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Mr. Chris Littlefield - 2 - 5 April 2001 The following violations of WDRs Order No. 5-00-227 were observed during the site inspection: • Discharge Prohibition A.2 prohibits discharge of contact water to the stormwater pond. Kellogg Garden Product's discharge of contact water to the stormwater pond violates this Prohibition. • Discharge Specification B.3 requires that the discharge shall remain within the designated disposal area at all times. The discharge of contact water to the stormwater pond violates this Specification. • Provision E.La requires submittal of a technical report describing the construction of the contact water pond and storage area. On 7 December 2000, Kellogg submitted the report but the information on vertical hydraulic conductivity was not included. • Provision E.l.c requires submittal of an Operation and Maintenance (O&M)Plan that describes O&M procedures to operate the facility in compliance with this Order. The O&M plan was due by 31 January 2001 but has not been received. Because of site constraints, and the issues discussed during the inspection, the Discharger has requested a revision of WDR Order No. 5-00-227 to allow discharge of contact water to the stormwater pond. To revise the existing WDRs, Kellogg Garden Products shall prepare a Report of Waste Discharge (RWD). The RWD shall include the Operation and Maintenance Plan as an individual document. Please submit the RWD by 29 June 2001. The RWD shall address all the issues identified in the I June 2001 correspondence request for an RWD (attached). The submittal shall include updated water balance calculations for the wastewater and stormwater ponds. Please note that the stormwater pond calculations must comply with the Regional Board's criteria for wastewater pond capacity in addition to any requirements the County imposes. In addition, by 5 May 2001 Kellogg Garden Products shall prepare a contingency plan to limit the flow of contact water to the stormwater pond pending evaluation of the acceptability of such a discharge in an RWD. The contingency plan shall identify procedures that will be implemented to limit the amount of product on the ground during storms, physical controls to minimize transport of soil amendment products to the stormwater pond, and other actions that will be implemented to comply with Order No. 5-00-227. If you have any questions about this information, please telephone Tim O'Brien at (916) 255-3116. i WEND_ Y WYELS, CHIEF Waste Discharge to Land Unit Lower San Joaquin River Watershed Enclosures (3) cc: Mike Huggins, San Joaquin County Environmental Health Department, Stockton