Telephone (530) 261-1414

LAW OFFICE
of
CLIFTON E. SCHOEDL, JR.
1120 Neptune Way
Mount Shasta, California 96067

March 20, 2018

City Council of the City of Mt. Shasta

305 North Mt. Shasta Boulevard
Mt. Shasta, CA 96067

Re: Crystal Geyser Water Company – Industrial Waste Discharge Permit Application

Dear Members of the City Council:

This office represents local organizations Water Flows Free and Mt. Shasta Tomorrow with
respect to the Crystal Geyser Bottling Plant (“Project”) and this Project’s request to connect the
facility to the City of Mt. Shasta’s sewer system.
I am writing to let you know that the discharge of harmful and dangerous chemicals into the
ground/sewer system from newly proposed cooling towers and other equipment has to be addressed.
The risk of serious water pollution due to hazardous chemicals released by industrial cooling
towers is well-established from the Erin Brockovich case, Anderson v. PG&E (File No. BCV 00300),
which resulted in an out-of court settlement paid by PG&E in the amount of $333 million for the
plaintiffs. The results of this lawsuit were dramatized by the widely-known film “Erin Brockovich”.
(See Attachment #1 for a history of that case entitled, “Erin Brockovich”)
Mt. Shasta officials have the duty to be aware of and be especially careful to protect our
community’s water. It is unconscionable for Crystal Geyser not to have disclosed the issues of
cooling tower discharges during its initial draft EIR preparation that such cooling tower discharges
were intended.
The City Council’s February 26, 2018 Agenda packet contains a draft version of this Project’s
“Industrial User Permit with Track Changes” that has been altered in material ways. These changes
pose substantial environmental risks that are required to be addressed and analyzed under CEQA
before approval of this sewer permit. (See Attachment #2, excerpts from amended draft sewer permit)
Crystal Geyser’s sewer permit application was amended in February 2018 to allow the
discharges of condensate from an oil-free compressor, cooling tower “blowdown” water, and boiler
“blowdown” water. These industrial discharges most likely contain hazardous and toxic substances
which were not disclosed in the draft 2016 version of this sewer permit application that was included
in the Project’s 2017 Final EIR. (See Attachment #3 for relevant excerpts from the 2017 EIR’s draft
sewer permit application)
This EIR neglected to evaluate the risks that such compressor condensate, “blowdown” water
chemicals and toxins could cause to local groundwater or the City's sewer system from potential anti-
scaling chemicals, corrosion-inhibitors, or biocides. These new changes pose significant
environmental risks, as evidenced in the enclosed attachments. (See Attachments #4)
The City of Mt. Shasta Municipal Code Section 13.56.320 prohibits such condensate or
“blowdown” water discharges to the City’s sewer system. At this time, making such an approval of