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Patricia Leary - 5 - 16 January 2009 "The Discharger shall attach a cover letter to the SMR. The information contained in.the cover letter shall clearly identify violations of the WDRs, discuss corrective actions taken or planned, and the proposed time schedule for : corrective actions. Identified violations must include a description of the requirement that was violated and a description of the violation." SUMMARY The Discharger has a history of non-compliance with the requirements of its Order, which prescribe the manner in which reclaimed wastewater may be utilized at the Park with methods that protect human health and the environment. The Discharger is also in violation of several requirements specified in its Monitoring and Reporting Program including: not reporting both I the Minimum Level and the current. Method Detection Limit for any of the constituents, and deficiencies in meeting the requirements for the SMR cover letters. Additionally, the Discharger is non-compliant with its CDO time schedule deadlines to submit several reports to the Central Valley Regional Water Board. CDO R5-2006-0040 provided a time schedule for the Discharger to comply with reclamation specifications for total coliform organisms and turbidity by 1 May 2008. The Discharger has reported reclamation specification violations at the Park from 1 May 2008 through 31 September 2008. Based on the Discharger's SMRs submitted from May 2008 through September 2008, the Park remains unable to meet the reclamation specifications and is in violation of WDRs Order R5-2006-0039 and CDO.R5-2006-0040. The following a summary of violations at the Park: rY f� z 1. The Discharger has consistently violated the Reclamation Specifications for turbidity, total coliform organisms, biochemical oxygen demand, total suspended solids, and pH. -A Cease and Desist Order provided a two-year time schedule to comply with the turbidity and total coliform organism limits by 1 May 2008. However, the facility continues to be unable to comply with the requirements. 2. The Discharger is in violation of the Construction, Operation, and Maintenance Specifications, Section C.5.a.i, which requires: "Wastewater shall be oxidized, disinfected, and in this situation filtered (to assure effectiveness of the ozone disinfection process) or equivalent pursuant to DNS criteria for the use of recycled water at a Golf Course with j restricted access in Title 22, CCR, Division 4, Chapter 3 (Title 22)." 3. The Discharger is in violation of compliance deadlines pursuant to its CDO by failing to submit its Compliance Workplan/Implementation Schedule, Pollution Prevention plans for all required constituents, and Progress Reports. 4. The Discharger is also in violation of the Monitoring and Reporting Program by: a. Failing to report the percent removal for biochemical oxygen demand and total suspended solids pursuant to Section X.B.3.