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CENTRAL VALLOREGIONAL WATER QUALITY ONTROL BOARD INSPECTION REPORT Report Date: 27 March 2001 DISCHARGER: CITY OF RIVERBANK LOCATION & COUNTY: RIVERBANK, STANISLAUS COUNTY CONTACT(S): STEVE BLACK, RANDALL DODD (CITY OF RIVERBANK) DAVE RICHARD, MIKE ANDERSON, JON CRAWFORD (NOLTE) INSPECTION DATE: 21 MARCH 2001 INSPECTED BY: ANNE OLSON AND WENDY WYELS ACCOMPANIED BY: OBSERVATIONS AND COMMENTS: The purpose of the visit was to inspect conditions related to pond freeboard and berm stability and to discuss concerns about potential berm failure. A photographic log is attached. The Discharger's water balance, completed last fall, showed that there was adequate disposal capacity at the plant for at least another 10 years. The Discharger believes the current freeboard problem is due to reduced percolation resulting from delayed routine pond maintenance. Staff stated that the overall condition and stability of the western and northern pond berms as identified in their geotechnical consultant's report is now a key issue because the berms are apparently saturated and the Discharger has had to repair leaks in the western berm. The Discharger requested permission to construct an emergency effluent storage/disposal area on a vacant orchard west of the plant site and has obtained an estimate to line the inside of the western berm with a geosynthetic clay liner. The Discharger has requested that RB-AAP cease discharge of treated groundwater to the sewer, which will reduce the influent flow by 250,000 gpd. The Discharger recognizes that it will probably be necessary to shut down the tomato cannery discharge this year so that most of the ponds can undergo routine maintenance to restore percolation rates, but that will not alleviate the current problem. We encouraged the Discharger to take any steps necessary to prevent and contain any possible spills and investigate the possibility of obtaining addition SRF loan monies to help raise capital to perform emergency work. We will contact the SWRCB to support their request. Because of the seriousness of the current situation and the recent pattern of violations related to inadequate maintenance and equipment, we will issue a draft Cleanup and Abatement Order to formalize the scope of required work and assign an enforceable schedule for that work. The Discharger has, through their own efforts and in response to previous enforcement letters, developed an appropriate scope of planned work, and the pace of planned long-term improvements has generally been adequate. Because of the emergency situation, they must act quickly to prevent a catastrophic spill.