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principles of Hantzsche-Finnemore Equation are still valid,but a rearrangement of terms and <br /> calculations is needed to more reasonably estimate the resultant nitrate-nitrogen percolation <br /> value. I recommend revising the analysis per the methodology outlined in Attachment 1. <br /> 2. Other Comments. Other comments that may or not be pertinent following recommended <br /> adjustment the methodology(Comment 1) are: <br /> a. Wastewater Flow. On page 7,the wastewater flow projection used for the analysis is <br /> stated as 600 gpd.This does not agree with the information from Siegfried,which <br /> estimates the wastewater flow to be 960 gpd. <br /> b. Precipitation Data(Table 4). The values for monthly precipitation values for the Tracy <br /> area in Table 4 (page 6) are labeled"2 years in 10"data from the Soil Survey of San <br /> Joaquin County. They are stated to be"conservative"(i.e.,lower)as compared with <br /> average precipitation amounts;but they are actually significantly higher than average <br /> monthly precipitation amounts for Tracy. The total of the individual monthly amounts <br /> equals 19.54 inches,well above the annual average precipitation for Tracy (10 to 11 <br /> inches). The total given at the bottom of Table 4 is correctly copied from the source <br /> document(Soil Survey), but I believe it represents the"2 in 10 years"annual total,which <br /> is different from the total of the individual monthly values list. The average monthly <br /> precipitation values should be used in the nitrate loading analysis instead of the"2 in 10 <br /> years"values listed in Table 4. <br /> c. Annual Rainfall-Recharge Value.In Table 4 the estimated value for rainfall-recharge <br /> ("deep percolation")is given as 2.21 inches per year. However, in the calculations that <br /> follow(bottom of page 8), a value of 9.5 inches per year is inserted for R,without any <br /> rationale or reference. <br /> 4 <br />