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c— Mr. Benjamin Hall - 2 - 30 November 2001 • The one million gallon pond routinely is overfilled, spilling wastewater into the natural drainage feature. Spills have become such a regular occurrence that an overfill discharge pipe was installed in the pond. The overfill pipe discharges into the natural drainage feature. This is an on-going and serious violation of the Discharger's WDRs. Although required by the Standard Provisions (copy enclosed), the Discharger is not notifying staff within 24 hours of knowledge of bypass or overflow of the wastewater system. • Three inlet pipes were observed at the one million gallon pond. Two of the pipes were discharging wastewater into the pond. During the inspection, Mr. Hall could not identify the sources of wastewater transmitted through the pipes. • The wastewater flow rate is not directly metered. • The condition of the one million gallon storage pond is very poor. Substantial accumulation of floating solids was observed and a strong odor was noted. In addition, the berm surrounding the pond displayed evidence of significant erosion due to previous overflows. • Inspection of the land application areas revealed tailwater runoff, despite a lack of rainfall. Portions of the land application areas had been disced, but the majority of the land areas did not appear to have been disced. No crops were observed in the land area with the exception of the sudan grass planted in the checks. Based on the site conditions observed, it.is not clear that the Discharger can apply wastewater to land without tailwater being generated. • The Discharger continues to apply wastewater during rain events, despite the tailwater runoff during dry climatic conditions. • The checks were constructed in violation of the WDRs. The checks are acting as water storage basins rather than as land application areas. Each of the checks was flooded with wastewater that was nearly black and possessed a strong offensive odor. • Aerial photographs taken on 11 October 2001 indicate distressed natural vegetation exists in most of the land application areas and shows ponded water in each of the three checks. Also visible is the discharge of water into a flooded check in Field No. 1. In general, most of the land application area has not been cropped. • The domestic wastewater system is inadequate for the number of employees on site. Mr. Hall stated that approximately 350 employees are employed at the facility,while information on the septic system available at the San Joaquin County Environmental Health Department indicates the septic system was designed for 35-40 employees. Additionally, during the site inspection, Mr. Hall could not locate the leachfield, which made inspection of the condition of the leachfield impossible. Violations observed during the site inspection are described in the enclosed site inspection report. It is noted that many of the violations are not single events such as might occur from operator error. The pattern of non-compliance indicates a disregard for responsible wastewater treatment/disposal, the WDRs, and C&A Order. Revised Monitoring and RMorting Program A review of the existing Monitoring and Reporting Program (MRP) shows that it is inadequate to monitor compliance with the WDRs. As discussed during the inspection, staff has revised the MRP. Enclosed with this correspondence is Revised MRP No. 97-037. Please note that it is effective CAPmpd Ri.e Sft.W—VW1 11 1901.DGC -�•"`