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Draft Sampling &Analysis Plan - 5 - 13 July 2022 <br /> Stockton Propeller, Inc. <br /> 2478 Wilcox Road, Stockton <br /> feasible. Additionally, Central Valley Water Board staff recommends documenting <br /> whether the influent compartment is stratified (scum on the top, liquid in the middle, and <br /> sludge on the bottom). If the influent compartment is not stratified, it may be an <br /> indication the tank is not processing the waste properly. <br /> COMMENT 7 <br /> Issue: The Draft SAP continues to neglect to include analysis for trihalomethanes from <br /> the septic tank and pH from the groundwater samples. Central Valley Water Board staff <br /> previously commented on the prior version of the SAP (Central Valley Water Board, <br /> 2022a). Comment 1 listed several analytes to be analyzed from samples collected from <br /> the septic tank contents, soils surrounding the septic tank, and groundwater. The <br /> comment included trihalomethanes from the septic tank and pH from the groundwater <br /> samples. Additionally, Central Valley Water Board staff requests collecting other field <br /> groundwater quality parameters, such as oxidation reduction potential (ORP), turbidity, <br /> etc. <br /> Requested Action: Revise the Final SAP to include the analysis for field groundwater <br /> quality parameters, including pH. Central Valley Water Board staff are amenable to <br /> retracting the request to sample for trihalomethanes at this point due to likely limited <br /> benefit. <br /> COMMENT 8 <br /> Issue: The Draft SAP states samples will be analyzed using the United States <br /> Environmental Protection Agency (USEPA) Test Methods for Evaluating Solid Waste: <br /> Physical/Chemical Methods Compendium (also known as SW-846). However, the Draft <br /> SAP neglects to specifically state which of the SW-846 methods will be used. <br /> Requested Action: Revise the Final SAP to include the specific USEPA method for each <br /> class of samples. For example, Central Valley Water Board staff identified the following <br /> SW-846 methods for analysis of toxicity characteristic leaching procedure (TCLP) <br /> Ieachates and groundwater analysis that may be appropriate. <br /> 1. Metals/ TCLP Scan- USEPA Method 1311/6010C <br /> 2. Chromium VI- USEPA Method 7196A <br /> 3. pH- USEPA Method 9040C/9045D <br /> 4. Volatile Organic Compounds (VOC)- USEPA Method 8260D <br /> 5. Semi-Volatile Organic Compounds (SVOC)- USEPA Method 8270E <br /> 6. Total Petroleum Hydrocarbons- USEPA Method 8015C and/or 8260D <br /> 7. Cyanide- USEPA Method 9010 or 9014 <br /> COMMENT 9 <br /> Issue: The Draft SAP compares two composite samples collected from the septic tank <br /> contents by SPI staff on 20 December 2021 to the CCR, title 22, section 66261.22 <br /> (characteristic of corrosivity) and CCR, title 22, section 66261.24 (characteristic of <br />