City is Now Required to Prepare an

Subsequent Environmental Impact Report

to Evaluate New Significant Risks with
Amended Sewer Permit Application
Crystal Geyser Water Company requested some changes to their sewer permit application
that first were made publicly known in February, 2018. These changes would now allow
CGWC to discharge air compressor condensate, boiler water blowdown, and cooling
tower blowdown., as well as to mix non-contact cooling water with contact cooling water
in its discharges to the City’s sewer system.

None of these changes were disclosed nor reviewed in the Project’s 2017 EIR. They
were added to its amended permit a few months after the EIR was certified.

These are changes that will create significant environmental impacts. Cooling tower and
boiler blowdown waters contain hazardous or toxic chemicals that are not even allowable
under existing City municipal code regulations. This is new information of substantial
importance because it reveals this Project will have significant environmental impacts
that were not disclosed in the EIR.

This information was not known and could not have been known even with the exercise
of diligence at the time the Project’s EIR was certified as complete in October, 2017. The
EIR never mentioned that blowdown water would be discharged to the City’s sewers. The
EIR did not disclose that any toxic biocides would occur in any waste or blowdown
water. The EIR never analyzed the disposal in City sewers of corrosion-inhibitor
chemicals that may be found in blowdown water. (It was improperly disposed of
corrosion-inhibitor chemicals that led serious health impacts to residents in Hinkley, CA
and the community becoming a virtual ghost town.)

The City, because it is the next agency reviewing a discretionary permit for this Project,
is obligated by CEQA Guidelines § 15162 to prepare a Subsequent EIR. That law and its
relevant provisions are made available in this Attachment #6.

Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #6