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Cary Keaten 3 • 26 January 2004 <br /> 8. References to land application of biosolids are present in the RWD. Please fully describe the plan <br /> for applying biosolids and show that it will be protective of water quality. <br /> 9. The groundwater quality data presented in Attachment 7 is not adequate to allow review. The <br /> summary of groundwater quality is taken from a regional groundwater investigation. Site specific <br /> studies have been performed at the site; that data must be summarized and presented in a format <br /> that allows reasonable review of the data. The reports contained in Appendices 1 through 5 <br /> contained a minimum amount of data on groundwater quality(a total of three tables and data from <br /> only two wells) and cannot be relied upon to characterize the wastewater storage and application <br /> areas. All relevant data must be presented in tabular and graphical format. The data shall be <br /> interpreted to determine groundwater flow directions and quality trends for each storage or <br /> application area. The assumption contained in Attachment 7, "Considering the fact that Mossdale <br /> Landing is located next to Lathrop Station it would be reasonable to assume that is has similar <br /> characteristics as observed in Lathrop Station,"is not supported by any data and is not acceptable. <br /> 10. Provide further information on the groundwater monitoring wells that exist at the sites, including: <br /> a. A summary table summarizing each well's construction information, <br /> b. A summary table presenting all depth to groundwater and groundwater elevation data. <br /> c. A summary table presenting all analytical data collected. For some analyses that contain <br /> numerous analytes (such as EPA Method 8010), summarization of the results can be <br /> presented. <br /> d. A figure that presents the locations of the monitoring wells and all storage or land application <br /> sites that allows evaluation of the monitoring network. If wells have not previously been <br /> sampled, but are considered appropriate for monitoring purposes,please sample those wells <br /> and include the data prior to resubmitting the RWD. At a minimum, groundwater monitoring <br /> wells must be present at all land application areas and storage ponds. It may be possible to <br /> design a regional groundwater network that accomplishes the required task. <br /> 11. Please perform an evaluation of the loading rates for biochemical oxygen demand(BOD),total <br /> nitrogen, and total dissolved solids. The evaluation should present the average and maximum <br /> loading rate for BOD, annual loading rate for nitrogen, and the annual loading rate for TDS. <br /> Compare the loading rates for nitrogen and TDS to the anticipated crop uptake rate and if the <br /> loading rate exceeds the uptake rate, explain how the application is protective of groundwater <br /> quality. Because depth to groundwater is shallow in many of the proposed land application areas, <br /> any attenuation factor that is employed in the explanation must be conservative. <br /> 12. Please update the status of the requested Federal Emergency Management Agency(FEMA) map <br /> revision. It should be noted that wastewater ponds cannot be located within 100 year flood zones <br /> unless they are designed to prevent inundation and washout during 100 year flood conditions. <br /> 13. Three water balances are presented; one each for Mossdale Landing,Lathrop Station, and River <br /> Islands. Please combine the water balances into one master water balance. For review purposes, <br /> staff focused on Table 7-1. I have the following comments on the water balance: <br /> a. Please revise the titles of the water balance to remove the Phase H reference. <br /> V,Iao Joo,a_Non l%UMbnen MJo in%nftn,_ WTP ER PhewN 000 22 Jm dEon <br />