SITE INFORMATION AND CORRESPONDENCE

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Mr. ,1 on Crawford - 3 - 16 December 1999 The schematic of water flow provided for Item 13 is incorrect, outlining the current treatment plant instead of an expanded plant with advanced treatment capability. 5. The following comments pertain to EPA Form A, Section II: - Item 2 needs to define an anticipated discharge startup date. Item 10 pertains to seasonal/periodic discharges. The application needs to include technical information regarding the available land disposal capacity, how.land disposal will be maximized, and the volume and months when a surface water discharge is expected to be necessary. Item 11 requires the discharger to provide a description of the treatment proposed. The schematic presented is of the existing plant, which is only capable of secondary treatment. Please provide specific details of the proposed future plant(s). Item 12 states an Operations and Maintenance manual is available, whereas the proposed plant has yet to be designed. Please correct the discrepancy. Please correct Item 13 in regard to current and future plant flows. Item 14 requires adequate influent and effluent data be collected and provided (or estimated) based on the design of the advanced treatment plant. Also, in our review of the data presented, staff noted that temperature data does not appear to be accurate, and the concentration of total dissolved solids to be very high(up to 2100 mg/1). 6. The quality and characteristics of the receiving water must be evaluated to determine the impacts of constituents in the discharge that are already in the receiving water at concentrations causing impairment, as well as the assimilative capacity for constituents not causing water quality impairment. 7. There is no discussion of how the increased production of sludge will be managed. A discussion of the projected increase of sludge volume and a means of managing that increase must be presented to the Board. 8. With increased treatment capabilities and the possibility of attracting additional industrial users to the treatment system, Lathrop may be required to incorporate a pretreatment program as outlined in 40 CFR Part 403. The Board requests the City to evaluate the need for a pre-treatment program as part of its proposed expansion. 9. On EPA Form A, Section IV,you are required to indicate if there are any industrial dischargers contributing to the influent wastewater flows. On the form it is indicated that there are presently "no industrial dischargers".However, during our meeting with you at the existing wastewater treatment plant,you indicated that the Nestle Facility is discharging boiler blowdown to the facility. Please correct your application to include accurate information regarding existing and projected industrial flows.