SITE INFORMATION AND CORRESPONDENCE 1980-1999

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• • 2 CEASE AND DESIST ORDER NO. CITY OF LODI WHITE SLOUGH WATER POLLUTION CONTROL FACILITY SAN JOAQUIN COUNTY Foot notes to previous table, adapted from permit 1 5-day,20°C biochemical oxygen demand(BOD) 2 To be ascertained by 24-hour composite samples 3 Based on an average dry weather flow capacity of 7.0 mgd 4 ND(non-detectable),The non-detectable limitation applies to each individual pesticide at any detection level. No individual pesticide may be present in the discharge at detectable concentrations. The Discharger shall use EPA standard analytical techniques that have the lowest practical detectable level for organochlorine pesticides with a maximum acceptable detection level of 0.02 pg/l. "F. Receiving Water Limitations: The discharge shall not cause the following in the receiving water: 1. Concentrations of dissolved oxygen to fall below 5.0 mg/l. " 3. The Discharger has completed an expansion of its secondary domestic waste treatment capacity to 8.5 mgd, but the effluent flow rate allowed by Order No. has not been increased beyond 7.0 mgd due to concerns regarding the impact of the discharge on dissolved oxygen concentrations in the receiving water. Previous permits required compliance with the dissolved oxygen objective at the point where Dredger Cut meets White Slough. However, this does not protect Dredger Cut. Receiving water monitoring data collected from January 1997 to May 1988 shows that, at the current discharge rate of less than 6 mgd, and a BOD loading up to 532 lb/day, the dissolved oxygen in Dredger Cut does not meet the Basin Plan objective for dissolved oxygen of 5 mg/l in 39% of samples collected when discharge was occurring, whereas it is usually met further downstream below the confluence with Bishop Cut and White Slough. The discharge is causing or contributing to the violations. Studies completed to date also indicate that an expanded discharge of 8.5 mgd of secondary-treated effluent may cause violations of the dissolved oxygen objective to occur in White Slough and, to a lesser extent, in Bishop Cut. The permit effluent limit of 10 mg/l for BOD represents a more stringent requirement than was imposed in the past. The permit recognizes that this alone will not achieve compliance with the dissolved oxygen objective in Dredger Cut, therefore it also requires that land disposal be maximized, and prohibits discharges when dissolved oxygen concentrations in Dredger Cut are less than 5 mg/1. The Discharger is not capable of meeting these requirements with the current treatment, storage and disposal facilities. 4. The Discharger will be unable to comply with the new effluent limitations for BOD, cyanide, zinc, and lead, as well as the discharge prohibition on discharging to Dredger Cut when dissolved oxygen concentrations are below 5 mg/l, without proceeding with plant improvements. The Discharger is in threatened violation of those requirements. Due to the time requirements to plan and construct necessary treatment facilities, a time schedule for Is compliance and interim effluent limitations is necessary.