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Deanna Walsh • - 3 - 8 October 2002 Mossdale Landing Draft EIR is our understanding in discussions with the RWQCB that discharge waters can be impounded on the surface, percolate into the ground, and eventually seep into an existing drainage ditch used by local farmers." That statement is not referenced so the personal quote is unknown. Waste discharge to land typically must not degrade groundwater quality, must be controlled to prevent escape from the storage area, and must not produce nuisance conditions. Discharge of wastewater into drainage ditches would require a National Pollutant Discharge Elimination System permit. • Section 7 of the Kleinfelder report states, "...embankments approximately 10-feet above the original grade may be needed." As previously discussed, such impoundments may require approval of the construction of the ponds by the Department of Water Resources, Division of Dam Safety. • The Kleinfelder report does not tabulate the analytical results of groundwater sample chemical analyses. Laboratory reports for two sample events are included in Appendix C of the report, but presentation of the data should allow review without requiring readers to create data tables. In addition, Section VI of the Kleinfelder report describes four sample events from 25 January to 13 June 2001, only data from 27 February 2001 and 16 April 2001 are included in the report. Presentation of incomplete groundwater monitoring data does not allow evaluation of the groundwater conditions. The following discussion provides information on permits required by the Regional Water Board for the project. Waste Discharge Requirements Because wastewater will be generated and treated, stored, or disposed on site, Waste Discharge Requirements (WDRs) will be required. The project proponent shall submit a Report of Waste Discharge (RWD) at least 120 days prior to discharging wastewater at the site. California Water Code Section 13260 requires submittal of the RWD. If groundwater dewatering is required, the owner/operator must first obtain an NPDES permit prior to initiating dewatering activities. If discharge of wastewater to surface water is anticipated, a complete Report of Waste Discharge is required Objections to the WDRs may cause significant delays in the adoption of WDRs by the Regional Board. The Regional Board staff previously submitted comments to the City of Lathrop (see attached letter dated 16 December 1999) regarding a proposed NPDES discharge, outlined several concerns regarding the process, and requested additional information if the process were to proceed. The long term wastewater disposal needs for the community need to be resolved, and appropriate permit limitations established before subdivisions are approved for development. Construction Siormwater Permit A NPDES General Permit for Storm Water Discharges Associated with Construction Activities, Order No. 99-28-DWQ is required when a project involves clearing, grading, disturbances to the ground, such as stockpiling, or excavation. Currently, construction activity that involves soil disturbances on construction sites five acres or greater or which are part of a larger common plan of development or sale require a construction storm water permit. Because construction associated with the project will disturb more than five acres, the property owner needs to obtain permit coverage under the NPDES General Permit No. CAS000002 for Discharges of Storm Water Associated With Construction Activity. Before construction begins, the proponent must V\Sen_Joaquin_Non i5\ uJffi0bnenWMjaut Res\SitesWix.Cou\Suva Clearinghoux\Wdsh092303.doc