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Patricia Leary - 4 - 16 January 2009 reported exceedances include turbidity and total coliform violations, occurring after the CDO time schedule for compliance passed, beginning 1 May 2008 through 31 September 2008. Other violations of final reclamation specifications include: total suspended solids, BOD, and pH. The list of violations is included with this memorandum as Attachment A. Several time schedule deadlines have passed without completion of the task by the Discharger. In addition to the failure to comply with the'l May 2008 compliance date prescribed for total coliform and turbidity, the Discharger has failed to submit.its Compliance i Workplan/Implementation Schedule, Pollution Prevention plans for all required constituents, and Progress Reports. It appears that the Discharger is still unable to meet reclamation specifications pursuant to its Order and CDO. MONITORING AND REPORTING PROGRAM VIOLATIONS Additional violations of the Monitoring and Reporting Program (MRP) defined in Attachment E of the Order include: 1. The Discharger has failed to report the average monthly percent removal for BOD and TSS in its SMRs as prescribed by IV.C.2: "2. Percent Removal: The average monthly percent removal of BOD 5-day at 20°C and total suspended solids shall not be less than 85 percent" 2. As shown by the frequent occurrences of reclamation specification exceedances, 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 DHS criteria for the use of recycled water ata Golf Course with restricted access in i Title 22, CCR, Division 4, Chapter 3 (Title 22)." 3. The.applicable Minimum Level and the current Method Detection Limit are not provided in the Discharger's SMRs for any of the constituents. i VI.B. MRP Requirements, X.B.7 "The Discharger shall report with each sample result the applicable Minimum Level (ML) and the current Method Detection Limit(MDL), as determined by the procedure in 40 CFR Part 936" i 4. While the Discharger provides a cover letter to its SMRs, the cover letters are deficient. to meet the requirements of the Order. The cover letters do not: (1) clearly identify violations of the WDRs, (2) discuss corrective actions taken or planned, (3).provide a proposed time schedule for corrective actions, (4) include a description of the I requirement violated, and (5) include a description of the violation. + VI.B. MRP Requirements, X.B.8