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.` California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Alan C.Lloyd Ph.D. Arnold Schwarzenegger <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Protection Intemet Address: htip://www.swrcb.ca.gov/—mgcb5 <br /> 11020 Sun Center Drive,#200,Rancho Cordova,CA 95670611 <br /> Phone(916)464-3291 •FAX(916)464-4780 " Y E V t�LIJILS�!'lln ED <br /> 4 February 2005 <br /> FEB 0 7 2005 <br /> Tom Wise <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Environmental Manager <br /> Carpenter Company <br /> 17100 South Harlan Road <br /> P.O. Box 279 <br /> Lathrop, Ca 95330 <br /> NOTICE OF VIOLATION, CARPENTER COMPANY, SAN JOAQUIN COUNTY <br /> Staff has reviewed the 2 November 2004 correspondence that requests rescission of Carpenter <br /> Company's Waste Discharge Requirements (WDRs). The WDRs address wastewater generated at the <br /> Carpenter Company facility located at 17100 South Harlan Road, Lathrop. When issued, the WDRs <br /> allowed discharge of industrial wastewater generated in on-site truck washing; that activity has ceased, <br /> trucks are now washed at an off-site location. However based on your telephone conversation with Tim <br /> O'Brien in December 2004, wastewater is still generated in boiler feed wa�er softening, boiler <br /> blowdown, and cooling tower blowdown which are all discharged to land at the facility. These <br /> wastewater sources are not described in the WDRs and therefore their discarge is a violation of the <br /> WDRs. <br /> Wastewater generated in ion exchange water softening, boiler blowdown, and cooling tower blowdown <br /> contains elevated concentrations of fixed dissolved solids that will not be reduced by applying the <br /> wastewater to ground. Staff has determined that the wastewater discharge is not protective of <br /> groundwater quality and is not consistent with the requirements of the California Water Code,the Basin <br /> Plan, or Title 27 of the California Code of Regulations. <br /> Groundwater Quality <br /> Although information on site-specific groundwater quality is not available, groundwater samples <br /> collected from nearby sites in the Crossroads development contain (unimpIacted) TDS concentrations of <br /> approximately 1,000 mg/L or less; staff anticipates the wastewater TDS c ncentration to be substantially <br /> higher than the TDS groundwater concentration. <br /> Determination of Wastewater Classification <br /> Comparison of the probable wastewater TDS concentration with groundwater concentrations and water <br /> quality objectives indicates the discharge is likely to exceed both the background groundwater <br /> concentration and the water quality objective for TDS presented in the Basin Plan. Wastewater with <br /> those characteristics is classified designated in accordance with the California Water Code Section <br /> 13173(b), which states: <br /> California Environmental Protection Agency <br /> CO Recycled Paper <br />