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Californiategional Water Quali0Control Board ....... ., <br /> Central Valley Region <br /> Robert Schneider, Chair <br /> Alan C.Lloyd Ph.D. Arnold Schwarzenegger <br /> Secretaryjor Sacramento Main Office Governor <br /> Environmental Protection Intemet Address: http://www.swrcb.ca.gov/—mgcb5 <br /> 11020 Sun Center Drive,#200,Rancho Cordova,CA 956706114 <br /> Phone(916)464-3291 •FAX(916)4644780 <br /> RECeym <br /> 7 February 2005 <br /> FEB 0 9 2005 <br /> ENVIRONMENT HEALTH <br /> Ted Johnston PERMIT/SERVICES <br /> Director of Public Works <br /> City of Ripon <br /> 259 N. Wilma Ave. <br /> Ripon, CA 95366 <br /> CONDITIONAL APPROVAL,INDUSTRL4L WASTEWATER BPTC EVALUATION WORKPLAN, <br /> SANJOA QUIN COUNTY <br /> I have reviewed the 13 August 2004 Industrial Wastewater Best Practicable Treatment and Control <br /> Evaluation Workplan, prepared by ECO:LOGIC Engineering. The workplan provides characterization <br /> of industrial wastewater quality and presents a method to develop Best Practicable Treatment and <br /> Control (BPTC) strategies to prevent or minimize groundwater quality degradation at the City's <br /> wastewater treatment plant. <br /> Staff believes the workplan does not adequately address the potential for industrial wastewater to <br /> degrade groundwater quality. A more aggressive approach in controlling the wastewater discharged to <br /> the facility is appropriate, as described below. <br /> • The BPTC evaluation should begin by characterizing the industrial wastewater. This comparison <br /> should be performed early in the BPTC process to guide subsequent decisions. The wastewater <br /> quality should be compared to available groundwater quality data. If the industrial wastewater is <br /> determined to be capable of degrading groundwater, source control at Nulaid and other industrial <br /> dischargers should be the primary focus of the BPTC implementation. <br /> • Further analysis of the character of the industrial wastewater TDS subcomponents should be <br /> performed. Volatile Dissolved Solids (VDS) are generally biodegradable and/or subject to <br /> physical treatment are therefore less likely to impact groundwater quality than Fixed Dissolved <br /> Solids (FDS). Clean-In-Place (CIP) solutions are generally composed of FDS that are not <br /> biodegraded and are more likely to result in groundwater degradation. <br /> • Because the groundwater quality data presented in Table 4 indicates groundwater quality already <br /> exceeds Water Quality Objectives, the goal of any BPTC program should be to prevent further <br /> groundwater quality degradation. <br /> • The variable nature of the Nulaid wastewater quality indicates inadequate flow equalization and <br /> source control prior to discharge. For example, TDS concentrations vary from 800 mg/L to over <br /> 5,000 mg/L. (Because the Nestle wastewater consists of treated groundwater, large variations in <br /> California Environmental Protection Agency <br /> Q*Recycled Paper <br />