Water is an issue of critical concern in our communities, as competing users vie for this limited resource with ever-growing demand.
Will the Biomass Project require so much of Weed's water, that there will be shortages for other users?
The risk of water shortages is quite likely. The EIR is evasive and incomplete on this issue of water rights and water consumption. Other existing water users will undoubtedly be impacted by the new consumption of water from Roseburg's power plant, estimated at 230,000 gallons per day. Downstream agricultural users, and the City of Weed itself, may end up not having enough water, especially during periods of drought. But the EIR does not adequately and accurately address these issues.
Will the Biomass Project pollute streams with contaminated wastewater discharges, into nearby streams and water resources ?
Pollution seems likely, since wastewater is produced, but the EIR fails to tell us how much, where this waste water will end up, or how it will be disposed. The EIR does not adequately describe water pollution impacts from the project, let alone mitigate for them. Regular wastewater discharges from the cooling towers - called "blow-down" - will contain a chemical stew of biocides, fungicides, anti-corrosives, and other chemical additives. The EIR doesn't sufficiently address or identify what chemicals this blow-down water will contain, where this contaminated water will be released, the quantity that will be released, and how this contaminated discharge can damage aquatic life, and other downstream water users.
More on both these important water issues below:
1. Water rights and reduced availability of water.
While it correctly states that Roseburg has several valid water rights, the EIR is defective because it:
• fails to acknowledge or explain that the holding of a water right does not guarantee that water is actually available to fill that right in all years,
• fails to indicate that that water right cannot be filled without taking water from someone else whose water right is more junior, when water is in short supply.
• fails to describe fully how much water from those rights is actually currently unavailable due to prior contractual commitments.
• fails to describe anticipated peak (i.e. summer) water usage
• fails to assess the growth inducing consequences of the changes in water use being proposed.
There is not enough water in Boles Creek, Beaughton Creek and the Shasta River to meet all existing water demands in many years, according to reports from the state Water Resources Department. An increase in consumptive use by Roseburg for their cooling towers must necessarily mean less water is available to some other water users. Those other water users relying on those water sources include the City of Weed, J.H. Baxter Co., a number of ranchers between the city of Weed and Lake Shastina, and the Montague Water Conservation District, owners of Lake Shastina itself.
Roseburg claims historical water rights, based on quantities of water used in earlier years at the mill. But as the state water reports show, much of Roseburg's historic use was non-consumptive. They diverted a lot of water, used it to spray log decks, then allowed the excess to run off and back to the stream. Then others downstream could re-use it to meet their water needs. So even though Roseburg had a substantial water right, there is no indication of just how much of it was used consumptively (i.e. was not available to anyone else once Roseburg was done with it) and how much was used non-consumptively (and would have been available to others). In addition, Roseburg has apparently not utilized its full water allocation for many years. During that time others have no doubt come to rely on that water for themselves.
Agricultural operators are most likely to find themselves shorted if Roseburg increases its consumptive water usage. Their water needs peak in the summer for irrigation of pastures and hayfields. Roseburg's consumptive use of water will likewise peak in summer as air temperatures soar, Redding's demand for electricity is highest, and evaporation from the cooling towers is the greatest. The EIR fails to provide data to allow a person to gauge just how much water (that in recent years had remained in the stream) will now be converted to clouds of steam in the summertime and lost to any other water users, many of whom are already in short supply.
Reducing water for irrigation significantly undermines the economics of any ranching operation. The ranches located downstream of Roseburg, toward Lake Shastina, are already in the path of urban development. Undermining their economic base may be the final blow that drives these businesses out of agriculture and into subdivision developments. The EIR fails to assess who would be shortchanged of water as Roseburg's use increased, and what impacts that might have on these businesses.
Will Roseburg's increased water use mean not enough for Weed residents? Roseburg's original water rights in part were intended to provide drinking water for the residents of Weed, then a company town. Part of Roseburg's water right is still allocated to the City of Weed, but no information was presented to document whether the City of Weed would be provided with water in preference to the cooling towers should water come to be in short supply. Obviously, a great number of people would be affected if water used for the biomass plant deprived them of their longstanding source of residential drinking water.
Crystal Geyser and apparently J.H. Baxter are also relying on Roseburg's water rights to meet their needs. Again, no information was provided to indicate just how they and their employees might fare should water become short. Finally, there was no accounting of just how much water from Roseburg's right was left after subtracting out the above uses.
Full impacts of increased water use by Roseburg not addressed - Changes in where and how water is to be used, and the resulting changes in residential water use, industrial water use and changes in land use from ranching and open space to more urban development are all significant potential impacts of this project. All these impacts should have been assessed to provide the affected citizens and decision makers with a full understanding of what they were approving. That information was not in the EIR.
2. Contaminated waste water disposal – discharged both into streams and air
The EIR states that the cooling towers are a "closed loop system" – implying that the same water is recirculated again and again. But this is misleading – in fact, about 230,000 gallons will be needed to supply the cooling tower every day. Where does this 230,000 gallons per day go? Part will go to evaporation. The rest becomes "blow down" water, that has to go somewhere. The EIR fails to adequately identify and address the pollution impacts of both these types of wastewater discharges.
Contaminated discharges through evaporation: In colder weather cooling towers produce visible plumes of water vapor, clearly indicating that they are in fact not "closed loops." (Contained in this evaporated water are contaminants, see below.) Less visibly, they also need to discharge liquid water (along with other contaminants; again see below) when the mineral content of that water gets too high from evaporation. The Roseburg EIR failed to fully disclose those discharges, their magnitude, what their various constituents might be, where they would go or what their consequences might be. All this information is necessary to properly assess the risks involved and to determine where mitigations might be needed.
Water vapor discharged from the cooling towers can generally be expected to partially evaporate, and partially condense into clouds that themselves may evaporate. When the fine droplets of water evaporate they leave behind airborne particles made of the minerals in the water. Those seemingly benign white clouds of 'steam' might be better described as sources of exceedingly fine dust, dust that may be able to cause cancer, emphysema or other disabling respiratory ailments, depending on the mineral makeup of the water source. Without knowing the amount of water lost as vapor/droplets/steam, nor knowing the mineral makeup of that water, an assessment of this risk of mechanical lung injury is impossible. Because cooling towers operate 24 hours/day, and are constantly heated, they generally provide an excellent habitat for bacteria, algae and fungi, all of which coat heat exchange surfaces and reduce the effectiveness of them as heat exchangers. The ordinary response is to add fungicides, algaecides and other biocides to suppress their growth. Some percentage of those generally toxic compounds are then carried off in the evaporated water exposing the community to whatever their effects might be. Since the EIR made no mention of their existence, and provided no description of which chemicals might be used, no assessment was possible of their suitability for use in towers surrounded by residences in Weed. People who will be forced to breathe such chemicals have a right to know.
Contaminated discharges through "blow-down water": Water used in cooling towers is generally re-circulated with pumps several times until its mineral content rises so high that there is a risk of the minerals coating the heat exchanger surfaces, thereby reducing their effectiveness. Chemicals can be added to the water to reduce this tendency, but regardless the water must eventually be replaced with fresh water. The discarded wastewater is referred to as 'blow-down water'. It contains anything concentrated from the original water, plus any chemicals added to suppress algal, fungal and bacterial growth, plus chemicals added to reduce corrosion of metal parts and chemicals added to reduce mineral deposition. It is potentially a complex chemical soup.
Of the 230,000 gallons of water lost daily, the EIR does not identify what part is evaporation, and what part is blow-down water. The EIR does not identify where this contaminated blow-down water is discharged, and what contaminants are released into the atmosphere through evaporation.
While the EIR is supposed to provide full disclosure of things such as this, again virtually nothing was said, despite repeated requests for this information by citizens. In public comments the only additional information given was a statement from Roseburg promising that "nothing would leave the site." This "trust me" approach is not the proper way to prepare an EIR. An EIR should inform the public of what will actually be happening on site, and how that may impact their businesses, families, and homes. Because there was no information presented documenting just what volumes of liquids were likely to be involved, what chemicals they would contain, or how they would be disposed of on site, the "trust me" approach is simply inadequate.
