1. GENERAL

2. Human Health and Environment

3. Technical Feasibility

4. Financial Feasibility and Project Management

5. Community Participation

6. Sustainable Development

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Contact Person: Beth C. Eby

Title: City Manager

Organization: City of Del Rio

Address: P.O. Box 4234

City, State, Zip Code: Del Rio, TX 78841

Country: USA

Telephone: (210) 774-8558

Fax: (210) 744-8542

The proposed project is a new potable water treatment plant for the City of Del Rio in Val Verde County, Texas, which includes the treatment plant, replacement raw water intakes and pumps, replacement potable water ground storage tanks, and new treated water pump and transfer lines.

The City of Del Rio is located in the U.S./Mexico border region of southwestern Texas, within southeastern Val Verde County. Its geographic area covers approximately 27 square miles. It is located about 5 miles from the international border and approximately 153 miles west of the City of San Antonio. The international dam and reservoir, Lake Amistad on the Rio Grande, is approximately 9 miles to the northwest of Del Rio

The treatment plant site is located north of U.S. Highway 90 at Jack Lowe Street and San Felipe Springs Road just east of the existing San Felipe Springs raw water intake. The replacement raw water intakes and pumps will be located at the springs, and the replacement potable water ground storage tank site is located at Bedell Avenue and Barbara Way, approximately 1.3 miles northwest of the treatment plant site. The new treated water pump and transfer lines will be located along a route between the treatment plant site and the storage tank site. The area of impact is the entire City of Del Rio.

The proposed site for the Water Treatment Plant (WTP) is east of and immediately adjacent to the present location of the City of Del Rio’s raw water pumping facility at San Felipe Springs. This location will eliminate the need to pump raw water from the supply point to a distant treatment facility site. The WTP property consists of about 20 acres of land bounded by Jap Lowe Street on the east, U.S. 90 Highway on the south, San Felipe Springs Road on the west, and private property on the north. The site is accessible by existing paved city streets, and is served by most local utilities including potable water, electric power, and natural gas supply. Sanitary sewer collection system will be extended to serve the plant site.

The environmental benefit to be achieved by implementation of this project is the risk reduction to the public health and safety caused by a potentially unsafe public water supply. However, no statistical or other evidence exists linking health problems to the currently unfiltered, disinfected water supply. The proposed project is being mandated by the Texas Natural Resource Conservation Commission (TNRCC) under the requirements of the Surface Water Treatment Rule (SWTR) of the Safe Drinking Water Act (SDWA). An additional benefit is the conservation of finite groundwater resources by the replacement of leaking existing potable water storage tanks and the elimination of additional potential contamination pathways.

The project presents both short-term environmental issues during construction, and a long-term environmental issue related to on-going operations of the proposed facility. These issues are addressed in the accompanying Environmental Assessment.

Project alternatives which were considered as responses to the human health needs and environmental issue were limited to treatment alternatives, project facility site locations, and alternative construction techniques. The "No-Build" alternative was not considered due to the fact that the TNRCC has mandated treatment of the City of Del Rio’s water supply. Treatment alternatives considered include conventional filtration, direct filtration, and membrane filtration.

• CERCLA—Comprehensive Environmental Response, Compensation, and Liability Act, through CERCLIS Information System
• CAA—Clean Air Act, by determination of no air pollutants resulting from WTP operations
• CWA—Clean Water Act, through Section 404 permit application
• ERNS—Emergency Response Notification System
• FINDS—Facility Index System database
• HMIRS—Hazardous Material Incident Report System
• HWS—Texas State Superfund Quarterly Report
• LUST—Texas Leaking Petroleum Storage Tank list
• NFRAP—No Further Remedial Action Planned database
• NPL—National Priority List database
• NPL Liens—Federal Superfund Liens database
• PADS--PCB Activity Database
• RAATS—RCRIS Administration Action Tracking System
• RCRA—Resource Recovery and Conservation Act, through RCRIS Notifiers database
• SARA—Superfund Amendments and Reauthorization Act, through HWS and NPL
• SDWA—Safe Drinking Water Act, through compliance with TNRCC Administrative Order
• SWF—Texas solid waste disposal site Permit Application file
• TRIS—Toxic Release Inventory System
• TSCA—Toxic Substances Control Act database
• UST—Texas Petroleum Storage Tank List

The following cultural resource laws and regulations have also been addressed in the environmental assessment:

• Chapter 26 Rules of the Texas Antiquities Code, through an on-going archeological survey

Total Project Cost $ 40,250,000.00

Total Contribution from Applicant (Water Revenue Bonds) $ 12,075,000.00

Total Contribution from Other Sources $ 0

Total Contributions $ 12,075,000.00

Total Financing Needed $ 28,175,000.00

The City of Del Rio is submitting this Step II Application to the BECC for certification of this project as eligible to receive funds from the North American Development Bank (NADBank). This Step II application is for both construction grant funding and for rate subsidy transition grant funding from the EPA’s BEIF funds.

1) USGS 7.5 minute topographic quadrangle Maps (4) (ATTACHMENT 1)

2) State of Texas Highway Road Map (ATTACHMENT 2)

3) Environmental Assessment (ATTACHMENT 3) (Continued next page)

4) Comprehensive Community Participation Plan (ATTACHMENT 4)

5) Preliminary Engineering Report (PER) (ATTACHMENT 5)

6) Draft TNRCC Administrative Order (AO) (ATTACHMENT 6)

7) Malcolm Pirnie, TNRCC, and IBWC Correspondence, dated 6/12/97, 7/8/97, and 8/18/97 respectively (ATTACHMENT 7)

8) Financial Statements—Historical (ATTACHMENT 8)

9) Financial Statements--Pro-Forma, and O&M Budget—Pro-Forma (ATTACHMENT 9)

10) Contributions Timetable (ATTACHMENT 10)

11) Capital Costs (ATTACHMENT 11)

12) Sensitivity Analysis; break-even Analysis; and Fee-Rate Model (ATTACHMENT 12)

13) Historical Fee Schedule (ATTACHMENT 13)

14) Billing vs. Collection Efficiency (ATTACHMENT 14)

15) Organizational Structure and Legal Opinion (ATTACHMENT 15)

16) City of Del Rio Water Conservation Plan (ATTACHMENT 16)

17) Preliminary Cultural Resources Letter Report (ATTACHMENT 17)

The proposed project is a new Water Treatment Plant for the City of Del Rio, which is being mandated by the Texas Natural Resource Conservation Commission. The city’s water supply from the prolific San Felipe Springs which is unfiltered at present, but is disinfected with chlorine prior to distribution, has been ruled by the TNRCC to be Groundwater Under the Direct Influence of Surface Water, thus requiring filtration the same as a surface water supply.

The State of Texas regulatory body with the responsibility of protecting the water quality within the state, the Texas Natural Resource Conservation Commission (TNRCC), has determined that the City of Del Rio’s raw water supply, San Felipe Springs, is Ground Water Under the Influence of Surface Water (GWUDI) based on brief, periodic, and irregular excursions of both turbidity levels and bacteriological levels.

Because of this finding, the TNRCC has imposed a requirement to treat the historically unfiltered, disinfected raw water, which is pumped from an artesian spring located below ground surface at the West Spring and from a surface withdrawal at the East Spring. This action is based on the federal SDWA requirement for filtration of surface water sources and GWUDI sources, associated with the need for reducing the risk to the public health which an untreated water supply might cause.

Because the City’s existing Bedell ground storage tanks have been leaking drinking water (estimated between 250,000 and 500,000 gallons per day), the TNRCC has also incorporated repair or replacement of the ground storage tanks into an administrative Agreed Board Order which, once executed, has the force of law with correspondingly serious civil and monetary penalties for violation of its requirements. The draft Agreed Board Order calls for the filtration and primary disinfection of the City’s water supply in accordance with the SDWA Surface Water Treatment Rule, and storage system improvements to be in place by about June, 1999.

The proposed technology for treatment of the raw water supply is membrane filtration. This alternative has been selected after careful consideration of other treatment alternatives, and the present as well as future needs of the community for a safe and dependable water supply.

The project includes a new 28 mgd treatment facility (expandable to 39 mgd), new raw water supply pumping facilities to replace the existing springs pump station, new treated water storage to replace existing deteriorated Bedell storage tanks, and new distribution system pump and transfer facilities.

The existing water supply and distribution system includes raw water supply pumps, and chlorine and fluoride injection facilities at San Felipe Springs, ground storage and elevated storage tanks, and distribution system pumps and pipe.

The proposed project includes the Study and Facility Planning Phase, the preparation of a Financial Assistance Application, the preparation of an Environmental Assessment, the coordination of the NEPA process to a FONSI, a Comprehensive Community Participation effort, the Design Phase, the preparation of required permit applications, the Construction Phase, and the Start-up Assistance Phase. The estimated costs of the different tasks are shown in the table below.

All of the tasks shown are proceeding concurrently. The costs shown, and the time required for completion, are estimates only (where noted) due to the uncertainty of the final level of effort required.

1Task not completed as of 1/15/98—cost and schedule are estimates

The current service area population estimate of 42,000 in 1995-96 was provided by the City of Del Rio Planning Department and verified by population projections by the Department of Rural Sociology of Texas A&M University. This figure is expected to increase to 46,500 by the year 1999, the projected year of the Water Treatment Plant start-up; and to 70,000 by the year 2020, which is the projected 25 year life span of the proposed project. These population projections are also from the Texas A&M University’s population study, and reflect a conservative annual population growth rate of 2.153%.

Additional information regarding population growth and water demand projections may be found in Section 4.3 of the Preliminary Engineering Report (PER).

Water service is provided by the City of Del Rio to 100% of the population in the community for 24 hours a day. The City also provides wastewater collection and treatment to 90% of the population in the community for 24 hours daily. Solid waste collection and disposal services are provided by the City to 100% of the population in the community. Pick-ups are scheduled twice-weekly on alternating days for different areas of the city.

Several project alternatives were considered for this project, including alternate project site locations and alternative means of treatment and filtration of the raw water. However, the "No Project" alternative was not considered because of the pending Administrative Order from TNRCC.

This Alternative was not considered because of the treatment mandate from the TNRCC as included in the Board’s Administrative Order.

Alternative Number 1, the selected alternative, consists of Membrane Filtration.

The selected membrane filtration process is Ultrafiltration (UF). The process is relatively simple, and includes a pretreatment step such as straining to remove large particles, followed by particle removal to a size of about 0.02 m m (± virus size) by the membrane units, and disinfection. It is described in more detail in Section 5.2.3, Membrane Filtration and Separation Processes, of the Preliminary Engineering Report (PER).

The proposed site for the membrane filtration water treatment facility is adjacent to the raw water supply source at San Felipe Springs in the City of Del Rio, Texas. This site was selected because it eliminates the need for additional pump and transfer facilities between the raw water supply point and the treatment facility site. After vacating by its present user, the Texas Department of Transportation, it will be ideally suited to the proposed use.

The site is accessible from existing City streets and is served by local utility services including potable water, electric power, and natural gas supply. Sanitary sewer service will be extended to the site as part of the project development.

The required human health and environmental action is the design, construction, and start-up and operation of a water treatment facility prior to the Administrative Order compliance date of about July, 1999. This has been mandated by the Texas Natural Resource Conservation Commission (TNRCC), which will monitor the completion of the project within the given time frame. The reason for the required action is the protection of the public health, which may be at risk from surface water influences which affect the City’s raw water supply. Periodic turbidity occurrences at the springs support TNRCC’s classification of GWUDI for San Felipe Springs. Turbidity is recognized as a gross indicator of overall water quality related to particulate contaminants, which may include infectious/pathogenic organisms. This issue is discussed in more detail in Section 3.0, Finished and Delivered Water Quality Criteria, of the Preliminary Engineering Report (PER).

No Action, or the "No Project" Alternative, is not feasible due to this risk to public health and the potentially severe civil penalties which the TNRCC’s Agreed Board Order may trigger for violation of its requirements.

The environmental effects of the selected alternative have been assessed by an Environmental Assessment . Because the proposed treatment facility site, the site of the existing ground storage tanks to be replaced, and the location of the new distribution system pumping and transfer improvements are all within urbanized areas, it is expected that the environmental impacts will be minimal.

The Technical Aspects of the selected Alternative, Membrane Filtration, are discussed in detail in Section 5.2.3 of the Preliminary Engineering Report.

Financing for this project is projected to come from municipal Water Revenue bonds. In order to reduce the impact to the water utility rate structure and to its ratepayers, the City Council has authorized this application to the BECC for both capital construction funds and for rate subsidy or transition funds.

The project will benefit all water customers of the City’s municipal water system. Additionally, the County of Val Verde and its consultant, CH2M, are currently in the Design Phase of a water supply project for colonias in the rural areas of the county, funded through the Economically Distressed Areas Program (EDAP) of the Texas Water Development Board (TWDB). These colonias at present do not have access to a drinking water supply and the residents purchase bottled water for drinking and cooking.

The colonias water supply project consists of extending the City of Del Rio’s water distribution system to supply water to these areas. Consequently, the health of these colonia residents will also potentially be at risk without implementation of the City of Del Rio Water Treatment Plant Project.

Sustainable Development Aspects

This project will not consume non-renewable resources and will not impact the environment in any appreciable manner other than during the construction phase. Construction equipment shall be required to be as environmentally protective as practicable, including implementation of noise limitation measures and dust control measures.

In contrast, this project will assist in the conservation of resources by the reduction or elimination of potable water supply storage losses through the replacement of leaking ground storage tanks at the Bedell Street site.

Alternative Number 2, the alternative considered further but not selected, consists of Conventional Treatment.

The conventional treatment process is applicable to a wide range of raw water qualities. The process usually includes the addition of a coagulant in a rapid mix step as the initial treatment, followed by flocculation and sedimentation, filtration, and disinfection. It may or may not include the addition of polymer prior to the filtration step, and may be varied by the bypassing of the sedimentation step or the application of high filtration rates as cost-saving methods during low turbidity periods. It is described in more detail in Section 5.2.1, Conventional Treatment, of the Preliminary Engineering Report.

The proposed site for the conventional process water treatment facility is the same as the site for Alternative 1, adjacent to the raw water supply source at San Felipe Springs in the City of Del Rio, Texas. However, the site would need to be expanded to a larger area due to the size requirements of the sedimentation and filtration units. Thus, additional cost would be involved for land acquisition by the selection of this alternative.

This site location was selected because it eliminates the need for additional pump and transfer facilities between the raw water supply point and the treatment facility site. For this reason, the site is highly suitable for the proposed use.

The site is accessible from existing City streets and is served by local utility services including potable water, electric power, and natural gas supply. Sanitary sewer service will be extended to the site as part of the project development.

For Alternative 2, the same health and environmental issues of Alternative 1 were addressed.

This Alternative 2, Conventional Treatment, was rejected after further consideration due to its inability to easily adjust to large variances in raw water turbidity levels; the higher energy demands, the chemical addition requirements and sludge management which are a normal part of this treatment technology; and the consequently higher operating costs.

The technical aspects of this rejected Alternative 2, Conventional Treatment, are discussed in detail in Section 5.2.1 of the Preliminary Engineering Report.

Same as in Alternative 1.

Same as in Alternative 1.

Sustainable Development Aspects

Same as in Alternative 1.

Alternative Number 3, the alternative immediately rejected, consists of Direct Filtration.

The direct filtration process is a modification of the conventional treatment process. However, it is generally applicable only to low turbidity raw water. This process includes the addition of a coagulant in a rapid mix step as the initial treatment, followed by flocculation, filtration, and disinfection. It eliminates the sedimentation step, and may or may not include the addition of polymer prior to the filtration step. It is described in more detail in Section 5.2.2 of the Preliminary Engineering Report.

Same as in Alternative 1.

Same as in Alternative 1.

This Alternative 3, Direct Filtration, was rejected early in the alternative selection process due to its applicability only to high quality raw water, that is, raw water with consistently moderate turbidity levels (generally £ 10 Ntu).

The technical aspects of this rejected Alternative 3, Direct Filtration, are discussed in detail in Section 5.2.2 of the Preliminary Engineering Report.

Same as in Alternative 1.

Same as in Alternative 1.

Sustainable Development Aspects

Same as in Alternative 1.

The need for the project is to reduce health risks for the residents of the City of Del Rio and some of the rural water utility customers of Val Verde County as well. The current status of the municipal water supply, periodically affected by high turbidity levels, requires that the raw water be treated to reduce potential health risks. At present the raw water supply from an artesian aquifer is classified by the TNRCC as groundwater under the direct influence of surface water (GWUDI), and is not filtered but is disinfected prior to pumping into the distribution system.

The consequences of not implementing the project are twofold. The first and most important is that by allowing the potential risks to public health to continue, the possibility of acute health problems exists. The second is the penalties which may be imposed by the TNRCC on the City of Del Rio for non-compliance with the terms of the TNRCC’s Agreed Board Order.

Human health impacts have already been addressed in the preceding subsections. Environmental hazards will not be created or increased by this project.

All communities, including the City of Del Rio, need a safe and dependable drinking water supply. In the past, the City has experienced occasional temporarily high levels of turbidity and periodic Coliform count, often following rainfall events on the upper reaches of the aquifer recharge area. Because the City’s raw water supply is withdrawn from two separate areas of San Felipe Springs, the East Springs and the West Springs, and the increase in turbidity normally varies by an increment of time between the two sources, the City has historically avoided turbid water intake by varying its withdrawal rates from the two sources during turbidity occurrences. By its ruling that both sources of raw water, the East Springs and the West Springs, are groundwater under the direct influence of surface water, the TNRCC has imposed the requirement that all of the City’s raw water must be filtered.

The best alternative to solve the problem of rapidly varying, broad range turbidity levels is the selection of a treatment process which can handle these conditions in as cost-effective a manner as possible. The membrane filtration treatment process has demonstrated success at meeting these treatment needs, and has therefore been selected as the preferred alternative.

The project will benefit all residents within the service area of the City’s municipal water system, including residents of several colonias in the rural areas of the county. Until recently, these colonias did not have access to a drinking water supply and the residents purchased bottled water for drinking and cooking.

The City of Del Rio has recently completed a project with the Texas Water Development Board in which they provided water and sewer service to the Cienegas Terrace Colonia. Cienegas Terrace is a colonia of about 400 lots with over half of them occupied. The water system that was in place was substandard and did not reach the full extent of the colonia. There were a number of wells used in the area in conjunction with a large number of septic systems on small lots that are just over 5,700 square feet. There was a grave health concern that prompted the TWDB to provide funds for the water and sewer project that was recently completed.

In the case of the Val Verde Park Estates Colonia, the lots are just under one half acre. There is no current sewer system available in the colonia. The sewer disposal is to septic tanks and cesspools. The water system in the colonia is undersized and of poor quality. The pipes are thin-walled and subject to breakage very often. The TWDB has assisted the City of Del Rio by providing grants to provide the replacement of the water system and installation of the water system. The most direct positive benefit for the recipients of the projects would be the disposal of sewer to a collection and treatment system and the distribution of water in lines sized adequately and not as subject to breakage as the current system.

As part of the TWDB projects for Val Verde Park Estates and Cienegas Terrace, there were provisions for connections to existing household on the date of application for the project. Any subsequent households that evolved after the project would be subject to application to the Community Development Program of the Texas Department of Housing and Community Affairs. The TWDB has developed the Colonia Plumbing Loan Program which enables the colonia residents to connect to the water and sewer lines as well as provides funds for the installation of plumbing for the residences. This program is currently being implemented very successfully by the County of Val Verde.

These colonias water supply projects include the extension of the City of Del Rio’s water distribution system to supply water to these areas. Consequently, the health of these colonia residents will also be at risk without implementation of the City of Del Rio Water Treatment Plant Project.

Because Del Rio is located on the border, it is a center for retail and wholesale trade for citizens on both sides. In addition, there is some level of transboundary employment on both sides of the border. Without implementation of this project, citizens of Ciudad Acuña, Coahuila, Mexico, who come to Del Rio for shopping or employment are also exposed to the potential health risks arising from an untreated water supply. Indirectly, it will benefit citizens on the Mexican side of the border when they are in Del Rio.

There will be a minimal impact to the Rio Grande water quality from the membrane filter backwash discharge, expected to be on the order of 2.0 mgd. The membrane filters will require periodic backwashing several times per day. Under normal operation, the membranes concentrate suspended solids (TSS) on the reject side of the membrane and reject these solids with the backwash stream. There is no increase in the solids mass of the San Felipe Creek flow, only a concentration in the backwash discharge where it is discharged back to the stream. The operation of the membrane filters will have absolutely no effect on the dissolved solids (TDS) in the stream; they pass through the membrane filters and therefore the TDS content of the reject or backwash stream is exactly the same as the TDS content of the raw water in the stream.

The City has proposed in its discharge permit application to the TNRCC the direct return of membrane backwash effluent to San Felipe Creek based on "negligible net stream impact" from this discharge. In addition, alternate dewatering and disposal of solids would add $1.5 to $2.0 million capital and O&M costs to the project. TNRCC has agreed to the direct discharge permit concept. Texas Parks and Wildlife and the U.S. Fish and Wildlife have been consulted continuously and have initially concurred with the "negligible net stream impact" concept. This approach will cause two different impacts to the water quality of the Rio Grande River, dependent on the condition of the raw San Felipe Creek stream flow.

Under normal conditions which occur 99.5% of the time (based on the raw water data presented in the PER), the turbidity level at the springs is < 1.5 Ntu (@ £ 3 mg/l TSS based on the historical 2:1 ratio of TSS:Ntu). For a combined springs and creek flow of 60 mgd with an assumed annual average WTP withdrawal of 20 mgd and a resulting 40 mgd downstream flow, and with membrane recovery of 90% (i.e., 10x concentration of membrane backwash solids) the following stream impacts result:

1USGS Water Resources Data—Texas, Vol. 2 , Surface Water: 1988-1996

During the remainder of the time, approximately 0.5%, and using conservative assumptions based on limited historic data during turbidity events as presented by the raw water data in the PER, the following stream impacts will occur. A springs turbidity spike of £ 200 Ntu (» £ 300 mg/l TSS based on the historical 1.5:1 ratio of TSS:Ntu @ elevated turbidity) and a £ 30 minutes duration is assumed. For a combined springs and creek flow of 60 mgd (which is actually likely to be greater after rainfall events typically associated with turbidity occurences), assume a 20 mgd WTP withdrawal with a 40 mgd resulting downstream flow, the following stream impacts will occur:

The above analysis shows that for the great majority of the time, approximately 99.5% of the total, there will be negligible impacts to both San Felipe Creek and Rio Grande River TSS solids levels. During a very small proportion of the time, approximately 0.5% (one-half of one percent), there will be a minimal impact of very short duration on the level of San Felipe Creek TSS, and a negligible impact on the TSS levels of the Rio Grande. In addition, the proposed backwash effluent discharge system includes constructed riparian wetlands at each of the two stream returns to enhance system performance, improving the natural stream conditions by removing TSS through filtration/sedimentation in the wetlands. The expected result is an actual decrease in suspended solids returned to the stream.

Regardless of the alternative selected, this proposed project will not consume onsite non-renewable resources and will not impact the environment in any appreciable manner other than during the construction phase. Construction equipment shall be required to be as environmentally protective as practicable, including implementation of noise limitation and dust control measures.

In contrast, this project will assist in the conservation of resources offsite by the reduction or elimination of potable water supply storage losses through the replacement of leaking ground storage tanks at the Bedell Street site, thereby reducing demands on finite groundwater resources.

No health statistics or other epidemiological studies showing a connection between the unfiltered water in the City of Del Rio’s system and health problems within the population are known to exist. The TNRCC has ordered the filtration of the City’s raw water as a preventive action taken as a preventive measure which is based on the Surface Water Treatment Rule (SWTR) of the federal Safe Drinking Water Act (SDWA) of 1974. The Administrative Order (AO) by TNRCC effectively states that unless the City of Del Rio provides water treatment of its drinking water by the established effective date, the residents shall be potentially exposed to unacceptable health risks, and the City may face civil as well as criminal penalties under both state and federal laws for failure to comply with the AO.

The U.S. Commissioner of the International Boundary and Water Commission, Hon. John W. Bernal, was notified by letter dated August 18, 1997. No other communication has taken place.

Copies of the Environmental Assessment for this proposed project have been circulated to both the U.S. Section and the Mexico Section of the IBWC.

The human health issue addressed by this project is the elimination of potential risks to public health and safety caused by periodic high turbidity in the untreated raw water supply. This has been mandated by the AO issued by the TNRCC to be on-line by approximately July, 1999. The environmental issue addressed is the conservation of natural resources through the reduction and elimination of potable water losses from the City of Del Rio’s ground storage tanks, and stricter enforcement of the City’s Water Conservation and Drought Contingency Plans.

This project will provide a high level of public health protection by eliminating potential health risks through the treatment process selected, membrane filtration, which is a physical barrier to contaminants. Environmental protection will be provided by close monitoring of process residual stream discharge to San Felipe Creek to prevent surface water resource contamination. Mitigation efforts have been incorporated into the membrane filter backwash discharge process to minimize impacts to San Felipe Creek’s habitat for endangered and threatened aquatic species.

There are no statistical, epidemiological, or other data connecting health problems to the currently unfiltered, disinfected water supply of the City of Del Rio. The proposed Water Treatment Plant is being mandated by the TNRCC under the requirements of the Surface Water Treatment Rule of the Safe Drinking Water Act.

Baseline data on raw water quality is provided in Section 1.0 of the PER. The data shows that for 99% of the time, the raw water quality from San Felipe Creek is well within drinking water parameters of the SDWA. Excursions of higher turbidity levels occur only during a very small time interval, usually a matter of hours, following intense rainfall events on the upstream reaches of the watershed. Finished Water Criteria are also provided in Section 3.0 of the PER

An Environmental Assessment is required under the U.S.’ National Environmental Policy Act (NEPA) because the City of Del Rio is applying for Border Environment Infrastructure Funds (BEIF) for both construction grant funds and transition rate subsidy grant funds for this project by the submittal of this Step II application for certification to the Border Environment Cooperation Commission (BECC). BEIF funds are federal funds budgeted by the U.S. Congress to the Environmental Protection Administration (EPA) which has authorized the funds to be administered through the BECC and the North American Development Bank (NADBank).

The project is located completely in the U.S. and thus will directly benefit U.S. residents only. Indirect benefits will accrue to Mexico residents when they are in the City of Del Rio for business, shopping, or entertainment purposes. For this reason, the project is not likely to have a significant transboundary impact. A marginal impact of a slight decrease in the level of solids in the Rio Grande from the San Felipe Creek flow contributed at the confluence is also likely.

An environmental assessment has been requested by the BECC which is intended to satisfy the requirements of the National Environmental Policy Act (NEPA) and which will assist in the determination of a Finding of No Significant Impact (FONSI) by the EPA.

Although no significant transboundary impacts are likely from this project, the City of Del Rio is only 5 miles from the international border and serves as a retail, wholesale, and employment center for residents on both sides of the border. While primary beneficial impacts are limited to the U.S. side, there will be secondary beneficial impacts on the Mexico side, also from reduced risk to public health and safety. There is also a very low possibility of minor impact to the Rio Grande water quality which is a transboundary issue.

The environmental assessment process has examined the affected environment as it may be impacted by the construction and operation of the proposed Del Rio WTP. The assessment includes a records search of available local, state, and federal environmental databases to identify recognized environmental conditions both in and adjacent to the project site.

The Environmental Assessment identifies probable positive and negative impacts of the project, including potential unfavorable transboundary effects which are minimal, consisting of slightly concentrated levels of pre-existing solids in San Felipe Creek and the Rio Grande River, and mitigation measures to minimize or eliminate any negative impacts. The net effects are a slight decrease of solids in the Rio Grande under normal stream conditions. The assessment also examines commitments of resources by the implementation of the proposed project, and compares alternatives available. The title of the document is Draft Environmental Assessment, Del Rio Water Treatment Plant.

An archeological/historical survey has been underway since September, 1997, and was completed in January, 1998.

The project will not have direct short-term or long-term impacts, either positive or negative, on the integrity, biological diversity, and sensitive environmental habitats of the existing ecosystem. No undeveloped land use is being converted by this project at this time. Potential cumulative effects of the project to sensitive environmental habitats may occur due to periodic increased levels of existing solids discharged to San Felipe Creek during periods of high turbidity in the raw water supply. However, these will only take place periodically, normally following rainfall events on the upstream watershed, when the solids level of the San Felipe Creek is already high, and Texas Parks and Wildlife (TPW) and U.S. Fish and Wildlife have indicated satisfaction with the City’s plan to alternate these higher levels of solids to the East and West Springs. The TPW initially concurs that the threatened or endangered aquatic species which inhabit the San Felipe Creek will not be compromised by these discharges, and consultation is ongoing with U.S. Fish and Wildlife for a final approval of proposed mitigation strategies both during construction and in the long-term during operation of the Water Treatment Plant.

Human health of U.S. residents will experience a direct positive impact from this project, both long-term and short-term, as well as cumulatively, because of the availability of a safe and dependable water supply. Indirectly, human health of Mexico residents will also benefit when they are in the City of Del Rio. The effects are discussed in greater detail in the Environmental Assessment document already mentioned.

The environmental benefits of this project will be increased conservation of limited regional groundwater resources through the elimination of leaking potable water ground storage tanks and increased enforcement of the City’s Water Conservation Plan. Any risks to existing endangered and threatened aquatic species in San Felipe Creek from the discharge of membrane filter backwash effluent during the operation of the proposed Water Treatment Plant have been mitigated by incorporating riparian constructed wetlands at the discharge point prior to the effluent release to the stream.

Costs of the project are expected to be paid by the City’s water utility ratepayers, which will experience a 130% to 140% increase in rates. For this reason the City is applying for construction grant and rate subsidy grant funding through BECC.

The environmental standards and objectives of the affected area which are to prevent loss or impact to sensitive habitat are expected to be met by this project which will provide a safe, dependable supply of drinking water to the community.

The proposed project does not have significant transboundary effects, other than the minimal one of solids levels contribution by the San Felipe Creek discharge at the confluence with the Rio Grande River. The net effect of this is normally a positive one. The combined flow of San Felipe Creek and the Rio Grande River result in a lowering of total suspended solids level in the Rio Grande River.

Because this Step II Application is for certification of eligibility to be considered for federal funds, the requirements of this Number 4 above (and Numbers 1, 2, and 3) must be met. The required Environmental Assessment under Numbers 1 and 4 has been submitted under separate cover. The environmental assessment process has examined the affected environment as it may be impacted by the construction and operation of the proposed Del Rio WTP. The assessment includes a records search of available local, state, and federal environmental databases to identify recognized environmental conditions both in and adjacent to the project site.

The Environmental Assessment identifies probable positive and negative impacts of the project, including potential unfavorable transboundary effects which are minimal, consisting of slightly concentrated levels of pre-existing solids in San Felipe Creek and the Rio Grande River, and mitigation measures to minimize or eliminate any negative impacts. An analysis of TSS levels shows that for the great majority of the time, approximately 99.5% of the total, there will be negligible impacts to both San Felipe Creek and Rio Grande River TSS solids levels. During a very small proportion of the time, approximately 0.5% (one-half of one percent), there will be a minimal impact of very short duration on the level of San Felipe Creek TSS, and a negligible impact on the TSS levels of the Rio Grande. In addition, the proposed membrane filter backwash effluent discharge system includes constructed riparian wetlands at each of the two stream returns to enhance system performance, improving the natural stream conditions by removing TSS through filtration/sedimentation in the wetlands. The expected result is an actual decrease in suspended solids returned to the stream.

The assessment also examines commitments of resources by the implementation of the proposed project, and compares alternatives available.

The proposed project has complied, or will comply, with all necessary environmental and cultural resource laws. The current status of compliance is indicated in the Table, REGULATORY COORDINATION SUMMARY of this document.

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