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Ernie Schenone, Jr. _ 2 _ 28 03 ; allowable drinkable limit before it even enters our septic system for denitrification"is misleading. Because septic systems act as anaerobic digesters, little if any denitrification occurs in the tank. The relatively high concentration of BOD reported in the wastewater sample will also tend to prevent any oxidation of nitrogen compounds. Misunderstandings such as these underscore the need for SSF to employ an engineer-that is experienced with wastewater systems to prepare the RWD. Your 9 August 2003 correspondence requests recommendations or suggestions to comply with the Board's.requirements, These suggestions (and others) should be prepared by your engineer after an evaluati'an of the'business practices and wastewater characterization. However, after the brief site visit the following iterris should be considered.- , • Use refrigeration to allow recycling of the non-contact cooling water to keep it out of the wastewater systdm. This is a common practice employed by facilities with much larger cooling needs than SSF. _ With_thatsimple-addition;some concerns about hydrauliccapacity-are-resolved— d-problems with -- emulsified oil passing through the oil/water separator and septic tank are reduced. • Investigate the source of the sodium and total dissolved solids that were reported in the laboratory analyses. The concentrations reported are high enough to impact groundwater quality. The concentrations of sodium indicate water softening is likely occurring on-site. Water softeners discharge high concentrations of sodium during regeneration,which cannot safely be discharged to a septic system. • Investigate the source of the BOD concentration in the wastewater. The BOD concentrations are at least five times higher than domestic wastewater. Discharge of high concentrations of BOD to septic systems may result in odors and can lead to acidic conditions that mobilize waste constituents resulting in groundwater degradation. Based on observations at the facility, it was apparent that substantial amounts of the waste constituents could be removed from the wastewater stream by removal of residual materials prior to sanitation activities using equipment such as plastic spatulas, etc. The material that is removed can be placed in trash for waste disposal. Such source control activities will also reduce the nitrogen concentration in the wastewater. It is emphasized that the suggestions listed above are based on a short visit to the facility and your --engineer would-likely-make-additional reconimendations-after-ehar-aetenzation-of-the wastewater.-and - - f n-ther investigation of the source of waste constituents. The findings of the investigation, wastewater characterization, and evaluation of manufacturing operations must be prepared into a technical report that will be submitted as part of your Report of Waste Discharge (RWD). In your 9 August 2003 response to the Regional Board's 25 June 2003 correspondence you state, "I would challenge anyone to use (sic)perform an estimate of actual usage based on reality and not local outdated plumbing standards that will even come close to the design point of this system." This underscores a basic misconception; the RWD is required to explain to Regional Board staff what the discharge is, how it is being treated, and how that treatment is protective of groundwater quality. Staff relies upon the RWD to prepare the WDRs. To date, we have not received a complete RWD. Therefore we again request that SSF submit the information required to allow evaluation of the industrial waste stream in the form of a complete RWD. Please submit the required filing fee of$2,300 and the Additional Information Requirements prepared VASan]oM%iu—Non 15%SlaWtliwT1Sm 70aquinSCho holkMcbmona 25 Aug 07.doe f