SITE INFORMATION AND CORRESPONDENCE

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Deuel Vocational Institution 2 San Joaquin County 18 November 2014 discharged again into the surface impoundment until Water Board staff agree that it has been repaired. CDCR has violated the WDRs because (a) it did not submit written notification of the release until the meeting on 21 October 2014 --26 days beyond what is allowed by the WDRs, and (b) the written notification does not contain any discussion of the timing for repairing the liner. The written notification does comply with the WDRs by stating that brine will not be discharged into SI No. 1. During the meeting on 21 October, Water Board staff asked for the schedule to repair the liner. CDCR stated that it could take a year or more for repairs, and that the process had not yet begun. Staff stated that wastewater cannot be discharged into SI No. 1 until it is repaired, and requested that CDCR submit weekly progress reports describing the status of contracting for repairs, the volume of waste in the ponds, and the monitoring results for the eight lysimeters. On 23 October, 3 November, and 17 November 2014, the Discharger submitted status updates. The reports state that the Discharger has not yet hired a professional to determine the location of the leak(s) in SI No. 1 and the Discharger anticipates that the process for contract development and solicitation of bid for the leak investigation may take six to nine months. Repair or the surface impoundment will subsequently follow. The monitoring data shows that, contrary to the WDRs, CDCR discharged wastewater to SI No. 1 between 18 October and 31 October 2014. This is a violation of Discharge Specification B.18 of the WDRs. A review of the monitoring data also finds that water has now been detected in the pan lysimeter of SI No. 3. The water was detected on 18 October 2014 and has continued to be detected in the pan lysimeter ever since. However, no notification (verbal or written) has been received by Regional Board staff. The failure to notify staff is a violation of Discharge Specification B.18 of the WDRs. This letter reiterates the provisions of the WDRs: namely, that wastewater may not be discharged into any surface impoundment for which leachate has been detected in a vadose zone monitoring system (i.e., pan lysimeter). Therefore, waste may no longer be discharged to surface impoundments #1 or#3. Water Code Section 13267 Order for Technical Reports Section 13267 of the California Water Code states, in part: In conducting an investigation specified in subdivision (a), the regional board may require that any person who has discharged, discharges, or is suspected of having discharged or discharging...waste outside of its region that could affect the quality of waters within its region shall furnish, under penalty of perjury, technical or monitoring program reports which the regional board requires. The burden, including costs, of these reports shall bear a reasonable relationship to the need for the report and the benefits to be obtained from the reports. In requiring those reports, the regional board shall provide the person with a written explanation with regard to the need for the reports, and shall identify the evidence that supports requiring that person to provide the reports.