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M-30-93 TUE 8:28 7nCKTCN PLATING INC. FAX N0. 209 4644010 P. 01 <br /> w <br /> - <br /> an . <br /> J i <br /> CERTIFIED MAIL <br /> February 21 , 1991 <br /> Stockton Plating <br /> 632 South E1 Dorado Street <br /> Stockton CA 95206 <br /> Attention; Richard Leland, President <br /> BYPASSING PRETREATMENT VIOL1iTIONs, , - ,�QMPLLAW o,RDeg <br /> on December 20, 1990, an environmental control officer inspected <br /> your facility. A hose was observed going into the final discharge <br /> sump where pretreated wastewater is discharged to the sanitary <br /> sewer. A sample was taken. The pretreatment operator, John <br /> Barnard, stated that he was emptying a spent tank containing an <br /> aluminum solution. He further stated that since there were no <br /> limits for aluminum there was no reason to pretreat the waste. <br /> When asked if testing had been done to determine if there might be <br /> other metals present he had no answer_ A 500 ml sample was taken <br /> out of the hose that had a sump pump at the end of it. <br /> The sample results are attached and show violations for copper, <br /> nickel, and zinc with respect to 40CFR Part 413 .14. Categorical <br /> pretreatment standards are Federally mandated. Because this waste <br /> was not pretreated, you are also in violation of Section 7-089. 14 <br /> which pertains to National Categorical Pretreatment Standards. <br /> Copies are attached. <br /> We regard these as very serious violations because this waste was <br /> not tested or pretreated before it, was discharged to the sanitary <br /> sewer. The Regional Wastewater Control Facility is designed to <br /> treat conventional waste such as biochemical oxygen demand and <br /> suspended solids. It is not specifically designed to treat copper, <br /> nickel, zinc or other metals, which end up being concentrated in <br /> the sludge generated by the wastewater treatment plant. In <br /> sufficient concentration these metals could cause the sludge to be <br /> deemed hazardous waste which would result in dramatically increased <br /> disposal costs. This would result inan unfair burden being placed <br /> on the taxpayers of this City. For this reason, Federally mandated <br /> programs require the wastewater plant to administer a pretreatment <br /> program so that industries treat their nonconventional wastewater <br /> f1 by removing metals and adjusting the pH_ <br />