SITE INFORMATION AND CORRESPONDENCE_CASE 2

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ADMINISTRATIVE CIVIL LbI&ILITY ORDER NO.R5-2005-0143 *40W -5- CITY OF TRACY SAN JOAQUIN COUNTY Notification of Violation: The Discharger's Emergency Action Plan did not identify the discharge of highly chlorinated effluent as needing to be reported to OES. In light of the incident, the Discharger issued an internal memorandum to all Utility Division personnel. Decree of Cooperation/Conduct: The Discharger determined that one of the two SO2 gas leak detector sensors went into a fault mode, causing the main SO2 gas feed valve to close. The audible alarm system was not configured to sound an audible alarm unless there was an actual SO2 gas leak. The Discharger has made necessary modifications to the system to correct this problem. In response to a Notice of Violation,the Discharger also committed to review and update existing standard operating procedures and emergency response procedures by 1 November 2004, including development of preventive and contingency plans and training of personnel with assistance from a contracted Health and Safety professional. Although Regional Board staff have requested the Discharger provide confirmation of completion, the Discharger has failed to provide adequate evidence that it has completed these actions. Prior history of violations: The Discharger does not have a history of chlorine residual violations. Overall, the Discharger has a relatively good record, with mostly minor violations. Ability to Pay: The Discharger has not stated nor demonstrated an inability to pay or continue in business if required to remit the liability. Economic Benefit: The Discharger derived an economic benefit estimated to be not less than $10,000 for not including necessary alarms and redundant systems to prevent or minimize the release of chlorinated effluent. The plant alarm system was not configured correctly and allowed the main SO2 gas feed valve to close without sounding an audible alarm. The Discharger promptly made necessary wiring connections to the plant alarm system to correct this problem. The cost of the repairs are not known, but were likely minimal. This modification would have likely minimized the chlorine release. However, additional controls and redundancy are warranted and should have been in place to prevent the discharge of chlorine. The dechlorination system should have in-line chlorine residual monitoring and a redundant SO2 feed system to safeguard the system. Other Matters that Justice May Require: Staff costs were estimated to be $8,000, assuming the ACL was settled without significant negotiations. Staff costs increased an additional $4,800 preparing for the hearing. 13. On 5 January 2005,the Executive Officer issued the Discharger Administrative Civil Lpability Complaint No. R5-2005-0500 (Complaint)proposing a$120,000 Administrative Civil Liability pursuant to CWC section 13385.