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Lee Gardiner - 2 - 28 December 2004 CALAMCO San Joaquin County 3. Attachment C Item 3. states "The Discharger shall amend the SWPPP whenever there is a change in construction, operation, or maintenance which may effect the discharge of significant quantities of pollutants to surface water, groundwater, or the local agency's storm drain system. The SWPPP should also be amended if it is in violation of condition of the permit, or has not achieved the general objectives of controlling pollutants in the discharges." The Discharger has not amended the SWPPP in response to on-going discharges of ammonia to the storm drain system. B. Heat exchanger failure detection: There has not been a scientific evaluation or theoretical calculation of the lower detection limits of the failure monitoring system, to support the capability of the current failure detection system to alert the Discharger of a heat exchanger failure less than catastrophic. The detection system has not been calibrated or tested to verify that it can detect ammonia discharges of a known concentration. We remain concerned that the system cannot detect any ammonia discharge other than that from a catastrophic failure. C. Product inventory reconciliation information request: One additional means for determining the likelihood that products may have been released to the environment is for the Discharger to provide an accounting or mass balance of the amount of ammonia products received, the amount stored, the amount distributed, and the amount assumed released to the environment on a regular basis, such as annually. We believe that this information will provide another means of assessing the need for additional controls on the operations at the facility. Because the Discharger's storm water shows high levels of pollutants and the wastewater ammonia leak detection system has an unknown detection limit and no means to perform a routine operational system test, pursuant to Section 13267 of the California Water Code, CALAMCO is ordered to submit a technical report by 1 April 2005, describing how it will comply with Order No. 96-201, and shall include the following: 1. Ammonia leak detection calibration: a. Calculations shall show at what ammonia concentration the pH changes enough to be detected by the leak detection system; b. Calculations shall include varying ammonia concentrations stepped incrementally to show the leak detection system response for all reasonable scenarios; c. Calculations shall incorporate background ammonia; d. Calculations shall use incrementally stepped influent temperature and pH values for each ammonia concentration to demonstrate the system detection limits; 2. An updated Storm Water Pollution Prevention Plan ; a. Include a site schematic of the storm water collection system (showing collection points and piping to the port's storm water system); b. Show all areas where the possible release of oil and grease and ammonia could take place (i.e., truck loading docks, rail loading platform, and other transfer/handling/release areas);