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Mr. Jeffrey Palumbo • - 2 - 15 November 2005 agency, either a principal executive officer or ranking elected/appointed official must sign. Title 27, California Code of Regulation, Division 2 (Title 27) Section 21740 SWRCB —Waste Characteristics 4. Title 27 §21740 (a)(1) Constituents and Reference Numbers. Requires types, quantities and concentrations of wastes proposed to be discharged to the brine evaporation ponds. Appendix A includes a list of parameters and their respective concentrations. How were these concentrations derived? Please provide in more detail the types and quantities of chemicals to be used in the RO treatment. Concentrations of sulfuric acid (2,601 mg/L) and sodium bisulfite (2,000 mg/L) are provided. What do these numbers represent? Is there laboratory data that can be provided to support the given concentrations? Is the RO treatment facility operating 24-hours per day, thereby generating 7200 gallons per day of brine waste? 5. Title 27 §21740(a)(2) Treatment, Storage and Disposal Methods (TSD). Very little detail was provided for the TSD. How will the brine be removed from the ponds such that the liner design is not compromised? What type of removal schedule is anticipated? How will the ponds be operated? This information shall be included in the Operations Plan pursuant to Title 27 §20375(b) Section 21750 SWRCB —Waste Management Unit Characteristics 6. Title 27 §21750(d)(1) Topography. The location of the evaporation ponds should be included on the topographic map.. 7. Title 27 §21750(d)(2) Floodplain. A FEMA map was provided in the RWD and the facility is located within the 100-year flood zone. The RWD shall include an engineering analysis to indicate the various hydrodynamic and hydrostatic forces expected to result at the site as a consequence of a 100-year flood. Structural and engineering studies shall be provided showing the design of the flood protection devices at the facility and how these devices will prevent washout and inundation from a 100-year flood event. The ponds shall be designed, constructed and operated to prevent inundation or washout due to floods with a 100-year return period. Class II surface impoundments and related containment structures shall be constructed and maintained to prevent,to the greatest extent possible, inundation, erosion, slope failure, washout, and overtopping under 1000-year, 24-hour wet season precipitation conditions, and shall be designed to contain the 100-year wet season precipitation (in back to back wet seasons)without using the two feet of freeboard. 8. Title 27 §21750 (e)(3) Climatology-Design Storm. The design storm is provided for the San Francisco Storm Return Period. Please provide justification for using this information for a different geographical location rather than data collected in the Tracy area. 9. Title 27 §21750 (e)(5) Runoff Volume/Pattern. This information required in this section should be included in the design of the surface impoundments.