SITE INFORMATION AND CORRESPONDENCE 1980-1999

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testing for sulfide compounds should be done twice annually. Sulfides are often a source or odors and gas buildup and industrial waste may contain significant amounts of sulfides. Certain plating tanks are listed under 40 CFR 240 as sources of hazardous waste. Under the Mixture Rule, if the contents of those plating tanks were discharged through a dedicated pipe, all of the contents of that pipe would become a hazardous waste. Lodi has never developed adequate local limits. To the extent that the City allows hazardous wastes to be discharged into the dedicated pipe for disposal to land they would need a RCRA permit. For example,molybdenum is typically not found in significantnificant quantities from domestic sources but is, however, frequently associated with industrial sources. We are concerned that molybdenum may be discharged to land. It is crucial that the Discharger be required to conduct wasteload allocation monitoring on each industry which proposes to discharge industrial wastes to the segregated pipeline. Simply requiring the Discharger to monitor at the end-of-pipe is not sufficient to determine potential hazardous waste discharges into the system and would violate federal regulations. The Mixture Rule (40 CFR 240) applies to the proposed cannery segregation line where even a small quantity of hazardous waste would effectively render the entire discharge hazardous. The wasteload allocation monitoring in the current NPDES permit must be retained and extended to the land application permit.The Discharger must develop local limits that will ensure that the cannery waste-stream meets sludge quality criteria specified in 40 CFR 503 even if the dedicated pipeline is limited to food processing industries. Canneries frequently have acidic and caustic discharges and often include other industrial activities such as can manufacturing and cooling tower discharges (which may contain metals,biocides and petroleum products). Pretreatment monitoring data are critical to the public review process and should have been included in the Tentative Permit. To the extent that staff disagrees with our belief that the industrial pipeline requires a RCRA permit,we would appreciate a response addressing the issue. C. Monitoring Of Effluent Of Industrial/domestic Reclamation Water. We believe that monitoring must include total dissolved solids as a composite. A continuous reading pH meter must be installed to verify compliance with the permit requirement C- 4 that"[e]ach pond shall not have an average pH less than 6.5 or greater than 9.0." The Discharger must also test for priority pollutants to ensure that industrial and domestic wastes are not discharged to land application. Since both biosolids and industrial irrigation waste water are being applied to land,the loadings of metals and other priority pollutants must be accounted for in DeltaKeeper,Tentative NPDES Permit,Lodi, 17 December 1999,Page 10.