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STAFF REPORT CITY OF ESCALON ESCALON WASTEWATER TREATMENT PLANT SAN JOAQUIN COUNTY CONSIDERATION OF A CEASE AND DESIST ORDER Background The City of Escalon (Discharger) owns and operates a wastewater treatment facility at 25100 West River Road, Escalon, San Joaquin County. The discharge is regulated by Waste Discharge Requirements (WDRs) Order No. 5-00-142, adopted by the Regional Board on 16 May 2000. The City system treats domestic and industrial wastewater. The industrial wastewater is generated seasonally by two food processing facilities. The industrial wastewater discharged to the City system has overloaded the treatment capacity, resulting in nuisance odors and numerous odor complaints to Regional Board staff. These odor complaints'have been a regular occurrence since 1996. The WWTP is on the north side of the Stanislaus River, while a country club and residential developments are on the south side of the Stanislaus River. The City system consists of mechanically aerated treatment ponds, followed by discharge to evaporation/percolation ponds. Industrial wastewater is delivered to the treatment plant in separate pipes, is treated in separate ponds, and is discharged to separate evaporation/percolation ponds than the domestic wastewater. Industrial wastewater treatment consists of four mechanically aerated treatment ponds and nine evaporation/percolation ponds. The Discharger allows the industrial wastewater ponds to dry completely prior to initiation of the industrial wastewater generation season. The ponds are disced and ripped annually to maintain percolation rates. The industrial dischargers consist of Escalon Premier Brand (tomato canner) and Eckert Cold Storage (frozen pepper processor). The industrial dischargers' processing season runs from approximately May through December. In 2001 the total industrial wastewater discharge was approximately 296 million gallons; while in 2002 the total industrial discharge was approximately 330 million gallons. Violations of Waste Discharge Requirements Generation of nuisance odors is prohibited by the Discharger's WDRs. WDRs Discharge Specification No. B.6 states, "Objectionable odors originating at this facility shall not beperceivable beyond the limits of the wastewater treatnzent facility." Odor complaints regarding the facility have been a regular occurrence during the vegetable processing season. Odor complaints related to the facility were documented in October 1996, November 1997, and September 1999. In March 2000, the Discharger submitted a Report of Waste Discharge and the facility WDRs were updated with revised WDRs adopted in June 2000. At the time of the WDR update, the Discharger sought a higher flow rate for the industrial wastewater and as part of that request,designed additional treatment consisting of pond enlargement and additional mechanical aeration capacity at the facility. When the improvements were completed, the higher flow rate was approved. However, the improvements have not been successful in controlling the nuisance odors and the construction of additional electrical service in July 2000 - which required shutdown of electrical