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