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• White Slough Water Pollution atrol Plant -3- • 11 March 2000 Inspection Report Review of the residual chlorine chart (Attachment 2) indicates a steady gradual chlorine increase beginning as early as 1900 hours continuing to 2300 hours at which point the graph "pegged out" at approximately 10 mg/1 residual chlorine. The chart remained "pegged" until 0700 hours the next morning when the problem was noted and corrected and the graph was changed by the morning staff. The graph from the residual analyzer also shows that the sulfonator was able to keep up with the additional chlorine loading until about 0200 hours on 4 January 2000 at which point a positive chlorine residual concentration began to be charted. The residual chlorine measurement continued to increase from approximately 0.5 mg/1 (0200 hours) to as high as 8.2 mg/l at 0610 hours until the problem was discovered shortly after 0700 on 4 January 2000. As indicated by Mr. Kerlin and Mr. Moroz, one of the last procedures to be performed by the swing- shift operator is to check the chlorination and sulfur dioxide units before leaving the facility. Review of the operator logbook.did not indicate that there was a problem with the chlorination unit. However, a non-characteristic pattern from the dose chlorine analyzer was charted from 2100 to 2300 hours, which should have been recognized during the swing-shift rounds. Mr. Kerlin indicated that at approximately 0700 hours on 4 January 2000, the morning rounds were made and staff identified the malfunction and diverted effluent to the storage ponds. Following flow diversion, facility staff inspected the receiving water in the immediate vicinity of the outfall for disruptions to aquatic habitat; none were identified. The Discharger reported the excursion to the Regional Board at 1240 on 4 January 2000. The discharger conducted additional receiving water inspection at the request of the Regional Board at approximately 1300 hours on 4 January 2000. It is not apparent that any receiving water samples were collected or analyzed to evaluate the magnitude and extent of the water quality impact due to the release. The Discharger did not notify the Office of Emergency Services of the release. Regional Board staff notified the Department of Fish and Game (DFG) of the release at 1300 hours on 4 January 2000. The DFG dispatched a game warden that made an inspection of the receiving waters and facility on 5 January 2000. Communication with DFG Warden Dennis DeAnda indicated that no obvious signs of residual aquatic distress were noted by the DFG inspection. A letter report was prepared by the Discharger and was received by the Regional Board on 12 January 2000. There was no written notification of the noncompliance described in the January 2000 self-monitoring report. Additional Information Regarding Incident At the time of the release, there was no alarm mechanism in place for the chlorination unit even though the plant is not staffed 24-hours per day. At the time of the chlorine release, there was no set maintenance schedule for the chlorine analyzers other than a yearly cleaning. At the time of the release, there was no set procedure for notification of local and state agencies in the event of a release. At the time of the inspection, a low-level chlorine alarm had been installed on the dose chlorine analyzer and plans to install a high level alarm were being finalized. Both Mr. Kerlin and Mr. Moroz indicated that the planned alarm system would incorporate a low and high alarm on both dose and residual analyzers. The alarms will call-out to a message service that will in turn, phone-out to a designated operator(s).