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California Regional Water Quality Control Board °::� Central Valley Region Robert Schneider,Chair ` ' Winston H. Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 4 May 2001 Mr. Randall Dodd, Public Works Director City of Riverbank 6707 Third Street Riverbank, CA 95367 COMMENTS ON CONTINGE'i r'CY PLAN FOR WAS TEEf'ATER DISPOSAL, Cm-OF RIVERBANK WASTEWATER TREATMENT PLANT, STANISLAUS COUNTY Staff have reviewed the subject report, which we received on 23 April 2001. In accordance with Cleanup and Abatement (C&A) Order No. 5-01-703, the report was to describe interim measures to control pond freeboard and prevent unauthorized releases until permanent improvements can be made. The report is generally responsive to the C&A; however, the following comments must be addressed: 1. The plan presents an approach that relies exclusively on the City's ability to secure the right to discharge excess effluent to a neighboring property owned by others, while acknowledging that such access might not be easy to obtain. The report must include a discussion of other disposal options and/or flow reductions that may be utilized separately or together if access cannot be obtained or is delayed. 2. Based on the revised water balance, the plan appears to show that both the Summer 2 and Summer 3 percolation ponds could be dried and serviced this year prior to the onset of the rainy season. Per the C&A, all three of the summer ponds (Nos. 1, 2, and 3) must be dried out and serviced by 30 December 2001. Please revise the text and associated calculations to show how this will be accomplished. 3. Although the report references the possibility of reduced flows from the Gangi Brothers tomato processing facility, specific restrictions or conditions of discharge have not been proposed. Discuss how and when such decisions will be made to ensure full compliance with the C&A and the WDRs. 4. The plan did not include an evaluation of the technical and economic feasibility of any of the options, including the selected approach. This evaluation must be made for each option. 5. Please develop a critical path schedule that shows how the City will ensure that freeboard returns to acceptable levels and that all other requirements of the C&A will be satisfied in accordance with the schedule set forth in the C&A. The schedule must reflect the impact of possible deviations from normal evaporation and inflow rates on each, and consider the California Environmental Protection Agency epi Rec)nled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgeb5