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ADMINISTRATIVE CIVIL LIABILITY COMPLAINT ORDER NO.R5-2005-0528 -2 - RODNEY AND GAYLA SCHATZ MOKELUMNE RIM VINEYARDS SAN JOAQUIN COUNTY documents that were submitted are incomplete: Water Balance and Treatment Report, Land Application Improvement Report, Operation and Management Plan, Groundwater Well Installation Report of Results, and Salinity Reduction Study. 7. Notices of Violations (NOVs) for the violations described above were issued on 30 August 2004 and 23 August 2005; in addition, staff contacted Mr. Shatz by telephone on 27 January and 23 August 2005 to discuss the noncompliance. The two NOVs are discussed below: a. The 30 August 2004 NOV stated that the 24 June 2004 Water Balance and Treatment Report, which consisted of three sentences, was inadequate because it does not address the issues required by the WDRs and was not prepared by a registered engineer or geologist as required by the WDRs. The report was required because the wastewater storage pond was not constructed as described in the RWD. The pond described in the RWD would provide approximately 347,000 gallons of storage but the constructed pond is smaller, providing approximately 226,000 gallons of storage. This indicates that the facility likely has inadequate wastewater storage capacity, which may result in wastewater spills. In addition, the report proposed installation of aerators in the wastewater pond but did not state when the work would be completed. The WDRs required that if aerators were necessary to comply with the Discharge Specifications, then they must be installed no later than 1 September 2004. b. The 23 August 2005 NOV stated that the Discharger's self-monitoring reports were incomplete, technical reports were incomplete or were not submitted, and the Discharger failed to comply with certain Discharge Specifications of the WDRs. The issues are further discussed below. Self-Monitoring Reports The NOV states that review of self-monitoring reports for the time period January through April 2005 revealed substantial noncompliance with the MRP, as follows: i. Wastewater flow is not metered and all the flow is not being reported. ii. Samples were not collected during the reporting period. iii. Not all the monitoring that is required is being performed, and some reporting is not specific enough for the reader to determine the result. iv. A certification statement is not included in any of the monitoring reports. Technical Reports The Discharger submitted incomplete technical reports or failed to submit reports that are required by the Provisions section of the WDRs. Each of these were discussed in the 23 August 2005 NOV, and are discussed in Findings No. 8-13, below.