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Triple E Produce <br /> P.O. BOX 239 TRACY,CA 95378-0239 PH.(209)835-5923 <br /> February 15, 1999 <br /> Ms. Wendy Cohen <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Rouiter Rd., Suite A <br /> Sacramento, CA 95287 <br /> Re: Regulatory Issue, Treatment Plant Waste Discharge Requirements (WDRs) Order No. 90-142, <br /> Triple E Produce, San Joaquin County. <br /> Dear Ms. Cohen, <br /> We are pleased to submit the following information and data in response to the January 12, 1999 letter from <br /> Mr. William Marshall at the Regional Water Quality Control Board to Mr. Michael A. Campos of Washburn, <br /> Briscoe & McCarthy in Sacramento. In that letter, a narrative report was requested outlining out treated <br /> wastewater gross flow estimates and wastewater handling and disposal methods for the 1995, 1996, 1997, and <br /> 1998 processing seasons. <br /> Please note that our Waste Discharge Requirements (WDRs), Order No. 90-142, recognize that both <br /> Triple E Produce and our adjacent, smaller "Roma"tomato packing facility, Esfresh, discharge chlorinated <br /> wash water to the treatment plant during the seasonal packing operation. The WRDs, therefore, consider these <br /> two flows as one under Triple E. <br /> Overview of Packing Operation <br /> Our annual packing season for fresh market tomatoes generally runs from July through early November. From <br /> the field, the tomatoes are received in large bins holding about 1,000 pounds of tomatoes each. The tomatoes <br /> are dumped into a circular washing system consisting of two large stainless steel tanks of warm circulating <br /> water that is chlorinated. The water is used to remove field dirt from the tomatoes as well as stems, leaves, and <br /> small bits foreign material. The chlorine is required as a disinfectant to control mold and soft rot, which can <br /> infect the tomatoes after packing. At the end of the day, the tanks are drained and cleaned. The water is piped <br /> to the treatment plant for treatment prior to disposal to a dedicated spray field and/or for dust control around our <br /> facility. <br /> Chlorine System Before and After 1997 <br /> Prior to the 1997 packing season, both Triple E and Esfresh used gas (cylinder) chlorine. Using gas chlorine <br /> required a continuous flow of chlorinated water into the wash tanks and a continuous flow out of the tanks. <br /> This flow resulted in a large volume of water requiring treatment and disposal. <br />