STATE 4F CALl~'ORNIASTATE WATER RESOURCES CONTROL BARD

In the Matter of the Petition of ~Crestline Sanitation District forReview of Order No. b-7$-23 of theC~3ifornia Regional Water Quality

~ontrol Board La.hontan Region. )i le No , A-2 Cab

ORDER N4. WQ ?$-- l2

By its petition dated May ~., . 197, Crestline

Sanitation District requested review of Order No. b-7$-23

of the California Regional Water Quality Control Board,

Lahantan Region. Qrder No. 6-7$-23 is an enforcement order,

pursuant to California Water Code Section 133Q1, which was

~ adopted April l3 , 197.

I. BACKGROUND

The ~Crestline San3.~ation District (hereinafter

~Ghe 'District") collects, greats and disposes of domestic

wastewater from the ~ewered areas of Crestline, Lake Gregory,

Valley of Enchantment, and the Sil~rerwood Lake recreati+~nal

areas, al3 located in San Bernardino County. Three separate

treatment plants, Houston Creek, Seeley Creek and Cleghorn,

treat the District's wastewater. The approximate design

capacities of these separate plants are .7,, .2, and .2

million gallons per day (mgd), respectively. Effluent

from these plants is discharged to a single ou~fall pipe-

line which conveys all of the t~ea~ed wastewater to the

f' Las Flores Ranch area, north Silverwood Lake.~ Attached

hereto as Appendix "A" is a map indicating the ,general

configuration and location of these facilities.) The

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effluent is disposed of by discharging to either pasture

irrigation or to two sand filtration percolation beds

located near the West Fork of the too jave River. Th.e waste

discharge by the District is governed by waste discharge

requirements contained in Order No. 6-'~'~-67,. adopted on

June 30, 1977: pursuant to Water Code Sec~tian 13 263 , by

the California Regional Water Quality Control Board,

I~ahontan Region (hereinafter the "Regional Board") .

Due to heavy rainfall in the San Bernardino

mountains during January, February, and March of 19?$,

large amounts of infiltration and inflow entered the

District's sewage collection system. During January,

February, and March of l97$, waste discharges

contrary to the District's requirements in Order No. 6-77-67

occurred, including various discharges of untreated

sewage into Lake Gregory and Seeley Creek, and discharges

of disinfected secondary ,effluent to Houston Creek,

Silverwood Lake and the West Fork of the Mojave River.

The Regional Board conducted a public hearing

on April 13` 197, prior to considering and adopting

Order No. dam?$-23. At the hearing evidence generally

concerning the improper waste discharges of the District,

their causes, and correction efforts by the District was

offered by the Regional Board staff , representatives of

the District, the Department of Health, the Department of

Water Resources, and San Bernardino County. The Regional

4r%' {

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Board adopted Order No. 6-?$-23 which directs that the

District "cease and deli St forthwith from discharging

wastes contrary to requirements and discharge prohibitions... "

and which prohibits "additional discharges ta~the sewer

system by dischargers who did not discharge into the

system prior to March 20, 197$", excluding certain enu-

mera~ed projects and discharges. Qrder No. b-7$-23

contains the following findings, among -`others

"b. Irlspectians and investigations byBoard staff and reports received from theCrestline Sanitation District indicate that,during the months of January, February andl~.rch, 197, the discharger has violated thedischarge specifications listed in Finding Na. 2,the discharge prohibi~ians listed in Finding Na.4 and Section 1337E of the Water Code."

°'?• The cause of the violations that occurredin January, February and March, 197$, was exces-~ive flow into the collection, treatment anddisposal facilities. "

"9• The discharger has violated and isthr.~atening to violate the r~q~irem~nts andprohibitions listed in Findings Nos. 2 and 1~above and Section x.3376 of the dater Code."

"10. Any increase in the discharge of wastewill increase the violation or likelihood ofviolation of waste discharge requirements andwill further unreasonabl3~ impair water quality. "

order No. ~-7$-23 also directs the District to

report to the Regional Board by May 1, 197$, and quarterly-

thereafter., describing progress made toward compliance with

requirements, and provides authority far the ~cecutive

officer of the Regional Board to request that the Attorney

General take appropri~.te judicial enforcement action if the

District fails to comply with the Order.

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The District's Petition for Review contends

generally that Order No. b-7$-23 is invalid and not supported

by ,the evidence before the Regional Board, and,.. therefore,

.that Order No, b-7$--23 should be rescinded. Pursuant to

the Notice of .Hearing .dated N1ay 3: 197$, and the Amendment

to Notice of Hearing dated May 9,..197$, a public hearing

was held May 15 , 19?$.. by the State T~ater Resources Control

Board State Board), Mr. Maughan and Mr. Adams presiding,

~o receive evidence relative to the adoption of order No.

6-7$-23. Pursuant to Water Code Section 13320(b), the

evidence before us in this matter consists of the record

before the Regional Board and other relevant evidence intro--

duced at~ the .hearing of ;May l5 , l97$.___

II. CONTENTIONS AND FINDINGS .

It is not disputed that Crestline Sanitation

District discharged wastes in violation of requirements

. ~ during the, first few months of 197~.~ Neither does there

appear ~o be any disagreement concerning the general cause

of the various violations cited by .the Regional Boardf,

is ~, , sustained heavy ~~asonal r~.nfall which caused

~. See Regional Board Reporter's Transcript {R.T. } of~ April 13 , 197$ , hearing,, at._ pales 3 ~. 51-5 5 ~_ State Board

Reporter's Transcript of May 15 19'7 , hearing, at pages101, 101~,~ 10?-109, 111-112 and ~chibits 1, 2, and A; andPetition of Crestline Sanitation District.

..

2 T'he District has described the causes in the hearingsand in their petition. See Regional Board R.T. at pages 31~, ~0,~.3 , ~.9-54, and b6, and State Board R. T, at pages 103 , 112,

' 125. The Regional Board made a finding as to the causesof violations, quoted herein at page 3.

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lar ~ amounts of infiltration inflow3 to the District's~ ~

collection, treatment, and disposal facilities. However,

the Di stri c~ asserts that Regional Board Order No. 6--7$-23

is improper and contends in summary that the subject order

violates the intend of various portions of the California

G~Tater Code and California Administrative Code and that

certain findings of the order are not supported by the

evidence presented to the Regional Board. These issues

are discussed separately below.

A. Are significant discharges in violation of requ3.re-

menu by Grestline Sanitation District threatened

' or likely to continue?

Among other enforcement mechanisms, the California

t~at~r Code provides in Section 13301 for the adoption of

cease and desist orders directing compliance. with appro-

priate requirements. Compliance r~.ay be obtained in one of

three ways, as Section 133b1 states4

"mien a regional board finds that a s~i.schargeof waste is taking place or threatening totake place in violation of requirements ar dis-~charge prohibitions prescribed by the regionalboard or the state board, the board may issuean order to cease and desist anc~ direct that

3. The term infiltrationfinflow refers to waters, whichare not wastewaters, .entering the T~istrict's ,collection andconveyance system either from undergrauncl sources (infiltra-tion ), such as high groundwater, or from surface flt~ws{inflow } , such as streams or surf ace stormwat er drainage,and contributing t+a the flows which must be treated and

a disposed of. No attempt has been made to separate thevalum~ of flow in the District's system which is attribu--table to inflow from that due to infiltration, nor is itnecessary to do so here.

those persons not complying with the require-ments or discharge prohibitions (a) +~o~p~-Yforthwith, (b) comply in accordance with a 'timeschedule set by the board, or (c) in the eventof ' a threatened' violation, fake appropriate reme-dal or preventive action."

State Board regulations, in particular Section

22.0, et seq. , of Title 23, California Administrative Code,

provide additional guidance to the Regional Boards in the

application o~f cease and desist orders. Section 22.0

recommends the usage of cease and desist orders as follows:

"A cease and desist order should be issuedwhenever significant violations of waste dis-charge ~ r~q~em~~.t~~ or prohibitions are. threatenedor'such violations ar+e occurring or have occurredand there is a likelihood that the violationswill continue in. the future.

It is the position of the District that, notwith-

standing the c~.ted violations of requirements, the Regional

'Board's adoption of a cease and desist order was improper,

because the District had promptly corrected the problems

causing violations , and .because the District

has an extensive ongoing water quality control program ade-

quate to prevent the recurrence of any such va.olations.

To address this issue we' must determine first

whether the evidence presented to the Regional Board and

to the State Board indicates that significant violation is

of discharge requirements have accursed and are threatened

in the rear future: Second', we must consider whether the

means chosen for obtaining compliance way appropriate,~ tt

~ . e. ~ the direction too comply forthwith

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Although it is admitted that waste discharges

contrary to requirements have occurred, neither the Water

Code nor the State Baard`s regulations define "'significant"'

as the term is used in Section 22t~U of the Board's regu-

lations, cited above, with respect to violations of waste

discharge requirements. For the issues to be determined

herein it is sufficient to indicate that ."significant•'

relates to the relative seriousness of a violation in its

effect on water quality and means other than a "technical"°

violation., such as a violation of monitoring or reporting

requirements or sampling and analysis variation within the

standard of tolerance for error of the testing procedure.

As a general matter we must consider repeated raw sewage .

discharges to. surface waters in close proximity to

dwellings and discharges cif secondary effluent to surface

waters used for unrestricted water contact recreation and

for domestic supply to be violations which are ~'si gnifi cant"'

to water quality anal to the public health. ~ This description

fits the violations of requirements by the District. We

consider such violations to be significant, notwithstanding

any dilution. of wastes that ma.y have occurred due ~o

seasonal rainfall and run-off.

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Given the nature of the violations cited and

the measures taken to correct them, are such violationsi

likely to recur during or after the next moderate rain-

storm in the Crestline area of the San Bernardino mountains

{ipe., even if arguably last season's rainfall is consideredi

unusually heavy)? For the reasons set forth below, we

conclude that it was proper for the Regional Board to

issue a cease and desist order. However, it is our opinion

that, due to the nature and history of violations of re-

quirements in this case, it was not appropriate to direct

compliance °'forthwith". Based on our review of the record,

we are convinced that compliance should be directed in

accordance with an appropriate time schedule,~as authorised

by Water Code section 13301. We propose to modify Regional

Board Order No. 6-7$-23 by adopting such a time schedule

as a part of this order.

~.. At the hearing of May 15 , 197$, some evidence wa.s presentedconcerning the severity and frequency of individual stormsduring the 197?-7$ winter season and the period of recurrenceof this type of season. This evidence supports the generalconclusion that the precipitation total and storm patternwere somewhat unusually high and frequent, respectively, al-though individual storms were generally not of a magnitudeexceeding between 10 and 20 year recurrence frequency. StateBoard. R.T. of May 15 , 19?$, at pages 34-35 , 101-102, and 127. }

However, requirements of Order No. 6-~?7-6? of the RegionalBoard indicate that the facilities should be protected againstwaters of up to 100 year storm or flood frequency. SeeLahontan Regional Board Order No. 6-~7?-67, Section I.D.3.No objection to this requirement was raised when Order No.b-77-67 was adopted, or immediately thereafter.

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The District's violations of requirements are

described in detail in the record before us (see footnote 1,

infra), as are its facilities. It is only necessary here

tc~ indicate certain facts relative to these subjects that

are significant to our conclusions. To the extent that

improper discharges occurred due -Go equipment failure, including

bs~oken laterals , main or outfall pipes : or manholes , the

District corrected the failures as soon as possible after

discovery, including relocating a pcartion cif. the outfall

~ line where ~t parallels Highway 13 $. However, certain in-

adequacies have been exposed in the Districts's facilities

as a result c~~' the precipitation which occurred during

1977-?$, which surport the issuance of a cease and. desist

order with a dime schedule.

Evidence in the record suggests that certain

areas will continue to be substantially likely to expe-

rience waste discharges contrary to requirements absent

preventive measures in addition to the District°s described

programs far .water quality control in general and fors

infiltration/inflow correction specifically as presented to

the Regional Board. Testimony concerning these preventive

measures was received by the State Board at the May 15, 19?$,

hearing. Specifically the problem areas include the col-

lection system in the Seeley Creek area, identified as general-

ly the area contained in Assessment District No. 5; the col-9

lection system in the Lake Gregory area, identified as general-

ly the area contained in Assessment Districts Nos. 1,2,3, and ~.;i

and the need to provide additional capacity in (or to relocate)

-~a

the disposal facilities located st the Las Flores Ranch.

These problem areas are discussed below.

.The Seele~r Creek area collection system ex-

perienced several problems during the past winter, which

are attributable in part to its location close to the bed

of Seeley Creek. In addition to actual equipment failures,

certainr portions of the system were exposed by storm flows,

which washed away protective coverings, making these parts

of the system vulnerable to breakage when additional flows

occur in Seeley Creek. However, at least some additional

protection of the laterals and pip~l~.nes is necessary prior

to the next moderate storms in the area to remove the threat

of discharge.

The Lake Gregory area collection system presents

a problem of continuing inflow/in~'iltration, despite the

District's ongoing program, due to its age and what has

been demonstrated to be a low point in the system which

is particularly vreak. The age of some lines may make it

difficult to control infiltration/inflow adequately with-

out replacing them._ In addition to whatever replacement

of lines is determined to be necessary, steps must be

taken to prevent backup and overflow of the system at its

low point. The District has proposed the installation of

a pump station to prevent overflow from the ma.nhole~ located

5~'

-~11-

north and west of Lake Gregory.

pages 1.13 ~ 125-126, x.30, x-35•

(See State Board R. T: at

A number of the District's violations of require-

menu occurred a~ the site of final disposal of the wastes,

~'r~om the testimony received by both the State and Regional

Boards it appears that these improper waste discharges were

nat solely the result of the high flows in the system due

to infiltration/inflow. Zne outfall line close to the dis--

po~al area $uff~red breaks which should be prevented in the

future bar installation of a pressure relief valve, and the

sand filtration/percolation ponds, which are the primary

disposal area when the wastewaters cannot~be disposed of by

irrigation, do nat have actual disposal capacity equal to

design disposal capacity. Their capacity pan be sncr~ased

either by adding pond area or by relocating the disposal

area to obtain better percolation capability. (See State

Board R.Te'at pages 135-i36.~ The District apparently

recognizes the need to correct deficiencies in the disposal

system before a new rain ~ season again increases wasteflaws

by the addition of infiltration/in~'low, although c+arrectian

was not proposed at the time of the Regional Board hearing.

(See Regional Board R.T. at pages 39, 52-53 • }

Finally, a potential area for future discharge

violation has been identified in that portion of the

District's 21 inch outfall line that parallels Highway 13$~

This portion of the outfall is located on the downhill side

of the highway right-of-wad, since the District was denied

permission to install it on the uphill sidea Testimony

before the Regional Board indicated that slippage of the

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ihighway caused the break in the outfall and consequently

the discharge of secondary effluent which reached Lake Silver-

wood. The portion of the outfall which failed has been

relocated to the uphill side of the highway right--of-way.

This area of the outfall presents a difficult prob lem~

as to both the assessment of potential for future failure

and appropriate measures to protect it from future failure.

Recognizing these difficulties, this particular potential

area of violations does not form part of our basis for

upholding .the Regional Board's Cease and desist order or

for the adoption of a time schedule.f

In addition to the above discussed problems,

evidence presented by the District to the Regional Board

indicated the time necessary for control and prevention of

infiltration/inflow received in the facilities to be 10

years.6 The Ilistrict presented evidence concerning funds

5. We must nonetheless urge both the District and theRegional Board to continue to seek protective measuresfor this outfall, which might include providing protectionfor the highway bank from rainfall saturation to preventslippage.

6~ Regional Board R.T. at pages ~9-50•

~~ 1~

! '~ a

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expended in the recent past and funds budgeted for the near

future to their infiltration/inflow program. This program

includes further identification of infiltration and inflow

problems, television examination of portions of the collection

system, and sealing of loose joints, connections and manhQl es,~

. Certain portions of the Di~tri ct ~'s collection

s~rstem which have not been identified beyond a general in-~

dication of their location, were constructed up to 2~

years ago and may contribute a significant portion of the

infiltration which enters the collection sy~stem.~ The

majority of the District t s facilities, however, were con-

structed sometime during the period from 1972 through ~.9'~~.

With respect to the general infi3tration/inflow problem

identified by the District and the program developed to

address it, no evidence has been received to establish the

following: the event and location of work accomplished

in the recent past to seal the system, the portion of the

system which remains to be surveyed and to have problem

areas sealed, a schedule for accomplishing phases of the

ro ram or for attendin ~~ the worst~ ~ g problem areas first,

or a schedule of work necessary to update or complete any

necessary inf`i~ltration/inflow inventory.

7. This program does~na~ include examination of privatelyowned portions of the collection system, such as individualhouse later~3s..

~• See Mate Boaa^d R. T, especially pages 117, 12,5--12E~,13a--~3~.

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It ~.s clear from the ev~den~e that was presented

that correction of infiltration/inflow is a long-term pro-

ject, involving several years., even though it will not be

necessary ~o ermine and seal the entire system. (See

footnote 6 )~ Until an assessment of the problem is com-

plete and the program identifies by schedule the areas to

be addressed, it will not be possible to determine whether

the infiltration/inflow program is in fact adequate to

prevent discharges contrary to requirements such as have

occurred. in the. past..

Given the above discussed evidence indicating

the substantial likelihood of continued difficulty in

meeting requirements, we cannot conclude that it was im- ~

proper for the Regional Board to find in Order loo. b--7$-23

,that the District was threatening to violate requirements

see page 3 infra}, and to order the District to cease

and desist from discharging wastes contrary to requirements.

As discussed above, there are certain remedial

and preventive measures• ghat can be taken by the District

to relieve the threat of discharge in violation of xequire--

ments, which were discussed and d-escribed during the hearing

of Nay 15, 19'x$, This evidence was not presented to the

Regional Board prior to the adoption of Order No. b-7~-23.

Section 2213 of the State Board regulations,. appearing in.~

Title 23, California Administrative Code, ir~d- Cates general-

ly when it is appropriate to direct compliance with a ~

cease and desist order "forthwith" and when a time schedule

_15_

9is approprzate.f In this case the Regional Board dzd

not have information an which to base a ~Gime schedule,

altho~zgh the violations of requirements were indicated to

have been caused in significant part by problems which

would fake substantial time to cure, During the May l~,

197, hearing some evidence was presented upon which to

establish an appropriate time schedule. Cease and desist

orders requiring compliance ~n~'orthwith" with requirements

should be used sparingly and are most appropriate to ad-

dress what are considered emergency situations or violation

of requirements which can be corrected immediately. State

Board regulations provide that '°.forthwith" means "a~ goon

as is reasonably possible". Section 22t~3{a~, Title 23,

California administrative Cade.) The determination of what

is a reasonable period of ~inie fQr compliance becomes a

question of fact which may finally be determ~.ned judicially,

making an order directing "forthwith compliance difficult

to enforce in the absence of a clear emergency or ability

to correct the problem. Therefore, it is appropriate to

substitute a time schedule far the "forthwith" compliance

date contained in the Regional Board°s order.

9, Section 22.3 , Title 23 , Galif ornia Administrative Code,sates as follows in pertinent part: "{a} A timeschedule should alv~ays be included in a cease and desistorder unless there is a laci~ of information upon which tobase a schedule in which c~ase~~he discharger should be

~~instructed to comply forthwith... "

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In accordance with evidence introduced at the

` hearing of 'May 15 197$ the f ol~owing time schedule i s

proposed for inclusion in Order No! 6-7$-23:

T

TIME SCHEDULE

DateReportCompliance Due

Install interim facilities 12/l/7$ 12/15/7$to prevent violations at the.Las Flores .Ranch disposalarea.

Modification or reinforcement 10/17$ ~ lOf 15/7of manholes which..:are subjectto st reamflow to prevent in-flow and repair. of failed man-hole in Seeley Creek.

Installation of facilities 10/1/7$ io/i~/7$tsuch as concrete blanketing)to protect laterals whichfailed, have been .exposed, orare in imminent danger of failure:due. to streamflow

Installation of facilities to 12/1/7 12/~-5/?$prevent overflow of collection 'system north., and west of LakeGregory.

Develop plan and schedule 3/1/79 3/~-5/79to provide .additional ds-posal capacity.

Update and complete assess— ~./~/79 ~./1s/7~went or inventory of inf l-t rat ion/inf low ~ problems . ~~

Prepare infiltration/inflow 7/1j79 ~ X15/79plan of action indicatingproblem areas and time forcorrec-~ve action.

Items ~ and .7 above( . e the planning items

will necessitate future modification of this time schedule

by the Regional Board. in order to impose dates for the

ultimate installation of facilities determined to be necessary.

Failure of the discharger to comply with the

above schedule should be referred to the At~arney General

for appropriate enforcement action.

B. Will increase in the discharge of waste in-

creas~e the violation ar likelihood of violation

of waste discharge requirements and further

unreasonably impair water quality

The Regional Board found that increases in

the discharge of waste by additional connections to the

community sewer system would result in incareased vio-

lotions o~ an increased likelihood of violations of waste

discharge requirements. Bayed upon this finding, the

Regional Board prohibited additional discharges to the

system by those who had not discharged there~Go before

March 2d, x.97$. Trie District contends that the evidence

before tie Regional Board is not sufficient to support

the connection ban and does not meet the requirements of

pertinent State Board regulations. We agree.

The staff report ,presented. to the Regional Board

an .April 13, lq7$, indicated the difficulty of establishing

whether there would be increased violations of discharge

requiremen~Gs -- either increased in frequency or magni~Gude

-- and increased impairment of water qualify from the

number of addition~.l discharges to the system. ghat the

s ~ ODistrict could expect in the absence of a connection ban.,

The primary cause of violation of requirements in this case

is infiltration/inflow; not overloading of the system as a

result of~an excessive number of connections to the treat-

ment or conveyance facilities. Without more evidence ofI

the impact of additional discharges to the system on vio--

lations of waste discharge requirements we can not justify

the connection ban. In this case,. unless there was evidence

to correlate the effect of~a given number of additional

discharges to a specific section of the system on the likeli-

hood of increased violations of requirements since certain

limited areas of the District's collection and conveyance

system appear to be the source of con~Ginuing problems) a

connection ban would not be appropriate. ~We can find no

evidence of this nature in the record° To be appropriate,

a connection ban must be 'supported by more than speculation

and conjecture about the possible effect of additional dis-

charges. ~ ~We find it necessary, therefore, to rescind the

prohibition against additional discharges contained in

order No. 6--7$-23 ~`

10. The District indicated both before the Regional Boardand before the State Board that somewhat fewer than 300additional discharges to the community sewer sys`~em annuallycould be expected based upon the historical rate of issuanceof building permits in the area and the d recti-on from theCounty to septic tank users to hook up to the sewer system.(State Board R.T, at pages 1~1~~,~~ $6-$~, 117, 121, 127-12$,~-37-13; Regional Board R.T. at pages 6$ and 92. )

1l. Our rescission of the connection ban for lack of evidencemakes it unnecessary to address the District's contentionthat the requirements of Section 221~~.:3 , Title 23 , California

• Administrative Cede, for removal of a connection ban havebeen met.

~ C. The District contends that the R ion 1 r 'eg a Boa d s

adoption of Order No. 6-7$--23 violated the intent

of the Porter-Cologne Act and applicable portions

of the California Administrative Gode.

In addition to the above-discussed contentions,

the District ° s petition states generally that Order No,

~-7~-23 is unreasonable and violates the Porter-Cologne

Act Water Code Division '~~ Section ~300o and following

and Section ~2~.~ through 2215 of the California Administra-

'Give Code in that it fails to relate reasc~nabl~ water quality

improvement and economic considerations to the propriety of

enforcement action concerning violations of requirements.

Its position appears to be that compliance with the directive

to cease and desist "forthwith" from violation of r~quire-

mentsp if that order stands, canna be accomplished without

-germination or severe lim t~.tian of other important aspects

of 'the District's overall water quality control ~program.~

Essentially Petitioner claims that unless order Na. b -7$-23

is rescinded "Limited resources of petitioner must be directed

toward attempted compliance with an order which cannot

reasonably be complied with rathex than a constructive plan,"

It is true that the Porter-Cologne Act will permit

some reasonable change in water quality. {See Water Code

Sections 13000 and 130x1. } Also, Water Code Section 132~.~

specifically provides for the inclusion of economic con-

siderations in the establishment of water quality objectives

in water quality control plans.

~.2. See Crestline Sanitation District Petition datedMai ~., 197$: Page 2.

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• .It zs also true, however, that once waste discharge

requirements are adopted in order t o implement an applicable

water quality control plan, the Regional Board may take any

enforcement action' within its statutory authority whi ch in

its discretion it finds necessary and appropriate. Appro—

priate enforcement action may include the construction of

emergency ~or interim facilities, as described in Section

22~.5~~; time schedules for construction and installation of

necessary facilities to meet requirements; and connection

bans where appropriate to prevent increased impairment of

water quality until consistent compliance with requirements

can be achievedo The history of the District's efforts to

improve water quality control facilities and their operation

in the Crestline area is not in question. However, when

waste discharge ~v~~i.olations occur, corrective measures may be

required in addition to or in lieu of the discharger's

planned programs. A general water qualify control effort in

the past will not serge to justify or to license improper

discharges of raw sewage or treated effluent at the expense

of the public health and water quality. _The discharger has

the responsibility of determining which of its programs will

receive funding, how much, and when. Likewise, the discharger

must accept the. consequences of those decisions.

13. Section 2215 states, in pertinent part: "~a) Each dis—charger should be expected to construct emergency facilitiesar modify existing plant operations to achieve rapid compliance.... {c) Extra cost of such facilities is not a reasonableexcuse for failure to construct them.... "

.~✓ . '.

~s

As discussed above, we consider the Regional Board ° s

adcaptian of a cease and d~si ~t oarder pursuant to Water Code

Section 13341 a reasonable and appropriate response to via-

latzons of waste discharge requirements in this case, except

as modified by this order. For all the reasons set forth

above, we do not consider Lahontan Regional Board Order No.

~~-7~-23, as modified hereinafter by this order, to violate

' the intent ~of the Porter-Cologne Act or applicable State

Boar~~ regulations contained in the California Adxnin~.stra~ive

Cade.

III . CONCLUSIONS

After review of the record, and far the reasons

heretofore expressed, we have reached the fallowing con-

clusions;

1. The Regional Board's issuance of~an enforcement

order pursuant t o Wat ~r Cade Section 13 3 01 was an appropriat e

mechanism for achieving compliance with waste discharge re-

quirements by the Crestline Sanitation District, in that

based upon the evidence presented tr e Regional Board pro-

perly found .that violations of requirements had occurred and

that vio3ations of requirements were continuing or threatened

to continue.

. 2, Given the nature of the violations of waste dis-

charge requirements by the Grestline 5anita~ian I?i~trict and

the measures necessary to prevent their recurrence, the adoption

of a time schedule is the appropriate means off' obtaining

compliance with waste discharge requirements and the cease

and desist ~arder.

'M! .. ~. A. 'M►

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3. ..The evidence in the record before the

Regional Board is not sufficient to support the inclusion

in Order No. 6-7$-23 of a prohibition against additional

discharges to the Crestline Community sewed system.

IV. ORDER

IT ~S HF~REBY ORDERED THAT:

1. The Crestline Sanitation District Petition

for Review of -Order No., 6--7$-23 of the :California Regional

Water Quality Control Board, Lahontan Region, is denied

in part and granted in part.

2. Section 1 on page 3 of the Order No. b-7$-23

of the California .Regional Water Quality Control Board,

Lahontan .Region, is amended as follo~nrs:

The Crestline Sanitation District cease anddesist from discharging wastes contrary to requirementsand discharge prohibitions listed in Findings Nos. 2 and !~above and Section 13376 of the Water Code in accordance:with the. time schedule set .forth on page lb of State BoardOrder No. WQ 7$- 12.

3. Sections 2 a.nd 3 on page 3 of~Order No. b-7$-23

of the California Regional WatEr Quality Control Board,

Lahontan Region, are rescinded.

w~ 1V .y y y~..

y

rt~- ~23~

1~. Order Noo 6 7~ 23 as amended by this order

is remanded to the Califarni a Regional Water Quality Control

Board, Lahontan Region, for administration consistent with

the terms ~ of this order.

Dated : ~ U ' 1~

~ Concur:

d'~~sa~4t

on u n BrysonVi c e-Chairman i rmar~

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