HomeMy WebLinkAboutC29670 - CVWD Nonpotable Water Agmt CITY OF PALM DESERT
STAFF REPORT
REQUEST: APPROVE THE NON-POTABLE WATER AGREEMENT
(BETWEEN THE COACHELLA VALLEY WATER DISTRICT AND
THE CITY OF PALM DESERT); AND AUTHORIZE THE CITY
MANAGER TO FINALIZE AND EXECUTE THE CONTRACT
SUBMITTED BY: Catherine Walker, Senior Management Analyst
DATE: April 8, 2010
CONTENTS: 1. New Non-Potable Water Agreement
2. Title 22 Code of Regulations
3. Water Code
4. General Waste Discharge Requirements for Discharge of
Recycled Water for Golf Course and Landscape Irrigation
Recommendation
By Minute Motion:
1. Approve Contract No.c296�o substantially to form; and
2. Authorize the City Manager to finalize and execute the Non-Potable
Water Agreement ("Agreement") between the City of Palm Desert and the
Coachella Valley Water District (CVWD) for water services at the Desert
Willow Golf Resort.
Backqround
On September 12, 1996, the Agency entered into an agreement with the CVWD to
utilize recycled water for irrigation of the Desert Willow golf courses. The Recycled
Water Use Agreement ("Original Agreement") provided for the construction of an
Effluent Delivery System and obligated the Agency to utilize effluent water at a flow rate
of 300 acre feet per year, per golf course or 50 percent of the total water use for golf
course irrigation. The term of the agreement was for a period of fifteen years. Under the
terms of the Original Agreement if the Agency did not meet its water usage obligation,
the Agency would pay the difference as established in Article 9 of the Agreement.
The term of the Original Agreement has expired and the Coachella Valley Water District
has proposed new parameters for water usage. Under the new terms of the five-year
Contract N0. C29670
Staff Report
CVWD Agreement
April 8, 2010
Page 2 of 2
Agreement, the City (current Owner) would be obligated to utilize non-potable water for
80 percent of the total water usage at both Desert Willow golf courses. This Agreement
is standard and the formula for the Non-potable Water Charge, set forth in section 8,
has also been streamlined for all customers. The City's 80 percent usage obligation has
been discounted to be 5 percent less than other non-potable water customers. Desert
Willow staff has confirmed that the 80% usage goal is obtainable based on current
water usage and its ease of use will be improved by the recent upgrades to the water
filtration system. In August 2009, the City Council approved the implementation of new
water filtration systems at each pump station. These new systems will allow for a more
efficient filtration of the non-potable water source, and provides further protection of the
entire irrigation system at the Desert Willow Golf Resort.
The City Attorney has reviewed and approved the attached Agreement. Staff
recommends approval of the Agreement in substantial form, and authorization of the
City Manager to finalize and execute the Agreement.
Fiscal Analvsis
Water rates for the non-potable water remain the same. The fiscal impact to the City at
this time is the cost of the non-potable water for the Desert Willow Golf Resort if 80
percent non-potable water usage is not achieved. With the recent filtration system
upgrades, utilizing 80 percent non-potable water for the golf course can be achieved.
Submitted By:
Catherine Walker, Sr. Management Analyst artin Alvarez, Re evelopment Manager
Department Head:
CtTY COUNC7LACTION
' � APPROVED `'� DF,NiF.b
RECENED OTHER
J in cCarthy, ACM for d velopment
MEETI G DA'T,� ` �
. .
' �'' AYES: ! ��
NOES:
Paul S. Gibson, Finance Director AI3SENT:
ABSTAIN:
Approval: VERtFIED BY: �
Original on File with City erk'a Office
M. Wohlmuth, City Manager
G:\rda\Cathy Walker\Word Data\STAFF REPORTS\StaffforCVWD.doc
No Recording fee
Required Per
Government Code
Section 27383
RECORDING REQUESTED BY AND
WHEN RECORDED RETURNED TO:
COACHELLA VALLEY WATER DISTRICT
Post Office Box 1058
Coachella, California 92236
(Space above this line for Recorder's Use)
File: 0655.
0710.1017
NONPOTABLE WATER AGREEMENT
THIS AGREEMENT is made this day of , 2010, between
the COACHELLA VALLEY WATER DISTRICT, a public agency of the State of California
(hereinafter denoted "District") and City of Palm Desert, a public agency of the State of
California(hereinafter denoted"Customer") located at 73-510 Fred Waring Drive, Palm Desert,
California 92260, for nonpotable water irrigation at Desert Willow Golf Courses located within a
portion of Section 4, Township 5 South, Range 6 East, San Bernardino Meridian.
RECITALS
A. The Coachella Valley's aquifer is in a state of overdraft.
B. It is in the best interest of the District and Customer to protect the aquifer in order to
ensure the long term economic health of the region. One way to protect the aquifer is to promote
the use of nonpotable water sources such as recycled water and/or raw imported water in place of
groundwater.
C. District owns and operates three Water Reclamation Plants ("Plant"), capable of
producing and providing recycled water to customers. In addition, the District operates the
Coachella Canal and the Mid-Valley Pipeline both of which serve imported water. Recycled
water and imported water both may be beneficially used for golf course and/or landscape
irrigation in place of groundwater with certain exceptions.
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D. California Water Code Section 32600-32603 requires the use of nonpotable water
source(s), including recycled water, for irrigation when a suitable nonpotable water source is
available and it is of suitable quality, available at a reasonable cost, and meets all conditions of
these sections and other applicable laws.
E. Customer desires to use such nonpotable water provided by the District for golf
course and landscape irrigation. Irrigation water shall be from the following sources in the
indicated order of priority and up to the available amounts of each: 1) recycled water; 2)
imported water; and 3) groundwater,to the extent available and subject to the terms of this
Agreement.
F. The Parties understand and agree that nonpotable water is an interruptible water
supply.
NOW, THEREFORE, THE PARTIES AGREE AS FOLLOWS:
l. DEFINITIONS
a. Groundwater—Water produced through wells from any aquifer underlying
the Coachella Valley.
b. Nonpotable Water—Recycled water produced by District's water
reclamation plants and/or raw imported water delivered by the District's Coachella Canal.
c. Nonpotable Water Charge ("NPWC")—The District's price for
nonpotable water delivered determined by the formula set forth in Paragraph 8-B herein.
d. Point of Connection—The point of delivery of nonpotable water from
District's facilities to Customer's facilities.
e. Pumping Costs ("PC")—The pumping cost is the cost of electrical energy
required to pump an acre foot of water through a well. For purposes of establishing the PC,
Customer will provide pump test data, including a cost analysis for the wells that are Customer's
alternate water supply for irrigation. If Customer has more than one well to use as the
groundwater supply source, the pumping cost will be prorated based on well capacity and the
average cost to pump an acre foot of water.
£ Replenishment Assessment Charge ("RAC")—The District has a RAC
for groundwater production in each of three separate areas of benefit within the District's service
area, an "area of benefit" being that geographic area benefited by recharge of the groundwater,
primarily with imported water. The RAC is a fee charged to producers pumping more than
twenty five (25) acre feet annually to raise funds to purchase replacement water supplies to
recharge the aquifer or to fund other projects that enhance groundwater supplies. The RAC is
adjusted annually by the District by Ordinance adopted by the District's Board. The annual
adjustment of the RAC will be reflected in the NPWC, as described in Paragraph 8-D below.
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2. FACILITIES
The District and Customer hereby agree that the Point of Connection (POC) for
this agreement is described as follows:
1. District has constructed, owns, operates, maintains and repairs manifold, valve,
meter, and all electrical appurtenances in the vault and telemetry including
radio, RTU, PLC, bladder level and pressure sensors, flow meter and remote
read display. Point of connection is at the meter.
2. Customer has constructed, owns, operates, maintains and repairs all pipelines,
valves, and impoundment located from the POC and throughout the irrigation
system.
3. SOURCES OF IRRIGATION WATER
Customer understands that District's nonpotable water supply is subject to
interruption and that at times Customer may be required to meet its irrigation demands with
groundwater, either solely or in conjunction with the District's available supply of nonpotable
water. For that reason, Customer shall have a backup supply available (groundwater) equal to
One Hundred Percent(100%) of its peak irrigation water demands, and Customer's irrigation
system shall be capable of operating in tandem with the District's facilities in arder to augment
District deliveries as and when required.
Nonpotable water shall be the Customer's primary source of irrigation water and
shall be used to the maximum extent practical, subject, however, to the requirement that in the
irrigation of golf courses and related landscaping, at least Eighty Percent(80%) of said irrigation
shall be with nonpotable water. See Paragraph 8-E below regarding a surcharge for
noncompliance with this requirement.
Groundwater shall be the secondary source of irrigation water and, except as
noted in the next paragraph, shall be used only to the extent required to meet Customer's
irrigation water demands that are not met by District's nonpotable water.
The foregoing notwithstanding, Customer may use groundwater rather than
nonpotable water in the following situations:
a. Specialized irrigation where the use of groundwater is deemed necessary
by the professional landscape community such as golf greens or plants or planting material
having special needs;
b. Lake or water feature "makeup"water;
c. Periodic irrigation system and lake or water feature maintenance
(purging);
d. Public road medians;
e. Indoor uses;
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f. Food service area perimeters.
4. WATER QUALITY, REGULATORY APPROVALS, VIOLATIONS
a. District's Nonpotable Water
Nonpotable water source(s) shall be of a suitable quality for the irrigation
of landscaping, and the recycled water component shall meet the requirements of Section
60301.230 of Title 22 of the California Code of Regulations, including any amendments thereof,
subject to availability as enumerated in Paragraph 5 below.
b. Regulatory Compliance
In connection with the use of nonpotable water by Customer, Customer
shall obtain all necessary authorizations or approvals from regulatory agencies having
jurisdiction and shall at all times comply with the provisions of its waste discharge permit or a
general permit issued by the California Regional Water Quality Control Board, Colorado River
Basin Section, General Order No. 97-700 (Exhibit"A"). In reference to this subparagraph,
District agrees to cooperate and make a good-faith effort to assist Customer in obtaining all
necessary authorizations or approvals from regulatory agencies having jurisdiction over the use
of such nonpotable water and to conform to all such regulatory requirements.
c. Reporting Violations
Customer agrees to notify the District and the California Regional Water
Quality Control Board, Colorado River Basin Section, of any non-compliance with its California
Regional Water Quality Control Board, Colarado River Basin Section, General Order No. 97-
700 within 24 hours of becoming aware of the failure. Customer also agrees to notify District
prior to making any modifications that would result in a material change in the quality or
quantity of nonpotable water discharged, or any material change in the location of discharge.
5. SCHEDULING
a. District Interruptions
The District shall use its best effort to complete delivery of the nonpotable
water source(s) as soon as possible, subject, however, to nonpotable water availability. The
District may cause interruptions of nonpotable water service due to scheduled maintenance,
equipment malfunctions, and natural disasters creating an emergency condition. District shall
give Customer 48 hours' notice of any scheduled maintenance which would interfere or interrupt
nonpotable water delivery to Customer. District shall make every reasonable attempt to
minimize any interruption relating to maintenance and shall, at all times, make a good-faith
effort to facilitate the delivery of nonpotable water to Customer.
b. Customer Interruptions
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If Customer plans to interrupt delivery of nonpotable water from the
District for a period longer than 48 hours, Customer and the District shall agree on a schedule for
restoration of deliveries, and Customer shall provide the District with notice in writing for each
additional day that nonpotable water delivery will be interrupted. Customer shall further make
every reasonable effort to minimize any interruption relating to maintenance and shall, at all
times, make a good faith effort to facilitate the acceptance of nonpotable water from the District.
6. DELIVERY PRESSURE
The nonpotable water delivery by the District shall be delivered within the range
of zero to 150 pounds per square inch (psi). The District will not be responsible or obligated to
provide the pressurization of the irrigation system beyond the point of connection.
7. MANAGEMENT, INDEMNIFICATIONS
Customer agrees to accept full and exclusive responsibility for the management
and use of all nonpotable water delivered by the District from and after the point of connection
and except for the negligence of District, defend and hold the District free and harmless from any
responsibility for any type of damage to the real or personal property of Customer and the claims
of any third party which may result directly or indirectly from management and use of such
nonpotable water by Customer from said point of connection. Failure of electrical, electronic ar
mechanical equipment shall not be construed as negligence or misconduct of the District.
District agrees to accept full and exclusive responsibility for the management and
delivery of the nonpotable water served by the District to and including the point of connection
and except for claims and damage related to negligence on the part of Customer, defend and hold
Customer harmless from claims related to said management and delivery of the nonpotable
water.
8. WATER CHARGES
a. Invoices
The District will invoice Customer monthly for the use of nonpotable
water. The amount of the invoice will be the product of the NPWC multiplied by the volume of
nonpotable water delivered to the point of connection during the billing period plus any
conservation charge (see Subparagraph"e" below). Nonpotable water will be measured in or
converted to acre feet for invoicing. Payment shall be due within thirty (30) days of presentation
of the bill. If not paid, the District shall provide a written Notice of Default to Customer before
taking further action.
b. Charges
The NPWC is intended to be set at approximately 85% of the reasonable
estimated cost of the pumping groundwater. It is understood that there may be incidental costs
associated with using nonpotable water for irrigation and the discount between 100% and 85% of
the cost of a groundwater supply can be used to offset these costs. The NPWC is derived as
follows;
5
. NPWC = .85 (RAC +PC)
Where:
RAC = Replenishment Assessment Charge, see Definitions, Paragraph 1 above
PC = Pumping Cost, see Definitions, Paragraph 1 above
c. PC Adjustments �
The PC will be adjusted annually to account for changes in electrical costs
and pumping plant efficiencies. Customer must provide new pump test data including a
pumping cost analysis that shows the average cost per acre foot for the wells used by Customer
as its alternate water supply. It will be the responsibility of Customer to provide an updated
analysis each year prior to May 31 so that the updated NPWC can be calculated. If Customer
fails to provide an updated pumping cost analysis, the PC will be increased 15% over the prior
year's cost.
d. NPWC Adjustments
The NPWC will be adjusted July 1 of each year. The District will notify
Customer by letter dated on or before June 15 of each year of the NPWC to be used for the
twelve-month period beginning on July 1. The updated NPWC will use the updated RAC plus
the updated PC as described in Subparagraphs 1-f and 8-c above.
e. Conservation Charge
There will be a Conservation Charge invoiced to Customer for any year
wherein the gross annual water use for golf course and landscape irrigation does not equal or
exceed 80%nonpotable water. This Conservation Charge revenue will be used by the District to
fund conservation programs designed to protect the aquifer, in keeping with the intent of this
agreement. The District will determine the total number of acre feet used below 80% by
Customer in the fiscal year. The fiscal year shall be from July 1 to June 30. On the monthly
invoice described in Subparagraph 8-a, the District will provide an update on Customer's
performance in meeting this 80% requirement. The Conservation Charge will be calculated by
multiplying the number of acre feet below 80% by one-half of the NPWC. An invoice will be
sent to Customer within thirty (30) days of the end of any fiscal year where Customer used less
than 80%nonpotable water.
9. TERM
The Term of this Agreement shall be for a period of five (5) years from its
execution by the parties. The parties may extend or renew the Term on existing or modified
terms and conditions as they can agree upon regarding any further renewal of the Agreement. At
the end of any Term provided herein or any extension thereof, District shall not sell the
nonpotable water provided to Customer in the Agreement to any other customer without first
offering to sell the nonpotable water to Customer(the "offer") on the same terms and conditions
proposed for the sale of the nonpotable water to said third party. Customer shall have thirty (30)
days from its receipt of the offer in which to accept or reject the offer. The offer shall expire at
5:00 p.m. on the last day of the offer period unless before that time, Customer has given written
6
notice of acceptance of the offer. The offer shall contain the name of the proposed purchaser of
the nonpotable water source(s), the proposed sales price, the terms of payment and other material
terms and condition in which the sale of the nonpotable water source(s) is to be consummated. If
Customer gives timely notice of the acceptance of the offer, then District shall be obligated to
sell, and Customer shall be obligated to purchase, the nonpotable water at the price and on the
terms and conditions of the offer. If Customer does not give timely notice of acceptance of the
offer, District may sell the nonpotable water to any third person on the same term and conditions
set forth in the offer.
10. DEFAULT
Failure on the part of District or Customer to meet any condition or requirement
of this Agreement, other than as a result of conditions beyond the control of District and/ar
Customer, shall constitute a default. The nondefaulting party shall provide the other party with
written notice of default before taking further action, and the other party shall have thirty (30)
days from the date of the notice of default to cure same. In the absence of cure, the
nondefaulting party may pursue all legal remedies available to it, including the termination of
nonpotable water sources and/or suit to collect any outstanding charges due.
11. TERMINATION
District shall have the right to terminate this agreement upon giving Customer one
hundred twenty (120) days written notice of termination and shall have the right to amend same
upon sixty(60) days written notice of the proposed amendment in which case Customer shall
have the right to terminate the agreement effective upon thirty (30) days notice thereof to the
District. In the event of termination, Customer shall be responsible for payment for deliveries of
nonpotable water to the date of termination.
In addition, The District may terminate delivery of nonpotable water in the event
of mandatory changes in the requirements of nonpotable water from regulatory agencies (other
than the District) having jurisdiction over nonpotable water and/or changes in its water quality
which would cause the District to expend funds for capital expenditures to such an extent that the
delivery of nonpotable water to Customer would no longer be economically feasible. Customer
hereby waives any claim that it may have against and will defend and indemnify District against
any claim by others for damage or economic loss resulting from the termination of nonpotable
water service for any reason. District shall give Customer a minimum of sixty(60) days notice
of its intent to permanently terminate nonpotable water service pursuant to this subparagraph.
12. CAPITAL COST AMORTIZATION
Not Applicable.
13. GENERAL PROVISIONS
a. Further Assurances. Each party shall execute, acknowledge and deliver
such other documents and instruments as are reasonably necessary to carry out the intent and
purposes of this Agreement.
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b. Counterparts. This Agreement may be executed in two or more
counterparts; each counterpart shall be deemed an original instrument as against the party who
signed it.
c. Binding on Successors. This Agreement is binding and shall inure to the
benefit of the parties hereto and to their respective successors, assigns and representatives.
d. Attorneys' Fees. In the event that any action, suit or other proceeding is
instituted to remedy, prevent or obtain relief from a breach of this Agreement, or arising out of a
breach of this Agreement, the prevailing party shall recover reasonable attorneys' fees incurred
in each and every such action, suit or other proceeding, including any and all appeals or
petitions.
e. No Assignment. The parties to this Agreement hereby warrant and
represent that the parties have not heretofore assigned or transferred, or purported to have
assigned or transferred to any person whomsoever, any matter, including claims, released or
covered by this Agreement or any part or portion thereof. Further, the parties hereto agree to
indemnify and holds harmless the parties hereto from any claims resulting from any person or
entity asserting any such claim pursuant to any such assignment or transfer by the indemnifying
party.
£ Governing Law. This Agreement shall in all respects be interpreted,
enforced and governed by the laws of the State of California. In the event that this Agreement
must be enforced by a court of law, the parties hereby agree that the said action shall be tried by
the Superior Court of Riverside County of the State of California, Desert Judicial District.
g. Power to Execute. The parties represent and warrant that they have
carefully read this Agreement and had the contents and legal effect hereof fully explained by
legal counsel of their choosing; that the parties have the sole and exclusive power and authority
to execute this Agreement and do so of their own free act.
h. Entire Agreement. This Agreement contains the entire agreement and
understanding concerning the subject matter hereof between the parties, and supersedes and
replaces all prior negotiations, proposed agreement and agreements, whether written or oral,
expressed or implied, of any type whatsoever. Each of the parties hereto acknowledges that
neither any other party hereto nor any agent or attorney or any other party whomsoever has made
any promise, representation or warranty whatever, expressed or implied, not contained herein
concerning the subject matter hereof to induce it to execute this Agreement, and acknowledges
and warrants that this Agreement is not being executed by such party in reliance on any promise,
representation or warranty not contained herein.
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PLEASE ATTACH APPROPRIATE
NOTARIAL CERTIFICATES
9
IN WITNESS WHEREOF,the parties hereto have executed this Agreement as of the dates
which appear below.
�
By: Dated:
COACHELLA VALLEY WATER DISTRICT
By: Dated:
Title:
CITY OF PALM DESERT
10
California Department of Public Health
Regulations Related to Recycled Water
January 2009
TITLE 22 CODE OF REGULATIONS
Division 4. Environmental Health
Chapter 3. Water Recycling Criteria
Article 1. Definifions.
§60301.230. Disinfected tertiary recycled water.
"Disinfected tertiary recycled water" means a filtered and subsequently disinfected
wastewater that meets the following criteria:
(a) The filtered wastewater has been disinfected by either:
(1) A chlorine disinfection process following filtration that provides a CT
(the product of total chlorine residual and modal contact time measured at
the same point) value of not less than 450 milligram-minutes per liter at all
times with a modal contact time of at least 90 minutes, based on peak dry
weather design flow; or
(2) A disinfection process that, when combined with the filtration process,
has been demonstrated to inactivate and/or remove 99.999 percent of the
plaqueforming units of F-specific bacteriophage MS2, or polio virus in the
wastewater. A virus that is at least as resistant to disinfection as polio
virus may be used for purposes of the demonstration.
(b) The median concentration of total coliform bacteria measured in the
disinfected effluent does not exceed an MPN of 2.2 per 100 milliliters utilizing the
bacteriological results of the last seven days for which analyses have been
completed and the number of total coliform bacteria does not exceed an MPN of
23 per 100 milliliters in more than one sample in any 30 day period. No sample
shall exceed an MPN of 240 total coliform bacteria per 100 milliliters.
http://www.cdph.ca.gov/certlic/drinkingwater/Documents/Lawbook/RWregulations-01-2009.pdf
CALIFORNIA CODES
WATER CODE
SECTION 32600-32603
32600. �nless the context otherwise requires, the definitions set
forth in this section govern the construction of this part.
(a) "Board" means the Board of Directors of the Coachella Valley
Water District.
(b) "District" means the Coachella Valley Water District.
(c) "New industrial facilities" means industrial facilities for
which either of the following applies:
(1) The building permit for that facility is issued on or after
January 1, 2010.
(2) If a building permit is not required for that facility,
construction for that facility commences on or after January 1, 2010.
32601. (a) The Legislature hereby finds and declares that the use
of potable domestic water for nonpotable uses for cemeteries, parks,
highway landscaped areas, new industrial facilities, and golf course
irrigation is a waste and an unreasonable use of the water within the
meaning of Section 2 of Article X of the California Constitution, if
nonpotable water, including recycled water, is available under all
of the following conditions as determined by the board, after notice
to any person or local public agency that may be ordered to use
nonpotable water or to cease using potable water and a hearing held
by the board if requested by the person or local public agency:
(1) The board determines that the source of nonpotable water is of
adequate quality for the proposed use and is available for that use.
In determining adequate quality, the board shall consider all
relevant factors, including, but not limited to, food and employee
safety, and level and types of specific constituents in the
nonpotable water affecting the use, on a user-by-user basis. In
addition, the board shall consider the effect of the use of
nonpotable water in lieu of potable water on the generation of
hazardous waste and on the quality of wastewater discharges subject
to permit.
(2) The board determines that the nonpotable water may be
furnished for the proposed use at a reasonable cost to the user. In
determining reasonable cost, the board shall consider all relevant
factors, including, but not limited to, the present and projected
costs of supplying, delivering, and treating potable domestic water
for the proposed use and the present and projected costs of supplying
and delivering nonpotable water for that use, and finds that the
cost of supplying the nonpotable water is comparable to, or less
than, the cost of supplying potable domestic water.
(3) The State Department of Public Health determines that the use
of nonpotable water from the proposed source will not be detrimental
to public health.
(4) The California regional water quality control board determines
that the use of nonpotable water from the proposed source will
comply with any applicable water quality control plan.
(5) The board determines that the use of nonpotable water for the
proposed use will not adversely affect groundwater rights, will not
degrade water quality, and is determined not to be injurious to plant
life, fish, and wildlife.
(b) In making the determination described in subdivision (a) , the
board shall consider the impact of the cost and quality of the
nonpotable water on each individual user.
(c) The board may require a person or public agency to furnish
information that the board determines to be relevant to making the
determinations described in subdivision (a) .
32602. Notwithstanding any other provision of law, but subject to
the other requirements of this part, no person or local public agency
shall use water within the district's service area from any source
that is suitable for potable domestic use for nonpotable uses for
cemeteries, parks, highway landscaped areas, new industrial
facilities, and golf course irrigation, if the board, in accordance
with Section 32601, determines that suitable nonpotable water is
available.
32603. (a) The use of nonpotable water, including recycled water,
in accordance with this part is subject to all applicable state
regulation.
(b) This part only applies to a use of water within the district's
service area that is not the subject of a determination pursuant to
Article 7 (commencing with Section 13550) of Chapter 7 of Division 7.
(c) This part is in addition to, and not a limitation upon, any
powers of a public agency or a court to prevent the waste or
unreasonable use of water.
http://www.leQinfo.ca.�ov/c�i-bin/wais�ate?WAISdocID=7931689293+0+0+0&WAISaction=retrieve
' � � � Fi1e: 0552.1135
. o�io.ioi� �ir�J
CA�IFORNIA REGIONAI WATER DUAtITY CONTROI BOARO
COLOfiADO RIVER BASIN REGION
OfiOER N0. 97•700
GENERAL WASTE OISCHARGE REOUfREMENTS
FOR
OISCHARGE OF RECYCLEO WATER
, FOR GOLF COUiiSE ANO lANOSCAPE IRRtGAT10N
The Califorrna Regional Water �uatity Control 8oard, Colorado River Basin fiegion, finds that:
1. Section 13260 (at of the Calitornia Water Code requires that any person discharging waste or
proposing to discharge waste within any region, other than to a community sewer system, that
could afiect the quality of waters of the state, shall file a report of waste discharge (ROWO).
2. Section 13512 of the California Water Code states,it is the intantion of the Legislature that the
state undertake all pOssib�e steps t0 entourage development of recycled water tacilities, so
recycled water may be made available ta meet the growing water requirements of the state.
3. Th�s Order serve as a region-wide General Permit tor discharge ot tertiary treated municipal
wastewater thereinaftar recycled water) for use in golf course and landscape irrigation.
Adoption of this General Permit will streamline the pe�mitting proCess and should encourage
recyc�ed water usage.
4. Each discharger of recycled water covered by this General Order sha11 submit an annual fee, and
an application fee equal to the first annual fee, pursuant to Section 13260, Calitornia Wate�
Code. The amount of the fee is currently determined by the type of Order issued the threat te
water quality and the complexity oi the discharge as detailed in Section 2200, Chapter 9,
Oiv�sion 3, Title 23, Calitornia Code o(Regu�ations. RecyNed water use projects would generally
be rated as Non•Chapter 15 waste discharge requirements with a "I11" threat to water quality,
and a 'C" complexity rating. Individual ratings may diifer, based on the characteristics of the
project.
5. To obtain coverage under ihis General Order, a compiete Notice of Intent tN01{ IA[tachme�t "A'
incorporated herein and made a part ot this Qrder) must be submitted with an appropriate fee.
Users who submit e duly filted NOi, an appropriate filing fee, snd meet the requireme�ts of this
permit, wifl be con�itionalty authorized to use tertiary reclafined water for landscapi�g and golf
courss irrigstion. A separate NOI must be filed for esch facility.
6. The Regional 8oard may st its discretio� issue individusl waste discharge requirements, or
prohibit discharge of recycled water when such actians are deemed appropriate. Upon issuance
of ind'+vidual waste d'+scharge requirements or prohibition ordars, discharge of recycled water
under this General Order is not applicable.
7. This General Order is not applicabla to producers (or p�oducersldischargers) of secondary or
tertiary recycled wate�, who are currently required to obtain individual waste discharge
reQuirements tor d�schar9e of recycled water. This Genera� Order does not apply to persons
engaged solety in distr+bution of recycled water.
1
' 8. On February 20, 1996, a Memorandum ot Agreement IMOA) was executed between the
Cal�forn�a Department of Heatth Services IDHSI and tha State Water Resources Control Board
(SWRCBI, on behalt o} the SWRCB and the rnne Cal�forn�a Regional Water Quality Control 6oards
IRW�CBs1. The DHS �s the pnmary agency respons�ble for protection ol p�blic health and the
regulat�on ol drink�ng water. The SWRCB and RW�CBs are pnmary state agencies authorized
w�th the protection oi water quality and the assignment of water nghts �n the state. The MOA
is intended to assure that the authority o( these agencies is exercised in a coordinated manner.
9. For the protection of public heatth, the DHS has promu�9ated regulations related to usage oi
�ecycled water. These regulatians are outlined in Section 60301, Chapter 2, Division 4, Title 22;
and Group 4, Chapter 5, Oivision t, Title 17; Calitornia Code of Fiegulations, et. seq. (hereinafter
ONS regulationsl.
10. The Regional 8oard considers the OHS, or their duly appointed agent, to be responsible for
determining compliance with the DHS regulations, including, but not limited to, requirements
listed under the 'Health•Based Provisions' of this General Order.
1 1. Only facilities which fall in the following categories are eligible to discharge recycled water under
� this General 8oard Order:
a. �n accordance with Section t 5301, Chapter 3, Tit1e 14 of the Califarn�a Code of Regulations,
the issuance of these waste discharge requirements, which govern the operation of an
exist�ng' fecility involving negligible or no expansion of use beyond that previously existing,
is exempt irom the provisions of the California Environmentat Quality Act (Public Resources
Code, Section 21000 et.seq.1.
b. A Negative Declaration or another environmental document, satisfying the requirements of
the California Environmental Quality Act ICEQA), and assessing the cumulative impacts of
General Permit 8oard Order No. 97-700, has been approved for the proposed project.
12. The Water Quatity Control Plan for the Colorado River 8asin Region of Ca�itornia lBasin Planl was
adopted on Novernber 17, 1993 and designates the beneficial uses of ground and surface waters
in this Region.
t 3. The btnelicial uses of ground waters in the Colorado River 6asin Region are:
a. Agricultura) Supply (AGFi)
b. lndustriat Supply (IND)
c. Municipal Supply (MUN1 �
Beneficiaf uses of groundwater in individuat hydrologic units are listed in the 8esin Plan.
14. 8eneficial uses of surface waters in the Colorado River 8asin Region are:
a. Agricultura! Setpply IAGR)
b. Aquaculture IAQUA)
c. Fresh Water Replenishment (FRSH►
d. Ground Water Recharge iGWR)
e. Industrial Service Suppty IINl7)
f. Municipal Supply �MUN)
g. Hydropower Generation lPOVt/)
h. Preservation of Rare, Endangered or Threatened Species IRAREf
2
�. Water Contact Recreation (REC I►
�. water Contact RecreaGon (REC II)
k. Warm Water Hab�tat IWARMI
I. Wddl�te Hab�tat (Wild)
8enefic�al uses of �nd�v�dual surface waters are hsted �n the Bas�n Plan.
15. The Board has not�f�ed the user and all known �nterested agenc�es and persons of its �ntent to
prescribe waste discharge requirements for sa�d d�scharge and has provided them w�th an
, opportunity for a public meeting and an opportunity to submit comments.
16. The 8oard in a public meeting heard and Cons�dered all comments pertaining to this d�scharge.
IT IS HEREBY ORDERED, that in order to meet the provis�ons co�tained in Oivision 7 of the Calilorn�a Water
Code and regulat�ons adoD�ed thereunder, the user shall comply w,�h the following:
A. Prohibitions
t. The intentional discharge of recycled •Nater to land not owned or controlled by the discharger
is prohibited.
2. There shall be no application of recycled water within 50 feet, and storage o( recycled water
within 100 feet of a domestic well, unless approved otherwise by the DHS .
3. The use of recycled water shall not cause the degradation of ground water used for domestic
purposes or cause any change in water quality parameters which would make the water
unsuitable for be�e(icial uses as described in the 6as�n Plan or the Safe Drinking Water and Toxic
Enforcement Act.
8. Specifications
1. Use ot recycled water shall not cause pollution or nuisance as defined in Section 13050 of
Division 7 of the California Water Code.
2. Only tertiary treated wastewater as defined by Section 603)3tb), Article 4, Chapter 3, Division
4, Title 22 of the California COde ot Regulations shall be accepted and used by the facility as
recycled water.
3. There shall be no direct or indirect discharge of recycled water into any on-gite domestic or
irrigation supply wells, as a result ot recycled wastewater storage or discharge.
4. Recycled water for discharge shal( be procured under a written agresment between the
discharger and producer of the water. A copy of this agreement shall be furnished to the
Regional Board and DHS within 90 days of obtaining this permit.
5. The discharger shatl not discharge recycled water in excess of the design capacity of the system.
In case of an emerge�cy, the Regional 8oard shall be duly notified and authority for any such
discharge sha11 be obtained in writing f�om the Fiegional Board's Executive Officer.
3 �
C. Prov�s�ons
1. The discharger shali comply w�th "Morntoring and Report�ng Program No. 9)•700", and fucure
rev�s�ons thereto, as spec�(ied by the Reg�onal Board's Execut�ve Otf�cer.
2. The discharger �s the responsible party tor compliance with these waste d�scharge requirements,
a�d the monitor�ng and repo�ting program for ihe faC�lity. The discharger shall �pmply w�th al1
conditions of these waste Cischarge reQuirements. Violations may result in enforcement actions,
including Regional Board Orders or court orders, requ�ring corrective actio� or imposing civil
monetary liability, or in moditication or revocation ot these waste discharge reduirements by the
• Regional BoarO.
3. The discharger shall designate an on•site supervisor responsible for operation ot the recycled
water system. The supervisor shall be responsible tor the instalfation, operation and maintenance
o( the irrigation system, implem�ntation ot this General Order, prevention of potential haZards,
maintenance of the distribution system plans in 'as-buitt" form, and for the distribution of the
recycled water in accordance with this General Order. The name oI the on-site supervisor sha!!
- - be furnished �n writ�ng to the Regional 8oard at least 30 days prior to commencement of
discharge of recycled water.
4. The discharger shall report any spill incident which endangers human health or the environment
to the Ca�itornia Ottice of Emergency Services at t-800-852•)550 and the Regional Water
Quatity Control 8oard at 760-346•7491. During non-business hours, the discharger shall Ieave
a message on the Regional 9oard's message machine which is available at the above listed
number. Incident information shall be provided orally as soon as possible and within 24 ha�rs
from the time the discharger becomes aware oI the incident. A written submission shall also be
provided to the Regional Board within five business days oi the time the discharger becomes
aware of the circumstances. �
The written submission shall contain:
a. A description of the nontompfiance and its cause;
b. The period of noncompliance including exact dates and times and if the noncompliance has
not been corrected, the expected time it �s expected to continue; and
c. Steps taken or ptanned to reduce, eliminate and prevent recurrence of noncompliance.
5. The discharger shall ensure that all site operating persAnnel are familiar with the conte�t ot this
General Order, and shall maintain a copy ot this Gerural Order at the aite. Personnel must be
in(ormed that recycled water is meent fo� irrigatfon and landscaping purposes only, and is not
approved for drinking, hand washing, etc. Personnel must also be informed of the locations
of domestie and recycled lines to ensure that the potable and retycled systems are not
interco�nected.
6. The discharger shatl assure that notification oi dischargeof recycled water is provided to people
who reside adjacent to i►rigation reuse areas and to golf course patrons. The content of the
natice and method of notification shall be approved by the Regional Board'S Executive Officer
and DHS. The public shall be notified at least 30 days prior to commencement at golf course
irrigation or Iandscaping with recycled water. Exist�ng discha►gers, whose individual waste
Cischarge requirements are replaced with this General Order are exempt from this provision.
4
7. The discharger shall at all times properly operate and ma�nta�n al! lac�lities and systems of
treatment and controi (and related appurtenancesl, wh�ch are �nstalled or used by the user to
ach�eve compliance w�th cond�t�ons of th�s General Order.
8, The d�scharger shall comply w,th ati oi the cond�t�ons of th�s Board O►der. Noncompl�ance w�th
th�s General Order�s cons�dered to be a v�olat�on of the Porter-Cologne water Quality Control Act
and may �nvotve v�oiat�on ot Reclamat�on Cr�ter�a promulgated by OHS�n T�tle 22, Californ�a Code
ot Regu�at�ons and �s cons�dered grounds for entorcement action.
9. The discharger shall allow the Regional 8oard, che DHS, or an author�zed representative, upon
• presentatio� of credentials and other documents as may be required by law, to:
a. Enter upon the premises regulated by this General Order, or the place where records must
be kepc under the cond�tions o( this General O�der;
b. Have access to and copy, at reasonable times, any recards that shall be kept under the
condiuons of th�s Genera! Order;
c. Inspect at reaso�able times any tacilities, equipment (including monitoring and control
equipmentl, practices, or operations regulated or required under this General Order; and
d. Sample or rnonitor at reasonable times, and while escorted by the dischargers' representative
for the purpose of assuring compliance with this Board Order or as otherwise authorized by
the California Water Code any substances or parameters at this location.
10. Pripr to any modifications in this facility which would result in material thange in the quality or
quantity oi recycled water discharged, or any material change in the tocation of discharge, the
user shall report all pertinent information in writing to the Regional 8oard and DHS and obtain
rev�sed requ�rements before any moditications are �mplemented.
1 1. Prior to any change in ownership or management of this operation, the user shall transmit a copy
of this General prder to the succeeding owner'operator, and torward a copy of the transm�ttal
letter co the Regional Board. The new owner�operator must tite a NOI w�th the Regional 8oard.
12. 7his General Order does not authorize violation of any federal, state, or local laws or regulations.
13. The user shafl furnish, under penalty of perjury, technical monitoring program reports, and such
reports shall be submirted in accordance with the specifications prepared by the Regional Board's
Executive Oifice►. Such specifications are subject to periodic revisions as may be warranted.
14. The user shall retain records ot ail monitoring information including all calibration and
maintenance records, copies of ali reports required by this General Order, and records of all data
used to complete the applicatian tor this General Order. Records shali be maintained for a
minimum af three years from the date of the sample, measurement, or report. This period may
� be extended during the course of any unresolved litigation regarding this discharge or when
requested by the Regional Board's Executive Officer_
5
D. Heafth Based Provisions
t. T�ere shail be no•cross connect�on between potable water suppiy and p�ping �onta�ning recycled
� water. Supplement�ng recycied water w�tn water used tor domest�c suppty shall not be ailowed
ezcept w�th an a�r•gap separac�on. An a�r•gap or r.educed pressure pr�nc�ple dev�ce shail be
prov�ded at all domest�c water service connec��ons to recycied water use areas.
2. The d�scharger shall prov�de documentat�on to ensure chat there �s no interconnection between
the potable and recycled water systems. O�schargers w�th both potable and irrigation water
delivered to the site shalf ensure that a cross•connection test is completed prio► to defivery of
recyc�ed water to the site. A cross•conneccion control test, mutually agreeable to the permittee
' and OHS shall be conducted at least once eve�y (our years. Existing users shall conduct a
cross•connection test within a time frame acceptable to OHS. The tests shall be conducted by
an American Waterworks Association fAWWA) certified cross•connection control program
sDecialist or equivalent. Prior to conducting the test the user shall not�fy the DHS and County
Department of Heatth Serv�ces. Results of the cross•connection test shall be submitted to the
Reg�onal Board, OHS and County Department of Heaith Services with�n 30 days of completion.
3. The user shall submit the "as buiit' plans and spec�fications showing the domestic and irrigation
systerns; the toration of all potable and recycled water connections; and locations of all on-site
and nearby wells to OHS. These plans shall be submitted within a time frame acceptable to
ONS. Wit�in 30 days of the issuance of this permit, existing facilities without "as buitt' plans
shall contac't bH$ tor guidance.
4. Adequate measures shall be taken to mirnmize public contact with recycled water. Clearly
visible, adequately sized warn�ng signs shall be posted in sufiicient numbers around the
application and storage areas. The size and number o/ warning signs shatl be mutually
determined by the discharger and DHS.
5. Prior to construction of new tacilities planning to discharge recycled water, the discharger shall
submit tha des+gn drawings to the OHS, field operations branch, tor approval. The discha�ger
shall, at a maximum, atlow the State Oepa►tment of Health Services a 30-day comment period
tor completed designs submitted. If comments are not received by the discharger from the State
Department of Heath Services within that 30-day period, then no response will be deemed as "no
comment" and the discharge► will be able to begin construction.
6. Golf cou�se pump houses utili2ing recycled water shall be appropriately tagged with warning
signs with proper wording of sutticient sire to warn the public that recycled water is not sate tor
drinking. All new and reptacement at grade vatve boxes shall be purple or appropriately ta99ed
for water reuse purposes.
7. The use of reeycled water sha(I be in conformance with the reclamation�riteria contained in Title
22 of the California Code ot Regulations, or amendments thereto.
8. Recycled water shall not be applied in a manner or at a location where it could come in contact
with drinking water fountains, food handting, food storage or dining arees.
9. There shalt be at least a 4-toot hori2ontal and 1•�oot vertical separation (with domestic water
above the recycled water pipetinel between all new�y installed constant pressure pipelines
tiansporting domestic water and those transporting reCytled water. All newly installed recycled
water distribution lines shall be cotored purple or labeted with purple tape. Existing pipelines are
excluded from this requirement.
6
10. Irr�gated areas shall be properly managed to m�n�m�Ze pond�ng,
1 1 . Recycled water shall not be used as domest�c supply water or �ntent�ona�ly used as an�mal
water supply.
i, Pn�l�p A. Gruenberg, Executive 011icer, do hereby cert�fy �he loreqo�n9 �s a full, true and correct copy of
an Order adopted by the Californ+a Regional Water �ual�ty CO�trol 8oa�d, Coiorado A�ver Bas�n Reg�on, on
June 25, 1997.
E ecutive Otficer �
7
_ CAIIFORNIA REGiONAI WATER QUALITY CONTROI 80Aq0
COlORA00 RIVER BASIN AEGION
MONITORING ANO REPORTING PROGaAM NO 97•700
fOR
GENERA� WASTE OISCHARGE REQUIREMENTS FOA
OiSCHARGE OF RECYCLED WAtER
FOR GOLF rOURSE ANO LANOSCAPE iRRIGATiON
Locat�on o} D�scharge: Co�orado R�ver 8as�n Reg�on (Reg�on 11.
" REPORTING
t. Report �rnmed�ately any fa�lure which endangers human health or the env�ronment tc the
Cal�torrna Ott�ce ot Emeraencv Services at t�800•852•7550 and the Regional Water puality
Controt Board at 760•346-7491 . Dur�ng non•bus�ness hours, the disc�arger shal� leave s
message on tre Reg�onal 8oard's messa9e macn�ns wn�cn �s ava�iable at cne above I�sted
number. A wr�cten subm�ss�on Shali be prov�ded to the Regional Board w�th�n tive bus�ness Cays
o� the d�schar9er becoming aware o1 the urc�mstances. �
2. A duly author�ied rep�esentat�ve of the d�scharger may s�yn the Cocuments if:
a. The author�zat�on is made in writ�ng by the person descr�Ded above;
b. The auchori2ation spec�fied an individual or person �av�ng respons�bitity for che overall
operation of the regu�ated disposal system; and
c. The written authorization is submittsd to the Regional Boa�d's Executive Oflicer.
3. Each monitoring report shalt contain the following statement:
'I decla►e under the penalty of law chat I have personally ezamined and am tsmiliar wi�h the
information submitted in this document. and that based on my inquiry of those individuals
�mmed�ately responsible for obtaining t�e information, I believe that che informacion is crue,
accurate, and comp�ete. 1 am aware chat t�ere are signiticant p�nalties for submi�eing false
information, including the possibility of a fine snd imprisonment for knowin� violations.'
Ordered by: �
Executive Officer
June 25. 1997
Oate
1
' � CALIfO� EGIONAL WATfR QUAIiZIf CONTROI �RO• �
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GENERAI WA5TE DISCHARGE REaUIREMENTS FOR
OISCHARGE OF RECYCIE� WATER
FOR GOIf COURSE ANO LANDSCAPE IRRIGATION
Coiorado Rive► 6as�n Region
Region • 7
o-s•�+ r.,�o, ��� 47.�nr�
• i
� INSTRUCTIONS
FOR COMPLETING THE NOTICE OF INTENT (NOI)
These instructions are intended to help you, the discharger, complete the NOI form for General Waste
Discharge Requirements for use of Recycled Water on golf courses and in (andscaping.
At the top of the form, please indicate if this.is a first time coverage under this General Permit, a regulated
facility, or change of information for a faciliry already covered under this General PermiUGeneral WDR. If
this is a regulated facility, please supply the eleven digit WDID number for the facility.
Section I—Owner/Operator
Section A
1. Name — The name (frrst and Iast) of the owner/operator of the facility. If the owneNoperator is a
company, corporation, etc. then put the name of the company, corporation, etc. in this space.
Please print Geariy.
Z. Mailing Address — The street number and street name where mail and correspondence should be
sent(P.O. Box is acceptable)
3. City, State, and Zip Code—The city, state, and zfp code that apply to the mailing address given.
4. Telephone— Daytime telephone number of the owner/operator.
Section B.
1. Contact Person — Please list the name (first and last) of the contact person for the ownerloperator
(agency,corporation, private business, etc.)listed above.
Z. Please check the boxes to the right of "Contact Person" to indicate whether the name given in
section"A"is the owner, operator,or both the owner and the operator.
3. Additional Owners — Please check the box if there is more than one owner/operator. Provide the
additional information in a supplementary letter addressed to the Colorado River Basin Regional
Water Quality Control Board as part of this NOI.
Section II—Facility Information
1. Name of Facility — The name of the facility that is requesting coverage under this General
PermiUGeneral WDR.
2. Mailing Address of Facitity—The street number and street name where the facility is located.
(P.O. 8ox is not acceptabte).
City, State,and Zip Code—The city, state, and zip code that apply to the facilty address given.
Telephone—The telephone number of the facility.
Section III—Bi!ling Address
' � � � State of California
� CCLORADO RIVER BASIN P,EGIONAL'rVi.TcR QUAI.ITY CONTROI BOARD
, Cal/EPA NOTICE OF INTENT
TO COMPLY WITH THE TERMS OF GENERAI WAS7E DISCHARGE RECIUIREMENTS FOR USE OF
RECYCLED WATER FOR GOLF COURSE & LANDSCAPE IRRIGATIO(V
1. New Discharqe ot Existing Unregulated Discharge
2. Existing Regulated Oischarge-W�ID�f
3. Change of Ownership/Operator information -WDIDM
I. OWNER/OPERATOR
A. Name
Mailing Addrass
City State 2ip Code Telephone
8. Contact Person Title
� Additional Ow�ers-it additional owners/operators are involvfld,provide the information on a separate piece of paper
II. FACILITY INFORMATION
A. Name Telephone
Mailing Address of Facility Street Address of Facility
City State Zip Code City State Zip Code
(II. BILLING AODRESS
SENO TO: Name
� OWNERIOPERATOR
IEMERINFORMA71pN AT iUGM, Mailing Address
ONLY If DIfFEREHT GROM ABOVE)
� OTHER
'&1ER1MfOR"'"T7O1'"'"'�"" C�tY State Zip Code
REGIONAL BOARO USE ONLY
W010: Regional Board Office: Daie NOI Received: Oate NOI Processed:
m
Fae Amount Received: Check N:
' Send To: - Piease check the appropriate box. If biliing should be sent to the property owner, please enter
the information to the right o�if it is different from the information given above. If the billing should
be sent to somewhere or someone else, please check the box titled "OTHER" and fill in the
information on the right.
2. Name—The name(first and last)of the person who wilt be responsible for the billing.
3. Mailing Address—The street number and street name where the billing should be sent.
(P.O. Box is acceptable) ,
4. City, State and Zip Code—The city, state, and zip code that apply to the mailing address given.
Section IV. —Verification
Please fill in whether or not a verification has been made to determine if the discharger(s) are in
compliance with prohibitions or orders of the Colorado River Basin Regional Water Quality Control Board.
Check the space marked"Yes"or"fV�".
Section V. — Description of Discharqe
Provide requested information.
Section VI. -Certification
1. Printed Name — Please letter your name legibly. This section should be filled out by the person
responsible according to Section I.A of Attachment A.
2. Signature and Date—Signature of name printed above, and the date signed.
3. Title—The professional title of the person signing the NOI.
Section VII.—Other Information Required
Provide requested information.
Have you contacted the RWQCB or otherwise verified ihat the proposed discharge will not violate prohibitions
or orders of the RWQCB? YES No
V. DESCRIPTION OF DISCHARGE
Describe the proposed dischargels)
Provide the Following Information:
Volume of Discharge tgallons): Maximum: Average:
Minimum:
Distance to Nearest Water Well:
VL CERTIFICATION
"I certify under penalty of !aw that this document and all attachments were prepared under my direction and
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry ot the person or persons who manage ihe system,
or those persons directly responsible for gathering the information, the information submitted is to ihe best of
my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including ihe possibility of fine and imprisonment". In addition, I certify that the
provisions of the permii, including the criteria for eligibility, will be complied with.
Printed Name:
Signature: Date:
Title:
VII. OTHER INFORMATION REQUIRED
8 Y:" x 1 1" maps up to a scale of 1:24000 are suggested unless the facility and disposal area are too farge for such a
scale to be practical, in which case of up to 1:144000 may be used. If a scale of 1:144000 is stilf impractical, a map
larger than 81/2 x 11' may be used.