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0 <br /> Messers. Chinchiolo and Stonebarger -2 - 1 October 2004 <br /> are concerned that limiting the sampling effort to a period from October to November will result in <br /> inadequate characterization. <br /> • The description on identification of wastestreams is inadequate. The reader has no indication of <br /> the methods used to identify wastestreams. As described above, the failure to identify water <br /> treatment processes such as ion exchange water softening indicates the identification is incomplete. <br /> In addition,the table presented in Attachment B is labeled"draft." <br /> • There is no substantial determination of flow from various site activities. The Draft Waste Stream <br /> Study Categories table contained in Appendix B presents estimated volumes per period and <br /> number of dumps per year. There is no discussion of how the factors presented in the table were <br /> established. <br /> • The analyte identification and analytical testing program discussion is inadequate. Staff notes that <br /> basic parameters used in wastewater characterization such as Biochemical Oxygen Demand <br /> (BOD), Total Kjeldahl Nitrogen (TKN), and other parameters were not included in the analytical <br /> program. At a minimum, each wastestream should be evaluated compared to the list of analytes in <br /> the Monitoring and Reporting Program(MRP)transmitted in the tentative Waste Discharge <br /> Requirements (WDRs) and if those analytes are likely to be present, they should be included in the <br /> sampling program. Other analytes that may be present based on the evaluation of the chemicals <br /> added to wastewater should be added as needed. Please refer to the 24 June 2004 tentative MRP <br /> for a list of analytes typically included in wastewater sampling plans. The analytical testing <br /> program information should include a list of,samples to be collected, analytical methods, sample <br /> containers, sample preservatives, and holding times. <br /> • No discussion of wastestreams that will not be available due to the schedule limitations is <br /> provided. Those wastestreams should be identified and wastewater quality estimated with <br /> supporting documentation. <br /> Preparation of WDRs has been delayed at Chinchiolo Stemilt California's (CSC's)request to allow <br /> collection of data needed to design the wastewater system. The 21 September 2004 Wastewater <br /> Characterization Workplan will not result in adequate characterization to resolve questions on flow and <br /> quality. Continued failure to present realistic investigation workplans will result in staff recommending <br /> enforcement actions, including the imposition of Administrative Civil Liability. By 15 October 2004, <br /> CSC shall resubmit the Wastewater Characterization Workplan. In the meantime CSC shall implement <br /> studies deemed necessary by your consultants to allow design of your wastewater treatment system. <br /> If you have any questions, or wish to schedule a meeting to discuss these issues,please telephone me at <br /> (916)464-4616. <br /> TIMOTH . O'BRIEN <br /> Waste Discharge to Land Unit <br /> cc: Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> Jeffory J. Scharff, Esq., Sacramento <br /> Chip Walker,Neal O. Anderson and Associates, Lodi <br /> WtSl nonTan JoquiaTl=luolo FmftTNwMolu)0 SW W.4 <br />