Att A_Comment Log_compiledDraft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 1 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit1ib 1.1 11st ppgh, last sentence: Lakeside Park Association is also a recognized Water System; Primary Source: SW. Suggest changing the sentence to: Groundwater is the primary source of drinking water in the TVS Basin. The primary producers of groundwater are the South Tahoe Public Utility District (District),..."2ib 1.1 13rd ppgh, 3rd line: chage to: "(LRWQCB) and"3ib 1.1 13rd ppgh, 7th line: chage to: "Entities referred to as Identified Dischargers are..."4 ib 2.1 10 2.1.B.i: "…Related to PCE Contamination (RCI, 2015)" FYI ‐ The copy of the report that I have is dated Febyruary 15, 20155 ib 2.1 10 2.1.B.ii: "…PCE Investigation Report (URS, 2016)"6ib 2.110C: "…by DRI."7ib 2.110D: add references for each listed source if results are from public available reports and included in References, such as 2018 PDI Sampling (KJ, 2019);8 ib 2.2.1 10 3rd line, change to…in May 2015."9Jenn Lukins Project Overview 10 Delete: "help the impacted water purveyors to" 10 Jenn Lukins Project Overview 10 Change paragraph starting "It should be noted…." to: "It should be noted that multiple parties have been collecting data related to PCE groundwater contamination in the South Y Area including data collected by Seven Springs/Fox pursuant to the Lahontan Regional Water Quality Control Board's (LRWQCB) Clean up and Abatement Order (CAO) R6T‐201‐0022 and data collected by a contractor for the LRWQCB under the Site Cleanup Subaccount Program (SCAP)."11 ib 2.2.2 12 1st ppgh, add sentence to end of ppgh; Further testing would be needed to confirm the need for iron and manganeese treatment prior to GAC filtration.12 ib 2.2.3 12 Last ppgh: "…described in Section 2.2.4."13 ib 2.2.4 12 1st ppgh, 1st line: "…District retained DRI to develop…"14 ib 2.2.4 12 1st ppgh, 6th line: "For the South Y Feasibilitry Study, DRI extracted…"15 ib 2.2.4 12 3rd ppgh, 1st line: "Information from the South Y Fate and Transport Model was used todevelop various management scenarios and screen and refine these scenarios for effectiveness."16 Jenn Lukins Alternatives Development‐ Alt's selected for further consideration12 Change second bullet starting "Targeted Pumping . . ." to: "Targeted Pumping of an existing well equiped with treatment to remove PCE and construction and operation of a new extraction well to be equiped with PCE treatment."\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 2 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit17 Jenn Lukins Recommended Alternative 13 As noted previously, all references to "LBWC 4R" must be changed to "R1" and all references to or implications that LBWC will construct or operate the new PCE extraction well must be removed. The "R1" well should be the responsibility of the LTLW RPs and/or the LRWQCB and will not be the responsibility of LBWC. Recommended rewording of this section is as follows: Based on the Evaluation and Ranking of Alternatives, Alternative 2 Option 1 is the recommended Alternative that will best meet the Feasibility Study goals to control or clean up HVOCs in groundwater that serves or has served as a source of drinking water.The recommended alternative would involve LBWC operating LBWC 5 (once it is equipped with PCE treatment) as its lead supply well, with LBWC 1 as its lag well. In addition the LTLW RP's and/or the LRWQCB would replace LBWC 4 with a PCE extraction well (R1) which will be equipped with PCE treatment and iron and manganese treatment to meet drinking water quality standards for potable reuse of extracted water.LBWC 5 would be operated to meet water system demands in a manner that would result in increased contaminant removal and plume containment compared to the No Action Alternative. R1 would be drilled and screened to remove PCE from groundwater above 150 feet bgs. Pumping rates and levels of treatment at TKWC wells would be maintained as is.18 Jenn Lukins Recommended Alternative 13 Figure ES 2 and Figure ES 3 show the conceptual site layout of the R1 facility, including approximate locations, sizes, and quantities of elements. Based on the Conceptual Design and Site Layout, it is estimated that implementation of this Alternative could take 3 to 5 years.19 SR Table ES 1 14 Perhaps it should be noted that the simulations for Alternative 2 do not incorporate the 3‐7 years to implementation ‐ they begin immediately. However, I don't think this invalidates the concentration trends/reduction in toxicity as you have stated them. 20 ib 2.3.3 17 1st ppgh, 2nd line:" …under direction from the LRWQCB."21 ib 2.3.3 17 Add bullit: PCE is present at high concentrations (PCE > 20 µg/L) at intermediate depths (70 ‐ 142 ft depths; Sonic 3) and above MCLs at deeper depths (178 ‐ 180; Sonic 3), neighboring LBWC4. PCE was not detected in two samples collected at depths below 200 feet from Sonic 3.22 ib 2.4 18 1st ppgh, 3rd line: "…located about 1,200 feet north and hydraulically down‐gradient with respect to the Tucker Avenue…"23 ib 2.4 18 1st ppgh, 9th line: : "…shown on Figure 2‐1."24 ib 2.5 18 1st ppgh, bottom line 7. Figure 2‐6 shows water quality trends in the LBWC and TKWC wells. Delete last sentence.25 Jenn Lukins Summary of Site History 18 Change "…two LBWC wells (LBWC 3‐destroyed and LBWC 4‐ offline)" TO: three LBWC wells (LBWC 2‐ inactive, LBWC 3‐ destroyed and LBWC 4‐ inactive) \\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 3 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit26 Jenn Lukins Summary of Site History 18 Change paragraph starting "Multiple parties are engaged . . ." to "Multiple parties are engaged in the collection of water quality data related to the occurrence anddistribution of PCE within the South Y Plume, including the local water purveyors (District, LBWC, and TKWC), LRWQCB staff, and Seven Springs/Fox (the designated Resposinble Parties for PCE contamination emanating from the LTLW site) pursuant to the LRWQCB's Clean up and Abatement Order (CAO) R6T‐201‐0022. Water quality sampling and regional investigations conducted since 2016 have contributed to a greater understanding of the extent, concentrations, and source of the PCE plume."27 Jenn Lukins 1.2.1 Feasibility Study Objective20 Delete: "help the impacted water purveyors to" 28 Jenn Lukins Table 1‐1: Technical Advisory Committee Roster21 Change: "Jennifer Lukins, Assistant General Manager" TO: "Jennifer Lukins, Manager"29 Jenn Lukins Table 1‐2: Stakeholder Advisory Group Members22 Change: "Jennifer Lukins: Position‐ Vice President" TO: "Jennifer Lukins, Manager"30 Jenn Lukins 1.2.5.1 Remedial Action Objectives23 Change paragraph starting "As this Feasibility Study . . ." to: "As this Feasibility Study is an effort to identify measures that can be taken to minimize the impact of the PCE contamination to impaired or threatened drinking water supplies, the RAOs were developed to assist the water purveyors evaluate actions that can be taken to promote that goal. These actions may overlap with, but are not necessarily the same as, the actions that the LRWQCB and dischargers of the PCE should take to clean up the PCE contamination impacting the South Y."31 Jenn Lukins 1.2.5.1 Remedial Action Objectives23 Change paragraph starting "With that focus . . ." to "With that focus, the RAOs were developed first to consider General EPA RAOs from EPA Document 540/R‐96/023 and EPA Document 540/G‐88/003 that are relevant to contaminated groundwater. The general EPA RAOs were supplemented with South Y specific RAOs to reflectthe needs of the PWS that are above and beyond direct plume remediation (which is also needed), as follows"32 Jenn Lukins 1.2.5.1 Remedial Action Objectives24 Change paragraph starting "These RAOs were a consideration . . ." to "These RAOs were a consideration in the screening and development of alternatives; the alternatives were not targeted specifically at wellhead treatment, though that is a typical focus of RAOs."33 Jenn Lukins 1.3 Goals of the Feasibility Study26 Delete "that can be implemented by the water purveyors"34 Jenn Lukins 2.2.1 LBWC PER 27 Change: "…in the water quality samples…" TO: "in LBWC 2 and LBWC 5 from water quality samples collected on June 16, 2014, the results of which were first reported to LBWC on July 7, 2014."35 SR Section 2.1 27 Item C, remove University of Nevada ‐ Reno (DRI is not a part of UNR)36 Jenn Lukins 2.2.2 District South Y Extraction Well Suitability Investigation28 Delete the entire paragraph commencing with "During this Investigation, LBWC 4 was found to be constructed …."37 SR Section 2.2.4 29 Remove University of Nevada38 Jenn Lukins Table 2‐1 30 Change "LBWC 4R" to "R1"\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 4 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit39 ib 4.1.2 32 2nd ppgh, 4th line: …was concern about the reuse of the excess treated water generated by these wells.40 ib 4.1.2.1 32 End of 1st bullet: delete :41 ib 4.1.2.1 33 Add ppgh at end of GAC section: The SWRCB‐DDW has accepted GAC for wellhead treatment at LBWC 5. LBWC is planning to start construction of this water treatment facilicty in 2020. Operation of this facility for the removal of PCE from groundwater is planned to start in February 2021.42 Jenn Lukins 2.3.1 SWRCB Final PCE Investigation Report33 Change: "in LBWC Well 2 and LBWC Well 5 in June 2014…" TO: "in LBWC 2 and LBWC 5 in samples taken from the wells on June 16, 2014."43 Jenn Lukins 2.4 PDI and Water Quality Sampling35 Change: …"presence of clay lens inhibiting the vertical movement…" to presence of clay lens limiting the…"44 Jenn Lukins 2.4 PDI and Water Quality Sampling35 Delete: "Error! Reference source not found.."45 Jenn Lukins 2.5 Summary of Current Conditions and Trends35 Change: …"The vertical extent of the South Y Plume is believed to be inhibited by the lens aquitard occurring between the two uppermost water zones." TO: "The vertical extent of the South Y Plume is believed to be affected by the lens aquitard occurring between the two uppermost water zones.46 SR Section 2.4 35 Missing figure reference47 Jenn Lukins 2.5 Summary of Current Conditions and Trends36 Delete the entire paragraph commencing with "In addition to the investigation being conducted at the LTLW site . . ."48 Jenn Lukins 2.5.1 Drinking Well Conditions36 LBWC 3 and 4 be included as a impaired wells. 49 Jenn Lukins 2.5.1 Drinking Well Conditions36 Change "A GAC filter…" TO: "GAC filtration facilities were installed at TKWC 2 and will be installed at LBWC 5 in the near future."50 ib 4.1.4 37 Last ppgh, bottom of page, 1st line; suggest changing to: In‐Situ Remediation concepts were considered for the mid‐plume area, but later abandoned as the Fate and Transport Model was not of sufficient resolution for individual parcel‐scale analysis.51 ib 4.1.4 38 1st ppgh, 1st line: consider changing to: " Initial screening using the Fate and Transport Model and input from the TAC was used to refine the initial alternative concepts into management scenarios that could be further developed for additional analysis. "52 ib 4.2. 38 Item 2.d.: ‐ Operate53 ib 4.2.1 38 1st line, change to: This Scenario is characterized by optimizing groundwater production from existing PWS wells with wellhead treatment (for the removal of PCE from groundwater), situated within the South Y Plume. 54 ib 4.2.1.1 38 1st line: "Change to: This Scenario would pump..." NOTE: for all Sections under 4.2 the introductory ppgh states that the conceptual alternatives were refined into management scenarios. As such, each sub‐section should refer to scenarios, not concepts. Please find Concept and replace with scenario thoughout Section 4.2.55 ib 4.2.1.2 39 1st ppgh, 5th line: Change to: "…installed at TKWC 2."56 ib 4.2.1.3 40 1st ppgh, 2nd bullet: change to" …(with GAC treatment) as lead well to meet existing…"\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 5 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit57 ib 4.2.1.3 40 2nd ppgh, 6th line: As I recall, TKPOA objected to using TKWC 2 as an extraction well and the potential obligations to maintain the operation of this well for PCE Removal. I do not recall that placing TKWC 2 in the lead resulted in significant changes in system pressures that were objectionable to TKPOA.58 ib 4.2.1.4 40 1st ppgh, 1st sentence: See previous comment regarding changes in system pressure.59 ib 4.2.1.4.1 40 2nd ppgh, 2nd bullet: change to" …(with GAC treatment) as lead well to meet existing…"60 ib 4.2.2 41 1st ppgh, 4th line: "… to loacte intake facilities and securing water rights through the District's surface water right application."61 ib 4.3 41 Consider changing title of this section to: Alternatives Selected for Detailed Analysis62 ib 4.3 41 1st ppgh: consider changing to: ".. .three Management Scenarios were further developed as potential remedial alternatives as shown in Table 4‐1. Criteria used for evaluation of these Alternatives are described in Section 5."63 ib Table 4‐1 42 Change title to: Table 4‐1: Alternatives Selected for Detailed Analysis64 ib Table 4‐1 42 Change Alternative 2 Description, 1st Line to: Operate LBWC 5 as lead well, LBWC 1 as lag well and R1 as extraction well for LBWC system.65 ib 4.3.2 42 Change title to: Targeted Pumping ‐ LBWC Demands with Replacement Well (R1)66 ib 4.3.2 42 1st ppgh, 4th line: change to: "… the new replacement well (R1), the well…"67 ib 4.3.2 42 At end of 5th line add a return to start new ppgh, beginning with The TKWC wells…68 ib 4.3.2 42 New infrastructure includes: •A 200 gpm replacement well (R1) •Drinking water treatment faciliƟes for the removal of iron, manganese and PCE from groundwater to meet drinking water standards. •District sewer connecƟon for pump to waste; and •LBWC water connecƟon for water distribuƟon through LBWC water system.Changes in operations and maintenance includes: •LBWC 1: reduced pumping •LBWC 5: Increased monitoring and GAC media replacement •R1: Increased monitoring, operaƟons and maintenance of new water treatment faciliƟes •Costs related to discharging to District sewer and disposal of treatment residualsPermits and agreements needed to implement and operate this Alternative include: •Drinking water permit for R1 and treatment facility •Approval of R1 for drinking water use may require 97‐005 documentaƟon (see SecƟon 4.1.2.2) •District sewer discharge permit • Required environmental permiƫng and documentaƟon related to LBWC 4 site •Temporary permiƫng related to construcƟon69 ib 5.1.1 44 Search document to find LBWC 4R and replace with R170 ib 5.1.1 44 1st ppgh, line 6: "…can be used to compare the effectiveness of each alternative."71 ib 5.1.3 45 1st ppgh; 1st line add: Addresses the period of time needed to complete the remedy, and any adverse impact on human health and the environment that may be posed during the construction and implementation period, until the cleanup standards are achieved.\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 6 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit72 ib 5.1.3 45 2nd ppgh, 2nd line; add after end of 1st sentence. Use of existing sites also reduces the potential of adverse impacts to the environment posed during the construction and implementation periods.73 ib 5.1.4 45 1st ppgh; 1st line add: Refers to the ability of a remedy to maintain reliable protection of human health and the environment over time, once cleanup goals have been met.74 ib 5.1.4 45 1st ppgh, line 4; change to : "….to provide sufficient high‐quality water supply to meet existing demand, including provision new drinking water to replace lost water production from destruction of an impaired well (LBWC4) .75 ib 5.1.5 45 1st ppgh; 1st line add: Addresses whether or not a remedy provides adequate protection and describes how risks posed through each pathway are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.76 ib 5.1.6 45 Add all abbreviated items in permitting agency list to Glossary, as needed.77 ib 5.1.6 45 Add (EDC)78 ib 5.1.6 45 Add (CSLT))79 ib 5.1.6 45 4th Bullit; change to: South Tahoe Public Utility District (District)80 ib 5.1.6 45 5th Bullit; change to: SWRCB ‐ DDW81 Jenn Lukins 3.1.2 Lukins Brothers Water Company45 Change 1st paragraph to: "LBWC currently produces water from one well (LBWC 1) and supplements its demand by purchasing water from the District through interties to meet their demands, because PCE was detected in four LBWC wells that have since been removed from service. One of those wells, LBWC 5, will soon be brought back into active service at a lower pumping rate once GAC treatment facilities have been installed. Table 3‐2 summarized the LBWC groundwater sources."82 Jenn Lukins Table 3‐2 Summary of Sources45 LBWC 1 was originally drilled in 1963; LBWC 5 was originally drilled in 1983; LBWC 5 capacity will be 750gpm83 ib 5.1.6 46 10th Bullit: add (DTSC) 84 ib 5.2 46 1st ppgh; 1st line add: Refers to the technical and administrative feasibility of a remedy, including the availability of materials and services needed to carry out a particular option.85 Jenn Lukins 3.2 Water Distribution System Infrastructure46 Delete: "The distribution system is undersized and does not meet fire flow standards. Lukins is in the process of rehabilitating the distribution system to meet current standards for fire protection and the needs of its customers." (Not applicable to this report)86 ib 5.2.2 47 Change to last line of final bullit: "…. largest demand for treated water would be for Single Family, Multi‐Family and Commercial uses.87 ib 5.3 47 1st ppgh, line 1; change to: To evaluate the potential environmental effects…\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 7 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit88 ib 5.3 47 Change 1st ppgh to read: To evaluate the potential environmental challenges effects to implementation of the Alternatives, the California Environmental Quality Act (CEQA) Initial Study Checklist and the Tahoe Regional Planning Agency (TRPA) Initial Environmental Checklist (IEC) were completed for each of the three Refined Alternatives. The preferred alternative considers activities that result in less than significant environmental effects and require minimal mitigation measures, which will also reduce costs of implementing mitigation. The results of both checklists helped to identify mitigation measures and potential costs of implementing mitigation. The preliminary checklists for each Alternative are provided in Appendix C.89 ib 5.3 47 1st Bullit, 3rd line, delete "…for this project"90 Jenn Lukins 3.2 Water Distribution System Infrastructure47 Change "The interties mutually benefit LBWC and STPUD . . " to : "The interties mutually benefit LBWC and STPUD during periods of extended service disruption or emergencies, and have been essential to LBWC's continued ability to provide sufficient water supply to its customers after LBWC 2 and LBWC 5 were placed on standby status in July 2014 due to PCE contamination."91 ib 5.4 48 1st ppgh, 6th line; state engineering cost index used by KJ as basis for costs.92 ib Section 6501st ppgh, second bullit: cvhange to: • Alternative 2: Targeted pumping – LBWC Demands with Replacement Well (R1)93 Jenn Lukins 4.1.2.1 PCE Treatment Methods/GAC50 Change "TKWC 2 is equipped with …" to: "TKWC 2 GAC Treatment facility consists of two vessels operating in lead/lag configuration. LBWC 5's future GAC Treatment facility also will consist of two vessels operating in lead/lag."94 ib 6.2 52 Change title to: 6.2 Alternative 2 ‐ Targeted Pumping – LBWC Demands with Repalcement Well (R1)95 ib 6.2.1.1 52 Change to: This Alternative increases pumping through LBWC 5 and construction of a new replacement well (R1) to provide new water production lost to the impairment and destruction of LBWC4. Water treatment for the removal of iron/manganese and PCE from groundwater is proposed at R1 to satisfy drinking water treatment requirements. Water treatment for the removal of PCE from groundwater at well LBWC5 is planned for construction starting in 2020 with operations planned to begin in 2021. Well LBWC 5 is planned to be operated as the lead well for the LBWC water system and LBWC 1 will operate as a lag well to meet water LBWC water system demands. R1 would be operated at 200 gpm for additional PCE removal and as an alternative water source for use by the water purveyors. The TKWC wells will would operate similar to the No Action Alternative. Based on the results of the South Y Fate and Transport Model, the anticipated mass of PCE removed over a period of 20 years ranges from about 700 lbs to 3,500 lbs.96 DFA Section 4.1.4 – In‐Situ Remediation52 The last sentence should read (see bolded word and insert) as follows: “Based on discussion with the TAC, in‐situ remediation was removed from further consideration as an activity that the water purveyors were not willing to pursue.” 97 ib 6.2.1.3 53 Change 1st sentence to: Alternative 2 consists of the use of existing treatment and wells to remove PCE and also requires a new well to be drilled and equipped with treatment to replace lost water production from the impairment and destruction of Well LBWC4. \\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 8 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit98 ib 6.2.1.3 53 change 2nd sentence to read: Activities proposed to design this Alternative includes…99 ib 6.2.1.4 53 1st ppgh, change to read: R1 replaces lost water production due to the impairment and destruction of Well LBWC4. Table 6‐4 presents the assumed flow rates for Alternative 2, which switches the average flow rates for each well from 2009 – 2018 for the lead wells to the wells with GAC treatment and adds new water production from R1. Over a period of 20 years, it is estimated that LBWC4R R1 will produce about 3,000 MG additional potable water to supplement the 4,000 MG that will be produced through the existing water purveyor wells for a total of about 7,000 MG of potable water.100 ib 6.2.1.4 53 2nd ppgh, change to read: This Alternative has the potential to increases the available water supply by over four times over the 20‐year timeframe as compared to the No Action Alternative. The addition of R1 equipped to provide treatment for potable water increases the available water supply and thus the reliability of the South Y water supply through intertie connections between water distribution systems. This would also ease reliance on the District’ water system for emergency water supply to LBWC in accordance with existing mutual aid and assistance agreements.101 ib 6.2.1.5 53 1st sentence; change to "…treatment to a new replacement well …"102 ib 6.2.1.5 53 2nd line; change to: "…requires a new replacement well…"103 ib 6.2.2.1 54 Delete last sentence of ppgh.104 ib 6.2.2.2 54 Change 1st ppgh: Based on the South Y Fate and Transport Model, this Alternative can produce an additional 7,000 MG throughmR1 in 20 years compared to Alternative 1. This Alternative would also generate additional treatment residuals from R1 water treatment (iron/manganese; PCE).105 ib 6.2.3 54 1st ppgh, cahnge to read: Alternative 2 consists of drilling a new replacement well and installing groundwater treatment facilities at 843 Hazel Drive. This property is a 1‐acre parcel owned by LBWC which was formerly used as the LBWC 4 well site. Operations changes consist of increasing groundwater production at LBWC 5 and adding new groundwater production at R1, which..."106 Jenn Lukins 4.1.4 In‐Situ Remediation 54 Change "Based on discussions with the TAC . . . " to read simply "Based on discussions with the TAC, in‐situ remediation was removed from further consideration as a viable alternative."107 SR 4.2.1.3 57 Typo in second bullet point108 SR 4.2.1.4 57 Same typo in second bullet point109 SR 4.2.1.4.1 58 Same typo in second bullet point110 Jenn Lukins 4.3.2 Targeted Pumping 59 Change "LBWC 4R" to "R1." Also delete reference in third bullet point to "LBWC water distribution connection for LBWC 4R treatment facility."111 DFA Section 4.3.2 – Targeted Pumping – Lukins Brothers Water Company Demands with Extraction Well59 Please confirm whether monitoring wells will be included in the bulleted list of new infrastructure. If not, it would be helpful to identify the existing monitoring wells that will be used to evaluate the effectiveness of the interim remedial alternative (i.e., the monitoring wells that were installed as part of the pre‐design investigation).112 Jenn Lukins 5.1.4 Long Term Effectiveness62 Changes: …in order to continue providing safe, reliable drinking water that meets all drinking water standards to their customers…\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 9 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit113 Jenn LUkins Section 667Rename Alternative 2 as follows: "Alternative 2: Targeted Pumping." Do not include any reference to the extraction well being associated with LBWC.114 Jenn Lukins 6.2.1.1 PCE Mass Removal 69 Change: …"through LBWC 5 and replacement well LBWC 4…" TO: through LBWC 5 and remediation well R1…115 DFA Section 6.1.4 – Cost 69 Please add a cost table for existing operation and maintenance costs for the No Action alternative for comparison to the preliminary cost estimates for interim remedial alternatives 2 and 3.116 Jenn Lukins 8 Development of Recommended Alternative86 P2: Change…" LBWC 4 would be replaced with LBWC 4.." TO: "LBWC 4 would be destroyed and Remediation well R1 would be drilled."117 Jenn Lukins 8 Development of Recommended Alternative86 P3: Change "…The replacement LBWC 4…." TO: "Remediation R1 well…"118 Jenn Lukins 8 Development of Recommended Alternative86 Delete paragraph beginning "Purchase water agreements between water purveyors . . ." Because the R1 well should be operated and maintained by the LTLW RPs and/or LRWQCB any purchase water agreements would not be between the PWS group. 119 SR 8.1 87 Is there missing text on this page?120 Jenn Lukins 8.3.1 Potential Sources of Financing95 Bullet 1: Further note that the California Public Utilities Commission will not allow LBWC to charge its customers for remediation activities, as it is not a expense necessary to provide customers with service. Again, the entirety of Section 8.3 must be deleted.121 Jenn Lukins 8.3.2 Potential Funding Approach96 Item No. 3. Note that LBWC did not apply for Prop 68 funding because LBWC cannot feasibly afford a 20‐year term requirement. 122 DFA Section 8.3.2 – Potential Funding Approach96 It should be noted that Lukins Brothers Water Company has not applied for Proposition 68 Groundwater and Remediation grant funding at this time. 123 SR References 97 F&T model reports are missing from the references124 Jenn Lukins Summary of Detailed Analysis of Refined Alternatives14‐15 Rename "LBWC 4R" as "R1" and otherwise ensure that the chart complies with the comment above relating to the fact that LBWC will not construct or operate R1.125 Jenn Lukins Figures ES‐2 and ES‐316‐17 Rename "LBWC 4R" as "R1"126 SR Section 2.5/Figures 2‐2 & 2‐3 35/39 I don't think Zones B and C are ever defined ‐ are they the monitoring well depth zones? Zone C is referred to as Zone Cu in a couple of places, not sure if this is a typo or a separate zone. Also, I think the opposing flow directions plotted in figures 2‐2 and 2‐3 could be an artifact of the positioning of the small number of closely located monitoring wells used to generate the contours.127 Jenn Lukins 2.5 Summary of Current Conditions and Trends35‐36 Delete: "The extent of PCE contamination from this site has not been fully defined; therefore, LRWQCB is requiring further off‐site investigation (LRWQCB, 2017) as well as conducting the Regional Plume Characterization."128 DFA Section 3.1 – Existing Extraction and Treatment Facilities (all tables)43, 45, 46 For all tables in this section, Table 3‐1, 3‐2, and 3‐3, please add a column for the current operational pumping rate for each supply well that is currently online.\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 10 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit129 Jenn Lukins 6.2 Alternative 2‐ Targeted Pumping‐ LBWC Demands with Extraction Well69‐74 Change title of 6.2 to just "Alternative 2: Targeted Pumping" Do not include any reference to the extraction well being associated with LBWC.Throughout Section 6.2 present this alternative without in any way suggesting that the construction, operation, ownership or responsibiltiy of the extraction well will fall on LBWC. This project should be the responsibiltiy of the LTLW RPs and/or the LRWQCB and not the responsibility of LBWC or any other PWS.Change all references from "LBWC 4R" to "R1." Create new column in tables for R1 and ensure that it is not in LBWC's column.130 Jenn Lukins Section 781‐85 Change all references from "LBWC 4R" to "R1." Analyze the alternatives without in any way suggesting that the construction, operation, ownership or responsibiltiy of the extraction well R1 will fall on LBWC. This project should be the responsibiltiy of the LTLW RPs and/or the LRWQCB and not the responsibility of LBWC or any other PWS.131 Jenn Lukins Section 886‐96 Change all references from "LBWC 4R" to "R1." Recommend alternative 2 without in any way suggesting that the construction, operation, ownership or responsibiltiy of the extraction well R1 will fall on LBWC. This project should be the responsibiltiy of the LTLW RPs and/or the LRWQCB and not the responsibility of LBWC or any other PWS.132 Jenn Lukins 8.3 Financial Plan 93‐96 This section is completely inaccurate and inappropriate and should be deleted in its entirety. LBWC has not and will not agree to be the lead agency with regard to funding for Alternative 2. LBWC cannot and will not burden its ratepayers with carrying the full costs to remediate PCE contamination caused by others. LBWC serves a disadvantaged community and is in the worst financial position among the PWS group to afford to remediate the plume. If this Section 8.3 is not removed LBWC cannot continue to be a member of the TAC because the Feasibility Study will be placing the entire financial burden of remediating a regional PCE problem on LBWC.133 Jenn Lukins Entire Document Entire DocumentChange reference of "LBWC 4R" TO "R1" (Remediation 1) throughout entire document and remove any language that implies that LBWC will have any association with constructing or operating the new R1 well. The construction and operation of R1 should be solely the responsibility of the LTLW RPs and/or the LRWQCB.134 Jenn Lukins Entire Document Entire DocumentChange references of LBWC Well 2 and LBWC Well 5 to LBWC 2 and LBWC 5 throughout document for consistency 135 ib Summary of of South Y PCE ES‐12nd ppgh, line 6: add space at start of last sentence: "….operation). A more…"136 ib Alternatives Development ES‐III 2nd ppgh, line 1: change to: "Following fate and transport modeling evaluation by…" 137 ib Recommended Alternative ES‐IV 2nd ppgh, line 3: search entire document to find LBWC 4R and replace with R1.138 ib Recommended Alternative ES‐IV 3rd ppgh, last sentence: change to "...maintained to meet TKWC system water demands."139 ib Recommended Alternative ES‐IV 4th ppgh, last sentence: Table ES 1 shows 3 to 7 years to implement. Which is it? Conform text to table or table to text, as needed.\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020
Draft Feasibility Study 27 Feb 2020Comments Received as of 5 March 2020Page 11 of 11Comment # Comment By Section#/Table# /Figure #PDF Page # Comment/Suggested Edit140 ib Recommended Alternative ES‐IV 4th ppgh; add last sentence indicating the estimated quantity of PCE mass removed by this Alternative, such as; The greatest total mass of PCE is believed to be removed through implementation of this Alternative. Modeling evaluation completed by DRI suggests about 700 to 3,500 pounds (lbs) of PCE could be removed from groundwater using this Alternative.141 DFA General Comment N/A Project Objective: The stated objective in the FS Report is to identify the most cost‐effective alternatives to remove PCE from groundwater and manage existing groundwater sources to maintain adequate drinking water supply and quantity. The objectives should also describe that the FS evaluates alternatives that will prevent further migration of contaminants and potential future impacts to downgradient water supply wells.142 DFA General Comment N/A Various terms are used throughout the document when referring to the alternatives (i.e., interim remedial alternatives, implementation alternatives, alternatives, remedies). Please revise the document to include consistent terminology that describes the remedial alternatives that were evaluated in this document.143 DFA General Comment N/A Please revise the document to indicate that the destruction of Lukins Brothers Water Company Well Number 4 (LBWC‐4) is being conducted under the Site Cleanup Subaccount Program (SCAP) and that the investigation performed has not been completed and is a separate activity from this FS.144 DFA General Comment N/A Please clarify that the funding for Lukins Brothers Water Company Well Number 5 (LBWC‐5) was funded by the State Revolving Fund Program and was not funded through the Proposition 1 Groundwater Grant Program. 145 DFA General Comment N/A Verify and revise text for missing figure call outs throughout the document (i.e., Figure 2‐1 is not referenced in the text).146 DFA General Comment N/A Check the Glossary for acronyms that are not called out on first time use in the document or acronyms that are used in the document but not defined in the Glossary.147 ib ES 1v, vi Recommended Alternative 4th ppgh, last sentence states 3 to 5 years : Table ES 1 shows 3 to 7 years to implement. Which is it? Conform text to table or table to text, as needed.148 ib ES 1v, vi Search table to find LBWC 4R and replace with R1.149 ib Glossary vii Add: O&M Operations & Maintenance150 ib Glossary vii Add: R1 Replacement Well (843 Hazel Drive)151 ib Document Universal find and replace LBWC 4r with R1\\Sac2\job\2017\1770027.00_South Tahoe PUD‐South Y Feasiblity Study\09‐Reports\9.09‐Reports\Task M.1‐M.10 Feasibility Study _(formerly Task D)\FS_Report\Comments\Mar_2020_FS_comments\CommentLog_compiled.xlsx3/5/2020