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DRAFT Staff Report -6- Administrative Civil Liability Complaint Rodney and Gayla Schatz dba Mokelumne Rim Vineyards San Joaquin County i. Wastewater flow is not metered and all the flow is not being reported. In the January 2005 monitoring report, Mokelumne Rim reported a total of 789 gallons of wastewater discharged; in February 2005, 1085 gallons was discharged; and in March and April 2005, no gallons were discharged. In a 17 June 2005 telephone conversation the Discharger informed staff that the flow numbers are an estimate and are not metered. Staff believes the flow rate is underestimated and not all flow is reported. For example, influent samples were collected on 3 March 2005 but the self-monitoring report indicates no wastewater was discharged on that day. Similarly, influent samples were collected on 10 February 2005, but according to the monitoring report, no wastewater was discharged that day. The MRP requires the flow rate to be metered. The Discharger submitted a response to the 23 August 2005 NOV stating a flow meter has been installed. However, in the 20 October 2005 meeting the Discharger informed staff the flow meter was improperly installed and not providing accurate data. ii. The March and April 2005 monitoring reports indicate no wastewater discharge to the pond occurred. However, because stormwater is discharged to the wastewater pond, and the monitoring reports indicated precipitation occurred during the monitoring period, the statement regarding a lack of wastewater in the pond cannot be correct. No pond monitoring was included in either report. iii. Analytical laboratory reports indicate that samples were not collected during the reporting periods. For example, in the January 2005 report, wastewater samples were collected on 10 February 2005; and in the February 2005 report, wastewater samples were collected on 3 March 2005. The reports were not organized so that the laboratory reports present the data collected in the monitoring period. iv. Not all the monitoring that is required is being performed, and some reporting is not specific enough for the reader to determine the result. For example, in the January 2005 monitoring report"NA" or a line drawn through the table where data should be reported exists, but that doesn't allow a reader to determine the status of the parameter being monitored. In the March and April 2005 reports, diagonal lines are drawn through the tables. The reports must be complete enough for a reader to determine if the monitoring was conducted and the result of that monitoring. If monitoring was not conducted, a statement should be provided explaining why it was not conducted. v. A certification statement is not included in any of the monitoring reports. The General Reporting Requirement B.3 of the Standard Provisions attached to the WDRs requires the following statement be included for report submittals. I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of the those individuals immediately responsible for obtaining the information, 1 believe that the information is true, accurate, and complete. I am aware that there W:1StaIDObrienTSan loaquinNokelttmme Rim ViwyardAACL Sept OAStalf Report.DOC