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FACT SHEET ORDER NO. 5f-031 is <br /> -13- <br /> ATTACHMENT C <br /> CITY OF LODI <br /> WHITE SLOUGH WATER POLLUTION CONTROL PLANT <br /> SAN JOAQUIN COUNTY <br /> however, as the collection system does not handle domestic wastewater, and the wastewater does <br /> not pass through treatment works. <br /> Additional study of the metal finishing waste discharges is necessary to verify whether the wastes <br /> can be legally discharged to the industrial waste collection system. If the wastes cannot be <br /> -discharged to the industrial waste system, either the discharges must cease or the wastes must be <br /> discharged to the domestic wastewater system. Before the metal processing wastes can be <br /> discharged to the domestic wastewater system, the potential impact on the quality of treated <br /> wastewater discharged to Dredger Cut and the impact on the City's sludge must be determined and <br /> appropriate adjustments made to the industrial pretreatment program and the effluent limits of this <br /> Permit. A provision has been included in the permit which implements these studies and provides a <br /> reopener for any necessary adjustments to the Permit. <br /> m) Groundwater <br /> The Discharger has installed seven groundwater monitoring wells in order to conduct monitoring of <br /> ground water upgradient and down gradient of the wastewater treatment facilities and the <br /> reclamation and biosolids disposal areas. This Order requires the Discharger to submit a report <br /> regarding the adequacy of the existing wells for this purpose, and the need for additional wells. <br /> Plans and specifications for any additional wells must be submitted for review and approval prior to <br /> construction. Any additional reclamation and/or biosolids disposal areas need adequate wells in <br /> plate and monitoring initiated for at least one year prior to use of those areas. <br /> If monitoring of the groundwater indicates that the discharge has caused an increase in constituent <br /> concentrations at the point of compliance, as compared to background, the Discharger will be <br /> required to conduct a study of the extent of groundwater degradation. If the study indicates the <br /> discharge has incrementally increased concentrations in groundwater, enforcement actions may be <br /> pursued and/or the permit may be reopened and modified. Points of compliance will be established <br /> as near to the discharge areas as practical, but shall not extend beyond property owned or controlled <br /> by the Discharger. <br /> n) Biosolids <br /> The Discharger currently mixes biosolids from the treatment plant with the effluent from the <br /> industrial wastewater holding ponds and effluent from the treatment plant, and discharges it to the <br /> 950 acres of City-owned agricultural fields surrounding the plant. <br /> The United States Environmental Protection Agency (EPA) has promulgated biosolids reuse <br /> regulations in 40 CFR 503, Standards for the Use or Disposal of Sewage Sludge, which establish <br /> management criteria for protection of ground and surface waters, set application rates for heavy <br /> metals, and establish stabilization and disinfection criteria. The Board is using the Standards in <br /> 40 CFR 503 as guidelines in establishing this Order, but the Board is not the implementing agency <br /> for the 40 CFR 503 regulations. The Discharger may have separate and/or additional compliance, <br /> reporting and permitting responsibilities to EPA, which are not covered by this Order. <br />