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•MEMORANDUM• Cal/EPA CAs� CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION v 3443 Routier Road,Suite A,Sacramento,CA 958273003 Pete Wilson,Gover r (916)255-3000 • CALNET 8-494-3000 • FAX(916)255-3015 TO: Greg Vaughn FROM: Patricia Leary Senior Engineer Associate Engineer DATE: 30 March 1998 SIGNATURE: Ci( Gt �t tt SUBJECT: COLIFORM VIOLATIONS, LIBBEY OWENS FORD CO., SAN JOAQUIN COUNTY Libbey Owens Ford Co. (LOF) manufactures float glass and both tempered and laminated automotive glass. Sanitary wastes generated by employees are treated in a package treatment plant and then mixed with industrial wastewater(washwater, cooling water, boiler blowdown, storm water) and ground water infiltration water in a reservoir. The facility has a NPDES permit(Order No. 91-056)to discharge wastewater to the San Joaquin River, and to also maximize land disposal of wastewater by irrigating 30 acres of lawn and discharging to two evaporation/percolation ponds. For the past several years the facility has discharged all wastewater to land. It has also added some land adjacent to the facility for land disposal. Although the permit was not amended to specifically include the land disposal area,the effluent limitations for discharge to land apply to both the fallow land and lawn areas. In either application, public access must be restricted from areas irrigated with effluent, runoff must be prevented, and effluent from the sanitary plant must be in compliance with effluent limitations. LOF has had continuing problems with the chlorination system at the sanitary treatment plant. On 17 May 1996, staff wrote a letter to LOF regarding the non-compliance. The attached chronology lists the correspondence and repairs made to the treatment system since that time. Also attached is a table summarizing the total coliform data from the discharger monitoring reports since the violation letter was written. The submitted data shows that total coliform violations are chronic and recurring. Weekly sample results have exceeded 23 MPN/100 ml, the daily maximum effluent limitation for land disposal, five times in the last six months The reclamation usage of this water is also in violation of water reclamation requirements and guidelines established by the California Department of Health Services. The reasons for the exceedances were attributed to equipment malfunction and operator error. Modifications and repairs are regularly made,but new problems continue to surface. The treatment plant is quite old, and LOF has indicated that it is difficult to obtain parts for repair. LOF should be required to upgrade the facility sufficiently to provide reliable treatment, or consider other alternatives to prevent effluent violations. Some possibilities which should be considered are hooking up to the sanitary sewer operated by either the City of Lathrop or the City of Manteca. PHL:p1 Attachments Recycled Paper Our mission is to preserve and enhance the quality of California's water resources,and ensure their proper allocation and efficient use for the 6enefif ofpresent andfuture generations.