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STAFF REPORT • CITY OF ESCALON, ESCALON WASTEWATER TREATMENT PLANT 2 CONSIDERATION OF A CEASE AND DESIST ORDER power for one day during constriction -resulted in significant odors that lasted approximately three weeks. Since adoption of the revised WDRs in June 2000, objectionable odor complaints related to the facility were documented in July and August 2000, August 2001, June and July 2002, and July and August 2003. In July 2003, staff of the San Joaquin Valley Air Quality Management District (SJAQMD) received 56 odor complaints regarding the City of Escalon wastewater treatment plant over a 9-day period. The SJAQMD issued five violations for odor generation. During that same period, Regional Board staff received numerous telephone calls and five written complaints regarding the odor generated by the Discharger's wastewater plant. The complainants report that odor conditions have been present for years, generally from mid-July through September. Notices of Violation (NOVs)were issued to the City for objectionable odors in August 2000, September 2002, and July 2003. All the NOVs informed the City of its responsibility to control the odors as required by their WDRs. The Discharger has informed staff that the facility is being overloaded with industrial wastewater and/or that the wastewater is not properly pH neutralized when it reaches the wastewater plant. Review of the data in the Discharger's Annual Monitoring Reports indicates industrial wastewater loading rates industrial wastewater loading rates increased from a total of 2.4 million pounds of BOD in 2001 to 3.1 million pounds of BOD in 2002. Data for 2003 is not yet available. The March 2000 Report of Waste Discharge anticipated that industrial wastewater would have a BOD loading rate of 40,000 lbs/day at a flow rate of 3.4 million gallons per day. Review of the Annual Reports indicates organic loading rates have been lower than the design criteria. However, because odors have been documented at significantly lower loading rates than assumed in the design, further investigation of the cause of the odors is warranted. Requirements of the Proposed Cease and Desist Order The proposed C&D Order requires immediate compliance and management changes at the facility to control odors. The proposed C&D includes the following: The Discharger is required to immediately comply with WDRs No. 5-00-142 Discharge Specification B.6, the odor control specification of the Discharger's WDRs as soon as possible. Staff believes that compliance with the requirement can be accomplished by effective pH neutralization of the industrial wastewater and limiting BOD loading rates to manageable levels. The Discharger is required to submit a technical report that evaluates the treatment capacity of the industrial wastewater system by 4 December 2003. Central to the treatment capacity evaluation will be the control of nuisance odors. The schedule for the submittal will allow additional data collection through the processing season for subsequent analysis and possibly some pretreatment pilot tests. Once the treatment capacity of the facility is established, the City shall implement a pretreatment program that requires the industrial wastewater dischargers to comply with loading limits that are within the treatment capacity of the City system. Note that this requirement will not limit the industrial dischargers from operating at their desired higher processing rates but it will limit their discharge to the