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C ��'" <br /> .� r <br /> * CITY COUNCIL • H. DIXON FLCNy Manager <br /> SUSAN HITCHCOCK, Mayor CITY OF L O D I SUSAN J. BLACKSTON <br /> EMILY HOWARD City Clerk <br /> Mayor Pro Tempore PUBLIC WORKS DEPARTMENT RANDALL A. HAYS <br /> JOHN BECKMAN City Attorney <br /> LARRY D. HANSEN CITY HALL, 221 WEST PINE STREET <br /> KEITH LAND P.O. BOX 3006 RICHARD C. PRIMA, JR. <br /> LODI, CALIFORNIA 95241-1910 Public Works Director <br /> Telephone (209) 333-6706 FAX (209) 333-6710 <br /> EMAIL pwdept@lodica.gov <br /> http:\\www.lodica.gov <br /> 0 C T 2 4 2003 <br /> October 20, 2003 ENVIRONIAZ—lT HEALTH <br /> PERMIT/SERVICES <br /> Mr. George Lockwood, P.E. <br /> Water Resources Control Engineer <br /> Central Valley Regional Water Quality Control Board <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3003 <br /> SUBJECT: Reply to Inspection Report Dated August 20, 2003 <br /> We submit this letter as our technical report in response to the issues raised concerning <br /> your June 20, 2003, inspection. The following addresses the three numbered issues <br /> raised in the transmittal letter, and the enclosure contains detailed comments and <br /> responses on the narrative and Attachment D in the Inspection Report. <br /> 1) Odor—The City does not accept your conclusions that occasional odors from the <br /> White Slough facility are significant. We note the following: <br /> a) The Water Code defines a nuisance as: <br /> §13050(m) "Nuisance" means anything which meets all of the following <br /> requirements: <br /> (1) Is injurious to health, or is indecent or offensive to the senses, or an <br /> obstruction to the free use of property, so as to interfere with the <br /> comfortable enjoyment of life or property. <br /> (2) Affects at the same time an entire community or neighborhood, or any <br /> considerable number of persons, although the extent of the annoyance or <br /> damage inflicted upon individuals may be unequal. <br /> (3) Occurs during, or as a result of, the treatment or disposal of wastes. <br /> The fact that a Board intern on her first trip to a wastewater treatment facility was <br /> "...seriously stressed..." by odors at the headworks hardly meets this definition. <br /> Nor does the addition of a few comments by other Board staff, particularly when <br /> there is no attempt to distinguish between possible odors from the City's facility <br /> and the adjacent dairy operation. <br /> b) The White Slough facility was built in the 1960's, at that location, partly in an <br /> attempt to stay away from "...an entire community or neighborhood, or any <br /> considerable number of persons..." At that time, 1-5 did not exist and no <br /> sensitive receptors were located in the proximity of the site. Both our Air Toxics <br /> Plan, required by the San Joaquin Valley Unified Air Board, and our Risk <br /> Management Plan, administered by the San Joaquin County Office of <br /> Emergency Services, address sensitive receptors in their respective reporting <br /> LCVRWOCB.DOC <br />