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California ktgional Water Quality`Control Board - Central Valley Region Winston H. Hickoz Sacramento Main Office Gray Davis Seeretarvfor Internet Address: http://w .sw cb.ca.gov/—mgcb5 Governor Environmental 3443 Routier Road,Suite A.Sacramento,Califomia 95827-3003 Protection Phone(916)255-3000•FAX(916)255-3015 13 December 2000 CERTIFIED MAIL 7099 3220 0005 3846 3700 Mr. Moms Allen, Director Department of Municipal Utilities 2500 Navy Drive. Stockton, CA 95206-1191 i NOTICE OF VIOLATION, TRANSMITTAL OF PRETREATMENT COMPLIANCE AUDIT REPORT,AND WATER CODE SECTION 13267 REQUEST FOR ADDITIONAL INFORMATION, CITY OF STOCKTON REGIONAL WASTEWATER CONTROL FACILITY,SAN JOA QUIN COUNTY Enclosed is a copy of the Pretreatment Compliance Audit (Audit) Report of the City of Stockton Regional Wastewater Control Facility(City), conducted during August and September 2000. The Audit included interviews with City pretreatment staff, a review of the City's overall pretreatment program and legal authorities, specific file reviews of seven significant industrial users (SIUs) for the years 1999 and 2000, and on-site inspections of two categorical industrial users (CIUs) and one non- categorical SIU. A legal authority review of the sewer use ordinance will be completed as part of this Audit and the findings will be sent separately. In general, the Audit found that the City is under-staffed to accomplish all of the necessary requirements of the Federal Pretreatment Program. The Audit Report presents recommendations which, in our opinion, would allow Stockton's Pretreatment Program to operate more effectively. The Audit Report also specifies violations of Federal Pretreatment Regulations that were identified during the Audit. The specific violations are cited in the enclosed Audit Report and are summarized as follows: Staffing Levels. The City has not maintained adequate staffing levels to effectively operate the program. This is a violation of Provision F.12.d. of Order 94-324 which requires the Discharger to provide requisite funding and personnel to implement the program as provided in 40 CFR 403.8(f)(3). Industrial Waste Surveys. The City has failed to actively update and report CIUs, SIUs and minor industrial users (Ns) through Industrial Waste Surveys. This is a violation of Provision F.12.c. of Order 94-324 pursuant to 40 CFR 403.12(i)(1) and 403.8(£)(2). Enforcing Pretreatment Requirements. The City has not issued an enforceable permit to a CIU (Gillis Plating) as required by 40 CFR 403.8(f)(1)(iii). This is a violation of Provision F.12.b. of Order 94- 324. California Environmental Protection Agency EJ Recveled Paper