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Cherokee Freight Lines • 2 • 26 May 2004 Inspection Report contact at CFL, Mr. Richard Damilano, was unavailable but Mr. Gary Scannavino, the owner, did meet me to discuss the wastewater system. Upon arriving at the Trailer Wash area, I noted CFL Truck No. 249 located at the wastewater system, presumably to haul wastewater to the disposal area. CFL was in the process of improving the boiler used to generate the hot water used in trailer washing. New Ion Exchange (IX) vessels were also observed. I inquired about the reverse osmosis system that was to be installed as described in the 2001 Annual Land Management Report prepared by Nolte Associates which stated, "The planned replacement of the ion exchange unit for a reverse osmosis unit will result in reduced TDS concentrations, further minimizing the impact to groundwater resources." A reverse osmosis unit was not installed. Mr. Scannavino responded that his wastewater contractors told him the use of potassium chloride solved the problem of salt associated with the IX process. Other issues at the trailer wash area included a lack of a flow meter for wastewater generated at the trailer wash, wastewater discharge to the stormwater storage pond, and undocumented disposal of floatants from the dissolved air floatation unit. Because no flow metering occurs at the trailer wash facility, there is no way to determine if all the wastewater generated at the facility is being applied as required by the WDRs. Mr. Scannavino and I later returned to the trailer bone yard (where the wastewater storage tanks and land application area are located) and we discussed the application of wastewater to the graveled surface. I explained that discharges to areas not described in the WDRs as application areas are violations of the WDRs. SUMMARY: Staff observed wastewater presumably from the trailer wash facility to be discharged on land that is not permitted for disposal. Although a flow meter exists at the wastewater storage tanks, there is no metering that occurs at the trailer wash facility. Wastewater can and has been directed to areas other than the wastewater system. Improvements to CFL Monitoring and Reporting Program (MRP) are required to prevent future illegal discharge of wastewater, floatants, sludges, and better characterize the wastewater quality. In addition, groundwater monitoring wells do not exist at the land application area; groundwater monitoring wells should be required consistent with the requirements of other industrial discharges. C` Timothy R. O'Brien Engineering Geologist enc: Facility Location Map Inspection Photograph Log Aerial Photographs (3) W:\UMO mT Jaa9vin�=ka Fmgiiummi RM 26 WY2M don