SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Messrs. Mark Madison and Thomas Flinn - 2 - 29 June 2004 • Page 34 states that bacteria monitoring will be conducted at strategic locations; however, the plan doesn't appear to provide the criteria for selecting these locations. The number of outfalls that will be monitored for a given water body is provided; but how many outfalls are there for each water body?What are the drainage areas for monitored outfalls and unmonitored outfalls? What are the land uses for monitored outfalls and unmonitored outfalls? Are some outfalls inaccessible for sampling? Since selection of sampling locations is so critical, this information should be presented in the plan. • Page 36 presents the two approaches of source identification studies: Location tracking and microbial source tracking. While these studies should certainly be designed to detect undiscovered pathogen sources, another goal should be to determine the contributions and relative significance of suspected sources (as listed on Page 27). We believe the plan should therefore include a discussion of how the two source ID studies can distinguish between suspected sources and determine their relative significance. This issue seems implicit in the description of the source ID studies; however, a more explicit discussion would better explain the Permittees' intent. • Section 4.6 is vague on what deliverables the Regional Board can expect. We presume the annual reports will contain updates on the progress of the pathogen studies. We'd prefer a final report broken out for each water body upon completion of its study, these final reports could be appendices to the annual reports. The plan should be revised to specify the Permittees' intent with regard to reporting. Pursuant to the MS4 permit, the Pathogen Plan requires approval by the Executive Officer(EO). We will not recommend EO approval until the issues discussed herein are resolved. Please revise the Pathogen Plan as appropriate in response to the above comments. If you disagree with any of staff's requested revisions,please contact Brett Stevens at your earliest convenience to explain why some revision is inappropriate, and to resolve any issues raised. We'll expect the revised plan to be submitted by 18 August 2004. If you have any questions,please contact Brett Stevens at (916) 464-4642. GEORGE D. DAY Senior Water Resource Control Engineer cc: Donna Heran, San Joaquin County Environmental Health Bill Jennings,Delta Keeper Charles Kelley, San Joaquin County Amin Kazemi, City of Stockton Fred Lee, G. Fred Lee &Associates Malcolm Walker, Larry Walker Associates