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Excerpts from amended Crystal Geyser

Industrial Sewer Permit Application


As Disclosed in February 2018

Crystal Geyser Water Company requested some changes to their sewer permit application
that first were made known to the public in February, 2018. Notably, some proposed
changes would now allow CGWC to discharge air compressor condensate, boiler water
blowdown, and cooling tower blowdown.

None of these changes were disclosed nor reviewed in the Project’s 2017 EIR. Crystal
Geyser just slipped them into its permit a few months after the EIR was certified.

These are not minor changes because they may create significant environmental impacts.
Cooling tower and boiler blowdown waters contain hazardous or toxic chemicals that are
not even allowable under existing City municipal code regulations.

The proposed Permit now deviates significantly from the previous draft permit included
in the EIR. The draft permit analyzed in the EIR made the distinction (page 26) between
contaminated and uncontaminated cooling water, and the draft indicated that
“noncontact” cooling water was not to be discharged to the City’s treatment system.
Now the proposed Permit mixes the two types of cooling water together, allowing for
discharge of contaminated and uncontaminated cooling water.

There is no mention in the sewer permit that Dolphin-type water treatment systems will
continue to be used for CGWC’s boilers and cooling towers.

Attached are those pages in the amended sewer permit application that newly reveal these
alterations.

Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2


City Council Agenda Item #8
Staff Report

Meeting Date: February 26, 2018 X Regular


Consent
To: Mayor and City Council Closed
Presentation
From: Bruce Pope, City Manager

Subject: Crystal Geyser Industrial Permit

Recommendation:
Staff respectfully requests the City Council authorize the City Manager to execute the proposed
Industrial Waste Discharge Permit (Permit) for Crystal Geyser Water Company.

Background & Summary:


The Siskiyou County Planning Commission held a public hearing on September 20, 2017 on the
Crystal Geyser Use Permit Application. Following the close of the public hearing, the Planning
Commission continued its consideration of the Crystal Geyser application for a conditional use
permit to September 27, 2017 for Planning Commission discussion and decision.
On October 4, 2017, the Notice of Determination was filed for the Crystal Geyser Water
Bottling Plant Project Use Permit and certifying the Final Environmental Impact Report (FEIR)
for the project.
Included in the FEIR was a draft version of the Permit for discharge to the City of Mt. Shasta
sewer collection system. The final Permit is being presented for consideration
on with minor
revisions.
Once approved, Crystal Geyser will be approved to connect to the City Wastewater collection
system and begin discharging in accordance with the provisions of the final Permit.

Attachments:
1. Resolution CCR-18-XX Changes are not
"minor"
2. Crystal Geyser Industrial Waste DRAFT Permit with track changes
3. Final Crystal Geyser Industrial Waste Discharge Permit

____________________________________________________________________________________
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2
Regular City Council Meeting February 26, 2018 52
RESOLUTION NO. CCR-18-XX

A RESOLUTION OF THE CITY COUNCIL


OF THE CITY OF MT. SHASTA
APPROVING THE CRYSTAL GEYSER INDUSTRIAL WASTEWATER PERMIT
AND AUTHORIZING THE CITY MANAGER
TO EXECUTE AND TRANSMIT SAID PERMIT

WHEREAS, Crystal Geyser Water Company has proposed to open and operate a water bottling
plant adjacent to the City of Mt. Shasta in Siskiyou County; and

WHEREAS, Siskiyou County has prepared and Certified an Environmental Impact Report
(EIR) for said project; and

WHEREAS, The City of Mt. Shasta is a Responsible Agency regarding the issuance of a
Wastewater Discharge Permit; and FALSE! The
amended
WHEREAS; Said Wastewater Discharge Permit was reviewed in the Project EIR. permit was
not reviewed
in the EIR.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Mt. Shasta
does hereby approve the attached Wastewater Discharge Permit and authorizes and directs the
City Manager to sign the Wastewater Discharge Permit and transmit an executed copy thereof to
Siskiyou County and to Crystal Geyser Company.

The foregoing Resolution was approved this 26th day of February, 2018 by the following vote:

AYES:
NOES:
ABSENT:
ABSTAIN:

DATED: February 26, 2018

ATTEST: CITY OF MT. SHASTA

______________________________ ______________________________
Kathryn M. Wilson, Deputy City Clerk Kathy Morter, Mayor

____________________________________________________________________________________
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2
Regular City Council Meeting February 26, 2018 53
DRAFT
INDUSTRIAL USER
PERMIT
WITH TRACK CHANGES

____________________________________________________________________________________
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2
Regular City Council Meeting February 26, 2018 54
Part 1 Effluent Limitations

INDUSTRIAL WASTE DISCHARGE PERMIT

PART 1 – EFFLUENT LIMITATIONS

A. During the period of February 5, 2018__________ to January 31, 2023__________, the


permittee is authorized to discharge process, non-process, and sanitary wastewater to
the City of Mt. Shasta sewer system from the outfalls listed below. Refer to Figure 1
provided in PART 7 - FACT SHEET.

Table 1 – Outfall Summary

Outfall Description
001 Outfall 001 is located in a manhole southwest of the Bottling Building, in Rd No 2M05
(southern entrance to facility from Mt. Shasta Blvd.). Outfall 001 is located on the
industrial discharge line, downstream of the pH Neutralization System and upstream
of the sanitary wastewater sewer connections. Sampling Points 001, 002, and 003
are the points of compliance, see ADDITIONAL/SPECIAL MONITORING
REQUIREMENTS.

002 Outfall 002 is located in a manhole southwest of the Bottling Building, just upstream
of the manhole along Rd No 2M05 (southern entrance to facility from Mt. Shasta
Blvd.). Outfall 002 is located on the sanitary wastewater discharge line, upstream of
the industrial sewer connections. Sampling Point 004 is the point of compliance.
003 Outfall 003 is south of the Bottling Building and discharges to a leach field. In the
event that non-compliance water is diverted directly to the City sewer system,
Sampling Point 002 will be utilized for compliance. In the event non-compliance
water is diverted to the City sewer system through the pH Neutralization System,
Sample Point 001 will be used for compliance.
Note: Sampling locations for each outfall are described in Table 7 – Sample Point Summary.
B. Discharge from Outfall 001 must not exceed effluent limitations. Refer to Table 2. Effluent
from Outfall 001 consists of wastewater from cleaning and sanitizing operations; tea brewing
and bottling; and juice batching and bottling from Drain System 1. Refer to Figure 1 provided
in PART 7 - FACT SHEET. This wastewater includes high-strength wastewater from spilled
product and internal and external cleaning and sanitizing chemicals (e.g., sodium hydroxide
and acids); flavor change rinse water; condensate, boiler blowdown water, cooling tower
blowdown water, and final rinse water from product lines and tanks. Outfall 001 is treated by
the pH Neutralization System. The facility is considered a non-categorical wastewater and
must comply with local limits (MSMC 13.56.030 & 13.56.320). Not in
EIR !
C. Discharge from Outfall 002 must not exceed effluent limitations. Refer to Table 2. Effluent
from Outfall 002 consists of domestic wastewater (e.g., faucets, drinking fountains, sinks,
bathrooms, and showers). Refer to Figure 1 provided in PART 7 - FACT SHEET. No
pretreatment is performed prior to discharge to the City sewer.

____________________________________________________________________________________
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2
City of Mt. Shasta 2 Permit No. XXXXXIWD-2018-01
Regular City Council Meeting February 26, 2018 63
Part 1 Effluent Limitations

E. The permittee must not discharge wastewater containing any of the following substances
from any of the outfalls:
a. Fats, oil, or greases of animal or vegetable origin in concentrations that will tend to cause
adverse effects on the City of Mt. Shasta Wastewater Treatment Plant;
b. Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin, in amounts
that will cause interference or pass through;
c. Pollutants that create a fire or explosive hazard in the Publicly Owned Treatment Works
(POTW), including but not limited to wastestreams with a closed-cup flashpoint of less
Condensate
can contain than 140 degrees Fahrenheit (60 degrees Celsius) using the methods specified at
oil 40 CFR 261.21
d. Wastewater that has a temperature greater than 120 degrees Fahrenheit (49 degrees
Celsius) or will inhibit biological activity in the treatment plant resulting in interference, but
in no case wastewater that causes the temperature at the introduction into the treatment
plant to exceed 104 degrees Fahrenheit (40 degrees Celsius);
e. Solids or viscous substances in amounts that will cause obstruction of flow in the POTW,
resulting in interference [but in no case solids greater than 3/8 inch(es) in any dimension];
f. Pollutants, including oxygen-demanding pollutants (e.g., BOD), released in a discharge at
a flow rate and/or concentration that, singly or by interaction with other pollutants, will
cause interference with the POTW. For the purpose of this section, the term interference
has the same definition as that in the City of Mt. Shasta ordinance MSMC 13.56.030(C)(5);
g. Wastewater having a pH of less than 6.5 or more than 8.5, or otherwise causing corrosive
structural damage to the POTW or equipment;
h. Pollutants that result in the presence of toxic gases, vapors, or fumes within the POTW in
a quantity that might cause acute worker health and safety problems;
i. Noxious or malodorous liquids, gases, solids, or other wastewater that, either singly or by
interaction with other wastes, are sufficient to create a public nuisance or hazard to life, or
Prohibits to prevent entry into the sewers for maintenance or repair;
biocides that
are j. Sludges, screenings, or other residues from the pretreatment of industrial wastes;
commonly
added to k. Any substance that could affect the treatment plant’s effluent and cause violation of the
cooling tower
water National Pollutant Discharge Elimination System permit requirements;
l. Any substance that would cause the treatment plant to be in noncompliance with sludge
use, recycle or disposal criteria pursuant to guidelines or regulations developed under
section 405 of the Clean Water Act, the Solid Waste Disposal Act, the Clean Air Act, the
Toxic Substances Control Act, or other regulations or criteria for sludge management and
disposal as required by the state;
m. Wastewater that imparts color that cannot be removed by the treatment process, such as
consequentl imparts color to the
dye wastes and vegetable tanning solutions that consequently
treatment plant’s effluent, thereby violating the City of Mt. Shasta Wastewater Treatment
Plant National Pollutant Discharge Elimination System permit;
n. Medical wastes, except as specifically authorized by the Public Works Director in a permit;

____________________________________________________________________________________
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2
n.
City of Mt. Shasta 4 Permit No. XXXXXIWD-2018-01
Regular City Council Meeting February 26, 2018 65
Part 1 Effluent Limitations

o. Stormwater, surface water, groundwater, artesian well water, roof runoff, subsurface
drainage, swimming pool drainage, condensate, deionized water, nNoncontact cCooling
wWater,
ater, and unpolluted wastewater, unless specifically authorized by the Public Works
Director.. The permittee has requested authorization to discharge two additional waste
streams:
1. Condensate - Condensate from an oil-free compressor.
2. Noncontact cooling water – Boiler and cooling tower blowdown water.
o. Further description of these waste streams is included in PART 7 - FACT SHEET,
PROCESS UNIT OPERATION/FLOW INFORMATION.. The permittee is authorized to
discharge these two waste streams complying with all effluent llimits as described in
herein;;
p. Wastewater causing, alone or in conjunction with other sources, the treatment plant’s
effluent to fail toxicity test;
q. Detergents, surface-active agents, or other substances that that might cause excessive
foaming in the POTW;
r. Wastewater containing any radioactive wastes or isotopes except in compliance
with applicable state or federal regulations; or
F. All discharges must comply with all other applicable laws, regulations, standards, and
requirements contained in MSMC 13.56.320(B) & (C) and any applicable state and
federal pretreatment laws, regulations, standards, and requirements, including any such
laws, regulations, standards, or requirements that might become effective during the term
of this permit.

This new information has not been analyzed in 2017 CGWC EIR!

____________________________________________________________________________________
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2
City of Mt. Shasta 5 Permit No. XXXXXIWD-2018-01
Regular City Council Meeting February 26, 2018 66
Part 7 Reporting Forms

D. PROCESS UNIT OPERATION/FLOW INFORMATION

Table 8 – Process Flow Description

Industrial Sample Process Process Description


Wastewater Point Operation
Permit Code
IWD-2018- 001, 003 Drain Utilized during cleaning and sanitizing operations; tea
01XXXXX System 1 brewing and bottling; and juice batching and bottling.
Includes high-strength wastewater from spilled product
and internal and external cleaning and sanitizing
chemicals (e.g., sodium hydroxide and acids); flavor
change rinse water; condensate4, noncontact cooling
water5 and final rinse water from product lines and tanks.
Wastewater is collected by floor drains and discharged to
the pH Neutralization System.
001, 002 Drain System is isolated from Drain System 1. Drain System 2
System 2 collects wastewater from water processing and
production of bottling sparkling water (e.g., filter
backwash, ozonated water rinse. Wastewater is
normally discharged to the leach field).
004 Sanitary The facility’s sanitary wastewater system conveys
Sewer wastewater (e.g., faucets, drinking fountains, sinks,
bathrooms, and showers) through a sanitary sewer
system that connects the City sewer.

E. DILUTION/AUXILIARY OPERATION/FLOW INFORMATION


The sanitary wastewater and pH neutralization effluent combine after Sample Points 001, 002,
003, and 004.
F. FLOW-MEASURING DEVICE
Crystal Geyser Water Company shall install magnetic flow meters in both the industrial
discharge line and the sanitary wastewater line to monitor flows to the City sewer system and to
use as a basis for determining monthly sewer rates.
G. PRETREATMENT UNIT OPERATIONS
Drain System 1 effluent is collected in a 10,000-gallon, in-ground sump. The wastewater is
pumped from the sump to the pH Neutralization System at a flowrate of 200 gpm. The pH
Neutralization System consists of a two-stage process. The first and second stage reactor tanks
include a mixer and baffle to prevent short circuiting prior to discharge from the reactor. Each
tank’s pH is monitored by a pH probe. The first stage reactor effluent gravity flows into the second
stage reactor. The second stage effluent gravity flows to a monitoring valve manifold. A third pH
probe monitors effluent pH just upstream of the manifold. Two chemical storage tanks provide up
to 50% sulfuric acid and up to 50% sodium hydroxide, respectively, to adjust pH. These chemical
storage tanks include both high and low level alarms. Chemical from these tanks is pumped into

4
FALSE. Not merely "water"!
Condensate from an oil-free compressor.
5 Noncontact water consists of boiler and cooling tower blowdown
blowdo water. Boiler blowdown water includes a
solution of up to approximately 300 ppm of anti-scaling agent 1 (Boilermate 1200S or equal) and up to
approximately 23 ppm of anti-scaling agent 2 (Boilermate 3300C or equal). Cooling tower blowdown water
consists of water from the onsite domestic well.
City of Mt. Shasta 38 Permit No. XXXXXIWD-2018-01
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Regular City Council Meeting February 26, 2018 99
Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #2