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Patricia Leary 0 -2- • 14 August 2008 Violations 13-31. The Discharger documented that, during start-up of the new tertiary filtration and UV disinfection facilities, the measured violations were the result of an improper sampling location and that moving the sampling location closer to the discharge of the disinfection system resulted in no violations. I deleted these violations because I concur with the Discharger's arguments that these violations were exempt as a result of an improper sampling location. Violations 32-36, 38-39. The discharger requested consideration as an SOU because effluent turbidities reduced the effectiveness of the UV disinfection system. These do not qualify as an SOU because the Discharger did not violate the effluent turbidity limitations or any other limitations. I consider this an operational error. I disagreed with the claim for an SOU. Violations 32, 34-36, 39, 41-46, 51-52, 54, 57-62, 64-68, and 70. WDRs Order No. 5-00-131 states that the weekly average coliform is to be determined as a 7-day median. The Discharger requested that coliform results be one median violation per week. I agree that the 7-day median can be interpreted as a static weekly median, rather than a rolling 7-day median. I reanalyzed the analytical results using a static weekly period (Sunday through Saturday). I deleted violations 32, 34-36, 39, 41-46, 51-52, 54, 57-62, 64-68, and 70 because these were improperly calculated as rolling 7-day medians rather than weekly medians specified by the WDRs. Violation 71. The Discharger documented that the exceedance was due to a sampling error and further documented that it had previously documented the sampling error. I deleted this violation. pH Violation 37. WDRs order 5-00-031 Effluent limitation B.7 states: "The discharger shall not have a pH less than 6.5 nor than greater than 8.5." The Discharger stated that the pH was 6.44-6.45 for 3 hours. This was a violation because the discharge pH was less than 6.5. 1 changed the violation from remarks 4 to remarks 3 because there were only two violations during the 180 day period. I retained the violation but it will not result in an MMP. No Surface Water Discharge Violations 46, 54. The Discharger documented that there was no discharge to surface waters. I deleted the violations. Liability Adjustments Violations 37, 48, 49, 53, and 56. After deleting other violations, violations 37, 48, 49, 53, and 56, non-serious violations, are the third or fewer violation during a preceding 180 day period and therefore do not result in assessed MMPs. Summary The total number of Group 1 violations is 0. The total number of Group 2 violations is 0. The total number of Group 3 violations is 25; 8 are subject to MMPs. The ACL decreases from $159,000 to $21,000. ATTACHMENT B