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City of Lathrop 2 20 October 2014 Questions: a) Did SAS pay the one-time $100,000 surcharge to the City? b) If so, did the City implement a water softener buyback program? How many units were purchased? Was all of the money spent? c) What other specific efforts has the City made to reduce effluent salinity? When were these things implemented? What demonstrable salinity reduction was achieved by each? d) If the City had imposed a TDS limit of 1,200 mg/L, what effect would that have on effluent TDS at the Crossroads WWTF? e) Why does the 2012 permit not have a flow limit or a TDS limit? 2. EKI's suggested language for the 2012 permit also included: "In order to reduce its discharges of Total Dissolved Solids, the Permit Holder is required to, at a minimum, install a "first rinse"capture system on its meat and spice production line. Permit Holder shall be required to submit a report to the City documenting the installation of this capture system within twelve months of the effective permit date. Upon two consecutive months of non-compliance with its discharge limitation for Biochemical Oxygen Demand, the Permit Holder shall be required to address reliability issues in its Dissolved Air Floatation system by installing a new equalization tank capable of complete mixing and/or a new high rate dissolved air floatation unit to replace its lower capacity unit. Permit Holder shall be required to submit a report to the City documenting the installation of this new equipment within twelve months of the date of the second sampling event showing non- compliance". However, the 2012 permit does not include that requirement. Question: Why does the 2012 permit not include such enforceable requirements for salinity reduction? 3. The City's 30 September 2014 letter (Page 2, No.6 a) states: "The City required Swiss America Sausage (SAS) to modify its operation to reduce effluent salinity to the extent feasible. The measures taken by SAS are described in an EKI report provided as Attachment E". Attachment E, the Wastewater Discharge Permit Compliance Study for Swiss American Sausage/Hormel Foods (EKI A50016.22) (page 8) dated on 30 January 2009 stated that: "According to available documentation and discussions with Swiss/Hormel, there are several effluent streams for the Swiss/Hormel Plant: • High-TDS brine from the plant's water softening system is collected separately from the City's process water and is transported by truck to East Bay Municipal Utility District ("EBMUD'). • High-TDS discharge from the plant's broth line is also collected separately from the City's process water and is transported by truck to EBMUD".