SITE INFORMATION AND CORRESPONDENCE

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Cary Keaten • -4- • 9 August 2004 Mossdale K-8 School, etc.)no groundwater monitoring wells are located near the land application or wastewater storage areas. The analytical data is also incomplete and the data that is provided varies in the analytes that are presented. In the 26 January 2004 Incomplete Draft Report of Waste Discharge correspondence, staff requested "...data must be summarized and presented in a format that allows reasonable review of the data," and"All relevant data must be presented in tabular and graphical format." While the July 2004 RWD includes significantly more data than the previous RWD, it also fails to present all the data that is available. For staff, knowing all the data that is available is impossible,but figures in the RWD indicate more data than what has been presented exists. This is especially evident for groundwater elevation data as discussed below, but the analytical data has not been clearly presented either. Because groundwater elevation and chemical concentrations often vary with season, it is important to indicate when the data was collected. This information is often not presented. In addition,the quality of the data is questionable. Staff notes that with the exception of the Reiter Property wells, no workplans for groundwater monitoring have been submitted for this project. As a result, staff have no information on the wells that are being used for monitoring, their construction, when they were installed, if they are appropriate for monitoring the first saturated interval, etc. Dates for collection of groundwater samples are not provided and unusual techniques were employed in evaluating groundwater elevation data. For example, the most critical groundwater elevation data should be collected in the winter and spring when groundwater elevations are likely to be the highest. However Figures A-39 and A-40 in Attachment 7 include the note, "Actual groundwater elevation on 4/16102 not available for Luckey Property. Water elevation was estimated from groundwater levels recorded on the Terry Property site and extrapolated using an estimated+0.3 feet elevation differential, as seen between April and July 2002 data at Terry Property." Reliance on such an approach when designing land application areas is questionable. If the assumption of a 0.3 foot increase proves incorrect, land application areas may not be available for wastewater application as a result of reduced infiltration or soil saturation. Staff also note the Luckey wells (from which data is not available), make up 11 of the 16 wells presented on Figures A-39 and A-40. In addition, it is not clear why data from 16 April 2002 is being referenced on figures that indicate the data being presented is from February and March 2004. Please clarify the drawings, remove inappropriate data, and present all data that is included on figures in tables to allow staffs review. 15. The RWD should discuss the variability of groundwater quality. Have previous land uses impacted groundwater quality? This will become an important issue for the Discharger when land application of recycled water begins; degraded groundwater may trigger further engineering studies and possibly prohibition of future use of the land application area. 16. The RWD does not discuss whether the Discharger has applied for coverage or submitted a Notice of Non Applicability for Order No. 97-03-D WQ, Discharges of Stormwater Associated with Industrial Activities. Please clarify this issue. Wifi ficvP5e Jo"tLLftW p_WW RPN N ton Aug Oa.p