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STAFF REPORT -3- <br /> CITY OF STOCKTON <br /> capacity available in the tertiary ponds at that time. The City did not operate <br /> the plant in a prudent fashion as they should have to prevent violations of 19 <br /> and 20 June and when they occurred, the City did not take appropriate immediate <br /> actions to stop the violations. The City subsequently utilized pond storage <br /> capacity by not discharging on the 22nd and 23rd of June. <br /> At the time of the fish kill , there were factors which contributed to the <br /> severity of the situation. Among these are: <br /> 1. Very low alkalinity in the effluent meant there was little buffer <br /> capacity. When acid and chlorine were added, the pH dropped rapidly. <br /> 2. The chlorine demand was very high. This means that to achieve good <br /> disinfection, large amounts of chlorine had to be added. <br /> 3. On 11 June the Dissolved Oxygen (DO) in the River fell below 5 mg/l . <br /> When this happens Stockton's effluent requirements are 10 mg/1 BOD and <br /> Suspended Solids. If the multi-media filters had been in operation, <br /> they would have been used to reduce BOD and Suspended Solids. Since <br /> this was not the case, large doses of chemicals (including acid) were <br /> added instead, to meet requirements. These chemicals further reduce <br /> the buffer capacity and the pH of the effluent. <br /> 4. The San Joaquin River, due to pumping by the federal and state water <br /> projects, was actually flowing "upstream" toward the south at 10 to 11 <br /> mgd. Stockton ' s discharge was approximately 25 mgd at the time, <br /> constituting more than 2/3 of the entire River flow. The City claims <br /> that it was unaware of the low flow conditions at the time of the fish <br /> kill . It receives river flow data from the USBR monthly and calcu- <br /> lates flows for the previous month. The City should have been aware <br /> of the low flow conditions so it could have operated the plant in a <br /> manner which minimized violations. <br /> ADMINISTRATIVE CIVIL LIABILITY <br /> The complaint issued on 10 July 1985 (Attachment E) recommends that the City pay <br /> $50,000 pursuant to Section 13350 of the Water Code. Section 13327 states that <br /> in determining the amount of Civil Liability the Regional Board shall take into <br /> consideration the following factors: <br /> "The nature, circumstance, extent, and gravity of the violation or <br /> violations , whether the discharge is susceptible to cleanup or <br /> abatement, and with respect to the violator, the ability to continue <br /> in business, any voluntary cleanup efforts undertaken, any prior <br /> history of violations, the degree of culpability, economic savings, <br /> if any, resulting from the violation, and such other matters as <br /> justice may require (Water Code Section 13327) ." <br /> .;:: - 3 <br />