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U, <br /> CITY COUNCIL 1.1 LV"fl- <br /> H. DIXON FLYNN <br /> STEPHEN J. MANN, Mayor CITY O F L O D I City Manager <br /> ALAN S. NAKANISHI JACQUELINE L. TAYLOR <br /> Mayor Pro Tempore PUBLIC WORKS DEPARTMENT. Interim city clerk <br /> SUSAN HITCHCOCK <br /> RANDALL A. HAYS <br /> KEITH LAND CITY HALL, 221 WEST PINE STREET City Attorney <br /> PHILLIP A. PENNINO P.O. BOX 3006 <br /> LODI, CALIFORNIA 95241-1910 RICHARD C. PRIMA, JR. <br /> (209) 333-6706 Public Works Director <br /> FAX (209) 333-6710 <br /> EMAIL pwdept@lodi.gov <br /> http:\\www.lodi.gov <br /> April 14, 2000 <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> Kenneth D. Landau, Supervising Engineer <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3003 <br /> SUBJECT: Response to Notice of Violation <br /> In response to your March 21, 2000 letter (enclosed), we submit the following <br /> information to address your request. Our responses are numbered to correspond with <br /> the items requested. <br /> 1) Chlorine Analyzer- At the time of the inspection, Board staff requested the <br /> Operation and Maintenance (O&M) Manual and the Standard Operating Procedures <br /> (SOP) for the chlorine analyzers. The manufacturer's O&M Manual was produced <br /> for inspection. This manual details a variety of maintenance to be performed to the <br /> chlorine analyzers. City staff utilizes this manual for more detail than the annual <br /> cleaning cited in the inspection report. I believe the comment about annual cleaning <br /> in the inspection report was a misunderstanding to questions posed to Brett Moroz <br /> and Del Kerlin. The annual maintenance was intended to cite how often the units <br /> are disassembled and serviced as mandated by CAL/OSHA through our <br /> Process Safety Maintenance Program. Our daily inspection sheets (Exhibit A) are <br /> used to inform and track daily maintenance to the entire facility, in addition to the <br /> chlorine analyzers. Additional maintenance duties are shown in a General SOP <br /> (Exhibit B), which also details cleaning and operational functions. With regard to a <br /> specific SOP for the chlorine analyzers, we do not have a specific procedure for the <br /> analyzers at White Slough. Brett Moroz trains new staff utilizing the operating <br /> procedures in the manufacturer's O&M Manual, which outlines how the units should <br /> be operated. This procedure has been utilized for many years and has been <br /> successful in training facility operations staff. The situation that led to this incident <br /> was an anomaly not previously encountered. To ensure it's not repeated, we have <br /> modified Exhibit B to include daily cleaning of the drain line and flow tube to <br /> eliminate fouling. <br /> 2) Alarm Systems - The alarm system, which was being modified at the time of <br /> inspection, was completed and checked for proper operation on February 11, 2000. <br /> The current analyzers have high- and low-chlorine set points, which can be set to <br /> WTRQLTYCNTRL9903 <br />