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City of Escalon 5 24 September 2014 San Joaquin County include recommendations as needed to repair/restore berm integrity and capacity such that the WWTF can comply with Discharge Specification B. 10 of WDRs Order 5-00-142, which states, "The pond system shall have sufficient capacity to accommodate allowable wastewater flow, design seasonal precipitation, seasonal ancillary inflow, and infiltration during the wet season. Design seasonal precipitation shall be based on total annual precipitation using a return period of 100 years, distributed monthly in accordance with historical rainfall patterns." The report shall also contain a construction schedule. 3. A plan for managing influent flows during 2014/2015 winter and spring such that two feet of freeboard is maintained in all wastewater ponds in accordance with WDRs Order 5-00-142. 4. A vegetation monitoring and removal plan that describes how the wastewater ponds will be maintained to minimize aquatic plants and algae, which reduce pond capacity as well as nuisance conditions. 5. An Odor Identification and Mitigation Plan. The plan shall describe how the wastewater treatment plant and Del Rio subdivision will be monitored to identify the presence of nuisance odors associated with wastewater and include notification and corrective action procedures for the City and WWTF staff to follow when odors are identified. The City shall evaluate using automated, real time sensors for odor monitoring surrounding the WWTF. Additionally, the plan shall contain measures that will be implemented immediately (additional pretreatment, aeration, vegetation removal) to prevent off-site odors during the remainder of the 2014 processing season. 6. A copy of the City's current industrial discharge permits with Escalon Premier Brands and Eckert Cold Storage, as well as an evaluation of each facility's compliance with their permit during the 2013 and 2014 processing seasons. 7. The name of the licensed engineer that the City has retained to evaluate the industrial pretreatment program and the organic loading and pH ranges which the City's industrial wastewater treatment plant is capable of treating in a manner that prevents nuisance odors. The evaluation shall include recommendations and a construction schedule for physical and management modifications to each facility (Escalon Premier Brand, Eckert Cold Storage, and the Escalon WWTF). All physical and management changes shall be implemented prior to the 2015 processing season. In addition to the Notice of Violation, staff is evaluating the need for additional enforcement actions. If you have any questions, please contact Brendan Kenny at (916) 464-4635. 444-- HOWARD HOLD, P.G. Senior Engineering Geologist WDR Compliance and Enforcement Section Enclosures: Photographic Inspection log cc list: see next page.