SITE INFORMATION AND CORRESPONDENCE

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r Mr. Moms Allen -2- 13 December 2000 Implementation of Programmatic Functions. The Audit found several accounts of the City failing to actively investigate and follow up with appropriate enforcement actions of SIUs (Com Products and Viktron) and a Special Use Permit ICT (Sierra Chemical) which violated their discharge conditions. The lack of enforcement is a violation of adequate implementation of programmatic functions as required by Order 94-324, Provision F.12.c. pursuant to 40 CFR 403.8(f)(2). Inadequate Local Limits. Adequate, technically-based local limits are needed to protect the City's collection system and to protect POTW workers and the public. The City is in violation of Order 94-324, Provision F.12.b. for not implementing necessary legal authorities as provided in 40 CFR 403.8 (f)(1). Improper Notification of Non-Substantial Program Modification. The City failed to notify the Regional Board of a March 2000 Emergency Order to increase the local limit for pH to SIUs of Collection System 7. The City is required to notify the Regional Board at least 45 days in advance of the change pursuant to 40 CFR 403.18 (d)(1). This is a violation of implementing programmatic function, Order No. 94-324, Provision F.12.c. Pursuant to Section 13267 of the California Water Code, the City of Stockton is required to submit a written technical report to the Regional Board, which summarizes the following subjects: 1. Describe what measures will be taken to increase staffing levels so that the City can come into compliance with Provision F.12.d. of Order 94-324. 2. Propose a plan to identify and incorporate Ills not presently permitted, including the referenced Gillis Plating site. The Annual Report shall be modified to identify all IUs, including Special Use permittees as required by 40 CFR Part 403.12(i)(1). 3. The City shall investigate and report what enforcement actions are being taken with the two specific cases cited within the Audit Report: 1) Corn Products unreported spill and 2) Sierra Chemical violations of a Special Use Permit. 4. Issuance of Special Use Permits requires more careful attention and review by City staff. Describe what measures will be taken to increase staffing levels or alter work practices to ensure adequate compliance and enforcement of Special Use Permits. 5. Describe what steps are being taken to reduce sulfide concentrations or their corrosive effects within Collection System 7. 6. Take immediate steps to begin a study of Local Limits revision. Provide a time schedule, which includes dates when a work plan will be developed,when the study will begin, and when changes to City Ordinances will be completed. Additionally, describe what changes will be made to the City's program to provide proper notification to the Regional Board of Local Limit changes (temporary or permanent) as required by 40 CFR 403.5 (c)(3).