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vCalifornia Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair C�I �I' ,, - (a TerryTamminen —_ 7a 1"�f,9AoldSchwarzene er Secretaryfor gg Sacramento Main Office �� Governor Environmental Protection Internet Address: http://www.sWcb.ca9ov/—Mgcb5QC r qq .11020 Sun Center Drive,#200,Rancho Cordova,CA 956706114 Q 5 6 0�� Phone(916)464.3291 •FAX(916)464.4780 ENVIR 1 October 2004 PER" �LE Mr. Tom Chinchiolo Mr. Larry Stonebarger Chinchiolo Stemilt California Chinchiolo Stemilt California 4799 N. Jack Tone Road 4799 N. Jack Tone Road Stockton, CA 95215 Stockton, CA 95215 INADEQUATE WASTEWATER CHARACTERIZATION WORKPLAN, CHINCHIOL0 STEMILT C4LIFORNI4,SAN JOAQUIN COUNTY Regional Board staff have reviewed the 21 September 2004 Wastewater Characterization Workplan prepared by Neil O. Anderson and Associates and determined it is inadequate. The workplan was required to be submitted no later than 27 September 2004 by the 26 August 2004 California Water Code (CWC) Section 13267 Order signed by the Executive Officer. It is noted that the text of the workplan is less than two pages. The workplan does not address the items listed in the CWC Section 13267 Order, which stated: By 27 September 2004, the Discharger shall submit a Wastewater Characterization Workplan that will result in identification and classification of all wastewater streams. The workplan shall include a schedule of implementation, method of identification of wastewater streams,flow determination methods, analyte identification, analytical testing program, and description of the technical report. If wastestreams are identified that will be unavailable to sample during the study period, estimates of the wastewater quality shall be provided. The workplan shall be implemented immediately upon submission and modified ifrequested upon staffreview. Staff has identified the following items that require explanation: • The workplan does not adequately describe site activities, which must be described both to determine where samples should be collected and when samples should be collected. In addition, the workplan should identify wastestreams that will not be available for sampling due to the project schedule and state how those wastestream qualities will be estimated. The failure to identify site activities will result in inadequate characterization. For example, the workplan doesn't mention ion exchange water softening even though it was identified in the 29 January 2004 Report of Waste Discharge. Depending on the use of water softeners, they can have substantial impacts on wastewater quality. • The schedule presented in the workplan does not compare the sample collection to the products being processed, therefore it is impossible to determine if the characterization is adequate. It is noted that the Wastewater Characterization Report required by the 13267 Order is due on 15 February 2005, but the sampling effort will be completed by the first week of November. Staff California Environmental Protection Agency 00 Recycled Paper