SITE INFORMATION AND CORRESPONDENCE

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Mr. Ben Hall • - 4 - • 1 July 2002 9. Page 12, Description of Potential Pollutant Sources, Land Application System The SWPPP states that 0.5 million gallons per day(MGD) of wastewater would be applied to land. However, the 24 June 2002 Report of Waste Discharge (RWD) addendum proposes to apply a weekly average of 0.525 MGD and a maximum of 0.65 MGD from November to March, and a weekly average of 1.6 MGD and a maximum of 1.8 MGD from April and to October. Please reevaluate your assumptions, in light of this new information from the RWD. The SWPPP also states that a bypass channel is used to convey uncontaminated stormwater past the retention pond without exposure to pollutants, and operation of the 350-acre foot retention pond is detailed in Section A.8.5.2. However, Section A.8.5.2 does not provide information on the operation of the 350-acre foot retention pond. This information must include the following: a. A water balance fhat is based on a 100-year storm; b. An evaluation of the watershed from which wastewater would be applied and runoff diverted around the storage pond; C. An explanation of how storm water would be separated from wastewater when Musco is applying wastewater during storm events; and d. Specific criteria describing when storm water can be diverted. 10. Page 15, Pollution Source Assessment and Best Management Practice Selection, Table 6-Summary of Potential Pollutant Sources and Corresponding Best Management Practices In the Land Application row and under Pollutant, the following constituents should be added: ammonia, nitrate, Total Kjeldahl Nitrogen(TKN),biochemical oxygen demand (BOD), and chemical oxygen demand (COD). 11. Page 25, Sampling Methods, Table 9 - Summary of Sampling Parameters Table 9 should include ammonia, nitrate, TKN, BOD, COD, electric conductivity, pH, and total suspended solids. 12. Page 25, Sampling Locations The SWPPP states that SW-1 should be representative of background concentrations existing throughout the unimpaired watershed. The SWPPP also states that SW-3 is in a tailwater sump that collects runoff from the largest southwest land application area. We concur that the upstream sampling location should represent background conditions. However, our experience on the site has shown that water may not be available at the proposed upstream sampling station, SW-1. The SWPPP should explain how potential impacts to storm water runoff would be assessed at the downstream sampling station, SW-4, when this is no flow from upstream that represents background conditions.