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City of Stockton - 4 - 13 December 2000 Pretreatment Compliance Audit drain by Sierra Chemical. The product was to have been dumped into a sanitary sewer manhole under a Special Use Permit issued by the City. The material dumped was 10,000 gallons of iron-contaminated chlorine product. Once in the storm drain, the material flowed to a stormwater retention pond where a portion of the product was inadvertently pumped by the City into North Littlejohn Creek (a water of the State). The OES notification alerted Mr. Fagemess of the Special Use Permit for this facility. An incident report filed by the City indicated that a Special Use Permit was issued to Sierra Chemical on 3 February 2000 by the City to allow it to dump high strength chlorinated stormwater generated on its yard into the sanitary sewer. The permit specified that the discharges were not to exceed any waste contaminant in excess of Specific Pollutant Limitation Section 7.089.16 (Local Limit of Municipal Code Discharge Standards). A 16 May 2000 Report of Discharge by Sierra Chemical to the City reported that 29 discharges of wastes with chlorine content as high as 3.3 % by volume and with a pH as high as 14 pH units were disposed to a sanitary sewer through a manhole. Twenty-four(24) out of the twenty-nine (29) discharges exceeded the Local Limit pH maximum of 10 pH units. The City did not notice the Discharger of the violation for the pH exceedances as required in the City's own ERP. This is a failure to implement pretreatment programmatic functions as required by Provision F.12.c. of Order 94-324 pursuant to 40 CFR 403.8 (f)(2) and risks worker safety and the physical integrity of sewer system. Despite the violations of pH exceedances of the stormwater discharges, on 2 August 2000 the City granted the discharger an additional Special Use Permit to discharge a batch of iron contaminated chlorine product to the sanitary sewer. The permit allowed Sierra Chemical to dump up to 10,000 gallons of 6% chlorine product with a reported pH of 11 into a sanitary sewer manhole at the east end of Industrial Way. Sierra Chemical dumped the product on 3 August 2000 in a stormwater collection box rather than the marked sanitary sewer manhole, which resulted in the above noted release to surface water. There are many aspects of the cited Special Use Permit that are disconcerting. One, it is unclear why Sierra Chemical was granted an additional permit in light of the numerous exceedances of the local limit for pH from the permitted stormwater discharges to the sanitary sewer. Two, the material discharged contained 6% chlorine, which is equivalent to a concentration of 60,000 mg/1 and should be considered a hazardous material. Three, the discharge was allowed to occur without adequate supervision or inspection by the City. Requirement: Users of Special Use Permits are IUs which must be regulated in the same manner as SIU or CIUs. The City must review discharge reports, conduct inspections, and take appropriate enforcement actions if violations of local limits or permit conditions are discovered. Recommendation: As is evidenced by the release of hazardous materials to the environment from the above example, issuance of Special Use Permits require a greater level of scrutiny by the City than is currently used. The City needs to provide adequate staffing levels to provide oversight of Special Use Permits. The