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Messrs. Hall and Musco - 2 - 2fOctober 2002 <br /> Table 1 lists analytes, preservatives, hold times, and filter status; I have the following commews on <br /> the table: <br /> o Electrical conductivity(EC) and pH are generally measured in the field using calibrated <br /> instruments. According to Table 9.8 in EPA's, Site Characterization for Subsurface <br /> Remediation (Site Characterization), EC and pH should not be filtered. <br /> o Biochemical Oxygen Demand (BOD) is affected by the size of the particles in wastewater and <br /> therefore filtering the samples prior to analysis is not appropriate. <br /> o Ammonia is listed as being filtered at the lab after preservation with sulfuric acid. It is noted <br /> that ammonia exists in an aqueous solution as ammonium below pH 9.3; Site Characterization <br /> does not recommend filtering sensitive organic species such as ammonium (Figure 9.9). <br /> o Total Kjeldahl Nitrogen (TKN) should not be filtered because TKN includes organic and <br /> ammonia nitrogen. As described above ammonia/ammonium samples should not be filtered. <br /> Please submit a revised table or further justification on why the analytes listed above should be filtered <br /> and address the rest of the issues identified above prior to implementing the well installation field <br /> activities. Please provide at least 48-hours notice prior to initiating the field work to allow Regional <br /> Board staff to observe the well installations if desired. <br /> A final comment is that this workplan does not satisfy Waste Discharge Requirement Order No. <br /> R5-2002-0148, Provision G.2.b. As required by Provision G.2.b by 1 November 2002 Musco Family <br /> Olive Products shall submit a workplan that complies with the WDRs. The well installation results can <br /> be combined with the Groundwater Well and Lysimeter Installation Report required by Provision G.2.h <br /> and shall be submitted by 1 May 2003. <br /> If you have any questions regarding this Conditional Approval, please telephone me at (916) 255-3116. <br /> TIMOTHY R. O'BRIEN <br /> Waste Discharge to Land Unit <br /> Lower San Joaquin River Watershed <br /> cc: Dennis DeAnda, Department of Fish and Game, Stockton <br /> Joe Spano, Department of Health Services, Office of Drinking Water, Stockton <br /> Mike Huggins, San Joaquin County Environmental Health Dept., Stockton <br /> David Irey, Esq., San Joaquin County District Attorney, Stockton <br /> Michael Campos, Esq., Stoel Rives LLP, Sacramento <br /> Bill Jennings, DeltaKeeper, Stockton <br /> V:Swjoequin NanIA taHlOMenT ro*t Files\MWC0\Ha11101702.doc <br />