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Mr. George Lockwood!*E. <br /> October 20, 2003 <br /> Page 2 <br /> requirements. When compiling these documents, we noted that 1-5 crosses our <br /> property. Both entities deemed that travelers on 1-5 did not qualify as sensitive <br /> receptors as only stationary residences, schools, hospitals, and other immobile <br /> facilities were of concern. They did not feel vehicles qualify since passengers <br /> were only adjacent to the site for a very short time. <br /> c) The sections in the permit which you cite are contained in provisions regarding <br /> application of effluent and biosolids to adjacent lands and to the ponds, not the <br /> headworks which are the only location noted in your report as a source of odor. <br /> d) Odor issues have not been raised by the Board in the past, thus no extraordinary <br /> action has been deemed necessary by the City. In fact, the June 18, 1999, <br /> inspection report states, "The ponds all had adequate free board and no odors <br /> were noted." <br /> e) The City has initiated pilot testing of chemical additions to the trunk sewer to <br /> reduce 1­12S caused corrosion in this pipe. We intend to begin long-term <br /> chemical addition shortly thereafter. Since 1­12S is a significant cause of odors, a <br /> beneficial byproduct of this effort may be a reduction of odors at the headworks. <br /> 2) Warning Signs —The lack of clear warning signs around the property boundary has <br /> been rectified. New signs have been posted every 500 feet as required in <br /> Specification D.14 of the Facilities Waste Discharge Requirements (WDR). <br /> 3) Tailwater and Storm Water Control —The requirement to verify that these waters do <br /> not leave the facility is unclear. This can be done on foot during the applicable <br /> irrigation and rainy seasons. If the Board wishes that a topographical survey be <br /> prepared showing all the site features and grades, that can be done. <br /> In closing, we note that it has always been our goal to work with Board staff to maintain <br /> a high standard of operations, comply with State mandates and protect the environment. <br /> In particular, we note the past inspection reports by Ms. Leary, Mr. Fagerness, and <br /> Mr. Marshall, all indicated the City's facility was well operated and maintained. We take <br /> pride in these comments and try hard to meet or exceed our discharge requirements. <br /> Given that we have essentially the same facility and staff, it causes us grave concern <br /> that this inspection is so negative, and, in fact, the inspector could find not one good <br /> comment to make about the quality of treatment, the facility or the staff. <br /> If you have any questions, please contact me at (209) 333-6759. <br /> SaneIy, <br /> Richard C. Prima r. <br /> Public Works Director <br /> RCP/mg <br /> Enclosure <br /> cc: H. Dixon Flynn,City Manager <br /> Thomas R. Pinkos, RWQCB Executive Officer <br /> Patricia H. Leary, P.E., Senior Engineer, NPDES Section, RWQCB <br /> Donna Heran, San Joaquin County Health Department, Stockton <br /> Fran E. Forkas,Water/Wastewater Superintendent <br /> Del Kerlin,Assistant Wastewater Treatment Superintendent <br /> LCVRWQCB.DOC <br />