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White Slough Water Pollution otrol Plant -5- • 21 March 2000 Inspection Report 6. Standard Provision and Reporting Requirement, General Reporting Requirement B.3 states, "The Discharger, upon written request of the Board, shall.file with the Board a technical report on its preventive (failsafe) and contingency (cleanup)plans.for controlling accidental discharges, and .for minimizing the effects of such events." PERMIT AND OTHER VIOLATIONS: Based on staff review of the applicable permit conditions of Order 93-090 and the Standard Provisions and Reporting Requirements, the following violations occurred as a result of the 4 January 2000 chlorine excursion: WDR Order No. 93-030, Effluent Limitation B.2. Excursion violated effluent chlorine limitation of 0.1 mg/l daily maximum allowable. Order No. 93-030 Receiving Water Limitation F.4. Receiving water samples were not collected by Discharger to evaluate chlorine residual and therefore it is impossible to evaluate if receiving water residual chlorine concentrations exceeded permit limits. However, there is minimal dilution at the outfall location and it is likely that receiving water residual chlorine concentrations exceeded the 0.01 mg/1 limitation. Standard Provision and Reporting Requirement General Provision A.6. Other than an annual cleaning, there were no set maintenance schedules for the operation and maintenance of the chlorine analyzers at the time of the excursion. This constitutes improper operation and maintenance of the chlorine analyzers. The facility is not staffed 24-hour per day and there were no alarms on the chlorine analyzers at the time of the release. This also constitutes improper operation and maintenance of necessary equipment allowing for the violation to continue for several hours. Standard Provision and Reporting Requirement General Provision A.17. Receiving water samples were not collected or analyzed by the Discharger immediately following the chlorine excursion. Visual observations of the full length of the receiving waters, to the confluence of White Slough, were not made until 5-6 hours after the identification of the release. This delay did not allow for adequate determination if a fish kill occurred or the extent of detectable chlorine concentrations in the receiving water. California Water Code 13271 Notification Requirement Pursuant to Section 13271 of the California Water Code, upon knowledge of a reportable quantity discharge, notification of the discharge must be made immediately to the Office of Emergency Services. CONCLUSION AND RECOMMENDATIONS: As a result of the discharge of chlorinated effluent on 4 January 2000, the City of Lodi violated Order No. 93-030, NPDES Permit No. CA00792433. The following summarize my recommendation for follow up to the violations. 1. The Discharger should develop a maintenance schedule for the chlorination and dechlorination units. This schedule must be submitt;,d to Regional Board for review.