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EDMUND G. RRowN JR. <br /> rENEW <br /> �Wo <br /> oulrowu• exv Ro..NP RODRRorzcnox <br /> Water Boards <br /> Central Valley Regional Water Quality Control Board <br /> 20 October 2014 RECEIVED <br /> Stephen Salvatore, City Manager OCT 2 4 2014 <br /> City of Lathrop ENVIRONMENTAL HEALTH <br /> 390 Towne Center Drive PERMIT/SERVICES <br /> Lathrop, CA 95330 <br /> REQUST FOR ADDITIONAL INFORMATION, REPORT OF WASTE DISCHARGE, CITY OF <br /> LATHROP CROSSROADS WASTEWATER TREATMENT FACILITY, SAN JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board staff has reviewed the City's 30 September 2014 <br /> Additional Information for City of Lathrop Crossroads Wastewater Treatment Facility. Based on the <br /> review, staff has following questions: <br /> 1. EKI completed a Wastewater Discharge Permit Compliance Study for Swiss America Sausage <br /> (SAS) prior to issuance of a new industrial discharge permit in January 2009. The EKI report <br /> recommended that the new permit contain a flow limit of 25,000 gpd, and a TDS limit of <br /> 1,200 mg/L as a daily maximum based on SAS's flow rate and the background groundwater <br /> TDS concentration of 1,010 mg/L. However, the City and SAS had determined that SAS may <br /> not be able to comply with the TDS limit of 1,200 mg/L. <br /> Based on the City's subsequent Draft Technical Memorandum dated 30 January 2009, <br /> the suggested TDS limit for SAS was 2,850 mg/L as a daily maximum upon payment of a <br /> one-time $100,000 surcharge to reimburse the City for costs associated with implementing a <br /> Self-Regenerating Water Softener Buyback Program for the City's residents. <br /> However, the Wastewater Discharge Permit#2011-3 for SAS, issued by the City on <br /> 6 December 2012 (the 2012 permit), does not have a flow limit or a TDS limit. Instead, <br /> the 2012 permit only contains TDS "Best Management Practices" goals: a maximum daily <br /> concentration of 4,700 mg/L and a monthly average concentration of 4,000 mg/L for TDS. <br /> After the permit was adopted on 6 December 2012, the SAS TDS concentrations from <br /> 7 December 2012 through 31 July 2014 ranged from 1,350 to 4,520 mg/L with an average of <br /> 2,636 mg/L. The TDS data also show that 58 out of 148 biweekly samples exceeded EKI's <br /> suggested TDS limit of 2,850 mg/L as a daily maximum, but all data are less than the TDS <br /> daily maximum goal of 4,700 mg/L. <br /> KARL E. LONGLEY Sc D, P.E., CHAIR � PAMELA C. CREEOON P.E.. BCEE, EXECUTIVE OFFICER <br /> 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 '1 www.waterboards.ca.gov/cenlralvalley <br /> l:e RECYCLED PAPER <br />