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• California R•oval Water Quality Control Board Central Valley Region 1 Robert Schneider,Chair Winston H. Hickox Gray Davis Secretary for Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gav/-mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 0 t= 1 July 2002 v Mr. Ben Hall Mr. Felix Mus69 _ Musco Family Olive Company , Studley Company 17950 Via Nicolo 17950 Via Nicolo Tracy, CA 95377 Tracy, CA 95376 COMMENTS ON THE STORM WATER POLLUTION PREVENTION PLAN FOR THE MUSCO FAMILY OLIVE COMPANY, TRACY,SAN JOAQUIN COUNTY On your behalf, HDR Inc. has submitted the May 2002 Draft Storm Water Pollution Prevention Plan (SWPPP) and Monitoring Requirements for the Musco Family Olive Company(Musco) in Tracy, San Joaquin County. Musco submitted the SWPPP to comply with the National Pollutant Discharge Elimination System Permit No. CAS000001, Water Quality Order No. 97-03-DWQ, Waste Discharge Requirements for Storm Water Discharges Associated With Industrial Activities (General Industrial Permit). hi addition,Musco submitted the SWPPP in accordance with our 30 November 2001 Notice of Violation and 15 May 2002 letter. Our comments on the SWPPP are presented below. 1. Page 3, Stormwater Originating from the Facility The SWPPP states that the property can be characterized into three discrete areas as shown in Figure 1 and described in Table 1 as follows: Area 1 consists of 23 acres of impervious and pervious areas surrounding the facility; Area 2 refers to 223 acres of land application area; and Area 3 refers to the impervious areas where contaminated materials may exist. In addition, Table 1 provides the time of concentration, average slope, and weighted SCS runoff coefficient. The SWPPP also states that storm water from Area 1 is typically uncontaminated and discharged from the property; Area 2 storm water is contaminated and contained on Musco property; and Area 3 storm water is potentially exposed to hazardous substances and is contained on Musco property. Figure 1 should be revised to clearly delineate Areas 1-3, the drainage patterns in each area, and the fate of wastewater, storm water, or non-storm other than wastewater in each area. Figure 1 also needs to show more areas to the south of the southernmost land application area (south of the reservoir). California Environmental Protection Agency 0a Recycled Paper The energy challenge facing California is real.Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can do to reduce demand and cut your energy costs,see our Website at http://www.swrcb.ca.gov/mgcb5.