongoing engineering studies have now identified
the volume of additional recycled water that could be provided to the CSIP area from the
project. As source flows for the proposed project were studied and the seasonal variability of
each was understood, the stakeholder agencies entered into a Memorandum of Understanding
Regarding Source Waters and Water Recycling (MOU). The Parties to the MOU are the
MRWPCA, the Monterey County Water Resources Agency, the City of Salinas, the Marina Coast
Water District (MCWD), and the Monterey Peninsula Water Management District. The MOU is
an agreement to negotiate a Definitive Agreement to establish contractual rights and
obligations of all Parties, that would include (1) protection of MCWDs recycled water right
entitlement, (2) provision of up to 5,292 AFY of recycled water to Monterey County Water
Resources Agency for the CSIP, and (3) provision of 3,500 AFY of highly treated water for
injection into the Seaside Groundwater Basin and extraction by CalAm. The MOU also includes
provisions for creation of a drought reserve, as discussed below. The MOU reflects the
stakeholder agencies positions regarding the combined benefits and conditions that would be
required to secure the necessary rights and agreements to use the source waters needed for the
proposed project.
Drought reserve storage and recovery: The proposed project now includes a drought reserve
component to support crop irrigation during dry years. Under this component, an extra 200 AFY
of advanced treated water would be injected in the Seaside Basin during normal and wet years,
up to a total of 1,000 AF, to create a banked reserve. During drought years, MRWPCA would
reduce the amount of water that it provides to the Seaside Groundwater Basin in order to
increase production of recycled water for crop irrigation. CalAm would be able to extract the
banked water in the Seaside Groundwater Basin to make up the difference to its supplies, such
that its extractions and deliveries would not fall below 3,500 acre-feet per year.
Project facilities: Ongoing technical and engineering evaluations have resulted in some new
proposed project facilities and updates to other proposed facilities, as noted below.
o Optimization of recycled water production at the Salinas Valley Reclamation Project: New
improvements at the existing reclamation plant would enable it to produce more
continuous flows in the winter and enhanced delivery to the CSIP area. Proposed
improvements would include new sluice gates, a new pipeline between the existing inlet
and outlet structures within the storage pond, chlorination basin upgrades, and a new
storage pond platform. All of the modifications would occur within the existing Salinas
Valley Reclamation Plant footprint. (Item #1 on Figure 1)
o Diversion location at Tembladero Slough. The proposed project now includes a proposed
diversion from Tembladero Slough, which is part of the Reclamation Ditch drainage system.
This diversion would consist of a new intake structure on the channel bottom, which would
connect to a new lift station on the channel bank via a new gravity pipeline. The new intake
would be screened to prevent fish and trash from entering the new pump station. The new
pump station would discharge through a new force main to the existing wet well at the
MRWPCA Castroville Pump Station. The channel banks and invert near the pump station
intake would be lined with concrete to prevent scouring. (Item #2 on Figure 1)

Removal of coastal recharge facilities as an injection location option in the Seaside Basin:
Groundwater modeling indicates that the coastal location is not feasible for injection. The
proposed project now includes only the inland location for the injection facilities. Product
water pipelines to that site have also been eliminated as a component of the proposed
project. (Item #3 on Figure 1)
Inclusion of CalAms proposed new distribution system pipelines as part of the GWR project:
Because the CalAm water supply system was initially built to deliver water from Carmel
Valley to Monterey Peninsula cities, a hydraulic trough currently exists in the peninsula
distribution system that prevents water delivery at adequate quantities from the Seaside
Groundwater Basin to most of Monterey, and all of Pacific Grove, Pebble Beach, Carmel
Valley, and City of Carmel areas. CalAm is proposing to construct two new pipelines, the
Transfer and Monterey pipelines (located in Monterey), to bridge this trough. These
pipelines are being studied in the EIR for the Monterey Peninsula Water Supply Project
proposed by CalAm. Because the pipelines are also needed to deliver the full amount of
GWR water injected into the Seaside Basin to CalAm customers, they are now also included
as part of the GWR project. (Item #4 on Figure 1)
Method of collecting and conveying agricultural wash water from the Salinas Treatment
Facility: The May 2013 NOP envisioned that agricultural washwater would be conveyed by a
new pump station and pipeline to a proposed new Blanco Drain pump station, and from
there to the Regional Treatment Plant. This water is now proposed to be diverted from the
existing Salinas collection and treatment facilities to the existing Salinas Pump Station. The
wash water would then mix with the municipal wastewater and be conveyed through the
existing 36-inch diameter Salinas interceptor to the Regional Treatment Plant. (Item #5 on
Figure 1)
Environmental Analysis
As described within the May 2013 NOP, the EIR will assess the following issues of potential
environmental effect: aesthetic resources, air quality and greenhouse gas emissions, biological
resources, cultural resources, geology and soils, hazards and hazardous materials, hydrogeology and
groundwater quality, hydrology and surface water quality, land use and planning, noise and vibration,
population and housing, transportation and traffic, other environmental issues (e.g., public services and
utilities; energy delivery systems; agricultural, mineral and forest resources). The EIR will also evaluate
growth-inducing effects that could result from implementation of the project, as well as cumulative
impacts and alternatives to the project.
Availability of Supplement to the NOP
The Supplement to the NOP is available for a 30-day public review period beginning December 10, 2014
and ending January 8, 2015. Copies of the document are available for review at MRWPCA, 5 Harris
Court, Building D, Monterey CA 93940 and on the MRWPCA website at: www.purewatermonterey.org.
Additionally, copies of this document are available for review at the following libraries:
Seaside Public Library
Marina Public Library
Monterey Public Library
Harrison Memorial Library (Carmel)
(
!
Tem
bl
ad
oS
er
New and Updated Project Facilities:
Tembladero Slough
Diversion
Castroville
gh
lou
1. Salinas Valley Reclamation Plant Modifications

2. New Reclamation Ditch Source Water Diversion
(Tembladero Slough at Castroville)
3. Elimination of Coastal Recharge Facilities and
Product Water Pipeline segments
4. Inclusion of CalAm Proposed Distribution System
Monterey
County
5. New Agricultural Washwater Diversion, including

Salinas Treatment Facility Storage and Recovery
Existing
Ocean Outfall
Treatment
Facilities at Regional
Treatment Plant
Blanco Drain
( Diversion
!
1
Monterey
Bay
Recl
am
at
Project ^
_
Location
n
io
Marina
Reclamation
Ditch Diversion
Salinas
(
!
(
!
(
!
D ra
in
io
pt
A
R UW P
Coastal
Booster Pump
Station Option
itc
h
lO
Co
ta
Bla n
as
pt
io n
(Salinas Pump
!
RUWAP
Booster Pump
Station Option
Salinas Industrial Wastewater

Treatment Facility
Storage and Recovery
5
Sa
Station Diversion
lina
1.5
iver
sR
Legend
New and Updated Project Facilities
Seaside
Pacific
Grove
Sand
City
Fort Ord
National Monument
City Limits
!
(
(
!
Proposed Booster Pump Station Options

Proposed Diversion Site
Existing Ocean Outfall
Injection
Well Facilities
Existing Wastewater Pipelines

Proposed Source Water Pipeline
Lake El Estero
Diversion
Monterey
(
!
Proposed Product Water Pipeline Options

Proposed CalAm Distribution System Pipelines
Proposed Injection Well Facilities
New and Updated Project Facilities

December 2014
Figure
Supplemental Notice of Preparation
APPENDIXF
SUPPLEMENTTONOPCOMMENTLETTERS
18 December 2014
Mr. Bob Holden, Principal Engineer
Email: gwr@mrwpca.com
Re: SUPPLEMENT TO THE MAY 2013 NOTICE OF PREPARATION FOR THE
MONTEREY PENINSULA GROUNDWATER REPLENISHMENT (PURE WATER
MONTEREY) PROJECT ENVIRONMENTAL IMPACT REPORT
Dear Mr. Holden:
Following are comments by WaterPlus on the 8 December 2014 supplement to
the NOP for the Pure Water Monterey Project.
Claimed project benefits. An overview of the project claimed the project
would meet these goals:
Create a reliable, publicly owned, safe water supply for Monterey Peninsula.
Allow other, more energy-intensive, options such as seawater desalination to
be smart-sized, thus enhancing the overall environmental benefits.
Diversify the community's water supply portfolio for a more secure water
supply.
Be online sooner and use far less energy than most other water supply
alternatives
To assure a safe water supply from advanced-level purification of municipal sewer

water, you would need, in addition to the processes described, either an amount of
fresh water equal to the amount of treated water for combined injection into the
Seaside Aquifer or the filtration of the treated water in settlement ponds prior to
aquifer injection, as in Santa Ana. The report makes no mention of these state
Health Department requirements or of how the project intends to meet them. Does
the project still intend to process municipal sewer water for injection into the
Seaside Aquifer? If not, the supplement should say as much.
What does the overview mean by smart-sized? Reduced energy use? That in
itself may be smart but still has to be demonstrated with comparable numbers
describing this and alternative projects. The cost of this alternative must also be
compared with the cost of others. The report claims $3,000 an acre-foot but needs
to break down that figure into components and update it if necessary (for example,
if it now includes the cost of DDT and other pesticide purification from
agricultural run-off sources). The cost of desal per unit decreases with increasing
plant size, and so down-sizing a desal plant only increases its cost. That is not
smart. The large desal plant at Carlsbad is about $1,000 less costly per acre-foot
than the proposed GWR project, and so the implication for smart-sizing would be
to increase rather than decrease the desal-plant size. This conflict requires
discussion and resolution.
Dependence on diversified water-supply sources can make a community
vulnerable to the failure of the least reliable of the sources, which in this case
would be GWR along with aquifer storage and recovery because both are
vulnerable to drought while the first is also vulnerable to conservation efforts for
whatever reason, as the supplement itself acknowledges. Diversification is not a
given as a good thing. It needs objective discussion and substantiation.
Every water-supply option requires an energy audit, and this one is no exception.
A desal plant at Moss Landing may be powered by solar and wind energy, for
example, and the cost effect of that may still keep desal more than competitive
with GWR. These comparisons need to be made objectively in an EIR if it is not
to be merely a Public Relations document in disguise.
The MOU underlying the NOP supplement. The supplement is at least partly
the product of an MOU described as an agreement to negotiate a Definitive
Agreement to establish contractual rights and obligations of all Parties, that
would include (1) protection of MCWDs recycled water right entitlement, (2)
provision of up to 5,292 AFY of recycled water to Monterey County Water
Resources Agency for the CSIP, and (3) provision of 3,500 AFY of highly treated
water for injection into the Seaside Groundwater Basin and extraction by Cal
Am.
This MOU does not indicate specifically how the parties to the agreement would
deal with the 19,500 acre-feet of treated sewer water that Salinas Valley growers
claim the right to use. Will the growers continue to have this right or will it be
reduced? If any reduced amount is to be treated for injection into the Seaside
Aquifer, as originally planned, has this option been presented to the public for
approval by Cal Am customers and, particularly, by authorized representatives of
the local hospitality industry? The NOP supplement must specify how much
untreated water is needed to meet the treated-water requirement and indicate
both (a) the sources of this water, together with the amount of water available
annually from each, and (b) where the treatment residuals will go--important
information for inclusion in an EIR .
In summary, the NOP document needs transformation from what in too many
portions appears to be a Public Relations endorsement of the project to an
objective and reliably documented project report.
Very respectfully,
Ron Weitzman
President, WaterPlus
From: PETER LE [mailto:peter381@sbcglobal.net]

Sent: Sunday, January 04, 2015 8:30 PM
To: GWR
Subject: Comments on the Supplement to May 2013 NOP dated December 8, 2014
January 4, 2015
Mr. Bob Holden
Principal Engineer, MRWPCA
Phone: 372-3367 Fax: 372-6178
gwr@mrwpca.com
I have the following comments on the scope and contents of the GWR (Pure Water Monterey) EIR
prepared by MRWPCA based on the Supplement to May 2013 NOP dated December 8, 2014:
1. The EIR needs to analyze thoroughly, calculate and show in table format how the proposed project
affects the agreed recycled water capacity and rights of the MCWD in the approximate amount of 1.1
MGD. If MCWD utilizes it 300 AF per month during summer months and the full 1.1 MGD recycled water
during remaining months (not including any unused recycled water), how much treated water the
proposed project can provide from different water sources? The EIR cannot assume that MCWD will not
utilize its senior water rights of the recycled water in any given month and/or any given year. The EIR
cannot assume that MCWD gives up its senior water rights of the recycled water either.
2. The MRWPCA claimed that it has spent about 3 million dollars on planning, designing and
modifying the regional treatment plant to provide recycled water to MCWD under the executed 2009
RUWAP agreement. Will this project utilize the MCWD designs or modified regional treatment that will
be paid by MCWD for this project? What additional work on the regional treatment plant that will be
done on this project? How does MRWPCA identify and separate all costs for two different projects,
MCWD and Pure Water Project?
3. What impacts does this proposed project affect the MCWD recycled water or RUWAP project in
terms of completed designs? What is the required separation between MRWPCA recycled pipes and
MCWD recycled pipes?
4. The EIR needs to consider the alternative of pumping excess winter flow from the Salinas River,
treat it, and recharge the Seaside Aquifer.
5. How do the discharges of the proposed advanced water treatment plant and secondary source
water affect the MCWD brine disposal capacity as described in the executed agreement with MRWPCA
and the total capacity of the existing outfalls? What is the status of the executed MCWD brine disposal
agreement with MRWPCA?
6. How does this project affect access to the Districts property at the Armstrong Ranch and adjacent
to the MRWPCA property and impact the proposed use of the Districts property?
7. Will this EIR utilize any part of the adopted and paid for by MCWD RUWAP EIR and/or any
previously EIRs adopted and paid for by MCWD?
The above comments are mine and they do not represent the official comments from MCWD. Let me
know if you have any questions.
Sincerely,
signed by Peter Le
January 7,
2015
Attn: Bob Holden, Principal Engineer
5 Harris Court, Building G
Monterey, CA 93940
gwr@mrwpca.com
Re: comments on Supplement to the Notice of Preparation for Monterey
Peninsula Groundwater Replenishment Project - SCH#2013051094
Via electronic mail
Dear Mr. Holden,
Thank you for the opportunity to comment on the Supplement to the Notice
of Preparation (Supplement to the NOP) for the Monterey Peninsula
Groundwater Replenishment Project. Surfrider Foundation is a non-profit
environmental organization dedicated to the protection and enjoyment of
oceans, waves, and beaches through a powerful activist network. In support
of this mission, and specifically in support of protecting water quality and
marine ecosystems, the Surfrider Foundation Monterey Chapter has been
very engaged in the effort to identify water supply and demand offsetting
solutions for peninsula cities, which would replace the deficit of water that
was formerly supplied by the Carmel River and Seaside Groundwater Basin.
The Surfrider Foundation Monterey Chapter (Surfrider) wishes to offer the
following comments on the document:
On page three of the Supplement to the NOP, it is mentioned states that one
of the project changes is the addition of a water diversion at Tembladero
Slough, comprised of a new intake structure on the channel bottom screened
to prevent fish from entering the pump system.
Although the Tembladero Slough is very impaired (--it is a Clean Water Act
Section 303d-listed water body for impairments from pesticides, nutrients,
fecal coliform, and ammonia), it serves an important role in delivering
freshwater into the Elkhorn Slough and also supports aquatic life, including
the federally listed tidewater goby. Surfrider is concerned that the proposed
water diversion intake could adversely impact aquatic species through
impingement and/or entrainment, and also that the loss of freshwater to this
system could exacerbate the current impairments and further reduce the
environmental services provided by the Tembladero Slough.
To ensure that the project is consistent with various environmental laws
(including Endangered Species Act, Clean Water Act, Porter-Cologne Water
Quality Control Act and the California Coastal Act, and others) and therefore
also specifically to comply with the California Environmental Quality Act
(CEQA), Surfrider believes it would be advisable to consider project
alternatives that appropriately avoid or minimize impacts to aquatic life by a)
using the Best Available Site, Design, and Technology to minimize
impingement and entrainment to aquatic species at all life stages and b)
minimizing the loss of freshwater from the Tembladero Slough to prevent
further degradation of the water body. To achieve these objectives, it may be
necessary to consider a project alternative that does not rely on water from
the Tembladero Slough.
Thank you for consideration of these comments. Please continue to include
the Surfrider Foundation Monterey Chapter in future notices related to this
project.
Sincerely,
Antony Tersol
Vice Chair
Surfrider Foundation Monterey Chapter
319 Forest Ave.
Pacific Grove, CA 93950
atersol@gmail.com
From:
To:
Subject:
Date:
Attachments:
Denise Duffy
Diana Buhler; Alison Imamura
FW: Supplement to NOP for MRWPCA GWR project (8028-110)
Friday, January 09, 2015 8:02:21 AM
CWSRF-FedralCrossCutterTrifoldBrochure(2-19-2014).pdf
CWSRF-CEQA Flyer(2-19-2014).pdf
CWSRF-BCBRR-Flyer(2-19-2014).pdf
FYI on another NOP comment see below - 3 brochures explaining the SRF program
From: Mike McCullough [mailto:MikeM@mrwpca.com]

Sent: Thursday, January 8, 2015 3:15 PM
To: Denise Duffy; bschussman@perkinscoie.com
Subject: FW: Supplement to NOP for MRWPCA GWR project (8028-110)
FYI
From: Kashkoli, Ahmad@Waterboards [mailto:Ahmad.Kashkoli@waterboards.ca.gov]

Sent: Thursday, January 08, 2015 3:11 PM
To: valerieyoung@rcn.com
Cc: Bob Holden; Mike McCullough; Brezack, Jim; Stewart, Susan@Waterboards; Alison Imamura; Hack,
Jody@Waterboards
Subject: RE: Supplement to NOP for MRWPCA GWR project (8028-110)
Hello Valarie,
I just realized that we have not responded to your NOP, and the due date is today. Attached are
three brochures that further explain the CWSRF Program environmental review process and the
additional federal requirements. For the complete environmental application package please visit:
http://www.waterboards.ca.gov/water_issues/programs/grants_loans/srf/srf_forms.shtml. The
State Water Board is required to consult directly with agencies responsible for implementing federal
environmental laws and regulations. Any environmental issues raised by federal agencies or their
representatives will need to be resolved prior to State Water Board approval of a CWSRF financing
commitment for the proposed Project.
Thank you for considering our requirements. Please let me or Susan Stewart know if any questions
or need additional information.
Ahmad Kashkoli, Senior Environmental Scientist

Division of Financial Assistance
State Water Resources Control Board
1001 I Street, Sacramento, CA 95814
Telephone: (916) 341-5855
Fax: (916) 341-5707
akashkoli@waterboards.ca.gov
From: Stewart, Susan@Waterboards

Sent: Wednesday, December 10, 2014 2:30 PM
To: valerieyoung@rcn.com; Kashkoli, Ahmad@Waterboards; Hack, Jody@Waterboards
Cc: Bob Holden; Mike McCullough; Brezack, Jim; Alison Imamura

Subject: RE: Supplement to NOP for MRWPCA GWR project (8028-110)
Hello Valerie,
Thank you for sending us early notice, and a copy of the Supplement to the NOP for the
Groundwater Replenishment Project. I will be sure Ahmad is aware of this document so we can
review the changes to the Project and provide comment as needed.
Susan Stewart
susan.stewart@waterboards.ca.gov
(916) 341-5879
From: valerieyoung@rcn.com [mailto:valerieyoung@rcn.com]

Sent: Wednesday, December 10, 2014 10:18 AM
To: Kashkoli, Ahmad@Waterboards; Stewart, Susan@Waterboards
Cc: Bob Holden; Mike McCullough; Brezack, Jim; Alison Imamura
Subject: Supplement to NOP for MRWPCA GWR project
Hi Ahmad and Susan,
Attached please find Supplement to May 2013 Notice of Preparation (NOP) for the Monterey Regional
Water Pollution Control Agency Groundwater Replenishment Project. You will recall we met with you
back in January of this year to describe the project and discuss environmental review protocols. The
project description has been updated since then, and we have issued this NOP Supplement to enable
agency and public comment on the environmental review of the project updates. The NOP Supplement
has been submitted to the State Clearinghouse and they will do their normal distribution, which includes
the SWRCB. We wanted you to receive this directly from out team as well.
Please let us know if you have any questions, and wishing you both a happy holiday season.
Cheers,
Valerie Young
for MRWPCA
Valerie J. Young, AICP

Environmental Planning Consultant
550 Battery Street #1904
San Francisco, CA 94111
415.341.4671
National Historic Preservation Act (NHPA)

Section 106 of the NHPA requires an analysis of the effects
on historic properties. The Section 106 process is designed
to accommodate historic preservation concerns for federal
actions with the potential to affect historic properties. Early
consultation with appropriate government agencies, Indian
tribes, and members of the public, will ensure that their
views and concerns are addressed during the planning phase.
Historic properties (i.e., buildings, structures, objects,
and archaeological sites 50 years or older) are properties
that are included in the National Register of Historic
Places or meet the criteria for the National Register.
ADDITIONAL INFORMATION
If your project has the potential to affect biological resources
or historic properties, the consultation process can be
lengthy. Please contact the State Water Board staff early
in your planning process to discuss what additional
information may be needed for your specific project.
Please contact your State Water Board Project Manager
or Mr. Ahmad Kashkoli at (916) 341-5855 or
Ahmad.Kashkoli@waterboards.ca.gov for more
information related to the CWSRF Programenvironmental
review process and requirements.
CLE AN WATER STATE REVOLVING FUND
Environmental
Review
Requirements
Required Documents:
A draft State Historic Preservation Officer consultation
request letter; and
A cultural resources report on historic properties conducted
according to the Secretary of the Interiors Standards,
including:
A clearly defined Area of Potential Effect (APE),

specifying the length, width, and depth of excavation,
with a map clearly illustrating the project APE;
A records search, less than one year old, extending to a
half-mile beyond the project APE;
Written description of field methods;
Identification and evaluation of historic properties
within the projects APE; and
Documentation of consultation with the Native
American Heritage Commission and local Native
American tribes.

REVISED: FEB. 2014
www.waterboards.ca.gov
ENVIRONMENTAL REVIEW
REQUIREMENTS
The Clean Water State Revolving Fund (CWSRF) Program is
partially funded by the United States Environmental Protection
Agency (EPA), and is subject to federal environmental regulations
as well as the California Environmental Quality Act (CEQA).
All applicants seeking CWSRF financing must comply with
both CEQA and the federal cross-cutting regulations. The
"Environmental Package" provides the forms and instructions
needed to complete the environmental review requirements
for CWSRF financing. The forms and instructions are available
at: http://www.waterboards.ca.gov/water_issues/
programs/grants_loans/srf/srf_forms.shtml.
Lead Agency/Applicant
The applicant will generally act as the "Lead Agency" for
environmental review. It will prepare, circulate, and consider
the environmental documents prior to approving the
project. It also provides the State Water Board with copies
of the CEQA documents, and a completed Environmental
Evaluation Form for Environmental Review and Federal
Coordination (http://www.waterboards.ca.gov/
water_issues/programs/grants_loans/srf/docs/forms/
application_environmental_package.pdf) with supporting
documents as part of the "Environmental Package."
Responsible Agency/State Water Board

The State Water Board acts on behalf of EPA to review and
consider the environmental documents before approving
financing. The State Water Board may require additional
studies or documentation to make its own CEQA findings, as
well as circulate CEQA documents and other environmental
reports to relevant federal agencies for consultation before
making a determination about the project financing.
The Applicant must address all relevant federal agencies'
comments before project financing is approved.
FEDERAL CROSS-CUTTING REGULATIONS

The CWSRF Program requires consultation with
relevant federal agencies on the following federal
environmental regulations, if applicable to the project:
Clean Air Act
Coastal Barriers Resources Act
Coastal Zone Management Act
Endangered Species Act
Environmental Justice
Farmland Protection Policy Act
Floodplain Management
Magnuson-Stevens Fishery Conservation
and Management Act
Migratory Bird Treaty Act
National Historic Preservation Act
Protection of Wetlands
Safe Drinking Water Act,
Sole Source Aquifer Protection
Wild and Scenic Rivers Act
The following is a brief overview of requirements
for some of the key regulations.
Clean Air Act (CAA)

The CAA general conformity analysis only applies to
projects in areas not meeting the National Ambient Air
Quality Standards or subject to a maintenance plan.
If project emissions are below the federal de minimis levels
then:
A general conformity analysis is not required.
If project emissions are above the federal de minimis levels
then:
A general conformity determination for the project must
be made. A general conformity determination can be
made if facilities are sized to meet the needs of current
population projections used in an approved State
Implementation Plan for air quality.
Using population projections, applicants must explain

how the proposed capacity increase was calculated.
An air quality modeling analysis is necessary of
all projects for the following criteria pollutants,
regardless of attainment status:
Carbon monoxide
Lead
Oxides of nitrogen
Ozone
Particulate matter (PM2.5 and PM10)
Sulfur dioxide
Endangered Species Act (ESA)

The ESA requires an analysis of the effects on federally listed
species. The State Water Board will determine the projects
potential effects on federally listed species, and will initiate
informal/formal consultation with the United States Fish
and Wildlife Service (USFWS) and/or the National Marine
Fisheries Service, as necessary under Section 7 of the ESA.
Required Documents:
A species list, less than one year old, from the USFWS and
the California Department of Fish and Wildlifes Natural
Diversity Database;
A biological survey conducted during the appropriate
time of year;
Maps or documents (biological reports or biological
assessments, if necessary); and
An assessment of the direct or indirect impacts to any
federally listed species and/or critical habitat. If no effects
are expected, explain why and provide the supporting
evidence.
Basic Criteria for Cultural Resources Report Preparation

For Section 106 Consultation with the State Historic Preservation Officer (SHPO)
under the National Historic Preservation Act
CULTURAL RESOURCES REPORT

The Cultural Resources Report must be prepared by a
qualified researcher that meets the Secretary of the Interiors
Professional Qualifications Standards. Please see the
Professional Qualifications Standards at the following website
at: http://www.cr.nps.gov/local-law/arch_stnds_9.htm
The Cultural Resources Report should include one of the
four findings listed in Section 106. These include:
No historic properties affected
(no properties are within the area of potential
effect (APE; including below the ground).
No effect to historic properties
(properties may be near the APE, but the
project will not have any adverse effects).
No adverse effect to historic properties
(the project may affect historic properties,
but the effects will not be adverse).
Adverse effect to historic properties
Note: Consultation with the SHPO will be required if a
no adverse effect to historic properties or an adverse
effect to historic properties determination is made,
to develop and evaluate alternatives or modifications
to the proposed project that could avoid, minimize or
mitigate adverse effects on historic properties.
RECORDS SEARCH
A records search (less than one year old) extending to a halfmile beyond the project APE from a geographically appropriate
Information Center is required. The records search should
include maps that show all recorded sites and surveys in
relation to the APE for the proposed project, and copies of the
confidential site records included as an appendix to the Cultural
Resources Report.
The APE is three-dimensional (depth, length and width) and
all areas (e.g., new construction, easements, staging areas, and
access roads) directly affected by the proposed project.
NATIVE AMERICAN
and INTERESTED PARTY CONSULTATION
Native American and interested party consultation should
be initiated at the planning phase of the proposed project
to gather information to assist with the preparation of an
adequate Cultural Resources Report.
The Native American Heritage Commission (NAHC) must be
contacted to obtain documentation of a search of the Sacred
Lands Files for or near the project APE.
All local Native American tribal organizations or individuals
identified by the NAHC must be contacted by certified mail,
and the letter should include a map and a description of the
proposed project.
Follow-up contact should be made by telephone and a phone
log maintained to document the contacts and responses.
Letters of inquiry seeking historical information on the
project area and local vicinity should be sent to local historical
societies, preservation organizations, or individual members
of the public with a demonstrated interest in the proposed
project.
Copies of all documents mentioned above (project
description, map, phone log and letters sent to the
NAHC and Native American tribal organizations
or individuals and interested parties) must be
included in the Cultural Resources Report.
Contact Information: For more information related to the CWSRF Program
Cultural Resources and Requirments, please contact Mr. Ahmad Kashkoli at
916-341-5855 or Ahmad.Kashkoli@waterboards.ca.gov
REVISED: JAN. 2014
PRECAUTIONS
A finding of no known resources without supporting
evidence is unacceptable. The Cultural Resources Report
must identify resources within the APE or demonstrate
with sufficient evidence that none are present.
The area is sensitive for buried archaeological
resources, followed by a statement that monitoring is
recommended. Monitoring is not an acceptable option
without good-faith effort to demonstrate that no known
resource is present.
If the area is already disturbed by previous
construction documentation is still required to demonstrate
that the proposed project will not affect historic properties.
An existing road can be protecting a buried archaeological
deposit or may itself be a historic property. Additionally,
previous construction may have impacted an archaeological
site that has not been previously documented.
SHPO CONSULTATION LETTER

Submit a draft consultation letter prepared by the qualified
researcher with the Cultural Resources Report to the State Water
Resources Control Board. A draft consultation letter template is
available for download on the State Water Board webpage at:
http://www.waterboards.ca.gov/water_issues/programs/
grants_loans/cwsrf_requirements.shtml
waterboards.ca.gov
California Environmental Quality Act Requirements

The State Water Resources Control Board

(State Water Board), Division of Financial
Assistance, administers the Clean
Water State Revolving Fund (CWSRF)
Program. The CWSRF Program is partially
funded by grants from the United States
Environmental Protection Agency. All
applicants seeking CWSRF financing
must comply with the California
Environmental Quality Act (CEQA), and
provide sufficient information so that
the State Water Board can document
compliance with federal environmental
laws. The Environmental Package
provides the forms and instructions
needed to complete the environmental
review requirements for CWSRF Program
financing. It is available at:
http://www.waterboards.ca.gov/
water_issues/programs/grants_
loans/srf/srf_forms.shtml
LEAD AGENCY
The applicant is usually the Lead Agency and

must prepare and circulate an environmental
document before approving a project. Only
a public agency, such as a local, regional or
state government, may be the Lead Agency
under CEQA. If a project will be completed by a
non-governmental organization, Lead Agency
responsibility goes to the first public agency
providing discretionary approval for the project.
RESPONSIBLE AGENCY
The State Water Board is generally a

Responsible Agency under CEQA. As a
Responsible Agency, the State Water Board
must make findings based on information
provided by the Lead Agency before financing
a project.
ENVIRONMENTAL REVIEW
The State Water Boards environmental review

of the projects compliance with both CEQA
and federal cross-cutting regulations must be
completed before a project can be financed by
the CWSRF Program.
DOCUMENT REVIEW
Applicants are encouraged to consult with

State Water Board staff early during preparation
of CEQA document if considering CWSRF
financing. Applicants shall also send their
environmental documents to the State Water
Board, Environmental Review Unit during
the CEQA public review period. This way, any
environmental concerns can be addressed early
in the process.
Contact Information: For more information related to the CWSRF Program environmental
review process and requirements, please contact your State Water Board Project Manager
or Mr. Ahmad Kashkoli at 916-341-5855 or Ahmad.Kashkoli@waterboards.ca.gov
REVISED: FEB. 2014
REQUIRED DOCUMENTS
The Environmental Review Unit requires the

documents listed below to make findings and
complete its environmental review. Once the
State Water Board receives all the required
documents and makes its own findings, the
environmental review for the project will be
complete.
Draft and Final Environmental Documents:

Environmental Impact Report, Negative
Declaration, and Mitigated Negative Declaration as appropriate to the project
Resolution adopting/certifying the environmental document, making CEQA findings,

and approving the project
All comments received during the public

review period and the Lead Agencys
responses to those comments
Adopted Mitigation Monitoring and

Reporting Plan, if applicable
Date-stamped copy of the Notice of

Determination or Notice of Exemption filed
with the County Clerk(s) and the Governors
Office of Planning and Research
CWSRF Evaluation Form for Environmental

Review and Federal Coordination with
supporting documents
waterboards.ca.gov
CITY OF SEASIDE- RESOURCEMANAGEMENTSERVICES

440 Harcourt Avenue
Telephone (831) 899-6736
Seaside, CA 93955
FAX (831) 899-6211
February6, 2015
Bob Holden, Principal Engineer

5 Harris Court, Bldg. D

Monterey, CA 93940
Via Email: (;wr(S),mrwpca. com
Subject:
NOP for Supplement to May 2013 Notice ofPreparation of an EIRfor the

Pure Water Monterey Groundwater Replenishment Project
Dear Mr. Holden,
This letter transmits comments for the proposed subject project. The City of Seaside respectfully
requests that the following comments be considered for incorporation into the environmental
documents.
1) The proposed monitoring wells will be relocated, if necessaryand at the owner's expense,
as soon as the City has approved developmentplans for the area. The monitoring wells
shall be relocated to be within a proposed future public right ofway or an accessible public
area.
2) The proposedmonitoring wells should not include any above grade features.
3) Proposed above grade features, such as injection well appurtenances, shall be screened to
minimize visual impacts.
4) The proposed backwashpits shouldbe designedto minimize visual impacts.

5) In the event that new undergroundpiping is required, the City requests that the sameroute
be used as for the proposed Cal-Am Monterey PeninsulaWater Supply Project.
6) MRWPCAshall coordinate with Cal-Am on work withinthe public right ofway within the
City of Seaside, such as pipeline installation, so that all work is performed concurrently
with Cal-Am.
7) To the greatest extent possible, locate the facilities within the City of Seaside that cannot be
located withina public right ofwayto areasclassifiedasthe Utility Corridor or

Borderlands under the Habitat Management Plan.
H-fjtgimering Review'GWR'^trRiedl hi f/oidea re h'OPMRiVPC^GIVRProjefl. doc
Welook forwardto workingwithyour staffto complete theproposed project in a timely manner.

You may contact me or Rick Riedl of my staff at 831-899-6825 or RRiedl@ci. seaside. ca. us to
discussany questions or comments.
Sincerely,
^.l/^f^
Tim O'Halloran
City Engineer / Public Works Services Manager
Cc: Diana Ingersoll, Deputy City Manager- Resource Management Services

Lisa Brinton, Community and Economic Development Services Manager
Rick Riedl, Senior Civil Engineer
Rick Medina, Senior Planner

DEIR Appendix A

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DEIR Appendix A

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Appendix A

Scoping Report for the Pure Water Monterey

Pure Water Monterey GWR Project

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Pure Water Monterey GWR Project

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Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

4. SUMMARY OF SCOPING COMMENTS......................................................................... 4

Denise Duffy & Associates, Inc.

2. PURPOSE OF SCOPING PROCESS

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

3. OVERVIEW OF SCOPING PROCESS

3.2 NOTICE OF PREPARATION

3.3 OTHER NOTIFICATIONS

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

NOP was sent to the following libraries for public posting:

3.4 PUBLIC SCOPING MEETING

4. SUMMARY OF SCOPING COMMENTS

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

National Environmental Policy Act Process, including Federal Regulatory Compliance

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

4.1 LIST OF LETTERS/COMMENTERS AND ACRONYMS

Eleanor Citen (EC)

List of Commenters at the Public Scoping Meeting

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

4.2 COMMENTS ON GENERAL CEQA AND PROCEDURAL ISSUES

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

4.3 COMMENTS ON PROJECT DESCRIPTION AND ALTERNATIVES

Denise Duffy & Associates, Inc.

Denise Duffy & Associates, Inc.

Denise Duffy & Associates, Inc.

4.4 COMMENTS ON NEPA PROCESS, INCLUDING FEDERAL REGULATORY COMPLIANCE

Endangered Species Act Section 7 (also comment C-4) (SWRCB)

4.5 COMMENTS ON PERMITS/AUTHORIZATIONS/AGREEMENTS/RIGHTS OF WAY

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

4.6 COMMENTS ON SPECIFIC EIR TOPICAL ISSUES

Endangered Species Act Section 7 (also comment C-4) (SWRCB)

Denise Duffy & Associates, Inc.

Pure Water Monterey GWR Project

Denise Duffy & Associates, Inc.

Denise Duffy & Associates, Inc.

Denise Duffy & Associates, Inc.

Denise Duffy & Associates, Inc.

4.7 ISSUES NOT ANALYZED UNDER CEQA

5. CONSIDERATION OF ISSUES RAISED IN SCOPING PROCESS

Denise Duffy & Associates, Inc.

Project Description: Mapping

Overall Purpose, Need,

Project Description: Mapping