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California Rfgional Water Qualitytontrol Board - Central Valley Region ; 1 Robert Schneider,Chair Winston I1. Ilickox Grav Davis Senrraryfor Sacramento Main Office Governn Environmental Internet Address: http://www.sw b.ca.gov/mgcb5 Prolection 3443 Routier Read.Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 - �U 18 December 2002 DEC 1 9 2002 Mr. Benjamin Hall Mr. Nick Musco ENVJRDfVMEjV i HEALTH Musco Family Olive Company Studley Company PERMIT/SERVICES 17950 Via Nicolo Road r-�'aN 17950 Via Nicolo Tracy, CA 95376 �or-0q4 Tracy, CA 95376 REPORT RESUBMITTAL REQUIREMENT, STORMWA TER BYPASS CRITERIA, MUSCO FAMILY OLIVE COMPANY, TRACY, SAN JOA Q UIN CO UNTY I have reviewed the 25 November 2002 Report of Stormwater By-Pass Criteria prepared by Musco Family Olive Products. The report presents sample locations and data analysis comparison criteria to determine the acceptability of bypassing stormwater around the 84-million gallon storage pond (84-Mgal pond). The report was submitted in accordance with Waste Discharge Requirements (WDRs) Order No. R5-2002-0148. In general, staff is concerned about the accuracy of field instruments for characterization of stormwater prior to allowing discharge. Because the WDRs do not allow discharge of wastewater constituents, bypass of stormwater with residual concentrations of wastewater constituents would constitute a violation of the WDRs, Cleanup and Abatement 9rder No. R5-2002-0149, and Time Schedule Order (TSO)No. R5-2002-0014-ROI. Violations of the orders may result in civil liability as described in Water Code Section 13385 and the TSO. I have the following comments on the report: • The report is not signed or stamped by a licensed engineer or geologist as required by WDRs Provision G.1. Please resubmit the report with the appropriate stamp and/or signature that indicates the professional responsibility for the report. • Determination of the constituent concentrations in the field may not be possible due to detection limits or the availability of field tests that provide suitably accurate results. In order to allow Regional Board staff to evaluate the proposed sampling plan, for each parameter listed in the table please describe the analytical technique, sample containers,preservatives, and holding time. If field instruments will be used to collect the data describe the instrument, calibration, and test accuracy. • As described in the 9 May 2002 meeting with HDR,Inc. and reiterated in the 1 July 2002 Regional Board correspondence on the May 2002 Stormwater Pollution Prevention Plan, determination of the stormwater quality must include the analytes ammonia,nitrate, total Kjeldahl nitrogen,biochemical oxygen demand, chemical oxygen demand, electrical conductivity, pH, and total dissolved solids. If you can demonstrate a reliable correlation between parameters (for example electrical conductivity and total dissolved solids, or biological and chemical oxygen demand) staff will consider alternative California Environmental Protection Agency ea Recycled Paper The energy challenge facing Califomia is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5