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. s <br /> Sam Monaco - 3 - 9 June 2017 <br /> Harvest-Lathrop Composting Facility <br /> b) Native area (Acres) sizing not supportable. The Discharger's water balance dated <br /> 10 April 2017 identifies 1.0 acres of native area draining to detention pond A and 2.7 <br /> acres of native area draining to detention pond B, both having a runoff coefficient of 0.3. <br /> However, construction drawing Grading and Drainage Plan (sheet 3) does not support <br /> the reported areas. The Discharger's water balance states that the pond A surface area <br /> is 83,600 sq. ft. (1.9 acres) and pond B surface area is 66,696 sq. ft. (1.5 acres). <br /> However the Grading and Drainage plan does not show native area draining to pond A <br /> and B amounting to anything close to that shown for the surface area of the ponds. <br /> Properly determining the size of the native area is crucial in the water balance since the <br /> native area uses a low runoff coefficient (0.3) and this area is used in calculating a <br /> weighted average runoff coefficient for the entire area draining into pond A (0.62) and <br /> pond B (0.60). <br /> c) Wet days per month (usage days). The Discharger's water balance dated 10 April <br /> 2017 identifies in column 8 the number of days per month that the Discharger will apply <br /> detention pond wastewater to compost windrows for operational use as well as for dust <br /> control. The Discharger's Water Balance Analysis section 5.2 determined the number of <br /> days where wastewater could be applied for operational use and dust control using <br /> historical data which provided the average number of days where precipitation was <br /> equal to or greater than 0.01 inches. The Discharger used the criteria of rainfall less than <br /> 0.01 inches to determine when wastewater could be beneficially reused. The Discharger <br /> proposes that during the wet season (November through April) 21 days per month will <br /> have favorable conditions where wastewater can be beneficially reused (i.e., not <br /> removed for waste disposal purposes). However, using average number of days per <br /> month during an average wet season when the water balance is based on the wettest <br /> year is incorrect. The Discharger should use the number of days available during the <br /> wettest year. Stockton Metropolitan Airport (KSCK) rainfall data obtained from <br /> https://www.wunderground.com/ reports a total of 18.25 inches for the 2016-2017 wet <br /> season from November through April which approaches the wettest year precipitation <br /> total reported in the Discharger's water balance (21.1 inches). During that period, KSCK <br /> reported 9,10,17,16, 9, and 10 days equal to or greater than 0.01 inches from November <br /> through April, respectively. In December there were 10 days, in January there were 17 <br /> days, and in February there were 16 days. During these months, the opportunity to use <br /> wastewater for operational and dust control purposes is very limited. <br /> d) Operational Use. The Discharger's water balance estimates that 30,000 gallons of <br /> wastewater will be removed daily from pond A for operational use in accelerating <br /> decomposition of organic matter in the compost windrows and 20,000 gallons will be <br /> removed daily from pond B. As stated in paragraph 3c above, the Discharger estimates <br /> that during 21 days per month through the wet season, the compost windrows will need <br /> additional water to accelerate the decomposition process. Based on 70% of the working <br /> area covered with compost material in windrows (see paragraph 3a above), the windrow <br /> area discharging to pond A is 12.46 acres and the windrow area discharging to pond B is <br /> 6.16 acres: The application of 30,000 gallons to 12.46 acres amounts to 4,010 cubic feet <br /> of wastewater applied to 12.46 acres per day or 0.007 inches of wastewater applied over <br /> 542,757 ft2 of area. As stated in paragraph 3c above, in December there were 10 days, <br /> in January there were 17 days, and in February there were 16 days where rainfall totals <br /> exceeded 0.007 inches. During these months, the opportunity to use wastewater for <br /> operational use is unnecessary. The same calculations can be made for the water needs <br /> 3r1IA°' <br />